Online Information Practices - Privacy Policy

 

Our Online Information Practices - Privacy Policy was last updated on July 31, 2022.

 

This Privacy Policy outlines Journey through life Counseling, LLC (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at www.JourneythroughlifeCounseling.com(" Site "), or otherwise share personal information with us (collectively: " Users ").

 

Journey through life Counseling, LLC is committed to protecting your privacy. To better protect your privacy, we provide this notice explaining our online information practices. To make this notice easy to find, we make it available on our website.

 

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

 

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy was generated by  TermsFeed Privacy Policy Generator.

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" means a 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 Agreement) refers to Journey through life counseling, LLC.
   
    For the purpose of the GDPR, the Company is the Data Controller.

 

• "Country" refers to United States

• "Consumer", for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

 

• "Cookies" are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.

 

• "Data Controller", for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

 

• "Device" means any device that can access the Service such as a computer, a cell phone or a digital tablet.

• "Do Not Track" (DNT)” is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

• "Personal Data" is any information that relates to an identified or identifiable individual.
   
  For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
   

 

• "Service" refers to the Website.

 

• "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

 

• "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

• "Website" refers to Journey through life counseling, LLC, accessible from journeythroughlifecounseling.com.

 

• "You" means 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.
   
  Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

We collect two types of data and information from Users.

 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g., pages viewed, online browsing, clicks, actions, etc.).

 

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) and other information which relates to your activity through the Site.

 

We collect information about visitors to our Site so that we can provide an experience that is responsive to our users' and clients' needs. We do not collect medical information or credit card information through our Site. Our Site may use forms in which you give us contact information (including your name, address, telephone number, and email address) so you can request information or support.

We receive and store any information you enter on our Site, or give us in any other way, including through email, telephone, or other communications. You do not need to give us any personal information in order to use our Site.

 

We will not sell, share, trade or otherwise use any information you provide unless you expressly provide in writing permission for such use. We collect this information to improve our service, and to help us determine your individual needs so we may serve you better individually, as well as collectively.

 

We will not sell, share, trade or otherwise use any medical information under any circumstances. If you require medical information, you must request it from us directly via a Medical Release form.

 

We may also collect non-personally identifiable information about you, such as your use of our web sites, communication preferences, aggregated data relative to your Services, and responses to surveys. We may use or disclose aggregate information only where no individual is identified for a number of purposes, including:

(a) Compiling aggregate statistics of usage for improving the web site.

(b) Developing, maintaining, and administering the web site; and

(c) Following up on comments and other messages that you submit to us through the web site.

 

Please note, to better safeguard your information, please do not include any credit card information in your electronic communication unless it is specifically required by us as part of Services or transaction fulfillment process sites, or our client contact process.

 

This Site and our Services may contain links to other websites. Unfortunately, we are not responsible for the privacy practices or the content of such sites.

 

Personal Data

 

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

●    Phone number

●    Address, State, Province, ZIP/Postal code, City

●    Usage Data

Usage Data

 

Usage Data is collected automatically when using the Service.

 

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

 

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

 

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

 

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

 

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.

 

• Web Beacons. Certain sections of our Service and our emails 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 opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

 

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

 

We use both Session and Persistent Cookies for the purposes set out below:

 

• Necessary / Essential Cookies
   
    Type: Session Cookies
   
    Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

 

• Cookies Policy / Notice Acceptance Cookies
   
    Type: Persistent Cookies
   
    Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

 

• Functionality Cookies
   
    Type: Persistent Cookies
   
    Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

 

• Tracking and Performance Cookies
   
    Type: Persistent Cookies
   
    Administered by: Third Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features, or new functionality of the Website to see how our users react to them.

 

For more information about the cookies, we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

 

The Company may use Personal Data for the following purposes:

 

• 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  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 psychoeducational information and general information about services, other services, and events  that you have enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• 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.

 

We may share Your personal information in the following situations:

 

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

 

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, and enforce our legal agreements and policies.

 

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

 

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.

Disclosure of Your Personal Data

Business Transactions

 

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

 

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

 

Other legal requirements

 

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

 

Security of Your Personal Data

 

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

 

We take great care in implementing and maintaining the security of the Site and your information, such as: we employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied, or otherwise, that we will prevent such access.

Correcting, Updating and Removing Personal Information

 

You may alter, update, or deactivate your account information or opt out of receiving communications from us at any time. You may send an email to drshayharris@journeythroughlifecounseling.com. We will respond to your request for access or to modify or deactivate your information within thirty (30) days.

