I. OUR PLEDGE REGARDING YOUR HEALTH INFORMATION:
We at Freedom360 understand that health information about you and your health care is personal. We are committed to protecting health information about you. During this therapeutic relationship, we create a record of the care and services you receive from us which is used to provide you with quality care and comply with certain legal requirements.
This notice applies to all records of your care generated by Freedom360 LLC. This notice will describe your rights to the health information we keep about you, describe the obligations we have regarding the use of these records, and the circumstances for disclosure of your health information. We are required by law to:
Make sure that protected health information (“PHI”) that identifies you is kept private.
Give you this notice of our legal duties and privacy practices with respect to health information.
Follow the terms of the notice that is currently in effect.
We can change the terms of this notice, and such changes will apply to all information we have about you. The new notice will be available upon request and on the Freedom360 website.
The following categories describe different ways that Freedom360 LLC., Timilia T. Williams MA, LPC (owner), and any other employee and contractor currently or previously affiliated with Freedom360 LLC. use and disclose health information. Each category of uses or disclosures included both details and some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.
II. WHAT PERSONAL INFORMATION DO WE COLLECT FROM THE PEOPLE WHO VISIT OUR WEBSITE, BLOG, OR CLIENT PORTAL?
When registering or managing your appointments on our Freedom360 Client Portal or website, as appropriate, you may be asked to enter your name, email address, phone number, credit card information, or other personal or health details to help you with your experience.
III. WHEN DO WE COLLECT INFORMATION?
We collect information from you when you register on the Freedom360 Client Portal, subscribe to a newsletter, fill out a form, use the live chat or enter information on our website.
IV. HOW DO WE USE YOUR INFORMATION?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
To provide optimal therapeutic services via telehealth.
To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
To allow us to better service you in responding to your customer service requests.
To quickly process your transactions.
To send periodic emails regarding your order or other products and services.
To follow up with them after correspondence (live chat, email, or phone inquiries)
V. HOW DO WE PROTECT YOUR INFORMATION?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
VI. WE USE REGULAR MALWARE SCANNING.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
VII. DO WE USE 'COOKIES'?
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, It won't affect the user's experience.
VIII. THIRD-PARTY DISCLOSURE
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it's release is appropriate to comply with the law, enforce our site policies, or protect our or others' rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
IX. THIRD-PARTY LINKS
We do not include or offer third-party products or services on our website.
X. CLIENT COMMUNICATION & HIPPA COMPLIANCE
We use Google Workspace for client and therapist communication, and it is covered under Google’s HIPAA Business Associate Addendum (BAA). This means that all contact between you and us is confidential and HIPAA compliant and cannot be disclosed to anyone without your permission or court order. All emails, texts, phone calls, and voicemails are protected.
More about the Google Workspace HIPAA Business Associate Addendum can be summed up here, https://workspace.google.com/terms/2015/1/hipaa_baa.html.
All of our Google entities that are HIPPA compliant and how they are used are described here:
https://services.google.com/fh/files/misc/gsuite_cloud_identity_hipaa_implementation_guide.pdf. This HIPAA implementation guide sums up how we protect customer and client information within Google Workspace.
XI. GOOGLE ADVERTISING
Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
XII. WE HAVE IMPLEMENTED THE FOLLOWING:
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
XIII. OPTING OUT:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt-out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.
XIV. CALIFORNIA ONLINE PRIVACY PROTECTION ACT
You can change your personal information by emailing firstname.lastname@example.org.
XV. HOW DOES OUR SITE HANDLE DO NOT TRACK SIGNALS?
We don't honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. We don't honor them because each visitor is allowed to opt-out of tracking via cookies notification.
XVI. DOES OUR SITE ALLOW THIRD-PARTY BEHAVIORAL TRACKING?
It's also important to note that we allow third-party behavioral tracking.
XVII. COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)
When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
We do not specifically market to children under the age of 13 years old.
XVIII. FAIR INFORMATION PRACTICES
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur we will notify you via email within 7 business days.
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
XIX. CAN-SPAM ACT
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions
Process invoices and send information and updates pertaining to services.
Send you additional information related to your product and/or service
Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN-SPAM, we agree to the following:
Not use false or misleading subjects or email addresses.
Identify the message as an advertisement in some reasonable way.
Include the physical address of our business or site headquarters.
Monitor third-party email marketing services for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly.
Allow users to unsubscribe by using the link at the bottom of each email.
XX. LAWSUITS AND DISPUTES
If you are involved in a lawsuit, we may disclose health information in response to a court or administrative order. We may also disclose health information about your child in response to a subpoena, discovery request, or other lawful processes by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
XXI. RELEASE OF INFORMATION
With your written consent Federal privacy rules (regulations) allow health care providers who have a direct treatment relationship with the patient/client to use or disclose the patient/client’s personal health information to carry out the health care provider’s own treatment, payment, or health care operations.
