MentorOn1 Privacy Policy

Effective Date: 7 September 2026
Last Updated: 7 September 2026
Primary Operating Area: Bankura District, West Bengal, India
Privacy and Support Contact: MentorOn1 X Hombell Support — support@hombell.com

Plain-language summary: MentorOn1 is a tutor–student discovery, matching, coordination, and record-keeping platform. We collect the information needed to create accounts, operate Tutor profiles, perform compatibility matching, handle inquiries and appointments, maintain engagement records, protect the Platform, communicate with users, and improve the service. We do not currently collect payments, Aadhaar, PAN, bank/UPI credentials, precise GPS location, or recordings of tutoring sessions or physical appointments. Public Student and Parent profiles do not exist. Public Tutor profiles may be indexed by search engines.

MentorOn1 is designed for use by Students, including some users under 18. Children require special protection. A Student under 10 may not operate an independent Student Account. A Student aged 10–17 may use a Student Account only with Parent/Guardian permission and subject to applicable law. Where law requires verifiable parental consent, MentorOn1 may require additional Parent/Guardian identity or age verification and may restrict the child’s account until that verification is completed.

This Policy intentionally distinguishes between what MentorOn1 does today and future features MentorOn1 may introduce. A future feature is not active merely because this Policy explains how it may work.

Table of Contents

1. Who We Are
2. MentorOn1 and Hombell
3. Scope of This Policy
4. Regulatory Context and Phased Compliance
5. Key Privacy Definitions
6. Our Role as Data Fiduciary
7. Privacy Principles
8. What We Do Not Currently Collect
9. Visitor Data
10. Account and Registration Data
11. Date of Birth and Age Data
12. Student Data
13. Parent and Guardian Data
14. Parent–Ward Relationships
15. Tutor Data
16. Tutor Verification and Identity Documents
17. Contact Information
18. Residential and Location Information
19. Academic and Educational Information
20. Optional Gender Information
21. Tutor Profile Photos and Media
22. Compatibility Questionnaire Data
23. Match Outputs, Scores, and Inferences
24. Automated Matching and Decision-Making
25. Match History
26. Inquiry and Free-Text Data
27. Appointment Data
28. No Recording of Physical or Tutoring Sessions
29. Communications Between Tutors and Students
30. Orders, Invoices, and Engagement Records
31. Reviews and Ratings
32. Testimonials, Results, and Success Stories
33. Internal Administrative Notes
34. Authentication and Security Data
35. OTP Data
36. Cookies and Similar Technologies
37. Analytics and Operational Telemetry
38. Error and Application Logging
39. Public Tutor Profiles and Search-Engine Indexing
40. No Public Student or Parent Profiles
41. Unauthenticated Browsing
42. Contact and Inquiry Forms Without an Account
43. Newsletter Sign-Up Without an Account
44. How We Use Personal Data
45. Purpose and Processing Matrix
46. Consent and Other Lawful Processing Grounds
47. Consent Withdrawal
48. Marketing Consent
49. AI-Training Consent
50. Children’s Privacy — Overview
51. Children Under 10
52. Students Aged 10–17
53. Current Parental Permission Flow
54. Verifiable Parental Consent
55. Parent Access to a Linked Ward
56. Parent–Ward Disputes
57. Minor Tutors
58. Children and Advertising
59. Children and AI
60. Tutor Data Shared With Students/Parents
61. Student/Parent Data Shared With Tutors
62. Sharing With Service Providers
63. Current Major Service Providers
64. Hombell-Related Operational Support
65. Sharing With Schools and Other Organisations
66. Sharing for Safety, Fraud Prevention, and Legal Compliance
67. Government and Law-Enforcement Requests
68. Professional Advisers
69. Business Transfers and Reorganisation
70. International and Cross-Border Processing
71. Artificial Intelligence Privacy
72. Google AI Processing
73. AI Prompts and Personal Context
74. AI Conversation Storage
75. AI Training and Model Improvement
76. Matching-System Improvement
77. Research and Statistical Use
78. Third-Party Academic Research
79. Advertising — Current State
80. Future Adult Behavioural Advertising
81. Advertising Data We May Use in the Future
82. No Child Advertising Profiles
83. Third-Party Advertising Cookies
84. Future Cookie Preference Centre
85. Social Login — Future Feature
86. CAPTCHA and Anti-Bot Services — Future Feature
87. Payments — Current State
88. Future Payment Processing
89. Data Retention Principles
90. Detailed Retention Schedule
91. Dormant Accounts
92. Account Deletion
93. Backup Copies
94. Legal Holds and Required Retention
95. Anonymous and Aggregated Data
96. Security Safeguards
97. Password Security
98. Access Controls
99. Security Logs and Monitoring
100. Personal Data Breaches
101. Your Privacy Rights
102. Access Requests
103. Correction Requests
104. Erasure and Account Deletion Requests
105. Data Export
106. Grievances and Questions
107. Rights Exercised by a Parent/Guardian
108. Withdrawal of Parental Consent
109. Identity Verification for Privacy Requests
110. Limitations on Access to Security/Internal Records
111. Public Content After Account Deletion
112. Search-Engine Caches
113. Marketing and Unsubscribe Rights
114. Data Minimisation
115. Accuracy of Personal Data
116. Data Submitted About Other People
117. Sensitive Information in Free-Text Fields
118. Data of Persons With a Lawful Guardian
119. Changes to Service Providers
120. Changes to This Privacy Policy
121. Material Changes and Fresh Consent
122. Language and Accessibility
123. Short Child/Parent Privacy Notice
124. Closure of MentorOn1
125. Contact Information
126. Annex A — Data Collection Matrix
127. Annex B — Data Sharing Matrix
128. Annex C — Retention Matrix
129. Annex D — Children’s Privacy Matrix
130. Annex E — AI Privacy Matrix
131. Annex F — Cookies and Future Advertising Matrix
132. Annex G — Rights Request Guide
133. Annex H — Current-vs-Future Feature Register

1. Who We Are

MentorOn1 is a tutor–student discovery, matching, coordination, and record-keeping platform operating primarily in Bankura District, West Bengal, India.

For purposes of this Privacy Policy, MentorOn1 is currently operated by Siddhartha Gorai, Bankura, West Bengal, India.

Where applicable privacy law uses the term Data Fiduciary, Siddhartha Gorai operating MentorOn1 is the person who currently determines the purposes and means of MentorOn1’s processing of personal data.

References to “MentorOn1,” “we,” “us,” or “our” refer to the MentorOn1 service and, where legally relevant, its current operator.

A full postal address may be published where required by applicable law or where reasonably needed for a particular legal notice. Unless such publication is required, MentorOn1 publicly identifies its operating location as Bankura, West Bengal, India.

2. MentorOn1 and Hombell

MentorOn1 is presented to users in association with Hombell as part of a broader service-oriented ecosystem.

MentorOn1 may be accessible through Hombell’s website or interfaces and may use Hombell-domain support infrastructure. Emails may therefore display the sender name “MentorOn1 X Hombell Support.”

The current privacy/support email is:

support@hombell.com

Use of the Hombell domain or shared support branding does not mean that MentorOn1 personal data is automatically sold to, transferred to, or made freely available to an unrelated third party.

Where shared operational resources are used, personal data is processed only for purposes described in this Policy and subject to appropriate access controls.

Unless MentorOn1 later publishes a different legal structure, the current Data Fiduciary/operator for MentorOn1 remains the operator identified in Section 1.

3. Scope of This Policy

This Policy applies to personal data processed through MentorOn1, including data connected with:

• public Tutor browsing;
• Account registration;
• email verification;
• password authentication;
• OTPs;
• Student Accounts;
• Parent Accounts;
• Ward relationships;
• Tutor Accounts;
• Tutor onboarding;
• Tutor verification;
• Tutor profiles;
• Tutor photos;
• public Tutor pages;
• search and filters;
• compatibility questionnaires;
• Match scores;
• Match history;
• inquiries;
• free-text contact forms;
• appointments;
• dashboards;
• engagement records;
• Orders and Invoices;
• Reviews;
• ratings;
• testimonials;
• newsletters;
• support;
• security monitoring;
• AI-assisted features;
• and other MentorOn1 services.

This Policy also explains certain future processing MentorOn1 may introduce, including adult behavioural advertising, social login, CAPTCHA/anti-bot services, payment processors, expanded analytics, and optional consent-based AI training. Those sections are labelled as future or planned where applicable.

4. Regulatory Context and Phased Compliance

MentorOn1 is based in India and is designed with Indian privacy and technology law in mind.

The principal modern Indian privacy framework includes the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, together with their commencement notifications and any amendments, exemptions, directions, or successor requirements.

