GRAB BAR INSTALLERS ASSOCIATION OF AMERICA LLC

PRIVACY POLICY


Effective Date: January 8, 2025

Last Updated: January 8, 2025


1. INTRODUCTION


This Privacy Policy describes how Grab Bar Installers Association of 

America LLC ("GBIAA," "we," "us," or "our"), a Florida limited liability 

company, collects, uses, discloses, and protects your personal information 

when you access our website, online courses, certification programs, and 

related services (collectively, the "Services") hosted on the Thinkific 

platform.


By using our Services, you agree to the collection and use of information 

in accordance with this Privacy Policy. If you do not agree with this 

Privacy Policy, please do not use our Services.


2. INFORMATION WE COLLECT


2.1 Information You Provide Directly

When you register for our Services, purchase courses or certifications, or 

interact with our platform, we may collect:

   • Name and contact information (email address, phone number, mailing 

     address)

   • Business information (company name, business address, license 

     numbers, service areas)

   • Payment information (processed by third-party payment processors)

   • Account credentials (username, password)

   • Course completion data and certification records for the GBIAA 

     Certified Grab Bar Installer Training program

   • Test scores and training completion records

   • Communications with us (support inquiries, feedback)

   • Profile information for our public member directory including name, 

     company name, location, contact information, certifications held, 

     years in business, and service areas (if you choose to be listed)

   • Background check information (if implemented in the future and where 

     applicable)


2.2 Information Collected Automatically

When you use our Services, we automatically collect:

   • Device information (operating system, device type, browser type)

   • Usage data (pages viewed, time spent, course progress)

   • IP address and general location information

   • Cookies and similar tracking technologies (see Section 6)


2.3 Information from Third Parties

We may receive information about you from:

   • Third-party authentication services including Google, Facebook, and 

     LinkedIn (if you use social login features)

   • Payment processors (transaction confirmation data)

   • Analytics providers

   • Social media platforms (if you interact with our social sharing 

     features)


3. HOW WE USE YOUR INFORMATION


We use your personal information for the following purposes:


3.1 Service Delivery

   • To provide access to courses, certifications, and membership benefits

   • To process payments and maintain transaction records

   • To track course progress, record test scores, and issue digital 

     certificates for the GBIAA Certified Grab Bar Installer Training 

     program

   • To maintain and improve our Services

   • To provide customer support

   • To verify certifications when inquiries are referred to you


3.2 Communications

   • To send service-related notifications (enrollment confirmations, 

     certification updates)

   • To send marketing communications about new courses, services, or 

     updates (with your consent)

   • To respond to your inquiries and requests

   • To conduct surveys about your experience


3.3 Member Directory

   • To display your profile information in our publicly accessible member 

     directory (if you opt in)

   • To facilitate networking among members and allow public search by 

     potential customers

   • To enable location-based searches for certified installers


3.4 Legal and Security

   • To comply with legal obligations and respond to lawful requests

   • To protect against fraud, unauthorized access, and security threats

   • To enforce our Terms of Service and other policies

   • To conduct background checks if implemented in the future and where 

     required or permitted by law


3.5 Analytics and Improvement

   • To analyze usage patterns and improve our Services

   • To understand member needs and develop new offerings

   • To measure marketing effectiveness through analytics and advertising 

     technologies


3.6 Social Features

   • To enable social login functionality

   • To facilitate content sharing on social media platforms


4. CONSENT AND YOUR CHOICES


4.1 How We Obtain Consent

When you provide personal information to subscribe, make a purchase, or 

use our Services, you consent to our collection and use of that 

information for the specific purpose disclosed.


For secondary purposes such as marketing communications, we will:

   • Ask for your express consent, OR

   • Provide you with an opportunity to opt out


4.2 Email Marketing Preferences

You may opt out of marketing emails at any time by:

   • Clicking the "unsubscribe" link in any marketing email

   • Contacting us at [email protected]

   • Updating your communication preferences in your account settings


Note: You cannot opt out of service-related communications (e.g., payment 

confirmations, certification status updates).


