1. Introduction

Court Counseling LLC ("Company," "we," "us," or "our") respects your privacy. This Privacy Policy explains what personal information we collect through www.courtcounseling.org (the "Site") and through our programs, courses, therapy sessions, and related services (the "Services"), how we use and disclose it, and the choices and rights available to you.

This Policy works alongside our Terms and Conditions. Where you receive clinical services, it also works alongside the informed consent and any notice of privacy practices you sign. Where a signed clinical consent conflicts with this Policy, the clinical consent governs the clinical relationship.

Because we serve clients in multiple countries, this Policy is written to address the broadest set of applicable laws, including the United States Health Insurance Portability and Accountability Act and state privacy law, Canadian federal and provincial privacy law, the European Union and United Kingdom General Data Protection Regulation, and the Australian Privacy Act 1988 and Australian Privacy Principles. Not every section applies to every user. Section 13 identifies the rights that apply based on where you live.

2. Who Is Responsible for Your Information

Court Counseling LLC is the controller of the personal information described in this Policy.

Privacy Officer

Jessica Echeverri, Chief Executive Officer

Court Counseling LLC

175 SW 7th Street, Miami, Florida 33130, United States

[email protected]

United States: 1 816 572 6878

Canada: 1 431 442 6878

3. Information We Collect

Information you give us

• Identity and contact details, including name, date of birth, mailing address, email address, and phone number.

• Account credentials and profile information.

• Referral information, including the referring court, agency, probation officer, attorney, case or docket number, and the terms of your order or directive.

• Program information, including enrollment selections, language preference, attendance, assignments, assessments, progress notes, and completion status.

• Health and clinical information, including intake and screening responses, presenting concerns, treatment notes, and correspondence with your clinician.

• Payment information, including billing name and address, and the last digits and expiry of your card. Full card numbers are collected and stored by our payment processor, not by us.

• Communications, including emails, messages, support requests, and call or session related notes.

• Information collected automatically

• Device and technical data, including IP address, browser type, operating system, device identifiers, and language settings.

• Usage data, including pages viewed, links clicked, referring URLs, session duration, and course progress.

• Cookies, pixels, and similar technologies as described in Section 7.

Information from other sources

• Courts, probation departments, child protection agencies, attorneys, and other referral sources where they contact us about your case or send a referral.

• Family members or third parties who pay for or arrange your Program on your behalf.

• Payment processors, scheduling platforms, and learning platforms we use to deliver the Services.

• Advertising and analytics providers, where permitted by law.

• Sensitive information. Health information, mental health information, and information about court involvement are sensitive. We collect them only where necessary to deliver the Services, and we handle them as described in Sections 8 and 9.

4. How We Use Your Information

We use personal information to:

• Create and administer your account and verify your identity.

• Enroll you in a Program, deliver Content, schedule and conduct sessions, and track attendance and progress.

• Provide clinical and therapeutic services where you have engaged them.

• Process payments, manage payment plans, and collect outstanding balances.

• Issue certificates of completion and progress reports, and report attendance, participation, and completion status to a court or referral source where required by your order or authorized by you in writing.

• Respond to your questions and provide support.

• Send transactional messages such as confirmations, receipts, reminders, and schedule changes.

• Send marketing communications where you have consented or where permitted by law.

• Operate, secure, troubleshoot, and improve the Site and the Services.

• Conduct internal quality assurance, clinical supervision, training, and program evaluation.

• Comply with legal, regulatory, professional, accreditation, and record keeping obligations.

• Establish, exercise, or defend legal claims, and prevent fraud or misuse.

Legal bases where European or United Kingdom law applies. We rely on performance of a contract for enrollment and service delivery, legal obligation for reporting and record keeping, legitimate interests for security, service improvement, and defending claims, and consent for marketing and for non essential cookies. Health data is processed on the basis of your explicit consent or for the provision of health care under Article 9.

5. Marketing Communications

Email. With your consent, or on the basis of an existing relationship where the law permits, we may send newsletters, program updates, and promotional offers. Every marketing email includes an unsubscribe link. Unsubscribing does not stop transactional messages about a Program you are enrolled in.

