1. Health Information and Our Notice of Privacy Practices (HIPAA)

As a health care provider, GentleCare Therapy is subject to the Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations (“HIPAA”). Health information that identifies a client and relates to the client’s care or payment for care (“Protected Health Information” or “PHI”) is governed by our Notice of Privacy Practices (“NPP”), which is provided to clients at intake and is available on request from our Privacy Officer, which describes how we may use and disclose PHI and explains your rights regarding that information.

This Privacy Policy is not our Notice of Privacy Practices and does not replace it. If there is a conflict between this Privacy Policy and our NPP regarding PHI, the NPP controls. You may request a copy of our NPP at any time from our Privacy Officer, Torrie Martin, COO, at info@gentlecaretherapy.com or (856) 484-5535, or by asking at our office at 88 Lakeview Drive S, Gibbsboro, NJ 08026.

Please do not send PHI through general website forms, email, social media, or text messages. Our general “Contact Us” form, job applications, and website email links are not intended for detailed medical, diagnostic, or treatment information. Please limit messages to your name, contact information, and a brief description of how we can help, and our Care Coordination team will follow up through appropriate channels.

Client Intake Form. To begin the intake process, our Website offers a Client Intake Form hosted by our form provider, which may ask for the inquiring individual’s contact information, the child’s name, date of birth, and address, service preferences, and images of the front and back of an insurance card. We use this form only to begin intake, verify benefits, and coordinate services. Information submitted through the Client Intake Form is handled as PHI in accordance with HIPAA and our NPP. Our form provider, Jotform, processes this information under a HIPAA Business Associate Agreement with us. Please share only the information the form requests.

2. Information We Collect

Information you provide to us

• Contact and inquiry information – such as your name, phone number, email address, and your message when you use our “Contact Us” form, email us at info@gentlecaretherapy.com, or call us.
• Intake information – such as the inquiring individual’s name and relationship to the child, the child’s name, date of birth, and address, preferred service setting (center, home, school, or social skills services), preferred times, best times to contact you, insurance card images, the services you are seeking, how you heard about us, and any additional information you choose to provide (see Section 1).
• Scheduling information – such as your name, contact details, and the date and time you select when you schedule a phone consultation through our online booking tool.
• Job application information – such as your name, email address, phone number, position of interest, current employment status, languages spoken, how you heard about us, and your résumé or other uploaded documents (see Section 7).
• Communications – records of your emails, calls, text messages, and other correspondence with us.

Information collected automatically

When you visit the Website, we and our service providers may automatically collect certain information, such as your IP address, browser type, device type and identifiers, operating system, referring and exit pages, pages viewed, links clicked, date and time of visits, general (non-precise) location derived from IP address, and similar usage information. See Section 5.

Information from other sources

We may receive information about you from insurance carriers (for example, benefits verification), referring physicians or providers, Early Intervention programs, job boards or recruiting platforms, and social media platforms when you interact with our pages. Information we receive about clients in connection with treatment or payment is handled under HIPAA and our NPP.

3. How We Use Information

We use the information we collect to:

• respond to your inquiries and requests and connect you with our Care Coordination team;
• begin the intake process, verify insurance benefits, and schedule assessments, consultations, and services;
• provide and coordinate our services (subject to HIPAA and our NPP);
• send you information about our services, events such as our free “Navigating Autism” parent workshops, and other updates, consistent with your preferences and applicable law;
• evaluate job applicants and manage recruiting;
• operate, maintain, secure, and improve the Website, including understanding how visitors use it;
• measure the effectiveness of our outreach and advertising, where permitted by law (we do not use PHI for advertising without your written authorization as required by HIPAA);
• detect, prevent, and respond to fraud, spam, security incidents, and other harmful activity; and
• comply with legal, regulatory, licensing, and insurance obligations, and enforce our Terms & Conditions.

4. How We Share Information

We do not sell your personal information, and we do not sell or rent PHI. We may share information as follows:

• Service providers. With vendors who perform services on our behalf, such as website hosting and site statistics (our Website runs on the WordPress.com/Jetpack platform), online forms (Jotform and our website form plugin), online scheduling (our booking widget provider), tag management and analytics (Google Tag Manager and Google Analytics), email and communications providers, IT and security providers, and insurance and billing partners. Service providers that handle PHI are required to protect it as required by HIPAA.
• Insurance carriers and health care partners. As needed to verify benefits, obtain authorizations, coordinate care, and receive payment, as described in our NPP.
• Analytics and advertising partners. Through cookies and similar technologies, as described in Section 5. You can opt out as described there.
• Legal and safety. When we believe disclosure is required by law, subpoena, or court order, or is necessary to protect the rights, property, or safety of GentleCare, our clients, staff, or others, including mandatory reporting obligations.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, subject to applicable law, including HIPAA.
• With your consent. When you direct or authorize us to share information.