 

Transfer of data outside the EEA

 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

 

If you are visiting this Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting this Site and communicating electronically with us, you consent to such transfers.

 

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.

Advertisements

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).

 

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites:

http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

If you no longer wish to receive emails and if you want to be removed from receiving emails from Journey through life Counseling, LLC, unsubscribe or opt-out. Journey through life Counseling, LLC respects your rights.

Unsubscribe: Click Here

 

Google

Email Marketing

 

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

 

Journey through life Counseling, LLC

 

Payments

 

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g., payment processors).

 

We will not share Your payment details. 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. Payment platforms are private, secure, HIPAA compliant.

 

• Square app
• Ivy Pay app

 

Minors

 

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at DrShayHarris@journeythroughlifecounseling.com .

 

 

Medical Privacy Notice

This Section describes how medical information about you may be used and disclosed by us and how you can get access to this information. Please review it carefully.

 

A. Who Will Follow This Notice

Journey through life Counseling, LLC will follow this notice and any other services you give written consent or release of information to.

 

B. Your Medical Information

This Section refers to your “medical information.” This means all information that identifies you and relates to your past, present or future physical or mental health or condition including information about payment and billing for the health care services you receive.

 

C. Our Pledge About Medical Information

We understand that your medical information is personal, and we are committed to its protection. We create a record of the care and services you receive to ensure that we are providing quality care and to comply with legal requirements. This notice applies to all your medical information that we maintain.

 

We are required by law to give you this notice of our legal duties and Online Information Practices - privacy policy with respect to your medical information, to follow the terms of this Privacy Notice, and to notify you following a breach of the privacy or security of your unsecured medical information.

 

D. How We May Use and Disclose Medical Information About You For each category of use and disclosure, we will try to give some examples, although not every use or disclosure in the category will be listed.

 

1. For treatment. We may use your medical information so that we and other health care providers may provide you with medical treatment or services. Different health professionals may also share your medical information in order to coordinate the different services you need. We may disclose your medical information to people outside our offices and/or locations who may be involved in your medical care after you leave our care.

 

2. For Payment. We may disclose your medical information so that treatment and services you receive may be billed by us to a third party. For example, your health plan may need to know about treatment you received so they will pay us for the services provided. We may also disclose your medical insurance information to obtain prior approval from your health plan, if applicable.

 

3. For Healthcare Operations Purposes. We may use and disclose your medical information for our internal operations, such as business management, and administrative activities, legal and auditing functions, and insurance-related activities. We may use medical information to make sure that all of our client’s receive quality care, such as reviewing our processes or to evaluate the performance of those caring for you. We may also disclose information to professional colleagues for review and learning purposes. We may remove information that identifies you from this set of information so others may use it to study healthcare and healthcare delivery without learning a specific patient’s identity. Under certain circumstances, we may disclose your medical information for the health care operations of other health care providers, with written consent and if applicable.

 

4. Individuals Involved in Your Care or Payment of Your Care. We may release your medical information to a friend or family member who is involved in your medical care, or to someone who helped pay for your care, with written consent.

 

5. Notification. We may release your medical information to notify a family member, personal representative, or another person responsible for your care of your location, general condition, or death. We also may release your medical information for certain disaster relief purposes.

 

6. Contacts. We may contact you to provide appointment reminders, information about treatment alternatives, or other health related benefits and services that may be of interest to you.

 

7. Worker's Compensation. We may release medical information about you for worker’s compensation or similar programs, which provide benefits for work related injuries or illnesses.

 

8. Mental Health Information. State laws create specific requirements for the release of mental health records. We will obtain your specific authorization to release mental medical information when required by these laws.

 

9. Drug & Alcohol Treatment Records. Specific rules apply to the release of certain drug and alcohol program records, and we will obtain your specific authorization to release those records as required by Federal regulation42 CFR, Part 2.

 

10. Miscellaneous. We may use or disclose your medical information without your prior authorization for several other reasons. Subject to certain requirements, we may give out your medical information without prior authorization for public health purposes, abuse or neglect reporting, health oversight audits or inspections, research studies, funeral arrangements, Coroner’s investigations, organ donation, and emergencies. We also may disclose medical information when required by law in response to a request from law enforcement in specific circumstances, for specialized government functions including correctional, military, or national security purposes, in response to valid judicial or administrative orders or to avoid a serious health threat. Additional specific rules may apply to mental health records.

