Dr. Arroyo-Carrion

7901 4th Street North

Suite 300

St. Petersburg, Florida

33702

WEBSITE PRIVACY POLICY

THIS PRIVACY POLICY (THIS "PRIVACY POLICY") DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.

Effective Date:  January 4, 2024

1.              Applicability. REFLECTION PSYCHOLOGY LLC ("Company" or "we") respect your privacy and are committed to protecting it through our compliance with this Privacy Policy.  We are also legally required to maintain the privacy of your protected health information ("PHI") under the Health Insurance Portability and Accountability Act ("HIPAA") and other federal and state laws.  We follow state privacy laws when they are stricter or more protective of your PHI than federal law.  This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website [www.reflectionpsychology.com] (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.  

A.            As part of our commitment and legal compliance, we are providing you with this Privacy Policy which describes:

i.               Our legal duties and privacy practices regarding your PHI, including our duty to notify you following a data breach of your unsecured PHI;

ii.             Our permitted uses and disclosures of your PHI; and

iii.            Your rights regarding your PHI.

B.             This Privacy Policy applies to information we collect:

i.               On this Website;

ii.             In email, text, and other electronic messages between you and this Website;

iii.            Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website; and/or

iv.            When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this Privacy Policy.

C.             This Privacy Policy does not apply to information collected by:

i.               Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or 

ii.             Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

D.            Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, your choice is not to use our Website.  By accessing or using this Website, you agree to this Privacy Policy.  This Privacy Policy may change from time to time subject to the Company’s sole discretion.  Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

2.              Children Under the Age of 18.  Our Website is not intended for children under eighteen (18) years of age.  No one under age eighteen (18) may provide any personal information to or on the Website.  We do not knowingly collect personal information from children under the age of eighteen (18).  If you are under the age of eighteen (18), do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use; provided however, that your legal guardian may submit this information on our Website on your behalf for purposes of receiving care from the Company’s mental health care providers.  If we learn we have collected or received personal information from a child under eighteen (18) without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child under the age of eighteen (18), please contact our office.  Please note that California residents under sixteen (16) years of age may have additional rights regarding the collection and sale of their personal information.  Please see your state’s privacy rights for more information.

3.              Information We Collect About You and How We Collect It.  

A.            We collect several types of information from and about users of our Website, including information:

i.               By which you may be personally identified, such as name, postal address, email address, telephone number, social security number or any other identifier by which you may be contacted online or offline ("personal information");

ii.             That is about you but individually does not identify you; and/or

iii.            About your internet connection, the equipment you use to access our Website, and usage details.

B.             We collect this information:

i.               Directly from you when you provide it to us;

ii.             Automatically as you navigate through the site (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and/or

iii.            From third parties, for example, our business partners.

4.              Information You Provide to Us.  

A.            The information we collect on or through our Website may include:

i.               Information that you provide by filling in forms on our Website.  This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services . We may also ask you for information when you report a problem with our Website. 

ii.             Records and copies of your correspondence (including email addresses), if you contact us.

iii.            Details of transactions you carry out through our Website and of the fulfillment of your orders.  You may be required to provide financial information on our Website.

B.             Please note that you may also submit information to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Contributions").  Your User Contributions are posted on and transmitted to others at your own risk.  Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable.  Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.  Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

5.              Information We Collect Through Automatic Data Collection Technologies.  

A.            As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

i.               Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

ii.             Information about your computer and internet connection, including your IP address, operating system, and browser type.

B.             The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties.  It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

i.               Speed up your searches.

ii.             Recognize you when you return to our Website.

C.             The technologies we use for this automatic data collection may include:

i.               Cookies, which are small files placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting, you may be unable to access certain parts of our Website.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 

ii.             Web beacons, which are small electronic files that may be contained in our Website and our emails (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 certain website content and verifying system and server integrity). 

