Privacy Policy

Privacy Policy

Who we are

Our website address is: http://expattherapy.pl

Privacy

If you’ve spent more than a few minutes looking at the website, it will be no surprise to you that my privacy policy for clients is long and detailed.

For clients in the US, I comply with Health Information Portability and Accountability Act (HIPAA) and use secure, encrypted communication.

For clients in Europe, under General Data Protection Regulation (GDPR) rules governing the European Union, I am required to let you know what information I collect, where and how it is stored, and the lawful purpose for which I collect it. Answers are below.

Under GDPR, it is my duty to protect your confidential information, even if you want to waive your right to privacy. Please do not include any health-related information or discussion about your concerns in unencrypted communication with me.  Texts, unencrypted messaging and unencrypted email are not private.

Visitors to my website

This website uses cookies and cloud storage.  Your IP address is anonymized and user information is collected and aggregated.  The lawful purpose for collecting this information is instrumental, for website functionality.

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Clients

I request that clients communicate with me via ProtonMail email.  Accounts are free and easy to set up, encrypted, private, and secure. It takes about 5 minutes to set up an account.

Protected health information: I will only ask you for information necessary to conduct online therapy / online counseling and contact information in case of emergency or technical problems.  All information will be stored on paper in double locked files for 8 years, as required by my insurance company.  The lawful purpose for collecting the information is the performance of contractual obligations on the part of therapist / counselor to the client.

Confidentiality

Therapists / counselors are bound by ethics and law (and because it’s the right thing to do) to keep communication with clients confidential and private.  We are required to keep your identity and your health information secure, private, and confidential.  We are also required to keep “the fact of the relationship” confidential. This means that therapists / counselors are not allowed to let anyone know that you are in therapy with them without your express, written permission. HIPAA (United States) and GDPR (European Union) mandate that therapists / counselors protect your name, contact information, the IP address of your device, and all your health information.  Therefore, therapists / counselors keep communication with clients secure, encrypted and private, just between the two of us and keep client records secure by working with providers under a Business Associate Agreement (BAA). A BAA binds the service provider to keep your information confidential, not record  or harvest other information about you from your computer, and not to sell it. The only exceptions are instances where disclosure is required by law, e.g., in cases of illegal activity on their platform.

Secure, encrypted service providers

Email:  ProtonMail
Calls and messaging:  Signal
Online meetings with clients over the internet / for online therapy / online counseling / telehealth / tele-mental-health:  Regroup Connect. The Regroup platform  uses Zoom with a HIPAA and GDPR-compliant Business Associate Agreement.

Follow me