Privacy

MASTERY IN TRANSFORMATIONAL TRAINING® PRIVACY POLICY

Effective Date: January 1, 2024

This Privacy Policy (“Privacy Policy“) explains how MITT Institute Inc., doing business as Mastery in Transformational Training (now referred for convenience in this Privacy Policy as “MITT“, “we” “us” or “our”) uses personal information (individually and collectively, in whole and in part now referred to for convenience in this Privacy Policy as “Personal Information” or “PI”), including yours. (“Personal Information” is defined in Section 1 below). This Privacy Policy is intended to comply with the California Consumer Privacy Act (the “CCPA”), applies to all individuals including but not limited to, those who reside in the State of California on or after the Effective Date above, who visit our website and/or app at www.masterytraining.com (individually and collectively now referred to for convenience in this Privacy Policy as the “Site”), subscribe to our workshops and trainings, access our related materials, send us emails, purchase or access anything on or through the Site including but not limited to, our training materials (all of the foregoing goods and services are now individually and collectively referred to for convenience in this Privacy Policy as “Services”. Those individuals, including you, who visit the Site are now sometimes individually and collectively referred to for convenience in this Privacy Policy as “User(s)”, “you”, or “your”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY, AS YOU MUST AGREE TO IT BEFORE ACCESSING THE SITE. YOU CAN ONLY ACCESS AND USE THE SITE BY CLICKING ON THE “I ACCEPT” BUTTON AT THE END OF THIS PRIVACY POLICY. THIS GRANTS YOU ACCESS TO THE SITE. IF YOU DO NOT AGREE TO ANY PORTION OF THIS PRIVACY POLICY, YOU SHOULD CLICK ON THE “I DECLINE” BUTTON AT THE END OF IT. DOING SO BARS YOU ANY FURTHER ACCESS TO THE SITE, any MITT online channel, other apps or websites where the Site be linked, such as but not limited to our pages on social media sites, the ability to enroll in our trainings, send us emails, purchase or access anything on or through the Site, obtain or use any of our Services, and otherwise interact with us at www.masterytraining.com.

Our General Contact Information. If you have any questions or comments about this Privacy Policy, the ways in which MITT collects and uses your PI described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

 

Phone: 310.305.7855

Website: www.masterytraining.com

Email:  office@masterytraining.com

Postal Address: MITT Training Inc.

5800 Hannum Ave., Suite 130

Culver City, Ca 90230

 

 

Our Privacy Policy is organized as follows:

  1. Categories and Specific Types of Personal Information
  2. How MITT Collects Personal Information
  3. How MITT Uses Personal Information
  4. With Whom MITT Shares Your Personal Information
  5. Disclosure of Personal Information for a Business Purpose
  6. Sale of Personal Information for a Business Purpose
  7. When, Why, and To Whom MITT Discloses Personal Information
  8. Your Rights and Choices, Including Opt-in and Opt-Out Rights
  9. Request Response Timing and Format
  10. Non-Discrimination
  11. Financial Incentives
  12. CCPA Compliance Training
  13. Cookies and Related Technologies
  14. Security of Personal Information
  15. Privacy Practices of Third Parties
  16. Communities
  17. Changes to this Privacy Policy
  18. Important Information for Non-U.S. Residents

 

 

  1. Categories and Specific Types of Personal Information.

“Personal Information” is information we collect that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular User, household, or device. Please keep your PI accurate at all times.

 

Categories of PI Specific Types of PI We Collect

 
A. Identifiers (e.g., your real name, aliases, postal address, company, unique personal identifiers, online identifiers, Internet Protocol addresses, emails addresses, social media addresses, account names, telephone number, social security number, drivers’ license and other government-issued identification number, passport number, and other similar identifiers). Names, email addresses, phone numbers, Google Analytics to provide enhanced User experience.  Unless a User opts-out of tracking, Google Analytics uses Client IDs to measure and track each individual User and their behavior in order to aggregate and present data about our site performance. Any PI beyond demographics, session site behavior, and location is protected by our membership portal.

 
B. Other information that identifies, relates to, describes, or is capable of being associated with you including but not limited to, your signature, physical characteristics or description, education, employment, employment history, onsite purchases, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information, areas of interest, areas of service, information collected from social media interactions, information about individuals who have referred Users to the Site, or who they have referred to the Site

 

 Credit and debit card numbers, User practice areas or specialties, the purpose for which Users intend to use the MITT platform.
C. Characteristics of protected classifications under California or federal law (e.g., age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including but not limited to, familial genetic information).

