Privacy Policy | Beltway ABA

የግላዊነት ፖሊሲ

This privacy notice applies to all users of our website where Beltway ABA ("Beltway ABA", "We") is the data controller for your personal data and explains the purposes for which we process your personal data, how we collect and use your personal data, how long we retain your personal data, and the rights you have in relation to your personal data. Personal data means any information that relates to an identified or identifiable living individual.

Information We May Collect From You

We collect personal data from:

Website visitors
Prospective clients inquiring about services
Prospective employees applying for an open position

Any references in this policy to "you" or "your" should be interpreted in the context in which the information is processed.

Our legal bases for processing your personal data include your consent, fulfillment of a contractual obligation, and where we have a legitimate interest to process your personal data, provided that our interests do not outweigh your individual rights and freedoms.

Our Legitimate Interests Include:

Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this policy
Protecting and defending our rights and properties, including intellectual property
Complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities or as otherwise required by law
Improving your experiences with our products and services
Understanding and improving our website, user experience, and customer relationships
Enabling our business operations

Personal Data Collection

We collect personal data that you provide to us directly, as well as information provided by your browser or device when you visit our website. We also collect personal data via the portals connected to our site (as described below).

Personal Data You Submit

We collect personal data only when you submit it to us, such as when you submit an intake form, fill out a general inquiry, apply for a job, or sign up for job alerts. The Personal Data you submit may include, but is not limited to, your name, postal address, telephone number, mobile number, email address, or gender. We will not disclose any information and phone numbers with any affiliate marketing or third parties.

Personal Data We Receive From Third Parties

To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services and commercially available sources. The Personal Data we receive from third parties may include your name, contact information, or relationships with various product and service providers, and your use of certain applications. For example, if you access the Beltway ABA site through a social media service or connect Beltway ABA to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content the social media service will share with us, such as your profile picture, or email address. The information we obtain depends on your privacy settings on the applicable social media service. When you access Beltway ABA through social media services or when you connect Beltway ABA to social media services, you are authorizing Beltway ABA to collect, store, and use such information and content in accordance with this Privacy Notice.

Other Information

"Other Information" is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, Protected Health Information, geolocation data obtained with your consent where required by applicable law, and aggregated information.

Other Information You Submit

We collect Other Information when you submit it to us. This may include your password, birthday, education or graduation year, occupation, financial information (such as your experience, professional licensing, and other information), and interests.

Other Information We Receive From Third Parties

We may receive Other Information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.

Other Information Collected Automatically

Our servers use cookies and other tracking technologies to function effectively and deliver certain features. For more information about how we use cookies and tracking technologies, read the Personal Data Collected via Web-Based Technologies section below.

Beltway ABA may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties, using iframes, tools, or plug-ins ("Linked Services"). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a Beltway ABA logo, even though they are not operated or maintained by us.

Beltway ABA is not responsible for the privacy practices of such third parties, and once you leave a Beltway ABA or subsidiary site or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.

How We Use Your Personal Data and Other Information

We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data, we treat the combined information as Personal Data.

To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal and Other Information we collect with information relating to your use of other Beltway ABA products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources, and information from Beltway ABA Affiliates or business partners.

Through third party analytics providers, ad networks, and advertisers, we can track your online activities over time and across third party websites, apps and devices, by obtaining information through automated means.

This information, along with information you submit, can be used to understand use across sites and devices to help improve our products, remember your preferences, provide content recommendations, and show you advertisements on Beltway ABA or other third party websites and apps that may be tailored to your individual interests.

To Provide, Measure and Improve Our Products and Services

We use the information we collect from and about you to provide our products, services and features to you, including: to process and fulfill your subscription, to create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve services and features, to allow you to engage with us (e.g., to comment on content and participate in online contests, promotions, special events, rewards programs, surveys or market research), to use collaboration tools to share content and collaborate with other users, to provide you with customer support, including online chat or chat bot, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Data may be included in a directory that can be viewed and used by other users of these collaboration tools.

To Deliver Relevant Content and Recommendations

To make your experience more interesting and personalized, we may use any of the Personal Data and Other Information we collect to assist us in delivering content on any Beltway ABA or subsidiary services.

To Deliver Advertising and Interest-Based Advertising

Beltway ABA and our service providers may use any of the information we collect from and about you (in certain cases, such as with respect to financial information, only with your express permission) to assist us in delivering ads about products and services tailored to your individual interests to you when you use Beltway ABA or another service provided by Beltway ABA, Beltway ABA Affiliates, or unaffiliated third parties. We may work with third party online advertising companies, advertisers and ad networks who help deliver these ads to you. These third parties may collect and use information about your activities on our Beltway ABA and on other websites, and Other Information about you which may include offline purchases, to limit the online ads you encounter to those we believe are consistent with your interests.

