Our Privacy Policy, which is part of our Terms of Use (“Terms”), is designed to advise you about how we use, protect, and disclose the information we receive or collect about individuals, explains your privacy rights, and how you can manage the privacy of your Personal Information. Please read the following information carefully. Capitalized terms herein have the same definition as specified in the Terms.

By accessing or otherwise using the Services, you consent to the data collection and use practices described below. Continued use by you of the Services constitutes your agreement to be bound by and subjected to this Privacy Policy as well as the Terms and User Agreement. If you do not agree with or accept the terms of this Policy and/or the Terms and/or User Agreement, you must not access or use the Services and you must discontinue all access and use of the Services.

Please note that this Policy does not govern practices of third parties, such as our partners or third party service providers. Any information you provide to a third party while utilizing their website or service will be governed by the third party’s privacy policy and/or terms of use. Please read all third parties’ privacy policies and terms of use carefully.

1. Information We Collect

We collect certain information when you use our Services. For instance, certain users must register before they may use the Services. During the course of this registration process, IBAO^® collects certain information about users. Moreover, through the use of our Services, users can provide us certain information about themselves. Such information includes:

Personal Information (also known as “Personal Data”): Any information that can be used to identify, locate, or contact an individual. This includes an individual’s (a) name; (b) phone number; (c) email address; (d) mailing/billing address; (e) an identification number (“User ID”) or other similar identifiers; (f) date of birth or age; (g) gender; (h) company name; (i) online identifiers, such as an IP address; (j) payment card information; (k) tax identification number; (l) location information; and/or (m) educational records or transcripts (n) supervision records (o) other identifying information.

Non-Personal Information (aka “Generic Information”): IBAO^® may also gather generic information from visitors to our Services automatically, but which does not directly reveal a visitor’s identity. This may include aggregate usage metrics such as the total number of visitors, the frequency of visitors to our Services, pages viewed, usage patterns within the Services, among others. We gather this information for limited purposes, like determining our Services or customer service needs. This information is not otherwise linked to your Personal Information. However, at times the combination of various types of data, including Generic information, may enable you to be identified, and may therefore qualify as Personal Information.

Aggregate Information: As noted above, we may collect aggregate usage metrics that inform how users use our Services. We may also aggregate and/or de-identify the data about users of our Services and/or learners about whom information is provided via the Services, and use it for product and service development and to improve the quality of our products and Services. This includes the information on users’ age, gender, or location, but cannot be used to individually identify any person.

2. How We Collect Information

IBAO^® collects and obtains information in a few ways: there is information you choose to give to us, information we obtain through your use of our Services, and information we obtain from third parties.

A. Information You Give To Us

At times, we may require you to provide certain Personal Information to use certain Services or to fulfill your request. For instance, users may be required to provide to IBAO^® the following information upon registration: legal name (first and last), e-mail address, telephone number, company name (if applicable), title or role (if applicable) and mailing address (“Contact Information”), date of birth, gender, educational records, transcripts, supervisor information and records. You consent to transfer and storage of any Contact Information and Student Information you provide to us on our servers. Upon user account activation, the email address used for registration is assigned as the account user ID. Upon first login to the Services, it is the user’s responsibility to create a private password.

In addition, by registering to use our Services, you agree that IBAO^® may collect billing account information, which includes billing-related contact information as well as payment card information, and/or tax identification number information (“Billing Information”). IBAO^® may share Billing Information with third party payment processors and fulfillment companies for the purpose of fulfilling and processing payments for customer orders.

We will also collect information you voluntarily provide to us, such as when you sign up for our subscription mailing service, or contact us when you have questions, feedback or comments about our Services.

To the extent users post information on or submit information to our Services, IBAO^® may collect this information and associate it with Personal Information to construct personalized user pages detailing a user’s transaction activity.

B. Information We Obtain When You Use Our Services

We also collect certain information from you through your use of our Services. For instance, our Services automatically record information a browser sends whenever a user requests login to the Services. These server logs may include information such as an Internet Protocol address, the User ID entered, the date and time of the request, and one or more cookies that may uniquely identify the browser. Any such information collected will be used only to detect and identify user login attempts/failures when login assistance is requested.

Cookies

We may use “cookies” and other similar technologies (e.g., Google Analytics) to collect certain information about your activities when accessing our Services. This is so that we can customize certain aspects of your specific experience, and improve the overall function and efficiency of our Services. Cookies are small data text files stored locally on your computer that uniquely identify your browser. For instance, certain cookies are used to enable you to move around pages that may be accessible through our Services without having to reenter your password as frequently. We may use cookies and other similar technologies (e.g., Google Analytics) to perform various tasks such as: monitoring aggregate usage metrics, storing and remembering your passwords (if you choose this option), storing your account and advertising preferences you have set, and personalizing the Services we make available to you. We do not otherwise associate your Personal Information with any information collected through the cookies.

