Version 2.0.6, Updated at 2019-01-22
To the extent that Mentimeter processes Personal Data in the course of providing the Services, it will do so only as a Processor acting on behalf of a Presenter or a Customer (as Controller) and in accordance with the requirements of the Agreement.
Presenter or Customer, as Controller, shall be responsible for ensuring that:
Mentimeter recognize that the User own and have full right to its own data, Mentimeter hereby receives a right to process that data for the purpose to enable Mentimeter to deliver the Services to the User.
Mentimeter will process the Personal Data only for the purpose of providing the Services in a reliable and safe way and in accordance with Controller's lawful instructions.
The Presenter has, at any time, right to obtain from Mentimeter confirmation as to whether or not Presenter Personal Data concerning the Presenter is being processed, where and for what purpose. Mentimeter will comply with such a request at latest within 30 days. Requests regarding User Personal Data, which the Presenter is responsible for, should be directed to the Presenter and the Presenter is obliged to grant access to such User Personal Data.
The Presenter shall have the right to request that Mentimeter erases Presenter Personal Data concerning the Presenter without undue delay. Mentimeter will comply with such request at latest within 30 days. If the Presenter exercises the right to be forgotten - the Service can no longer be provided the Presenter. Mentimeter may be mandated by law to keep some Personal Data even if the Presenter has requested to be forgotten. User shall have the right to request that the Presenter erases User Personal Data. The Presenter shall comply with such request within 30 days.
Mentimeter does not process any special categories of Personal Data defined under article 9 of GDPR.
The Mentimeter platform is built to be easy accessible and beautiful, a simple way to create interactivity and engagement in meetings, webinars, workshop, presentations and other real-time gatherings of people. The openness and easy accessible process is a very valuable and important aspect of the the Mentimeter value proposition to our Users. Presenters and/or Users can share URLs, ID or other information to make the presentations non-secure. Mentimeter cannot take responsibility for security that is breached by the fundamental openness of the platform or by some of our Users sharing information they shouldn't have. Mentimeter will have in place and maintain throughout the term of this agreement appropriate technical and organizational measures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing (a "Security Incident"). In the event of a Security Incident, Mentimeter will notify User and provide reasonable assistance in order to remedy or mitigate the effects of the Security Incident.
Top management shall set direction for and show commitment to information security. The information security policy shall be reviewed at planned intervals or if significant changes occur to ensure its continuing suitability, adequacy and effectiveness. See Security Revision Schedule. Mentimeter maintains separation/segregation of duties to prevent error and fraud by ensuring that at least two individuals are responsible for separate parts of any task, so that no single role or account, can access, modify or use User Data without authorization or detection.
Mentimeter has a process that ensures that all personnel with access to systems or information that can have access to User Data have signed a Non-Disclosure Agreement (NDA) as part of their contract with Mentimeter. Mentimeter has a staff onboarding process that includes verifying the identity of staff and the background and skill they state. Mentimeter has a rigorous staff termination process that includes revoking access rights, seizing IT equipment, invalidating company access card as well as notification of continuous confidentiality obligations. Any staff with access to User Data shall be required to take appropriate security training on a regular basis. See Security Revision Schedule To gain access to the internal resources from remote locations, users must have the required authorization. Remote access for an employee, external user or partner can be requested only by members of the leadership team.
In consideration of being entrusted rights to use Mentimeter's systems, repositories and information all employees must acknowledge the following: 1. That disclosure of information that would cause harm to Mentimeter irrespective of the form in, or the media on, which the information is displayed or contained, is considered confidential information. 2. That employees will not, directly or indirectly, make use of information other than in the course of work duties; 3. That employees will keep passwords, PIN codes, etc. entrusted to the employee, strictly confidential; 4. That employees use at least 2 factor authentication for systems with user data. We also require password protected SSH keys. 5. Mentimeter implements host based (i.e. per work station) security by contractually requiring strong (at least AES128) encryption and firewalls on all work stations. This is verified at start of employment and at least twice per manually. 6. Firewall enabled on all workstations 7. That employees will log off the computer or activate the screensaver configured with password immediately upon completion of each work session; 8. That the employee understand that his/her rights to use Mentimeter systems, repositories and information expire upon the termination of their work duty, or at any time upon the request by Mentimeter. If the employee is not otherwise instructed, Mentimeter requests that the employee shall immediately return all intellectual properties that the employee hold when his/hers rights have expired. 9. A clear desk policy to protect customer information
Mentimeter Password Control Policy defines the requirements for the proper and secure handling of passwords in the Organization. All employees who handle assets and services related to Mentimeter uses password management via a certified password management system and strong passwords are required.