 

 None in this Category.
D. Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming history or tendencies).

 

 Those Services purchased or used through the Site.
E. Biometric information (e.g., genetic, physiological, behavioral, and biological characteristics, or activity

patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data).

 

 None in this Category.
F. Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding your interaction with an Internet website, app, or advertisement)

 

 None in this Category.
G. Geolocation data (e.g., physical location or movements). Analytics-related information for User experience optimization. In the future, we will expand these capabilities to leverage a multi-language translator to extend out connection to student around the globe, with resources and accessibility to future workshops.

 
H. Sensory data (e.g., audio, electronic, visual, thermal, olfactory, or similar information).

 

 None in this category.
I. Professional or employment-related information (e.g., current or past job history or performance

evaluations).

 

 None in this category.
J. Non-public personally identifiable education information, as defined in the Family Educational Rights and Privacy Act (FERPA) (e.g., education records directly related to a student maintained by an educational institution or party acting on its behalf, including but not limited to, grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

 

 Education records of each User who signs up for our trainings and workshops.
K. Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

 None in this category.
L. Other Information when you visit or leave the Site (e.g., our plugins, cookies or similar technology on the

sites or apps of others when you leave our Site. We usually receive the URL of both the site you came from and the one you go to next), your proxy server, operating system, web browser and add-ons, device identifier and features, ISP and/or your mobile carrier. If you use the Site from a mobile device, that device will likely send us data about your location based on your phone settings.  If and when we decide to use GPS or other location tools to identify your precise location, we’ll ask you to Opt-In per Section 6 of this Privacy Policy before we do.

 Cookies, as explained in our Cookie Policy.

 

 

Personal Information does not include:

  • Publicly available information from government records;
  • Deidentified or aggregated User information; and,
  • Information excluded from CCPA’s scope including but not limited to: HIPPA, clinical trial data, and the Fair Credit Reporting Act.

 

 

  1. How MITT Collects Personal Information.

We collect PI when you visit the Site, contact us, purchase Services on or through the Site, or otherwise interact with the Site. We may track the Services you view or purchase, when you post listings or other data. We use cookies and related technologies to collect information about the devices Users use to access and interact with the Site. You can read more about cookies and other technologies in the Cookies and Related Technologies  section, which is Section 13 below.

 

The social media platforms, or other methods of communication Users use to interact with MITT or the Site, may have their own specific privacy statements or policies that governs the use of Personal Information related to that platform or app. You should FIND AND CAREFULLY READ those privacy statements and policies, as OUR PRIVACY POLICY DOES NOT APPLY TO THOSE PLATFORMS OR APPS.

 

We may receive additional Personal Information from third parties. This may include, but isn’t limited to Google Analytics, and the Facebook Meta pixel on the Site. We may use this Personal Information to enhance other information we have about Users to help us better understand them, and to otherwise enhance the Site, and/or the Services.

 

  1. How MITT Uses Personal Information.

MITT uses Personal Information for the following reasons:

  • Auditing related to a current interaction with You;
  • Respond to User questions and inquires;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Short-term, transient use, provided the PI that is not disclosed to a third party;
  • Performing services on behalf of a business or service provider with whom we have a relationship including but not limited to, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, and processing payments;
  • Undertaking internal research for technological development and demonstration; and,
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
  • To measure each User and their behavior in order to aggregate and create data about a User’s Site performance.
  • For our marketing.
  • To track Site activities, the channel and campaign of each entry associated with each User. Unless a User opts out, behavioral marketing and insights, which includes Facebook advertising, targeted audiences for future advertising and remarketing to Users who have already taken some kind of action on the Site.

(All of the above bullet points in this Section 3 are each an example of a “business purposes”, which is defined in Section 4 below).

  • Operate and improve the Site;
  • Facilitate and process orders for Services including but not limited to, their purchase and shipping;
  • Track Users purchasing and/or use habits of Services, and perform other analytics;
  • Manage and develop our business and operations;
  • Communicate and provide additional information that may be of interest to Users about MITT business partners, such as newsletters, special offers, curated content, and announcements, but only in which a User has elected to participate;
  • Send Users reminders, technical notices, updates, security alerts and support, administrative messages, service bulletins and marketing information;
  • Send Users other information we believe may be pertinent to their use of the Site, via email messages, text messages, apps, phone calls, and other methods of communication;
  • Add to our contact database; and,
  • Manage our everyday business needs, such as Site administration, forum management, fulfillment, analytics, enforcement of our corporate reporting obligations, our Terms of Use, or to comply with the law.

