Policy

Terms and Conditions for Online Counseling

October 2019

These Terms and Conditions (“Terms”, “Terms and Conditions”) govern your relationship with Colorado Rocky Mountain Talk Therapy website (including, but not limited to, therapist chat, worksheet feedback and emails) and its affiliated sites (the “Service” or the “Site”) operated by Lori Pahl of Colorado Rocky Mountain Talk Therapy and the site itself.

Please read these Terms and Conditions carefully before using the Service.

Your access to and use of the Service is conditioned on your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who access or use the Service.

By accessing or using the Service you agree to be bound by these Terms and my Privacy Policy »

If you disagree with any part of the terms or my privacy policy then you may not access the Service.

C.R.M. Talk Therapy is devoted to safeguarding you and employee private information and ensuring the highest level of confidentiality of records. This Privacy Policy describes the information we collect, how we use it, and the standards and procedures in place to safeguard your personal nonpublic information.

C.R.M. Talk Therapy, its personnel, and its affiliates strictly adhere to this Privacy Policy and the security practices and procedures described herein to ensure the confidentiality of customer information. It is our policy to comply with all federal and state laws and regulations relating to the privacy of our customers’ private information (PI) and private health information (PHI).

We receive a number of different types of information about you, including:

The information that’s required when you sign up for the site, as well as the information you choose to share.
If you are coming to the site through an employer such as an Employee Assistance Program (EAP) then there is additional information collected by these Parties. This information is typically collected to confirm your eligibility with the EAP or network benefit administrator and is not shared with your Provider (who will collect your contact information separately). Further, your Employer or the Employer of the subscriber of your benefits will not be provided this information (you likely already gave them similar information in your employee file unless you are a family member of an eligible employee).
Except as permitted by law or as otherwise described below, C.R.M. Talk Therapy does not disclose any PI/PHI about its customers, or former customers, or employees, to anyone. C.R.M. Talk Therapy does not sell lists or customer information.

Information C.R.M. Talk Therapy Collects for Customers

C.R.M. Talk Therapy collects, retains, and uses PI/PHI from customers to include the following:

● The information that’s required when you sign up for the site, as well as the information you choose to share.

● Required information such as your name, email address, birthday, and gender. We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.

● “Contact Information” is personal information and or family/friend/relation that C.R.M. Talk Therapist stores confidentially for your Therapist to access in case of an emergency or mental health crisis.

● Information C.R.M. Talk Therapy receives on forms, including, but not limited to, identifying information such as address, telephone number, e-mail address related to customer projects;

● Banking information for billing purposes; such as account # and routing information for invoicing purposes

Information C.R.M. Talk Therapy Collects for Employees and Sub-Contractors

Federal law requires us to obtain, verify, and record personal information – such as your name, address and date of birth – in order to confirm your identity, social security number and banking information.

C.R.M. Talk Therapy collects, retains, and uses PI from employees and subcontractors including the following:

● Information C.R.M. Talk Therapy receives on applications or other forms, including, but not limited to, identifying information such as address, telephone number, e-mail address, social security number, date of birth, mother’s maiden name, medical history;

● Federal Tax ID #;

● Medical records;

● Investment information;

● Background security checks

Information C.R. M. Talk Therapy May Share

C.R.M. is a “DBA” used by Vista Print who runs the site and keeps the Data.We keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies or during an emergency circumstance as judged by your Therapist working with local authorities). Generally, we only use your information within our company. However, sometimes we use third parties to process your information (for example as credit card payment providers). We require these third parties to comply strictly with its instructions and we require that they not use your personal information for their own business purposes.

The Uses of the Collected Data by C.R.M. Talk Therapy

C.R.M. Talk Therapy uses non-identifying and aggregate information to better design our Web site and to use in research and trend analysis. For example, we may tell an advertiser that X number of individuals visited a certain area on our Web site, or that Y number of men and Z number of women filled out a site survey or form, but we would not disclose anything that could be used to identify those individuals. We only provide data to our partners, if any, after we have removed your name and any other personally identifying information from it, or have combined it with other people’s data in a way that it no longer personally identifies you.

C.R.M. Talk Therapy uses non-identifying (De-Identified or “Safe Harbor” form) and aggregate information about responses to the clinical outcome assessments (personal assessments), and the frequency of the utilization of the C.R.M. Talk Therapy service. These efforts enhance program evaluation.

The anonymous and aggregated data also may be published through various media platforms/academic journals. No personal identifying information is tied to the results, and C.R.M. Talk Therapy does not share anything that could be used to identify your account or your private information.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will contact you before we use your data for these new purposes to notify you of the policy change and to provide you with the ability to opt out of these new uses.

c.R.M. Talk Therapy stores data only for as long as it is necessary to provide products and services to you and others, including those described above and for legal protections or as required by applicable laws and regulations.

C.R.M. Talk Therapy may enable access to public information that has been shared through our services.

