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Emotional Health: Privacy Policy 1.1. Emotional Health (“us”, “we”, or “our”) is committed to safeguarding the privacy of our clients, staff and visitors of Emotional Health, as well as those who visit our website. 1.2. Emotional Health is bound by the Privacy Act 2020 and other laws governing how health service providers handle your Personal Information and Sensitive Information (including information about your health). 1.3. This Privacy Policy (Policy) describes how we collect and treat your Personal and Sensitive Information. The Policy applies to our website, www.emotionalhealth.co.nz, which we operate, and the products and services we provide. 2. Definitions In this policy: 2.1. Personal information” is categorised as information held by Emotional Health that may identify you, or by which your identity might be reasonably determined. The information you provide us may include, amongst other things, your name, address, email address and phone number. It does not include “Sensitive information” 2.2. “Sensitive information” means any information about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliation, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information. Therapeutic record keeping, though, which usually includes Sensitive Information is included elsewhere in the Terms and Conditions and is limited to the therapeutic contract between the therapist and client. 3. Collection of Your Data 3.1. To provide our services to you, Emotional Health may receive and store Personal Information and Sensitive Information (together, ‘your Data’), that you enter onto our website, provide to us directly or give to us in other forms. 3.2. Your Data may include your: 3.2.1. Contact details including name, phone number, address and email address; 3.2.2. Payment and billing information, which we may use to bill you for our services and to process your payments (including credit card details); 3.2.3. Health information (both physical and mental health) including information relating to injuries past or present, or whether you are pregnant; 3.2.4. Personal history and family history; and 3.2.5. Other information voluntarily provided by you. Your Data is collected to ensure your safety and wellbeing, and that of other participants and facilitators at Emotional Health, to send information, provide updates and process purchases of services and products provided by Emotional Health. 3.3. Sensitive Information, which includes the definition of your Data relating to your health, will not be collected unless you consent to the collection of that information. 3.4. Emotional Health collects your Data from you in a variety of ways, including but not limited to in-person, via a website or online platform, social media and when a service is provided. For example, a client’s personal information is collected in several ways during psychological consultation with Dr Carien Lubbe, including when the client provides information directly using hardcopy forms or electronic forms, or correspondence via email, and when other health practitioners provide personal information to Dr Carien Lubbe, via referrals, correspondence and medical reports. 3.5. We may collect additional personal Data at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your contact or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with us in any other way. 3.6. We may receive your Data from third parties. Those third parties may include your medical practitioners, hospitals, clinics, lawyers and/or family members. If we do, we will protect and use this information as set out in this Policy. 4. Use of Your Data 4.1. Personal Information collected by us will only be used and disclosed for the purpose for which it was collected as set out below. This includes maintaining your account and contact details, providing you with our products and services, and processing payments. 4.2. Emotional Health may use Personal Information collected from you to provide you with information and updates on our services, additional products, or opportunities available to you. 4.3. We may use your Personal Information to improve our products and services and better understand your needs. [Consider how your business may contact those bound by the privacy policy] 4.4. We may from time to time use your Personal Information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act. This includes to effect or enforce a transaction, or procure advice from legal and accounting firms, auditors and other consultants. 4.5. Sensitive information will remain confidential except when: 4.5.1. It is subpoenaed by a court; or 4.5.2. Failure to disclose the information would in the reasonable belief of Dr Carien Lubbe place a client or another person at serious risk to life, health or safety; or 4.5.3. The client’s prior approval has been obtained to: a) provide a written report to another professional or agency, e.g., a GP; or b) discuss the material with another person, e.g. a parent, employer or health provider; or c) disclose the information in another way; or 4.5.4. You would reasonably expect your personal information to be disclosed to another professional or agency (e.g. your GP) and disclosure of your personal information to that third party is for a purpose which is directly related to the primary purpose for which your personal information was collected; or 4.5.5. Disclosure is otherwise required or authorised by law. A client’s personal information is not disclosed to overseas recipients, unless the client consents or such disclosure is otherwise required by law. Clients’ personal information will not be used, sold, rented or disclosed for any other purpose. 