Privacy Policy
Privacy Policy
Last modified: 3/8/2026
Definitions
For the purposes of this Privacy Policy (“Policy”):
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“Affiliate” means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
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“Account” means a unique account created for You to access our Service.
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“Company” (referred to as either "the Company", "We", "Us" or "Our" in these Terms) refers to The Village ABA Services, LLC.
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"Consumer", for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
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"Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
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“Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet.
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“Feedback” means feedback, innovations or suggestions sent by you regarding the attributes, performance or features of our Service.
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"Personal Data" is any information that relates to an identified or identifiable individual.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You. -
"Sale", for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Data to another business or a third party for monetary or other valuable consideration.
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“Service” refers to products and services we provide you through the Website.
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"Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
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"Website" refers to the website of The Village ABA Services, LLC accessible from www.tviaba.com
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“You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Introduction
We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes (a) the types of information we may collect from you or that you may provide when you visit the Company’s Website, and (b) our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
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On the Website.
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In email, text, and other electronic messages between you and the Website.
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When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
Except as otherwise provided in this policy, it does not apply to information collected by:
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Us offline or through any other means, including on any other website or application operated by Company or any third party; or
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Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, including, without limitation, by providing us with Personal Data to complete a transaction, verify your credit card, or place an order, you agree to this privacy policy and consent to our collecting such information. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
You also acknowledge and agree that your access to and use of our Website is subject to our Terms of Use and any conflict between this policy and the Terms of Use will be determined in favor of the Terms of Use. You also acknowledge and agree that we are not responsible for how third-parties, vendors, and Service Providers collect or use your information.
Capitalized terms used in this policy, and not otherwise defined, will have the same meaning as in our Terms of Use.
Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under-age 13 may provide any information to or on the Website. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on the Website or Application or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at contact@tviaba.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Data. Please see the California Privacy Statement section below for more information.
Personal Data We Collect
When you use the Website, we automatically collect certain information about your Device, including information about your web browser, IP address, time zone, and some of the Cookies that are installed on your Device. Additionally, as you browse the Website, we collect information about the individual pages or features of the Website that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this automatically collected information as “Device Information”. Finally, we collect information you provide about yourself, your firm or company, and your practices when you register for an account, purchase products and services we sell and provide, or register for email newsletters and alerts.
We collect Device Information using the following technologies:
- “Cookies”. For more information about cookies, and how to disable Cookies, visit http://www.allaboutcookies.org.
- “Log files” which track actions occurring on the Website or Application, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” which are electronic files used to record information about how you browse the Website or Application.
How do we use your Personal Data?
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Website (for example, by generating analytics about how our customers browse and interact with the Website, and to assess the success of our marketing and advertising campaigns). Generally speaking, we use your Personal Data for purposes of administering and expanding our business activities, providing client services and making available other products and services to our clients and prospective clients.
Sharing your Personal Data
a. Third Party Service Providers
We share your Personal Data with third party service providers to help us use your Personal Data, as described above. For example, we may use Google Analytics, Facebook Pixel, and LinkedIn Insight to help us understand how our customers use the Website.
In general, these third-party service providers will only collect, use, and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for your purchase-related transactions. For these third-party service providers, it's mandatory that you read their privacy policies so you can understand the manner in which your Personal Data will be handled.
Remember that certain third-party service providers may be located in, or have facilities that are located in, a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party, then your information may become subject to the laws of the jurisdiction(s) in which that third party service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your Personal Data used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Once you leave our Website, or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Website’s Terms of Use.
When you click on links on our Website, they may take you away from our Website. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements or policies.
b. Emails
We reserve the right to share emails between connected users on the Website. All users agree to share their emails with us.
c. Postal addresses
We may access a user’s personal postal address information only if the user has agreed to share their personal address with other Users.
This address information can only be used to deliver tangible products and cannot be shared with anyone else even if the User made a personal agreement with another user to do so.
d. Applicable Laws and Regulations
Finally, we may also share your Personal Data to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful request for information we receive, or to otherwise protect our rights.