Those requirements have a phased commencement. Accordingly:

1. this Policy distinguishes between requirements already applicable and requirements that become applicable later;
2. MentorOn1 may implement controls before their mandatory commencement;
3. MentorOn1 does not claim that a future-required control already exists where it does not;
4. where a future legal requirement becomes applicable, the Platform may restrict, modify, or reconfigure features to comply; and
5. if this Policy conflicts with a mandatory requirement of applicable law, the mandatory requirement prevails.

For example, current minor-account flows may rely on a Parent/Guardian permission self-check. Where applicable law requires verifiable parental consent, MentorOn1 will require a stronger verification process and will not rely solely on the self-check.

5. Key Privacy Definitions

For this Policy:

“Account” means a registered MentorOn1 user account.

“Child” or “Minor” means a person under 18 where the applicable Indian privacy framework uses that threshold.

“Data Fiduciary” means the person who determines the purpose and means of processing personal data, where that legal concept applies.

“Data Principal” means the individual to whom personal data relates and, where applicable law provides, includes a Parent or lawful Guardian acting for a child.

“Personal data” means digital information about an identifiable individual or information that relates to an identifiable individual, as recognised under applicable law.

“Processing” includes collection, recording, organisation, storage, use, sharing, retrieval, analysis, deletion, anonymisation, or other operations performed on personal data.

“Parent” includes a lawful Guardian where context permits.

“Ward” means a Student linked to a Parent/Guardian relationship on MentorOn1.

“Tutor” means a person listed or seeking to be listed as a provider of tutoring services.

“Match Data” includes compatibility-questionnaire answers, eligibility information, Match scores, Match explanations, and Match history.

6. Our Role as Data Fiduciary

MentorOn1 determines why and how core Platform personal data is processed.

Examples include deciding which Account fields are required, which Tutor information is public, which data is used to calculate compatibility, how long Match history is kept, when a Tutor profile may be published, what security records are retained, and which service providers are used to operate the Platform.

Some third-party providers may independently determine aspects of their own processing under their terms and applicable law. Where that occurs, their privacy notices may also apply.

MentorOn1 does not become responsible for every independent act of a Tutor, Student, Parent, school, payment provider, or external website merely because MentorOn1 facilitated an introduction or link.

7. Privacy Principles

MentorOn1 aims to follow these principles:

1. Purpose limitation — use personal data for clear Platform, safety, legal, or user-requested purposes.
2. Data minimisation — avoid collecting data that is not reasonably necessary.
3. Accuracy — allow appropriate correction and verification.
4. Security — use proportionate technical and organisational safeguards.
5. Transparency — distinguish current functionality from future possibilities.
6. Child protection — apply enhanced safeguards to users under 18.
7. Controlled sharing — share only what is reasonably required for the relevant function.
8. Retention discipline — avoid keeping identifiable information forever without a reason.
9. Consent separation — keep optional marketing and AI-training consent separate from ordinary Platform acceptance.
10. No false guarantees — do not promise impossible absolute security, instant deletion from every backup, or processor behaviour MentorOn1 cannot verify.

8. What We Do Not Currently Collect

As of the Effective Date, MentorOn1 does not intentionally collect the following as part of its standard service:

• Aadhaar numbers or Aadhaar copies;
• PAN;
• bank-account credentials;
• UPI credentials;
• debit-card or credit-card details;
• precise device GPS coordinates;
• recordings of physical appointments;
• recordings of tutoring sessions;
• in-platform Tutor–Student chat history, because the Platform does not currently provide that chat system;
• public Student profiles;
• public Parent profiles;
• behavioural advertising data from children;
• child advertising profiles; or
• cross-device advertising profiles.

If a future feature requires a category not currently collected, MentorOn1 will update the relevant notice or obtain additional consent where legally required.

Users should not submit Aadhaar, PAN, banking credentials, medical information, passwords, OTPs, or other unnecessary sensitive information in free-text fields unless MentorOn1 specifically requests it for a legitimate purpose.

9. Visitor Data

A visitor may browse public Tutor information without creating an Account.

For ordinary unauthenticated browsing, MentorOn1 does not intentionally collect profile information about the visitor beyond what is reasonably necessary to:

• serve the website;
• maintain essential sessions or preferences where applicable;
• prevent abuse;
• secure the Platform;
• diagnose errors;
• and operate hosting/network infrastructure.

Hosting and infrastructure providers may automatically process technical data such as IP address, requested URL, timestamp, browser information, device information, network information, or error metadata as part of ordinary web delivery and security.

MentorOn1 does not currently install a dedicated behavioural analytics product for ordinary visitors.

10. Account and Registration Data

When a user creates an Account, MentorOn1 may collect:

• name;
• email address;
• password-derived authentication data;
• full date of birth;
• role;
• verification status;
• signup timestamp;
• consent records;
• Account status;
• and role-specific information.

The exact fields depend on whether the user is a Student, Parent, Tutor, or a user with another permitted role combination.

MentorOn1 may also maintain Account IDs, status flags, policy-version acceptance records, security metadata, and administrative audit information.

11. Date of Birth and Age Data

MentorOn1 collects a full date of birth where required by the Account flow.

Date of birth is used to:

• determine whether the user is a child;
• apply age-specific eligibility rules;
• enforce the under-10 restriction;
• determine when Parent/Guardian permission is necessary;
• apply child-safety protections;
• distinguish Adult advertising eligibility if advertising is introduced;
• and support compliance with applicable law.

Date of birth is not intended to be publicly displayed merely because it is collected.

A user must not provide a false date of birth to bypass a child-protection control.

12. Student Data

Student personal data may include:

• name;
• email;
• date of birth;
• Account status;
• grade/class;
• board;
• school or institution, where optionally provided;
• location or PIN code;
• Match questionnaire answers;
• Match results;
• Inquiry information;
• Appointment information;
• linked Parent/Ward information;
• Order/Invoice information;
• Reviews;
• support requests;
• and security/account logs.

MentorOn1 does not currently require Student marks, examination scores, medical details, disability information, caste, religion, family income, or mental-health information as part of the standard compatibility questionnaire.

A Student may voluntarily disclose additional information in a free-text Inquiry. Users are encouraged to provide only what is reasonably necessary.

13. Parent and Guardian Data

Parent/Guardian data may include:

• name;
• email;
• date of birth where collected through the Account system;
• Account role;
• Ward relationships;
• contact information;
• Inquiry information;
• Appointment information;
• Match information accessed for a Ward;
• Orders/Invoices;
• Reviews;
• support communications;
• and security records.

A Parent/Guardian must have legitimate authority to act for the relevant Ward.

MentorOn1 may request evidence of Parent/Guardian authority where a Ward relationship is disputed, a child-safety issue arises, a privacy request is made for a child, verifiable parental consent is legally required, or another legitimate reason makes verification necessary.

14. Parent–Ward Relationships

A Parent–Ward link is not mandatory for every Student aged 10–17 under the current product design.

Where a legitimate Parent–Ward link exists, the Parent may have broad visibility into the Ward’s MentorOn1 data, including where supported:

• Account/profile information;
• Match questionnaire information;
• Match scores and history;
• Inquiries;
• Appointments;
• Tutor selections;
• Orders;
• Invoices;
• and related dashboard information.

A Student cannot currently unilaterally remove a linked Parent through the ordinary Student interface.

MentorOn1 Administrators may create, manage, correct, restrict, or remove Parent–Ward relationships where authorised and reasonably necessary.

If a Student disputes a Parent link, the Student should contact MentorOn1 X Hombell Support.

15. Tutor Data

Tutor data may be more extensive because Tutor profiles are part of a public discovery service.

Tutor data may include:

• name;
• email;
• telephone number;
• date of birth;
• residential or postal address;
• PIN code;
• public location/service areas;
• profile photo;
• biography;
• headline;
• subjects;
• grades/classes taught;
• teaching modes;
• languages;
• qualifications;
• education;
• professional credentials;
• experience;
• categories;
• fee information;
• availability;
• questionnaire answers;
• verification status;
• verification metadata;
• ratings;
• Reviews;
• engagement history;
• Inquiry/Appointment relationships;
• Order/Invoice records;
• support communications;
• moderation history;
• and security/account logs.

Not all Tutor data is public.

16. Tutor Verification and Identity Documents

Depending on the case, Tutor verification may involve:

• government-issued identity documents other than Aadhaar where appropriate;
• academic certificates;
• marksheets or educational credentials;
• professional credentials;
• other supporting documents;
• manual review;
• and verification metadata.

MentorOn1 does not currently collect Aadhaar or PAN as part of standard Tutor verification.

Verification documents:

• are not intended for public display;
• are restricted to authorised personnel and necessary service providers;
• may be retained while the Tutor remains active;
• may be removed when no longer reasonably necessary;
• and may be retained longer where a dispute, fraud concern, legal hold, safety issue, or legal obligation requires.

After the underlying document is deleted, MentorOn1 may retain verification metadata such as document category, date checked, status, verification result, review history, and non-sensitive audit information.

