Privacy Notice for Counseling Recovery

Effective Date: May, 18, 2018 Notice Version: 1.0

Counseling Recovery

Michelle Farris, psychotherapist, and business owner

6105 Snell Ave Su 101

San Jose CA 95123 USA

This document governs the privacy notice of our website

Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may collect

from you, how we collect it, how we protect it, how we may share it, how you can access

and change it, and how you can limit our sharing of it. Our privacy notice also explains certain

legal rights that you have with respect to your personal data. Any capitalized terms not defined

herein will have the same meaning as where they are defined elsewhere on our website.

Your Rights

When using our website and submitting personal data to us, you may have certain rights under

the General Data Protection Regulation (GDPR) and other laws. Depending on the legal

basis for processing your personal data, you may have some or all of the following rights:

The right to be informed

You have the right to be informed about the personal data we collect from you, and how we

process it.

The right of access

You have the right to get confirmation that your personal data is being processed and have the

ability to access your personal data.

The right to rectification

You have the right to have your personal data corrected if it is inaccurate or incomplete.

The right to erasure (right to be forgotten)

You have the right to request the removal or deletion of your personal data if there is no compelling

reason for us to continue processing it.

The right to restrict processing

You have a right to ‘block’ or restrict the processing of your personal data. When your personal

data is restricted, we are permitted to store your data, but not to process it further.

The right to data portability

You have the right to request and get your personal data that you provided to us and use it for

your own purposes. We will provide your data to you within 30 days of your request. To request

your personal data, please contact us using the information at the top of this privacy notice.

The right to object

You have the right to object to us processing your personal data for the following reasons:

  • Processing was based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
  • Direct marketing (including profiling); and
  • Processing for purposes of scientific/historical research and statistics.
  • Rights in relation to automated decision-making and profiling.

Automated individual decision-making and profiling

You will have the right not to be subject to a decision based solely on automated processing,

including profiling, which produces legal effects concerning you or similarly significantly affects


Filing a complaint with authorities

You have the right to file a complaint with supervisory authorities if your information has not

been processed in compliance with the General Data Protection Regulation. If the supervisory

authorities fail to address your complaint properly, you may have the right to a judicial remedy.

For details about your rights under the law, visit


‘Non-personal data’ (NPD) is information that is in no way personally identifiable.

‘Personal data’ (PD) means any information relating to an identified or identifiable natural person

(‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly,

by reference to an identifier such as a name, an identification number, location data, an

online identifier or to one or more factors specific to the physical, physiological, genetic, mental,

economic, cultural or social identity of that natural person. PD is in many ways the same as

Personally Identifiable Information (PII). However, PD is broader in scope and covers more data.

A “visitor” is someone who merely browses our website. A “member” is someone who has registered

with us to use or buy our services and products. The term “user” is a collective identifier

that refers to either a visitor or a member.

Topics Covered in Our Privacy Notice

  • Information We Collect
  • Our Use of Cookies
  • How Your Information Is Used
  • Retaining and Destroying Your PD
  • Updating Your PD
  • Revoking Your Consent for Using Your PD
  • Protecting the Privacy Rights of Third Parties
  • Do Not Track Settings
  • Links to Other Websites
  • Protecting Children’s Privacy
  • Our Email Policy
  • Our Security Policy
  • Use of Your Credit Card
  • Transferring PD from the European Union
  • Changes to Our Privacy Notice

Information We Collect

Generally, you control the amount and type of information that you provide to us when using

our website.

Our Legal Basis for Collecting and Processing Personal Data

Our legal basis for collecting and processing your PD when you buy our products or services is

based on and the necessity for the performance of a contract or to take steps to enter into a

contract. Our legal basis for collecting and processing your PD when you sign up for our newsletter

and information about our products and services through our website opt-in forms is

based on consent.

What Happens If You Don’t Give Us Your PD

If you do not provide us with enough PD, we may not be able to provide you with all our products

and services. However, you can access and use some parts of our website without giving

us your PD.

We Collect Your PD in the Following Ways:

Automatic Information

We automatically receive information from your web browser or mobile device. This information

includes the name of the website from which you entered our website, if any, as well as

the name of the website you’ll visit when you leave our website. This information may also include

the IP address of your computer/the proxy server you use to access the Internet, your

Internet service provider’s name, your web browser type, the type of mobile device, your computer

operating system, and data about your browsing activity when using our website. We use

all this information to analyze trends among our users to help improve our website.

When Entering and Using Our Website

When you enter and use our website and agree to accept cookies, some of these cookies may

contain your PD.

At User and Member Registration

When you register as a user or member, we collect your name, email address, and other information


When Buying Products or Services

If you buy products or services from us, we collect your first and last name, email address, physical

address, credit card or other payment information, phone number, and other information


Mobile Application

If you use our mobile application, you may have to provide PD to use it.

Collecting Your Location Information

When you use our services, we may collect and process information about your actual physical

location. We use several technologies, like GPS and IP tracking, to determine your location.

These technologies may also provide us with information about nearby cell towers, Wi-Fi access

points, and other devices.

Website Chat Software or Contact Forms

Our website contains chat software or contact forms that enable visitors to communicate with

us live online or offline by email. In some cases, visitors can communicate with us without becoming

a member or buying our products and services. When you use our chat software or contact

forms, we may collect some or all the following information: your email address, first

name, last name, location, and any other information you willingly choose to provide to us. You

should limit the information you provide to us that is only necessary to answer your questions.

