Privacy Policy

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PRIVACY NOTICE 

Last updated October 26, 2022 

This privacy notice for Old Town ABA, LLC ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you: 

Visit our website at http://www.oldtownaba.com, or any website of ours that links to this privacy notice 

Engage with us in other related ways, including any sales, marketing, or events 

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at rachelevans@oldtownaba.com. 

SUMMARY OF KEY POINTS 

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents. 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Old Town ABA, LLC and the Services, the choices you make, and the products and features you use. Click here to learn more. 

Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Click here to learn more. 

Do we receive any information from third parties? We do not receive any information from third parties. 

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more. 

In what situations and with which parties do we share personal information? 

We may share information in specific situations and with specific third parties. Click here to learn more. 

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 

Click here to learn more. 

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more. 

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. 

Want to learn more about what Old Town ABA, LLC does with any information we collect? Click here to review the notice in full. 

TABLE OF CONTENTS 

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 4. HOW LONG DO WE KEEP YOUR INFORMATION?
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
6. DO WE COLLECT INFORMATION FROM MINORS?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
10. DO WE MAKE UPDATES TO THIS NOTICE?
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 

1. WHAT INFORMATION DO WE COLLECT? Personal information you disclose to us 

In Short: We collect personal information that you provide to us. 

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

names
phone numbers
email addresses
mailing addresses
job titles
contact preferences billing addresses debit/credit card numbers 

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information: 

health data 

genetic data 

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Quickbooks. You may find their privacy notice link(s) here: https://quickbooks.intuit.com/hk/privacy/. 

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. 

Information automatically collected 

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services. 

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. 

2. HOW DO WE PROCESS YOUR INFORMATION? 

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. 

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. 

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services. 

To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below). 

To post testimonials. We post testimonials on our Services that may contain personal information. 

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. 

To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience. 

To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights. 

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties. 

We may need to share your personal information in the following situations: 

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 

4. HOW LONG DO WE KEEP YOUR INFORMATION? 

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

5. HOW DO WE KEEP YOUR INFORMATION SAFE? 

In Short: We aim to protect your personal information through a system of organizational and technical security measures. 

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment. 

6. DO WE COLLECT INFORMATION FROM MINORS? 

In Short: We do not knowingly collect data from or market to children under 18 years of age. 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at __________. 

7. WHAT ARE YOUR PRIVACY RIGHTS? 

In Short: You may review, change, or terminate your account at any time. 

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. 

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. 

8. CONTROLS FOR DO-NOT-TRACK FEATURES 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice. 

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. 

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. 

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.). 

CCPA Privacy Notice 

The California Code of Regulations defines a "resident" as: 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose 

All other individuals are defined as "non-residents." 

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information. 

What categories of personal information do we collect? 

We have collected the following categories of personal information in the past twelve (12) months:

Category 

A. Identifiers 

B. Personal information categories listed in the California Customer Records statute 

C. Protected classification characteristics under California or federal law 

D. Commercial information 

E. Biometric information 

F. Internet or other similar network activity 

G. Geolocation data 

Examples 

Collected 

Contact details, such as real name, alias,
postal address, telephone or mobile
contact number, unique personal identifier

H. Audio, electronic, visual, Images and audio, video or call recordings thermal, olfactory, or similar created in connection with our business NO 

information

I. Professional or employment-related information 

J. Education Information 

K. Inferences drawn from other personal information 

activities

Business contact details in order to
provide you our Services at a business
level or job title, work history, and professional qualifications if you apply for
a job with us 

Inferences drawn from any of the collected personal information listed above to create
a profile or summary about, for example, an individual’s preferences and
characteristics 

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: 

Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries. 

How do we use and share your personal information? 

More information about our data collection and sharing practices can be found in this privacy notice. 

You may contact us by email at rachelevans@oldtownaba.com, or by referring to the contact details at the bottom of this document. 

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. 

Will your information be shared with anyone else? 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for- profit entity that processes the information on our behalf. 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. 

Old Town ABA, LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Old Town ABA, LLC will not sell personal information in the future belonging to website visitors, users, and other consumers. 

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. 

Right to be informed — Request to know 

Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used; whether we sell your personal information to third parties; 

the categories of personal information that we sold or disclosed for a business purpose; 

the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and 

the business or commercial purpose for collecting or selling personal information. 

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re- identify individual data to verify a consumer request. 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights. Verification process 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you. 

Other privacy rights
You may object to the processing of your personal information. 

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information. 

You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. 

You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. 

To exercise these rights, you can contact us by email at rachelevans@oldtownaba.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you. 

10. DO WE MAKE UPDATES TO THIS NOTICE? 

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. 

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. 

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 

If you have questions or comments about this notice, you may email us at rachelevans@oldtownaba.com or by post to: 

Old Town ABA, LLC 111 Nevermore Drive Winchester 22602 

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU? 

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by clicking here.