Verification status is not a guarantee of safety, competence, identity, or future conduct.

17. Contact Information

MentorOn1 may process email addresses, telephone numbers, support contact information, and contact details users voluntarily provide in free-text fields.

A telephone number is currently required for Tutors.

Students and Parents may provide contact information where a workflow reasonably requires it, such as an Inquiry, Appointment, support request, or direct Tutor coordination.

Private contact information is not automatically public.

18. Residential and Location Information

MentorOn1 may collect an exact residential or postal address where the Account or Tutor workflow requests it.

MentorOn1 also uses location information such as PIN code, locality, town, district, teaching/service area, or other location descriptions.

Current matching primarily uses PIN code/location information, not precise device GPS coordinates.

MentorOn1 does not currently request real-time GPS location from the user’s device.

An exact residential address is treated as private unless the user intentionally identifies it as a public teaching location, a specific feature clearly requires publication, or disclosure is otherwise authorised or legally required.

19. Academic and Educational Information

Student academic data may include class/grade, board, school or educational institution where optionally provided, subject needs, educational preferences, and Match-related requirements.

The standard Platform does not currently require marks/results as part of the Match questionnaire.

Tutor academic/professional data may include degrees, certificates, educational history, professional credentials, experience, subjects, and supporting verification records.

Public Tutor academic claims may be displayed where approved.

20. Optional Gender Information

Gender may be collected on an optional basis.

Where collected, MentorOn1 may use it for Account/profile context, user preferences, matching where the user has lawfully expressed a relevant preference, safety or support, or other clearly described Platform purposes.

MentorOn1 will not intentionally use optional gender information to make unlawful discriminatory decisions.

21. Tutor Profile Photos and Media

Tutor photos may be uploaded to MentorOn1.

A Tutor photo may be displayed publicly on the Tutor profile, shown in search results, shown in Match recommendations, processed by Cloudinary or another approved media provider, resized/optimised/cached for technical display, and used in MentorOn1 promotional materials where permitted by the Terms and applicable law.

Students and Parents do not currently upload public profile photos as part of the ordinary Account model.

A Tutor should not upload a photo they do not have permission to use.

22. Compatibility Questionnaire Data

MentorOn1 operates a structured compatibility questionnaire.

Questionnaire data may include preferences and circumstances relating to teaching style, communication preferences, scheduling preferences, format preferences, subject-related needs, pace, structure, interaction style, practical tutoring preferences, and other non-sensitive compatibility dimensions.

The current standard questionnaire does not intentionally ask about medical conditions, mental-health diagnoses, disability, religion, caste, sexual life, political affiliation, family income, or other similarly sensitive categories.

If MentorOn1 later introduces a question that materially changes the sensitivity of Match Data, the notice and consent design will be reviewed.

23. Match Outputs, Scores, and Inferences

MentorOn1 may derive compatibility scores, ranking positions, strongest-alignment dimensions, explanation labels, eligibility results, and limited preference inferences needed to operate or explain the Match.

MentorOn1 does not treat these outputs as psychological diagnoses, medical conclusions, permanent personality profiles, educational guarantees, or legally significant determinations.

A Tutor generally receives the Match result or compatibility output necessary to understand the potential engagement, not unrestricted access to the Student’s individual questionnaire answers.

Student/Parent questionnaire answers are visible to the Student, a legitimately linked Parent where supported, authorised MentorOn1 Administrators, and systems/service providers that need the data to perform the Match.

Tutor questionnaire answers are not ordinarily exposed individually to Students; Students receive the resulting compatibility information.

24. Automated Matching and Decision-Making

MentorOn1 uses algorithmic logic to assist Tutor discovery.

The Match system may apply eligibility filters, compare questionnaire responses, calculate scores, rank eligible Tutors, and present recommendations.

The system does not make a legally significant decision that automatically denies a Student access to education.

The Student or Parent makes the final Tutor selection.

MentorOn1 staff may also assist with advising, review, and coordination.

Users may contact support if they believe Match information is materially incorrect.

25. Match History

MentorOn1 may retain identifiable Match history for approximately one year while the Account remains active.

Match history may be retained to let users revisit prior recommendations, understand prior interactions, support inquiries and appointments, investigate disputes, assess Platform quality, and maintain continuity.

After the ordinary Match-history period, MentorOn1 may delete identifiable answers/history, anonymise data, retain aggregate statistics, or preserve specific records where legally or operationally necessary.

After Account deletion, identifiable Match answers are generally deleted or de-linked, subject to legal holds, security needs, active disputes, required records, and backup cycles.

Genuinely anonymised Match statistics may be retained.

26. Inquiry and Free-Text Data

MentorOn1 permits Inquiries, including forms that may contain free text.

Inquiry data may include name, contact information, selected Tutor, subject, Ward information, Match reference, message, source page, status, follow-up notes, and timestamps.

Because free-text fields allow users to type their own information, a user may accidentally or voluntarily disclose data MentorOn1 did not request.

Users should avoid submitting Aadhaar, PAN, banking credentials, medical records, passwords, OTPs, highly sensitive family information, or other unnecessary data.

MentorOn1 may remove, redact, or restrict unnecessary sensitive information where practicable.

27. Appointment Data

Appointment records may include Tutor, Student/Parent, requested date/time, confirmed date/time, status, scheduling notes, message/reason, rescheduling history, cancellation data, no-show data, and related administrative information.

An Appointment record documents scheduling and coordination.

It does not mean MentorOn1 records what the parties actually say during the conversation.

28. No Recording of Physical or Tutoring Sessions

MentorOn1 does not currently record or store audio or video from physical appointments, tutoring sessions, or independent Tutor–Student conversations.

Those conversations occur between the Tutor and Student/Parent.

If a Tutor or Student independently records a session using another service or device, that processing is outside MentorOn1 unless MentorOn1 expressly participates in it.

If MentorOn1 ever introduces a recording feature, it will require a separate notice and any legally required consent.

29. Communications Between Tutors and Students

MentorOn1 does not currently provide an internal Tutor–Student chat system that stores complete private chat history.

Contact may occur after an Inquiry, after an Appointment, after staff finalisation, after approved contact release, through the user’s own telephone/email/messaging service, or through voluntary contact exchange.

MentorOn1 may therefore know that an introduction or scheduling event occurred without having the content of later off-platform conversations.

Users remain responsible for the privacy practices of the external communications tools they choose.

30. Orders, Invoices, and Engagement Records

MentorOn1 may store engagement records, Orders, and Invoices.

These may include Tutor identity, Student/Parent identity, subject, Tutor Fee, dates, start date, duration, billing period, status, notes, Order/Invoice identifiers, and administrative history.

Under the current model, MentorOn1 does not generally collect the underlying tuition payment.

An Invoice may therefore document the Tutor–Student arrangement without proving that MentorOn1 received money.

Order/Invoice information may be retained after Account deletion where necessary for accounting, audit, legal compliance, fraud prevention, disputes, and evidentiary records.

31. Reviews and Ratings

Users may submit Reviews and ratings.

A Review may display the reviewer’s public name as configured by the Platform.

Review records may include reviewer, Tutor, rating, text, date, moderation status, and administrative notes.

Users do not currently have an unrestricted self-service delete/edit mechanism for every Review. They may request correction or removal through support.

MentorOn1 may retain a legitimate Review after the Tutor or reviewer deletes an Account, but may minimise attribution, anonymise identity, remove unnecessary personal information, or retain a private moderation copy where appropriate.

Reviews involving children may be subject to additional identity minimisation or Parent/Guardian controls.

32. Testimonials, Results, and Success Stories

MentorOn1 may manually publish testimonials, Student results, success stories, experience statements, or related promotional material.

MentorOn1 requires appropriate permission before publishing identifiable testimonials or results.

For a child, MentorOn1 should obtain Parent/Guardian permission where required.

Student success stories, result data, or photos are not treated as covered by a general right to market the Platform without appropriate permission.

MentorOn1 may use public Tutor profile information and Tutor photos in MentorOn1 marketing where permitted by the Terms, the Tutor’s publication choices, applicable law, and any separate consent required for the specific use.

33. Internal Administrative Notes

MentorOn1 Administrators may create internal notes relating to Tutor verification, user support, Parent–Ward issues, complaints, safety concerns, fraud, Inquiry follow-up, Appointment administration, publication review, moderation, Orders/Invoices, and other operational matters.

Internal notes are not automatically public.

A privacy access request does not necessarily entitle a user to every internal note if disclosure would expose another person’s data, compromise fraud detection, reveal security controls, prejudice an investigation, expose legally privileged material, create safety risk, or fall within another lawful restriction.

MentorOn1 will provide what applicable law requires.

34. Authentication and Security Data

MentorOn1 may collect or generate security information such as IP address, browser/user-agent, device or session identifiers, login timestamps, logout timestamps, refresh-session information, OTP-request metadata, failed-login data, password-reset events, Account-lock events, security alerts, rate-limit events, and audit information.

