Privacy Policy

1. Who we are and what this policy covers

The Black Technology Mentorship Program ("BTMP", "we", "us") is an educational organisation that runs mentorship, technical education, career placement and startup incubation programmes. This policy explains what personal information we collect, why we collect it, how long we keep it, who we share it with, and the rights you have over it.

It applies to btmpprogram.com, to the BTMP education platform, to every application form on this site, to our mentorship matching process, and to communications we send you. It does not apply to third-party sites we link to, each of which has its own policy.

BTMP is the data controller for the information described here. Our contact details for privacy matters are set out in section 14.

2. Information we collect

We group the information we hold into six categories.

2.1 Information you give us directly

• Identity and contact data — name, email address, telephone number, country and timezone, and where you provide it, a link to a professional profile or portfolio.
• Application data — the track or service you are interested in, your current career stage, hours available each week, years of experience, and the free-text answers you write about your goals.
• Support and accessibility data — anything you tell us about barriers such as connectivity, hardware, caring responsibilities or accessibility needs, which you provide voluntarily so that we can allocate stipends, loans and adjustments.
• Correspondence — the content of emails, contact form messages and support requests.

2.2 Information generated by taking part in a programme

• Development plans, session notes and action items recorded by you and your mentor.
• Coursework submissions, assessment outcomes, capstone artefacts and facilitator feedback.
• Attendance at labs, speaker sessions and range exercises.
• Quarterly review outcomes, including re-match and pause decisions.

2.3 Technical information collected automatically

• IP address, browser type and version, operating system, and device category.
• Pages visited, time on page, referring URL, and the search terms used in our on-site search.
• Error and performance diagnostics where a page fails to load.

2.4 Information from third parties

• References supplied by a person you nominate when applying to mentor.
• Placement outcomes confirmed by hiring partners, where you have asked us to make an introduction.
• Aggregate, non-identifying analytics from our email delivery provider.

2.5 Information we deliberately do not collect

• We do not ask for government identification numbers.
• We do not collect payment card details, because our core programmes are free to accepted participants.
• We do not use device fingerprinting, cross-site tracking pixels or data brokers.
• We do not require demographic self-identification in order to apply. Where we ask it for programme evaluation, it is always optional, always separable from your application, and always reported only in aggregate.

3. How and why we use your information

We use personal information only for the purposes set out below.

Where we rely on legitimate interests, we have carried out a balancing assessment and recorded it. You may ask us for a summary of that assessment at any time.

3.1 Automated decision-making

We do not make decisions about applications by solely automated means. Matching suggestions are generated automatically from stated preferences, but every match is reviewed and confirmed by a member of the programme team, and both people may decline.

4. Who we share information with

We do not sell personal information, and we do not share it for anyone else's marketing purposes. We share it in four limited circumstances.

1. With your mentor or mentee. Matched pairs see each other's name, discipline, stated goals and development plan. Free-text answers about personal barriers are never shared without your explicit permission.
2. With hiring partners, only on your instruction. We make an introduction only when you have asked for it and confirmed what may be shared.
3. With service providers acting on our behalf. Email delivery, hosting, video conferencing and the learning platform. Each is bound by a written processing agreement, may act only on our instructions, and may not use your data for their own purposes.
4. Where the law requires it. In response to a valid legal process, or where disclosure is necessary to protect someone's vital interests. Where we are permitted to tell you, we will.

4.1 Categories of processor

5. International transfers

BTMP operates globally and matches participants across timezones. Some of our service providers process data outside the country in which you live, including in the United States.

Where information is transferred out of the United Kingdom or the European Economic Area, we rely on one of the following safeguards: an adequacy decision covering the destination country; the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses; or, where neither applies, your explicit and informed consent. We carry out a transfer risk assessment before any new provider is engaged and review it annually.

You may request a copy of the relevant safeguard by writing to [email protected].

6. How long we keep information

We keep personal information only as long as it is needed for the purpose it was collected for, or as long as the law requires.

At the end of a retention period we delete records or irreversibly anonymise them. Anonymised data may be retained indefinitely for statistical purposes; it cannot be linked back to you.

7. Your rights over your information

Depending on where you live, you have some or all of the following rights. We apply them to everyone, wherever they are, as a matter of policy.

• Access. Ask for a copy of the personal information we hold about you, and an explanation of how we use it.
• Rectification. Ask us to correct information that is inaccurate or incomplete.
• Erasure. Ask us to delete information where we no longer have a good reason to keep it. Some records — assessment outcomes, safeguarding records — may need to be retained, and we will explain why if that applies.
• Restriction. Ask us to pause processing while a dispute about accuracy or legitimate interests is resolved.
• Portability. Receive the information you gave us in a structured, commonly used, machine-readable format, or have it sent to another organisation.
• Objection. Object to processing based on legitimate interests, and object at any time to direct marketing, which we will always stop immediately.
• Withdraw consent. Where we rely on consent, withdraw it at any time. This does not affect processing already carried out.
• Complain. Lodge a complaint with your data protection regulator. In the UK this is the Information Commissioner's Office; in the EEA it is your national supervisory authority. We would appreciate the chance to resolve matters first.

