Privacy Policy

Data Controller

Mitchell Gunn

Forseti Services Ltd, are committed to ensuring a high-quality educational experience for its customers and learners, supported by appropriate academic, administrative and welfare support services and facilities.

This policy describes our privacy practices – what Personal Information we collect about our Users, what we do with it, how we share it, and your rights regarding that Personal Information.

By accessing or using any of our Services, you acknowledge that you have read this Privacy Policy.

01. Please read carefully!

Forseti Services Ltd, cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how Forseti Services Ltd, together with its affiliated companies worldwide (“Forseti Services Ltd”, "Mitch Gunn Training, Mitchell Gunn Photography, Mitch Gunn Photography, Best Behaviour Dog Training, Veterans Owned Assistance Dogs, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all Forseti Services Ltd, users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all services, including our websites (including www.mitchgunntraining.com and any of its subdomains, the “Website”), web applications (“Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”).

This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us at mitch@mitchgunntraining.com

02. What Personal Information do we collect.

2.1. User Information:

To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

1. Information you provide us. When you register for our Services, purchase and/or register domain names, use any of our Services; and/or when you contact us directly by any communication channel (e.g., Mitch Gunn Training's support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).

2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc

3. Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

2.2. Users of Users Personal Information

We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.

03. Why do We collect such Personal information

We use your Personal Information for the following purposes:

1. To provide and operate the Services;

2. .To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;

3. To provide our Users with ongoing customer assistance and technical support;

4. To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);

5. To help us to update, expand and analyse our records to identify new customers;

6. To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;

7. To analyse our performance and marketing activities;

8. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;

9. To provide you with professional assistance, only upon your request;

10. To enhance our data security and fraud prevention capabilities; and

11. To comply with any applicable laws and regulations.

We use your Personal Information for the purposes set out in Section 3 where:

1. Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);

2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or

3. Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of Forseti Services Ltd, by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.

#ItsThatEasy

We use the Personal Information we collect about you to provide our services and make them better and safer.

We also collect and use Personal Information in order to contact Users and to comply with the laws applicable to us.

04. How we share your Personal Information

4.1.

Third Party Service Providers: Forseti Services Ltd, has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).

Forseti Services Ltd, may share the following categories of Personal Information with Third Party Service Providers for a business purpose:

· identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers

· commercial information, for example information regarding products or services purchased, obtained, or considered

4.2.

Law Enforcement, Legal Requests and Duties: Forseti Services Ltd, may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

4.3.

Protecting Rights and Safety: Forseti Services Ltd, may share your Personal Information if we believe in good faith that this will help protect the rights, property or personal safety of Forseti Services Ltd, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.

4.4.

Social Media Features and Framed Pages: Our Services include certain Social Media features, widgets, and single sign on features, such as the “Facebook Connect,” “Google Sign-in,” “Facebook Like”, or “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect certain Personal Information such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.

In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing are governed by those third parties’ policies and not ours.

4.5.

App Market Developers: As part of our App Market program, we allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications in conjunction with Mitch Gunn Training.

We encourage you to review any privacy policy accompanying a Third Party App and ask Third Party Developers for any clarifications you may need before deciding to install and use their Third Party App. Forseti Services Ltd, does not control and is not responsible for the actions or policies of any Third Party Developers, and your use of any Third Party App is at your own risk.

You are solely responsible for notifying your Users-of-Users of the collection, processing and use of their Information and informing them that their Information will be transferred to and processed by Mitch Gunn Training on your behalf.

4.6.

Forseti Services Ltd, Subsidiaries and Affiliated Companies: We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with www.mitchgunntraining.com in the course of facilitating and providing you (and your Users-of-Users) with our Services.

Sharing Personal Information from Forseti Services Ltd, subsidiaries and affiliated companies in the European Union and Switzerland to Forseti Services Ltd, United States subsidiary will be only when the relevant Model Standard Contractual Clauses are in place.

4.7.

Connection With a Change in Corporate Control: In addition, should Forseti Services Ltd, or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.

4.8.

Upon Your Further Direction: Forseti Services Ltd, may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.