Losses, theft, damages, tampering or other incident related to IT-assets that compromises security must be reported as soon as possible to the VP-Engineering.
Mentimeter shall implement new updates and versions of the Application, to the extent deemed suitable by Mentimeter. Mentimeter has world class engineering practices to ensure everything we do has a security perspective. This list is an example of things we do to uphold information security.
Mentimeter shall always have the right to disconnect the Application for service and upgrading without giving prior notice to the User. Mentimeter intends to give notice on beforehand to the User before updates or maintenance of the Application.
Mentimeter has an incident management process to detect and handle breaches of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data.
All privacy or security related incidents shall be reported to the VP Engineering (email@example.com) as soon as they are detected. This applies to Mentimeter employees and all sub-processors that handle personal data. All incidents are documented and evaluated internally and an action plan for each individual incident is made, including mitigatory actions. If the incident is grave and the risk of damage to personal rights and freedoms of natural persons are high, Mentimeter shall as soon as possible (but no later than 72 hours):
Mentimeter reserves the right to decide what level of notification is needed for what severity of breach of data.
If the incident is grave Mentimeter will also continuously inform the Controller how we work to ensure Personal Data is kept safe.
Mentimeter have entered into Data Processing Agreements that meet the GDPR requirements for all our subcontracts. Users authorize Mentimeter to subcontract processing of Personal Data under the Agreement to a third party provided that: (i) Mentimeter provides Presenter and Customer with reasonable prior notice of any such subcontracting; and (ii) Mentimeter flows down Purpose Limitation and Security to any subcontractor it appoints. Third Party Sub-Processors shall be restricted to only the necessary access, use, retention and disclosure of customer Information needed to fulfill contractual obligations.
In accordance with GDPR a transfer of personal data to a third country may take place where the Commission has decided that the third country in question ensures an adequate level of protection. Such a transfer shall not require any specific authorisation. The European Commission has so far (as of May 2018) recognised Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the United States of America (If part of EU-US Privacy Shield Framework) as providing adequate protection. Mentimeter hereby reserves the right, and in compliance with GDPR, to use sub-suppliers in countries approved by The European Commission at the current date. Mentimeter use subcontractors to deliver the best Application possible to our Users, we don’t sell Personal Data to sub-processors.
|Name||Address / Country||Purpose||Data Processing Agreement in place||Approved through EU-US Privacy Shield|
|Salesforce.com Inc (Heroku)||The Landmark @ 1 Market St. Suite 300 San Francisco, CA 94105, USA||Data hosting||Yes||Yes|
|PayPal (Europe) S.à.r.l. (Braintree)||et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg||Payment||Yes||n/a|
|Mixpanel Inc||405 Howard Street, 2nd Floor, San Francisco, CA 94105, USA||Data Analytics||Yes||Yes|
|New Relic Inc||188 Spear St., Suite 1200 San Francisco, CA USA 94105, USA||Incident / issue tracking||Yes||Yes|
|Rollbar Inc||51 Federal St, San Francisco, CA 94107, USA||Incident / issue tracking||Yes||Yes|
|Rapid7 Ireland Limited (Logentries.com)||Sobo Works, Windmill Lane, Dublin 2, Ireland||Incident / issue tracking||Yes||n/a|
|Dropbox Inc 333||Brannan Street San Francisco, CA 94107, USA||Internal file storage||Yes||Yes|
|Slack Technologies||Limited 4th Floor, One Park Place Hatch Street Upper Dublin 2, Ireland||Internal communication||Yes||n/a|
|Facebook, Inc||1601 Willow Rd. Menlo Park, CA 94025, USA||Advertising||Yes||Yes|
|Intercom, Inc||55 2nd Street, 4th Fl., San Francisco, CA 94105, USA||User communication (chat and email)||Yes||Yes|