Behavioral advertising
We may maintain a presence on third-party social networking sites such as Facebook, LinkedIn, X, and others. We do not control, and are not responsible for, the collection, tracking, use, or disclosure of your information (including your Personally Identifiable Information) gathered through social networking websites and applications, including through other applications, or otherwise as a result of your participation in social networking sites. Third-party social networking applications and advertisers on these applications, including on the Website pages within these sites, are not obligated to follow or apply this policy or our Terms of Use. If you have any questions about an advertisement or other targeted content, you should contact the responsible social networking provider directly and refer to the applicable privacy policy and terms of use of that social networking provider.
As described above, we may use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Cross-Device Tracking
Functionality within our Website may permit you to roam and access services, preferences, and content across your computing devices from phones to tablets. Rather than residing as a static software program on your device, key components of the Website are cloud-based, updated periodically, to provide you with the latest improvements and features. In order to provide this experience, we collect data about you, your device, and the way you use our Website.
Do Not Track
Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.
Changes
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
Accessing and Correcting Your Information
You can review and change your Personal Data by logging into the Website and visiting your Account profile page. You may also send us an email at contact@tviaba.com to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Data Security
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the, if any. The information you share in such public areas may be viewed by any user of the Website.
Your credit card data is stored through a PCI-compliant payment gateway service data storage. They store your data on a secure server behind a firewall. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands including Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our Website and its Service Providers.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' Personal Data, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: contact@tviaba.com.
Privacy Statement – California
This privacy statement section is for California residents and supplements the information contained in our Privacy Policy. It applies solely to Consumers who reside in the State of California.
Information we Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular client or Device. The following is a list of categories of Personal Data we have collected, or may collect, from California residents within the last twelve (12) months.
Please note that the categories and examples provided below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact collected by us, but reflects our good faith belief, to the best of our knowledge, that some of that information from the applicable category may be and may have been collected. For example, certain categories of Personal Data would only be collected if You provided such Personal Data directly to us.
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Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Account name, driver's license number, passport number, or other similar identifiers.
Collected: Yes
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Category B: Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Data included in this category may overlap with other categories.
Collected: Yes.
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Category C: Protected classification characteristics under California or federal law.
Examples: 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 familial genetic information).
Collected: No
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Category D: Commercial information.
Examples: Records and history of products or services purchased or considered, or other purchasing or consuming histories or tendencies.
Collected: Yes
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Category E: Biometric information.
Examples: 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.
Collected: No
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Category F: Internet or other similar network activity.
Examples: Browsing history, search history, information on a Consumer’s interaction with a website, application, or advertisement.
Collected: Yes
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Category G: Geolocation data.
Examples: Physical location or movements.
Collected: No
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Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No
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Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No
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Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: Yes
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Category K: Inferences drawn from other Personal Data.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: Yes
Personal Data does not include:
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Publicly available information from government records
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De-identified or aggregated Consumer information
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Information excluded from the CCPA's scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
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Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Sources of Personal Data
We obtain the categories of Personal Data listed above from the following categories of sources:
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Directly from you. For example, from the forms you complete on our, preferences you express or provide through our Website, or from your purchases through our Website.
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Indirectly from you. For example, from observing your activity on our Website, or in the course of providing goods or services to you.
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Automatically from you. For example, through Cookies we, or our third parties that interact with us in connection with products or services we provide (“service providers”), set on your Device as you navigate on our Website, of from submissions through our Website.
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From Service Providers. For example, third-party vendors to monitor and analyze the use of our Website, third-party vendors for payment processing, or other third-party vendors that we use to provide our products or services to you.
Use of Your Personal Data
We may use or disclose Personal Data we collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following:
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To operate our Website and provide you with our products and services.
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To improve our Website and present its contents to you.
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To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our products or services.
