Privacy Policy

Effective: 15 October 2024

We at The Mintable, Inc., including in Australia its subsidiary The Mintable Pty Ltd ABN 87 653 712 719 (we, us or our), respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you.

ReviewGenie

This Privacy Policy sets out how we protect the privacy of personal information provided to us when you use ReviewGenie (Tool). You can review The Mintable Privacy Policy which applies to the use of our website and platform where we give you the tools to accelerate your management career here.

A note about accuracy: Tools like ReviewGenie use Large Language Models to generate AI feedback summaries, scripts, and drafts. While these models are advanced, they have limitations and may occasionally generate inaccurate or incorrect content. We encourage you to use your own judgment when making decisions based on the AI-generated content. If you notice that ReviewGenie output contains inaccurate information, you may submit a support request by emailing support@themintable.co.

1. Personal information we collect

We collect personal information relating to you (“Personal Information”) as follows:

Personal information you provide: We collect Personal Information when you use ReviewGenie as follows:

• User Content: When you use our Tool, we collect Personal Information that is included in the input, file uploads, or feedback that you provide to our Tool (“Content”).
• Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (“Communication Information”).
• Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
• Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys or provide us with information to establish your identity (collectively, “Other Information You Provide”

Personal information we receive automatically from your use of the Tool: When you visit, use, or interact with the Tool, we receive the following information about your visit, use, or interactions (“Technical Information”):

• Log Data: Information that your browser or device automatically sends when you use our Tool. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Tool.
• Usage Data: We may automatically collect information about your use of the Tool, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
• Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
• Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Tool and enhance your experience when you use the Tool.

2. How we use personal information

We may use Personal Information for the following purposes:

• To provide, administer, maintain and/or analyze the Tool;
• To improve our Tool and conduct research;
• To communicate with you; including to send you information about our Tool and events;
• To develop new programs and services;
• To prevent fraud, criminal activity, or misuses of our Tool, and to protect the security of our IT systems, architecture, and networks;
• To carry out business transfers; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Aggregated or de-identified information. We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our Tool, to improve and add features to our Tool, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Tool and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Tool, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to reidentify the information, unless required by law.

3. Disclosure of personal information

In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, email communication software, web analytics services, and other information technology providers, among others. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us.
• Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: We may share your Personal Information, including information about your interaction with our Tool, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability.
• Affiliates: We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with The Mintable. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
• Other Users and Third Parties You Share Information With: Certain features allow you to share information with other users or third parties. For example, you may email a draft performance review to an email address. Be sure you trust any user or third party with whom you share information.

4. Your rights

Depending on location, individuals may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:

• Access your Personal Information and information relating to how it is processed.
• Delete your Personal Information from our records.
• Rectify or update your Personal Information.
• Transfer your Personal Information to a third party (right to data portability).
• Restrict how we process your Personal Information.
• Withdraw your consent—where we rely on consent as the legal basis for processing at any time.
• Object to how we process your Personal Information.
• Lodge a complaint with your local data protection authority.

Please submit your request by emailing support@themintable.co.

5. Additional U.S. state disclosures

The following provides additional information about the categories of Personal Information we collect and how we disclose that information. You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal Information in “How we use personal information” above, and how we retain Personal Information in “Security and Retention” below.

Identifiers, such as your name, contact details, IP address, and other device identifiers

Disclosure of Personal Information: We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; to corporate administrators of enterprise or team accounts; and to other users and third parties you choose to share it with.

Commercial Information, such as your transaction history

Disclosure of Personal Information: We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to corporate administrators of enterprise or team accounts.

Network Activity Information, such as Content and how you interact with our Tool

Disclosure of Personal Information: We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to other users and third parties you choose to share it with.

Geolocation Data

Disclosure of Personal Information: We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; and to parties involved in Transactions.

Your account login credentials and payment card information (Sensitive Personal Information)

Disclosure of Personal Information: We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions.