4.3 Member Directory

Inclusion in our public member directory is optional. You may:

   • Choose which information to display in your public profile

   • Control whether your contact information is visible

   • Opt out of the directory entirely

   • Update your directory listing at any time through your account 

     settings


Please note that if you choose to be listed in the directory, your 

selected information will be publicly accessible and searchable by anyone 

visiting our website.


4.4 Social Login

Use of social login features (Google, Facebook, LinkedIn) is optional. By 

using these features, you authorize us to access certain information from 

your social media account as permitted by that platform.


4.5 Withdrawing Consent

To withdraw your consent for data processing, contact us at 

[email protected]. Please note that withdrawing consent may limit your 

access to certain Services.


5. INFORMATION SHARING AND DISCLOSURE


5.1 We Do Not Sell Your Information

We do not sell, rent, or trade your personal information to third parties 

for their marketing purposes.


5.2 Service Providers

We share information with third-party service providers who perform 

services on our behalf, including:

   • Thinkific Labs Inc. (platform hosting)

   • Payment processors (Stripe, PayPal, or others as determined by 

     Thinkific)

   • Email service providers (when implemented)

   • Analytics providers (which may include Google Analytics and similar 

     services)

   • Advertising technology providers (which may include Facebook Pixel, 

     LinkedIn Insight Tag, and similar services)

   • Social media platforms (for login and sharing functionality)


These providers are contractually obligated to protect your information 

and use it only for the purposes we specify.


5.3 Public Member Directory

If you opt into our member directory, your selected information (which may 

include name, business name, location, contact information, certifications 

held, years in business, and service areas) will be publicly visible and 

searchable by anyone, including non-members.


5.4 Partners and Affiliates

We may share limited information with:

   • Association partners, state chapters, or affiliated organizations 

     (with your consent or as necessary for membership benefits)

   • Industry partners for educational or professional development 

     purposes

   • Organizations that may be established in the future to support the 

     grab bar installation industry


5.5 Certification Verification

When third parties (such as insurance companies, contractors, or 

customers) contact us to verify your certification status, we refer them 

directly to you. We do not share your certification information without 

your direct involvement.


5.6 Background Check Providers

If we implement background checks in the future, we may share necessary 

information with background check service providers. You will be notified 

and asked for consent before any such checks are conducted.


5.7 Legal Requirements

We may disclose your information when required by law, including:

   • In response to court orders, subpoenas, or legal processes

   • To comply with government investigations

   • To protect our rights, property, or safety, or that of our members or 

     the public

   • In connection with fraud prevention or security matters


5.8 Business Transfers

If GBIAA is acquired, merged, or sold, your information may be transferred 

to the new owner to ensure continuity of service. We will notify you of 

any such transfer.


6. COOKIES AND TRACKING TECHNOLOGIES


6.1 What Are Cookies?

Cookies are small text files stored on your device that help us recognize 

you, remember your preferences, and improve your experience.


6.2 How We Use Cookies

We use cookies and similar technologies to:

   • Maintain your login session

   • Remember your preferences and settings

   • Analyze website traffic and usage patterns

   • Measure the effectiveness of our content and marketing campaigns

   • Provide personalized content and recommendations

   • Enable social media features and sharing

   • Deliver relevant advertisements (when advertising features are 

     implemented)


6.3 Types of Cookies We Use

   • Essential Cookies: Required for the Services to function (login, 

     course access)

   • Analytics Cookies: Help us understand how you use our Services 

     (including Google Analytics and similar tools)

   • Functional Cookies: Remember your preferences and settings

   • Social Media Cookies: Enable social login and sharing features

   • Marketing Cookies: Used to deliver relevant advertisements and 

     measure campaign effectiveness (including Facebook Pixel, LinkedIn 

     Insight Tag, and similar technologies when implemented)


6.4 Third-Party Cookies

Our Services may use third-party cookies from:

   • Analytics providers (e.g., Google Analytics)

   • Social media platforms (e.g., Facebook, LinkedIn, Google)

   • Advertising networks (when implemented)


These third parties may collect information about your online activities 

over time and across different websites.