05. Where do we store your Personal Information?

5.1.

We may store and process Personal Information in the USA, Europe, Israel, or other jurisdictions, whether by ourselves or with the help of our affiliates and service providers.

Forseti Services Ltd, data storage providers are contractually committed to protect and secure your data.

Users’ and Users-of-Users’ Personal Information may be stored in data centres located in the United States of America, Ireland, Japan and Israel. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.

Forseti Services Ltd, is based in The United Kingdom, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.

Forseti Services Ltd, affiliates and Third-Party Service Providers that store or process your Personal Information on Forseti Services Ltd, ’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.

5.2.

Transfer of EU Personal data : If you are located in Europe, when we will transfer your Personal Information to the United States or anywhere outside Europe, we will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Model Standard Contractual Clauses are in place.

Among other things, Forseti Services Ltd, will ensure that there is the adequate level of protection or that relevant Model Standard Contractual Clauses are in place for the international transfer of our EU users’ data.

5.3.

Privacy Shield Certification: Forseti Services Ltd, and its affiliates, including DeviantArt Inc., participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List, here.

In compliance with the Privacy Shield Principles, Forseti Services Ltd, commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us. For the avoidance of doubt, Forseti Services Ltd, does not rely on the Privacy Shield as a mechanism for transferring GDPR protected personal data.

mitchgunntraining.com has further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider at https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services are provided at no cost to you.

06. Users-of-users’ Personal Information

Forseti Services Ltd, may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with Forseti Services Ltd, , on the User’s behalf.

For such purposes, Forseti Services Ltd, serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.

The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.

The Processing of the Users-of-users’ Personal Information shall take place within the territory of the European Union, Israel or a third country, territory or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection and such processing and transfer will be in accordance to the Data Processing Agreement – Users (“DPA"). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission, shall be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Annex 1of the DPA. For the sake of clarity, “Processing” should be understood as per the definition provided in the DPA.

You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.

Forseti Services Ltd, cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.

If you are a visitor, user or customer of any of our Users, please read the following: Forseti Services Ltd, has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by Forseti Services Ltd, on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data).

07. Use of cookies and other third-party technologies (Currently no cookies are used)

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.

You can learn more about how we use cookies and similar technologies and how you can exercise control over them in our Cookie Policy.

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

08. Communications from Mitch Gunn Training

We use your Personal Information for the following purposes:

1. To provide and operate the Services;

2. .To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties;

3. To provide our Users with ongoing customer assistance and technical support;

4. To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below);

5. To help us to update, expand and analyse our records to identify new customers;

6. To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;

7. To analyse our performance and marketing activities;

8. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;

9. To provide you with professional assistance, only upon your request;

10. To enhance our data security and fraud prevention capabilities; and

11. To comply with any applicable laws and regulations.

We use your Personal Information for the purposes set out in Section 3 where:

2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or

#ItsThatEasy

We use the Personal Information we collect about you to provide our services and make them better and safer.

We also collect and use Personal Information in order to contact Users and to comply with the laws applicable to us.

8.1. Promotional Messages

We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from Forseti Services Ltd, or our partners (acting on Forseti Services Ltd, behalf) through such means.

If you do not wish to receive such promotional messages or calls, you may notify Forseti Services Ltd, at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

8.2. Service and Members Messages

Forseti Services Ltd, may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance.

It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a Forseti Services Ltd, User (which can be done by emailing us or deactivating any log in member accounts).

09. Your rights in relation to your Personal Information

Forseti Services Ltd, agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, Forseti Services Ltd, is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

If you are a Forseti Services Ltd, User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, or Permanently Deleting Your Forseti Services Ltd, Account”. You can also mail your request to mitch@mitchgunntraining.com. We will make reasonable efforts to honour your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.

Please note that permanently deleting your Forseti Services Ltd, account erases all of your Personal Information from Mitch Gunn Training's databases. After completing this process, you can no longer use any of your Forseti Services Ltd, Services, your account and all its data will be removed permanently, and Forseti Services Ltd, will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.

10. Questions and Complaints

If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.

Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.

You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.

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