6.              Third-Party Use of Cookies and Other Tracking Technologies.  Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers.  These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website.  The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.  They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.  We do not control these third parties' tracking technologies or how they may be used.  If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

7.              How We Use Your Information.  

A.            We use information that we collect about you or that you provide to us, including any personal information:

i.               To present our Website and its contents to you.

ii.             To provide you with information, products, or services that you request from us.

iii.            To fulfill any other purpose for which you provide it.

iv.            To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

v.              To notify you about changes to our Website or any products or services we offer or provide through it.

vi.            To allow you to participate in interactive features on our Website.

vii.          In any other way we may describe when you provide the information.

viii.         For any other purpose with your consent.

8.              HIPAA and PHI.  

A.            Confidentiality.  Generally, we will not disclose information about you, or the fact that you are our patient (if applicable), without your written consent.  Our formal mental health records describe the services provided to you and contain the dates of our sessions, a diagnosis if applicable, functional status, symptoms, prognosis and progress, and any assessment tools administered or obtained.  Health care providers are legally allowed to use or disclose records or information for treatment, payment, and health care operations.  However, we do not routinely disclose information in such circumstances, and we will require your permission in advance, either through your consent at the onset of our relationship (by signing the consent form), or through your written authorization at the time the need for disclosure arises.  You may revoke your permission, at any time, in writing by contacting us.

B.             Limits on Confidentiality.  There are some important exceptions to the above-referenced rule of confidentiality, which permit or require us to disclose confidential information without your consent or authorization.  If such situations arise, we will limit our disclosure to what is necessary.  If you wish to receive mental health services from us, we require that you sign a document indicating that you understand and accept our policies regarding confidentiality and their limits.  We may use or disclose records or other information about you without your consent or authorization in the following circumstances, either by policy, or because we are legally required:

i.               If you are involved in a court proceeding and a request is made for information concerning your diagnosis and treatment, such information may be protected by the psychologist-patient privilege law.  We cannot provide any information without your (or your legal representative's) written authorization, or a court order, or if we receive a subpoena of which you have been properly notified and you have failed to inform us that you oppose the subpoena.  If you are involved in or contemplating litigation, you should consult with an attorney to determine whether a court would be likely to order me to disclose information.

ii.             If a government agency is requesting the information for health oversight activities, within its appropriate legal authority, we may be required to provide it for them.

iii.            If you file a complaint or lawsuit against us, we may disclose relevant information to defend the claim.

iv.            If you file a worker's compensation claim, and we are providing necessary treatment related to that claim, we must, upon appropriate request, submit treatment reports to the appropriate parties, including your employer, your insurance carrier or an authorized qualified rehabilitation provider.

v.              We may disclose the minimum necessary health information to business associates of the Company that provide us with services if the information is necessary for such functions or services.  Our business associates sign agreements to protect the privacy of your information and are not allowed to use or disclose any information other than as specified in our contract.

vi.            If you are involved in a life-threatening emergency and we cannot ask you for permission, we will share information if we believe you would have wanted us to do so, or if we believe it would have been helpful to you.

vii.          There are some situations in which we are legally obligated to take actions, which we believe are necessary to attempt to protect others from harm, and we may have to reveal some information about your treatment:

a.              If we know or have reason to suspect that a child under 18 has been abused, abandoned, or neglected by a parent, legal custodian, caregiver, or any other person responsible for the child's welfare, the law requires that we file a report with the FL Abuse Hotline.  Once such a report is filed, we may be required to provide additional information.

b.              If we know or have reason to suspect that a vulnerable adult has been abused, neglected, or exploited, the law requires that we file a report with the FL Abuse Hotline.  Once such a report is filed, we may be required to provide additional information.

c.              If we believe that there is a clear and immediate probability of physical harm to the patient, to other individuals, or to society, we may be required to disclose information to take protective action, including communicating the information to the potential victim, and/or appropriate family member, and/or the police or to seek hospitalization of the patient.

C.             Data Breach Notification.  We will promptly notify you if a data breach occurs that may have compromised the privacy or security of your PHI.  We will notify you within the legally required timeframe.  Most of the time, we will notify you in writing, by first-class mail, or we may email you if you have provided us with your current email address and you have previously agreed to receive notices electronically.  In some circumstances, our business associates may provide the notification.  In limited circumstances, when we have insufficient or out-of-date contact information, we may provide notice in a legally acceptable alternative form. 