5. Disclosure of Your Data 5.1. Emotional Health may disclose your Personal Information (but not Sensitive Information) to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. 5.2. Personal Information is only supplied to a third party when it is required for the delivery of our services. 5.3. We may from time to time need to disclose Your Data to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request. 5.4. We may use Your Data to protect the copyright, trademarks, legal rights, property or safety of Emotional Health, www.abccoaching.example.com, its clients or third parties. 5.5. We may also use and share aggregate or non-personally identifying information about clients for market analysis, research, marketing or other purposes. 5.6. We will not disclose, sell, share or trade your Personal Information to any third parties unless we first receive your consent, except as set out in this Policy. 5.7. We may provide health information (Sensitive Information) to relevant organisations when an external health funder requires this (e.g. ACC) 5.8. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of New Zealand. 5.9. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer, to the extent permissible at law, our user databases together with any Personal Information, Sensitive Information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances. 5.10. By providing us with your Data, you consent to the terms of this privacy policy and the types of disclosure covered by this policy. Where we disclose your Personal Information to third parties, we will request that the third party follow this policy regarding handling your personal information. 6. Security of Your Data 6.1. Emotional Health is committed to ensuring that your Data is secure. Client files are held in a secure electronic document management system which is accessible only to the clinician. The information on each file includes personal information such as name, address, contact phone numbers, medical history, and other personal information collected as part of providing the psychological service. 6.2. Emotional Health will take reasonable steps to protect your Data from misuse, loss, unauthorised access and modification or disclosure. 6.3. Despite taking appropriate measures to protect your Data used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. The transmission and exchange of information is carried out at your own risk. 6.4. We cannot guarantee the security of your Data that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of your Data, we cannot assure you that your Data we collect will not be disclosed in a manner that is inconsistent with this privacy policy. 6.5. You are solely responsible for maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services. 7. Access to and correction of your Information 7.1. At any stage clients may request to see and correct their personal information kept on file. The psychologist may discuss the contents with them and/or give them a copy, subject to the exceptions in the Privacy Act. If satisfied that personal information is inaccurate, out of date or incomplete, reasonable steps will be taken in the circumstances to ensure that this information is corrected. All requests by clients for access to or correction of personal information held about them should be lodged in writing to Dr Carien Lubbe. These requests will be responded to in writing within 30 days, and an appointment will be made if necessary for clarification purposes. 7.2. A small administrative fee may be payable for the provision of your Data. If you would like a copy of your Data which we hold about you or believe that any of your Data we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us. 8. Website 8.1. When you visit the website of Emotional Health, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. 8.2. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service. 9. Marketing Emails 9.1. We may send you direct marketing emails and information about products and services that we consider may be of interest to you. 9.2. If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email. Please note that it may take a few business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you emails about your account, any services you have requested or received from us, or for other customer service purposes. We do not provide your personal information to other organisations for the purposes of direct marketing. 9.3. If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below. 10. Concerns about privacy 10.1. Consequence of not providing personal information If the client does not wish for their personal information to be collected in a way anticipated by this Privacy Policy, Dr Carien Lubbe may not be in a position to provide the psychological service to the client. 10.2 Clients may request to be anonymous or to use a pseudonym, unless it is impracticable for Dr Carien Lubbe to deal with the client. 10.3 If you have any complaints about our privacy practices, please feel free to send in details of your complaints to: info@emotionalhealth.co.nz. We take complaints very seriously and will respond shortly after receiving written notice of your complaint. 10.4. Please don’t hesitate to speak with Dr Carien Lubbe should you have any further questions. 11. Changes to privacy policy 11.1. Our Privacy Policy is subject to change. 11.2. Emotional Health may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website, or through distribution by email. Please check back from time to time to review our privacy policy.

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