SMS and text messaging. Our SMS program is active. Where you opt in, we may send appointment reminders, program updates, and promotional texts to the number you provide, sent from 1 816 572 6878 in the United States and 1 431 442 6878 in Canada. Message and data rates may apply. Message frequency varies. Reply STOP to opt out and HELP for assistance. Consent to marketing texts is not a condition of purchase. We do not sell or share mobile numbers or SMS consent with third parties for their own marketing.

Canadian and Australian recipients. We send commercial electronic messages in accordance with Canada's Anti Spam Legislation and the Australian Spam Act 2003, including identification, consent, and unsubscribe requirements.

We do not use your health, clinical, or court referral information to target marketing to you.

6. When We Disclose Information

We do not sell your personal information for money. We disclose it only as follows:

• Service providers. These currently include Stripe for payment processing, HealthSync and GoHighLevel for client relationship management, scheduling, course delivery, and email and SMS messaging, together with cloud hosting, video conferencing, analytics, and professional advisers. These providers are bound by contract to protect your information and to use it only to provide services to us.

• Clinicians and facilitators. Contracted clinicians, group facilitators, translators, and clinical supervisors who need the information to deliver or supervise your Program.

• Courts and referral sources. Attendance, participation, progress, and completion information where your court order requires it or where you have signed a written authorization naming the recipient.

• Legally required disclosures. In response to a subpoena, warrant, court order, or other lawful request, and where reporting is mandated by law, including suspected abuse or neglect of a child, elder, or dependent adult, and a serious and imminent risk of harm to you or an identifiable person.

• Payers. Where a third party such as an employer, agency, family member, or insurer pays for your Program, we may confirm enrollment, attendance, and payment status. We do not disclose clinical content to a payer without your written authorization.

• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to continued protection of your information.

With your consent. Any other disclosure you direct in writing.

7. Cookies, Pixels, and Advertising

We use cookies and similar technologies, including:

• Strictly necessary cookies for login, security, and site functionality.

• Analytics tools such as Google Analytics to understand how the Site is used.

• Advertising pixels, including the Meta pixel, to measure the performance of our advertising and to show ads to people who have visited our Site or who resemble our audience.

Under some United States state privacy laws, the use of advertising pixels is treated as "sharing" or as "targeted advertising," and you have the right to opt out. See Section 13.

We configure our advertising and analytics tools to run on public and informational pages. We take steps to avoid transmitting health information, clinical intake responses, court referral details, or program specific enrollment data to advertising platforms, and we do not build advertising audiences from clinical information.

Your choices. You can control cookies through your browser settings and through the opt out tools offered by advertising and analytics providers. You may also opt out of targeted advertising by contacting us at [email protected]. We honor Global Privacy Control signals where required by law. Blocking some cookies may affect Site functionality.

8. Health Information

The Company provides mental health services and treats the clinical information it holds as protected health information under the United States Health Insurance Portability and Accountability Act. We handle that information in accordance with HIPAA and the HITECH Act, and in accordance with our Notice of Privacy Practices, which is provided to you separately at intake. Our vendors who handle protected health information do so under business associate agreements.

Where services are delivered in Canada, personal health information is handled in accordance with the Personal Information Protection and Electronic Documents Act and applicable provincial legislation, including Ontario's Personal Health Information Protection Act and equivalent statutes in other provinces.

Where services are delivered to clients in Australia, personal and health information is handled in accordance with the Privacy Act 1988 and the Australian Privacy Principles, including the Notifiable Data Breaches scheme.

In all cases, clinical confidentiality is subject to the legal limits described in Section 6 and in your clinical consent.

9. Records Related to Court Ordered Programs

If you were referred by a court or agency, assume that your enrollment, attendance, participation, and completion status are reportable to that referral source. This reporting is a condition of participation in a court related Program and may occur without a separate authorization where your order requires it.

10. International Transfers

We operate across borders. Our records are hosted in the United States, and our leadership, administrative staff, and contracted clinicians may access information from the United States, Canada, and Colombia. Your information may be stored and processed in a country other than your own, including countries whose privacy laws differ from those in your jurisdiction, and may be accessible to courts and law enforcement in those countries under local law.

Where required, we use appropriate safeguards for these transfers, including the European Commission's Standard Contractual Clauses, the United Kingdom International Data Transfer Addendum, contractual protections consistent with Australian Privacy Principle 8, and business associate agreements where protected health information is involved.

