ADA Program Solutions, PC | Privacy Policy

Amended as of April 05, 2024

Welcome to ADA Program Solutions, PC [“ADA Program Solutions” or “Company”]. ADA Program Solutions is a boutique consulting firm that assists employers in following employment regulations and offers a range of support services to help businesses of any size effectively create a positive work environment. 

This Privacy Policy [“Policy”] applies to the use of ADA Program Solutions [“Company”] website https://adaprogramsolutions.com, store and other resources [independently, this “Site”, or collectively, the “Sites”] and outlines how we may collect, receive, process, and share your personal data. This Policy applies to personal data you provide us and any personal data we may collect from other sources, except to the extent you receive a different, more specific privacy notice at the time of data collection, and includes personal data collected or received in various business to business contexts, directly from you for example, as part of the job applicant process, and via visits to our website.  For the purpose of this Privacy Policy, unless otherwise noted, all references to the Company include https://adaprogramsolutions.com. This Policy does not apply to any third-party websites, applications, or portals linked on our Sites. Please review our website Terms and Conditions in conjunction with this Privacy Policy.

Changes to Privacy Statement 

ADA Program Solutions reserves the right, in its sole discretion, to change the Policy from time to time. For example, when there are changes to our services, changes in our data protection practices, or changes in the law. If we amend the Policy, we will provide notice by updating the “Amended” date. By continuing to use our Sites and/or services available on or after such modifications will constitute your: [a] acknowledgement of the modified Policy and [b] agreement to abide and be bound by that Policy. The most current version of the Policy will supersede all previous versions. ADA Program Solutions encourages you to periodically review the Policy to stay informed of our updates.

Contact Information

ADA Program Solutions welcomes your questions or comments regarding this Policy. If you believe that the Company has not adhered to this Policy, please contact the Company at: 

ADA Program Solutions, PC
P.O. Box 756

Celina, TX 75009

Email Address: info@adaprogramsolutions.com

Company Main Office: 877.992.3277

Privacy of Children

ADA Program Solutions does not knowingly collect, either online or offline, personal information from persons under the age of 13. If you are under the age of 13, you may use these Sites only with permission of a parent or guardian.

Use of Cookies

We employ the use of cookies. By using ADA Program Solutions’ Sites, you consent to the use of cookies in accordance with ADA Program Solutions’ privacy policy. Most of the modern-day interactive websites use cookies to enable us to retrieve user details for each visit. 

Cookies are used in some areas of our sites to enable the functionality of these areas and ease of use for those people visiting. Some of our affiliate/advertising partners may also use cookies. 

Eternal Links

Our Site may link to websites created and maintained by other public or private organizations [“Linked Sites”]. Linked Sites are not under the control of ADA Program Solutions and ADA Program Solutions is not responsible for the content of any Linked Site, including, without limitation, any link contained in a Linked Site, or any changes or updates to a Linked Site. ADA Program Solutions is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by ADA Program Solutions of these Sites or any association with its operators.

If you click on a link to an outside website, you will leave our website, and you are subject to the privacy and security policies of the owners/sponsors of the outside website that you go to.

Certain services made available via these Sites are delivered by third party sites and organizations. By using any product, service or functionality originating from the https://adaprogramsolutions.com domains, you hereby acknowledge and expressly agree that ADA Program Solutions may share such information and data with any third party with whom ADA Program Solutions has a contractual relationship to provide the requested product, service or functionality on behalf of these Sites’ users and customers. 

Privacy Rights 

Some privacy laws, such as those in California, Colorado, Connecticut, Utah, and Virginia, require that we disclose to you your rights that you have about the collection, use, and sharing of your personal data. These rights may be subject to certain limitations or exceptions depending on your state of residency or country from which you are engaging with us, and the purpose for which we process personal data about you. 

We’ve included this information in the Privacy Rights Chart at the end of this Policy under the section “Additional Information”.

Collection of your Personal Information

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services. These may include: [a] registering for an account; [b] entering a sweepstakes or contest sponsored by us or one of our partners; [c] signing up for special offers from selected third parties; [d] sending us an email message; [e] submitting your credit card or other payment information when ordering and purchasing products and service. To the extent we will use your information for, but is not limited to, communicating with you in relations to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.

Use of Your Personal Information

The Company collects and uses your personal information in the following ways: 

- To operate and deliver the services you have requested;

- To provide you with information, products, or services that you request from us;

- To provide you with notices about your account;

- To carry out the Company’s obligations and enforce our rights arising from any contracts entered between you and us, including for billing [as applicable];

- To notify you about changes to our Sites or any products or services we offer or provide through it;

- In any other way we may describe when you provide the information; and

- For any other purpose with your consent.

The Company may also use your personally identifiable information to inform you of other products or services available from the Company and its affiliates, as applicable.

Sharing Information with Third Parties 

The Company does not sell, rent, or lease its customers list to third parties.

The Company may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information [email, name, company name, address, phone number] is transferred to the third party. The Company may share data with trusted partners based on your interactions with us, pursuant to the provision of our services, for the legitimate business operation purpose including marketing, data analytics, survey benchmarking, to help perform statistical analysis, send you email or postal mail, provide customer support, arrange for deliveries, or to comply with a legal obligation. All such third parties are prohibited from using your personal information except to provide these services to the Company, and they are required to maintain the confidentiality of your information. 