This information is used to authenticate users, prevent session abuse, detect fraud, investigate suspicious activity, enforce access controls, secure minor Accounts, and respond to security incidents.

35. OTP Data

MentorOn1 uses OTP mechanisms for verification and security workflows.

MentorOn1’s intended security design is not to store reusable OTP values in readable plaintext for longer than operationally necessary.

Where OTP information is retained, MentorOn1 aims to retain only what is needed for temporary verification, expiry enforcement, one-time use, abuse detection, rate limiting, and audit/security records.

Expired OTP-related data may be deleted or reduced to non-reusable metadata.

Users must never disclose an OTP to someone claiming to need it for support.

36. Cookies and Similar Technologies

MentorOn1 currently intends to use essential cookies or equivalent local/session technologies only.

Essential technologies may be used for:

• authentication;
• session continuity;
• security;
• CSRF or similar protection;
• necessary preferences;
• and Platform operation.

MentorOn1 does not currently install third-party behavioural advertising cookies or a dedicated analytics cookie suite.

If non-essential analytics or advertising cookies are introduced, MentorOn1 intends to provide an appropriate preference mechanism where legally required.

37. Analytics and Operational Telemetry

MentorOn1 does not currently use a dedicated user analytics product such as a conventional behavioural analytics platform for ordinary user tracking.

However, infrastructure providers may generate aggregate traffic information, operational metrics, performance measurements, request counts, error rates, and similar server-level analytics.

This technical telemetry may be necessary to operate the site, detect outages, understand performance, manage capacity, and secure the service.

MentorOn1 does not treat infrastructure telemetry as permission to build advertising profiles of children.

38. Error and Application Logging

MentorOn1 and its service providers may maintain error, application, and server logs.

Depending on the event, logs may contain:

• timestamp;
• endpoint or route;
• error code;
• Account identifier;
• IP address;
• user-agent;
• session identifier;
• request metadata;
• and limited diagnostic context.

MentorOn1 does not intentionally include passwords, raw OTPs, or unnecessary verification-document contents in logs.

Infrastructure logging behaviour may differ by provider and configuration.

39. Public Tutor Profiles and Search-Engine Indexing

Published Tutor profiles are public.

Public Tutor pages may be viewed without an Account, indexed by Google and other search engines, cached by search engines, linked from external sites, shared by users, and displayed in search results.

Public profile data may include approved fields such as Tutor name, photo, subjects, educational/professional claims, experience, public service areas, fee information, ratings, and other approved profile attributes.

Private verification documents, exact private contact information, Match answers, and internal notes are not intended for public indexing.

40. No Public Student or Parent Profiles

MentorOn1 does not currently operate public Student or Parent profile pages.

Student and Parent personal data is not intended to be indexed by search engines merely because the person has an Account.

A Student or Parent can still make information public independently, for example by posting a public Review under their name. That public submission is treated separately.

41. Unauthenticated Browsing

Users may browse Tutor profiles without creating an Account.

Unauthenticated access may still generate ordinary network/server logs required to deliver and secure the service.

MentorOn1 does not currently create a persistent behavioural profile of an unauthenticated visitor for advertising.

42. Contact and Inquiry Forms Without an Account

MentorOn1 may allow a person to submit a Contact or Inquiry form without creating an Account.

Such a form may collect:

• name;
• email;
• telephone number where requested;
• subject;
• message;
• Tutor reference;
• and other information necessary to respond.

The data is used to answer the Inquiry, recommend or coordinate Tutors, prevent spam, maintain support records, and follow up where requested.

Submitting an Inquiry does not automatically subscribe the person to marketing.

43. Newsletter Sign-Up Without an Account

A person may opt into MentorOn1 newsletters without creating an Account.

Newsletter data may include email address, subscription status, consent timestamp, unsubscribe status, and limited delivery metadata.

MentorOn1 does not currently disclose a subscriber database to a separate marketing-data platform.

If newsletter delivery is performed through Resend or another email provider, the provider may necessarily process delivery information such as the recipient email and message metadata solely to transmit the message.

Users may unsubscribe through an unsubscribe mechanism where provided or through support@hombell.com.

MentorOn1 may retain a minimal suppression record after unsubscribe so the user is not accidentally re-subscribed.

44. How We Use Personal Data

MentorOn1 may process personal data to:

1. create and manage Accounts;
2. verify email addresses;
3. authenticate logins;
4. protect Account security;
5. identify children and apply age rules;
6. manage Parent–Ward relationships;
7. onboard Tutors;
8. verify Tutor information;
9. publish approved Tutor profiles;
10. display public Tutor search results;
11. perform compatibility matching;
12. preserve Match history;
13. handle Inquiries;
14. schedule Appointments;
15. facilitate introductions;
16. manage Tutor–Student engagements;
17. create Orders and Invoices;
18. publish Reviews;
19. manage testimonials with permission;
20. send service communications;
21. send optional marketing after opt-in;
22. answer support requests;
23. investigate abuse;
24. prevent fraud;
25. enforce Terms;
26. comply with legal obligations;
27. respond to safety concerns;
28. improve matching using de-identified/aggregate data;
29. conduct internal product research;
30. operate AI features;
31. maintain and debug the Platform;
32. defend legal claims;
33. manage service providers;
34. and prepare for future lawful features described in this Policy.

45. Purpose and Processing Matrix

This table is explanatory. The exact legal basis depends on the law applicable to the processing at the relevant time.

MentorOn1 does not rely on GDPR terminology such as “legitimate interests” as though it were automatically the governing Indian basis.

46. Consent and Other Lawful Processing Grounds

Where consent is required, MentorOn1 aims to obtain consent that is informed, specific to the relevant purpose, capable of withdrawal, recorded, and separated from unrelated optional uses where appropriate.

Not every lawful processing activity necessarily requires a new checkbox for each technical operation.

Applicable law may allow processing in circumstances such as providing a service the user requested, using data the person voluntarily provided for a clear purpose, complying with law, responding to emergencies, protecting against fraud, or other legally permitted uses.

MentorOn1 will not use a broad “we can do anything” clause as a substitute for a real lawful purpose.

47. Consent Withdrawal

Where MentorOn1 relies on consent, a user may withdraw that consent through available Platform controls or support@hombell.com.

Withdrawal applies to future processing that depends on the withdrawn consent.

Withdrawal does not automatically invalidate processing already lawfully completed, erase records MentorOn1 must retain, remove a Review that MentorOn1 may lawfully retain, erase security logs required for fraud/safety, or prevent processing based on another lawful ground.

If withdrawal makes a requested feature impossible to provide, MentorOn1 may disable that feature.

48. Marketing Consent

Marketing/newsletter consent is separate from ordinary acceptance of the Terms or Privacy Policy.

MentorOn1 will not treat Account creation alone as consent to optional newsletters.

A user may opt in, opt out, unsubscribe, or contact support.

Service messages such as OTPs, security alerts, Appointment changes, or policy notices are not treated as optional marketing merely because they are sent by email.

49. AI-Training Consent

Consent to use identifiable personal data for MentorOn1 AI/model training is separate from Terms acceptance, Privacy Policy acceptance, ordinary AI feature use, Match participation, and marketing consent.

Without separate explicit AI-training consent, MentorOn1 does not intentionally use identifiable personal prompts, Match answers, or Account information to train MentorOn1-owned models.

If a user separately opts in, MentorOn1 may use the consented data to train or improve MentorOn1-owned or MentorOn1-controlled models or systems.

MentorOn1 does not treat that opt-in as permission for an unrelated third-party AI provider to train its general models on the data.

Where possible, MentorOn1 may still prefer de-identification or aggregation even for consented improvement work.

50. Children’s Privacy — Overview

MentorOn1 serves Students and therefore processes children’s data.

MentorOn1 treats a person under 18 as a child for the purposes of the child-specific rules described here where applicable.

The child framework includes:

• no independent Account for a child under 10;
• Parent/Guardian permission for Students aged 10–17;
• stronger verification when legally required;
• Parent access where a legitimate Ward relationship exists;
• no behavioural advertising directed at children;
• no child advertising profiles;
• no use of child Match answers for advertising;
• no precise GPS tracking;
• no sale of child data as part of the current model;
• enhanced safety review;
• and special controls for minor Tutors.

51. Children Under 10

A child under 10 may not create or operate an independent Student Account.

A Parent/Guardian must use MentorOn1 on the child’s behalf.

MentorOn1 may delete, restrict, or convert an Account if it discovers that a child under 10 registered independently.

The Parent should provide only information reasonably necessary to find an appropriate Tutor.

52. Students Aged 10–17

A Student aged 10–17 may use a Student Account subject to Parent/Guardian permission, the age information supplied during registration, safety rules, applicable child-data law, and any additional verification MentorOn1 requires.

