Privacy Policy

Our Commitment to Online Privacy

At Gramercy Specialty Clinic PLLC, doing business as Gramercy Counseling (“Gramercy”, “us,” “we,” or “our”), we care about our users’ online privacy (“you,” “your,” or the “user”). We have this Privacy Policy (the “Policy”) to ensure that you understand what we are doing with your Personal Information (as defined below) and to remind you that you have rights when it comes to controlling what is shared online.

Please note that this Policy is subject to our Terms of Use Agreement (the “ToU”). There are terms in the ToU that materially affect your right to bring a lawsuit against Gramercy and other rights regarding this Policy. As such, you should read the ToU in addition to this Policy.

Acceptance of Policy

We know these privacy policies can be tedious to get through. However, by continuing to use our Online Services, you agree to let us use your information in the ways discussed in this Policy. For this reason, it would greatly benefit you to read this entire Policy.

Changes Made to This Policy

We may modify this Policy from time to time. The date at the top of this Policy lets you know when this Policy was last revised. It is important to check back here occasionally to make sure you have read the latest policy. By continuing to access or use our Online Services after the policy changes, you allow us to use your Personal Information in the way we describe in our updated policy.

Online Services This Policy Covers

Gramercy provides counseling and mental health services in English and Spanish using telehealth tools (the “Counseling Services”). To help us provide our Counseling Services, we offer a website platform (the “Site”), and an online portal (the “Portal”), where clients can make a profile, book and pay for sessions, meet with their therapist, and supplement their counseling journey with recommended reading and interactive tools. This Policy applies to our online services, including our Site, the Portal, our social media pages, and any future online services we develop (collectively the “Online Services”). Additionally, our Portal and all payments made through the Portal are hosted by a third-party service; as such, when using the Portal, you are subject to that third-party service’s policies in addition to ours.

Services This Policy Doesn’t Cover

We may link to third-party websites and services to provide you with supplemental reading and other resources that we think you may find helpful and informative. When you click on one of these links, you are leaving Gramercy, and this Policy no longer applies. The way third parties do business is out of our hands, and we assume no responsibility for the content, privacy policies, or practices of any third-party website or service. Please note that when you are using any other third-party platform to interact with our Online Services such as Google, Instagram, Facebook, and other applicable third-party services and platforms, you agree to their policies, and this Policy is in addition not in place of such agreements.

Likewise, this Policy does not apply to our privacy commitments and practices during the course of rendering Counseling Services, including our practices and your rights with regard to Protected Health Information. This Policy applies only to your use of our Site and Portal and the privacy practices relevant to those Online Services. If you decide to utilize our services and if you should meet criteria for our services for your mental health journey, we will provide you with a Therapy Service Agreement and Privacy Notice (the “Service Agreement”) for you to review and agree to. Our Service Agreement contains important information about our Counseling Services, your PHI, and your rights. This Policy is provided to you in addition to our Service Agreement and does not cover our handling of PHI.

What is Personal Information?

“Personal Information” is any information that may allow for an individual to be personally identified. For example, your name, email address, social security number, phone number, residential address, and credit card details are all considered Personal Information. Other information, such as your interests, economic status, customer number, IP address, geolocation, education, and job title, may also be considered Personal Information if that information, when combined with other information, is used to reveal your identity.

Personal Information that Gramercy Collects

We only collect Personal Information from you when you voluntarily agree to us collecting and using it. You voluntarily agree to us collecting and using your Personal Information by:

  • Directly providing the Personal Information to us: In some circumstances, when interacting with our Online Services, you may be asked to provide specific information so that we can help you with a particular inquiry, or you may give information to us on your own accord, such information may include Personal Information (e.g., your name, email address, phone number, residential address). For example, you consent for us to use the Personal Information you have provided when you create an account for our Portal, reach out to us by email or through our social media accounts, when you use any “contact us” form on our Online Services, when you interact with our support or customer service teams, and when you interact or comment on our social media pages. When providing Personal Information, you permit us to use such information to fulfill your requests and for our legitimate business purposes. The information that you provide when you create your user account and when you arrange for payment for your sessions, such as your credit card information, insurance information, and email address, is not made available to the public. You should also be aware that your comments on our social media pages are accessible to the public.
  • Interacting with our services: You also permit us to collect other information such as your IP address, browser type, general geolocation, device type, usage information, click activity on links, frequency of visits to our Site and Portal, and network connection type while you use our Site and Portal. We also may receive some interest-based information about you (e.g., your age, gender, general location, and likes) when you interact with our social media pages (if you have agreed for third-party platforms to collect such information about you). We only receive and share this type of information in anonymized and aggregated forms; this means you are not personally identifiable to us unless the information is publicly available by another means (e.g., social media engagement data and public social media profiles).

However, you should be aware that, in some circumstances, we may be legally required to hand over aggregate data information to law enforcement or regulatory authorities, who may then use this information to reveal your identity. We may use cookies and third-party services, such as Google Analytics, Facebook, and other related services to help us collect and analyze this information.

  • Protected Health Information (PHI): In the course of rendering our Counseling Services, we may collect certain Protected Health Information (“PHI”). PHI is identified under the Health Insurance Portability and Accountability Act (“HIPPA”) and Texas Medical Records and Privacy Act (“TMRPA”) as including all individually identifiable health information, including demographic data, that relates to (a) the individual’s past, present, or future physical or mental health condition; (b) the provision of health care to the individual; or (c) the past, present, or future payment for the provision of health care to the individual. For more information on what PHI we collect, how we protect your PHI, and when we may disclose your PHI in compliance with state and federal laws, please refer to the Service Agreement that we provided to you when you joined us as a client.

What About My Credit Card Information?

All payments made through the Portal are processed by a PCI-compliant payment processor to process credit card transactions. This means we never personally see your credit card information when you use our Online Services or pay for Counseling Services unless there is a technical error resulting in us needing to manually enter your payment details with your express permission.

What About My Passwords?

To access our Portal, you must create an account and password. Your password is fully encrypted, and we never get access to this information. If you forget your password, simply use the “forgot my password” link to reset it. There may also be times when a password is required to access other certain accounts, such as when you are interacting via our social media platforms. The third-party platform completely administers these passwords, and we do not have access to such passwords.

PLEASE NOTE THAT CREATING AN ACCOUNT ON OUR PORTAL DOES NOT CREATE A THERAPIST-CLIENT RELATIONSHIP BETWEEN YOU AND GRAMERCY OR ANY OF OUR PROVIDERS. TO CREATE SUCH A RELATIONSHIP, YOU MUST FIRST QUALITY FOR SERVICES, READ AND SIGN OUR SERVICE AGREEMENT, AND BOOK AN APPOINTMENT WITH ONE OF THE THERAPISTS ON OUR SITE.

Cookie Policy

Cookies are small files that we transfer to your computer’s hard drive through your browser when using and interacting with our Online Services.

  • Types of cookies we use: We use both session cookies that are erased once you exit your browser and persistent cookies that stay on your device for a set period of time or until you manually delete them.
  • Why does Gramercy use cookies? We mainly use cookies to help ensure you have the best user experience possible. However, as mentioned above, we also use cookies to provide us with insight into things like the number of visitors to our Site and Portal, the type of devices being used to access our Site and Portal, how visitors ended up on our Site and Portal, and the general geographic area they are located (again, this information is aggregated and anonymized). As you have probably heard, cookies may also be used to ensure that you see advertisements relevant to your interests. Out of respect for your privacy and the confidential nature of our Counseling Services, we do not use targeted advertising on our Site or Portal or sell any advertising space on our Site or Portal for third-party use. Likewise, we do not use targeted advertising through YouTube, Google, Instagram, Facebook, and other third-party websites. We will never use PHI or any information disclosed in connection with your treatment as part of our Counseling Services in connection with any advertising.
  • Can I block cookies? Most browsers have an option to stop your computer from accepting cookies altogether, as well as an option to stop only certain types of If you decide to block cookies, our Online Services may operate a little strangely, as we rely on some cookies for our Online Services’ functionality. Again, we do not sell space for or use targeted advertising. However, if you are concerned about targeted advertising in general or on other websites, you can choose to specifically opt-out of targeted advertising by going the following links:

Facebook – https://www.facebook.com/settings/?tab=ads
Google – https://adssettings.google.com
Digital Advertising Alliance – http://optout.aboutads.info/
You can learn more about cookies at www.allaboutcookies.org.

