1. Scope and Relationship to Other Agreements 

1.1 Scope. This Website Privacy Policy (the “Policy”) explains how ABA Town Square, Inc. (“ABA Town Square,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you visit abatownsquare.com; create an account; use the Career Center, Community Hub, Learning Hall, Resource Commons, ABA Directory, Partner Pavilion, forms, or other general website features; register for learning or events; or otherwise interact with our online services (collectively, the “Website Services”). 

1.2 Independent Third Parties. This Policy does not govern the independent privacy practices of employers, Platform Providers, learning systems, payment processors, or other third parties whose sites, products, or services you use. Their policies may apply in addition to this Policy. 

1.3 Affiliate Services and PHI. An ABA Town Square Affiliate Services Agreement, Order Form, BAA, and Platform Provider terms may govern a separately contracted service. A BAA controls regarding PHI handled by ABA Town Square as a business associate. This Policy continues to apply to ordinary account, contact, billing, and website-use information that is not governed as PHI under a BAA. 

2. Personal Information We Collect 

The information we collect depends on the Website Services you use and the features enabled. 

Information You Provide 

• Account and profile information, such as name, email address, authentication information, location, professional role, employer or organization, credentials, biography, profile photo, and communication preferences. 

• Career Center information, such as employment interests, resume or professional-profile details, job alerts, saved jobs, applications or expressions of interest, and employer-provided listing or recruiting information. 

• Community and User Content, such as posts, comments, messages, uploaded materials, feedback, and reports submitted through interactive features. 

• Learning and event information, such as registrations, course selections, attendance, progress, assessment results, continuing-education records, certificate information, and resource downloads. 

• Affiliate, business, and inquiry information, such as practice size, service interests, requested platform or consulting support, partnership inquiries, Authorized User and administrator information, directory submissions, and information entered in forms or Order Forms. 

• Transaction information, such as the service purchased, amount, date, billing contact, and payment status. Payment-card information may be collected directly by a payment processor rather than stored by ABA Town Square. 

• Communications with us, including emails, support requests, survey responses, and records of consent or preferences. 

Information Collected Automatically 

• Device, browser, IP address, approximate location derived from IP, operating system, referring page, pages viewed, links selected, date and time, session, and similar usage information. 

• Cookie and analytics information used to operate the site, remember preferences, understand traffic, measure engagement, protect the Website Services, and improve performance. 

• Security and diagnostic information, such as login activity, error logs, suspected abuse, and fraud-prevention signals. 

Information from Other Sources 

We may receive information from service providers, Platform Providers, learning or event partners, employers, referral sources, publicly available professional sources, an ABA Town Square Affiliate, or another person who directs us to contact you. 

3. How We Use Personal Information 

• Provide, personalize, maintain, and secure Website Services, accounts, directories, and Affiliate administration. 

• Operate Career Center functions, job alerts, employer submissions, candidate profiles, and application or introduction workflows. 

• Deliver learning, MTAG, continuing-education, resource, event, and contracted-service experiences; track eligibility or completion; and issue or coordinate certificates. 

• Coordinate enrollment, Authorized User administration, billing, onboarding, and communications for selected Third-Party Platforms and other Affiliate services. 

• Host and moderate interactive areas, enforce rules, and respond to reports or disputes. 

• Respond to requests, route inquiries to the appropriate team or provider, and manage customer, Affiliate, and partner relationships. 

• Send service communications and, with any consent required by law, marketing communications. 

• Process transactions; maintain records; prevent fraud; troubleshoot; analyze use; improve accessibility, security, and user experience; and develop new features. 

• Comply with law, protect rights and safety, resolve disputes, and enforce agreements. 

4. How We Disclose Personal Information 

4.1 Service Providers. We may disclose information to vendors supporting hosting, authentication, customer relationship management, analytics, communications, security, payments, learning administration, document management, and technical operations. They may use information only for the services and purposes authorized by us and applicable agreements or law. 

4.2 Platform Providers and Service Partners. We may provide information reasonably necessary to enroll users, create accounts, coordinate onboarding or support, administer courses or certificates, process billing, or fulfill a request involving a Third-Party Platform, learning system, event, or professional service. A provider’s own terms and privacy policy may govern its separate processing. 

4.3 Employers and Career Participants. Information intentionally submitted for a job, employer, candidate introduction, or recruiting request may be shared with the relevant employer, candidate, recruiter, or application destination. A recipient independently controls information it receives outside ABA Town Square. 

4.4 Members and the Public. Profile, directory, community, or other content you choose to publish may be visible to other members or the public, depending on the feature and settings. Do not publish information you want to keep confidential. 

4.5 Legal, Safety, and Compliance. We may disclose information when reasonably necessary to comply with law or legal process; protect users, ABA Town Square, or others; investigate misuse; enforce agreements; or establish, exercise, or defend legal claims. 