To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their Personal Information:

• The right to know information about our processing of your Personal Information, including the specific pieces of Personal Information that we have collected from you;
• The right to request deletion of your Personal Information;
• The right to correct your Personal Information; and
• The right to be free from discrimination relating to the exercise of any of your privacy rights.

We don’t “sell” Personal Information or “share” Personal Information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also don’t process sensitive Personal Information for the purposes of inferring characteristics about a consumer.

Exercising your rights. To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request to support@themintable.co.

Verification. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.

Authorized agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us. Authorized agent requests can be submitted to support@themintable.co.

Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please send your request to support@themintable.co.

6. Children

Our Tool is not directed to children under the age of 13. We do not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Tool, please email us at support@themintable.co. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you are 13 or older, but under 18, you must have permission from your parent or guardian to use our Tool.

7. Links to other websites

The Tool may contain links to other websites not operated or controlled by The Mintable, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

8. Security and retention

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

We’ll retain your Personal Information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

9. California Site Ownership Disclosure

Under California Civil Code Section 1789.3, California residents are entitled to the following specific consumer rights information: the provider of this website is The Mintable, Inc., 13980 W. 78th Avenue, Arvada, CO, 80005 United States. To file a complaint regarding this website or to receive further information regarding use of this website, send a letter to the above address or contact us via e-mail at hello@getmintable.com. You may also contact the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento CA 95834 or by telephone at 1-800-952-5210.

10. California “Do Not Track” Disclosure

“Do Not Track” is a web browser privacy preference that causes the browser to broadcast a signal to websites requesting that the user’s activity not be tracked. Currently, our websites do not respond to “Do Not Track” signals.

11. International users

By using our Service, you understand and acknowledge that your Personal Information will be processed and stored in our facilities and servers in Australia and may be disclosed to our service providers and affiliates in other jurisdictions.

Legal basis for processing. Our legal bases for processing your Personal Information include:

• • We need it to provide you the Tool;
  • It satisfies The Mintable's legitimate interests (which are not overridden by your data protection interests), such as for improving, marketing, and promoting the Tool and protecting our legal rights;
  • We need to process your data to comply with our legal obligations.

Transfer of EU Users’ Personal Information outside the EU. We will transfer your Personal Data to recipients outside of the EEA, Switzerland and the UK for the purposes described in this Privacy Policy. If you are based in the EEA, Switzerland or the UK and your Personal Data is transferred to a third country, that third country may not offer the same level of data protection as your home country. However_,_ we transfer Personal Data pursuant to applicable data protection laws. To transfer your Personal Data outside of the EEA, Switzerland or the UK, we rely on the European Commission’s adequacy decisions on certain countries and, for other jurisdictions, we rely on the Standard Contractual Clauses as approved by the European Commission and any applicable country addenda. For more information on or to obtain a copy of the appropriate safeguards we have in place, please contact us at support@themintable.co.

By using our Tool, you understand and acknowledge that your Personal Data will be processed and stored in our facilities and servers in Australia and may be disclosed to our service providers and affiliates in other jurisdictions.

EU Users’ Rights to Control Personal Information. You have control over your Personal Information. Below are the rights you have and the steps you can take to exercise them. Please note that your rights may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your employer are permitted by law or have compelling legitimate interests to keep, and it may take time for us to investigate your request. If you believe that we are not respecting your rights with regard to your Personal Information, you may lodge a complaint with your local supervisory authority.

Right to Access. You have a right to request a copy of the Personal Information that The Mintable holds. To request this information, please email us at support@themintable.co.

‍Data protection officer. You can contact our data protection officer at  in matters related to Personal Information processing.

12. Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

The Mintable, Inc., including in Australia its subsidiary The Mintable Pty Ltd ABN 87 653 712 719

Email: support@themintable.co

‍

Appendix: Mode and place of processing the Data

Methods of processing

The Mintable takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to The Mintable, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of The Mintable (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by The Mintable. The updated list of these parties may be requested from The Mintable at any time.