6.5 Managing Cookies

You can control cookies through your browser settings:

   • Most browsers allow you to refuse cookies or delete existing cookies

   • Disabling cookies may limit your ability to use certain features

   • To opt out of Google Analytics: 

     https://tools.google.com/dlpage/gaoptout

   • To manage social media cookies, adjust your settings on each platform

   • To learn more about cookies: https://www.allaboutcookies.org


6.6 Do Not Track Signals

We currently do not respond to "Do Not Track" browser signals, as there is 

no consistent industry standard for compliance.


6.7 Web Analytics

We use web analytics tools to collect information about how you use our 

Services. This helps us improve content, user experience, and understand 

which marketing efforts are most effective. Analytics data is typically 

anonymized or aggregated.


7. SOCIAL MEDIA FEATURES


7.1 Social Login

We offer the option to create an account or log in using your existing 

social media accounts (Google, Facebook, LinkedIn). When you use social 

login:

   • You authorize us to access certain information from your social media 

     profile

   • The information we receive depends on your privacy settings on that 

     platform

   • We may access your name, email address, profile picture, and other 

     basic profile information

   • You can revoke this access through your social media account settings


7.2 Social Sharing

Our Services include social sharing buttons that allow you to share 

content on social media platforms. When you use these features:

   • The social media platform may collect information about your visit

   • Your activity may be visible to your social media connections

   • The social media platform's privacy policy governs how they use this 

     information


7.3 Social Media Interactions

If you interact with our social media accounts or mention us on social 

media, we may view and use that information in accordance with the social 

media platform's terms and this Privacy Policy.


8. DATA SECURITY


8.1 Security Measures

We implement reasonable technical, administrative, and physical safeguards 

to protect your personal information, including:

   • SSL/TLS encryption for data transmission

   • Secure data storage with encryption

   • Access controls limiting who can view your information

   • Regular security assessments and updates

   • Compliance with industry best practices


8.2 Limitations

While we follow industry standards and PCI-DSS requirements, no method of 

transmission or electronic storage is 100% secure. We cannot guarantee 

absolute security of your information.


8.3 Data Breach Notification

In the event of a data breach that affects your personal information, we 

will notify you and relevant authorities as required by Florida Statutes 

§501.171 and other applicable regulations. Notification will be provided 

without unreasonable delay.


8.4 Your Responsibility

You are responsible for:

   • Maintaining the confidentiality of your account credentials

   • Notifying us immediately at [email protected] of any unauthorized 

     access

   • Using a strong, unique password

   • Securing your device and internet connection


9. DATA RETENTION


9.1 How Long We Keep Your Information

We retain your personal information for as long as necessary to:

   • Provide you with Services

   • Maintain certification and course completion records

   • Comply with legal obligations (tax records, business records)

   • Resolve disputes and enforce our agreements


9.2 Retention Periods

   • Active accounts: Duration of membership plus applicable legal 

     retention periods

   • GBIAA Certified Grab Bar Installer Training records: Indefinitely, 

     for credential verification and professional record-keeping

   • Test scores and training completion data: Indefinitely, as part of 

     your permanent certification record

   • Digital certificates: Indefinitely, for verification purposes

   • Payment records: Seven years, as required by law

   • Marketing communications: Until you opt out

   • Member directory listings: Until you opt out or close your account

   • Background check records (if implemented): As required by applicable 

     law


9.3 Deletion Requests

You may request deletion of your personal information (see Section 11). 

Note that we may retain certain information as required by law or for 

legitimate business purposes, including:

   • Certification records for professional credential verification

   • Records necessary to comply with legal, tax, or regulatory 

     requirements

   • Information necessary to resolve disputes or enforce agreements


10. PAYMENT PROCESSING


10.1 Third-Party Payment Processors

All payments are processed by third-party payment processors integrated 

with the Thinkific platform, currently including Stripe and PayPal. We do 

not directly collect, store, or process credit card information.