5. Cookies, Analytics, and Tracking Technologies

We and our service providers use cookies, pixels, tags, scripts, and similar technologies to operate the Website, remember preferences, understand how visitors use the Website, and measure our outreach. These currently include or may include:

• Essential technologies needed to deliver the Website, prevent spam (for example, CAPTCHA on our forms), and keep it secure;
• Google Tag Manager and Google Analytics, which we use to manage analytics and marketing tags and to understand how visitors use the Website;
• Jetpack/WordPress.com statistics, which provide aggregate site usage statistics;
• Meta (Facebook) Pixel, if used, to measure and improve the effectiveness of our outreach on Meta platforms;
• Other analytics and advertising partners that help us understand Website traffic and measure our outreach; and
• Embedded third-party tools, such as our Jotform forms and online booking widget, which may set their own cookies.

We do not intend for tracking technologies to collect PHI, and we configure our forms and pages to avoid sharing PHI with analytics or advertising vendors that have not agreed to protect it as required by HIPAA.

Your choices. Most browsers let you block or delete cookies; blocking some cookies may affect Website functionality. You can learn about Meta’s practices and ad settings at facebook.com/privacy/policies/cookies and about Google’s practices at policies.google.com/technologies/partner-sites and opt out of Google Analytics using the Google Analytics Opt-out Browser Add-on. You may also opt out of interest-based advertising from participating companies at optout.aboutads.info and optout.networkadvertising.org. Global Privacy Control: we treat a Global Privacy Control (GPC) or similar universal opt-out signal sent by your browser as a request to opt out of targeted advertising and any “sale” of personal data for that browser, as required by applicable law. Our Website does not otherwise respond to “Do Not Track” signals.

6. Email, Phone, and Text Message Communications

Email (CAN-SPAM)

If you receive promotional or newsletter emails from us, each will identify GentleCare Therapy as the sender, include our physical address, and include a way to unsubscribe. You may opt out at any time by using the unsubscribe link or emailing info@gentlecaretherapy.com, and we will honor your request within ten (10) business days. Even if you opt out of marketing emails, we may still send transactional or relationship messages, such as appointment, intake, scheduling, or billing communications.

Phone calls and text messages (TCPA)

GentleCare Therapy sends text messages to clients, families, and job applicants. By providing your phone number on a form on our Website or otherwise to us, and where you expressly agree, you consent to receive calls and text messages from or on behalf of GentleCare Therapy at that number, including calls and messages sent using automated technology or prerecorded or artificial voice, about your inquiry, intake, scheduling, appointment reminders, services, and job applications, and — only where you have given separate prior express written consent — promotional messages. Consent to receive calls or text messages is not a condition of receiving services or of employment.

Message frequency varies. Message and data rates may apply. Reply STOP to opt out of text messages at any time; you may receive one final message confirming your opt-out. Reply HELP for help, or contact us at (856) 484-5535 or info@gentlecaretherapy.com. You may also revoke consent to calls by any reasonable means, including telling us during a call. Wireless carriers are not liable for delayed or undelivered messages. Mobile phone numbers and text-messaging opt-in consent are not shared with third parties or affiliates for their own marketing purposes. Because standard text messages are not encrypted, please do not text PHI to us.

7. Job Applicants

If you apply for a position through our “Join Our Team” page, our Early Intervention application, or otherwise, we collect the information you submit (such as name, contact details, position of interest, employment status, languages spoken, how you heard about us, and your résumé) and information from references, background checks, licensure and certification verifications, and clearances where permitted by law and with any required notice or authorization. We use this information to evaluate your application, communicate with you, verify qualifications and credentials, comply with legal and payer requirements, and, if you are hired, for employment purposes. Applications are submitted through our form providers (including Jotform and our website form plugin) and may be shared with our recruiting and HR service providers. GentleCare Therapy is an equal opportunity employer. We do not discriminate in hiring or employment on the basis of race, creed, color, religion, national origin, ancestry, nationality, sex, pregnancy, sexual orientation, gender identity or expression, age, marital or domestic partnership or civil union status, disability, genetic information, military or veteran status, or any other characteristic protected by federal, New Jersey, or Pennsylvania law. Please do not include Social Security numbers, health information, or other sensitive information in your résumé or application unless specifically requested.

8. Children’s Privacy (COPPA)

Although our services are provided to children, the Website is intended for use by parents, guardians, caregivers, referring professionals, and job applicants who are adults. The Website is not directed to children under 13, and we do not knowingly collect personal information online directly from children under 13. Information about a child that a parent or guardian provides to us (for example, through the Client Intake Form) is provided by the adult on the child’s behalf and is handled as described in Section 1 and our NPP. If you believe a child under 13 has provided personal information to us through the Website, please contact us at info@gentlecaretherapy.com and we will delete it as required by the Children’s Online Privacy Protection Act (“COPPA”). We do not sell the personal data of, or process for targeted advertising the personal data of, individuals we know to be under 17 years of age.

