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Privacy Policy

This Privacy Policy describes Our policies and procedures and how The Unicorn Program LLC (“Company,” “We,” “Us,” or “Our”) collects, uses, stores, and discloses personal information when you access or use Our website, courses, digital products, and services (collectively, the “Service”). By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Last updated: February 22nd, 2026

Interpretation and Definitions

Interpretation The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural. Definitions For the purposes of this Privacy Policy: Account refers to the unique account created for You to access our Service or parts of our Service. Company (referred to as either "the Company", "We", "Us" or "Our" in this Policy) refers to The Unicorn Program LLC, located in Wheeling, IL. Service refers to the Website, courses, video trainings, digital downloads, assessments, templates, PDU offerings, materials, and all related content provided by the Company. You refers to 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. Website refers to The Unicorn Program, accessible from https://theunicornprogram.thinkific.com or any affiliated domains. Terms and Conditions (also referred to as “Terms”) refers to this agreement governing access to and use of the Service. Professional Development Units (also referred to as “PDU” or “PDUs”) refers to the continuing education training hours recognized by credentialing bodies such as the Behavior Analyst Certification Board® (BACB®) for the maintenance of Registered Behavior Technician® (RBT®) credentials. Enrollment refers to the act of registering for, purchasing, or otherwise gaining authorized access to a course or educational offering provided by the Company.

Collecting and Using Your Personal Data

Information We Collect While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to: • Email address • First name and last name • BACB Certification Number • Information required for Professional Development Unit (PDU) documentation • Billing information (processed by third-party payment processors) • Any information you voluntarily provide in communications. We collect personal information directly from you when you: • Create an account • Purchase a course or product • Submit Professional Development Unit (PDU) documentation • Contact us via email • Participate in discussions (if enabled) We do not collect Social Security numbers, biometric data, health information, or sensitive personal data. We do not use advertising tracking tools, remarketing services, or behavioral ad networks. Basic technical information may be automatically collected by the platform provider (e.g., Thinkific), such as: • IP address • Browser type • Device type • Log data necessary for account functionality and security We do not use independent analytics or advertising technologies at this time. How We Use Your Information The Company may use Personal Data for the following business purposes: • To provide You access to our Service and purchased courses • To provide and maintain our Service, including to monitor the usage of our Service. • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation. • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information. • To manage Your requests: To attend and manage Your requests to Us. • To issue Professional Development Unit (PDU) documentation. • To process payments. • To respond to inquiries. • To send necessary service-related communication. • To comply with legal and regulatory obligations. • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience. Data Retention and Transfer The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, provide the Service, and maintain required PDU records. You are responsible for maintaining Your own copies of PDU documentation. Sharing of Information Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to, and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information. We may share personal information only with: • Service providers (e.g., payment processors, hosting providers) • Legal authorities when required by law • Successors in the event of a business transfer We do not sell personal information to third parties. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: • Comply with a legal obligation • Protect and defend the rights or property of the Company • Prevent or investigate possible wrongdoing in connection with the Service • Protect the personal safety of Users of the Service or the public • Protect against legal liability Data Security We implement reasonable administrative, technical, and organizational safeguards to protect your personal information. However, no method of electronic storage or internet transmission is 100% secure, and we cannot guarantee absolute security.

Cookies and Essential Technologies

Our Service uses essential cookies and similar technologies necessary for website functionality, security, account access, and course delivery. These technologies allow us to: • Maintain secure user sessions • Enable account login • Process purchases • Remember basic user preferences We do not use cookies for advertising, behavioral tracking, or remarketing purposes at this time. You may configure your browser to refuse cookies; however, doing so may limit certain features of the Service.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies. Email Communications We may use Your Personal Data to email you: • Course access • PDU documentation • Account notifications • Customer support responses We do not send routine promotional or marketing emails at this time. If marketing communications are introduced in the future, you will be given the ability to opt out. Payment Processing Payments are processed through secure third-party payment processors. We do not store or have access to your full credit card information. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