|Peaberry Software Inc.||(customer.io) 921 SW Washington St, Suite #820, Portland, OR 97205, USA||User communication (email)||Yes||Yes|
|Google Inc||1600 Amphitheatre Parkway, Mountain View, CA 94043, USA||User & internal communication (email) and advertising||Yes||Yes|
|Amazon.com Inc (Amazon Web Services)||410 Terry Avenue North. Seattle, WA 98109-5210. USA||Data hosting||Yes||Yes|
|The Rocket Science Group, LLC (Mailchimp)||1526 DeKalb Ave NE, Atlanta, GA 30307, USA||User communication (email)||Yes||Yes|
|LIVESTORM SAS (Livestorm.co)||24 rue Rodier 75009 Paris, France||User communication (webinar and email)||Yes||n/a|
|Wootric Inc||3616 18th Street Apartment 1 San Francisco, CA 94110, USA||User communication (NPS & survey)||Yes||Yes|
|APIHub, Inc (Clearbit)||90 Sheridan St, San Francisco, CA 94103, USA||Data Analytics||Yes||Yes|
|Pipedrive OÜ||Paldiski mnt 80 Tallinn 10617, Estonia||User communication and sales admin||Yes||n/a|
|Lunaweb Ltd (Cloudconvert)||Mühlfeldweg 8, 85738 Garching b. München, Germany||Content hosting and uploading||Yes||n/a|
|Trello Inc||55 Broadway, 25th Floor, New York NY 10006, USA||Internal communication (task management)||Yes||Yes|
|Linkedin Corporation||2029 Stierlin Ct. Ste. 200 Mountain View, CA 94043, USA||Recruitment, Advertising||Yes||Yes|
|Jobylon AB||Hälsingegatan 49, 113 31 Stockholm, Sweden||Recruitment||Yes||n/a|
|Mixmax, Inc||512 2nd Street, First Floor, San Francisco, CA 94107, USA||User Communication (email)||Yes||Yes|
|TYPEFORM S.L||B65831836 Bac de Roda, 163 Barcelona 08018, Spain||User Communication (survey & email)||Yes||n/a|
|Zapier, Inc||548 Market St #62411, San Francisco, California 94104, USA||Internal Communication||Yes||Yes|
|Scrive AB||Barnhusgatan 20 2TR, 111 23 Stockholm, Sweden||Contract Management||Yes||n/a|
|Wave Financial Inc||235 Carlaw Ave., Suite 501, Toronto, ON M4M 2S1, Canada||Invoicing||Yes||n/a|
|Igil Webs SRL (FirstPromoter)||Str. Talmacelului, nr. 30, Talmaciu, Sibiu, Romania||Advertising||Yes||n/a|
|PE Accounting Sweden AB||Torsgatan 2, 111 23 Stockholm, Sweden||Accounting||Yes||n/a|
Mentimeter reserves the right to add subcontractors if they comply with the rules and regulations of this Data Processing Agreement and Privacy statement
Physical access to Mentimeter's office premises shall be restricted to staff individually and on a need to have basis. Physical access to where Services are performed shall log physical access related events such as date, time, swipe/proximity card-id, door-id, access denied or access granted.
Mentimeter is working with the best in class service providers for data storage. The service providers' physical infrastructure is hosted and managed within Heroku's and Amazon's secure data centers and utilize the Amazon Web Service (AWS) technology. Amazon continually manages risk and undergoes recurring assessments to ensure compliance with industry standards. Amazon's data center operations have been accredited under:
Keeping User Data secure is extremely important and Mentimeter spend a lot of effort and time to ensure all data sent to Mentimeter is handled securely. We will, in this section and the section regarding Security Revision Schedule, describe what Mentimeter do to accomplish this. Top management is responsible for setting direction for and show commitment to data integrity and user privacy. Mentimeter have experienced engineers designing and building our systems according to best practices to ensure highest data security in all parts of the application. We only use well-recognized and highly secure 3rd party systems with proper security certifications and practices. Our employees are required to use 2 factor authentications for all systems where data is stored, together with individual accounts to ensure that we can follow who did what and when. When an employment is ended, we immediately revoke all accesses that such employee had. Security measures are taken to protect User and User Data both for "Data at rest" and "Data in transit ". (Read more below). Mentimeter respects intellectual property rights and will remove any content that infringes copyright, trademark, patent or other intellectual property rights of third parties upon notification from a Presenter, Customer or third party.