The Company may disclose aggregated information about our customers without restriction. This data cannot be attributed to any specific individual. We may disclose aggregated customer data to our affiliates and to other third parties for lawful purposes.

The Company may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: [a] conform to the edicts of the law or comply with legal process served on the Company or the site; [b] protect and defend the rights or property of the Company; and/or [c] act under exigent circumstances to protect the personal safety of users of the Company, or the public. 

If some or all of our assets are sold or transferred or used as security, or to the extent we engage in business negotiations with our business partners, the information collected on the website may be transferred or shared with third parties as part of that transaction or negotiation.

Opt-Out of Disclosure of Personal Information to Third Parties

In connection with personal information, we may disclose to a third-party for a business purpose, you have the right to know the categories of personal information that we disclosed about you for a business purpose. These categories are listed below under the “Legal Categories of Personal Information” section.

Information for California Residents and Residents of other States with Applicable Privacy Laws

In certain circumstances, we may choose to or may be required to provide additional or different disclosures to residents of different states or countries. Below are the disclosures that may be applicable to you, if you reside in California or another state with applicable state privacy laws including the States of Colorado, Connecticut, Virginia, and Utah. This section specifically describes your rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act, and applicable regulations (collectively the “CPRA”) and how to exercise those rights, as applicable. It is also designed to describe your rights under Colorado, Connecticut, Virginia, and Utah laws, as applicable.

California's "Shine the Light" Law

California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our website that our California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which the Company shared information in the immediately preceding calendar year. To make such a request, please send an email here.

"Do Not Track" Signals

“Do Not Track” is a privacy setting that you may set in your web browsers. If turned on, this setting requests that websites not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals.

Legal Categories of Personal Information

Certain state- or country- specific laws require us to tell you about the personal data we collect about you in a certain way – specifically in California, we need to tie it back to “legal categories” of personal information that are listed in the law. To do this, we bundled the information we provided in this Policy and matched the different types of personal data we collect about you with the legal category. To make things easier to understand, we’ve made a chart that shows you six [6] things:

1. The legal category of personal information.

2. Examples of the types of personal information included in each legal category.

3. The source from which your personal information is collected.

4. The purpose for why we collect and use your personal information for each legal category.

5. The business purposes for which we share your personal information and with whom.

6. Whether we sell your personal information.

We’ve included this information in the Personal Information Privacy Chart at the end of this Policy under the section “Additional Information”. 

Privacy Rights for California Residents and Residents of other States with Applicable State Privacy Laws (as applicable)

This section describes your above privacy rights in greater detail. In certain situations where we have established a direct relationship with you, versus receiving your information from our clients or other third parties in order to perform services for them, you may have the right to:

- Access: You can request a copy of your personal information.

- Know: You have the right to request that the Company disclose certain information to you about our collection and use of your personal information, including what information we collect, the sources, the purpose for collecting and/or selling your information, third parties with whom your information is shared or sold, and the specific pieces of personal information we have about you.

- Change or Correct: You have a right to correct personal information that we hold about you that is inaccurate or incomplete. You can review and edit your personal information by logging onto our websites and visiting your account. You may also send us an email to correct any personal information that you have provided to us.

- Delete: Under certain circumstances, you can request that we erase or delete all or some of your personal information (e.g., it is no longer necessary to provide services to you).

- Object to or Restrict Use: Under certain circumstances, you can request that we stop using and processing your personal information or restrict our use and processing of your personal information.

- Data Portability: You have the right to have your personal information transferred to another organization.

- Opt-Out of Sale or Sharing: You may have the right to ask us not to sell your personal information or share it for purposes of targeted advertising or profiling that produces significant effects about you.

- Automated Individual Decision-Making: You have the right not to be subject to a decision based on automated profiling.

- Marketing: You may opt-out of direct marketing or profiling we carry out for direct marketing by sending us an email.

- Limit Sensitive Information: Sensitive Personal Information includes your Social Security number, driver’s license number, state ID card, passport number, precise geolocation, racial or ethnic origin, union membership, and health and genetic data. You may have the right to ask us to limit our use of your Sensitive Personal Information to only what is required to accomplish the purposes we included in this privacy notice or that you reasonably expect from us. Our practice is to not process your Sensitive Personal Information except when it is necessary to accomplish the purposes disclosed in this Policy.

- Withdraw Consent: If we have collected or processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information based on other lawful processing grounds.

- Non-Retaliation for Exercising Privacy Rights: You also may have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by applicable law.

These rights may be subject to certain limitations or exceptions depending on your state of residency or country from which you are engaging with us, and the purpose for which we process personal information about you. 

Exemptions Under California Privacy Rights Act (CPRA) and Other State Privacy Laws, as Applicable

State privacy laws generally do not apply to the following types of data, which are exempt from applicable state privacy laws in California, Colorado, Connecticut, Utah, and Virginia. This includes but is not limited to: protected health information collected by a covered entity or business associate and governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); medical information governed by the California Confidentiality of Medical Information Act (CMIA); personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA). 

