Privacy Policy

Welcome to manara.tech, a site operated by Manara, co. (“Manara,” “us,” and “we”). Manara provides online classes, platforms, programs, products, tools, systems, services and other offerings through which users can learn, teach, develop, communicate, mentor and connect to employers (collectively, the “Service”). 

This Policy describes how Manara (hereinafter also “us,” “we”) collects, uses, discloses and otherwise processes the Personally Identifiable Information (PII) you provide by using the Manara website, located at https://manara.tech or the services, rendered through the Site, or any other services provided at any subdomain of *.manara.training (the “Site”), and integration with third party software including but not limited to Slack, Canvas, Airtable (collectively the “Service”).

If you have any questions about these terms please contact us.

PLEASE READ OUR PRIVACY POLICY CAREFULLY TO GET A CLEAR UNDERSTANDING OF HOW WE COLLECT, USE, PROTECT OR OTHERWISE HANDLE YOUR PERSONALLY IDENTIFIABLE INFORMATION IN ACCORDANCE WITH OUR WEBSITE.

BY CLICKING ON THE “I ACCEPT” BUTTON, COMPLETING THE REGISTRATION PROCESS, OR ACCESSING OR USING ANY OF THE SERVICES, YOU CONFIRM THAT

        (1) YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS AGREEMENT,

        (2) YOU ARE OF LEGAL AGE TO FORM A BINDING CONTRACT WITH MANARA, AND

        (3) YOU HAVE THE AUTHORITY TO ENTER INTO THE AGREEMENT PERSONALLY OR ON BEHALF OF THE COMPANY YOU HAVE NAMED AS THE USER, AND TO BIND THAT COMPANY TO THE AGREEMENT.

THE TERM “YOU” OR “USER” REFERS TO THE INDIVIDUAL OR LEGAL ENTITY, AS APPLICABLE, IDENTIFIED AS THE USER WHEN YOU REGISTERED FOR THE SERVICES.

IF YOU DO NOT AGREE TO BE BOUND BY THIS AGREEMENT, YOU MAY NOT ACCESS OR USE THIS WEBSITE OR THE SERVICES.

When you use the Service, you become a user of the Services and consent to our collection, use, and disclosure of information about you as described in this Privacy Policy.

This privacy policy (“Privacy Policy") is incorporated by reference into the Terms of Use of Manara, located at https://manara.tech/terms and your consent to the provisions of such Terms includes your consent to the provisions of this Policy, provided however that from time to time we may ask for your separate consent hereto.

Our Site and the Services are not intended for nor directed toward users under the age of 18, and we do not knowingly collect personal information from users under 18 years. If you believe that your child under the age of 18 may have provided us with Personal Information without your consent, you may alert us at privacy@manara.tech. If we learn that we have inadvertently collected any Personal Information from users under 18, we will promptly take steps to delete such information and terminate the user's account.

1. PURPOSES OF PROCESSING

As used in this Policy, “Personally Identifiable Information” (PII) is as described in US privacy law and information security, which includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, email address. We need certain personal data in order to provide you with access to our Service. To process your personal data as outlined below, we rely on the following legal bases:

Contractual Performance: The primary reason we process your personal data is to perform the contract that you have with us by having your Manara Account or using the Site as registered user. For example, as you use our Service, we use your personal data to provide your Account, to allow to make it visible to other users and to make employment opportunities available to you.

Legitimate Interests: We may also use your personal data where we have legitimate interests to do so. For instance, we review users’ actions while using our Service to improve our Service and we process personal data for administrative, fraud detection and other legal purposes such as payments processing, and income share agreements.

Consent: We may also ask for your consent to use your personal data for specific reasons. You may withdraw your consent at any time by contacting us as set out at the end of this Policy.

2. INFORMATION WE COLLECT AND HOW WE USE IT

In using the Service, you are required to provide personal data to verify that you are the specific person you say you are. This personal data can include first and last name, email or phone number. In order to create your Manara Account (hereinafter – “Account”) as described in our Terms, you provide us with certain personal data, such as your name and email. After Account created and you receive access thereto, you are entitled to input and amend any information, including your personal data into your Account. In both cases you warrant that you

(a) provide us with true, relevant and actual information, AND

(b) have never committed any crime involving fraud, and you are not under any police control as an intellectual property fraudster.