The Student Account is not a substitute for Adult authority where a binding financial or contractual decision requires an Adult.

A Parent–Ward link is not mandatory in every current Student flow, but Parent/Guardian permission is still required.

53. Current Parental Permission Flow

The current Platform may allow a Student aged 10–17 to confirm through a self-check/attestation that Parent/Guardian permission has been obtained.

That current workflow is a product-control mechanism.

It must not be misunderstood as a statement that MentorOn1 independently verified the Parent’s identity, independently verified the Parent’s age, or that a self-check will satisfy every future legal requirement for verifiable parental consent.

Where current applicable law permits the workflow, MentorOn1 may continue to use it.

Where a stronger verification standard becomes legally applicable, Section 54 applies.

54. Verifiable Parental Consent

Where applicable law requires verifiable parental consent before processing a child’s personal data, MentorOn1 may introduce technical and organisational measures to establish that the person identifying as the Parent/Guardian is an identifiable Adult.

Such measures may include, where lawful and proportionate:

• checking reliable age/identity details already held by MentorOn1;
• Parent Account verification;
• age/identity evidence voluntarily provided for the verification;
• use of a government-authorised or legally recognised identity/age mechanism;
• use of an authorised virtual token;
• use of Digital Locker or another permitted verification service;
• or another compliant method.

MentorOn1 may restrict creation or continued use of a child Account until the required verification is completed.

MentorOn1 does not currently collect Aadhaar as a standard verification method, and this Policy does not authorise indiscriminate Aadhaar collection.

If a Parent withdraws consent, MentorOn1 may restrict or delete the child’s affected Account/data, subject to lawful retention exceptions.

55. Parent Access to a Linked Ward

A legitimately linked Parent may be able to access broad information relating to the Ward.

This may include profile information, date-of-birth/age context, academic context, Match answers, Match results, Match history, Inquiries, Appointments, Orders, Invoices, Tutor relationships, and relevant account settings.

MentorOn1 does not grant this access merely because an adult claims to be a Parent.

Where a dispute or safety concern exists, access may be frozen pending verification.

56. Parent–Ward Disputes

If two adults dispute authority over a Ward, or a Student disputes a Parent link, MentorOn1 may temporarily freeze Parent access, restrict changes, request evidence, preserve relevant records, seek clarification, and restore access only after authority is reasonably established.

MentorOn1 will not adjudicate complex family-law disputes beyond what is necessary to protect the Account and comply with law.

Where necessary, users may be asked to obtain appropriate legal documentation.

57. Minor Tutors

MentorOn1 may accept a Tutor under 18 in special cases.

A minor Tutor requires Parent/Guardian consent where applicable.

Minor-Tutor data may include public profile data, DOB, Parent/Guardian consent information, verification records, qualification information, and other Tutor onboarding data.

MentorOn1 may apply enhanced review and may restrict public contact information, teaching modes, Student age groups, or other features.

The minor Tutor’s Parent/Guardian may be required to participate in privacy or contractual decisions.

58. Children and Advertising

MentorOn1 does not currently deploy behavioural advertising.

If adult behavioural advertising is introduced:

• it will be limited to eligible Adult users;
• child Accounts will be excluded;
• MentorOn1 will not use a child’s Match answers for advertising;
• MentorOn1 will not intentionally place behavioural ad cookies for child-targeted profiling;
• and MentorOn1 will not direct targeted advertising at children where prohibited.

MentorOn1 may show non-personalised, contextual, or service-related information where lawful, but it will not treat that as permission to create a behavioural profile of a child.

59. Children and AI

A child may encounter AI-assisted features only under the controls MentorOn1 makes available.

MentorOn1 does not intentionally use a child’s AI prompts or Match data to train MentorOn1 models without the legally required Parent/Guardian consent.

The AI Assistant is not a psychological evaluator, is not a safeguarding authority, may be inaccurate, and should not be used by a child to disclose unnecessary private or sensitive information.

Where AI context includes a child’s personal data, MentorOn1 aims to minimise the data sent to the AI provider.

60. Tutor Data Shared With Students/Parents

MentorOn1 may share or display Tutor data needed for discovery and engagement, such as public profile data, subjects, qualifications, teaching modes, location/service areas, fee information, ratings, compatibility result, availability or scheduling information, and approved contact details at the appropriate workflow stage.

MentorOn1 does not ordinarily share private verification documents, exact private residential address, internal moderation notes, password/security information, or private Tutor questionnaire answers.

A Tutor may voluntarily share additional contact information directly with a Student/Parent.

61. Student/Parent Data Shared With Tutors

A Tutor receives only the information reasonably needed to respond to an Inquiry, consider a Match, schedule an Appointment, understand the tutoring request, and manage an Engagement.

Depending on the workflow, this may include Student/Parent name, class/grade, subject, locality/PIN code, scheduling needs, Match score or explanation, Inquiry message, approved contact information, and relevant engagement details.

A Tutor does not receive unrestricted access to the Student’s full Account, individual Match questionnaire answers, Parent Account data unrelated to the Engagement, internal Admin notes, authentication information, or verification/security records.

Contact details may be released after an Inquiry, Appointment, Match, staff finalisation, or other approved step, and users may also voluntarily share contact details directly.

62. Sharing With Service Providers

MentorOn1 uses service providers to operate the Platform.

A provider may process personal data only to the extent needed for its function, subject to its contractual relationship, applicable law, technical configuration, and MentorOn1’s instructions where MentorOn1 acts as the controlling party.

Provider categories may include frontend hosting, backend hosting, databases, email delivery, file/image storage, AI infrastructure, security, error logging, future analytics, future payment processing, future CAPTCHA, and future identity/authentication providers.

MentorOn1 does not treat using a cloud provider as a sale of personal data.

63. Current Major Service Providers

The following major providers are currently used or identified for MentorOn1 operations:

The exact infrastructure, region, and subprocessor arrangements may change.

MentorOn1 may replace or supplement a provider where security, reliability, cost, functionality, legal requirements, or Platform architecture make a change appropriate.

A material change in purpose will receive additional notice where required.

64. Hombell-Related Operational Support

Because MentorOn1 is accessible through and operationally associated with Hombell, support communications may use the Hombell domain and the sender identity MentorOn1 X Hombell Support.

MentorOn1 may use shared operational support resources associated with Hombell to receive support emails, route users to MentorOn1, respond to account questions, and maintain service continuity.

This operational relationship does not authorise unrelated use of MentorOn1 personal data.

MentorOn1 personal data is not treated as a freely transferable marketing database merely because the support email uses the Hombell domain.

65. Sharing With Schools and Other Organisations

MentorOn1 may in the future work with schools, coaching centres, educational organisations, Tutor organisations, community partners, or other institutions.

MentorOn1 will not automatically give such an organisation unrestricted Student Account data.

Identifiable data may be shared only where the user has given appropriate permission, the sharing is necessary for a requested programme/service, another lawful basis exists, or law requires the sharing.

Where a partnership materially changes how personal data is used, MentorOn1 may provide a separate notice.

66. Sharing for Safety, Fraud Prevention, and Legal Compliance

MentorOn1 may share limited relevant personal data where reasonably necessary and legally permitted to prevent serious harm, investigate child-safety concerns, respond to fraud, protect a Tutor/Student/Parent, prevent account takeover, enforce legal rights, respond to abuse, protect Platform security, or comply with legal obligations.

Recipients may include an affected user, Parent/Guardian, service provider, professional adviser, insurer, law-enforcement authority, regulator, court, or other appropriate person.

MentorOn1 will attempt to limit disclosure to what is reasonably necessary.

67. Government and Law-Enforcement Requests

MentorOn1 may disclose personal data to government, law-enforcement, regulatory, or judicial authorities where legally required, permitted by applicable law, necessary to comply with valid legal process, or necessary in a genuine emergency where disclosure is legally permitted.

MentorOn1 does not adopt a policy of handing over entire user databases merely because an informal request is made.

Where appropriate, MentorOn1 may request proper legal authority, narrow an overbroad request, preserve records, and document the disclosure.

Users may not always be notified where law prohibits notice or where notice would prejudice an investigation.

68. Professional Advisers

MentorOn1 may disclose limited personal data to professional advisers such as lawyers, accountants, auditors, cybersecurity professionals, insurers, or consultants where reasonably necessary for legal advice, compliance, claims, audits, accounting, security, or business operations.

Such recipients are expected to handle information confidentially or under professional duties where applicable.

69. Business Transfers and Reorganisation

MentorOn1 may later register a proprietorship, form a partnership, form an LLP, incorporate a company, merge, transfer the service, raise investment, or sell relevant business assets.

Personal data may be transferred to a successor operator where reasonably necessary for business continuity, subject to applicable law, appropriate privacy obligations, and notice or consent where required.

A successor does not automatically receive permission to use historical data for an unrelated purpose.

