PRIVACY POLICY
We respect your right to privacy and, therefore, we have drafted this privacy policy to inform you about its data processing practices and your rights. 

Please read this privacy policy carefully. If, after reading it, you have any questions, please contact us for further clarifications. 

1. General
1.1 Applicability and responsible entity. This privacy policy applies to the processing of personal data collected through the website https://www.mygatewaynow.com (the “Website”) and the related services (the “Services”) (collectively, “MyGatewayNow”) owned and operated by the sole proprietor Justin Black having a business address at 810 Guy Street, Montreal, QC H3J 1T4, Canada (“we”, “us”, and “our”). This privacy policy does not cover any third-party websites, software products or services. 

1.2 About MyGatewayNow. MyGatewayNow provides information about digital marketing strategies and offers for sale products and services in the field of digital marketing. 
1.3 We as a data controller and data processor. When handling personal data, we act as a data controller and a data processor in terms of the applicable data protection laws, including, the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is collected and used as explained in detail below:
We as a data controller. We act in the capacity of a data controller when we ask you to submit your personal data that is necessary to ensure your direct access and use of MyGatewayNow (e.g., when you conclude a service contract, browse the Website, or communicate with us). In such instances, we make decisions about the types of personal data to be collected and the purposes for which such personal data should be used. We comply with data controller’s obligations set forth in the applicable laws.
-  We as a data processor. We act in the capacity of a data processor in situations when you, within the scope of the Services, submit personal data to us for processing (the “Service Data”) and that Service Data contains personal data. We do not own, control, or make decisions about the Service Data. We processes the Service Data only in accordance with the instructions provided by you. When submitting the Service Data, you usually act as a data controller and you are responsible for deciding what personal data should be collected from data subjects and how such data should be processed by us.   
1.4 Children. MyGatewayNow is not marketed to and should not be accessed and used by persons under the age of 18. Therefore, we do not collect personal data from persons under the age of 18. 
1.5 Term and termination. This privacy policy enters into force on the date specified at the top of the privacy policy and continues in effect until updated or terminated by us. 
1.6 Amendments. If we decide to amend this privacy policy in order to address changes in our business practices, laws, regulations, or industry standards, this page will be amended and, if your your contact details are known to us, you will receive a notice about the amendments. We will specify the date of last amendment at the top of the privacy policy. We encourage you to review then-current privacy policy from time to time to stay informed.
1.7 Your consent. Taking into account that we rely on the legal bases for the processing of your personal data other than your consent (section 2 provides more information), you do not have to consent to this privacy policy. Nevertheless, we may seek your specific and informed consent if: 
- We decide to collect personal data that is not mentioned in this privacy policy; 
- Your personal data needs to be used for purposes that are not indicated in this privacy policy; 
- Your personal data needs to be disclosed or transferred to third parties that are not specified in this privacy policy; or
- Your consent is required under the applicable law. 
1.8 Cookies. The Website uses cookies. Some of the Services are also based on cookies. Cookies may be considered to be personal data (e.g., when they allow tracking you and customizing the Website accordingly). 
1.9 Third-party links. The Website may contain links to other websites or services. Please be aware that we are not responsible for the privacy practices of those third-party websites and services. For security purposes, you should always consult the privacy notices of any third-party websites, software, or service that you access.