We do not intend to gather any personal data which may be considered or “sensitive” in certain jurisdictions, for example religious and political views (“Sensitive Personal Data”). 

We may collect and store information about you in connection with your use of the Service, including any information you transmit to or through the Service:

1.        a)  Make a purchase
2.        b)  Sign up for our newsletter
3.        c)  Respond to a survey or marketing communication
4.        d)  Surf the website or use certain other site features
5.        e)  Provide the Service
6.        f)   Fulfill your requests and improve the Service's quality
7.        g)  Engage in research and analysis relating to the Service
8.        h)  Personalize your experience
9.        i)   Track usage of the Service
10.        j)   Market the Service
11.        k)  Share with Manara hiring partners
12.        l)   Share with Manara community
13.       m)  Provide customer support
14.       n)   Message you
15.       o)   Back up our systems
16.       p)   Enhance the security of the Service
17.       q)   Help combat fraud and abuse
18.       r)    Estimate and report total audience size and traffic
19.       s)   Comply with legal obligations

Please also note:

1. 1. Information collected automatically: When you use our Site, our servers automatically record your log data which is the information that your browser sends whenever you visit a website as well as your personal data. This data may include but is not limited to:

This personal data allows us to diagnose bugs as well as detect fraud. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information. This personal data also allows us to send notifications.

2. 2. Account Information: In order to create your Manara Account and after that – during the whole period it exists, we may store and use the information you provide during that process, such as your name and other information you may provide with your Account, such as your name, email, pictures, etc. We may publicly display such information as part of your Account profile. You are entitled to create an Account of your own only and you are strictly forbidden to use any personal data of any other persons while creating your Account. If you believe that someone has created an unauthorized account depicting you or your experience, please, contact us at privacy@manara.tech immediately.
3. 3. Public Content: No public content, which is not belonging to us, is intended for posting on the Site or through the Service. 
4. 4. Contacts: You can invite others to join Manara (but not to create their Manara Account anyway) by providing us with their contact information. Please note, that we may address such invited person with written notice using his / her contact data you provided to us and we will indicate that it was you who invited him/her to join Manara and in the same time you bear sole responsibility for the lawfulness of our access to such third person personal data you provided.
5. 5. Communications: When you sign up for a Service Account or use certain features, you are opting to receive messages from other Site users and us. You cannot opt out of receiving certain administrative, transactional, or legal messages from us. Please note that in case you opt out you may miss some important notification from us and hence you relieve us from any liability related to such notification delivery or non-delivery. We may also track your actions in response to the messages you receive from us or through the Service, such as whether you deleted, opened, or forwarded such messages. If you exchange messages with others through the Service, we may store them in order to process and deliver them and administrate the Services and render our mediation services, as well allow you to manage such messages, and we may review and disclose them in connection with investigations related to use of the Service, as well as our efforts to improve the Service.
6. 6. No spam: We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests for some services, which can not be provided or requested through the Site.
7. 7. Mobile: If you send or receive messages through the Service using cell (mobile) phone), we may log phone numbers, phone carriers, and the date and time that the messages were processed. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person.
8. 8. Business: If you are a representative of a business entity, we may contact you, including by phone or email, using the contact information you provide us, which is made publicly available, or that we have on record for your business. Our calls with you may be monitored and recorded for quality purposes and with no additional notification.
9. 9. Activity: When you use the Service, we may collect personal data as you take actions within the Service, such as what profile, course, interviews, test results that are created within your Account and your progress. Any interview results you receive within such activity. This may include but is not limited to passing, liking, commenting, messaging, blocks and other reports, your search activity, the screens you view, the date and time of your visit. Collecting this information allows us to provide the Service and helps us improve our Service by refining our recommendation algorithm, diagnosing bugs or issues, developing new features, and monitoring for behavior that violates our Terms of Use. This information is also used for financial reporting.
10. 10. Background information: even after Service user shares his or her personal data with Service we do not conduct criminal background or identity verification checks on such user, his / her activities or otherwise inquire into the background of its users, unless it is strictly stated in this Privacy Policy. That means we do not warrant any non-criminal background of any Service user, including a user you are communicating with through or due to the Service use.

