Trust Center
Privacy, Ethics, and Transparency
Our framework for responsible operation: everything you need to know about how we protect data, children, and apply AI ethically.
Data Processing Authorization
Legal framework under Law 1581 of 2012 regarding personal data collection, use, and transfer, detailing security principles and subject rights.
Read full policy →Privacy and Security
Encryption protocols, international standards, and incident response measures to protect information integrity and the safe use of AI.
View commitments →Terms of Use
Usage conditions for SHAIA, including AI operation, user profiles, educational licenses, and MENTU's intellectual property.
Explore terms →Privacy Notice
Transparent information on algorithmic transparency (ShaIA), exercise of data rights, and privacy commitment.
View notice →Data Processing Authorization
In order to comply with current data protection legislation, especially Law 1581 of 2012, Decree 1377 of 2013, and Decree 1074 of 2015 (as well as any other regulations that modify, add, complement, or develop it), we hereby inform you of the relevant aspects regarding the collection, use, transmission, and transfer of Personal Data that the company MENTU EDUCACIÓN S.A.S. (hereinafter "MENTU") domiciled in the city of Bogotá, at Calle 79b #5-81, with telephone (+57) 320 4550793, identified with NIT No. 901.753973-0, and email admin@mentu.co as Controller or Processor of your Personal Data, by virtue of the applicable law or the authorization granted by you to carry out such processing and management.
In this Personal Data Processing Policy (the "Policy") you will find the organizational and legal guidelines under which MENTU processes your data, the purpose, your rights as a data subject, as well as the internal and external procedures for the exercise of such rights.
In accordance with the provisions of Article 15 of the Political Constitution of Colombia, and applicable legislation, we have a clear privacy and protection policy for your Personal Data: we do not obtain personal information from third parties who have a commercial, labor, educational cooperation, or legal relationship with MENTU, including you, students, parents, teachers, users, employees, or providers, unless they have voluntarily provided it through their prior, express, and informed consent.
INTRODUCTION.
MENTU's main corporate purpose is the development of new complementary learning models for education, based on the best pedagogical, educational, technological, and digital practices, with the aim of complementing education and promoting access to it for thousands of people in Latin America, starting with Colombia. The activities carried out by MENTU in the development of its corporate purpose are supportive of education and serve the general interest to the extent that they benefit specific population groups: • Children and adolescents. • Educational institutions. • Teachers. • Families. In the development of relationships established with its stakeholders, MENTU receives personal information of a private, public, and in some cases sensitive nature. The data managed and processed by MENTU are of a private nature and/or potentially of a sensitive nature, thus information confidentiality is guaranteed.DEFINITIONS
For the interpretation of this Policy, we ask you to take into account the following definitions: • PERSONAL DATA: Any information linked to or that can be associated with one or more determined or determinable natural persons; • SENSITIVE DATA: Those data that affect the intimacy of the Subject or whose misuse can generate discrimination; • DATA PROCESSOR: Natural or legal person, public or private, who by itself or in association with others, carries out the processing of Personal Data on behalf of the Data Controller; • PERSONAL DATA PROCESSING POLICY OR POLICY: Refers to this document, as the Personal Data Processing Policy applied by MENTU in accordance with the guidelines of current legislation on the matter; • PROVIDER: Every natural or legal person who provides some service to MENTU and its community by virtue of a contractual/obligatory relationship; • CLIENT: Every natural or legal person with whom MENTU enters into a contract for the provision of services; • DATA CONTROLLER: Natural or legal person, public or private, who by itself or in association with others, decides on the database and/or the Processing of the data; • DATA SUBJECT: Natural person whose Personal Data is the object of Processing, whether Client, provider, employee, teacher, user, or any third party who, due to a commercial or legal relationship, provides Personal Data to MENTU; • TRANSMISSION: refers to the communication of Personal Data by the Controller to the Processor, located within or outside the national territory, so that the Processor, on behalf of the Controller, processes Personal Data; • TRANSFER: refers to the transmission and/or storage of data originally collected in Colombia, to another country where they will be processed by a Data Processor with the explicit guidelines determined by MENTU in the Policy. • PROCESSING: Any operation or set of operations on Personal Data, such as collection, storage, use, circulation, or suppression. For the understanding of terms not included in the previous list, you should refer to the current legislation, especially Law 1581 of 2012 and Decree 1377 of 2013, giving the sense used in said norm to terms whose definition there is any doubt about.GUIDING PRINCIPLES APPLICABLE TO THE PROCESSING OF PERSONAL DATA.