Reasons Gramercy Collects Personal Information

We do not collect your Personal Information for the purpose of selling, renting, trading, or otherwise abusing it. Please note that PHI will only be collected, stored, and shared in compliance with state and federal law, as stated in our Service Agreement. We only use your Personal Information for our legitimate business purposes, including, but not limited to, the following reasons:

  • To personalize our online features and content;
  • To fulfill or enforce a contract that you have entered into with us;
  • To help you efficiently access your information;
  • To allow for affiliated third parties, including our therapists, your insurance provider, and payment processors, as needed, to provide additional services to you;
  • To improve, monitor, and test our Online Services and new products or features;
  • To prevent, investigate and address the misuse of our Online Services;
  • To learn about the types of people that are using our Online Services and how we can better market to and enhance services for those people;
  • To allow you to contact us;
  • To allow you to participate in social sharing;
  • To allow you to access and participate in our Online Services;
  • To respond to your inquiries and fulfill your requests;
  • To comply with law enforcement and other regulatory authorities; and
  • To communicate with you about our Online Services and

Sharing of Personal Information with Third Parties

Although we try to limit who we share your Personal Information with, there are situations where sharing is necessary for our legitimate business purposes. We may share your Personal Information with third parties in the following ways:

  • Insurance Companies and Third-Party Payers: We may use and disclose your information so that the treatment and services you receive may be billed and payment may be collected from appropriate payers, such as an insurance company or a third-party payer. All such information will be used and disclosed in accordance with our Service Agreement.
  • Agents: Sometimes, we may need to use other trusted companies and individuals to help us provide our Online Services. Whenever a company or individual is working for us, they are acting as our agent. Sometimes our agents may need to access your Personal Information for a particular task, but they do not have the right to use your Personal Information beyond what is necessary and must comply with our privacy
  • New Owners: If we are involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your Personal Information may be sold or transferred as part of that
  • Third-Party Software and Apps: We use several third-party software and apps to make our jobs a little Some Personal Information may be stored, processed, or shared with these apps.
  • Law Enforcement: We may sometimes be required to share your Personal Information with law enforcement. We will only share your Personal Information when we believe, in good faith, that sharing your information is necessary to protect our business, our clients, or we are obligated under the law to provide such information. Examples include where a legal warrant or subpoena has been issued to us, where we must report information due to a belief that fraud or misuse of our Online Services has occurred, or where our property or safety, or a user’s property or safety, is at risk. In fraud cases, we may also be required to share your Personal Information with investigatory authorities and banks.

Messages Policy

  • Messages you can opt out of: We may at times send emails, text messages, newsletters, push notifications and other messages (collectively the “Messages”) related to the Portal and our Online Services, and to keep you updated on what is happening with our business and new Online Service offerings. If you are receiving these types of Messages, it means that you consented to receive these Messages either by opting-in or by otherwise letting us know that it was all good for us to contact you in this way. You can unsubscribe or opt-out of Messages by following the instructions in the specific Message or emailing us at support@mygramercycounseling.com. We will be sad to see you leave!
  • Messages you will not be able to opt out of: You will not be able to opt out of some important Messages. For example, we may notify you of an upcoming session that you booked or changed, a change to your fees has occurred, that updates have been made to this Policy, or in the unlikely event that our security safeguards have been

Personal Information Retention and Your Rights

Gramercy only keeps your Personal Information for as long as necessary to provide our Online Services and per our legal obligations. Depending on your residency, under the law (e.g., the California Consumer Privacy Act and General Data Protection Regulation), you may also have the right to request at any time for us to:

  • Give you access to any Personal Information that we have processed;
  • Disclose third parties we have shared your Personal Information with;
  • Correct any Personal Information that may have been incorrectly processed;
  • Delete your Personal Information from our storage systems;
  • Transfer your Personal Information to another service, when technically feasible; and
  • Stop using your Personal Information in specific ways by withdrawing the consent you have given us.

