Privacy Policy

Last Updated: May 15, 2023 inc. (iCouldBe) is an online mentoring program whose mission is to provide high school students with an online community of professional mentors, empowering teens to thrive in school, plan for future careers, and achieve in life. iCouldBe respects the concerns of our users and is committed to protecting the privacy of the information that is collected through your use of our e-mentoring platform. iCouldBe has created this privacy policy to clearly outline how your personal information is used and the following discloses our information-gathering and dissemination practices.

By using iCouldBe you are indicating your agreement to these Privacy Policies. iCouldBe reserves the right to update these Privacy Policies at any time and without prior notice. The revised Privacy Policies will apply to all information that iCouldBe may have about you.

The Last Updated field at the top of this page indicates when these Privacy Policies were last modified. You should review these Privacy Policies on a regular basis as your continued use of the iCouldBe platform indicates your agreement with the Privacy Policies that are posted at the time of your use.

iCouldBe is the sole owner of the information collected on this site, with the exception of student data as may be required by state or federal law.

Who uses iCouldBe?

iCouldBe is an online mentoring service for youth and adults. Access to iCouldBe is provided through partner organizations that have contracted with iCouldBe to make the e-mentoring platform available to their students or youth.

Adults are either Mentors or partner organization Administrators. “Administrators” includes administrators, coordinators, technical support staff, teachers or other individuals who access iCouldBe on behalf of a partner organization. “Mentors” are generally the adults paired with students and youth who participate in the iCouldBe program. Mentors must be at least 21 years old, a matriculated college student who is at least 18 years old, or a member of the military who is at least 18 years old. Only mentors in the iCouldBe approved peer programs can be under 18 years old.

Youth users of iCouldBe are “Mentees”. Mentees must be at least 13 years of age. If a youth under the age of 13 wishes to use the iCouldBe online mentoring platform their parent or guardian must first provide consent to iCouldBe. Consent forms can be obtained from the youth’s school or partner organization through which access to iCouldBe was granted. Please see the COPPA section below for additional information. “Alumni” are Mentees who have completed the iCouldBe program and continue using iCouldBe in order to benefit from the mentorship provided. Within this Privacy Policy the term Mentee will include Alumni, too, although Alumni may not have access to all functionality.

iCouldBe staff, members of the iCouldBe Board of Directors, corporate partners and some third-party vendors may also have access to the iCouldBe online mentoring platform as regular users or for testing and demonstration purposes.

Disclosure of Personally Identifiable Information with Mentees is Not Permitted

In order to ensure a safe environment for our youth, iCouldBe does not allow Mentors and Mentees to share personally identifying information with each other, nor do we allow Mentees to share personally identifying information with other Mentees. Personally identifiable information is any information that may allow another Mentee to personally identify you, including but not limited to your last name, email addresses, telephone numbers, street address, city you live in, the name of your employer, social media information or any other self–identifying information. Personally identifiable information may directly or indirectly identify you (for example, a parent's name or address). Failure to comply with this policy in any part of the iCouldBe program may result in the user’s access being restricted. iCouldBe does allow, share and display Mentee and Mentor usernames and first names within the iCouldBe program.

Usage Monitoring

Automatic filters monitor email communications between Mentee and Mentor to ensure that no personally identifiable information has been shared. If personally identifiable information is detected iCouldBe staff may reject the email and the user and or administrator will receive an automated message with a reminder of the privacy policy rules. If personally identifiable information is detected in other parts of iCouldBe it may be made unreadable or flagged for review by iCouldBe staff who may delete it.

Throughout the school year, each Mentee’s usage and the interactions with their Mentor, is monitored by the Mentee’s teacher or program Administrator to help administer the program. The teacher or program Administrator cannot view any Mentor’s personally identifying information unless a partner organization recruits and registers their own mentors in the iCouldBe program

iCouldBe may collect information from its users at several different points in our platform. Please see the section How Data is Used by iCouldBe below for information on how this data may be used.


Mentors voluntarily provide personally identifiable information, such as first and last name and email address when inquiring to be a Mentor. When registering as a Mentor, individuals must provide personally identifiable information such date of birth, home address and other information.

Mentors must undergo a background check prior to being approved as a Mentor. iCouldBe uses a third-party vendor to conduct the background checks and individuals must provide to the vendor their social security number. This information is provided directly to the third-party background check vendor and iCouldBe does not have access to it. iCouldBe does not require its third-party vendor to conduct the background checks when working with other organizations who confirm in writing that they have already background checked their Mentors. In such cases, these organizations are responsible for managing and protecting Mentor personally identifiable information submitted to conduct the background checks.