2. Types and purposes of personal data collected by us
When you use MyGatewayNow, we collect some data from you, both personal and non-personal as described in detail below. We comply with data minimisation principles and, therefore, we collect only a minimal amount of personal data that is necessary to ensure your use of MyGatewayNow. Your personal data is used only for specific purposes for which it is requested. We do not re-purpose your personal data without your prior consent. Below, you can find a detailed list of all personal data that we collect from you, the purposes for which your personal data is used, and the legal bases on which we rely when processing your personal data.
2.1 Personal data collected when you signup. When you signup on the Website, we collect your (i) full name, (ii) email address, (iii) phone number, and (iv) credit card number and its expiration date. Such personal data is used to:
- Verify, create, and maintain your user account;
- Provide you with the requested services;
- Process your payments;
- Maintain our business records;
- Contact you, if necessary;
- Send updates;
- Analyse our business; and
- Send promotional materials (subject to your prior consent).
The legal bases that we rely upon when processing your personal data are: 
- Performing a contract with you;
- Pursuing our legitimate business interests (i.e., to analyse and improve our business); and 
- Your consent (for promotional materials).
2.2 Personal data collected when you purchase our products and Services. When you purchase our products and services, we collect your (i) full name, (ii) email address, (iii) phone number, and (iv) credit card number and its expiration date. Such personal data is used to:
- Process your order;
- Deliver you the ordered products and services;
- Process your payments;
- Maintain our business records;
- Contact you, if necessary;
- Analyse our business.
The legal bases that we rely upon when processing your personal data are: 
- Performing a contract with you; and
- Pursuing our legitimate business interests (i.e., to analyse and improve our business).
2.3 Personal data collected when you browse the Website. When you browse the Website, we or our third-party analytics service providers collect your IP address and cookie-related data. Such data is used to conduct analytics about your use of the Website, analyse the content available on the Website, and prevent abuse of the Website. The lawful basis that we rely upon when processing your IP address is pursuing our legitimate business interests (i.e., to analyse and improve our business and ensure security).
2.4 Personal data collected when you contact us. When you contact us by email, we collect your (i) name, (ii) email address, and (iii) any information that you, at your own discretion, decide to provide in your message. Such data is used to respond to your message. The legal basis that we rely upon is pursuing our legitimate business interests (i.e., to grow the business); if you provide optional personal data, the legal basis is your consent.  
2.5 Personal data collected when you leave a testimonial. When you agree to submit a testimonial, we collect your (i) name, (ii) company name, (iii) professional position, (iv) photo, and (v) any information that you, at your own discretion, decide to provide in your testimonial. Please note that the submission of testimonials is entirely optional. The legal basis that we rely upon is your consent.  
2.6 Sensitive data. We do not collect special categories of personal data (also known as sensitive data), i.e., information about natural person’s health, opinion about religious and political beliefs, racial origins, membership of a professional or trade association, or information about sexual orientation.
2.7 Your refusal to provide personal data. If you decide not to provide us with your personal data when requested, we may not be able to perform the requested operation (e.g., to register your user account, deliver you the requested services, or reply to you) and you may not be able to use the full functionality of MyGatewayNow.
2.8 Personal data received from third parties. We may also receive and retain information, including personal data, from third parties, such as our service providers, social media networks, ad networks and marketing agencies, which all relate to your preferences and your use of different websites on the Internet. Such personal data will be used to provide the Services only, as agreed with the respective third party and, in most cases, we will act as a data processor with regard to such personal data.

3. The Service Data processed by us
3.1 Types of the Service Data. When you use the Services, we process personal and non-personal data submitted by you. Such data may include data subjects’ social media profiles, geo-location data, IP addresses, cookie-related data, device ID, browser type, operating system, activity logs, browsing history, search history, interest-related data, interactions with other websites, online behaviour data, and other personal data submitted by you to us within the scope of the Services.
3.2 Purposes of the Service Data. We use the Service Data to provide you with the requested services. The legal basis that we rely upon when processing the Service Data is performing a contract with you. We do not intentionally access, manage, correct, delete, share, disclose or grant rights to the Service Data in any manner if it is not necessary for the provision of the Services or enforcement of our legal terms. You are solely responsible for the Service Data, including making sure that the Service Data was obtained in a lawful manner.You are not allowed to submit any personal data that was obtained in an unlawful manner (e.g., without consent of a data subject).