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To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Service, We will use that Personal Data to respond to your inquiry. If you provide your Personal Data to purchase a product or service, we will use that information to process your payment and facilitate delivery.
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To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
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As described to you when collecting your Personal Data or as otherwise set forth in the CCPA.
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For internal administrative and auditing purposes.
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To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
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As necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.
If we decide to collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Statement.
Disclosing Your Personal Data
We may use or disclose, and may have used or disclosed in the last twelve (12) months, the following categories of Personal Data for business or commercial purposes: Categories A, B, D, F, J, K
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be, and may have been, disclosed.
When we disclose Personal Data for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract.
Sale of Your Personal Data
As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's Personal Data by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing Personal Data, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of Personal Data were in fact sold, but reflects our good faith belief that, to the best of our knowledge, some of that information from the applicable category may be, and may have been, shared for value in return.
We may sell, and may have sold in the last twelve (12) months, the following categories of Personal Data: None
Sharing Your Personal Data
We may share your Personal Data identified in the above categories with the following categories of third parties:
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Service Providers
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Payment processors
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Our Affiliates
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Our business partners
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Third party vendors to whom you or your agents authorize us to disclose your Personal Data in connection with products or services we provide to you.
Sale of Your Personal Data of Minors Under 16 Years of Age
We do not knowingly collect Personal Data from minors under the age of 16 through our Website, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies, and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.
We do not sell the Personal Data of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the Sale of Personal Data may opt-out of future Sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with Personal Data, please contact us with sufficient detail to enable us to delete that information.
Your Rights and Choices under the CCPA
The CCPA provides California residents with specific rights regarding their Personal Data. If you are a resident of California, you have the following rights:
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The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which your Personal Data is being used.
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The right to request. Under the CCPA, You have the right to request that we disclose information to you about our collection, use, Sale, disclosure for business purposes and share of Personal Data. Once we receive and confirm your request, we will disclose to You:
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The categories of Personal Data we collected about you
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The categories of sources for the Personal Data we collected about you
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Our business or commercial purpose for collecting or selling that Personal Data
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The categories of third parties with whom we share that Personal Data
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The specific pieces of Personal Data we collected about you
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If we sold your Personal Data or disclosed your Personal Data for a business purpose, we will disclose to you:
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The categories of Personal Data sold
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The categories of Personal Data disclosed
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The right to say no to the Sale of Personal Data (opt-out). You have the right to direct us to not sell your Personal Data. To submit an opt-out request please contact us.
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The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, We will delete (and direct our Service Providers to delete) your Personal Data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
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Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
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Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
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Debug products to identify and repair errors that impair existing intended functionality.
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Exercise free speech, ensure the right of another Consumer to exercise their free speech rights, or exercise another right provided for by law.
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Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
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Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
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Comply with a legal obligation.
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Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer's rights, unless permitted by the CCPA, including by:
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Denying goods or services to you
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Charging you different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
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Providing a different level or quality of goods or services to you
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Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact Us:
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By calling us at 404-313-2723
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By sending us an email: james@havgas.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Data. You may also make a verifiable Consumer request on behalf of your minor child.
Your request to us must:
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Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
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Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with the required information if we cannot:
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Verify your identity or authority to make the request and confirm that the Personal Data relates to you.
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We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.
For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Data
You have the right to opt-out of the Sale of your Personal Data. Once we receive and confirm a verifiable Consumer request from you, we will stop selling your Personal Data. To exercise Your right to opt-out, please contact us.
The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells Personal Data as defined by the CCPA. If you wish to opt out of the use of your Personal Data for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.
Website
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on our Website:
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The NAI's opt-out platform: http://www.networkadvertising.org/choices/
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The EDAA's opt-out platform http://www.youronlinechoices.com/
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The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the Cookies saved by your browser, you will need to opt out again.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Website does not respond to Do Not Track signals.
However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser.
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Contact Us
If you have any questions about this Privacy Statement, you can contact us:
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By sending us an email: contac@tviaba.com