 

11. Other Disclosures. Other uses and disclosures not described above will be made only with your written authorization. Additionally, we will not use or disclose your medical information for marketing purposes unless we have a signed authorization from you. You may revoke your authorization at any time unless we have relied on your authorization, or your authorization was required as a condition of obtaining health care services.

 

E. Your Rights Regarding Medical Information About You

1. Right to Inspect and Copy. In most cases you have the right to inspect or receive a copy of your medical information (or have a copy provided to an individual whom you designate) when you submit a written request. If your medical record is maintained electronically in a designated record set, you have the right to request a copy of the information in an electronic form and format. We may deny your request in certain circumstances. If you are denied access to your medical information, you may appeal.

 

2.Right to Amend. If you believe the information in your record is incorrect or incomplete, you have the right to request an addendum be added to your record by submitting a written request giving your reason. We may deny your request under certain circumstances. If we deny it, we may advise you in writing of the reason or explain your rights to submit a statement of explanation.

 

3. Right to an Accounting of Disclosure. You have the right to a list of those instances where we have disclosed your medical information other than for treatment, payment, healthcare operations, or where a disclosure was specifically authorized., for the Hospital’s directory, to persons involved in your care, and certain other limited situations. To request an accounting of disclosures, you must submit a written request form.

 

4. Right to a Paper Copy of this Notice. If this notice was sent to you electronically you have a right to a paper copy of this notice. You may request that we send other communications of protected health information by alternative means, or to an alternative location. This request must be made in writing to the person listed below in Section 13. We are required to accommodate only reasonable requests. Please specify in your correspondence exactly how you want us to communicate with you; and if you are directing us to send it to a particular place, the contact/address information.

 

5. Right to Request Restrictions. You may request in writing that we not use or disclose your medical information except when specifically authorized by you, when required by law, or in an emergency. Except in the case of certain requests related to disclosures to health plans, we are not required by law to agree to your request, but we will consider the request. We will inform you of our decision.

 

6. Right to Request Restrictions on Disclosures to Health Plans. You may request in writing that we restrict disclosures of your medical information to a health plan for purposes of carrying out payment or healthcare operations if the disclosure is not required by law and the medical information pertains solely to a health care item or service for which you (or a person other than the health plan who is acting on your behalf) have paid us out of pocket and in full at the time of service. We must agree to a request that meets these requirements.

 

7. Google Workspace-

 

Legal and compliance:

Google Cloud Storage Locations: https://www.google.com/about/datacenters/inside/locations/?hl=en

Google Cloud subprocessors: https://www.google.com/intx/en/work/apps/terms/subprocessors.html?hl=en

Google Cloud Privacy Notice: https://cloud.google.com/terms/cloud-privacy-notice?hl=en

Privacy certifications: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&hl=en

Security certifications and third-party audits: https://cloud.google.com/security/compliance/?hl=en

Google Cloud security overview:  https://support.google.com/a/contact/googlecloud_dpr?hl=en

 

GDPR: Google Cloud "We remain committed to helping all customers who rely on our cloud services meet applicable regulatory requirements by protecting any international transfers of their data. data processing terms for Google Cloud Platform, and Google Workspace (including Workspace for Education) and Cloud Identity, to incorporate various modules of the new EU SCCs approved by the European Commission on June 4, 2021, as well as separate UK SCCs. " More information is provided at: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0915&from=EN

GDPR Privacy Policy

To achieve GDPR on the cloud, Journey through life Counseling, LLC take these additional steps

The location where the data is stored and processed by google workspace/cloud identity/files

My GDPR agreement sets out how any personal data I collect from you, or that you provide to me, will be stored, and processed confidentially.

How I gather your personal information

Information that you provide by emailing me via my website and via various therapy directories and platforms (Google platforms; Zoom; Psychology today platforms; adobe; square app; Ivy pay app; Journey through life counseling, LLC website), or by phone to request further information about therapy service.

For Google Workspace Covered Services:

The HIPAA Implementation Guide is available for review at the following URL:  https://services.google.com/fh/files/misc/gsuite_cloud_identity_hipaa_implementation_guide.pdf

HIPAA Included Functionality

As of July 21, 2020, the following functionality is Included Functionality under the applicable HIPAA

Business Associate Addendum:

Gmail, Calendar, Drive (including Docs, Sheets, Slides, and Forms), Apps Script, Keep, Sites, Jamboard, Hangouts (chat messaging feature only), Google Chat, Google Meet, Google Voice (managed users only), Google Cloud Search, Cloud Identity Management, Google Groups, Google Tasks and Vault (if applicable).