4. Non-personal data
4.1 Types of non-personal data. When you browse the Website, we or our third-party service providers automatically collect information about your activity on the Website that helps them to analyze the Website, including:
- The type of your computing device; 
- The type of your operating system; 
- The type of your browser; 
- Your scroll depth;
- The pages that you view and your time logs; 
- Web addresses that you access from the Website; 
- Information about your screen; and 
- Your other online behavior data. 
4.2 Purposes of non-personal data. The non-personal data listed above is used to assist you in using the Website (e.g., to avoid re-entering certain data), resolve technical issues, analyze your use of the Website, personalise your browsing experience, improve the Website, develop new services, and prevent abuse of the Website.
4.3 Aggregated and de-identified data. If your non-personal data is combined with your personal data and such combination allows us to identify you as a natural person, we will treat aggregated data as personal data. If your personal data is de-identified, such data will not be personal data and we may use it for any reasonable business purpose. 

5. Disclosure of personal data
5.1 When is your personal data disclosed? To ensure and facilitate the provision of MyGatewayNow, we may need to disclose your personal data to its third-party service providers and other third parties mentioned in this section 5. Your personal data will be disclosed to third parties only in circumstances where:
- Your personal data is necessary for (i) ensuring the provision of services requested by you, (ii) replying to your inquiries, or (iii) achieving other purposes for which your personal data was provided;
- We have obtained your prior informed consent for sharing your personal data with third parties. Such consent will be requested for any purpose that is not directly connected with providing MyGatewayNow; or 
- We have a good reason to believe that your personal data is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process, enforceable governmental or regulatory request; (ii) enforce our legal terms; (iii) detect, prevent, or otherwise address fraud, security or technical issues; or (iv) protect our or your rights, property or safety, as required or permitted by law.
5.2 List of third parties that access your personal data. The third parties that we cooperate with to ensure and facilitate the provision of MyGatewayNow (i.e., our data processors) agree to ensure an adequate level of protection for your personal data that is consistent with this privacy policy and the applicable data protection laws. Our data processors include the following entities:
- Automated email service provider Sendgrid located in the United States (https://sendgrid.com);
- Marketing funnels service provider Click Funnels located in the United States (https://www.clickfunnels.com); 

- Payment service provider Stripe located in the United States (https://stripe.com); and
- Our independent contractors and consultants.
5.3 Merger and acquisition. In the event of merger or acquisition, we may need to share and transfer your personal data to the new business entity (or the new combined entity), which will be required to follow this privacy policy with respect to your personal data.
5.4 Disclosures required by law. If we receive a request from a public authority, we may disclose information about you, including your personal data, if such a disclosure is necessary for pursuing a public interest objective, such as national security or law enforcement.

6. Security
6.1 Security measures. We implement industry-appropriate organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure, including: (i) secured networks (SSL encryption); (ii) strong passwords; (iii) limited access to your personal data by its staff; and (iv) anonymisation of personal data (when possible). In order to ensure the security of your personal data, you should use MyGatewayNow through a secure network only. 
6.2 Security breaches. We put our best efforts to protect your personal data. However, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond its reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law. 

7. International transfers
7.1 Transfers. If it is necessary for the provision and facilitation of MyGatewayNow, your personal data may be transferred to third parties located outside the country where you reside. For example, if you reside in the country belonging to the European Economic Area (EEA), we will transfer your personal data to jurisdictions outside the EEA (e.g., to Canada or the United States). 
7.2 Safeguards. When a transfer of your personal data is necessary, we implement the necessary safeguards to ensure that the transferred personal data is properly protected. For example, we make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for personal data, the recipient is a Privacy-Shield certified entity, or an agreement is concluded with a respective third party that ensures such protection (e.g., a data processing agreement based pre-approved standard contractual clauses).