The processing, management, and protection of Personal Data carried out by MENTU as Controller and/or Processor of information will be subject to the following principles, which will be applied and interpreted in a harmonic, systematic, and integral way in all activities: • Legality: The Processing of Personal Data carried out in accordance with this policy is a regulated activity that must adhere to what is established in the norms that develop the matter. • Purpose: The Processing of Personal Data must obey a legitimate purpose, consistent with the constitution and the law, which must be informed precisely, previously, and concretely to the subject. • Freedom: Processing can only be exercised with the prior, express, and informed consent of the subject. Personal Data may not be obtained or disclosed without prior authorization or absence of a legal mandate that relieves consent. • Principle of Truthfulness: Information subject to Processing must be true, complete, exact, updated, verifiable, and understandable. Processing of partial, incomplete, fractioned, or misleading data is prohibited. • Transparency: In Processing, the right of the Subject to obtain from the Data Controller or the Data Processor, at any time and without restrictions, information about the existence of data concerning them must be guaranteed. • Restricted Access and Circulation: Personal Data collected or processed by MENTU will be used only within the scope of the purpose and authorization granted by the Data Subject, therefore, they may not be accessed, transferred, assigned, nor communicated to third parties without prior authorization. Personal Data, except public information, may not be available on the Internet or other mass disclosure or communication media, unless access is technically controllable to provide restricted knowledge only to the subjects or authorized third parties. • Security: MENTU, in its capacity as controller or processor of Personal Data processing as the case may be, will adopt the physical, technical, and administrative security measures it finds necessary to provide security to the records, avoiding their alteration, loss, leak, consultation, use, or unauthorized or fraudulent access. • Confidentiality: All persons involved in the Processing of Personal Data that do not have a public character are obliged to guarantee information confidentiality, which extends even after their relationship with any of the tasks that Processing comprises has ended. • Temporality: Once the purpose for which the information was collected is exhausted, MENTU must cease its use, except for information that must be preserved in compliance with legal provisions. • Special Protection of Sensitive Data: MENTU does not collect nor will process Personal Data of a sensitive nature unless expressly authorized by the subject and in those legal cases where consent is not required. Sensitive information that may be collected will have a special level of protection.USE AND PURPOSE OF PROCESSING
The processing that MENTU will perform acting as Controller and/or Processor of databases will be that of collecting, storing, processing, using, transmitting Personal Data, strictly following the guidelines established by Law 1581 of 2012, and Decree 1377 of 2013, with the following purposes as the case may be: Personal Data are used for: • Execution of agreements, conventions, and/or commercial or civil contracts signed by MENTU. • Registration and profile creation for the use of the MENTU platform under any of the modalities selected by the teacher or Client. • Payment of contractual obligations. • Sending information to government or judicial entities by express request of the same. • Support in external/internal audit processes. • Sending/Receiving messages for commercial, informative, academic, pedagogical purposes or those related to the development of students who are part of MENTU. • Registration of information of administrative employees, teachers, students, and parents and/or those responsible for minors linked to MENTU in the database, as appropriate. • Registration of provider information in MENTU's database, as appropriate. • Registration of information of applicants to enter into donation contracts or making investments in MENTU's database, as appropriate. • Contact with employees, providers, teachers, parents, and/or legal representatives of minors and students, for sending information related to the contractual, commercial, and obligatory relationship that takes place with each of these Subjects. • Collection of data for compliance with duties that, as Controller and/or Processor of information and Personal Data, correspond to MENTU. • For security purposes or fraud prevention and prevention of information incidents and information leaks. • To provide those linked to MENTU with platform licensing services. • Inform about new services offered by MENTU. • Achieve efficient communication between MENTU and information subjects and thus facilitate compliance with its corporate purpose. • Comply with obligations contracted with users, Clients, contractors, providers, and employees of MENTU, as well as when necessary with judicial and administrative entities in compliance with the law. • Management and delivery of information to third-party Processors of information contractually linked to MENTU and government education entities that require it. • Accounting and tax effects, payment and collection of invoices, payroll payment, and others. • Management of information that the user generates with the use of the system to provide services and make the platform a comprehensive academic tool; • To generate information for internal statistical purposes, study, and personalization in the educational field and development of MENTU services. • To have a demographic and socioeconomic context of students and be able to analyze how these variables impact the interaction and usability of the platform; For this purpose, sensitive data will be collected such as: name, age, grade, school, socioeconomic level, digital level, voice, parents' education, information on behavior and student performance in their interaction with the platform. We also inform you that, in your capacity as Provider, contractor, Client (parent and/or student) or Teacher your Personal Data are only collected for the identification of your position, trade, profession or quality as a merchant or for the identification of your educational cooperation relationship, data that in some cases are of a public nature, your prior, express, and informed authorization not being required, but in other cases Personal and/o sensitive Data that are subject to the authorizations given by you in favor of MENTU. In any case, even being of a public nature, you are empowered to exercise the rights that protect you as a Personal Data Subject. If you provide us with Personal Data, this information will be used only for the purposes indicated here, and we will not proceed to sell, license, or disclose it outside MENTU unless (i) you expressly authorize us to do so, (ii) it is necessary to allow our contractors or agents to provide the services we have entrusted to them, (iii) for the purpose of providing you with our pedagogical and/or educational services, (iv) it relates to a merger, consolidation, acquisition, divestiture or other restructuring process, or (vi) as required or permitted by law. In order to implement the purposes described above, your Personal Data may be disclosed for the purposes provided to human resources personnel, Processors, consultants, advisors, contractors, teachers, and other persons and offices as appropriate. MENTU may subcontract third parties for the processing of certain functions or information. When we actually subcontract with third parties the processing of your personal information or provide your personal information to third-party service providers, we warn said third parties about the need to protect said personal information with appropriate security measures, we prohibit the use of your personal information for their own purposes and prevent them from disclosing your personal information to unauthorized others. In the same way, MENTU may transmit or receive (as appropriate) Personal Data to/from other national or foreign companies, as well as third-party contractors, for reasons of security, administrative efficiency, agreements, conventions, and better service, in accordance with the purposes stated here. MENTU has adopted the case measures so that those companies implement in their jurisdiction and according to the laws applicable to them, security and Personal Data protection standards at least similar to those provided in this document and in general in MENTU's Policy on the matter. In the case of Personal Data transmission, the relevant transmission contract will be signed in the terms of Decree 1377/13. Additionally, we inform you that once the need and purpose of Processing your data ceases, they may be eliminated from MENTU's databases or archived in secure terms so that they are only disclosed when necessary according to law.Collected Data.
Identification data for the registration process, such as name, email, date of birth, institution, city, identity document, gender, and contact information. We also collect information about user behavior in the application to improve our product, as well as course description and special class considerations. Indirect collection of unrequested but necessary information for the context of intelligent assistants shared by the user may exist. All data are stored with robust encryption measures and with limited access. Contact information: will be used only for the management, execution, and communication related to the contracted project. It will not be used for marketing, advertising purposes, or for sending commercial communications other than those strictly necessary for the provision of the service. WARNING: The user undertakes not to disclose personal or sensitive information of third parties without having the corresponding express authorization or without there being a formal processing agreement or relationship that empowers them to act as processor of said data. The user will assume responsibility for the insertion of any information without the due authorization.DATA SUBJECT RIGHTS.