The pre-therapy questionnaire form.

Brief session notes.

Regarding online therapy, Journey through life Counseling, LLC use the platforms Zoom platform, psychology today platform and google meet platform. All these platforms are securely encrypted. Zoom has the facility to record sessions which I will not use. Chat transcripts and therapeutic email exchanges will be destroyed either after the session or after therapy has finished and which will be agreed by both of us.

Where I store your personal data

Personal data that I collect from you via any form of contact by email or phone will be kept securely.

The pre-therapy questionnaire form, your contact details, and brief session notes are stored on a computer and password protected.

I take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Uses made of the information

I use your contact details to allow me to provide you with information of the service that you request from me, to allow you to tell me about changes in your availability and to notify you about changes to my availability and any other relevant administrative changes.

How long I keep your information/notes for

I will retain your pre-therapy questionnaire and brief sessions notes for as long as we are working together. After therapy has finished, I will retain these documents for a further five years in case you decide to return to therapy with me, and which is also a requirement of my indemnity insurance, and then after which the documents will be destroyed.

Disclosure of your personal information

In the event of my incapacity or death your personal contact information will be disclosed to my two clinical executors of my Professional Will so that they can notify you. In the event of my death my executors will also destroy all contact information and notes on my computer.

Legal Basis for Processing Personal Data under GDPR

 

We may process Personal Data under the following conditions:

 

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

 

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

 

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

 

You have the right under this Privacy Policy, and by law if You are within the EU, to:

 

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, we may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

 

You may exercise Your rights of access, rectification, cancellation, and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, we will try our best to respond to You as soon as possible.

 

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

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 for 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.

 

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 "Use of 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.

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.

Sale of Personal Information of Minors Under 18 Years of Age

 

We do not knowingly collect personal information from minors 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.

 

We do not sell the personal information of Consumers We actually know are less than 18 years of age, unless We receive affirmative authorization (the "right to opt-in") from the parent or guardian of a Consumer less than 18 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

 

If You have reason to believe that a child under the age of 18 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights

 

You have specific rights regarding their personal information. If You are a resident of Texas, 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.  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.
• 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 services to You
• Providing a different level or quality or services to You
• Suggesting that You will receive a different price or rate for goods or services or a different level or quality services. Please review ‘good faith estimate’ link from journeythroughlife.com and review your forms/documents provided by the counselor.

Website

 

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

 

●    The NAI's opt-out platform:  http://www.networkadvertising.org/choices/ 

●    The EDAA's opt-out platform  http://www.youronlinechoices.com/ 

●    The DAA's opt-out platform:  http://optout.aboutads.info/?c=2&lang=EN 

 

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

 

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

 

●    "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

●    "Limit Ad Tracking" on iOS devices

 

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

 

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.

Children's Privacy

 

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

 

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use 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 Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

 

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

 

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.

 

Complaints and Requests

 

If you have questions about this notice or want to talk about a problem without filing a formal complaint, please contact Journey through life Counseling, LLC at the following number: (210) 864-9939 or email:  drshayharris@journeythroughlifecounseling.com.

 

If you believe your privacy has been violated, you may file a complaint with our organization or with the Secretary of the U.S. Department of Health and Human Services. Information about how to file a complaint with the Department of Health and Human Services may be found at the following website:

http://www.hhs.gov/ocr/privacy/hipaa/complaints/index.html.

 

You will not be penalized for filing a complaint.

If you feel that there is basis for a formal complaint or grievance about anything related to the professional services, we provide we request you to first communicate your concerns to us directly so that we will be informed and have an opportunity to respond and resolve any potential misunderstanding. You have a right to file a complaint about your therapist and may do so by contacting the board at the following phone numbers:

• Texas Behavioral Health Executive Council: main line:(512) 305-7700 investigations/complaints 24-hour, health professions

• council toll free complaint referral system: (800) 821-3205

• Texas State Board of Examiners of Professional Counselors: (512)834-6658

• Texas State Board of Examiners of Psychologists: (512)305-7700

• Texas State Board of Social Workers Examiners: (512)834-6677

• Texas State Board of Examiners of Marriage and Family Therapists: (512)834-6657

 

Contact Us

 

If you have any questions about this Online Information Practices - Privacy Policy, you can contact us:

 

• By visiting this page on our website: Journeythroughlifecounseling.com

• By sending us an email: DrShayHarris@journeythroughlifecounseling.com