California Privacy Rights (CCPA/CPRA)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California. Categories of Personal Information Collected 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 Consumer or device. The following is a list of categories of personal information which we may collect from California residents. Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information 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 information would only be collected if You provided such personal information directly to Us. ● 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. ● Category B: Personal information 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 information included in this category may overlap with other categories. Collected: Yes. ● 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. ● Category D: Commercial information. Examples: Records and history of products or services purchased or considered. Collected: Yes. ● 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. ● Category F: Internet or other similar network activity. Examples: Interaction with our Service or advertisement. Collected: Yes. ● Category G: Geolocation data. Examples: Approximate physical location. Collected: No. ● Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No. ● Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: No. ● 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: No. ● Category K: Inferences drawn from other personal information. Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No. Under CCPA, personal information does not include: ● Publicly available information from government records ● Deidentified or aggregated consumer information ● 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 ● Personal Information 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 Information We obtain the categories of personal information listed above from the following categories of sources: ● Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service. ● Indirectly from You. For example, from observing Your activity on our Service. ● Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service. ● From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third- party vendors that We use to provide the Service to You. Use of Personal Information for Business Purposes or Commercial Purposes We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples: ● To operate our Service and provide You with our Service. ● To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service. ● 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 information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery. ● To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. ● As described to You when collecting Your personal information or as otherwise set forth in the CCPA. ● For internal administrative and auditing purposes. ● To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities. 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 "Collecting and Using Your Personal Data" section. If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy. Disclosure of Personal Information for Business Purposes or Commercial Purposes We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes: ● Category A: Identifiers ● Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ● Category D: Commercial information ● Category F: Internet or other similar network activity 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 information 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 information 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 information confidential and not use it for any purpose except performing the contract. Sale of Personal Information Because we do not sell or share personal information for advertising purposes, there is currently no sale of personal information under CCPA/CPRA. To exercise your rights, contact via email: [email protected] We will verify your identity before responding Share of Personal Information We may share Your personal information identified in the above categories with the following categories of third parties: ● Service Providers ● Payment processors ● Our affiliates ● Our business partners ● Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You Your Rights under the CCPA The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights: ● The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used. ● The right to request. Under 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 information. Once We receive and confirm Your request, We will disclose to You: ○ The categories of personal information We collected about You ○ The categories of sources for the personal information We collected about You ○ Our business or commercial purpose for collecting or selling that personal information ○ The categories of third parties with whom We share that personal information ○ The specific pieces of personal information We collected about You ○ If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You: ■ The categories of personal information categories sold ■ The categories of personal information categories disclosed ● 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 information. To submit an opt-out request please contact Us. ● 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 information 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: ○ Complete the transaction for which We collected the personal information, 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. ○ Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. ○ Debug products to identify and repair errors that impair existing intended functionality. ○ Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. ○ Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). ○ 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. ○ Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us. ○ Comply with a legal obligation. ○ Make other internal and lawful uses of that information that are compatible with the context in which You provided it. ● The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by: ○ Denying goods or services to You ○ Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties ○ Providing a different level or quality of goods or services to You ○ 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: ● By sending us an email: [email protected] 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 information. Your request to Us 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 the required information if we cannot: ● Verify Your identity or authority to make the request ● And confirm that the personal information relates to You ● 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 information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to “Do Not Track” signals. Because we do not use advertising tracking tools or cross-site tracking technologies, your browsing behavior is not used for targeted advertising by us. 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 DNT 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.

Children's Privacy

The Service is intended for individuals aged 18 and older. We do not knowingly collect personal information from anyone under the age of 18 through our Service, 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. If we become aware that personal information from a child has been collected, we will take appropriate steps to delete such information. If You have reason to believe that a child under the age of 13 (or 18) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last Updated” date. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Continued use of the Service after changes are posted constitutes acceptance of the revised policy.

Contact Us

If you have any questions about this Privacy Policy, You can contact: The Unicorn Program, LLC By email: [email protected]

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