9. Data Retention

We keep personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide services, comply with legal, licensing, insurance, and record-keeping obligations, resolve disputes, and enforce our agreements. Client records containing PHI are retained in accordance with HIPAA and the record-retention requirements of New Jersey, Pennsylvania, and applicable payers. Our general retention periods are:

• Client clinical and billing records: ten (10) years, or longer where required by law or payer contracts (for example, for records of a minor, until the client reaches the age of majority plus any additional period required by applicable law);
• General inquiries that do not result in services: up to two (2) years;
• Job applications for candidates not hired: three (3) years; and
• Website analytics data: fourteen (14) months.

When information is no longer needed, we delete, de-identify, or securely destroy it.

10. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, and we maintain safeguards for PHI as required by the HIPAA Security Rule, such as encrypted (HTTPS) connections, access controls, and HIPAA-capable form technology for intake. No method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee absolute security. If we learn of a security breach affecting your information, we will notify you and regulators as required by HIPAA, the New Jersey Identity Theft Prevention Act (N.J.S.A. 56:8-161 et seq.), and other applicable law.

11. Your Privacy Rights – New Jersey Residents

To the extent the New Jersey Data Privacy Act (N.J.S.A. 56:8-166.4 et seq.) (“NJDPA”) applies to our processing of your personal data, New Jersey residents have the right to:

• Access – confirm whether we process your personal data and access it;
• Correct – correct inaccuracies in your personal data;
• Delete – delete personal data concerning you;
• Portability – obtain a copy of your personal data in a portable and, to the extent feasible, readily usable format;
• Opt out – opt out of processing of your personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects; and
• Withdraw consent – withdraw consent previously given for processing of sensitive data (such as health information or data of a known child).

We will not process sensitive data, including personal data of a known child, without consent where consent is required by the NJDPA (for a known child, consent of the parent or guardian, consistent with COPPA). PHI governed by HIPAA is exempt from the NJDPA and is instead covered by our NPP, which describes your HIPAA rights to access, amend, and receive an accounting of disclosures of your PHI.

How to submit a request. Email info@gentlecaretherapy.com with the subject line “Privacy Request,” or call (856) 484-5535. Requests may be directed to our Privacy Officer, Torrie Martin, COO. We will verify your identity before responding and will respond within 45 days, which may be extended by an additional 45 days when reasonably necessary, with notice. You may use an authorized agent, subject to verification. We will not discriminate against you for exercising your rights.

Appeals. If we decline to take action on your request, you may appeal by emailing info@gentlecaretherapy.com with the subject line “Privacy Request Appeal” within a reasonable time after our decision. We will respond to your appeal within the time required by law. If you are not satisfied with the outcome, you may contact the New Jersey Division of Consumer Affairs / Office of the Attorney General.

12. Other State Privacy Rights (Including California)

Residents of certain other states, including Pennsylvania and California, may have similar rights under applicable law. If you are a California resident, and to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), applies to us, you may have the right to know the categories and specific pieces of personal information we collect, use, and disclose; to request deletion or correction; to opt out of the “sale” or “sharing” of personal information for cross-context behavioral advertising; to limit the use of sensitive personal information; and to be free from discrimination for exercising these rights. The categories of personal information we collect, their sources, our purposes, and the categories of recipients are described in Sections 2 through 5. We do not sell personal information, and we do not knowingly sell or share the personal information of consumers under 16. Medical information and PHI governed by HIPAA or the California Confidentiality of Medical Information Act are exempt from the CCPA. To exercise any applicable rights, contact us as described in Section 17.

13. Your Choices

• Marketing emails: use the unsubscribe link or email us.
• Text messages: reply STOP.
• Cookies and analytics: adjust browser settings, use the opt-out tools in Section 5, or enable Global Privacy Control.
• Your information: contact us to access, correct, or delete your information as described above.

14. Third-Party Websites and Services

The Website contains links to and embedded content from third parties, including our social media pages (Facebook, Instagram, LinkedIn, TikTok, YouTube, and X/Twitter), Jotform, our online booking provider, and external resources such as government Early Intervention programs and autism organizations. We are not responsible for the privacy practices of those third parties, and their collection and use of your information is governed by their own privacy policies. Please do not post PHI on social media, including in comments or messages to our pages.

15. Accessibility

We are committed to making this Privacy Policy and our Website accessible to individuals with disabilities. If you need this Privacy Policy in an alternative format, or have difficulty accessing any part of the Website, please contact us at (856) 484-5535 or info@gentlecaretherapy.com. See the Accessibility Statement in our Terms & Conditions.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and revise the “Last Updated” date above. If we make material changes, we will provide additional notice as required by law, such as a notice on the Website. Your continued use of the Website after an update is posted means the updated Privacy Policy applies to information collected after that date.

17. Contact Us

If you have questions about this Privacy Policy or our privacy practices, or wish to exercise your rights, please contact:

For questions or complaints about how we handle PHI, please refer to our Notice of Privacy Practices, which is provided at intake and is available on request from our Privacy Officer. You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights. We will not retaliate against you for filing a complaint.