Use of Sensitive Personal Information

We do not use, receive, collect, or disclose sensitive personal information for purposes other than those authorized under the CPRA and other state privacy laws. At times, ADA Program Solutions may need to receive, collect, or disclose your sensitive personal information as necessary for provision of insurance services, our operations in furtherance of a substantial public interest, and/or where you have given us your explicit consent, or where your organization, employer or another third party is responsible for obtaining your explicit consent to enable us to collect and use your data for the purposes described in this Policy, or to establish, exercise or defend legal claims; only. If ADA Program Solutions wishes to use your personal information beyond what is needed for or expected by you in the context of your relationship with the Company, ADA Program Solutions will request your affirmative consent before using your sensitive personal information for these new purposes. Read the Personal Information Privacy Chart.

Opt-Out and Unsubscribe from Third-Party Communications

We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information, Users may opt out of receiving any or all communications from third-party partners of the Company by contacting us via email, as provided under the “Contact Information” section of this Policy. 

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

- Delete your personal information from our records; and

- Direct any service providers to delete your personal information from their records.

Please note that ADA Program Solutions, PC may not be able to comply with requests to delete your personal information if it is necessary to: 

- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall;

- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 

- Debug to identify and repair errors that impair existing intended functionality;

- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech; or exercise another right provided for by complying with the California Electronic Communications Privacy Act;

- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics;

- Enable solely internal uses that are reasonably aligned wit your expectations based on your relationship with us;

- Comply with an existing legal obligation; or

- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. 

How to Make a Request

To exercise any of the privacy rights described above, please submit a request via email, as provided under the “Contact Information” section of this Policy.

In your request, please include your full legal name, email address, home address, zip code, and the type of request you would like to make. To the extent you have established an account with our system, you can review and change your personal information by logging into the website and visiting your account. You may also send us an email to correct or delete any personal information that you have provided to us. If you request that your account information be deleted or if you unsubscribe from communications, we may maintain information about your transactions or inquiries for future service and recordkeeping purposes. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide you with information, products, or services. 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.

Verify Your Identity

For your protection, we may need to verify your identity before fulfilling your request. To do this, we may ask for at least two data points that match the data points we maintain about you to compare the information and verify your identity. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request, and will request your contact information [name, address, email address, employer name and address, phone number], and as necessary, may request your account information, date of birth, partial social security number, geolocation, and/or professional details including professional licensure and professional credentials. 

Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions that occurred prior your request. We will also retain your personal information if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or enforce the Terms of Use.

Only you, or a representative that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. The verifiable consumer request must:

- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

- 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

Requests by Authorized Agents

You may have the right to designate an authorized agent to make a request on your behalf. You may authorize an agent to make a request by providing the agent with written permission to act on your behalf. We will ask the agent to provide proof of that written permission by providing their professional licensure information and letter of representation. If permitted by law, we will also require that you and/or your agent verify your own identity in response to a request, even if you chose to submit a request using an agent.

Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and whether we have a legal obligation that prohibits us from fulfilling your request. If we can’t honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Social Media Sites

ADA Program Solutions manages a presence on social media sites such as Meta, X, Instagram, LinkedIn, and others to share general information and to engage with the public. 

We’ve included this information in the Terms of Use at the end of this Policy under the section “Additional Information”. Reference the Legal Disclaimer section within the “Terms of Use”. 

Electronic Communications 

Visiting our Sites or sending emails to ADA Program Solutions constitutes electronic communications. You consent to receive electronic communications and you agree that all agreements, notices, disclosures, and other communications that ADA Program Solutions provides to you electronically, via email and on these Sites, satisfy any legal requirement that such communications be in writing. If you do not wish to continue receiving electronic communications, you can opt out by following the unsubscribed instructions provided in such communications. 

Applicable Law 

We recognize that the website may be accessed from anywhere in the world, and that the laws of the jurisdictions in which some users are located may differ substantially from those of the United States, the State of California and the State of Texas. Because we cannot prevent users in different jurisdictions from accessing the website, you are responsible for knowing and complying with the laws of your jurisdiction. If such laws conflict with your use of the website or any of its content or functionality, the website is not intended for you, and we ask you not to use them or submit any information through them.

International Users

Our Sites or services are controlled, operated, and administered by ADA Program Solutions from our offices within the USA. If you access our Sites or services from a location outside the USA, you are responsible for compliance with all local laws. You agree that you will not use ADA Program Solutions content accessed through https://adaprogramsolutions.com in any country or in any manner prohibited by any applicable laws, restrictions or regulations.

Interpretation of this Privacy Policy

Any interpretation associated with this Policy will be made by ADA Program Solutions, PC’s legal counsel. This Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it means “including without limitation.”

This Policy does not create or confer upon any individual any rights, or impose upon ADA Program Solution, PC any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable country, state, and other privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Policy and applicable privacy laws, this Policy shall be interpreted in that case to give effect to, and comply with, such privacy laws.

- Personal Information Privacy Chart

- Privacy Rights Chart

- EU Privacy Notice

- Gramm-Leach Bliley (GLBA) Policy