You can adjust your browser or mobile device settings to limit, control, or let you know about what cookies your computer or device accepts. Please refer to instructions provided by your mobile device’s manufacturer and/or your browser to determine how you can limit the placement of and/or remove cookies or other technologies on your device. Please note, however, if you set your browser to reject cookies, some features of our Services may not work for you, which could impact your experience.

Our third-party service providers may use cookies or other similar technologies to collect your information and track your behavior. These companies may collect information about your use of our Services and other online services over time and across different services. IBAO^® is not responsible for the functioning of cookies or other technologies used and placed by third parties on your device.

Pixel tags: Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

Other technologies: We collect many different types of information from other technologies to improve the quality of services we provide. For example, we may collect information about the device you use to access our Services, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet.

The Services do not track user behavior over time and across other third-party websites or online services. The Services do not respond to “do not track” browser signals.

C. Information We Obtain from Third Parties

IBAO^® may collect information from various third parties about you, such as any third-party service providers who we use to provide our Services to you. For example, we may obtain information about you from our third party payment providers related to your purchasing access to and use of our Services.

3. Why We Use and Share Information

As detailed in this Policy, we will primarily use, share, and/or disclose information we obtain to provide you access to, and facilitate your use of, our Services. This includes the following instances:

1. When you consent for us to do so. We may also ask for your consent to process your personal information for a specific purpose that we communicate to you, for instance, to receive our newsletter and other such mailings you may be interested in. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.
2. To fulfill a contractual obligation that we have with you, where applicable. This includes providing you access to and use of our Services.
3. To fulfill another legitimate interest. For instance, in responding to an email from you with comments or questions about our Services.
4. To comply with a legal or statutory requirement or obligation. This may include responding to a lawful and enforceable request by law enforcement, judicial body, or other public authorities, or in connection with a legal obligation, or reporting unlawful activity to law enforcement.

4. How We Use the Information We Collect

Except as otherwise outlined in this Policy, IBAO^® only uses Personal Information for internal purposes. For instance, we will primarily use your information to provide you access to, and facilitate your use of our Services. We may also use the information provided to customize the content we provide to you.

All Personal Information beyond name, address, email address, and phone number will be used solely for IBAO^®’s internal purposes, or companies providing IBAO^® support and assistance in processing of financial transactions, fulfilling orders, and administration of the Services. Such instances include but are not limited to: order account processing and activation, processing of financial transactions, administration of our Services, account maintenance, technical and product development, customer support, and/or sales’ history, billing purposes, and construction of personalized pages for each user. More information on how IBAO^® shares or discloses information is outlined below.

We may also ask for your consent to process your Personal Information for a specific purpose that we communicate to you. When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.

5. How We Disclose or Share Information

A. Information Sharing with Other Users – Personal Information

IBAO^® only shares Personal Information with other users when we have your consent. We require opt-in consent for the sharing of any user or account information.

B. Disclosure of Information to Third Parties

We do not sell, trade, or rent your Personal Information to others, except in the limited ways outlined in this Policy. As outlined elsewhere in this Policy, IBAO^® may release or disclose your information to our subsidiaries, affiliated third-party service providers or agents who perform functions on our behalf or who facilitate the provision of our Services to you. However, we limit sharing Personal Information to those third party companies that assist IBAO^® in administering the Services, as well as companies that assist it in processing and fulfilling its orders.

IBAO^® requires that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.

In addition IBAO^® may share aggregate-level user information that it has obtained from users of the Services (such as age, gender or location) to share with third parties. The aggregate-level user information shared will not contain any Personal Information and cannot be tied to any individual user.

IBAO^® may share information with other IBAO^® entities. We may also share your information and information collected in relation to a merger, sale, financing, acquisition, or other transaction involving all or part of IBAO^® with another company.

We may also be required to disclose information in response to a lawful request by law enforcement, judicial, or other public authorities, or in connection with a legal obligation. In such instances, we will disclose your Personal Information upon receipt of a court order, subpoena, or other lawful process, or where otherwise required by law. We also reserve the right to report to law enforcement any information related to the use of our Services used to further any unlawful activity or activity we in good faith believe to be unlawful. It is IBAO^®’ policy to cooperate fully with any law enforcement officials or agencies in the investigation of any violation of any applicable laws.

IBAO^® reserves the right to use or disclose information – including Personal Information – if IBAO^® reasonably believes that the use or disclosure is necessary to protect IBAO^®’ rights. For instance, we may disclose information when have a good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary to enforce our Terms of Service, including investigation of potential violations thereof; detect, prevent, or otherwise address fraud, security or technical issues; or protect against imminent harm to the rights, property or safety of IBAO^®, or the registered users of our Services.

6. Your Access to and Choices About Your Personal Information

IBAO^® provides its users with the ability to view, update and edit, any Personal Information stored on the Services. You may view, update, edit, your Personal information on the Services by using the “Account” link to make updates or changes to your account preferences, contacting your internal Organization administrator user, or using the internal contact form found at www.theibao.com. To protect your privacy and security, we will take reasonable steps to verify your identity before making corrections, changes, or updates.