3. COOKIES

We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers (including Google’s Advertising ID) and similar technology (jointly “Cookies”) in connection with your use of the Service, third party websites, and mobile applications. Cookies may have unique identifiers and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session. We use Cookies once you are entering the Site even in case you use it without your account registration 

The purposes for which we use Cookies in the Service include:

You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Site. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. Please note that changing any of these settings does not prevent the display of certain advertisements to you.

5. HOW WE SHARE YOUR INFORMATION

We may share your personal data with other Service users, with service providers and partners who help us operate the Service, in the event of a business transaction and for law enforcement purposes. Third parties may receive information about you as follows:

1. 1. Service Providers: we may share your personal data with third parties to provide you with the Service (such as analytics services or customer relationship management services). We vet all service providers before we provide them with your personal data and ensure we have appropriate contractual safeguards in place.

2. Partners: If you sign-up to participate in our program, we may share your Personal Information with our third-party partners including mentors, other participants and hiring partners for purposes of highlighting your profile for a particular role at the hiring partner.  These partners will use your Personal Information for purposes of providing the service and determining your eligibility or suitability for available roles. The use of information by such hiring partners will be governed by their privacy policies.

4. 4. Business Transfers: We may share information from or about you with our parent companies, subsidiaries, joint ventures, affiliates, or other companies under common control, in which case we will require them to honor this Privacy Policy. If Manara is involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, dissolution, bankruptcy or other change of control or ownership, we may transfer personal data in relation to that transaction with respect to that information as described in this Privacy Policy.

5. 5. Investigations and Legal Disclosures: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure:  

(a) is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process or law enforcement requests served on us;

(b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service; or

(c) protects our rights, reputation, property, or that of our users, affiliates, or the public.

6. Complaints: If you report or otherwise complain to us about content through the Site or about any Service result, we may share the substance of your complaint with the contributor of that content to provide an opportunity for the contributor to respond.

We may disclose personal information about Site users, or information regarding your use of the Services or websites accessible through the Site or Service use, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, General Data Protection Regulation, the California Consumer Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating this Policy or Terms of Use, or other user policies; to operate the Services properly; or to protect our company and our shareholders, directors, partners and Site users.

We drive your attention to the fact that sharing your information in no case means selling, renting, releasing, disclosing, transferring or other communicating orally, in writing, by email or other means to any third party for monetary gain. 

6. CONTROLLING YOUR PERSONAL DATA AND YOUR RIGHTS

Below, we have outlined some of the tools you have to control your personal data.

1. 2. Other software permissions: other applications or software development tools (jointly “other software”), integrated into the Services or used alongside with the Service use, may have additional technical features or require additional settings of personal data use, such as screenshots and screencasts making prohibition from other devices using Software. Please note that some of other software may display its shields or watermarks on your personal data (such as photos) and from time to time their own privacy policy and terms of use and that is why we highly recommend you to familiarize with those documents in order to understand whether you want to use such other software of the Service with such other software integrated and whether processing of your personal data by such other software is acceptable for you.
2. 3. Privacy Rights
3.  

You should also be aware of your privacy rights.

1. 1. Opt-out: You may contact us anytime as set out at the end of this Policy to opt-out of:

1.                    1. direct marketing communications.
   1.                    2. any new processing of your personal data that we may carry out beyond the original purpose; or
   2.                    3. the transfer of your personal data outside the USA. Please note that your use of the Services may be ineffective upon opt-out or you may miss some important information  or notification upon opt-out. And also any our obligation on sending you notification under this Privacy Policy or Terms of Use of the Service shall be considered duly fulfilled immediately after the moment it must be sent – irrespective to the fact it can not be sent due to your opting-out.
      

2. 2. Reviewing your information: Applicable privacy laws may give you the right to review the personal data we maintain about you. To request access to your personal data, please contact us as set out at the end of this Policy.
3. 3. Updating your information: If you think the information we hold about you is inaccurate or that we are not entitled to use it and would like to request that we rectify, delete or object to our processing of this personal data, please contact us as set out at the end of this Policy. You retain the whole responsibility for the accurateness and actuality of the information we hold about you.
4. 4. Moving your information: Your data is portable – i.e. you have the flexibility to move your data to other service providers as you wish. To request this, please contact us as set out at the end of this Policy.
5. 5. Accountability: Some countries, including those in the European Union, provide you with a right to file a complaint with the appropriate data protection authority if you have an issue with how we process your personal data.