 

  1. With Whom MITT Shares Your Personal Information.

We routinely share Personal Information with:

  • Service providers we use to help deliver our Services to you, such as payment service providers, and delivery companies;
  • Affiliated companies, if any (such as our subsidiaries and/or controlled by or affiliated with, MITT); and,
  • Other third parties we use to help us run our business, such as marketing agencies, sites through which one can subscribe to our Services, website hosts, and those third parties set out in Section 2 above.
  • Google and Facebook Meta will collect surface-level data from Users visiting the Site, limited to demographics, geography, and behavioral activity for Site and marketing campaign(s) optimization.

We may sell and/or disclose, subject to your Opt-Out and Opt-In Rights discussed in Section 6 below, your PI to a third party solely for a business purpose. A “business purpose” is defined as the use of PI for our or a service provider’s (“SP”) operational purposes, or other notified purposes, provided that the use of PI is reasonably necessary and proportionate to achieve the operational purpose for which the PI was collected or processed, or for another operational purpose that is compatible with the context in which the PI was collected. When we sell or disclose PI for a business purpose, we enter into a contract with that third party that describes the purpose and requires the recipient to both keep that PI confidential, and not use it for any purpose except performing the contract. (The CCPA prohibits third parties who purchase or receive the PI we hold from reselling or redisclosing it, unless you have received explicit notice and an opportunity to Opt-Out of further sales or disclosure).

 

  1. Disclosure of Personal Information for a Business Purpose.

In the preceding twelve (12) months, we have not disclosed PI for a business purpose.

 

  1. Sale of Personal Information for a Business Purpose.

In the preceding twelve (12) months, we have not sold PI for a business purpose.

 

  1. When, Why, and To Whom MITT Discloses Personal Information.

 We will not sell and/or disclose your Personal Information to third parties except to:

  • Affiliated companies, if any (such as our subsidiaries and/or controlled by or affiliated with, MITT) who may only use the Personal Information for the purposes described in Section 3 above;
  • Third party merchants, but only to the extent a User has participated in an activity sponsored or offered through MITT on behalf of that merchant. We may also provide merchants with Personal Information to combat fraud and as part of legal proceedings affecting MITT and that merchant;
  • MITT business partners (including but not limited to, advertisers) as part of an offer or other activity that is provided by or in conjunction with MITT and/or its business partners, and in which a User has elected to participate. For example, if a User is referred to MITT from a business partner’s website or through an invitation facilitated by or in conjunction with a MITT business partner, we may provide that business partner certain PI to validate the referral, and to support the terms of the relationship between us and that business partner. This in turn may allow that business partner to contact you directly and/or to advertise to you;
  • Effect or evaluate a merger, acquisition, or otherwise to support the sale or transfer of some or all of our business assets;
  • To enforce our rights or protect our property;
  • To protect the rights, property, or safety of others, investigate fraud, respond to a government request; or, as needed to support auditing, compliance, and corporate governance functions; and,
  • To defend ourselves in litigation or a regulatory action and when required or advised to do so by law or our legal counsel in their representation of us. This includes but is not limited to, in response to a subpoena or similar legal proceedings, including to law enforcement agencies, regulators, and courts in the United States and other countries.

 

We encourage our third-party merchants and business partners to adopt and post their own privacy policies, since they are NOT covered or governed by ours. So, THE USE OF YOUR PERSONAL INFORMATION BY THIRD PARTIES YOU CAN ACCESS THROUGH THE SITE, OR WHO PROVIDE GOODS OR INFORMATION ON OR THROUGH THE SITE, IS GOVERNED BY THEIR PRIVACY POLICIES, AND IS NOT SUBJECT TO OURS.

You will be notified by email and we will post a prominent notice on the Site of any changes in ownership or uses of your Personal Information, as well as of any new or different choices you may have regarding your Personal Information.

We may also disclose information about Users that is not personally identifiable. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our Users.

 

  1. Your Rights and Choices, Including Opt-in and Opt-Out Rights.

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

 

8.1  Accessing, Correcting and Deleting Personal Information. We think that you benefit from a more personalized experience when we know more about you and the kinds of Services you like. However, you can limit the information you provide to MITT and you can limit the communications that MITT sends to you.