To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising. To learn how to opt out of online interest-based advertising, please email info@beltwayaba.com.

If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product, event, or promotional information in a text or SMS message ("Text Messages"). Your consent to receive Text Messages is not required to purchase goods or services from us. We do not share SMS opt-in or phone numbers for marketing purposes.

To Allow Social Sharing Functionality

If you log in with or connect a social media service account with Beltway ABA or one of its subsidiaries, we may use Personal Data and Other Information to facilitate your sharing of information between Beltway ABA and your social media service.

To Contact You

Beltway ABA and Beltway ABA Affiliates may periodically send promotional materials, with your permission where required, surveys, market research, contest or promotional awards, or notifications related to our products and services. To help make these materials more relevant to you, we may use and combine any of the Personal Data and Other Information we collect to assist us in sending you these materials. We may also use your information (including a telephone or mobile number you may have provided for this purpose) to contact you, including to respond to your comments, inquiries, or requests. If you want to stop receiving these materials, please follow the instructions in the Your Rights and Choices section below.

To Protect the Rights of Beltway ABA and Others

Beltway ABA may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Beltway ABA, our Beltway ABA Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.

Lawful basis: The processing is necessary for our legitimate interests, or the legitimate interests of a third-party.

If you choose to register for updates from Beltway ABA, we collect information for the purpose of providing you with periodic updates regarding new product offerings, job opportunities, clinical research and product or company updates.

Lawful basis: You must have provided your clear consent to us processing your personal data for a specific purpose.

Personal Data Collected via Our Website Portals

Submit a Job Application

Any personal information, including the submission of your resume and/or cover letter, will be used to evaluate your candidacy for employment, as well as contact you regarding your application.

Lawful basis: The processing is necessary for our legitimate interests, or the legitimate interests of a third-party. In some instances, the processing is necessary for a contract that we have with you, or because we need to take steps to enter into a contract with you.

Personal Data Collected via Web-Based Technologies

Browser or Device Information

When you use the website, we automatically receive certain information provided by the interaction of your mobile phone or web browser and the website. This information includes your internet website provider name, web browser type, type of mobile device (if applicable), and computer operating system. We use this information to analyze trends among our Users to help improve the Website. Such information is collected in anonymous, aggregate form and is typically not considered personal data.

We also collect information on computer operating system, your IP address, the web browser, and information about the websites visited before accessing the website.

We collect this data for the following general purposes:

Customizing your user experience
Fulfilling your requests for products and services
Promoting and improving services

Lawful basis: You must have provided your clear consent to us processing your personal data for a specific purpose.

Cookies and Web Beacons

The website uses "cookies" to identify the areas of the website that you have visited.

A cookie is a small piece of data stored on your computer or mobile device by your web browser and is often used to make websites work, as well as provide information to the website operator.

We may use cookies to personalize the content that you see on our website, analyze our web traffic, and improve your experience while visiting the website. Most web browsers can be set to disable the use of cookies.

Communications you receive from us, as well as pages of our website, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that enable us to analyze email and website statistics, including visits and click-through rates. The web beacons only collect aggregate, anonymous data and cannot be traced back to you individually.

Lawful basis: You must have provided your clear consent to us processing your personal data for a specific purpose.

Third-Party Cookies and Web Beacons

Some content or applications on our website are served by third parties, including content providers and application providers. Our third-party partners may use cookies alone or in conjunction with web beacons or other tracking technologies already in your browser to collect information about you when you visit our website. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services.

Third-party cookies and web technologies are controlled by our advertising partners and not subject to this privacy notice. If you have any questions about the practices of such third party, you should contact the responsible third-party directly.

Lawful basis: You must have provided your clear consent to us processing your personal data for a specific purpose.

Conduct Marketing and Advertising

If you request to be updated about our products, services, company news, or other information, we will use the contact information you provided to send you the requested information, to provide you with marketing communications, and to keep you informed about product updates, events, webinars, or other materials.

Lawful basis: You must have provided your clear consent to us processing your personal data for a specific purpose.

Third-Party Advertising

We may use Google Ads, LinkedIn, Facebook/Instagram, and other third-party platforms to advertise across the Internet. We share anonymous, aggregate information regarding visitors to our website with some of the platform's third-party website analytics tools. These companies use this aggregate data, which has been stripped of any personally identifying information about you, to provide us with insight regarding our web usage patterns. As we only share anonymous, aggregate data, this information cannot be traced back to you individually by either us or the website analytics vendors.

Meet Legal and Regulatory Obligations

In certain circumstances, we use your personal data if we are required to by law or legal proceeding. We will only share the information we are required to disclose by law and only when we are required to do so, including to meet national security or law enforcement requirements.

