Effective Date: March 23, 2025

1. Introduction

Posit Therapy PC (“Practice,” “we,” “our,” or “us”) is committed to safeguarding your privacy and protecting the personal information you share with us. This Privacy Policy describes how we collect, use, disclose, and secure information when you access or interact with our Website at https://posittherapy.com (the “Website”).

This Privacy Policy applies only to information collected through our Website. It does not apply to information exchanged through secure client portals, in-session disclosures, or clinical records, which are governed separately by our HIPAA Notice of Privacy Practices.

• This policy is designed to comply with the following laws and regulations:
• The Health Insurance Portability and Accountability Act of 1996 (HIPAA);
• The Florida Information Protection Act (FIPA);
• The Federal Trade Commission Act (FTC Act), including provisions prohibiting deceptive or unfair data practices;
• Other applicable state and federal privacy and consumer protection laws.

By accessing or using our Website, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with any part of this policy, you should immediately discontinue use of the Website.

2. Information We Collect

We may collect the following types of information when you visit our Website or interact with our online services:

• Personal Information: Name, phone number, email address, and any details submitted via contact forms.
• Health Information (if voluntarily provided): Limited health-related details you submit when requesting an appointment or making an inquiry.

We do not intentionally collect sensitive health information through our Website and encourage users not to submit detailed medical, diagnostic, or therapeutic information via general contact forms.

• Device & Usage Data: IP addresses, browser type, operating system, pages visited, referring URLs, and website analytics.
• Communication Data: Emails, text messages, voicemails, or inquiries sent through the Website.
• Third-Party Tracking Information: Website usage data collected by third-party analytics providers, such as Google Analytics.
• Location Data: If permitted by your device settings, we may collect your approximate location to improve service access.

2.1 Children’s Privacy

our Website is not intended for individuals under the age of 18. We do not knowingly collect personal data from minors without parental or guardian consent. If you believe a minor has provided information, please contact us for prompt deletion.

3. How We Use Your Information

We collect and use your information to:

• We collect and use your information for legitimate business purposes, including to:
• Respond to inquiries and provide requested services;
• Communicate with you, including updates or appointment confirmations (if you have opted in);
• Enhance website security and prevent fraudulent activity;
• Analyze website traffic and improve website performance and functionality;
• Ensure compliance with legal and regulatory obligations;
• Enforce our Website policies and protect against unauthorized access or misuse.

We do not use your information for automated decision-making, behavioral profiling, or advertising targeting based on sensitive personal data.

4. Cookies and Tracking Technologies

our Website uses cookies and similar technologies to:

• Track visitor usage and enhance site performance;
• Provide customized website content based on user preferences;
• Improve website security and detect fraudulent behavior.

4.1 Managing Cookies & Opt-Out Options: You have control over how cookies and tracking technologies are used:

• Browser Settings: You can disable cookies in your browser settings. However, some website features may not function properly if cookies are disabled.
• Google Analytics: We use Google Analytics to track website usage. You can opt out via Google’s opt-out tool.
• Do Not Track (DNT) Signals: Where technically feasible, we will honor Do Not Track (DNT) settings enabled in your browser. However, some third-party tools we use may not respond to DNT signals.

If you have concerns about tracking technologies, contact us at info@posittherapy.com for further options.

5. How We Share Information

Posit Therapy PC does not sell, rent, or trade your personal information. However, we may share information in the following circumstances:

• Third-Party Service Providers: We may share data with vendors assisting with website operations, appointment scheduling, payment processing, and analytics. These providers are required to comply with HIPAA, FIPA, and other applicable privacy regulations.
• Legal & Regulatory Compliance: We may disclose personal information if required by law, court order, or government regulations. This includes compliance with HIPAA’s permitted disclosures, such as responding to public health authorities.
• Law Enforcement & Fraud Prevention: We may share data to investigate or prevent fraud, cybersecurity threats, or other legal violations.
• Business Transitions: If Posit Therapy PC undergoes a merger, acquisition, or sale, your personal information may be transferred only if the new entity agrees to honor the terms of this Privacy Policy.