It is important that you keep your Personal Information current and accurate at all times by: logging into your account through our Site,  sending us an email at office@masterytraining.com, or by phone or postal mail,  at the address at the end of the next sentence. Our system will notify us of any changes you make to PI, so as to facilitate those changes. If you want to close your account, need help with accessing, updating and deleting your personal Information, or have other questions or requests, please contact our customer service department at support@masterytraining.com or by postal mail, or phone at:

 

Mastery in Transformational Training

5800 Hannum Ave. Suite 130

Culver City, CA 90230

Phone: 310.305.7855

 

You can manage your email preferences by logging into your account through our Site, entering the “My Account” section, and selecting “Manage Email Subscriptions.” You can also manage your subscriptions by following subscription management instructions contained in some of the commercial messages that we send you. You may choose to subscribe or unsubscribe to some or all types of messages. You can update your subscription preferences whenever you want. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account, subscription and/or purchases. For example, even if you have unsubscribed from our promotional email messages, we will still send you confirmations when you purchase Services, or register for training or workshops from us.

You may manage how your browser handles cookies and related technologies by referring to Section 8 below.

While we’re ready to assist you in managing your Personal Information or closing your account, we can’t always delete records of past interactions and transactions. For example, we’re required to retain records relating to previous purchases on the Sites for financial reporting and compliance reasons.

We will retain your information for as long as your account is active, to provide you Services and other services, to maintain a record of your transactions for financial reporting purposes and otherwise as we feel is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

8.2 You have the right to request that we disclose to you certain information about our use and collection of your PI (a “Right to Know”) over the past twelve (12) months. Here  is a link to the Right to Know request form. Once we receive and have “verified” (defined just after Section 8.5 below) the request, we will disclose to you:

  • The categories of PI we have collected about you, actively, passively, by observing your behavior, and inferences drawn from all this;
  • The categories of sources from which the PI is collected;
  • The purposes for collecting, disclosing, or selling your PI;
  • The categories of third parties with whom we have sold and/or disclosed your PI;
  • The specific pieces of PI that we have collected about you;
  • The categories of PI that we disclosed about you for a “business purpose”, as well as the categories of third parties to whom your PI was disclosed, both by reference to the enumerated category or categories of PI that most closely describes the PI disclosed;
  • We do not knowingly do business with anyone under the age of 18; and,
  • If we collect sensitive PI such as Social Security or drivers’ license numbers, or biometric information like fingerprint scans, our response to a Request to Know for these will say that we collect this type of PI, and specify the types of these we collect, but will not disclose the numbers themselves, or actual biometric information data.

 

8.3 You have the right to request that we permanently delete, deidentify, or anonymously aggregate with the PI of others, all or parts of your PI (a “Right to Delete”). Here [is a link to the Right to Delete request form. However, we can deny a Right to Delete request when the PI is needed to:

  • Complete the transaction for which we collected the PI;
  • Fulfill the terms of a written warranty or product recall conducted under applicable law;
  • Provide Services or services you previously requested;
  • Otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
  • Debug and repair errors that impair Site functionality;
  • Exercise a legal right, such as free speech rights;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest;
  • Enable internal uses reasonably aligned with your expectations based on your relationship with us;
  • Comply with a legal obligation; or,
  • Otherwise use your PI internally in a lawful manner that is compatible with the context in which you provided the PI.

We will inform the requester that we received the request within ren (10) days of our receipt, and how we will process the request. If we deny all or part of a Right to Delete request, we will respond to the requester the reasons for any denials not prohibited by law, as well as ask the requester if they want to Opt-Out of sales of their PI, and provide a link for them to do so.

We do not sell your Personal Information.

 

For all these requests:

  • We will maintain a record of all requests, and how they were responded to, for at least twenty-four (24) months.
  • Please note that only two requests are allowed in any twelve (12) month period. However, the categories of sources and purposes need not be specified for each category of PI identified.

 

8.5 We do not knowingly acquire or sell the PI of Users we actually know are less than 18 years of age. Please notify us at the phone number or addresses in the “Requests to us can be made by either” paragraph below in this Subsection  8.5.

We do not charge a fee to process or respond to a verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the requester why we made that decision and provide the requester with a cost estimate before completing the request.

We honor Do Not Track (“DNT”) signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place.