Lawful basis: The processing is necessary for us to comply with the law.

Security and Fraud Prevention

When necessary, we will use your personal data to preserve the security of our website, systems, and personal data in our control. If necessary, we will also use your personal data to investigate possible fraud, to identify violations of this Privacy Policy and our Legal Terms, and to prevent any attempted harm to you and other Members.

Lawful basis: The processing is necessary for our legitimate interests, or the legitimate interests of a third-party.

Personal Data Sharing and Disclosure

We share your personal data when you have granted us permission to do so, when it is necessary to fulfill our obligations to you, or when it is in the legitimate interest of our business to do so, provided that our interests do not outweigh your individual rights and freedoms.

Website Analytics Companies

We may share anonymous, aggregate information regarding visitors to our website with third-party website analytics companies. These companies use this aggregate data, which has been stripped of any personally identifying information about you, to provide us with insight regarding our web usage patterns. As we only share anonymous, aggregate data, this information cannot be traced back to you individually by either us or the website analytics vendors.

Legal Requirements

We may be legally required to disclose your personal data, if such disclosure is:

Required by subpoena, law, or other legal process;
Necessary to assist law enforcement officials or government enforcement agencies; and/or
Necessary to protect us from legal action or claims from third parties including you and/or other Members.

Security and Fraud Prevention Efforts

When necessary, we will share your personal data to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or suspected violations of this Privacy Policy, our agreements or arrangements with you or other policies in effect from time to time to which you are subject, or as otherwise required by law.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.

Third-Party Websites

The website may contain links to other websites that are not under our direct control. This Privacy Policy applies only to our websites and not to any third-party websites, which may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. You access such linked websites at your own risk.

You should check the privacy policies, if any, of those individual websites to see how the operators of those third-party websites will utilize your personal information. In addition, these websites may contain a link to websites of our affiliates. The websites of our affiliates are not subject to this Privacy Policy, and you should check their individual privacy policies to see how the operators of such websites will use your personal information.

Security

We have implemented organizational and technical safeguards for protecting the personal data you share with us. These measures include secure infrastructure, carefully configured access to resources, and best practices around data safety and retention.

How We Protect and Retain Personal Data

Beltway ABA uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service in accordance with the instructions below.

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.

Children Under the Age of 16

We do not knowingly collect personal data from individuals under the age of 16. Our website is not intended for anyone under the age of 16, and no one under the age of 16 may provide information on this website.

Privacy Notice Changes

We reserve the right to modify this privacy notice at any time. You can find the most current version of our privacy notice at any time by clicking on the "Privacy Policy" link at the bottom of our website. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we choose is at our sole discretion. Any changes we make to our privacy notice are effective as of this Last Updated date and replace any prior privacy notices.

If you have questions about this Privacy Notice or how we or our service providers handle your Personal Data, please contact us at info@beltwayaba.com.

We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, depending on where you are located you can contact a supervisory authority or your state's attorney general. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.

Last updated: 10/27/2025

Terms & Conditions

A Terms of Service is a legally binding agreement between a service provider and the user, delineating the rules and conditions for utilizing the service. It typically encompasses aspects such as user rights, responsibilities, and limitations of liability.

SMS Communications

By accessing or using our services, including receiving SMS communications, you agree to comply with and be bound by these Terms and Conditions. If you do not agree with these terms, please do not engage with our SMS services.

Consent for SMS Communication

By providing your consent to receive SMS communications, you acknowledge and agree to receive text messages from Beltway ABA at the phone number you provide. Information obtained as part of the SMS consent process will not be shared with third parties.

Types of SMS Communications

If you have consented to receive text messages, you may receive SMS communications related to the following:

Goods and Services: Information about your child or new client intakes, general inquiries, and other relevant information related to our services.
Job Applicants: Information about your application status, onboarding materials, or other employment-related updates.

Standard Messaging Disclosures

Message and data rates may apply. Standard messaging rates will be charged by your mobile service provider. You can opt-out of receiving SMS messages at any time by texting "STOP" to the number from which you received the message. For assistance, text "HELP" or visit our Privacy Policy.

Privacy

We respect your privacy and will only use the information you provide to communicate with you via SMS as outlined above. Your personal data will not be shared with third parties unless required by law or as necessary to deliver the requested service.

Modifications

We reserve the right to update or modify these Terms and Conditions at any time. Any changes we make to our Terms & Conditions are effective as of this Last Updated date and replace any prior Terms & Condition notices. By continuing to engage with our services, you agree to be bound by any changes to these terms.

If you have questions about these Terms & Conditions or how we or our service providers handle your Personal Data, please contact us at info@beltwayaba.com.

