Cortesia Counseling, LLC Privacy Policy
Last Updated: January 5, 2025
This Cortesia Counseling Privacy Policy describes how Cortesia Counseling, LLC and our contracted services (“Cortesia Counseling,” “we,” “us”) collect, use, and disclose information about you. This Privacy Policy applies to information we collect from you as a consumer when you access or use our website, and other online services provided by other organizations that support Cortesia Counseling services, or when you otherwise interact with us where we provide this Privacy Policy. In some circumstances, we may provide different or additional notices of our privacy practices to the extent they apply to you because of the services you obtain from us, the capacity in which you engage with us, or different laws that may apply. Other policies and documents may apply should you engage with Cortesia Counseling services.
Cortesia Counseling, LLC will not sell your personal information. Some information may be shared with authorized service providers to ensure services are provided to clients.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Contents
Notice of Collection and Uses of Information
Disclosure of Information
Advertising and Analytics
Transfer of Information to the United States and Other Countries
Your Choices
Privacy Rights
Contact Us
Notice of Collection and Uses of Information
We collect and use your information in a variety of ways. We collect information you provide directly to us. For example, we collect information directly from you when you engage us for service, fill out a form on this website or other, request services, or otherwise communicate with us. We also collect certain information from you or your device automatically when you interact with our online Services such as activity or usage information. We use this information to provide you Services and for other business purposes. The types of information about you that you provide and that we collect automatically are listed below along with our uses of that information.
Cortesia Counseling generally collects the Personal Information described below as part of our HIPAA covered services. We describe below certain information we might collect to the extent you interact with Cortesia Counseling as a consumer (where HIPAA does not apply), along with our uses of that information.
Identifiers, including name, user name, email address, postal address, online identifier, IP address. Identifiers are used to maintain and service accounts, improve products and services, debug, and repair errors in services.
Client records, including name, user name, email address, photos, postal address, telephone number. Client records are used to provide client services, process, or fulfill transactions, verify client information, process payments, communicate with you, analytics, and for security.
Commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories. Commercial information is necessary to provide services including maintaining and servicing accounts, debugging, and repairing errors in services, providing client services, processing, or fulfilling transactions, and analytics.
Internet or other electronic network activity information, including browsing history, search history, information regarding your interaction with the Services, communications, internet service provider, device ID, cookie, or other tracking information.
Audio, such as phone calls or Zoom recordings. Audio and video recordings will be made only after you approve making recordings.
Sensitive personal information, including account log in and password managed by a contracted service provider, consumer health data, information relating to sex life or sexual orientation, age, gender, race, ethnic information, and any information covered by HIPAA regulations. This information is used to directly provide service to you and is protected by counselor-client privilege rules.
In addition, we or a contracted service provider may use the above information to create de-identified, anonymized, or aggregated information that no longer identifies or relates to a specific person. We use such de-identified, anonymized, or aggregated information in accordance with applicable law.
We may also use the personal information listed above to comply with legal and financial obligations and/or to carry out any other purpose described to you at the time the information was collected.
Additionally, if you make a payment through our Services, we work with a third-party payment processor that collects and processes your payment information.
Information We Collect from Other Sources
In addition to collecting information from you, we obtain information from other sources. For example, we may collect and process information from Providers and Health Plans that use or support our Services to you.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.
Retention of Personal Information
We will retain your Personal Information for as long as reasonably necessary to carry out the purposes disclosed in this policy. Certain records will be retained for a number of years after services are ended to ensure compliance with regulations and to protect Cortesia Counseling liabilities.
Disclosure of Information
We do not knowingly sell or share personal information about consumers under the age of 16.
We disclose the following categories of personal information to the recipients described below for the following business purposes or as otherwise described in this policy:
Cortesia Counseling generally discloses Personal Information listed above that is part of our HIPAA covered products and services. We describe below certain information we might disclose to the extent there might be instances where HIPAA does not apply, along with our purposes of disclosure of that information.
Service Providers and Contractors that perform services on our behalf or that assist us with our business purposes described above, including Internet service providers, data analytics service providers, data management providers, operating systems and platforms, payment processors, fulfillment partners, Health Plan providers, client support partners, marketing service partners, and fraud prevention partners
In addition, we may disclose any of the categories of personal information listed above for the following purposes:
We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Cortesia Counseling, our users, the public, or others.
We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Personal information is disclosed between and among Cortesia Counseling and our current and future authorized service providers.
We disclose personal information with your consent or at your direction.
We may also use and disclose aggregated or de-identified information that cannot reasonably be used to identify you.
Transfer of Information to the United States and Other Countries
Cortesia Counseling is headquartered in and offers Services to people residing in the State of Minnesota, United States. Those services we obtain that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, these services provide adequate protection for the transfer of personal data in accordance with applicable law.
Your Choices
Account Information
You may update and correct certain account information at any time by logging into your account and editing your information. If you wish to deactivate your account, please contact us from the website, but note that we may retain certain information as required by law or for our legitimate business purposes.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
Privacy Rights
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request correction of your personal information, (3) request deletion of your personal information, and (4) not be discriminated against for exercising these rights. You may make these requests by sending a message through the website message form or contact Cortesia Counseling directly. If we need to further verify your request, we may do so by asking you to provide information related to your interactions with us.
If we deny your request, you may appeal our decision by contacting us at the website message form at https://cortesiacounseling.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state of Minnesota where you reside.
Opt-out Preference Signals
Some browsers allow you to enable privacy-controls in the browser's settings to automatically signal your opt-out preference to the websites you visit (e.g., Global Privacy Control). To the extent we are required to offer opt-outs through Global Privacy Control, we honor these signals as a valid request to opt-out of the sharing of information linked to your browser. Please be aware, however, that opt-out preference tools are limited to the browser or device you are using. Also, to maintain your privacy preferences, your browser may save some information in its cookies and cache, and if you clear cookies, you may remove your opt-out preferences so that you may have to opt-out again.
If we receive your request from an authorized agent and they do not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent seeking to make a request, please contact us through the website message form at https://cortesiacounseling.com.
Contact Us
If you have any questions about this Privacy Policy, please contact us through the website message form at https://cortesiacounseling.com.