11. How Long We Keep Information

• Clinical and program records: seven years after the closure of your file, or longer where a professional regulator, statute, or jurisdiction requires a longer period.

• Records for clients who were minors: seven years after the client reaches the age of majority in the relevant jurisdiction.

• Financial and transaction records: as required by tax and corporate law, generally seven years.

• Account and Site usage data: for as long as your account is active, plus a reasonable period afterward.

• Marketing contact data: until you unsubscribe or withdraw consent, plus a short suppression period so we can honor your opt out.

When a retention period ends, we securely delete, destroy, or anonymize the information.

12. Security

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encryption in transit, access controls and role based permissions, staff and contractor confidentiality agreements, vendor due diligence, and secure disposal.

No method of transmission or storage is completely secure. Email and text message are not fully confidential channels, and you should avoid sending sensitive clinical details through them. If we become aware of a breach affecting your personal information, we will notify you and the applicable regulators as required by law.

13. Your Privacy Rights

If you live in the United States

Depending on your state, you may have the right to know what personal information we collect and how we use and disclose it, to access a copy, to correct inaccuracies, to request deletion, to opt out of targeted advertising, of the sale or sharing of personal information, and of certain profiling, to limit the use of sensitive personal information, and to appeal a denied request. We will not discriminate against you for exercising these rights.

California residents may also designate an authorized agent and may request the categories of information disclosed in the preceding twelve months. Personal information governed by HIPAA or by the California Confidentiality of Medical Information Act is exempt from certain of these rights.

If you live in Canada

You may request access to the personal information we hold about you, request correction of inaccuracies, and withdraw consent where consent is the basis for processing, subject to legal and contractual limits. Access to clinical records may be limited where disclosure would create a risk of harm or would reveal information about a third party. You may complain to the Office of the Privacy Commissioner of Canada or to your provincial commissioner.

If you live in Australia

You may request access to the personal information we hold about you and ask us to correct it. We will respond within a reasonable period, generally thirty days. We will tell you if we refuse access or correction and explain why. You may complain to us first, and then to the Office of the Australian Information Commissioner if you are not satisfied with our response.

If you live in the European Economic Area or the United Kingdom

You have the right of access, rectification, erasure, restriction, portability, and objection, and the right to withdraw consent at any time without affecting processing already carried out. You may lodge a complaint with your local supervisory authority.

How to exercise your rights. Contact us at [email protected]. We will verify your identity before responding, which may require additional information. We respond within the timeframe required by the applicable law, generally thirty to forty five days, and will tell you if we need an extension. Some rights are limited where we must retain records to comply with a court order, a professional obligation, or a legal claim.

14. Children's Privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from them online. Where a Program serves minors, enrollment is completed by a parent or legal guardian who provides consent. If you believe a child has provided information to us without appropriate consent, contact [email protected] and we will address it.

15. Third Party Sites and Platforms

The Site may link to or rely on third party services. We are not responsible for the privacy practices of those services. Review their privacy policies before providing information to them.

16. Video Sessions

Virtual sessions are delivered through a third party video conferencing platform. We do not record sessions unless you have given prior written consent, or where recording is required for a specific supervisory or legal purpose that has been disclosed to you. Participants are prohibited from recording sessions. Please attend from a private location where you cannot be overheard.

17. Changes to This Policy

We may update this Policy from time to time. We will post the revised version with a new Effective Date and, where changes are material, notify you by email or by notice on the Site. Continued use of the Services after the change takes effect constitutes acceptance.

18. Contact and Complaints

Questions, requests, and complaints can be directed to:

Court Counseling LLC

Attention: Jessica Echeverri, Chief Executive Officer, Privacy Officer

175 SW 7th Street, Miami, Florida 33130, United States

[email protected]

United States: 1 816 572 6878

Canada: 1 431 442 6878

https://courtcounseling.org/

If you are not satisfied with our response, you may contact the United States Department of Health and Human Services Office for Civil Rights, your state attorney general, the Office of the Privacy Commissioner of Canada or your provincial commissioner, the Office of the Australian Information Commissioner, or your local data protection supervisory authority.