We take steps to ensure third-party compliance with data protection regulations. However, we are not responsible for the privacy practices of external websites or third-party platforms linked from our Website.

5.1 Third-Party Data Sharing Protections

We require all third-party vendors to comply with HIPAA, FIPA, and other applicable privacy regulations when handling personal data.

6. Data Protection & Security Measures

To safeguard your information, we implement strict security measures in compliance with HIPAA, FIPA, and federal standards:

• Encryption: All data transmitted through our Website is encrypted using industry-standard encryption protocols.
• Secure Storage: Personal information is stored on HIPAA-compliant, secure servers with multi-layer access controls.
• Access Restrictions: Only authorized personnel with a valid business need can access stored data.
• Regular Security Audits: We conduct periodic risk assessments and security audits to ensure data protection compliance.
• Breach Prevention: Our cybersecurity protocols align with HIPAA and FIPA requirements to mitigate risks.

Despite our efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. You are encouraged to avoid transmitting sensitive personal information through unencrypted channels.

7. User Rights & Choices

Under Florida and federal law, you have the following rights regarding your personal data:

• Right to Access: You may request a copy of the personal information we have collected about you.
• Right to Correct Information: If your data is inaccurate, you may request corrections.
• Right to Request Deletion: You may request the deletion of your personal information, subject to legal retention requirements under HIPAA or FIPA.
• Right to Restrict Processing: You may request that we limit how we use your data under certain circumstances.
• Right to Opt-Out of Marketing: You may opt out of receiving promotional emails or texts. To do so, reply “STOP” to text messages or email info@posittherapy.com.
• Right to Non-Discrimination: Exercising your privacy rights will not affect your access to services.

To exercise these rights, submit a written request to info@posittherapy.com. Please allow up to 30 days for processing.

8. Electronic Communications & Consent

By submitting information through our Website, you consent to electronic communications, including:

• Emails and text messages related to inquiries, service requests, or administrative purposes.
• For more information on how we manage electronic communications, including text messaging practices, security measures, and opt-out options, please refer to the Posit Therapy Client Electronic Communication & Texting Policy.

9. Data Retention Policy

We retain personal data only as long as necessary to:

• Comply with HIPAA and FIPA legal obligations;
• Fulfill the purposes outlined in this policy;
• Improve website security and functionality.

When data is no longer required, we securely delete or anonymize it in accordance with HIPAA and industry best practices.

10. Breach Notification Policy

If a data breach occurs affecting Protected Health Information (PHI) or personal data, we will notify affected individuals in compliance with Florida and federal laws:

• Under FIPA: Notification will occur within 30 days of discovery.
• Under HIPAA: Notification will occur within 60 days of discovery.
• Notifications will include: The nature of the breach, the affected data, steps taken to mitigate harm, and recommended actions for affected individuals.

11. SMS Communications Privacy Policy

If you provide your mobile phone number to Posit Therapy PC and consent to receive text messages, you agree that Posit Therapy PC may send you SMS messages related to customer care and administrative communications, including appointment scheduling, appointment reminders, account notifications, and other service-related messages.

Message frequency varies. Message and data rates may apply. Reply STOP to opt out. Reply HELP for help.

Your mobile phone number and SMS consent information will not be sold, rented, or shared with third parties or affiliates for marketing or promotional purposes. We use this information only to send the communications you have agreed to receive, to provide services to you, and as otherwise described in this Privacy Policy.

You may opt out of SMS messages at any time by replying STOP to any message. For assistance, reply HELP or contact us at privacy@posittherapy.com or +1 (212) 818-1900.

12. Updates to This Privacy Policy

We may update this Privacy Policy at any time to reflect changes in laws, security standards, or website functionality.

If material changes are made, we will post a notice on our Website.

Your continued use of our Website constitutes acceptance of any revised policy.

13. Contact Information

For privacy-related inquiries, data access requests, or to exercise your rights under this policy, contact us at:

Posit Therapy PC
25 SE 2nd Ave Ste 550 #595
Miami, FL 33131-1601
Email: info@posittherapy.com