8. Retention period
8.1 Retention of personal data. Your personal data is stored in our databases only as long as it is necessary for the purposes described in this privacy policy or until you request us to delete your personal data. After your personal data becomes no longer necessary for its purposes and there is no other lawful basis for storing it, we will make sure to immediately securely delete such personal data.
8.2 Retention of non-personal data. We may retain non-personal data (e.g., technical data collected from you or de-identified data) for as long as necessary for the purposes described in this privacy policy, including for the time period needed for us to pursue legitimate business interests.
8.3 Retention as required by law. In certain cases prescribed by law, we obliged to store your personal data for a limited period of time (e.g., for accountancy purposes or for archiving business records). In such cases, your personal data will be stored for the time period stipulated by the applicable law and deleted as soon as the required retention period expires.

9. Data subjects’ rights
9.1 List of your rights. You, as a data subject, have certain rights to control how your personal data is used by us. Unless there are any exemptions provided by the applicable law, you have the right to ask us to:
- Get a list of your personal data that we store;
- Get information about the purposes for which your personal data is collected and used;
- Rectify inaccurate personal data;
- Move your personal data to another processor;
- Delete your personal data;
- Object and restrict processing of your personal data (e.g., for marketing purposes);
- Withdraw your consent, if you have previously provided it; or
- Process your complaint regarding your personal data.
9.2 Exercising your rights. Some of the rights above (e.g., rectification or deletion of your personal data) can be exercised through your user account on the Website. You merely need to edit or delete personal data that you do not wish to share. To exercise other rights, you can contact us by email at support@mygatewaynow.com and explain your request in detail. You may be asked to provide an identifying piece of information for verification purposes. Your request will be answered within a reasonable timeframe but no later than 30 calendar days.
9.3 Lodging a complaint. If you have any concerns about the way in which we handle your personal data, please contact us first. After receiving your complaint, we will investigate it and provide you with its response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
9.4 Requests regarding the Service Data. When we act in the capacity of a data processor with regard to the Service Data, we do not accommodate requests related to the access, rectification, deletion, or other rights with regard to the Service Data. The persons that would like to exercise their rights with regard to the personal data processed by us should contact the respective data controller with regard to that personal data. In case we receive a request related to the Service Data directly from a data subject, it will not take action and inform the respective data controller without undue delay.
10. Commercial communication
10.1 Commercial communication. From time to time, we may send you promotional information about us, our discount offers, our other services, websites, sales promotions, newsletters, and SMS updates relating to MyGatewayNow. You will receive such commercial communication only in the following instances:
- If we receive your prior express (“opt-in”) consent to receive marketing messages (please note that your voluntary subscription to our newsletters or other promotional materials substitutes such consent); or
- If we decide to send you marketing messages about our new services that are closely related to the services already used by you. 
10.2 Opting-out from commercial communication. If you would prefer not to receive any commercial communication from us (or any part of it), you can easily opt-out free of charge. To do so, please follow the unsubscribe instructions in the message that we send to you. Kindly note that unsubscribing from one commercial communication medium does not automatically lead to un-subscription from the other. We will cease to send you commercial communication as soon as possible. If you have any concerns regarding our commercial communication, please contact us immediately. 
10.3 Informational notices. From time to time, we send you important informational notices related to service updates, technical or administrative matters, information about MyGatewayNow, your orders, payments, user accounts, your privacy and security, and other important matters. Such informational notices are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that requires your prior consent.

11. Contact
We wish to make our privacy practices clear and easy to understand. If you have any questions or concerns regarding this privacy policy or your personal data, please contact us by using the following contact details:
Email: support@mygatewaynow.com
Postal address: MyGatewayNow, 810 Guy Street, Montreal, QC H3J 1T4, Canada

***
TERMS & CONDITIONS
These Terms and Conditions (the “Terms”) for the website http://www.mygatewaynow.com (the “Website”) constitute a legal agreement between the user (“user”, “you”, and “your”) of the Website and Justin Black having an address at 810 Guy St, Montreal Quebec, Canada (“JB”).

By using the Website, you agree to be legally bound by these Terms. In case you do not agree with one or more provisions of these Terms, please do not use the Website. You are authorized to use the Website only if you agree to these Terms.