In accordance with Article 8 of Law 1581 of 2012, the rights that as a Subject assist you in relation to your Personal Data are: • Know, update, and rectify your Personal Data before MENTU as the Data Controllers or Data Processors. This right may be exercised, among others, against partial, inaccurate, incomplete, fractioned, misleading data, or those whose Processing is expressly prohibited or has not been authorized; • Request proof of the authorization granted to MENTU as Data Controller except when expressly excepted as a requirement for Processing; • Be informed by MENTU, as Data Controller or by the Data Processor, upon request, regarding the use it has given to your Personal Data; • Present complaints before the Superintendence of Industry and Commerce for violations of the provisions of this law and other norms that modify, add, or complement it; • Revoke authorization and/or request data suppression when Processing does not respect constitutional and legal principles, rights, and guarantees; • Request elimination of your personal information when you so consider. • Access for free your Personal Data that have been subject to Processing. Within this Policy you will find the procedure through which MENTU guarantees the exercise of all your rights.PROCEDURE FOR THE EXERCISE OF YOUR RIGHTS AS DATA SUBJECT
If you have questions about this Policy, or any concern or claim regarding the administration of the Policy, please contact us through any of the following means: MENTU EDUCACIÓN S.A.S. Telephone: +57 320 4550793 Email: admin@mentu.co In the case of exercising a complaint, rectification, update, consultation, or request for access or data subtraction, you should send it to the Personal Data Protection Officer: oficial.datospersonales@mentu.co Keep in mind that once you inform the responsible area within MENTU, depending on which of them your petition is directed to, the consultation, request, or complaint will be processed. Your request or petition in relation to your Personal Data must be attended within a maximum term of fifteen (15) business days from the receipt of the request or petition. For the correct and complete consideration of your petition, request, or claim, we ask you to provide the identity of the applicant, their identification number, the address for notifications/responses and the documents you want to enforce. If your request or petition does not have sufficient data and facts to allow MENTU to attend it correctly and completely, you will be required within five (5) days following the receipt of the request, petition, or claim to correct its faults. After five (5) days have passed from the date of the requirement, if you as the applicant have not corrected as required, MENTU as recipient of your petition understands that you have withdrawn your request.SECURITY MEASURES
MENTU, as development of the Processing of Personal Data it collects or for which it is responsible as the case may be, will adopt all physical, technological, and administrative security measures it deems pertinent according to the data it manages, which will be applicable in all cases to the areas in charge. MENTU, in compliance with statutory law 1581 of 2012 and the requirements established by the Superintendence of Industry and Commerce will communicate to the latter any case of information security failures that may have caused loss, theft, consultation, or fraudulent modification, and the measures taken in this regard. Here you can consult our information security policy https://mentu.co/politica-securityDELIVERY OF PERSONAL DATA TO ADMINISTRATIVE AND JUDICIAL AUTHORITIES
In case authorities with jurisdictional or administrative functions request from MENTU the consultation and/or delivery of Personal Data recorded in its databases; such request will be evaluated internally, and in case of complying with all legal requirements, the case will be documented internally and added to the history that MENTU manages internally, this in compliance with the norms governing the matter.MODIFICATION OF THIS POLICY
This Policy can be modified at any time, reason for which we recommend you review regularly or periodically on our website https://mentu.co/autorizacion-de-tratamiento-de-datos. Nonetheless, MENTU will notify according to the Law substantial changes not only in the mentioned link, but will also make efforts to notify its users through communications on the platform, email among others.THIRD PARTY CONTENT:
It is possible that the MENTU platform links to third-party websites or offers content that is not owned by MENTU, so it will have no control over that material and they will be governed by the data treatment and privacy policies of those third parties. MENTU is not responsible for the data treatment and privacy policies of any third party.SENSITIVE DATA:
Through this Policy, I acknowledge and accept that MENTU may perform information Processing, for the purposes established here, which, by its nature, can be considered as sensitive data. I understand that, as Subject, I have the facultative capacity to answer and/or provide sensitive data or information when requested for its collection and Processing. Therefore, and through this document, I have been informed that I have the right not to answer questions related to these data and/or to provide or not the information requested from me, and that no activity can be conditioned on providing sensitive Personal Data.DATA OF CHILDREN AND ADOLESCENTS:
Through this Policy, I acknowledge and accept that MENTU will perform information Processing, as Processor or Controller, for the purposes established here, of children and adolescents that will be subject to the following Law requirements: i) that it responds to and respects the superior interest of children and adolescents, ii) that it ensures respect for their fundamental rights, iii) that once the above are fulfilled, the legal representative of the child or adolescent will grant authorization after the minor's exercise of their right to be heard, an opinion that will be valued taking into account maturity, autonomy, and capacity to understand the matter. Through this document, I have been informed that I have the right not to answer questions related to these data and/or to provide or not the information requested from me.VALIDITY
This Personal Data Processing Policy in charge of MENTU, who acts as Controller and/or Processor of third-party information in parallel has been approved and therefore will govern as of February 24, 2026. Know our privacy notice: https://mentu.co/aviso-privacidadPrivacy and Security
All storage systems are encrypted with robust algorithms.
Information in transit is encrypted throughout its journey.
Storage systems comply with international security and privacy standards.
Strict access measures are applied, limiting entry only to authorized personnel.
Access to information for assistants is restricted to a brief period and is maintained in our own systems.
Sharing data with third parties.
Data is not sold or assigned to third parties for profit or research purposes. Data may be shared with third parties authorized by the user, provided that: • They implement strict security measures. • They process the data only for authorized purposes. • There is a data processing agreement and a commitment not to disclose to other third parties.Security measures.
We continuously seek to improve security measures and take advantage over existing threats. Here you can view our complete information security policy.Systems security and data administration.
• Encryption with robust algorithms at rest and in transit. • Continuous update and maintenance of systems. • Permission segmentation according to functions and data access. • Backup systems against failures. • Network segmentation and responsibilities. • Constant and active monitoring. • Risk analysis and application of control measures.Provider administration.
• Verification of confidentiality and privacy compliance. • Periodic validation of compliance mechanisms. • Data sharing with usage restrictions.Incident response and business continuity.
• Monitoring and alert system. • Automatic scaling to guarantee availability. • Documentation and procedures for recovery from failures or incidents. • Automated recovery mechanisms. • Hiring providers with high reliability and availability. In the event of a security incident: • Immediate containment and isolation of the threat. • Investigation based on the NIST Framework. • Notification to users and affected parties according to regulations. • Implementation of remediation and prevention measures.Secure AI development.
• Use of secure models to support our intelligent assistants. • Development of functionalities includes multiple validation processes. • Validation and reliability testing, bias reduction, and non-discrimination by human reviewers throughout the cycle. • Multidisciplinary team in the entire development process. • Optimal use of AI, limiting shared data use to the necessary minimum. Here you can view our secure AI use policy.Aligned regulations and regulatory compliance.
