Rachel M Totten, MSW, LICSW, LADC (“RMT”) is dedicated to maintaining your privacy and protecting your personal information. We work to protect your personal information and maintain your privacy through your use of our websites. This Privacy Policy (the “Policy”) applies to our websites available at RachelTotten.com.   BY USING THE SITES YOU CONSENT TO THE TERMS OF THIS POLICY AND TO RMT’S COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY YOU ARE NOT PERMITTED TO USE THE SITES.

 

Information Collected

We collect two types of information from users of the Sites: 1) Personal Information (e.g. your name, email address, payment information); and, 2) Non-Personal Information (e.g. cookies or IP address).

Personal Information

“Personal Information” is information that identifies you personally, such as your name, postal address, telephone number, or email address. RMT collects and stores the Personal Information that you have provided to us. Here are some examples of manners in which we may collect your Personal Information on the Sites:

  • We may collect your first and last name, email address, and postal address when you become a member and sign up to receive information from RMT;
  • We may collect your email address if you contact us with a question;
  • We may collect your first and last name, postal address and billing information if you make a purchase through our Site;
  • We may collect particular information about your business and business practices through your use of the Sites; and,
  • We may collect your device ID number when you interact with the Sites using a mobile device.
  • We may collect information provided by Google Analytics’ Demographics and Interest Reports, including age, gender, affinity categories, in-market segments, and other categories provided by the service.

The above list provides an example of the Personal Information that may be collected from you on the Sites. This list may be non-exhaustive and may change from time to time as our practices change, or as we add or change the features or services through the Sites. If you do not want RMT to collect your Personal Information, please do not provide it to us.

Retention and Deletion

RMT will retain your Personal Information after your account has been deactivated; as needed to provide you with the products or services described above; as needed for the purposes outlined in this Policy or at the time of collection; as necessary to comply with our legal obligations (e.g., to honor opt-outs), resolve disputes, and enforce our agreements; or to the extent permitted by law.

At the end of the retention period, RMT will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.

Sensitive Information

We ask that you not send us, and you not share any sensitive Personal Information (e.g., Social Security numbers).

Non-Personal Information

“Non-Personal Information” can be technical information or it can be demographic information, such as your age, gender, ZIP code or other geolocation data, or interests. Non-Personal Information does NOT identify you personally. Here are some examples of the Non-Personal Information that is collected via the Sites and a description of how this information is used:

  • Internet Protocol (IP) address — Your IP address is a number that lets computers attached to the Internet know where to send you data — such as the webpages you view. We use this information to deliver our webpages to you upon request, to tailor our Sites to the interests of our users and to measure traffic within our Sites.
  • Cookies — our Sites use “cookies” to improve functionality and usability. We use this information for planning, tracking and to improve the technical functions of our Sites and products. By using our products and agreeing to this Policy, you consent to our use of cookies in accordance with the terms of this Policy.
  • Physical Location — We may collect the physical location of your device and use it to provide you with personalized location-based services or content. In some instances, you may be permitted to allow or deny such use of your device’s location, but if you choose to deny such use, we may not be able to provide you with the applicable personalized services or content.

About Cookies

Cookies are text files sent by Web servers to Web browsers and are stored on the user’s computer or mobile device. If the browser is loading a page and the server requests the information stored in the cookie, the cookie is sent back to the server.

Cookies contain data about the user’s activities on the website, and can be used by Web servers to identify and track users as they navigate different pages on a website, and to identify users returning to a website.

Cookies may be either “persistent” or “session” cookies. A persistent cookie will remain valid until its set expiration date (unless deleted by the user). A session cookie will expire at the end of the user session, when the Web browser is closed.

How RMT uses cookies

Cookies do not contain any information that personally identifies the user, but information that we store about the user may be linked by us to the information stored in and obtained from cookies.

The Sites use the information we obtain from people’s use of our website through cookies for the following purposes:

  • To recognize the user’s computer when the user visits the Sites.
  • To track some user actions during website navigation.
  • To improve the Sites’ usability.
  • To analyze the use of the Sites.
  • To administer the Sites.
  • To report click-through data to our advertisers.

Third-party cookies

When users visit the Sites, third-party cookies may be sent to their computers by RMT’s advertisers or service providers.

They may use the information obtained from these cookies:

  • To track users browsing across multiple websites.
  • To build profiles of users’ Web surfing.
  • To target advertisements that may be of particular interest to users.

Blocking cookies

Most browsers allow users to refuse to accept cookies.

  • In Internet Explorer, you can refuse all cookies by clicking “Tools,” “Internet Options,” “Privacy,” and selecting “Block all cookies” using the sliding selector.
  • In Firefox, you can block all cookies by clicking “Tools,” “Options,” and un-checking “Accept cookies from sites” in the “Privacy” box.
  • In Google Chrome, you can adjust your cookie permissions by clicking “Options,” “Under the hood” and Content Settings in the “Privacy” section. Click on the Cookies tab in the Content Settings.
  • In Safari, you can block cookies by clicking “Preferences,” selecting the “Privacy” tab and “Block cookies.”