Mentors are asked to complete a profile that requests information such as their educational, work and professional experiences as well as their personal interests and other information. During registration Mentors are required to answer certain questions related to career categories and years of experience. Other questions are optional and no personally identifiable information is requested as part of the profile. iCouldBe does allow, share and display Mentee and Mentor usernames and first names within the iCouldBe program. We may share employee usernames, first and last names, email addresses and background check results with company partners where the employee works for grant reporting purposes.


In order to use iCouldBe, Mentees must create a user-name and fill out a registration page that includes their first name, last name and email address in order to participate in the program. Mentees may participate in a survey that requests demographic information as well as a series of questions including some about prior experience with Mentors. Please see the section How Data is Used by iCouldBe below for information on how this data may be used.

The iCouldBe program asks Mentees to complete a profile page as well as a range of activities where limited personally identifiable and non-identifiable information may be requested. Personally identifiable information collected in these areas is used only for internal monitoring and reporting purposes. iCouldBe does allow, share and display Mentee and Mentor usernames and first names within the iCouldBe program.

Mentees and Mentors may also have the ability to email, chat or write posts in other spaces that are within the password protected, monitored and secure iCouldBe site and can be viewed by other iCouldBe users. The Mentee’s and Mentor’s user name, first name and profile information is visible with the information they post. Mentees are only permitted to share their user name and /or first name when using the iCouldBe program. Please refer to the section above titled Disclosure of Personally Identifiable Information with Mentees is Not Permitted for further information.


iCouldBe Program Staff provide logins to Administrators, Teachers and anyone facilitating the iCouldBe program who require access to the administrative portal. Logins are generated after said users provide details such as name and contact information, including email address and telephone number.


iCouldBe uses surveys to gain feedback from users in order to monitor, evaluate and improve the programs and services offered. Only aggregated and non-personally identifiable information collected through the surveys will be used for management reporting purposes. iCouldBe conducts surveys in two ways, 1) using proprietary software that stores the data within our databases, and 2) through use of a third-party survey provider. Users should refer to the third-party provider’s privacy policy for information on how they use and protect data that is stored on their systems or that they may collect directly.

Information that is Automatically Collected from Users

Information collected automatically is used to enable individuals to register for and use the iCouldBe online mentoring platform. This information is used to allow iCouldBe to learn how the platform is used in order to monitor network performance, develop enhancements and for other purposes that support iCouldBe’s program.

Cookies, log files and other types of technology may be used to help us understand if you have used our platform before, how often you do, the type of device or computer you are using, your IP address, the operating system, for how long you use the platform when you login, the pages you visit and other information that is helpful for iCouldBe to know in order to support the platform. Most, but not all, cookies are deleted upon a user logging off the iCouldBe platform. For example, on computers where there are multiple users iCouldBe must maintain a cookie in order keep track of the different users who login. The cookies that iCouldBe uses allow us only to track user interaction with the iCouldBe platform and do not allow us to track usage on other websites.

If you wish to disable or stop accepting cookies you can find instructions on how to do this under the "help" menu on most browser toolbars. By disabling cookies you may not be able to access iCouldBe.

How Data is Used by iCouldBe

iCouldBe uses information that is collected, both voluntarily and automatically, for administrative and management purposes. This usage may include compiling non-personally identifiable information for reporting to funders, corporate partners or other parties, such as researchers or external evaluators.

iCouldBe may use Mentee and Mentor quotes and comments in marketing, training, fundraising, social media, or other similar initiatives and will only use fictional user names, unless written approval to use user names or real names has been given.

iCouldBe may use Mentor contact information collected for fundraising purposes including sending communications through newsletters, individual emails and regular mail.

iCouldBe will not sell, share, or rent any personally identifiable information entered by you, or collected through your use of the iCouldBe e-mentoring platform, to third-parties for their own marketing or commercial purposes. You will only receive promotional material from our partners and advertisers if you request it.

iCouldBe may share non-personally identifiable information with third-parties or service providers with whom we have contracted to provide services. These third-parties are only authorized to use or disclose your information as may be necessary to perform the services on our behalf for which they have been hired and to comply with legal requirements. For example, iCouldBe provides de-identified information to third-party data analysis organizations to allow them to assist iCouldBe in learning how the platform is being used.


If iCouldBe becomes aware or suspects that a Mentee may be a victim of sexual, emotional or physical abuse, that a Mentee has or is planning to do harm to him/herself or others or if a Mentee confesses to involvement in any illegal activity, iCouldBe may be required to report this information to the program Administrator for the organization that provided access to iCouldBe. iCouldBe may also be required to share information with law enforcement as required by law.