For your protection, we may ask you to prove your identity before we answer any requests related to the above items. Note, that we may request additional information from you to verify your identity and even reject a request for certain reasons, including if it is unlawful or if fulfilling the request will infringe a trade secret or other intellectual property or the privacy of another user.

7. THIRD-PARTY PAYMENT PROCESSOR

We use a third-party payment processor to process payments made to us and to you. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as, inter alia, credit card numbers. Rather, all such information is provided by you directly to our third party processor, Stripe. You can read more about their policies at: https://stripe.com/privacy.

We draw your attention to the fact, that if you initiate a transaction through the Service, such as a purchase, payment processor may collect and store information about you, such as your name, phone number, address, email, and payment information (such as a credit card number and expiration date), as well as any other information as the case may be, in order to process your transaction, send communications about them to you, and even populate forms for future transactions. This information may be shared with third parties for the payment operating and processing purposes. 

In any case, we hereby encourage you to keep your payment information in strict confidence and not to share it with any persons (including other Service members, your children and relatives) except for with payment processors for the purpose of making purchase you independently have decided to make at your own discretion and will – so that any purchase you make through the Service is considered as made by you personally and willingly.

8. DATA RETENTION AND ACCOUNT DELETION

If You decide to delete your Account on the Site You can ask us to delete it by notifying us at the contact information set out below. Irrespective to the way your Account is deleted,

(a) some of your information provided or posted by you in the course of your relationship with Manara can not be deleted if the information is used for business purpose

b) in case you don’t ask us to delete your personal information, we may retain information about you for the purposes authorized under this Privacy Policy, for the whole period your  Account exists in the Service, unless prohibited by law. 

For example, we may retain information to manage a placement with a hiring partner or if we have executed an income share agreement, to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations. Please remember that even though our systems are designed to comply with the above retention periods.

9. CROSS-BORDER DATA TRANSFERS

The sharing of personal data as explained in this Policy may involve the transfer of personal data across borders, for instance from the United States to other jurisdictions, where data protection and privacy regulations may not offer the same level of protection. As an opposite example, where the Service allows users to be located in the European Economic Area (“EEA”), their personal data is transferred to countries outside of the EEA. Your personal data we process is stored in the United States (“USA”) – in no case it means that it will be shared, as described herein, only within the territory of the USA.

10. SECURITY

We use various safeguards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via a mobile device, or method of electronic storage can be guaranteed as secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We may suspend your use of all or part of the Service without notice if we suspect or detect any breach of security. If you believe that your Account or personal data is no longer secure, please notify us immediately at the contact information set out below.

11. SERVICE AREA BEYOND OUR CONTROL

Other users: The Service includes user-generated profiles and interactive messaging services. Please remember that any information that is disclosed in these areas may be seen and copied by other users and you should exercise caution when deciding to disclose your personal data. You remain the only one liable for any of your activities or posting any messages that may harm or abuse any third party in any manner; and from others.

Due to the specific nature of the Site, other Service users may post some content which can be abusing or inacceptable for you – we do not bear any liability for such content posting, but you may contact us with appropriate complaint at complaints@manara.tech for which we shall send you a proper answer with no warranty of your complaint settlement or solution. 

Third-party websites: The Site, the Service (or any Contract created inside of it) may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

12. MODIFICATIONS TO THIS PRIVACY POLICY

We reserve the right, at any time, to add to, change, update, or modify this Policy. The most current version of the Privacy Policy will govern our collection, use, and disclosure of information about you and will be located here. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on the Site prior to the effective date of the changes. By continuing to access or use the Service after those changes become effective, you acknowledge the revised Privacy Policy.

13. HOW TO CONTACT US

You may contact us concerning our Privacy Policy, please write to us at the following address: privacy@manara.tech with the subject title “Privacy Policy”, and our data protection officer will answer you within a reasonably short time.