You can also manage the sharing of certain of your Personal Information with us when you connect with us through a social media platform or app such as but not limited to, through Instagram, Twitter, Facebook, or LinkedIn. Please refer to the privacy policies and settings of the social media platform or app to determine how you may adjust our permissions and manage the interactivity between MITT and that social media account.

If you wish to Opt-Out of receiving offers directly from MITT’s merchants or business partners, you can follow the Opt-Out instructions in the emails that they send you.

 

Identifying and Verifying the Requester.

 

To identify and verify the requester, we associate the information provided in the verifiable request to any of your PI previously collected by us. “Verify” means determination by us that the requester making a Right to Know request, Right to Delete request, Right to Opt-Out request, or Right to Opt-In request, is about your PI, is you, or someone properly authorized by you, or is your parent or legal guardian if you are less than 13 years of age.

We verify requests associating the information provided to us in the request to any of your PI we previously collected. We can’t require that you notarize a request, but we can ask for the request to be a signed declaration under penalty of perjury, request the requester to identify Services or services you recently purchased, or the dollar amounts of those recent purchases.

How to Make Requests.

Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your PI. The request must provide sufficient information that allows us to properly understand, evaluate, and respond to it, as well as reasonably verify you are the person about whom we collected PI or an authorized representative of that person. Your request should at a minimum include the following:

  • Your account number, the approximate date you opened your account, and your password for the Site;
  • When you last purchased something on the Site, and the dollar amount of that purchase;
  • The type of request you are making; and,
  • The specific PI to which your request pertains.

You may also make a verifiable request on behalf of your minor child, although the Site is not intended for use by anyone under the age of 18 years of age.

You can also designate an authorized agent to make a request for you. To designate an authorized agent, you must provide your:

  • account number, the approximate date you opened your account, and your password for the Site.
  • a copy of your email or other correspondence to your agent, verifying you want that person to act as your agent in this regard, from the email address of yours which you have on file with us, with the agent’s contact information in it, so we can verify your request.

Requests to us can be made by either:

  • Calling us at 310-305-7855;
  • Emailing us at office@masterytraining.com and placing “PI Request” in the subject line;
  • Visiting our Site page to make a request, at masterytraining.com;
  • Visiting your password protected account with us (if you have one), via the “Make PI Request” link there. We may consider requests made through your password protected account sufficiently verified when the request relates to PI associated with that specific account, but have the right to re-authenticate the Request before we act on it; and,

If new PI of yours is obtained by us so we can verify the request, we will only use it for that verification and then delete it, unless the requester consents otherwise.

We cannot respond to your request or provide you with PI if we cannot verify your identity or authority to make the request, and confirm that the PI relates to you, within forty-five (45) days of our receipt of your request.

 

  1. Request Response Timing and Format.

 We endeavor to respond to verifiable requests (e.g., to disclose, delete, effectuate Opt-In or Opt-out) within forty five (45) days of our receipt of it. If we require more time, which can be up to an additional 45 days, we will within the initial forty five (45) days inform the requester of the reason and length of the extension period in writing.

If you have registered with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by postal mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For all requests, we will select a format to provide your PI that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance including but not limited to, an email that that can be forwarded.

 

  1. Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless not permitted by the CCPA, we can without limitation:

  • Deny you Services;
  • Charge you different prices or rates for Services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of Services or other services; or,
  • Suggest that you may receive a different price or rate for Services, or a different level or quality of Services or other services.

 

  1. Intentionally Left Blank.

 

  1. CCPA Compliance Training.

 We will inform our employees, developers, and any others  responsible for handling User inquiries about our privacy practices and our compliance with the CCPA, of all requirements set out in the CCPA, how to effectuate those requirements, and how to direct Users to exercise their rights under the CCPA.

 

  1. Cookies and Related Technologies.

When Users use the Site, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags, clear gifs (also known as web beacons and web bugs), browser analysis tools, and web server logs. A “clear gif” is a nearly invisible, pixel-size graphic image on an app, website page, app or website-based document, or email. It helps us do things like view the URL of the page in which the clear gif appears, and the time our Site and the email in question is viewed. In emails, clear gifs help us confirm the receipt of and respond to our emails including but not limited to, those that Users forward to friends and family, as well as to help us deliver a more personalized online experience.

As a User uses the Site, their browser and other devices, like certain types of phones and tablets, communicate with servers operated by us, our business partners and service providers, to coordinate and record the interactivity and fill their requests for Services and information.