Blocking all cookies will, however, have a negative impact upon the usability of many websites. If you block cookies, you may not be able to log on, access content or use search functions, for example.

Deleting cookies

Users can also delete cookies already stored on their computers:

  • In Internet Explorer, you must manually delete cookie files.
  • In Firefox, you can delete cookies by first ensuring that cookies are to be deleted when you “clear private data” (this setting can be changed by clicking “Tools,” “Options” and “Settings” in the “Private Data” box) and then clicking “Clear private data” in the “Tools” menu.
  • In Google Chrome, you can adjust your cookie permissions by clicking “Options,” “Under the hood,” and Content Settings in the “Privacy” section. Click on the Cookies tab in the Content Settings.
  • In Safari, you can delete cookies by clicking “Preferences,” selecting the “Privacy” tab and selecting “Remove All Website Data.”

Doing this may have a negative impact on the usability of many websites.

Other Forms of Non-Personal Information

  • Web Beacons (also known as “clear gifs,” “Web bugs” or “pixel tags”) —”Web Beacons” are tiny graphics with a unique identifier, similar in function to cookies, and are used to allow us to count users who have visited certain pages of the Sites and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user’s computer hard drive, Web beacons are embedded invisibly on Web pages.

Please note that we also consider aggregated information, which is not personally identifiable, to be Non-Personal Information. The above list provides an example of the Non-Personal Information that is collected via the Sites.   If you do not want RMT to have access to your Non-Personal Information, please do not use the Sites.

Use of Information Collected Via the Sites

Personal Information

We use your Personal Information that is collected on the Sites primarily for the following purposes:

  • To deliver services, such as educational programs, information or newsletters you request or purchase;
  • To alert you to special offers, updated information and other new services from RMT or other third parties or to forward promotional materials;
  • To process your order and, if necessary, to contact you regarding the status of your order;
  • To fulfill the terms of a promotion;
  • To ensure the Sites are relevant to your needs;
  • To help us create and publish content most relevant to you;
  • To contact you regarding additional services and features;
  • To request your feedback about your experience with RMT;
  • To notify you about a material change to this Policy, if necessary; and
  • To allow you access to limited-entry areas of the Sites.
  • To research and develop predictive algorithms related to information security.

Non-Personal Information

Non-Personal Information is used as described above and in other ways as permitted by applicable laws, including combining Non-Personal Information with Personal Information.

Release of Information to Third Parties

By using the Sites you grant RMT the right to use your Non-Personal Information for marketing and to improve the Sites. This use may involve the disclosure of your Non-Personal Information to third parties. PCT will not share or disclose your Personal Information with third parties.

Children Under 13

The Sites do not knowingly target children under the age of 13 and we do not collect Personal Information from any child under the age of 13. In the event we learn that such information has been provided to the Sites, we will delete or destroy it.

Third Party Websites and Advertisers

The Sites may provide you with links to other websites, although we do not necessarily advise that you link to another website. In the event that you choose to access such websites, RMT is not responsible for any actions or policies of those sites. Further, please note that the third party’s privacy policies and security practices may differ from RMT standards. RMT neither assumes responsibility for, nor does it control, endorse or guarantee any aspect of your use of any linked sites. We recommend that you check the privacy policy of such a party before providing Personal Information to it.

The RMT may also permit advertisers, third party ad networks or other advertising companies to serve advertisements on the Sites. Please be advised that such advertising companies may gather information about your visit to the Sites or other sites (such as through cookies, Web beacons and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which Web pages you were viewing when such ads were delivered. PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH ADVERTISING COMPANIES.

Opt-Out

We communicate with our members on a regular basis via email. For example, we may use your email address to confirm your request, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, members cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional.

However, we provide you the opportunity to exercise an opt-out choice if you do not want to receive other types of communications from us, such as messages or updates from us regarding new services and products offered on the Sites. For emails, you may opt-out by clicking on the “unsubscribe” link within the text of an email. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. Please note that electing to opt-out of our promotional emails does not mean that we will delete or remove your email address from our systems.

Changes in Our Privacy Policy

RMT reserves the right to make changes to this Policy at any time and for any reason without prior notice. Any changes to this Policy will be posted on this page so that you are always aware of our current policies. We may also contact you by email with changes. Additionally, we will update the “last updated” date below.

Website Security

No data transmissions over the Internet can be guaranteed to be 100 percent secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to RMT is done at your own risk. However, RMT uses website security measures consistent with current best practices to protect the Sites, email and mailing lists. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorized access or disclosure, loss, alteration or destruction.