7.1 Rights specific to California residents

If you are a California resident you additionally have the right to know the categories of personal information collected, the categories of sources, the business purpose, and the categories of third parties with whom it is shared; the right to delete; the right to correct; and the right not to be discriminated against for exercising any of these rights. We do not sell or share personal information as those terms are defined by the California Consumer Privacy Act, and we have not done so in the preceding twelve months.

7.2 How to exercise a right

Write to [email protected] with the words "data request" in the subject line and tell us which right you wish to exercise. We will verify your identity using the email address on your record or, if that is not possible, by another proportionate means. We respond within one calendar month and may extend by a further two months for complex requests, telling you within the first month if we do. There is no charge unless a request is manifestly unfounded or excessive.

8. How we protect information

We apply technical and organisational measures proportionate to the sensitivity of the data we hold.

• Encryption in transit using current TLS for all connections to this site and the platform.
• Encryption at rest for participant records and programme data.
• Role-based access control, with access to free-text personal barrier answers restricted to a named subset of the programme team.
• Multi-factor authentication required for all staff and facilitator accounts.
• Least-privilege service accounts and quarterly access reviews.
• Logging and alerting on administrative access to participant records.
• Annual penetration testing and a published vulnerability disclosure route.
• Written processing agreements and security review before any new processor is engaged.
• Mandatory data protection training for staff, facilitators and mentors before they see any participant record.

8.1 If something goes wrong

We maintain an incident response plan that is tested annually. Where a personal data breach is likely to result in a risk to your rights and freedoms, we notify the relevant supervisory authority within seventy-two hours of becoming aware of it. Where the risk is high, we notify affected individuals directly and without undue delay, describing what happened, what data was involved, what we are doing, and what you can do.

8.2 Reporting a vulnerability

If you believe you have found a security vulnerability in this site or our platform, write to [email protected]. We commit to acknowledging within two working days, keeping you informed, and not pursuing legal action against good-faith research that respects user privacy and does not degrade service.

9. Children and young people

BTMP runs programmes for participants from the age of thirteen. We take additional care with the data of anyone under eighteen.

• Applicants under sixteen must provide the contact details of a parent or guardian, and we obtain that adult's consent before processing the application further.
• Where local law sets a higher age of digital consent, we apply the higher age.
• Mentors matched with participants under eighteen complete an additional safeguarding module and are subject to background checks where local law permits.
• Sessions with participants under eighteen follow our safeguarding policy, which includes a requirement that a programme adult has access to the session record.
• We do not use any information from participants under eighteen for marketing.
• A parent or guardian may exercise any of the rights in section 7 on behalf of a child, and a participant may exercise them for themselves once they reach the age of digital consent in their jurisdiction.

10. Marketing and communications

We send three kinds of message and treat them differently.

We never pass your address to another organisation for their marketing, and we do not run advertising on this site.

11. Your choices when using this site

You can use most of this site without providing any personal information. Specifically:

• Reading any page, including all six articles, requires no account and no form.
• The cookie notice lets you accept all cookies or essential cookies only; see the Cookie Policy for the full list and what each one does.
• Form validation happens entirely in your browser before anything is sent.
• We honour Global Privacy Control and Do Not Track signals where your browser sends them, by treating them as an instruction to load no non-essential cookies.

12. Third-party links and embedded content

This site links to external organisations, including social networks and partner companies. Following such a link takes you to a site with its own privacy policy over which we have no control, and we encourage you to read it.

Photographic images on this site are served from a third-party image delivery network. Loading an image causes your browser to make a request to that network, which will receive your IP address and browser information in the ordinary course of serving the file. No cookie is set by us for this purpose. If you prefer to avoid such requests entirely, most browsers offer per-site controls for remote image loading.

13. Changes to this policy

We review this policy at least annually and whenever we make a material change to how we handle personal information.

• The version number and last-reviewed date at the top of this page always reflect the current text.
• For material changes we give at least thirty days' notice by email to enrolled participants and by a notice on this site.
• Where a change requires consent, we ask for it before the change takes effect rather than treating continued use as agreement.
• Previous versions are available on request from [email protected].

14. Contact details and complaints

For anything relating to this policy, write to [email protected], or to the Data Protection Lead at the postal address below. We acknowledge within five working days.

Black Technology Mentorship Program
Attn: Data Protection Lead
1200 Innovation Way, Suite 400
Atlanta, GA 30308
United States

If you are not satisfied with our response you may complain to your data protection regulator. In the United Kingdom that is the Information Commissioner's Office; within the European Economic Area it is the supervisory authority in the country where you live, work, or where the issue arose. You do not need to complain to us first, though we would welcome the chance to put matters right.

How to contact us about this policy

Write to [email protected], or by post to the Legal Team, Black Technology Mentorship Program, 1200 Innovation Way, Suite 400, Atlanta, GA 30308, United States. We acknowledge every enquiry within five working days and aim to resolve substantive questions within thirty days.

Use the contact form