The information from cookies and related technology is stored in web server logs and also in web cookies kept on the computers or other devices from which Users access the Site. This information is then transmitted back to the Site by these devices. These servers are operated, and the cookies managed, by us, our business partners, or our service providers.

For example, when a User visits the Site, MITT and/or our service providers may place cookies on that computer or device. Cookies allow us to recognize the User when they return and to track and target your interests in order to provide a customized experience. They also help us to detect certain kinds of fraud.

A “cookie” is a small amount of information that a web server sends to your browser. It stores information about your account, your preferences, and your use of the Site. Some cookies contain serial numbers that allow us to connect your Site activity with other information we store about you or as related to your interactions with the Site.

Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons including but not limited to, managing page views. Browsers usually erase session cookies once the browser is exited. “Persistent” cookies are more permanent cookies that are stored on the computers or other devices people use even beyond when they exit their browser. We use persistent cookies for a number of purposes. These include but aren’t limited to, retrieving certain information a User has previously provided (like their password, if they asked to be remembered), and storing that User’s preferences, such as the types of Services in which they’ve told us they’re interested.

“Pixel tags” are tiny graphic images placed on website pages or in our emails that allow us to determine whether a User has performed certain specific actions. When that User accesses these pages or opens our email messages, the pixel tags generate a notice of that action to us and/or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.

We collect many different types of information from the devices a User uses to access the Site, using these cookies and other technologies. Some examples of this information are the User’s operating system type, browser type, domain and other system settings, the language the User’s system uses, and the country and time zone of that device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP“) addresses of the devices a User uses to interact with the Site. An “IP address” is a unique identifier that devices use to identify and communicate with each other online. We may also collect information about the website or app a User was visiting before they came to the Site, and the app or website they visit after they leave the Site, if this information is supplied to us by the User’s browser.

In many cases, the information we collect using cookies and other technologies is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about Users to optimize the Site and understand its traffic and usage patterns. Another example is we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information.

One of MITT’s third party service providers is Google Analytics. They provide certain analytics and optimization services for the Site. If you’d like more information on how to remove yourself from the tracking and reporting functions performed for or by the Site by Google Analytics, please access the Op-Out request form by clicking Here.

Users can also RID THEIR DEVICES OF COOKIES by blocking or deleting them. This is often done by adjusting their browser’s privacy and security settings. How to do this depends on the type of browser being used. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You might also find information about this by clicking your browser’s “Help” tab, or by contacting them. One can also try typing something like “deleting cookies” and your browser type into an internet search engine.

 

  1. Security of Personal Information.

 MITT has implemented an information security program that contains administrative, technical, and physical controls designed to reasonably safeguard Personal Information. For example, we use an industry-standard encryption technology called Knack to secure PI when it is being transmitted over the Internet. We also use industry-standard security strategies for password encryption, security certification, periodic vulnerability testing, and periodic service, database, and server security scanning and vulnerability patching. Sensitive information of our Users beyond demographics, geography, and behavioral activity, is protected by a membership portal which requires the User to sign-up with an email address and password, with full consent to manage information (solely) for MITT’s database of User records for communication and order fulfillment. When our employees need to access your PI in the course of providing Services to you, we track it internally. When our third-party providers, like our credit card processing provider, need to access your PI in the course of providing our Services, they do so according to PCI (Payment Card Industry) data security standards. However, despite our security program and procedures, you acknowledge and understand that WE CAN’T GUARANTEE that any person or company will be prevented from obtaining your PI, or any other information including but not limited to, through unauthorized means such as cyberattacks or hacking.

 

  1. Privacy Practices of Third Parties.

This Privacy Policy ONLY addresses the use and disclosure of information by us through your interaction directly with the Site. Other website and apps that may be accessible through links from the Site may have their own privacy statements and information collection, use, protection, and/or disclosure practices. WE ARE NOT RESPONSIBLE and do not monitor the internet or other practices of any third parties. Our affiliates, business partners, merchants or service providers may have their own privacy policies too. We encourage you to READ CAREFULLY and be familiar with the privacy policies provided by these other parties prior to providing them with any information or taking advantage of any of their offers or promotions. MITT IS NOT RESPONSIBLE for the privacy or security of any information you provide to these third parties.