Certain uses & disclosures that require your authorization:
Psychotherapy Notes. We do keep “psychotherapy notes” as that term is defined in 45 CFR § 164.501, and any use or disclosure of such notes requires your Authorization unless the use or disclosure is:
For your therapist's use in treating you.
For your therapist's use in a group, joint, family, or individual counseling or therapy in which you co-participate.
For your therapist's use in defending myself in legal proceedings instituted by you.
For use by the Secretary of Health and Human Services to investigate my compliance with HIPAA.
Required by law and the use or disclosure are limited to the requirements of such law.
Required by law for certain health oversight activities pertaining to the originator of the psychotherapy notes.
Required by a coroner who is performing duties authorized by law.
Required to help avert a serious threat to the health and safety of others.
Marketing Purposes: As psychotherapists, we will not use or disclose your PHI for marketing purposes.
Sale of PHI: As psychotherapists, we will not sell your PHI in the regular course of Freedom360 business operations.
Certain uses & disclosures that DO NOT require your authorization:
Subject to certain limitations in the law, we can use and disclose your PHI without your Authorization for the following reasons:
When disclosure is required by state or federal law, and the use or disclosure complies with and is limited to the relevant requirements of such law.
For public health activities, including reporting suspected child, elder, or dependent adult abuse, or preventing or reducing a serious threat to anyone’s health or safety.
For health oversight activities, including audits and investigations.
For judicial and administrative proceedings, including responding to a court or administrative order, although my preference is to obtain Authorization from you before doing so.
For law enforcement purposes, including reporting crimes occurring on my premises.
To coroners or medical examiners, when such individuals are performing duties authorized by law.
For research purposes, including studying and comparing the mental health of patients who received one form of therapy versus those who received another form of therapy for the same condition.
Specialized government functions, including, ensuring the proper execution of military missions; protecting the President of the United States; conducting intelligence or counter-intelligence operations; or, helping to ensure the safety of those working within or housed in correctional institutions.
For workers' compensation purposes. Although our preference is to obtain Authorization from you, we may provide your PHI in order to comply with workers' compensation laws.
Appointment reminders and health-related benefits or services. We may use and disclose your PHI to contact you to remind you that you have an appointment with a Freedom360 Therapist, to tell you about treatment alternatives, or other health care services or benefits that we offer.
Certain uses & disclosures require you to have the opportunity to object:
Disclosures to family, friends, or others: We may provide your PHI to a family member, friend, or another person that you indicate is involved in your care or the payment for your health care unless you object in whole or in part. The opportunity to consent, using a written and signed Release of Information (ROI), may be obtained retroactively in emergency situations.
XXII. YOU HAVE THE FOLLOWING RIGHTS WITH RESPECT TO YOUR PHI:
The Right to Request Limits on Uses and Disclosures of Your PHI: You have the right to ask Freedom360 and your Therapist not to use or disclose certain PHI for treatment, payment, or health care operations purposes. We are not required to agree to your request and may say “no” if we believe it would affect your health care.
The Right to Request Restrictions for Out-of-Pocket Expenses Paid for In Full: You have the right to request restrictions on disclosures of your PHI to health plans for payment or health care operations purposes if the PHI pertains solely to a health care item or a health care service that you have paid for out-of-pocket in full.
The Right to Choose How We Send PHI to You: You have the right to ask Freedom360 and your Therapist to contact you in a specific way (for example, home or office phone) or to send mail to a different address, and we will agree to all reasonable requests.
The Right to See and Get Copies of Your PHI: Other than “psychotherapy notes,” you have the right to get an electronic or paper copy of your medical record and other information that Freedom360 and your Therapist have about you. We will provide you with a copy of your record, or a summary of it, if you agree to receive a summary, within 30 days of receiving your written request. A Document Fee of $50.00 USD per request will apply.
The Right to Get a List of the Disclosures We Have Made: You have the right to request a list of instances in which we have disclosed your PHI for purposes other than treatment, payment, or health care operations, or for which you provided me with an Authorization. We will respond to your request for an accounting of disclosures within 60 days of receiving your request. The list we will give you will include disclosures made in the last six years unless you request a shorter time. We will provide the list to you at no charge, but if you make more than one request in the same year, we will charge you a reasonable cost-based fee for each additional request.
The Right to Correct or Update Your PHI: If you believe that there is a mistake in your PHI, or that a piece of important information is missing from your PHI, you have the right to request that Freedom360 and your Therapist correct the existing information or add the missing information. We may say “no” to your request but we will tell you why in writing within 60 days of receiving your request.
The Right to Get a Paper or Electronic Copy of this Notice: You have the right to get a paper copy of this Notice, and you have the right to get a copy of this notice by e-mail. And, even if you have agreed to receive this Notice via e-mail, or the Freedom360 Client Portal you also have the right to request a paper copy of it.
If at any time you would like to unsubscribe from receiving future emails, you can email us at
email@example.com and we will promptly remove you from ALL correspondence.
Last Updated on February 2, 2022