10.2 Payment Security

   • All payment transactions are encrypted using industry-standard SSL 

     (Secure Socket Layer) technology

   • Payment processors comply with PCI-DSS (Payment Card Industry Data 

     Security Standard)

   • Your purchase transaction data is stored only as long as necessary to 

     complete your purchase and fulfill legal obligations

   • Credit card information is stored and encrypted by the payment 

     processor using AES-256 encryption


10.3 Payment Information We Receive

While we do not receive your credit card details, we may receive:

   • Transaction confirmation and payment status

   • Billing name and email address

   • Transaction amount and date

   • Last four digits of credit card (for reference purposes)


10.4 Payment Processor Privacy Policies

We recommend reviewing the privacy policies of our payment processors:

   • Stripe: https://stripe.com/privacy

   • PayPal: https://www.paypal.com/us/webapps/mpp/ua/privacy-full


Please note that Thinkific may change payment processors without our 

direct control. We will update this Privacy Policy accordingly when we 

become aware of such changes.


11. THIRD-PARTY LINKS AND SERVICES


11.1 External Links

Our Services may contain links to third-party websites, resources, or 

services, including:

   • Educational resources

   • Partner organizations

   • Industry publications

   • Manufacturer websites

   • Social media platforms


We are not responsible for the privacy practices of these external sites.


11.2 When You Leave Our Services

Once you leave our website or are redirected to a third-party website or 

application, you are no longer governed by this Privacy Policy or our 

Terms of Service. Each third-party service has its own privacy policy and 

terms.


11.3 Third-Party Service Providers

Certain third-party service providers (payment gateways, analytics 

providers, social media platforms) have their own privacy policies 

regarding the information we provide to them. These providers may be 

located in jurisdictions with different data protection laws than the 

United States.


11.4 Recommendation

We encourage you to read the privacy policies of any third-party sites or 

services you use in connection with our Services.


12. YOUR PRIVACY RIGHTS


Depending on your location, you may have the following rights:


12.1 Access and Portability

   • Request a copy of the personal information we hold about you

   • Request your data in a portable, machine-readable format

   • Request information about how we use your data


12.2 Correction

   • Request correction of inaccurate or incomplete information

   • Update your profile information directly through your account settings

   • Update your member directory information at any time


12.3 Deletion

   • Request deletion of your personal information (subject to legal 

     retention requirements)

   • Note: Deletion may affect your access to Services, certification 

     records, and member directory listing

   • We may retain certification records for professional verification 

     purposes even after account deletion


12.4 Restriction and Objection

   • Request restriction of processing in certain circumstances

   • Object to processing based on legitimate interests

   • Opt out of marketing communications at any time


12.5 California Residents (CCPA Rights)

If you are a California resident, you have additional rights under the 

California Consumer Privacy Act (CCPA):

   • Right to know what personal information is collected, used, shared, 

     or sold

   • Right to know the categories of sources from which we collect personal 

     information

   • Right to know the business or commercial purpose for collecting or 

     selling personal information

   • Right to know the categories of third parties with whom we share 

     personal information

   • Right to delete personal information (subject to certain exceptions)

   • Right to opt out of the sale of personal information (we do not sell 

     your information)

   • Right to non-discrimination for exercising your CCPA rights


We will not discriminate against you for exercising any of your CCPA 

rights, including by:

   • Denying goods or services

   • Charging different prices or rates

   • Providing different quality of goods or services

   • Suggesting you will receive different prices or quality of services


12.6 European Residents (GDPR Rights)

Although we currently operate exclusively within the United States, if you 

are located in the European Economic Area (EEA), you may have additional 

rights under the General Data Protection Regulation (GDPR):

   • Right to access your personal data

   • Right to rectification of inaccurate data

   • Right to erasure ("right to be forgotten")