C.R.M. Talk Therapy may allow service providers to access information so they can help us provide services. IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use; and to analyze and improve the services offered on our website, e.g. to provide you with the most user-friendly navigation experience.

Certain information is needed to provide you with services, so we only delete this information after you delete your account. Some forms of processing (sending promotional information, commercial profiling, behavioral advertising, geo-location, etc.) may require the express consent of the User. Specific information may be shown on the pages of the Site in connection with particular services or processing of Data provided by the Site User.

Upon request we provide site visitors with access to a description of information that we maintain about them. Industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site. If you feel that this site is not following its stated information policy, you may contact us at addresses or phone number below.

Disclosure of Personal Information

We do not share nonpublic personal information about our customers (present, former and potential) with anyone, except as required by law, or as follows:

● To any person when you authorize such disclosure;

● To computer services consultants and technicians or other security consultants, in

order to ensure the confidentiality and security of customer & employee records;

● To financial service providers or consultants to carry out requested services,

and/or to protect against or prevent actual or potential fraud, unauthorized

transactions, claims, or other liability;

● To independent auditors or consultants in order to carry out institutional risk

control;

● To government or regulatory agencies, including self-regulatory organizations

and to comply with a legal summons, court order, subpoena or a similar legal

process, audit or investigation;

● To swap data repositories

Protection: How We Protect Personal Information

We restrict access to information about you to those employees who need to know that information as part of their job responsibilities. Our employees are educated about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities. Precautions have been developed that comply with federal regulations to ensure the security and confidentiality of customer records and information, to guard against any anticipated threats or hazards to the security or integrity of such records, and to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to our customers or our employees.

C.R.M. Talk Therapy maintains strict information security procedures, including physical, electronic and procedural safeguards, to protect the confidentiality of your information. We conduct semi-annual Risk Privacy Assessments and remediate to update our technology to improve the protection of information storage.

We protect nonpublic personal information by:

● Restricting access to customer information to only those personnel for whom the information is necessary.

● Entering into written confidentiality/non-disclosure agreements with third party service providers for certain disclosures.

● Maintaining physical, electronic, and procedural safeguards that comply with the relevant laws and regulations.

● C.R.M Talk Therapy uses firewall barriers and digital certifications to maintain the security of your online session and information.

● We do not collect any non-public personal information about visitors on our website, unless information is provided to us voluntarily or derived from website navigation and usage of the C.R.M. Talk Therapy website.

● Information may be gathered and analyzed regarding usage of our website, including domain name, the number of hits, the pages visited, previous/subsequent sites visited and length of user session. This information may be gathered by using cookies to track usage of the website, to address security issues and store your preferences relating to use of our website. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet, tablet, cell phone or other electronic device (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

Cookies record information about your preferences and allow us to tailor C.R. M. Talk Therapy to your interests. During the course or any visit to the Site, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things such as finding out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking for the cookie left there on the previous visit. Information supplied by cookies can help us to analyze the profile of our visitors so we can provide you with a better user experience.

Privacy Enforcement

Personnel using C.R.M. Talk Therapy information resources in opposition to this policy may be subject to limitations on the use of these resources, suspension of privileges (including internet access), as well as disciplinary and/or legal action, including termination of employment. Employees, contractors, consultants, interns, and all personnel affiliated via third parties sign the Privacy Policy agreement to comply and be governed by this policy and the C.R.M Talk Therapy Information Security Policies upon hire and again annually. All Employees have background checks performed. All Therapists acting as contractors go through rigorous vetting processes meeting or exceeding national credentialing standards.

Copyrights: C.R.M. Talk Therapy and Protecting Other People’s Intellectual Property Rights

We respect other people’s rights, and expect you to do the same. You will not take any action on C.R.M Talk Therapy that infringes or violates someone else’s rights or otherwise violates the law. You will not use our copyrights or any confusingly similar marks, without our written permission.

Portable Electronic Devices

The C.R.M. Talk Therapy website is available on a multitude of portable electronic devices. We provide our connection to mobile services for free, but please be aware that your carrier’s normal rates and fees, such as text messaging fees, may still apply. You provide all rights necessary to enable C.R.M. Talk Therapy Users to sync (including through an application) their contact lists with any basic information and contact information that is visible to them on CR.M. Talk Therapy as well as your name and profile picture.

Social Networks and C.R.M. Talk Therapy

C.R.M. Talk Therapy Users can share information and Data supplied to this Site with the social networks with which the User is registered, accepting their privacy policy. Facebook social buttons/widgets (Facebook) Facebook Social button is a service run by Facebook Inc., a company that complies with the “Safe Harbor” Privacy Policy Framework initiative, guaranteeing the handling of Personal Data.

C.R.M. Talk Therapy reserves the right to amend this Privacy Statement at any time without notice, and only the current Privacy Statement may be deemed effective. Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.

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