Regardless of whether we are obligated under the law or not, if you would like us to do any of the above, you can contact us using the information provided at the end of this Policy. We will do our best to try to fulfill your requests. However, sometimes we may be required to retain your Personal Information to comply with our administrative, legal, and/or regulatory obligations. For example, we may be required to keep a history of transactions to report our taxes or may need to retain some Personal Information for law enforcement purposes (e.g., fraud monitoring, detection, and prevention). Additionally, we reserve the right to de-identify your data by removing identifying details rather than deleting it completely. For more information regarding your specific rights under the laws of the jurisdiction you reside, visit:

Where Your Information is Processed and Stored

We are a business that is formed and operated in the United States. However, in addition to storing Personal Information directly onto our hard drives, we also may use some third-party cloud storage systems and apps to ensure that your Personal Information is not lost. These third parties may store and transfer your information outside of the United States. In certain situations, the courts, law enforcement agencies, regulatory agencies, or security authorities in those countries might be entitled to access your Personal Information.

Liability for Third-Party Software, Apps & Services

We always use our best efforts to pick reputable third-party software, platforms, services, and apps. However, we do not control such third parties and are not liable for any breach of privacy or data security that occurs due to the fault of these third parties.

Keeping Your Information Safe

We are committed to protecting your Personal Information and have physical, electronic, and managerial systems and procedures in place to help safeguard your Personal Information. Unfortunately, no system can guarantee complete security. Third-party viruses or security failures may result in your Personal Information being compromised. You can help prevent unauthorized access to your Personal Information by using antivirus software, creating strong passwords, and limiting access to your personal computer. In the unlikely event that your Personal Information is compromised due to a security breach on our end, we will notify you, per the law, as soon as reasonably possible.

Protection of Children

All children between the ages of 13 and 17 must have permission from their parent or guardian before accessing our other Online Services, regardless of whether they are also participating in our Counseling Services. Moreover, all children of any age must have written permission from their parent or guardian before participating in our Counseling Services. Our services are intended to be used by residents of the United States. We do not knowingly collect Personal Information from anyone under the age of 13 and delete such Personal Information as soon as we become aware of it.

Parents of children between the ages of 10 and 12 may choose to have their child participate in our Counseling Services. However, children under the age of 13 may not access our Site or provide any personal information on their own behalf. Parents may contact us and provide their own personal information and/or their child’s personal information in order to enroll their child in our Counseling Services. We appreciate your compliance with these requirements to ensure your child’s online privacy rights are respected.

Dispute Resolution

We will always try to resolve your concerns about our privacy practices promptly and hope that together we can find a solution without involving costly legal channels. However, if we cannot agree, by using our Online Services, you agree to binding arbitration rather than formal court proceedings to have the matter resolved. You can read more about this process in our ToU. THE DISPUTE RESOLUTION TERMS IN OUR TOU MATERIALLY AFFECT YOUR ABILITY TO BRING A LAWSUIT AGAINST US IN REGARDS TO THIS POLICY AND OUR ONLINE SERVICES. PLEASE READ THESE TERMS CAREFULLY.

Additional ToU Terms

This Privacy Policy is subject to terms stated within our ToU. Specifically, this agreement is subject to all clauses in our ToU regarding warranties, limitation of liability, indemnification, assignment, waiver, severability, applicable law, jurisdiction, and any other ToU provisions that logically ought to apply to this Policy.

Entire Agreement

This Policy and our ToU represent the entire and exclusive agreement between our users and us. All previous written and oral agreements and communications related to the subject matter of this Policy and our ToU are superseded.

Contact Gramercy

Thank you for your patience in getting through all of the necessary legal language in this document! We have tried to be as transparent as possible in communicating our expectations regarding our Online Services. However, if you have any questions about this Policy, our ToU, or our Online Services in general, please reach out! We would be more than happy to explain.

support@mygramercycounseling.com
4009 Banister Lane, Ste 355 Austin, TX 78704

Ask Us Anything