How we handle your data
Last updated: 2026-05-11
Quick summary (5 points)
- For the public site and our business records, Moji Mediji d.o.o. is the controller. For employee data inside tenants, the customer is typically the controller and we act as processor.
- Application servers and the database run in Frankfurt, EU. AI features may involve transfer outside the EU and can be disabled at the company level.
- We do not sell data, we do not run marketing trackers, and analytics cookies are only loaded after your explicit consent.
- Exercise your GDPR rights at legal@getmentor.eu — we respond within a reasonable time, no later than 30 days.
- You can lodge a complaint with the Slovenian Information Commissioner (ip-rs.si).
1. Controller and contact
Controller: Moji Mediji d.o.o., Dunajska 165, 1000 Ljubljana, Slovenia, EU.
Privacy contact: legal@getmentor.eu
Security incidents: security@getmentor.eu
The service Mentor (available at getmentor.eu and app.getmentor.eu) is a multi-tenant learning platform for corporate employee training. You may interact with it as a public-site visitor, as a tenant admin, or as an employee inside a customer tenant.
2. Categories of personal data we process
- Account data: first and last name, email address, role (admin / employee), hashed password, last sign-in timestamp.
- Company / tenant data: name, address, tax number, subscription plan and status, Stripe customer ID.
- Learning data: modules, section progress, quiz results, certificates, XP rewards, live event attendance, activity log.
- Technical data: IP address, device / browser info, security and audit logs, session ID, presence heartbeat.
- Billing data: Stripe is the independent controller for card data. Mentor stores only the Stripe customer ID and invoice history (amounts, dates, status). We never see card numbers.
- Communications: contents of emails, in-app notifications, comments and chat messages where those features are enabled.
- AI input data: only when an AI feature is used. See AI processing.
3. Purposes of processing
- Operating the service (authentication, access to content, progress tracking).
- Creating and tracking training (modules, quizzes, certificates, gamification).
- Security and abuse prevention (rate limiting, audit log, bot detection).
- Subscription billing (Stripe), invoicing.
- Customer support and service communications.
- Legal obligations (accounting, tax, GDPR notifications).
- Product improvements — strictly in aggregated or anonymized form.
4. Lawful bases (GDPR Art. 6)
- Performance of a contract (Art. 6(1)(b)) — using and billing the service.
- Legitimate interest (Art. 6(1)(f)) — security, audit log, abuse prevention, aggregated product improvements.
- Legal obligation (Art. 6(1)(c)) — accounting, tax, invoice retention.
- Consent (Art. 6(1)(a)) — non-essential cookies, marketing communications, opt-in email digests.
- Processing on the controller's behalf (Art. 28) — for tenant employee data we act as processor on the customer's instructions.
5. Roles: controller vs. processor
Mentor operates in two distinct roles depending on context:
- Moji Mediji d.o.o. is controller for public-site visitors, signup forms, billing data, our own business records, and platform security logs.
- Moji Mediji d.o.o. is processor for the personal data of employees inside customer tenants, which the customer uploads into its workspace. The customer is the controller of that data and determines purposes of processing. This relationship is governed by a DPA.
6. Data location
- Application servers: Frankfurt, EU.
- Primary database: Frankfurt, EU.
- File storage: EU region.
- Cache / rate limit / presence: EU region.
- AI providers: processing may take place outside the EU. AI features can be disabled at the tenant level — see AI processing.
For transfers outside the EU we rely on the European Commission's Standard Contractual Clauses (SCC) where required by the vendor.
7. Sub-processors
Mentor uses a limited set of sub-processors required to operate the service, grouped into the following categories:
- Hosting, database, and storage (EU): application infrastructure, database, file storage, and cache — all in the EU region.
- Payments and billing: EU-based card-payment partner; we never store card numbers ourselves.
- Transactional email: provider for system and contractual messages.
- Bot protection and video infrastructure: global CDN for performance and bot detection.
- Authentication (SSO): Google and Microsoft (only where the tenant explicitly enables SSO).
- Public-site analytics: only with user consent.
- Error monitoring: EU region.
- AI providers (optional): for text generation, image generation, and transcription. Processing may take place outside the EU; can be disabled at the tenant level.
A detailed, current list of sub-processors with vendor names, locations, and contractual transfer mechanisms is available to paying customers and business contacts on request via legal@getmentor.eu. We notify paying customers of material changes by email at least 30 days in advance.
8. AI data processing
AI features (AI module builder, AI quiz suggestion, cover image generation, video transcription) are optional. The tenant administrator can disable them in settings. Without AI the platform works normally.
- When an AI feature is used, the data required for the task is sent to the external AI provider (see the sub-processors table).
- Before sending, we minimize and anonymize data where possible: we strip emails, phone numbers, Slovenian personal IDs, tax numbers, IBANs, URL tokens, and internal IDs.
- AI never receives passwords, billing data, or internal system secrets.
- AI results are not automatically authoritative — the user must verify content before publishing / training.
For full detail see the separate AI data processing page.
9. Your rights (GDPR Art. 15–22)
- Right of access to your data.
- Right to rectification of inaccurate data.
- Right to erasure (the "right to be forgotten").
- Right to restriction of processing.
- Right to object to processing based on legitimate interest.
- Right to data portability in a machine-readable format.
- Right to withdraw consent where processing is consent-based.
- Right to lodge a complaint with a supervisory authority — in Slovenia, the Information Commissioner, ip-rs.si.
10. Retention
- Account and tenant data: for the duration of the subscription. After termination, data is deleted or anonymized within 90 days unless retention is required by law.
- Billing data (invoices, payments): 10 years, per Slovenian tax law (ZDavP-2).
- Security / audit logs: 12 months to support investigations, then anonymized or deleted.
- Demo / trial tenants without payment: 14 days after trial expiry, then archived; hard delete within 90 days.
- Email logs (Resend): ~30 days in the Resend dashboard.
11. Export and deletion
The admin can export their tenant's data at any time (CSV / JSON exports of users, progress, certificates). For a personal export or deletion request, email legal@getmentor.eu. We verify identity before acting.
After subscription termination we export data on customer request within 30 days and then delete it, except where retention is required by law (e.g. invoices).
12. Security measures
Technical and organizational measures include TLS 1.3, AES-256 at rest, bcrypt for passwords, multi-tenant isolation, RBAC, audit log, rate limiting, CSP / HSTS / SameSite cookies, Sentry error monitoring, regular backups (Neon PITR), and webhook signature verification (Stripe, RealtimeKit) with Redis idempotency.
More detail on the Security page.
13. Children
Mentor is a B2B service not directed at children. Accounts for individuals under 16 are not created without explicit authorization from the organizational customer and in accordance with local law.
14. Changes to this policy
We may update this policy. We notify paying customers of material changes by email at least 30 days in advance. The last-updated date is shown at the top of the page.