IBAO^® also offers individuals the opportunity to choose or “opt-in” to receive emails or other communications we feel may interest you. We will ask you if you want to receive such emails before we begin sending them to you. If have opted in to receive such communications from us but later decide you do not want to receive solicitations from us or our partners related to your account with us, you always can “opt-out” by accessing and editing your account information to no longer receive such offers and mailings, or by following the “unsubscribe” directions attached to such emails.

7. Your Privacy Rights

We will ensure that you can exercise your rights pertaining to your Personal Information, including rights as provided by various data protection laws. IBAO^® therefore informs you that, where applicable under relevant law, you are entitled:

• to have access to your Personal Information upon simple request – that is, you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account;
• to have access upon simple request, and free of charge, the categories and names of addresses of third parties that have received Personal Information for direct marketing purposes;
• to obtain a rectification of your Personal Information should it be inaccurate, incomplete or obsolete;
• to obtain the deletion of your Personal Information in the situations set forth by applicable data protection law (the “right to be forgotten”).
• to withdraw your consent to the data processing without affecting the lawfulness of processing, where your Personal Information has been collected and processed on the basis of your consent;
• to object to the processing of your Personal Information (where it has been collected and processed on the basis of our legitimate interests) in which case we may ask you to justify your request by explaining to us your particular situation;
• to request a limitation of the data processing in the situations set forth by applicable law;
• to have your Personal Information directly transferred by IBAO^® to a third-party processor of your choice (where technically feasible and when processing is based on your consent); and
• to non-discrimination, as defined under relevant law, in the Services or quality of Services you receive from us for exercising your rights.

Under certain laws, you may also have the right to “opt-out” of having your Personal Information sold to a third party. However, IBAO^® does not sell your Personal Information to any other party. Only in the case of a merger, sale, financing, acquisition, or other transaction involving all or part of IBAO^® may your information be involved in a transaction, as noted above.

For deletion/“right to be forgotten” requests, we will undertake a good faith effort to accommodate requests for access to or deletion of Personal Information. However, these requests may be subject to the evaluation of additional factors, including disproportionate burden or expense, or the risk to the rights, including the privacy rights, of others.

We will strive and work to resolve any inquiry you may have regarding our privacy practices. If you have any questions, would like to exercise any of these rights, or if you need any assistance with privacy related matters, please contact us as described in the “Contact Us” section below. We will take the necessary steps to respond to you as soon as possible.

8. Retention of Collected Information

We keep your Personal Information and all other information provided to IBAO^® to enable the continued use of our Services and other users, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by applicable law, as necessary to protect our rights and interests, or as otherwise communicated to you.

9. Children

All of our Services are for adult use only, and are not intended for those under 18 years of age. Similarly, our Services are not intended for or geared towards individuals under 18 years of age. Minors (individuals under the age of 18) are not eligible to use our Services. Further, by completing the registration process, during which personal identification information is collected, each authorized user verifies he or she is at least 18 years of age. All Student Information provided to IBAO^® may only be provided by individuals over 18 years of age.

10. Third Party Sites

Our Services may contain links to other websites such as accredible.com, stripe.com, etc. IBAO^® makes no representations about, and is not responsible for, the user data collection practices and uses of such other websites. Your interaction with all third party service providers’ websites is governed by the applicable third party privacy policies. We encourage you to review the privacy policies of such third party providers before using their sites or services.

11. Security

At IBAO^®, we take reasonable and appropriate security measures to protect your information from loss, misuse, and unauthorized access, alteration, disclosure, and destruction. While we strive to make your information as secure as possible, no transmission system or data network can be guaranteed to be 100% secure. As a result, visitors and users must be aware and by using the Services acknowledge, that there are data security and privacy limitations inherent to the Internet, and that the security, integrity, and privacy of any and all information cannot be guaranteed. If you are not comfortable risking the inadvertent disclosure of your private information, please do not use the Services.

12. User Communications

We may retain any communications you send to us, including emails, in order to process your inquiries, respond to your requests, and improve our Services.

13. Changes to Our Privacy Policy

IBAO^® reserves the right to change this Privacy Policy at any time and at our sole discretion. The most current version of our Policy is accessible through our Services at all times. We encourage you to review the Policy from time to time to ensure that you are familiar with our practices, and aware of any changes. IBAO^® will provide notification of material changes to this Privacy Policy through our Services at least thirty (30) days prior to the change taking effect. Your continued use of our Services after any change in Privacy Policy will constitute your acceptance of such change.

14. How to Contact Us

Should you have other questions or concerns about this Privacy Policy or our practices, please contact us at:

International Behavior Analysis Organization, Inc.

Attn: Legal

2470 Windy Hill Road, Suite 300

Marietta, GA 30067

Or by email at: info@theibao.com

15. Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents who have supplied Personal Information, as defined in the statute, to us to request and obtain certain information regarding our disclosure, if any, of Personal Information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of Personal Information shared and the names and addresses of all third parties that received Personal Information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to us at the below address. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this address.

Effective Date: 03.11.2020