70. International and Cross-Border Processing

MentorOn1 uses cloud providers that may process or store data in India or other jurisdictions.

Accordingly, personal data may be processed outside India where the provider operates, technical routing requires it, and applicable Indian law permits it.

MentorOn1 will comply with applicable restrictions or government notifications relating to cross-border transfer.

International processing may mean that data is subject to foreign infrastructure, foreign data-centre operations, and legal requirements applicable to the provider.

MentorOn1 aims to use reputable providers and appropriate contractual/security measures.

71. Artificial Intelligence Privacy

MentorOn1 may provide an AI-enabled Assistant.

AI processing is treated separately because a user prompt may contain personal data.

The AI Assistant may be used to answer MentorOn1 questions, explain features, summarise relevant Account information, use Match context, recommend Tutors, and assist with Platform navigation.

Users should not enter passwords, OTPs, bank credentials, Aadhaar, private verification documents, unnecessary medical data, or secrets unrelated to the request.

72. Google AI Processing

MentorOn1 currently identifies Google as the AI provider.

When a user invokes the AI Assistant, Google’s AI infrastructure may receive:

• the raw prompt;
• instructions/system context necessary to provide the feature;
• and limited MentorOn1 Account or Match information where needed for the requested response.

MentorOn1 does not claim that every Google service has identical retention or subprocessor behaviour.

Actual provider-side processing depends on the specific Google AI service, configuration used, contractual terms, provider policies, and applicable law.

MentorOn1 will not intentionally send more personal context than reasonably necessary for the feature.

73. AI Prompts and Personal Context

The AI provider may receive the raw user prompt.

Where the user is logged in, MentorOn1 may also send limited context such as role, Tutor information, Match result, subject, relevant Account context, or other data needed to answer the request.

MentorOn1 does not intend to send plaintext passwords, OTP secrets, private identity documents, full internal fraud notes, or unrelated personal data to the AI provider.

Users should assume that information typed into the AI prompt is processed by the AI provider to generate the response.

74. AI Conversation Storage

MentorOn1 does not currently store a persistent AI conversation history in the user’s MentorOn1 Account.

This means a prior AI conversation may not be recoverable from MentorOn1 after the interaction.

However:

• transient request/response data may exist in application memory or logs for technical operation;
• security/error logs may contain limited metadata;
• and the third-party AI provider may process or retain data according to the applicable service configuration and contract.

MentorOn1 does not promise a provider-side retention period that it has not technically or contractually verified.

75. AI Training and Model Improvement

MentorOn1 distinguishes between:

1. using AI to answer a user’s request; and
2. using user data to train or improve a model.

Those are not treated as the same permission.

Without explicit AI-training consent, MentorOn1 does not intentionally use identifiable AI prompts, Account data, Match answers, or Student/Parent information to train MentorOn1-owned models.

With separate explicit consent, MentorOn1 may use selected data for MentorOn1-controlled training or improvement.

MentorOn1 does not interpret that consent as authorisation for a third-party AI provider to train a general third-party model on the user’s personal data unless the user is separately informed and consents where required.

76. Matching-System Improvement

MentorOn1 may use aggregate, de-identified, or genuinely anonymised Match usage data to evaluate matching quality, improve question design, assess weighting, detect systematic errors, and improve the recommendation service.

MentorOn1 does not intend to tune global matching weights using identifiable individual Match answers where de-identified or aggregate methods can reasonably achieve the purpose.

The purpose is to improve matching, not to create advertising profiles.

77. Research and Statistical Use

MentorOn1 may use de-identified or aggregate Platform data for internal research, service statistics, product development, matching evaluation, operational planning, impact measurement, and published aggregate insights.

Examples may include:

• number of Tutors;
• number of Matches;
• subject demand;
• location distribution;
• grade distribution;
• Match completion rates;
• and aggregated service outcomes.

Published statistics should not reasonably identify an individual.

78. Third-Party Academic Research

MentorOn1 may support academic or research projects.

Possible models include sharing genuinely de-identified datasets, sharing aggregate statistics, or, in a carefully controlled project, sharing identifiable information with separate explicit consent.

Where identifiable data is involved, MentorOn1 may require:

• specific informed consent;
• a defined research purpose;
• restricted access;
• confidentiality;
• data minimisation;
• retention limits;
• and ethics or institutional safeguards where appropriate.

Ordinary Platform consent is not treated as blanket consent for unrelated identifiable academic research.

79. Advertising — Current State

MentorOn1 does not currently deploy behavioural advertising technology.

MentorOn1 does not currently place third-party ad cookies for profiling, create cross-device advertising profiles, build advertising profiles from child Match answers, or direct behavioural advertising at children.

MentorOn1 may display its own promotional content or contextual information without behavioural tracking.

80. Future Adult Behavioural Advertising

MentorOn1 may introduce behavioural advertising for Adults in the future.

If introduced, MentorOn1 intends to:

• exclude child Accounts;
• obtain consent or provide choice where legally required;
• provide appropriate notice;
• allow control through a cookie/ad preference mechanism where required;
• and restrict the data shared to what is reasonably necessary.

A future ad model does not activate merely because this Policy describes it.

MentorOn1 will update implementation notices when the feature actually launches.

81. Advertising Data We May Use in the Future

For eligible Adult advertising, MentorOn1 may use or share contextual page information, pseudonymous browser/device identifiers, consent status, broad service interests, page/activity information, and campaign measurement information where lawful.

MentorOn1 does not currently intend to provide advertisers with unrestricted direct Account identity/contact data for behavioural targeting.

MentorOn1 does not currently sell personal data for money as part of its business model.

If a future business model materially changed that practice, MentorOn1 would provide a revised privacy notice and obtain any consent required before the new processing begins.

82. No Child Advertising Profiles

MentorOn1 will not intentionally build an advertising profile of a child from Match answers, subject preferences, browsing behaviour, Tutor searches, Appointment history, Ward information, or Account activity.

This restriction applies even if the child is technically capable of using the website without a Parent Account link.

Child Match Data is for Tutor discovery and related service/safety purposes, not advertising optimisation.

83. Third-Party Advertising Cookies

If third-party advertising cookies are introduced, MentorOn1 intends to load them only after the user’s appropriate opt-in choice where consent is legally required.

Users who do not consent should still be able to access ordinary Platform functions that do not depend on advertising cookies, subject to technically necessary cookies.

MentorOn1 may use an “Advertising” toggle, consent banner, preference centre, or another appropriate control.

84. Future Cookie Preference Centre

If MentorOn1 introduces non-essential tracking, it intends to provide controls such as:

• Essential;
• Analytics;
• Advertising;

or equivalent categories.

Essential cookies may remain active because the service cannot securely operate without them.

A user may be able to change non-essential choices later.

MentorOn1 may also maintain a consent record proving which preference was selected.

85. Social Login — Future Feature

MentorOn1 does not currently rely on social login as an active standard authentication method.

Social login is planned as a potential future feature.

If introduced through providers such as Google or another identity provider, MentorOn1 may receive Account identifier, name, email, profile information, and authentication tokens to the extent authorised by the user and provider.

The provider’s own privacy notice will also apply to its independent processing.

86. CAPTCHA and Anti-Bot Services — Future Feature

MentorOn1 does not currently use a CAPTCHA/anti-bot provider in the standard flow.

MentorOn1 may later introduce Google reCAPTCHA, Cloudflare Turnstile, or another anti-bot service.

Such a provider may process IP address, browser information, device signals, interaction signals, and other technical information necessary to identify bots or abuse.

MentorOn1 will update the applicable notice if such a service becomes active.

87. Payments — Current State

MentorOn1 does not currently operate a payment processor for Tutor payments.

MentorOn1 does not currently collect card numbers, card CVV, UPI credentials, bank-account credentials, or Tutor payout account details through a standard MentorOn1 checkout.

Orders and Invoices may record Tutor Fee information without MentorOn1 receiving the underlying money.

Tutor and Student/Parent currently handle payment themselves.

88. Future Payment Processing

MentorOn1 may introduce paid Platform services or payment collection in the future.

If it does:

• MentorOn1 intends to use an appropriate payment processor;
• full card/bank credentials should be handled by the payment provider where practicable;
• MentorOn1 may receive payment metadata such as transaction ID, amount, status, payer reference, refund status, and timestamps;
• additional KYC/tax information may be required if law requires it;
• and a separate payment notice or updated Policy may apply.

MentorOn1 does not intend to store raw full card credentials merely for convenience.

89. Data Retention Principles

MentorOn1 keeps identifiable personal data only for as long as reasonably necessary for the requested service, an active Account, the stated retention schedule, security, legal obligations, fraud prevention, child safety, disputes, audits, backups, and legitimate record-keeping.

Different categories have different retention needs.

MentorOn1 avoids giving a false promise that every byte disappears instantly when an Account is deleted.