 

  1. Communities.

 The Site may contain or be linked to online or other communities, social media platforms, and other areas where you may be able to publicly post and otherwise share information, interact, network, make comments and communicate with others such as but not limited to, Instagram, LinkedIn, Twitter, Facebook, discussion boards, chat rooms, and blogs, where you can among other things, discuss your experiences with us, submit and view media and other User’s content, and seek advice (individually and collectively “Communities”). Prior to posting in any of these areas, please read our Terms of Use  carefully. All the information you post will be accessible to anyone with Internet and/or mobile access, and any Personal Information you include in your posting may be read, collected, and used by others. YOU SHOULD ALWAYS BE VERY CAREFUL ABOUT PUBLICLY POSTING YOUR PERSONAL INFORMATION. YOU SHOULD ALSO REFER TO THE PRIVACY POLICIES OF EACH SOCIAL MEDIA PLATFORM YOU USE AND ON WHICH YOU HAVE AN ACCOUNT OR CHANNEL, TO SEE HOW THEY DEAL WITH PERSONAL AND OTHER INFORMATION. PLEASE REMEMBER THAT MITT IS NOT RESPONSIBLE FOR THE PRIVACY OR SECURITY OF ANY INFORMATION YOU PROVIDE TO THESE THIRD PARTIES.

If you have questions about Personal Information posted in our Communities, please contact office@masterytraining.com with “Communities” in the subject line.

 

  1. Changes to this Privacy Policy.

From time to time, we may update this Privacy Policy at out discretion to clarify our practices, or to reflect new or different privacy practices, such as when we add new features to the Site or other sites or apps, or to comply with current laws and regulations. If we make any changes, we will post a “Updated on” date under the Effective Date” at the top left of this Privacy Policy. We will notify you by email (sent to the email address you have provided us), and post a notice on the Site’s home page, both of which will contain a link to the updated Privacy Policy so you can read it. We also encourage you to periodically review this Privacy Policy for the latest information about our privacy practices.

Your continued use of the Site after we publish and/or send a notice about our changes to this Privacy Policy constitutes your acceptance of the updated Privacy Policy.

 

  1. Important Information for Non-U.S. Residents.

 Data Transfers

MITT is headquartered in the United States. This Privacy Policy originates and is hosted on a website located in the United States, which has different data protection laws from those of other nations, and particularly member nations in the European Union, and the European Economic Area (the “EEA”). Due to differing laws and legal practice, be aware that law enforcement agencies in the United States may have access to your Personal Information.

If you are located in the EEA or other regions, they may have laws governing data collection and use that may differ from the laws in the United States, and/or may not provide equivalent levels of data protection as your home jurisdiction. Please note that we or our service providers may transfer your information to, or access it in, a country or jurisdiction that does not have the same data protection laws and/or may not provide equivalent levels of data protection as your home jurisdiction. It may also be processing your information by staff operating outside the EEA who works for us or for one of our service providers. If required by applicable law, we will seek your explicit consent to process your Personal Information collected on our Site or volunteered by you.

We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the EEA or Switzerland, we provide adequate protection for the transfer of Personal Information to countries outside of the EEA or Switzerland through a series of intercompany agreements based on the Standard Contractual Clauses. We may also need to transfer your information to other group companies or service providers in countries outside the EEA. This may happen if our servers or suppliers and service providers are based outside the EEA, or if you use access, avail yourself and/or purchase Services while visiting countries outside this area.

If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.

 

GDPR

The following provisions apply to you if you are a European citizen or resident. All processing of your Personal Information used to be performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the “Directive”), and the implementations of the Directive in local legislation. As of May 25, 2018, the Directive and local legislation based on the Directive was replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of PII and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”), and our applicable processing will take place in accordance with the GDPR. For purposes of the GDPR, we will be the “data controller” of PII (referred to in the GDPR as “personal data”) we collect through the Site, unless we collect such information on behalf of a data controller, in which case we will be a “data processor.” This Privacy Policy does not apply to websites, applications or services that do not display or link to this Privacy Policy, or that display or link to a different privacy policy.

This Privacy Policy has been compiled to better serve those who are concerned with how their PII is being used online. PII, as described in U.S. privacy law, Directive 95/94C (“The EU Directive”) and its replacement/ the GDPR, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Should designation of a data privacy officer be required of us, our person is:

 

Roger Morgan

5800 Hannum Ave. Suite 130

Culver City, CA 90230

Email:office@masterytraining.com

 

END OF PRIVACY POLICY.