Last Updated: 10/27/2025

Notice of Privacy Practices (HIPAA)

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU AND/OR YOUR CHILD MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

All services provided by Beltway ABA are delivered as part of a medical model and are, therefore, subject to HIPAA (Health Insurance Portability and Accountability Act) regulations. As such, all clients and their families can expect that the organization will keep all protected health information fully confidential and secure and will provide immediate notification of any suspected breach in accordance with applicable laws.

Your Rights Under HIPAA

HIPAA (Health Insurance Portability and Accountability Act) laws and regulations provide all clients and families with the following rights:

The Right to Receive a Notice of Our Privacy Practices

You have the right to receive a copy of this notice of privacy practices that tells you how your health information may be used and shared.
You have the right to request a copy of Beltway ABA's privacy policies and procedures.

The Right to Access Your Child's Clinical Record at Any Time and to Obtain a Copy

Laws require that your child's Protected Health Information (PHI) be kept in his/her clinical record. The clinical record contains information about your child including results of assessments, details of curriculum, individual programs, and treatment and progress records, as well as any treatment records obtained from other providers.
You have the right to request a copy of your child's clinical record. The request must be submitted in writing and allow a reasonable time for Beltway ABA to fulfill the request. Beltway ABA may charge a reasonable cost-based fee for multiple copies/requests.

The Right to Request Corrections to Your Child's Clinical Record

You have the right to inspect your child's clinical records and request amendments and/or corrections as deemed necessary.

The Right to Request Restrictions on Uses and Disclosures of Your Health Information

Your child's information will be confidential and will not be shared with others unless required by law.
You have the right to determine who your information can be shared with, along with how/when it can be shared.
You have the right to share your child's information with other practitioners or educators for coordination of care purposes. If you choose to exercise this right, Beltway ABA will require you to complete a Release of Information form stating exactly what information is to be shared and with whom.
You have the right to choose who can access your records including family members and others involved in your child's care.
The information you choose to disclose may be used for diagnostic, treatment planning, service coordination, and/or continuity of care purposes. Once your information has been disclosed, Beltway ABA will no longer have control over how it is used or stored by the recipient.
You have the right to revoke the authorization of sharing your information with other individuals at any time. Revoking an authorization will not have any effect on any actions, uses, or disclosures already made based upon your original authorization and such disclosures cannot be taken back.
You have the right to authorize or decline the use or disclosure of your health information for specific purposes, such as marketing, advertising, or publicity purposes.

The Right to Request Confidential Communications

You have the right to specify your confidential communication preferences (phone call, text, email, mailing address, etc.).

The Right to an Accounting of Disclosures

You have the right to receive a list of those with whom we've shared information.
You have the right to receive a report regarding when and why your health information was shared.
You have the right to request an accounting of most disclosures of PHI that have not been authorized to determine the locations to which PHI has been sent.

The Right to Restrict Fundraising Solicitations

You have the right to opt out of receiving communications related to Beltway ABA's fundraising events and opportunities.

The Right to File a Complaint

If you feel we have violated your rights, you have the right to file a complaint without fear of retaliation.
You have the right to submit a complaint to our Director of Compliance at info@beltwayaba.com.
You have the right to file a complaint with your insurance provider.
You have the right to file a complaint with the Behavior Analyst Certification Board (BACB) by mailing 7950 Shaffer Parkway; Littleton, Colorado 80127, by faxing (720) 468-4145, or by visiting https://www.bacb.com/contact-us/.

Our Responsibilities

When using or sharing your information for treatment, payment, or healthcare operations, our responsibilities are as follows:

We are required to maintain the privacy and security of your protected health information (PHI).
We are required to notify affected individuals following a breach of unsecured PHI. This notification would be provided to you in writing via email or mail.
We must abide by the terms and follow the privacy practices described in this notice and give you a copy of it.
We will not use or share your information other than as described here unless you tell us we can in writing. However, we can share health information about you for certain situations such as reporting suspected abuse, neglect, or domestic violence, or preventing/reducing a serious threat to anyone's health or safety, to law enforcement or other government agencies including responses to a court, administrative order, or in response to a subpoena.
Beltway ABA staff are legally required to report suspected occurrences of child abuse or neglect, or if you or your child present clear and present danger to yourselves or others.
Beltway ABA is required to obtain a client's written authorization for such uses as marketing or the sale of the patient's PHI. Other uses and disclosures not described in this notice will only be made with the individual's written authorization.
Beltway ABA is required to obtain your informed written consent before releasing any information except where required by legislation or directed by the courts per Beltway ABA's Privacy Policy.
Beltway ABA can change the terms of this notice, and the changes will apply to all information we have about you and your child. The new notice will be available upon request, in our office, and on our website.

Last Updated: 10/27/2025