Your use of the Website is also governed by the Privacy Policy available at https://www.mygatewaynow.com/legality any other terms and conditions contained elsewhere on the Website.

1. About the Website
1.1 The Website allows you to purchase a digital course on how to change your Facebook profile to generate more leads and sales (the “eLearning Course”).

2. Payments
2.1 The eLearning Course is offered in three versions, namely, (i) a USD 7 version, (ii) a USD 37 version, and (iii) a USD 197 version. The USD 197 version constitutes a membership version allowing users to access multiple lessons once they fully pay the USD 197 version. The USD 197 version can be paid in two installments, namely one installment of USD 99 and one installment of USD 99.

2.2 The fees for the eLearning Course can be paid by using Stripe (stripe.com).

2.3 JB offers a full 100% moneyback guarantee for users requesting refund within a time period of 30 days commencing on the day of the purchase.

3. Customer support
3.1 Customer support is provided by email at support@mygatewaynow.com.

4. License to use the eLearning Course
4.1 Subject to paying the applicable fee, JB grants you a limited and non-exclusive license to use the eLearning course for the purpose for which it is provided. You are not allowed, without the explicit written permission of JB, to make the eLearning Course publicly available or share it with third parties.

5. JB’s Content
5.1 Some of the content published on the Website, including, but not limited to, text, images, audiovisual content, source code, trademarks, service marks, and trade names, is owned by JB, its partners, agents, licensors, vendors, and/or other content providers (“JB’s Content”). JB’s Content is protected by the applicable intellectual property laws. Unless otherwise provided in the Terms, you are not allowed to copy or use in any manner JB’s Content without obtaining a prior written permission from JB.

6. Your warranty to JB
6.1 You represent and warrant that you will not use the Website and the eLearning Course in a way that violates these Terms and any applicable law.

7. Availability
7.1 JB puts reasonable efforts to ensure that the Website is always available. Nevertheless, JB cannot guarantee that the Website would be always available because the availability of the Website may be affected by factors which JB cannot control, e.g., bandwidth problems, equipment failure, and other Force Majeure events. JB disclaims any liability for the unavailability of the Website caused by such factors.

8. Testimonials
8.1 The Website contains various testimonials. The results obtained by the clients who provided the testimonials are not necessarily typical. You specifically recognize and agree that the testimonials are not a guarantee of results that you or anyone else will obtain by using the eLearning Course. 

9. No professional advice and professional-client relationship
9.1 The information contained in the eLearning Course and on the Website shall not be understood or construed as professional advice. The information in the eLearning Course and on the Website is not a substitute for advice from a professional who is aware of the facts and circumstances of your particular situation. Regardless of anything to the contrary, nothing stated in the eLearning Course or on the Website shall be understood as a recommendation that you should not consult with a professional to address your particular situation. JB expressly recommends that you seek advice from a professional.

9.2 JB shall not be liable or responsible for any errors or omissions in the eLearning Course or on the Website or for any damage that you may suffer as a result of failing to seek competent advice from a professional who is familiar with your situation.

9.3 Your use of the eLearning Course and the Website, including implementation of any suggestions set out in the eLearning Course and on the Website, does not create a professional-client relationship between JB and you.  

10. No guarantees
10.1 You agree that JB has not made any guarantees about the results of taking any action, whether or not recommended in the eLearning Course and on the Website. JB provides information and educational resources that are intended to help people to succeed in their business. You, nevertheless, recognize that the ultimate success or failure will result from various factors, including, but not limited to, your particular situation, your efforts, and circumstances beyond your control. You also acknowledge that prior results do not always lead to a similar outcome. You agree to conduct due diligence prior to taking any action based on the information in the eLearning Course or on the Website.