   • Right to restriction of processing

   • Right to data portability

   • Right to object to processing

   • Right to withdraw consent

   • Right to lodge a complaint with a supervisory authority


12.7 How to Exercise Your Rights

To exercise any of these rights, contact us at:

   

   Email: [email protected]

   Subject Line: "Privacy Rights Request"

   

   Mailing Address:

   Grab Bar Installers Association of America LLC

   Attn: Privacy Request

   7901 4th St N, Ste 300

   St. Petersburg, FL 33702


Please include in your request:

   • Your full name and email address associated with your account

   • Specific right(s) you wish to exercise

   • Any additional information to help us verify your identity


12.8 Verification Process

To protect your privacy, we will verify your identity before processing 

requests to access or delete personal information. We may ask for 

additional information to confirm your identity.


12.9 Response Time

We will respond to verified requests within:

   • 30 days for general requests

   • 45 days for CCPA requests (with possible 45-day extension for complex 

     requests)

   • 30 days for GDPR requests (with possible 60-day extension for complex 

     requests)


12.10 Authorized Agents

California residents may designate an authorized agent to make CCPA 

requests on their behalf. We may require proof of authorization and 

verification of your identity.


13. CHILDREN'S PRIVACY


13.1 Age Requirement

Our Services are intended for adults and businesses in the professional 

grab bar installation industry. We do not knowingly collect personal 

information from individuals under 18 years of age.


13.2 Parental Consent

If you are under 18, you may use our Services only with the involvement 

and consent of a parent or legal guardian who must agree to this Privacy 

Policy on your behalf.


13.3 Professional Services

Our Services are designed for professional training and certification. We 

expect our users to be adults engaged in or preparing for professional 

work in the grab bar installation field.


13.4 If We Learn of Collection

If we become aware that we have collected personal information from a 

person under 18 without appropriate parental consent, we will take steps 

to delete that information promptly. If you believe we have collected 

information from someone under 18, please contact us at [email protected].


14. INTERNATIONAL DATA TRANSFERS


14.1 Current Operations

We currently operate exclusively within the United States. Your 

information is collected, processed, and stored on servers located in the 

United States.


14.2 U.S. Data Protection Laws

The United States may not provide the same level of data protection as 

some other countries. By using our Services, you consent to the transfer 

and processing of your information in the United States under U.S. law.


14.3 Future International Operations

If we expand to serve international members in the future, your 

information may be transferred to and processed in countries outside your 

country of residence, which may have different data protection laws. We 

will update this Privacy Policy and implement appropriate safeguards if 

this occurs.


14.4 Third-Party Service Providers

Our third-party service providers may process your information in various 

jurisdictions:

   • Thinkific Labs Inc. is based in Canada

   • Payment processors may process transactions in multiple jurisdictions

   • Analytics and advertising providers may operate globally

   • Social media platforms operate internationally


By using our Services, you consent to such international transfers and 

processing.


14.5 Legal Basis for Processing (GDPR)

If GDPR applies to you, our legal bases for processing your information 

include:

   • Performance of a contract (providing Services you requested)

   • Legitimate interests (improving Services, security, fraud prevention)

   • Consent (marketing communications, optional features)

   • Legal obligations (compliance with applicable laws)


15. BACKGROUND CHECKS (FUTURE IMPLEMENTATION)


15.1 Notice of Future Implementation

We may implement background check procedures in the future for 

certification or membership purposes. If we do so, this section will 

govern our practices.