The Website is secured using secure socket layer (SSL) encryption. This encryption applies to your Personal Information provided through the Website, including your credit card information transmitted through the Website. Assignment

In the event that all or part of RMT’s assets are sold or acquired by another party, or in the event of a merger, you grant RMT the right to assign the Personal and Non-Personal Information collected via the Sites.

Contacting RMT

Please email any questions or concerns regarding this Please contact info@racheltotten.comWhile we may not be able to respond to every report, we take each report seriously and will investigate it thoroughly.

 

This notice describes how medical information about you may be used and disclosed and how you can access this information.  Please review it carefully.

These are the disclosures of protected health information (PHI) that Rachel Totten, MSW, LICSW, LADC may make without a patient’s consent or authorization:

  • In connection with treatment, for example to a licensed practitioner working in or covering this practice in Rachel Totten, MSW, LICSW, LADC’s absence, or health care office or payment operations, such as appointment scheduling or patient claim for reimbursement from his or her insurance company.
  • To qualified service organizations or business associates who provide services to Rachel Totten, MSW, LICSW, LADC regarding treatment, payment or health care operations;
  • In medical emergencies;
  • Authorized by court order;
  • To auditors and evaluators;
  • To researchers if the information will be protected as required by Federal regulations;
  • To report suspected child or elder abuse or neglect, or vulnerable person abuse and neglect: and
  • To report a crime or a threat to commit a crime on Rachel Totten, MSW, LICSW, LADC premises or against Rachel Totten, MSW, LICSW, LADC personnel.

Other disclosures will be made only with a patient’s written consent or authorization which can be revoked verbally or in writing, unless Rachel Totten, MSW, LICSW, LADC has taken action in reliance on the consent or authorization.

Rachel Totten, MSW, LICSW, LADC may contact patients to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to patients.

Rachel Totten, MSW, LICSW, LADC is required by law to maintain the privacy of PHI and to notify patients of its legal duties and privacy practices, including any changes to its policies;

Rachel Totten, MSW, LICSW, LADC must abide by the terms of the notice currently in effect; Rachel Totten, MSW, LICSW, LADC reserves the right to change the terms of its notice and to make the new notice provisions effective for all information it maintains; changes to this notice will be posted on the websitewww.racheltotten.com posted in a prominent place in the Rachel Totten, MSW, LICSW, LADC office, and available on paper by request from Rachel Totten, MSW, LICSW, LADC staff;

Rachel Totten, MSW, LICSW, LADC at 802 448-0075, is the person patients can contact to access PHI, for further information, or to complain about privacy issues;

patients have rights with respect to PHI which may be exercised in the following ways:

  • The right to request restrictions on certain uses and disclosures of PHI, Rachel Totten, MSW, LICSW, LADC is not required to agree with requested restrictions;
  • The right to receive confidential communications of PHI (such as having mail and telephone calls be limited to home or office location);
  • The right to access and amend PHI;
  • The right to receive an accounting of the Rachel Totten, MSW, LICSW, LADC’s disclosures of PHI;
  • The right to be notified following a breach of unsecured PHI;
  • The right to limit release of PHI to a health plan when patient pays in full out of pocket.
  • The right to complain—free from retaliation—to Rachel Totten, MSW, LICSW, LADC and to the Secretary of Health and Human Services (HHS) about violations of privacy rights, The complaint must be written, either on paper or electronically, and filed with HHS Office for Civil Rights within 180 days of when the complainant knew, or should have known, that the act or omission complained of occurred, unless a waiver is granted. The complaint must name Rachel Totten, MSW, LICSW, LADC and describe the violation of the Privacy Rule;
  • Complaints against Rachel Totten, MSW, LICSW, LADC may also be filed with United States Attorney for the judicial district in which the alleged violation occurred, and with Rachel Totten, MSW, LICSW, LADC herself

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with Rachel M Totten, MSW, LICSW, LADC or with the Office of Professional Regulation, Vermont Secretary of State. You will not be penalized for filing a complaint.

To file a direct complaint with Rachel M Totten, MSW, LICSW, LADC contact:

Rachel Totten, MSW, LICSW, LADC
PO Box 4473
Burlington VT  05406
802-448-0075
Rachel@RachelTotten.com

The Office of Professional Regulation can be contacted at:

Vermont Secretary of State Office of Professional Regulation
Attn: Carla Preston
89 Main Street, 3rd Floor Montpelier, Vermont 05620-3402
(802) 828-2875
carla.preston@sec.state.vt.us

All complaints must be submitted in writing. Complaint forms for the Vermont Secretary of State are available online at https://www.sec.state.vt.us/media/390288/complaint_form_2014_0605-for-web.pdf.

  • The right to obtain a paper copy of the notice upon request.

 

HIPAA and 42 CFR part 2 compliant

The effective date of this notice is 11/2/16.

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