D.            Patient’s Rights and Therapist’s Duties.

i.               Patient’s Rights.  

a.              Right to treatment.  You have the right to ethical treatment without discrimination regarding race, ethnicity, gender identity, sexual orientation, religion, disability status, age, or any other protected category. 

b.              Right to confidentiality.  You have the right to have your health care information protected.  If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer.  We will agree to such unless a law requires us to share that information.

c.              Right to request restrictions.  You have the right to request restrictions on certain uses and disclosures of protected health information about you. However, we are not required to agree to a restriction you request.

d.              Right to receive confidential communications by alternative means and at alternative locations.  You have the right to request and receive confidential communications of PHI by alternative means and at alternative locations.

e.              Right to inspect and copy.  You have the right to inspect or obtain a copy (or both) of PHI.  Records must be requested in writing and release of information must be completed.  Furthermore, there is a copying fee charge of $1.00 per page (plus necessary postage). Please make your request well in advance and allow 2 weeks to receive the copies.  If we refuse your request for access to your records, you have a right of review, which we will discuss with you upon request.

f.               Right to amend.  If you believe the information in your records is incorrect and/or missing important information, you can ask us to make certain changes, also known as amending, to your health information. You must make this request in writing.  You must tell us the reasons you want to make these changes, and we will decide if it is and if we refuse to do so, we will tell you why within 60 days. 

g.              Right to a copy of this notice.  If you received the paperwork electronically, you have a copy in your e-mail.  

h.              Right to an accounting.  You generally have the right to receive an accounting of disclosures of PHI regarding you.  On your request, we will discuss with you the details of the accounting process.

i.               Right to choose someone to act for you.  If someone is your legal guardian, that person can exercise your rights and make choices about your health information; we will make sure the person has this authority and can act for you before we take any action. 

j.               Right to choose.  You have the right to decide not to receive services with us.  

k.              Right to terminate.  You have the right to terminate therapeutic services with us at any time without any legal or financial obligations other than those already accrued.  We ask that you discuss your decision with us in session before terminating or at least contact us by phone letting us know you are terminating services.

l.               Right to release information with written consent.  With your written consent, any part of your record can be released to any person or agency you designate.  Together, we will discuss whether we think releasing the information in question to that person or agency might be harmful to you.

m.            Right to make complaints.  If you are concerned that we have violated your privacy rights, or you disagree with a decision we made about access to your records, you may contact us, the State of FL Department of Health, or the Secretary of the U.S. Department of Health and Human Services.  You will not be penalized for filing a complaint.  

ii.             Therapist’s Duties.  

a.              We are required by law to maintain the privacy of PHI and to provide you with a notice of our legal duties and privacy practices with respect to PHI.  We reserve the right to change the privacy policies and practices described in this notice.  Unless we notify you of such changes, however, we are required to abide by the terms currently in effect.  If we revise our policies and procedures, we will provide you with a revised notice.

b.              We use and disclose your health information internally in the course of your treatment.  If we wish to provide information outside of our practice for your treatment by another health care provider, we will have you sign an authorization for release of information.  Furthermore, an authorization is required for most uses and disclosures of psychotherapy notes.  We may also use and disclose your health information to obtain payment for services provided to you.  We may use and disclose your health information as part of our internal operations.  For example, this could mean a review of records to assure quality.  We may also use your information to tell you about services, educational activities, and programs that we feel might be of interest to you.

9.              Data Security.  We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, and alteration.  However, the safety and security of your information also depends on you.  Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards.  The information you share in public areas may be viewed by any user of the Website.  Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website.  Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

10.           Changes to Our Privacy Policy.  It is our policy to post any changes we make to our Privacy Policy on this page.  If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page.  The date the Privacy Policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.  

11.           Contact Information.  To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: drarroyo@reflectionpsychology.com