Our organization is committed to complying with the following regulations and rules regarding data protection and privacy: Law 1581 of 2012 (Colombia). Statutory law for personal data protection. • We implement technical measures to guarantee personal data security, including information encryption in transit and at rest. • We apply principles of purpose, freedom, truthfulness, transparency, restricted access, and circulation. • We guarantee data subjects' rights to know, update, and rectify their personal data. • We have clearly defined and accessible information processing policies. • We timely notify any security incident according to the guidelines of the Superintendency of Industry and Commerce. COPPA (Children's Online Privacy Protection Act). • We obtain verifiable parental consent before collecting personal information from children under 13. • We limit the collection of data from minors exclusively for authorized educational purposes. • We maintain transparent privacy policies in clear and accessible language for parents and guardians. • We implement special security procedures for children's information. • We provide parents with the ability to review, delete, and control information collected from their children. FERPA (Family Educational Rights and Privacy Act). • We guarantee that educational records are only accessed by authorized personnel with strictly limited permissions according to their function. • We implement technical and administrative controls to prevent information leaks and protect educational record confidentiality. • We respect and facilitate the exercise of parents' rights to: - Access their children's educational records. - Request corrections in case of inaccurate information. - Consent to the disclosure of identifiable information. - File complaints for non-compliance. GDPR (General Data Protection Regulation). • We process personal data in a lawful, fair, and transparent manner. • We implement appropriate technical and organizational measures to guarantee an adequate security level. • We respect the rights of data subjects (access, rectification, erasure, restriction, portability, opposition). • We maintain records of processing activities when applicable. • We perform impact assessments when processing involves high risk for people's rights and freedoms.General compliance measures.
• We conduct continuous cybersecurity and privacy training and awareness for all our personnel. • We carry out periodic audits to verify regulatory compliance. • We regularly update our policies and procedures as regulations evolve. • We designate data protection and regulatory compliance officers. • We implement the "Privacy by Design" principle in all our developments and operations. • During all phases of AI implementation and deployment we implement human-in-the-loop.Data flow diagram.
Below you can view a diagram of how we collect data in Shaia, what data we collect, and how we process and present it. You can click on it to view it in an independent tab for better visibility.Terms of Use
What is MENTU?
MENTU EDUCACIÓN S.A.S (hereinafter MENTU) is a company duly constituted under the laws of Colombia, with NIT No. 901753973-0 and domiciled in the city of Bogotá D.C., with address at Cl. 79b #5-81, telephone +57 320-455-0793 and email info@mentu.co that develops and implements technology and innovation activities that promote the adoption of pedagogical, educational, technological and digital practices based on research with the aim of complementing education and promoting access to quality learning in Latin America and the Caribbean.Introduction:
This document contains the Terms and Conditions of Use (hereinafter "the Terms") of the SHAIA Web Platform (https://shaia.mentu.co/) owned by MENTU. Shaia is an assistant for teachers, which uses artificial intelligence to integrate high-quality resources and methodologies to help teachers improve student learning, reducing effort time. Shaia offers tools (called superpowers) that help in pre-class work (planning with best practices that recognize student variability and high-quality curated resources), during (recording relevant information privately) and after (pedagogical reflection and connecting what happened in the classroom with following plans).How to read these Terms?
The MENTU Terms and Conditions of Use are divided as follows: first, general use conditions for any User are listed. Subsequently, specific use conditions per profile will be developed. Consequently, you can determine which parts apply to you and must be read and which do not.General Conditions:
Object: The following Terms aim to regulate and constitute the agreement between MENTU and the User governing access and use of the contents, functions, and products and services available on the Web Platform (https://shaia.mentu.co/, https://contenido.mentu.co) and its mobile version (hereinafter "the Platform"). Please note that these Terms apply to teachers, authorized third parties, collaborators, contractors, and/or any natural or legal person entering the platforms. Definitions: The following definitions will help you navigate the Terms. • MENTU: refers to MENTU EDUCACIÓN S.A.S its subsidiaries, branches and other commercial divisions. • The Platform: means the Web Platform: https://shaia.mentu.co/ and the content available at https://contenido.mentu.co, and its mobile versions owned and/or created by MENTU. The main functionalities of the platform are described in the "Registered User Profile" section. • User(s): refers to the natural or legal person visiting and using the web platform and mobile application created and owned by MENTU regardless of gender.Use of Artificial Intelligence on the Platform.
The Platform uses Large Language Models, Retrieval-augmented generation, function calling and multi-agent prompt engineering workflows to support teachers throughout the entire teaching cycle. Large Language Models: The Platform uses a type of generative artificial intelligence (AI) called Large Language Models (LLMs). These are created by third parties (MENTU providers such as OpenAI, ElevenLabs, Google and others) and are used to generate various types of texts in superpowers. Quality Resources, Retrieval-augmented generation (RAG) and Function Calling: To minimize errors or hallucinations that LLMs can make, the platform integrates resources, such as lesson plans and activities selected by the pedagogical team and MENTU allies that serve as a base for AI models (LLMs) to develop generation processes. Mentu's pedagogical team and its allies select pedagogical resources that are indexed so that the AI can, with multi-agent flows (below), search and select the most relevant ones and use them as a base for generation processes. Multi-agent flows: To complete the series of complex and cognitively demanding tasks that Shaia performs for Users, such as planning a sequence of classes taking into account the course characteristics, the Platform creates various agents, systems receive and process information, take decisions like consulting additional information or confirming data with the User and perform actions like generating an activity text or the image accompanying a math problem. For planning an activity, for example, the Platform chains agent work searching for relevant activities or strategies with others translating them and others creating final images and formats shown to the User. Human review (humans in the loop): Mentu's interdisciplinary team, including experts in pedagogy, psychology, ethics and technology periodically reviews random selections of resources generated by the platform and evaluates them in terms of relevance, quality and bias potential. This human review strategy (Human-in-the-loop) seeks that tools, intended to enhance end-user capabilities, are always monitored by humans through internal audits and social impact metrics. For Mentu, supporting teachers is directly linked to the commitment to responsible innovation, where technology acts as an inclusive facilitator, never as a substitute for critical human criteria.Acceptance:
By accessing and using the Platform in any way and for any product or service as a User you are expressing your consent, agreement and understanding of these Terms. In case you do not agree with the obligations and rights of the Terms agreed herein, it is recommended to suspend use of the Platform and request deactivation of your user account if you created it, by contacting admin@mentu.co.Modifications and/or Updates:
MENTU can modify these Terms by publishing them on the Platform and it is understood that as a User you accept and comply with any changes, updates or modifications made. MENTU also reserves the right to modify, adjust, delete or change products or services offered on the Platform at any time and without prior notice. Therefore it may discontinue and/or restrict use at its discretion, including software updates, new functions and/or other elements and functionalities of the Platform. Continued use of the Platform following an update notification will constitute acceptance of modifications. In case of disagreement, the User must immediately cease access to the service and inform MENTU to cancel the account.Binding:
These Terms are binding and govern use of the Platform, its products, services and other content offered by MENTU.User Declaration:
By using, browsing or entering MENTU's Platform, as a User you declare and warrant that i) the use you give to the Platform and its products and services does not violate any local or international law or regulation that is applicable; ii) you will not enter personal information if you are under 18 and not duly represented by your parents or responsible adult; iii) at the moment of creating an account, that the information is true and accurate; iv) you will use the Platform ethically and responsibly, and v) that you have the capacity to understand and accept the conditions and requirements agreed in these Terms. The user undertakes not to disclose personal or sensitive information of third parties without having the corresponding express authorization or without a formal processing agreement or relationship empowering them to act as processor of such data. The user will assume responsibility for insertion of any information without due authorization.Questions, doubts or complaints:
If you have questions, doubts, complaints or claims regarding these Terms, you can contact the following email info@mentu.co with the subject: "PQRS-Terms", or telephone +57 320- 455-0793.Applicable Law:
MENTU's headquarters is in Colombia, so the Terms are governed by the laws of the Republic of Colombia. However services used and provided through the Platform in other countries must respect current regulations of the country from which services are used without detriment to Colombian norms. Any User deciding to access the Platform does so by their own decision and assuming responsibility in case of violating any local applicable law. In case of conflict between Colombian norms and those of another country, provisions best protecting internationally recognized fundamental rights and public order will prevail. MENTU reserves the right to restrict or limit access to the Platform in countries where its use may fail to comply with local regulations or compromise the company's ethical principles. Examples include, but are not limited to: jurisdictions under international sanctions, countries with laws violating human rights, or territories not covered by international data transfer and copyright/intellectual property protection agreements.Conflict Resolution:
Any difference arising relating to these Terms will be solved by an amicable settler jointly appointed by the User and MENTU subject to the Amicable Composition regulation of the Bogotá Chamber of Commerce (CCB). The procedure related to amicable composition is carried out at CCB facilities. Costs caused are borne by the losing party and process expenses and fees will be established according to current CCB rates regarding Amicable Composition.Unauthorized Uses:
Any User of the MENTU Platform, (regardless of whether they have a registered account or not) MAY NOT perform the following activities: • Use MENTU Platform and its products and/or services for creation, transmission, disclosure of messages or content containing images or texts that are obscene, illegal, threatening, defamatory, violent, considered 'spam'. • Use MENTU Platform and its products and/or services for creation, transmission, disclosure of messages or content violating children and adolescent rights established in current regulations. • Use MENTU Platform and its products in ways that are harmful or discriminatory. • Threaten privacy or personal data of third parties. • Violate copyright, trademarks, image rights, patents, business secret, intellectual property, know-how and/or confidential information of a third party without authorization. • Introduce malware (malicious software) intended to harm or interrupt correct functioning of the Platform or third-party computers. • Attempt or exploit any technological vulnerability found on the Platform, violate security measures, access without authorization, extract data or reverse engineer any part of the Platform, its systems, databases, source code, technological infrastructure or related services. • Impersonate another person or perform fraud with false identities. • Perform any illicit act typified in Colombian, international and local norms from where the User accesses MENTU services. • Use automated methods, like bots or scrapers, to collect information from the Platform without MENTU express authorization. Non-compliance with any described use conditions empowers MENTU to take measures and decisions it considers necessary, including legal resources to which it is entitled or cancellation, suspension or deletion of the user account, at its discretion and without prior notice.Prohibition of Commercial Use:
Any commercial use for own benefit of the User or third parties of content and/or products and services hosted, published or made available on the Platform is strictly prohibited. As a User you may not use content object of these Terms to perform, among others, the following activities without Mentu's express written authorization: • Include in promotion of commercial activities or sales of third parties, as well as contests, gifts, raffles and other advertising offers. • Sell or transmit to third parties mentioned contents in exchange for consideration (in kind or not), in any known or to be known physical, electronic and/or magnetic medium. • Enter into any contract or agreement that may generate income or considerations for disclosure and/or reproduction of mentioned contents, without MENTU's due authorization. • Any other involving commercial, advertising or industrial use of contents.Responsibility:
To the extent permitted by law, it is understood that under no circumstances MENTU, its employees, agents, representatives, providers, contractors and/or assignees will be responsible for: • Contents, materials or any information generated on the Platform through use of artificial intelligence systems are designed and fed with resources based on evidence from learning science research. Each development phase—from design to implementation—integrates mechanisms to prevent discrimination and bias, aligned with ethical data management. The platform uses Retrieval-augmented generation (RAG) techniques seeking to ensure information provided is based on theories and resources selected for quality by Mentu's team. However, we recognize that, despite our measures and configurations to guide AI towards appropriate results, the possibility exists that Users generate inappropriate content, either intentionally or due to unexpected system interpretations. Therefore, the User will be solely responsible for use made of the Platform and generated content, committing to use it ethically and according to applicable laws and norms. • Damages regarding software or hardware caused by technical problems affecting the User due to Platform access or use of its functions are User responsibility accessing them at their own account, risk and responsibility. • The User recognizes and accepts that any material downloaded or obtained through the Platform is performed at their own account and risk, being the sole responsible for any damage, loss, cost or expense resulting from mentioned actions. • The User assumes responsibility and exempts Mentu for any damage, virus, malware or harm on computer or mobile device or other compatible device caused or resulting from use, download, access or navigation on the Platform. • The User assumes responsibility and exempts Mentu for personal injuries, property damage or other damages resulting from Platform access or use.Links to sites and third-party content:
The Platform may contain links and/or third-party content. Mentu reviews and performs content curation processes. However, link content provided by the platform may have changed or disappeared without Mentu's knowledge. Therefore, if as user you decide to access any mentioned links, it is understood you do so at your own account and risk exonerating MENTU from any responsibility or claim.MENTU Warranties and Declarations:
Although MENTU strives for the Platform to be available at least 98% of time each day, MENTU, its employees, agents, representatives, providers, contractors and assignees do not guarantee availability and continuity of Platform functioning at all times because it is constantly updated. Nor does it guarantee that the Platform operates permanently and free of failures, nor assumes responsibility for damages suffered by User due to non-use or impossibility of use of information or services and products provided, as well as damages suffered by unauthorized access or misuse of servers or any personal information or User data. Due to the nature of internet and generative artificial intelligence, MENTU, its employees, agents, representatives, providers, contractors and assignees also do not represent or warrant that information or content generated by the Platform, or linked third-party content, is complete and accurate at all times despite reasonable measures and best practices implemented in its processes. As User you assume responsibility regarding interpretation and use of information contained in the Platform, including any damage, loss, cost or expense resulting from any content published or shared through it. As User you understand and accept that content, material and information found on the Platform is provided 'as is' and 'as available', without any warranty either express or implied.Personal Data:
With acceptance of these Terms as User you recognize and accept that MENTU performs Processing of your personal data according to the Personal Data Processing Policy. For more information check the document available at: https://mentu.co/autorizacion-de-tratamiento-de-datos, where you can also check the Privacy Notice. If a User signs additional authorizations with MENTU these will form part of Personal Data Processing and will be integrated to these Terms.Age Requirements:
Access and use of MENTU Platform requires User to be at least 18 years old. Otherwise, parents or a legal guardian will be responsible for creating User account and supplying pertinent information if necessary. On the other hand, it is also necessary to have mentioned minimum age for acceptance of these Terms. In cases where User is a minor, authorization from parents or legal guardian empowered to accept on their behalf must be obtained.Security:
Although MENTU, its employees, agents, representatives, providers, contractors and assignees do everything in their power to maintain User security, they cannot guarantee or represent that unauthorized third parties cannot access or overcome security measures. In case of encountering suspicious activities, every User is obliged to immediately contact MENTU writing to info@mentu.co or telephone +57 320-455-0793.Intellectual Property:
All content, products, services, information, illustrations, courses, videos, interfaces etc., found, obtained or hosted on the Platform are protected by current Colombian and international intellectual property and know-how regulations. In this sense, any content found on the Platform belongs to MENTU or its respective current holders, so any unauthorized use is understood as an infringement of mentioned rights, among other possibilities law assigns to their protection. Any use not comprised in these Terms must be previously authorized in writing by MENTU or respective current legal holders.Copyright:
All works, texts, drawings, software, videos, diagrams, among other content susceptible to copyright protection found on the Platform and/or part of provided service are MENTU and legitimate holders property. Any use contravening these Terms provisions constitutes misuse of works and thus as User you will be subject to legal actions permitted by Law 23 of 1982 and others concurrent. You also cannot reproduce or modify works or content on the Platform. Products created by User: See "RU Use License" section.Distinctive Signs:
Any brand, commercial slogan, logo, logosymbol and/or distinctive sign property of MENTU or legitimate legal holders cannot be used for purposes other than expressed in these Terms. In this sense any sign used or found within the Platform belongs to MENTU or its corresponding holder being protected under respective distinctive signs provisions (Decision 486 of 2000 of CAN, among others) being prohibited misuse without previous written authorization from owners.Know-how:
Elements within content and/or service provided by MENTU protected under know-how (or know-how) figure belong exclusively to MENTU and/or legitimate holders and as User you cannot use them contrary to what established in these Terms, nor attribute or award yourself their ownership.Business Secret:
Any non-disclosed information MENTU or any legitimate holder possesses, that can be used in some productive, industrial or commercial activity, and susceptible to be transmitted to a third party, to the extent that such information is: secret, has commercial value for being secret; and has been object of reasonable measures taken by its legitimate possessor to keep it secret will be understood as business secret. Among them included that referred to nature, characteristics or purposes of products; to production methods or processes, such as platform architecture details; or to means or forms of distribution or marketing of products or services. Thus, whoever lawfully has control of a business secret, is protected against disclosure, acquisition or use of such secret contrary to fair trade practices by third parties.No Assignment:
The above is not interpreted as a transfer (assignment) or a use license authorization for purposes other than established in these Terms or by virtue of Parties, of any of the aforementioned intellectual property assets.Removal:
MENTU reserves at its discretion and without prior notice the faculty to remove any User or suspend temporarily or indefinitely their possibility of using the Platform, if receiving reasonable notification alleging infringement (or reasonable suspicion of infringement) of MENTU or third parties intellectual property and/or know-how rights or violating these Terms in any other way. Above regardless of responsibility assumed for those conducts and regardless of any progress already made on the Platform.Assignment:
MENTU has the faculty and is fully authorized to assign its rights and obligations derived from present Terms, without needing User previous authorization.Divisibility and independence of provisions:
If one or more provisions contained in these Terms are considered null, illegal or ineffective in any aspect, validity, legality, enforceability or efficacy of rest of provisions contained herein will not be affected or annulled by such event.Integrality:
As User you accept that both Personal Data Processing Policy, Privacy Notice and these Terms constitute the totality of Terms and Conditions of Use.User and Password Creation:
For access to some content and execution of Shaia superpowers within the Platform you must create a user and password and become a Registered User. For above, MENTU will request email or phone and a password. Additionally you will be asked to provide name, last name and city of residence. As User you must provide complete and true information and update information when pertinent. Note that account creation under false identity or with incorrect data is prohibited. MENTU reserves right to delete, suspend temporarily or block an account if detecting information supplied is not true. Your email and password aim for individualization and privacy protection of all Users so must not be shared with third parties, understanding these are personal and non-transferable and User is responsible for any consequence derived from disclosure. In this sense, committing to maintain account information confidentiality, including non-disclosure of details to other people or entities, being responsible for immediately notifying MENTU of any suspicious access or unauthorized use. Non-compliance with this notification is understood as a breach and MENTU may delete, suspend temporarily or block definitively the account. The User is sole responsible for actions and activities occurring on Platform through account. Also recognizes and accepts that MENTU is not responsible for i) any damage, loss, cost or expense resulting from any activity derived from unauthorized access to account or ii) any unauthorized activity performed on Platform through account. Any activity performed under email and password is understood as performed by yourself, under own account and risk. MENTU reserves faculty to change some or all requirements for user account creation. In such case, MENTU must send notification with mentioned changes and it is User duty to update account within reasonable period of time.User Account Cancellation:
Any User can proceed with account cancellation (password and email) when considering. Must send cancellation request notification to info@mentu.co, with subject 'User account cancellation'. Above does not apply if commitments acquired via contract, convention, agreement or any other document with MENTU exist. Any violation or non-compliance with these Terms empowers MENTU to cancel, block or suspend an account, without prior notice or notification.Registered User Profile:
Applicability: This section applies to any natural or legal person entering the Platform under an account created for "Registered User" modality (hereinafter RU) to access and use educational resources offered by MENTU on its Platform that are not openly available, such as Shaia superpowers. Registered User Use Particularities: Registered User access is free with limited uses per month. This limited use number is measured by 'credits' amounting to total of one hundred (100). These will be renewed every 30 days from registration. User can always consult how many 'credits' available in Platform user interface (UI). Every time using one Shaia superpowers, a credit number is discounted summing up to exhausting one hundred (100). Credit number associated with each superpower is a determination taken by MENTU and corresponds to internal criteria and parameters. Main functionalities offered to registered user: On MENTU Platform you can use one or more Shaia superpowers—a constantly growing list of tools for use before, during and after class—such as (this list is constantly evolving, not exhaustive and may include superpowers in development, design or testing stage. Enter http://shaia.mentu.co to see a full list of superpowers available at any moment: • Course: A course allows saving information Shaia needs every time using a superpower. Data like subject, student number, ages, course learning objectives, etc. are saved to always obtain results adjusted to each student group context. • Course Variability Inclusion: Using models developed by Digital Promise, select Variability factors and Classroom strategies you want to take into account for each course and that will be available every time using a superpower. With these research-based strategies, ensure Shaia pedagogical suggestions and proposals really adjust to learning profile diversity of all your students. Planning Superpowers (before): Before class, Shaia can support various types of teacher planning activities such as: • Activity or Class: Design an activity (as long or short as needed) for Math, Language and many other areas using variability inclusion classroom strategies and best educational practices. • Concretizing strategy: Select a research-based classroom strategy from our ally Digital Promise and Shaia helps search ways to apply it in class. • Planning Math Conversation: Plan a powerful collaborative problem solving activity for Math class, with methodology recommended by our allies Youcubed and Digital Promise. • Story: Create a story with pre-reading, reading and post-reading activities for a class session. • Evaluation: Design various types of activities to evaluate student learning. • Rubric: Create rubrics for any context defining what you want to evaluate and number of levels and criteria needed. Superpowers for during and after class: • Feedback: Record what teacher says in class, with own phone and transcribe audio to receive feedback on teaching practice aspects. At end of process, save key ideas to take into account in future plans. • Class Summary: Create a class summary to save in logbook, use to reflect or send to students if absent or as study help.General Use Procedure:
When entering superpower you want to use, must complete some key context data. If having a Course created, this information will be used automatically and only must answer some additional questions in a form or through conversation (text chat or in some superpowers voice) with Shaia. These questions are designed to act as parameters guiding the artificial intelligence system. All information shared with Shaia in this process is private and neither Mentu nor its AI providers use it to train models nor share with third parties for marketing or advertising purposes. Only User has access to this information and not shared with other users. This form has mandatory questions that must be filled for Platform to throw requested content. Also includes guiding questions used to enhance quality of content received. More precise and detailed in answering questions more adjusted and useful content Platform throws. With information provided, Shaia generates a final product, which can be planning, explanation, feedback, etc. and responds to user with a product or requesting more information in a conversation. At end of process, Shaia presents User with a final product that can be exported in various ways (for example in a PDF document). Download or iteration of thrown content: Once satisfied User can click "Export" to generate a downloadable version of content thrown by Platform and save it in personal library on platform to consult or export in future.Registered User Use License:
As Registered User, MENTU grants a limited, non-exclusive, non-transferable and non-sublicensable use license to access, use, view, download and interact with all products, services and content offered on Platform for educational, pedagogical and instructional use (non-commercial). In this sense, as Registered User can access all content hosted and generated with Platform, as well as perform allowed downloads, provided material used to fulfill educational, pedagogical or similar purposes related to MENTU corporate purpose or in compliance with any agreement or contract. On the other hand, any right not expressly granted by this license is reserved in head of MENTU and/or other legitimate holders according to law. As Registered User declare entering and using Platform only with user and password assigned by MENTU, unless having written authorization from company to have more than one authorized account or without creation of one, and that no other natural or legal person will use it in your name. Use of Platform does not grant any intellectual property or know-how right in your favor.Resources generated by Registered Users with Shaia superpowers
With Shaia superpowers, Users can generate content using artificial intelligence innovatively to create personalized resources responding to each user needs, such as lesson plans or feedbacks described in Main Functionalities section. User is authorized to copy material and modify it for own non-commercial use or to share with third parties provided complying with following conditions: • Maintain attribution indicating it was generated with artificial intelligence using Shaia platform with corresponding links and logos to allies included in download or screen display. • Maintain attribution to used resources when included in result (Shaia includes it when exists). • Use for strictly non-commercial purposes, without profit motive.No Labor Subordination:
Acceptance of these Terms does not involve or establish any type of labor relationship so MENTU and RU perform activities with full independence and absolute autonomy, using own means and schedules.Indemnity:
As Registered User accept and agree to indemnify and hold harmless MENTU, its employees, agents, representatives, providers, contractors and assignees from any demand, claim, damages, harm, losses, liens, fines, sanctions, costs or expenses incurred or suffered arising from, or in relation to: i) Platform use, ii) incorrect use or non-compliance of any of these Terms, iii) violation of any applicable law, iv) content or material created or published under your account and risk, v) any misuse of material downloaded from Platform.Registered User Use Conditions:
Besides conditions already mentioned, as Registered User adhere to following additional use criteria recognized as essential part of these Terms: • Provide information to different forms requested by Platform not contravening MENTU Personal Data Processing Policy and Privacy Notice compliance. • Not authorized to create new account if MENTU previously deleted, suspended or cancelled a previous one controlled by you as User. • Not use Platform for illegal purposes, as well as participating in any activity harming or violating natural or legal person right. • Not give other uses to Platform going against these Terms and/or any other applicable law. • Not perform conducts restricting or inhibiting Platform use or enjoyment. • Strictly prohibited impersonating MENTU or one of its employees or any other natural or legal person, provided above is false. • Not use Platform with aim to exploit, harm or threaten in any way against minors, through exposure to inappropriate content, requesting personal data or any other way not authorized by these Terms or as agreed with MENTU. • Misuse understood as any action made by Registered User aiming to fraudulently and illegally decrypt source code used by MENTU, as well as any help, assistance or proposal given to others to achieve mentioned end. Nor can use reverse engineering or any other reconfiguration method for recreation of MENTU or third party legitimate holders property content. • Platform will be used only and exclusively under specific purposes established in these Terms. Any use by you for purposes other than previously mentioned understood as non-compliance.Registered User Declarations:
By accepting these Terms as Registered User confirm following declarations: • Assume responsibility for use given to Platform including personal user account use. • Abstain from using false or misleading information when creating account on Platform and misusing third-party personal data. • Use material or content downloaded from Platform according to purposes established here, without own commercial benefit and without intention to infringe MENTU or third-party rights. • Assume responsibility for data or information used when filling forms on Platform, understanding better or more detailed filling higher content quality delivered.Institutional User Profile (private or public educational organization):
Applicability: This section applies to any Registered User who has received an institutional license through an invitation from an organization having an agreement with Mentu. If your organization does not have a license contact info@mentu.co. Institutional User Use Particularities: Institutional User accesses Platform through a personal and non-transferable invitation assigning a limited use license according to conditions agreed with each institution. Institutional Users are a type of Registered User and as such governed by same Terms described for these. Additionally, institutional license may include: • Unlimited use of Shaia superpowers. • Superpower personalization through inclusion of institution's curriculum or learning objectives in course profiles and superpowers. • Custom-designed superpowers tailored to institution needs. • Training and support resources. • Evaluation and monitoring. • Premium support. Institutional User uses same main functionalities and general procedures of Registered Users. In case of custom superpowers, specific procedures are designed for each case responding to same general pattern of other Shaia superpowers described in General Use Procedure section for Registered Users.Authorized Third Party Profile:
Applicability: This section applies to collaborators, contractors, providers, authorized third parties and/or any natural or legal person (hereinafter "Third Party") entering MENTU Platform with aim to comply with a contractual obligation with MENTU or under a convention or agreement involving use for labor development. Third Party Use License: As Third Party, MENTU grants a limited, non-exclusive, non-transferable and non-sublicensable use license to access, use, view, interact with all products, services and content offered on Platform to comply with function, mission or specific purpose granted via contract, convention, agreement, collaboration or any other document signed between parties. In this sense, can access all content arranged on Platform, as well as perform downloads for those cases where permitted, provided material used to comply with mentioned purposes or as previously agreed with MENTU. On the other hand, any right not expressly granted by this license is reserved in head of MENTU and/or other legitimate holders according to law. As Third Party declare entering and using Platform only with user and password assigned by MENTU, unless having written authorization from company to have more than one authorized account, or without creation of one, and that no other natural or legal person will use it in your name. Use of Platform does not grant any intellectual property or know-how right in your favor. Indemnity: As Third Party accept and agree to indemnify and hold harmless MENTU, its employees, agents, representatives, providers, contractors and assignees from any demand, claim, damages, harm, losses, liens, fines, sanctions, costs or expenses incurred or suffered arising from, or in relation to: i) Platform use, ii) incorrect use or non-compliance of any of these Terms, iii) violation of any applicable law, iv) content or material created or published under your account and risk. Third Party Profile Use Conditions: Besides conditions already mentioned, as Third Party adhere to following additional use criteria recognized as essential part of these Terms: • Not authorized to create new account if MENTU previously deleted, suspended or cancelled a previous one controlled by User. • Comply with MENTU Personal Data Processing Policy and Privacy Notice. • Not use Platform for illegal purposes, as well as participating in any activity harming or violating natural or legal person right. • Not give other uses to Platform going against these Terms and/or any other applicable law. • Not perform conducts restricting or inhibiting Platform use or enjoyment. • Appropriately identify as official, contractor or ally of Mentu clearly and transparently, as case may be. Strictly prohibited impersonating MENTU or one of its employees or any other natural or legal person, provided above is false. • Not use Platform with aim to exploit, harm or threaten in any way against minors, through exposure to inappropriate content, requesting personal data or any other way not authorized by these Terms or as agreed with MENTU. • Misuse understood as any action made by Third Party aiming to fraudulently and illegally decrypt source code used by MENTU, as well as any help, assistance or proposal given to others to achieve mentioned end. Nor can use reverse engineering or any other reconfiguration method for recreation of MENTU or third party legitimate holders property content. • Platform will be used only and exclusively under specific purposes established in these Terms. Any use by you for purposes other than previously mentioned understood as non-compliance. Third Party Profile Declarations: By accepting these Terms as Third Party confirm following declarations: • Responsibility for Platform use including personal user account use. • Abstain from using false or misleading information when creating account on Platform and misusing third-party personal data. • If applicable, being owner of content published on or through Platform having capacity to grant rights to MENTU and confirming publication of content does not infringe third party intellectual property or other related rights and being true according to best judgment and due diligence capacity.Privacy Notice
MENTU EDUCACIÓN S.A.S (hereinafter MENTU), a company duly constituted in Colombia and domiciled in the city of Bogotá, with address at Calle 79b #5-81, telephone +57 320 4550793, and email admin@mentu.co, identified with NIT No. 901753973 – 0 as Data Controller of third-party personal data, makes this privacy notice available to all information subjects, in compliance with the provisions of Statutory Law 1581 of 2012, regulated by National Decree 1377 of 2013, Decree 1074 of 2015, and its constitutional foundations regarding the protection of privacy, personal data, and the right to habeas data.
Your personal data will be treated responsibly, under the relevant legal and security standards, and will be used generally for the following purposes described and expanded in the company's Personal Data Processing Policy and/or in the particular authorizations signed with MENTU regarding data processing:
• Provide our services in compliance with all obligations contracted by MENTU.
• Inform about new services offered by MENTU.
• Achieve efficient communication between MENTU and the information subjects and thus facilitate the fulfillment of its corporate purpose.
• Comply with obligations contracted with users, clients, providers, and employees of MENTU, as well as when necessary with judicial and administrative entities in compliance with the law.
• Management and delivery of information to third-party data processors contractually linked to MENTU and government education entities that require it.
• Accounting and tax effects, payment and collection of invoices, payroll payment, and others.
• Management of information that the user generates with the use of the system to provide services and make the platform a comprehensive academic tool;
• To generate information for internal statistical purposes, study, and personalization in the educational field.
Specific purposes can be found developed in the Personal Data Processing Policy and/or in the particular data processing authorizations signed with the company, documents adopted by MENTU.
The data subject, according to the law, retains their facultative capacity to provide sensitive data, and if they do so, acknowledges that MENTU will treat them with high standards of confidentiality and security, in consideration of their nature.