Deletion may occur in stages:

1. public access disabled;
2. active sessions revoked;
3. live application data deleted or anonymised;
4. processor deletion initiated;
5. backups expire according to provider cycles;
6. legally retained records remain until the retention purpose ends.

90. Detailed Retention Schedule

The following is MentorOn1’s intended current retention approach. “Approximately” allows for operational processing, backup cycles, disputes, and legally required retention.

Where applicable law requires a minimum retention period for particular processing or security logs, MentorOn1 will follow that mandatory period even if the user deletes the Account earlier.

Where law requires earlier erasure, the mandatory erasure requirement prevails.

91. Dormant Accounts

MentorOn1 may retain a dormant Account for up to approximately five years after meaningful Account activity.

Before deleting or anonymising a dormant Account, MentorOn1 may, where practicable, send a warning, invite the user to log in, allow the user to preserve the Account, or provide another notice.

MentorOn1 may delete earlier where the user requests deletion, the Account is fraudulent, the Account belongs to a child without required consent, security requires closure, or law requires deletion.

MentorOn1 may retain specific records after dormant-account deletion where Section 94 applies.

92. Account Deletion

A user may request Account deletion through available Account controls or by contacting support.

When deletion is accepted:

• active sessions are revoked;
• public Tutor visibility is removed;
• Account access is disabled;
• live personal data is deleted or anonymised according to the data category;
• and processor deletion may be initiated.

MentorOn1 does not promise a fixed recovery/grace period.

A deletion request may therefore become irreversible.

MentorOn1 may retain specific records where required for legal obligations, security, fraud, safeguarding, Orders/Invoices, disputes, or claims.

93. Backup Copies

MentorOn1 uses infrastructure providers that may maintain backups.

Backup retention is provider-dependent.

Accordingly:

• data deleted from the live application may remain temporarily in protected backups;
• backup copies are not intended for ordinary user access;
• backup restoration may temporarily reintroduce deleted records, in which case deletion controls should be reapplied;
• and backups expire according to provider architecture and retention cycles.

MentorOn1 does not promise an exact backup-erasure period unless the architecture supports and verifies that commitment.

94. Legal Holds and Required Retention

MentorOn1 may suspend deletion of specific data where necessary for litigation, threatened claims, fraud investigation, child-safety investigation, payment/Invoice disputes, regulatory requests, law-enforcement requests, security incidents, or another legally recognised retention obligation.

A legal hold should be limited to the data reasonably relevant to the matter.

Once the hold is no longer necessary, ordinary deletion/retention rules resume.

95. Anonymous and Aggregated Data

MentorOn1 may retain genuinely anonymised data indefinitely.

Data is treated as anonymised only where it is no longer reasonably linkable to an identifiable person using reasonably available means.

MentorOn1 may also create aggregated statistics, including numbers of Tutors, Students, Matches, subjects requested, localities served, Tutor category distribution, Match completion rates, and engagement statistics.

Aggregate publication should not expose identifiable individual records.

96. Security Safeguards

MentorOn1 uses or intends to use reasonable technical and organisational safeguards appropriate to the nature of the Platform.

Measures may include:

• hashed passwords;
• encrypted network transport;
• role-based access controls;
• email verification;
• OTP workflows;
• session controls;
• refresh-session management;
• access logging;
• rate limiting;
• audit records;
• restricted Admin permissions;
• provider security controls;
• backups;
• incident investigation;
• and least-necessary access to verification data.

Security practices evolve.

MentorOn1 does not publish exploit-sensitive architectural details in this Policy.

No internet service can guarantee absolute security.

97. Password Security

MentorOn1 stores passwords in hashed form, not readable plaintext.

MentorOn1 does not need to know the user’s original password to authenticate the user.

Password-reset workflows may therefore use OTP verification, reset tokens, or other secure reset mechanisms rather than revealing an existing password.

Users are responsible for selecting a secure password and protecting access to their email.

98. Access Controls

Access to personal data is limited according to role and operational need.

Examples:

• public visitors see only published Tutor data;
• Students do not see internal Admin notes;
• Tutors do not see unrestricted Student Match answers;
• Parents see only legitimate linked Wards;
• verification documents are limited to authorised Admin personnel and necessary processors;
• and administrative actions are restricted to authorised roles.

MentorOn1 may review permissions periodically and revoke access when no longer needed.

99. Security Logs and Monitoring

MentorOn1 may log sign-in events, session events, failed authentication, suspicious activity, Account changes, Admin actions, OTP abuse, and access/security events.

The purpose is to detect unauthorised access, investigate incidents, prevent recurrence, enforce Account security, and maintain continuity.

Some security/processing logs may need to be retained for a minimum period required by applicable law once the relevant provisions apply.

MentorOn1 may retain longer where a genuine security investigation remains open.

100. Personal Data Breaches

A personal data breach may include unauthorised access, disclosure, loss, alteration, destruction, or compromise of personal data.

MentorOn1’s response may include:

1. containment;
2. credential/session revocation;
3. investigation;
4. evidence preservation;
5. provider coordination;
6. remediation;
7. risk assessment;
8. notification;
9. and security improvements.

MentorOn1 will notify affected users and competent authorities where required by applicable law.

MentorOn1 may also voluntarily notify affected users where a material risk exists even if a specific mandatory notification threshold is not clearly triggered.

Where future-applicable DPDP breach rules prescribe specific content or regulator timelines, MentorOn1 will follow those requirements when they apply.

101. Your Privacy Rights

Depending on the law applicable at the relevant time, users may have rights concerning:

• access to information about processing;
• correction;
• completion;
• updating;
• erasure;
• grievance redressal;
• consent withdrawal;
• nomination of another individual in circumstances recognised by law;
• and other statutory rights.

MentorOn1 also provides practical Account controls even where a specific statutory right is not yet in force.

Rights may be limited where another person’s privacy is involved, security would be compromised, a legal exception applies, retention is legally required, or identity/authority cannot be verified.

102. Access Requests

A user may request information about personal data MentorOn1 processes.

MentorOn1 may provide Account information, Tutor information, Match history, Inquiry information, Appointment information, Orders/Invoices, Review records, consent information, or other information where appropriate and legally required.

MentorOn1 may withhold or redact information where disclosure would improperly expose another user, internal security mechanisms, fraud-investigation methods, legally privileged material, or protected third-party information.

103. Correction Requests

Users should keep information accurate.

Many fields may be corrected through the dashboard.

Where a field is locked, Admin-controlled, verification-related, public-profile controlled, or disputed, the user may contact:

support@hombell.com

A Tutor may request correction of an Admin-edited profile field.

MentorOn1 may require evidence before changing a verified claim.

104. Erasure and Account Deletion Requests

A user may request erasure or Account deletion.

MentorOn1 may erase, anonymise, or de-link personal data where appropriate.

MentorOn1 may lawfully retain data required for Orders/Invoices, legal obligations, fraud, security, safety, disputes, consent evidence, backup cycles, or claims.

A request to erase public content does not guarantee immediate removal from third-party search-engine caches.

105. Data Export

MentorOn1 does not currently provide a universal automated “download all my data” feature.

A user may request an appropriate copy/export through support.

MentorOn1 may provide data in a reasonable electronic format where technically feasible, appropriate, and required or voluntarily supported.

MentorOn1 may verify identity before providing an export.

106. Grievances and Questions

Privacy questions, rights requests, and grievances may be sent to:

MentorOn1 X Hombell Support
Email: support@hombell.com
Location: Bankura, West Bengal, India

MentorOn1 currently uses this address as its privacy/support contact.

MentorOn1 may later designate a separate privacy email, Grievance Officer, Data Protection Officer, or another responsible person where required by law or operationally appropriate.

If that happens, updated contact details will be published.

107. Rights Exercised by a Parent/Guardian

Where a child’s Parent/Guardian is recognised as entitled to act for the child, the Parent/Guardian may exercise privacy rights on the child’s behalf.

MentorOn1 may require evidence that the person is an Adult, is the Parent or lawful Guardian, and is authorised to act for that child.

A Parent’s right to act does not permit unrestricted access to another unrelated child’s data.

108. Withdrawal of Parental Consent

A Parent/Guardian may withdraw consent for child processing that depends on that consent.

After withdrawal, MentorOn1 may restrict the child Account, disable Match features, prevent future processing, delete or anonymise affected data, and revoke relevant access.

MentorOn1 may retain information where legally necessary for safety, disputes, fraud, consent records, Orders/Invoices, or legal obligations.

Withdrawal does not necessarily erase lawful historical processing.

109. Identity Verification for Privacy Requests

MentorOn1 must avoid giving personal data to an impostor.

Before acting on a request, MentorOn1 may ask for reasonable verification such as access to the registered email, Account authentication, OTP confirmation, Parent/Guardian verification, relevant Account identifiers, or other proportionate evidence.

MentorOn1 will not request more identity information than reasonably necessary merely to discourage rights requests.

