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Privacy Statement/Privacy Policy

ACES 2020, LLC, f.k.a. Comprehensive Educational Services, Inc. (“Company” or “we“), respects your privacy. This policy describes how we may collect, use, share and otherwise process personal information we collect through our website www.acesaba.com (our “Website“), as well as information that we may collect via other means (including offline), as described below. It does not apply to information we collect from our employees, contractors, or applicants for employment.

How We Collect and Use Personal Information

We collect and use personal information in a number of ways, depending on how you interact with us. We collect information in the following ways:

Information You Provide to Us on Our Website

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of contacting us through our Website, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website.
  • Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect on Our Website Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Internet or electronic network activity, such as details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including online identifiers such as your IP address, as well as your operating system, and browser type.

This information helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. 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 permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Information We Collect Offline

We collect additional Personal Information when you interact with us other than on our Website. This includes during the client onboarding process as well as billing verification. We principally collect this information from you when you provide it to us; however, we may collect additional information from third parties, such as your physician, school, or the regional center with whom we interact in order to provide our services to you. The information we collect offline may include:

  • Identifiers, such as your name, date of birth, address, email address, service location address, telephone number and similar information about your parent or guardian.
  • Referral information.
  • Location data.
  • Medical information, diagnosis as well as insurance information.
  • Education information.
  • Personal information categories listed in the California Customer Records statute, such as your social security number or other government identifier.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on, available here.

To learn more about certain third-party Cookies used for interest-based advertising, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance or Network Advertising Initiative.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information or services that you request from us.
  • To conduct client intake.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our clients, or others.

Third party links

Our Website may contain links to third party websites, products and services. These third party websites and services have separate and independent privacy policies, which we encourage you to read. We have no responsibility or liability for the content and activities of such linked sites. However, we want to protect the integrity of our Website and thus welcome any feedback you may have about third-party sites we link to.

California Privacy Rights

Under the California Consumer Privacy Act (“CCPA”), California residents may have certain privacy rights, including the rights to: (i) request additional disclosures about the Personal Information and obtain a copy of that information, i.e., a “Request to Know,” sometimes called the Right to Access; (ii) request deletion of Personal Information, i.e., a “Request to Delete Information,” sometimes called the Right to Be Forgotten or the Right to Erasure; and (iii) opt out of the sale of Personal Information if we were to sell Personal Information, i.e., a “Request to Opt Out.”

How to Exercise Privacy Rights

If you wish to exercise any of these rights please email info@acesaba.com, call us via our toll-free number: 1(855) 223-7123, or click here. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your personal data only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.

We do not discriminate against you, for example, by charging you a different price or offering a different level of service, for exercising any of these rights.

If you make a request related to personal data about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

California Shine the Light

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@acesaba.com or write us at: P.O. Box 33568, San Diego, CA 92163.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Please keep in mind that “perfect security” does not exist on the internet or elsewhere and no transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security.

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 personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information 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 1 (855) 223-7123.

Changes to Our Privacy Policy

We may update this Privacy Notice periodically, without prior notice, so please review it frequently. If we decide to change our Privacy Notice, we will post those changes on the Website so that you are aware of what kinds of personal information we collect, use, share and otherwise process. If we make material changes to this Privacy Notice, we will notify you on this Website and update the effective date above.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: info@acesaba.com or via our toll-free number: 1 (855) 223-7123.