We avoid storing any Personal Data that is not needed to supply our users with a great experience and gain value from Mentimeter. We have deemed the following to be the minimum amount of Personal Data we need from a User:
Mentimeter stores this Personal Data the minimum time we can and at the same time deliver a safe, reliable and valuable Application. We have deemed the following timeframes appropriate until we delete Personal Data needed:
Mentimeter's staff do not access or interact with User Data or applications as part of normal operations. There may be cases where Mentimeter is requested to interact with User Data at the request of the Presenter or Customer for support purposes or where required by law. User Data is access controlled and all access by Mentimeter's staff is accompanied by customer approval, government mandate or top management approval. Reason for access, actions taken by staff, and support start and end time is recorded for each access.
Mentimeter uses Encryption of all data "at-rest".
Mentimeter stores User Personal Data, Presenter Personal Data and User Data on AWS (an Amazon service https://aws.amazon.com/compliance/) servers. The geographical location of our AWS hosting is "US east, N. Virginia".
Mentimeter have legally binding Data Processing Agreement with Amazon and Amazon is certified under the EU-U.S.
Privacy shield framework. This setup gives Mentimeter “adequacy of the protection of personal data in non-EU countries” under the GDPR-regulation as stated by the European Commission: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
Mentimeter utilizes ISO 27001, SOC2 and FISMA certified data centers managed by Amazon. Credit card information is stored with a Level 1 PCI compliant third party vendor, see 9.7. Payment Details for more information.
Mentimeter uses standard SSL, ie. Encryption of data "in-transit, and are rated A+ by 3rd party vendor, SSL Labs. Privacy and the protection of User Data are of highest importance to Mentimeter and we both have technical and operational support in place to ensure this. We are using standard SSL, ie. encryption of data "in-transit". We also leverage all protection through https://www.heroku.com/policy/security.
Data is backed up continuously and we have an automatic failover system if the main system would fail.
We encrypt (hashed and salted) passwords using the Bcrypt algorithm to protect them from being harmful in the case of a breach. Mentimeter can never see User passwords and Users can only self-reset them by email.
Mentimeter use PCI compliant payment processor Braintree for encrypting and processing credit card payments. Mentimeter employees do not see or handle credit card information.
Mentimeter may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as "Likes", profile information gathered from social networking sites or the fact that you viewed or interacted with our content. Mentimeter allows partner vendors to use and store limited amount of Personal Data that is needed for Mentimeter to provide support, marketing, business intelligence and monitoring. Mentimeter ensures that Personal Data is not excessively stored, printed, copied, disclosed or other means processed outside the purpose for use. We never sell User Personal Data, behavior data nor any other user generated data to any third party. We do however share Presenters email addresses with organisations connected to the User, but only in order to enable us to develop an even better Application. Credit card information is handled with a Level 1 PCI compliant third party vendor. (See 9.7. Payment Details for more information).
Voting on Mentimeter's voting site menti.com is anonymous and we believe this is an important part of the voting experience. For preventing abuse we do, however, store the Audience's IP address for a short period of time (it is erased within 14 days).
This section shows how often Mentimeter conducts security revisions and conduct different types of test. If significant changes occur Mentimeter will initiate an otherwise planned activity to ensure continuing security.
|Security training for personnel||Yearly and at beginning of employment|
|Revoke system, hardware and document access||At end of employment|
|Ensures access levels for all systems and employees are correct.||2 times a year|
|Audit of Access management process and catalogue||2 times a year|
|Firewall settings verification for workstations and Network||2 times a year|
|Ensure all critical system libraries are up-to-date||Continuously|
|Unit and integration tests to ensure system functionality and security||Continuously|
|External penetration tests to ensure system security||Continuously|