4.6 Business Changes. Information may be transferred in connection with a financing, merger, acquisition, reorganization, sale of assets, or similar transaction, subject to applicable law. 

4.7 Your Direction or Consent. We may disclose information for another purpose that we explain when you direct or consent to the disclosure. 

4.8 No Sale or Targeted Advertising. ABA Town Square does not sell personal information, share personal information for cross-context behavioral advertising, or process personal information for targeted advertising. Disclosures to service providers and Platform Providers are limited to the operational and fulfillment purposes described in this Policy. 

5. Cookies, Analytics, and Similar Technologies 

We and authorized providers may use cookies, pixels, local storage, and similar technologies to operate Website Services, remember preferences, measure traffic and engagement, and support security. We do not use these technologies for targeted advertising. Where required, we will request consent before using non-essential technologies. Browser settings may permit blocking or deleting cookies, but some functions may not work properly. 

6. Communications and Marketing Choices 

We may send account, security, transaction, learning, platform-administration, billing, or other service messages needed to provide requested services. You may opt out of promotional emails by using the unsubscribe link or contacting us. Opting out of marketing does not stop essential service communications. 

7. Data Retention 

During an active account, service, or business relationship, we retain personal information as reasonably necessary to provide the requested services. Unless a longer period is required by law, a Specific Agreement, or a legitimate recordkeeping obligation, we will delete or de-identify personal information no later than six (6) months after the applicable account is closed, service is completed, or last substantive interaction occurs. Transaction, continuing-education, dispute, security, and compliance records may be retained longer when reasonably necessary or legally required. PHI retention, return, or destruction is governed by the applicable BAA and Specific Agreements. 

8. Security 

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. No website, transmission, or storage system is completely secure, and we cannot guarantee absolute security. You are responsible for protecting login credentials and promptly notifying us of suspected unauthorized access. Security and breach duties concerning PHI are governed additionally by the applicable BAA. 

9. Your Choices and Privacy Rights 

9.1 Account and Marketing Choices. You may update certain account information through your profile and may unsubscribe from promotional email. Public profile and community visibility may depend on available settings. 

9.2 Legal Rights. Depending on where you live and whether a law applies to ABA Town Square, you may have rights to request access, correction, deletion, or a copy of personal information; opt out of certain sale, targeted advertising, sharing, or profiling; limit certain uses of sensitive information; withdraw consent; or appeal a decision on a request. Rights are subject to applicable exceptions and do not all apply in every jurisdiction. 

9.3 Requests and Appeals. Submit a request or appeal using the contact methods in Section 15. We may verify your identity and authority. Authorized agents may submit requests where permitted. You are not required to create a new account solely to exercise a privacy right, and we will not discriminate against you for exercising an applicable right. 

10. Children’s Privacy 

Website Services are intended for adults and professional users and are not directed to individuals under eighteen (18). We do not knowingly collect personal information from children under thirteen (13). If you believe a child has provided personal information, contact us so we can evaluate and address the request. We do not authorize users to submit identifying information about a child through general Website Services. 

11. Patient, Client, and Protected Health Information 

11.1 General Website Features. Do not submit patient or client names, treatment records, PHI, confidential case material, or identifying information about a child through profiles, community posts, forms, resumes, or other general Website Services. General Website Services are not represented as a clinical record system or HIPAA-compliant repository. 

11.2 Approved Service Configurations. An ABA Town Square Affiliate may transmit PHI only through a service configuration expressly approved for that purpose after all required BAAs and Platform Provider agreements are effective. The applicable BAA establishes permitted uses and disclosures, safeguards, incident reporting, subcontractor duties, and return or destruction requirements. A Platform Provider may act as the Affiliate’s direct business associate or as ABA Town Square’s subcontractor, as documented for the configuration. 

12. Third-Party Sites and Services 

Website Services may link or redirect to employers, Platform Providers, learning systems, payment services, social networks, and other third parties. Those parties operate independently and may collect information under their own policies. Review their terms and privacy practices before providing information. ABA Town Square is not responsible for a third party’s independent privacy or security practices. 

13. Users Outside the United States 

Website Services are offered only to users located in the United States at this time, and international users may not create accounts, enroll in paid offerings, or otherwise use restricted Website Services. International visitors are encouraged to contact ABA Town Square using the information in Section 15 to express interest or ask about future availability. 

14. Changes to This Policy 

We may update this Policy prospectively. We will post the revised version and update the effective date. If required by law, we will provide additional notice or obtain consent. An update to this Policy does not amend a BAA or other Specific Agreement. 

15. Contact Us 

• ABA Town Square, Inc. 

• 5306 Lee Hwy., Warrenton, Virginia 20187 

• Privacy requests and appeals: info@abatownsquare.com