Legal basis of processing

The Mintable may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations The Mintable may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any precontractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which The Mintable is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in The Mintable;
• processing is necessary for the purposes of the legitimate interests pursued by The Mintable or by a third party.

In any case, The Mintable will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at The Mintable's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries and about the security measures taken by The Mintable to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with The Mintable using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of the Tool shall be retained for as long as is reasonably required to maintain and provide service of the tool.
• Personal Data collected for the purposes of The Mintable's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by The Mintable within the relevant sections of this document or by contacting The Mintable.

The Mintable may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, The Mintable may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the Users is collected to allow The Mintable to provide its Tool, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Infrastructure monitoring, Tag Management, Hosting and backend infrastructure, Managing contacts and sending messages, User database management, Handling payments and Managing support and contact requests.

For specific information about the Personal Data used for each purpose, the User may refer to the section "Detailed information on the processing of Personal Data".

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following third-party service providers (each, a “sub-processor”):

Analytics

The services contained in this section enable The Mintable to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC ("Google"). Google utilizes the Data collected to track and examine the use of ReviewGenie, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable The Mintable to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of ReviewGenie.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored:

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy supported by Data Protection Addendum including Standard Contractual Clauses (reference: https://d1.awsstatic.com/legal/aws-gdpr/AWS_GDPR_DPA.pdf)

Speech recognition, text generation, and language understanding services

We use OpenAI to provide performance attributes based on the information you provide about your direct report's title and level of seniority. OpenAI also synthesizes the data you input to generate a draft performance review.

To provide these services, OpenAI processes and stores the content you create and any data necessary for the functioning of the AI models. By using our Services and submitting requests, you agree to have your information processed by OpenAI’s API. OpenAI’s API is developed and maintained by OpenAI Inc., and any information you provide when using our Services may be transferred and processed by OpenAI for the purpose of providing their services to us. Note: OpenAI does not use data transmitted by API to train its models.

Personal Data processed: various types of Data, specifically data input by the user, as specified in the privacy policy of the service.

Place of processing: United States

OpenAI’s privacy policy: https://openai.com/policies/api-data-usage-policies

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Customer.io

Customer.io is is a customer engagement platform for web and mobile apps.

Personal Data processed: name, email address.

Place of processing: United States – Privacy Policy supported by Data Protection Addendum including Standard Contractual Clauses (reference: https://customer.io/legal/dpa)

MailChimp (The Rocket Science Group LLC)

Mailchimp is an online marketing platform operated by The Rocket Science Group LLC.

Personal Data processed: name, email address.

Place of processing: United States – Privacy Policy supported by Data Protection Addendum including Standard Contractual Clauses (reference: https://mailchimp.com/legal/data-processing-addendum/)

Typeform (Typeform SL)

Typeform is a service that allows to create online forms and collect information online provided by Typeform SL

Personal Data processed: any type of personal data collected through typeforms.

Place of processing: Spain - Privacy Policy

Google Workspace (Google LLC)

Google Workspace is a suite of office tools that we use for communication with users and storage of some of their information.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Google Workspace data processing agreement: https://workspace.google.com/terms/09242021/dpa_terms/

Managing support and contact requests

This type of service allows The Mintable to manage support and contact requests received via email or by other means, such as the contact form.

The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

Hubspot (Hubspot, Inc)

Hubspot is a customer relationship manager and communication service provided by Hubspot, Inc.

Personal Data processed: various types of Data, specifically data input by the user, as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy supported by Data Protection Addendum including Standard Contractual Clauses (reference: https://legal.hubspot.com/dpa)

Tag Management

This type of service helps The Mintable to manage the tags or scripts needed on The Mintable in a centralized fashion.

This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy supported by Data Protection Addendum including Standard Contractual Clauses (SCCs) (reference: https://privacy.google.com/businesses/compliance/)