We reserve the right to release information to the proper authorities, because of a user violation of our standards or because of unlawful acts, if the information is subpoenaed, and if we deem it necessary and/or appropriate.

Research and Analytics

iCouldBe uses the data collected for research purposes to improve our program and understand how users benefit from using iCouldBe. iCouldBe works with academic or other third-parties to develop research tools and help us analyze the data collected. iCouldBe only provides anonymous data to these third-parties.

iCouldBe uses proprietary analytics tools in order to track users on our platform, and to analyze and gain knowledge from the usage data that is collected. iCouldBe may use third-party analytics providers, such as Google Analytics, to understand how our platform is used.

Financial Donations

iCouldBe provides individuals with the ability to submit on-line donations by credit card. The donation page is accessible from the public iCouldBe website. Individuals who register to be Mentors are also able to access the donation page from within the logged in site. When making online donations users will be asked to provide information including their name, contact information (including mailing and email addresses), credit card number and billing address, expiration date and security code. iCouldBe uses a secure server (SSL) to process your credit card transactions and this encryption process protects your credit card information while it is being transmitted for authorization. iCouldBe retains your name, contact information and amount donated for required reporting purposes and for future fundraising communications; we do not retain your full credit card information.

Third-Party Sites

The iCouldBe platform contains links to other sites. iCouldBe is not responsible for the privacy practices or the content of linked web sites. Any information you provide to a third-party, or that is automatically collected by the third-party as a result of your use of their website or content, is subject to the third-party’s privacy policy. We recommend that you review the privacy policies and practices for each third-party site that you chose to access. iCouldBe is not responsible for any information shared with or collected by any third-party website that you access through a link on iCouldBe.


iCouldBe uses a third-party provider to distribute newsletters. iCouldBe provides email addresses, names, school name as well as other information in order to enable the third-party provider to provide this service. The third-party provider is required to use the data only to provide the services for which they are contracted by iCouldBe. Users should refer to the third-party provider’s privacy policy for information on how they use and protect data they may collect directly.

Data Protection & Security

iCouldBe considers the protection of privacy and the information users provide to be a top priority. iCouldBe has a range of security protections in place to protect against unauthorized access, misuse, loss or alteration of information that iCouldBe has collected. These protections include the use of perimeter firewalls, limited inbound ports, Microsoft System Center Endpoint Protection (SCEP), regular security patches, and Transport Layer Security (TLS) which is the successor protocol for SSL.

iCouldBe follows best practices for user authentication. A password strength meter is used to assist users with for password creation. All user and admin passwords are encrypted with a strong one-way hash before being stored in the database. The passwords cannot be decrypted.

If you believe that your user name and password have been accessed without your authorization, or that someone has posted your personal information or something under your user name without authorization, you must contact iCouldBe using the email address provided under How to Contact iCouldBe at the end of this Privacy Policy.

Assistance to Delete Information or to Terminate Access

If any of the information you provide us changes or if you no longer desire our services, we will attempt to provide a way to correct, update or remove your personal data provided to us. This can be done by contacting iCouldBe using the email address provided under How to Contact iCouldBe at bottom of this Privacy Policy.

Children’s Online Privacy Policy Act (COPPA)

It is iCouldBe’s intent to comply with all COPPA requirements. If the parent or guardian of a user under 13 years of age would like to review the information that has been collected by iCouldBe they can gain access to this information by asking their child for their user name and password, by contacting their child’s teacher or program Administrator or by contacting iCouldBe by email. If a parent or guardian of a child under 13 years of age would like some or all of the data that has been collected deleted or to request that access to iCouldBe be terminated, they should email us. Our email address can be found under How to Contact iCouldBe at the bottom of this Privacy Policy.

Additional Policies

It is iCouldBe’s intent to comply with other major federal and state requirements including:

  • The Family Educational Rights and Privacy Act (FERPA) 20 U.S.C. § 1232g; 34 CFR Part 99
  • Protection of Pupil Rights Amendment (PPRA) 20 U.S.C. § 1232h
  • Student Online Personal Information Protection Act (SOPIPA) California Senate Bill 1177
  • Pupil records: privacy: 3rd-party contracts: digital storage services and digital educational software (AB 1584) California Assembly Bill 1584

How to Contact iCouldBe

If you have any questions about this Privacy Policy, the practices of iCouldBe, or your dealings with this website, you can reach us by email at or regular mail at: Inc.
222 Broadway, 19th Floor
New York, NY 10038

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of New York. Exclusive jurisdiction for any claim or action arising out of or relating to these Privacy Policies or your use of this website shall be filed only in the federal courts located in New York.