11. Disclaimers
11.1 The results of the practical application of the eLearning Course may vary and will be based on your business experience, expertise, business situation, and other factors. Hence, JB does not guarantee any results from using the eLearning Course. JB does not guarantee that you will make any income as a result of the use of the eLearning Course and you accept the risk that the earnings and income statements differ by individual. The use of the eLearning course should be based on your own due diligence and you agree that JB is not liable for any success or failure of your business that is indirectly or directly related to the purchase and use of the eLearning Course.

12. NO WARRANTIES AND REPRESENTATIONS
12.1 JB MAKES NO WARRANTIES REGARDING THE ELEARNING COURSE AND THE WEBSITE. JB MAKES NO REPRESENTATIONS OR WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, AS TO THE INFORMATION, CONTENTS, AND MATERIALS INCLUDED IN THE ELEARNING COURSE AND THE WEBSITE. TO THE FULLEST EXTENT PERMISSIBLE UNDER THE LAW, JB DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. 

12.2 JB MAKES NO REPRESENTATIONS ABOUT THE SUITABILITY, RELIABILITY, AVAILABILITY, TIMELINESS, AND ACCURACY OF THE ELEARNING COURSE AND THE WEBSITE. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE ELEARNING COURSE AND THE WEBSITE ARE PROVIDED ON AN “AS IS” BASIS, WITHOUT ANY WARRANTY OR CONDITION OF ANY KIND.

13. LIMITATION OF LIABILITY
13.1 YOU AGREE TO ABSOLVE JB OF ANY AND ALL LIABILITY OR LOSS THAT YOU OR ANY PERSON OR ENTITY ASSOCIATED WITH YOU MAY SUFFER OR INCUR AS A RESULT OF USE OF THE ELEARNING COURSE AND THE WEBSITE. YOU AGREE THAT JB SHALL NOT BE LIABLE TO YOU FOR ANY TYPE OF DAMAGES, INCLUDING DIRECT, INDIRECT, SPECIAL, INCIDENTAL, EQUITABLE, OR CONSEQUENTIAL LOSS OR DAMAGES FOR USE OF THE ELEARNING COURSE OR THE WEBSITE, EVEN IF THE JB HAS BEEN ADVISED OF THE POSSIBILITY OF DAMAGES. BECAUSE SOME STATES/JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. UNLESS OTHERWISE STATED IN THESE TERMS, IF YOU ARE DISSATISFIED WITH ANY PORTION OF THE ELEARNING COURSE AND THE WEBSITE, OR WITH ANY OF THESE TERMS, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE ELEARNING COURSE AND THE WEBSITE.

14. Third party links
14.1 The Website and the eLearning Course may contain links to websites owned by third parties. JB is not responsible in any manner for the content of such third party websites.

15. Governing Law
15.1 The Terms shall be governed by the laws of Quebec, Canada. Any disputes arising out of or in relation to these Terms shall be submitted to the exclusive jurisdiction of Montreal, Canada.

16. Amendment of the Terms
16.1 The Company reserves the right to amend or modify the Terms from time to time by posting an amended version on the Website and indicating the date of the amendment. In case you continue using the Website and the eLearning Course after such an amendment, you agree to the amendments of the Terms. Please note that it is your responsibility to (i) read the Terms before starting to use the Website and the eLearning Course and (ii) regularly review the Terms for any amendments. 

17. Severability
17.1 Any part, provision, representation or warranty of these Terms which is prohibited or which is held to be void or unenforceable shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions of these Terms.

18. Last amendment
18.1 The Terms have been last amended on the 15th of July 2020.
EARNINGS DISCLAIMER
The results of the practical application of the eLearning Course may vary and will be based on your business experience, expertise, business situation, and other factors. Hence, JB does not guarantee any results from using the eLearning Course. JB does not guarantee that you will make any income as a result of the use of the eLearning Course and you accept the risk that the earnings and income statements differ by individual. The use of the eLearning course should be based on your own due diligence and you agree that JB is not liable for any success or failure of your business that is indirectly or directly related to the purchase and use of the eLearning Course.

REFUND POLICY
100% money back guarantee within 30 days of purchase .
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