15.2 Consent and Disclosure

If background checks are implemented:

   • We will obtain your express written consent before conducting any 

     background check

   • You will be informed of the nature and scope of the background check

   • You will receive a copy of your rights under the Fair Credit 

     Reporting Act (FCRA) if applicable

   • You will have the opportunity to review and dispute any findings


15.3 Information Collected

Background checks, if implemented, may include verification of:

   • Criminal history

   • Professional licenses and credentials

   • Employment history

   • Educational credentials

   • Professional references


15.4 Use of Background Check Information

Background check information will be used solely for:

   • Verification of eligibility for certification or membership

   • Compliance with legal or regulatory requirements

   • Protection of public safety where applicable


15.5 Third-Party Background Check Providers

If we use third-party background check services, we will:

   • Ensure they comply with FCRA and applicable state laws

   • Require them to protect your information

   • Limit information sharing to what is necessary


15.6 Retention of Background Check Information

Background check records will be retained as required by law and our 

legitimate business interests, typically for the duration of your 

certification plus applicable legal retention periods.


15.7 Your Rights

If background checks are implemented, you will have rights including:

   • Right to consent or decline

   • Right to receive a copy of the report

   • Right to dispute inaccurate information

   • Right to know how the information will be used


15.8 Updates to This Section

We will update this Privacy Policy and notify members before implementing 

any background check procedures.


16. CHANGES TO THIS PRIVACY POLICY


16.1 Right to Modify

We reserve the right to update or modify this Privacy Policy at any time 

to reflect:

   • Changes in our practices or Services

   • New technologies or features

   • Legal or regulatory requirements

   • Industry best practices

   • User feedback and needs


16.2 Notification of Changes

When we make changes:

   • The "Last Updated" date at the top of this policy will be revised

   • Changes take effect immediately upon posting to our website

   • For material changes that significantly affect your rights or how we 

     use your information, we will provide prominent notice via:

     - Email to your registered email address

     - Prominent banner notification on our website

     - Notice upon your next login to the Services

   • Continued use of our Services after changes are posted constitutes 

     your acceptance of the updated Privacy Policy


16.3 Material Changes

Examples of material changes include:

   • Significant changes in how we use your personal information

   • New categories of information collected

   • Changes in information sharing practices

   • Implementation of new technologies that affect privacy

   • Changes to your rights or how to exercise them

   • Implementation of background check procedures


16.4 Review Regularly

We encourage you to review this Privacy Policy periodically to stay 

informed about how we protect your information and what rights you have.


16.5 Version History

You may request previous versions of this Privacy Policy by contacting us 

at [email protected].


17. CONTACT INFORMATION


If you have questions, concerns, or requests regarding this Privacy Policy 

or our privacy practices, please contact us:


Grab Bar Installers Association of America LLC


Email: [email protected]

Subject Line: "Privacy Inquiry"


Mailing Address:

7901 4th St N, Ste 300

St. Petersburg, FL 33702


We will respond to your inquiry within a reasonable timeframe, typically 

within 5-10 business days for general inquiries and within the timeframes 

specified in Section 12 for privacy rights requests.


For urgent privacy or security concerns, please indicate "URGENT" in your 

subject line.


18. GOVERNING LAW AND DISPUTE RESOLUTION


18.1 Governing Law

This Privacy Policy and any disputes related to privacy matters are 

governed by the laws of the State of Florida and applicable federal laws 

of the United States, without regard to conflict of law principles.


18.2 Jurisdiction

By using our Services, you consent to the exclusive jurisdiction of the 

state and federal courts located in Pinellas County, Florida for any 

disputes arising from or related to this Privacy Policy.


18.3 Severability

If any provision of this Privacy Policy is found to be invalid or 

unenforceable, the remaining provisions will continue in full force and 

effect.


18.4 No Waiver

Our failure to enforce any provision of this Privacy Policy does not 

constitute a waiver of that provision or any other provision.


19. ENTIRE AGREEMENT


This Privacy Policy, together with our Terms of Service and any other 

legal notices or agreements published on our Services, constitutes the 

entire agreement between you and GBIAA regarding the collection, use, and 

disclosure of your personal information.


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ACKNOWLEDGMENT


By using our Services, you acknowledge that you have read, understood, and 

agree to be bound by this Privacy Policy. If you do not agree, please do 

not use our Services.


Last Updated: January 8, 2025

Version: 1.0


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For questions about this Privacy Policy, contact: [email protected]