110. Limitations on Access to Security/Internal Records

Users will not automatically receive a copy of every fraud score, internal Admin note, investigation hypothesis, security rule, abuse signature, access-control design, or other sensitive operational record.

Disclosure may be limited where it would help attackers evade controls, expose another person, compromise safety, prejudice an active investigation, reveal privileged material, or fall within a lawful exception.

MentorOn1 will still provide information required by applicable law.

111. Public Content After Account Deletion

Account deletion does not necessarily require deletion of every public contribution.

For example:

• a legitimate Review may remain;
• a Tutor profile will normally be unpublished;
• a testimonial may be removed if permission is withdrawn where required;
• aggregate statistics may remain;
• and legal/audit records may remain privately.

Where a public Review remains after Account deletion, MentorOn1 may minimise or anonymise attribution where appropriate.

112. Search-Engine Caches

When MentorOn1 removes or unpublishes a Tutor profile, external search engines may temporarily retain cached copies, snippets, thumbnails, or stale search results.

MentorOn1 does not directly control third-party cache deletion schedules.

MentorOn1 may remove the source page, use appropriate indexing controls, request de-indexing where warranted, or allow the cache to expire.

Users should understand that public publication inherently allows some external copying/caching.

113. Marketing and Unsubscribe Rights

Marketing/newsletter messages are opt-in.

A user can unsubscribe through an unsubscribe link where available or through support@hombell.com.

Unsubscribing does not stop OTPs, security alerts, policy notices, Inquiry responses, Appointment notices, or other necessary service communications.

MentorOn1 may retain a suppression record proving the user opted out.

114. Data Minimisation

MentorOn1 aims to collect no more personal data than reasonably necessary for the feature.

Examples include:

• no precise GPS when PIN code is sufficient;
• no bank credentials when MentorOn1 does not collect payment;
• no Aadhaar merely for convenience;
• no Student marks where grade/board information is sufficient;
• no tutoring-session recording where the service does not require it;
• no child advertising profile;
• and no persistent AI chat history where the product does not need one.

Future features may change what is necessary, but material changes will receive an updated notice.

115. Accuracy of Personal Data

Users are responsible for providing accurate information.

MentorOn1 may correct obvious errors, request evidence, flag disputed claims, suspend publication, or reject inaccurate verification information.

Where personal data used to make a material decision is inaccurate, users may request correction.

MentorOn1 may preserve prior values in audit history where necessary for fraud, disputes, or accountability.

116. Data Submitted About Other People

Users must not submit another person’s personal data without authority.

Examples include creating an unauthorised Ward, uploading another person’s identity document, using another person’s photo, naming a Student in a public testimonial without permission, or providing another person’s contact information without a legitimate reason.

A Parent may provide a child’s data only where authorised to act for the child.

A Tutor should not upload Student records into a free-text field.

117. Sensitive Information in Free-Text Fields

MentorOn1 does not currently design the standard Match questionnaire to collect highly sensitive categories.

However, free-text fields can contain whatever a user types.

Users should not submit unnecessary medical history, mental-health information, disability details, caste, religion, political views, sexual information, Aadhaar, PAN, financial credentials, passwords, or private documents.

If such data is genuinely necessary for a support/safety issue, the user should provide only what is relevant.

MentorOn1 may redact or delete excessive data.

118. Data of Persons With a Lawful Guardian

Where applicable law recognises a lawful Guardian for a person who requires such representation, MentorOn1 may require verification of the Guardian’s authority before allowing that person to exercise privacy rights or give legally required consent on behalf of the Data Principal.

MentorOn1 may request only the information reasonably necessary to establish that authority.

119. Changes to Service Providers

MentorOn1 may change cloud or service providers.

A provider change does not automatically require new consent where the purpose remains the same, data categories remain materially the same, security and legal requirements remain appropriate, and applicable law does not require fresh consent.

MentorOn1 may update the provider table without individually asking every user to re-accept the entire Policy.

If a provider change materially alters purpose, sensitivity, advertising use, AI training, or cross-border risk in a way requiring additional notice or consent, MentorOn1 will provide it.

120. Changes to This Privacy Policy

MentorOn1 may update this Policy because of legal changes, new features, provider changes, child-safety changes, advertising, AI changes, payment features, security changes, or business reorganisation.

The “Last Updated” date will be revised.

Minor changes may be published without requiring fresh consent.

121. Material Changes and Fresh Consent

For material changes, MentorOn1 may provide notice through email, dashboard, banner, modal, Account notice, or another reasonable method.

Fresh consent will be requested where legally required.

Examples that may require more prominent notice include a new use of child data, a new AI-training purpose, launch of behavioural advertising, use of a new sensitive data category, or a material change in who receives identifiable data.

122. Language and Accessibility

This Policy is currently provided in English.

MentorOn1 may provide a Bengali version, Bengali summary, or Bengali assistance on request in the future.

Where translations are provided, MentorOn1 may identify which version controls legally, subject to applicable law.

MentorOn1 aims to use clear language even though this full Policy is intentionally comprehensive.

123. Short Child/Parent Privacy Notice

MentorOn1 may later publish a shorter Child/Parent Privacy Summary explaining:

• what data is collected;
• why DOB is needed;
• how Parent permission works;
• what a linked Parent can see;
• what Tutors receive;
• how Match answers are used;
• that children are not behaviourally targeted;
• and how to request deletion/help.

That short notice will supplement this full Policy, not replace it.

124. Closure of MentorOn1

If MentorOn1 ceases operation, personal data may be deleted or anonymised after required records are settled, transferred to a lawful successor, or handled through a combination of those approaches.

Where practicable and appropriate, users may receive advance notice.

A closure does not require deletion of data that law requires MentorOn1 to preserve.

A successor must process transferred data subject to applicable privacy obligations.

125. Contact Information

MentorOn1
Operated by Siddhartha Gorai
Bankura, West Bengal, India

Privacy, Support, Legal, and General Grievances:
MentorOn1 X Hombell Support
support@hombell.com

Where applicable law later requires publication of a specific Data Protection Officer, Grievance Officer, full postal address, or additional regulatory contact, MentorOn1 will publish that information.

126. Annex A — Data Collection Matrix

127. Annex B — Data Sharing Matrix

128. Annex C — Retention Matrix

129. Annex D — Children’s Privacy Matrix

130. Annex E — AI Privacy Matrix

131. Annex F — Cookies and Future Advertising Matrix

132. Annex G — Rights Request Guide

MentorOn1 will respond within applicable legal timelines and may request reasonable identity verification.

133. Annex H — Current-vs-Future Feature Register

This Annex prevents a user from reading a future disclosure as though the feature already exists.

Final Privacy Summary

By using MentorOn1, users should understand the following core points:

1. MentorOn1 is currently operated by Siddhartha Gorai in Bankura, West Bengal, India.
2. MentorOn1 is operationally associated with Hombell and uses MentorOn1 X Hombell Support — support@hombell.com.
3. MentorOn1 collects full date of birth to apply age and child-protection rules.
4. Children under 10 cannot operate an independent Student Account.
5. Students aged 10–17 require Parent/Guardian permission.
6. A current self-check is not represented as equivalent to future-required verifiable parental consent.
7. A linked Parent can access broad Ward information.
8. Tutors may provide verification documents, but those documents are private.
9. MentorOn1 does not currently collect Aadhaar, PAN, bank/UPI credentials, or payment-card data.
10. MentorOn1 does not collect precise GPS location.
11. MentorOn1 does not record physical appointments or tutoring sessions.
12. MentorOn1 does not currently store an internal Tutor–Student chat history.
13. Match answers are used for Tutor compatibility, not psychological diagnosis or child advertising.
14. Tutors generally receive Match outputs, not the Student’s raw questionnaire answers.
15. Public Tutor profiles may be indexed by search engines.
16. Student and Parent profiles are not public.
17. MentorOn1 currently uses Vercel, Render, Neon, Resend, Cloudinary, and Google for identified operational functions.
18. Google AI may receive the raw AI prompt and limited relevant context.
19. MentorOn1 does not currently store a persistent AI conversation history.
20. Identifiable AI-training use requires separate explicit consent.
21. De-identified/aggregate data may be used to improve matching and conduct research.
22. Behavioural advertising is not currently deployed and, if introduced, is intended for eligible Adults only.
23. MentorOn1 does not build behavioural advertising profiles from child data.
24. MentorOn1 does not currently sell personal data for money.
25. Accounts may remain dormant for approximately five years before deletion/anonymisation review.
26. Account deletion revokes sessions, but legally required records and backups may persist temporarily.
27. Security, fraud, legal, and child-safety records may be retained where necessary.
28. Users may request access, correction, deletion, export, or grievance assistance through support.
29. Optional marketing and optional AI-training consent are separate.
30. This Policy may be updated when Indian privacy obligations, Platform architecture, or MentorOn1 features change.

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