Our Use of Cookies

Our website uses cookies. A cookie is a small piece of data or a text file that is downloaded to

your computer or mobile device when you access certain websites. Cookies may contain text

that can be read by the web server that delivered the cookie to you. The text contained in the

cookie generally consists of a sequence of letters and numbers that uniquely identifies your

computer or mobile device; it may contain other information as well.

By agreeing to accept our use of cookies, you are giving us, and third parties we partner with,

permission to place, store, and access some or all the cookies described below on your computer.

Strictly Necessary Cookies

These cookies are necessary for proper functioning of the website, such as displaying content,

logging in, validating your session, responding to your request for services, and other functions.

Most web browsers can be set to disable the use of cookies. However, if you disable these

cookies, you may not be able to access features on our website correctly or at all.

Performance Cookies

These cookies collect information about the use of the website, such as pages visited, traffic

sources, users’ interests, content management, and other website measurements.

Functional Cookies

These cookies enable the website to remember a user’s choices – such as their language, user

name, and other personal choices – while using the website. They can also be used to deliver

services, such as letting a user make a blog post, listen to audio, or watch videos on the website.

Media Cookies

These cookies can be used to improve a website’s performance and provide special features

and content. They can be placed by third parties who provide services to us or by our company.

Advertising or Targeting Cookies

These cookies are usually placed and used by advertising companies to develop a profile of your

browsing interests and serve advertisements on other websites that are related to your interests.

You will see less advertising if you disable these cookies.

Session Cookies

These cookies allow websites to link the actions of a user during a browser session. They may

be used for a variety of purposes, such as remembering what a user has put in their shopping

cart as they browse a website. Session cookies also permit users to be recognized as they navigate

a website so that any item or page changes they make are remembered from page to

page. Session cookies expire after a browser session; thus, they are not stored long term.

Persistent Cookies

These cookies are stored on a user’s device in between browser sessions, which allows the user’s

preferences or actions across a site (or, in some cases, across different sites) to be remembered.

Persistent cookies may be used for a variety of purposes, including remembering users’

choices and preferences when using a website or to target advertising to them.

We may also use cookies for:

  • Identifying the areas of our website that you have visited
  • Personalizing content that you see on our website
  • Our website analytics
  • Remarketing our products or services to you
  • Remembering your preferences, settings, and login details
  • Targeted advertising and serving ads relevant to your interests
  • Affiliate marketing
  • Allowing you to post comments
  • Allowing you to share content with social networks

Most web browsers can be set to disable the use of cookies. However, if you disable cookies,

you may not be able to access features on our website correctly or at all.

Web Beacons

We may also use a technology called web beacons to collect general information about your

use of our website and your use of special promotions or newsletters. The information we collect

by web beacons allows us to statistically monitor the number of people who open our

emails. Web beacons also help us to understand the behavior of our customers, members, and


Google Analytics Privacy Notice

Our website uses Google Analytics to collect information about the use of our website. Google

Analytics collects information from users such as age, gender, interests, demographics, how often

they visit our website, what pages they visit, and what other websites they have used before

coming to our website. We use the information we get from Google Analytics to analyze

traffic, remarket our products and services to users, improve our marketing, advertising, and to

improve our website. We have enabled Google Analytics advertising features such as remarketing

with Google Analytics, Google Display Network Impression Reporting, and Google Analytics

Demographics and Interest Reporting. Google Analytics collects only the IP address assigned to

you on the date you visit our website, not your name or other identifying information. We do

not combine the information collected using Google Analytics with PD. Although Google Analytics

plants a permanent cookie on your web browser to identify you as a unique user the next

time you visit our website, the cookie cannot be used by anyone but Google. Google also uses

specific identifiers to help collect information about the use of our website. For more information

on how Google collects and processes your data, visit

You can prevent Google Analytics from using your information by opting out at this link:

Facebook Remarketing

Third parties, including Facebook, may use cookies, web beacons, and other storage technologies

to collect or receive information from our website and elsewhere on the internet, and use

that information to provide measurement services and target ads. With Facebook remarketing

you may see our ads on Facebook after you have visited our website. For this to happen, Facebook

uses a Custom Audience Pixel that is activated when a visitor lands on a webpage and a

unique “cookie” is placed in their browser. Facebook lookalike audience targeting allows us to

show ads on Facebook to people who are similar to those who have already visited or made a

purchase from our website. To opt out of Facebook’s collection and use of information for ad

targeting visit:

How Your Information Is Used

We use the information we receive from you to:

  • Provide our products and services you have requested or purchased from us
  • Personalize and customize our content
  • Make improvements to our website
  • Contact you with updates to our website, products, and services
  • Resolve problems and disputes
  • Contact you with marketing and advertising that we believe may be of interest to you

Communications and Emails

When we communicate with you about our website, we will use the email address you provided

when you registered as a member or user. We may also send you emails with promotional

information about our website or offers from us or our affiliates unless you have opted out of

receiving such information. You can change your contact preferences at any time through your

account or by sending us an email with your request to:

Sharing Information With Affiliates and Other Third Parties

We do not sell or rent your PD to third parties for marketing purposes. However, for data aggregation

purposes we may use your NPD, which might be sold to other parties at our discretion.

Any such data aggregation would not contain any of your PD. We may provide your PD to

third-party service providers we hire to provide services to us. These third-party service providers

may include but are not limited to: payment processors, web analytics companies, advertising

networks, call centers, data management services, help desk providers, accountants, law

firms, auditors, shopping cart and email service providers, and shipping companies.

Sharing Information With Facebook and Google for Marketing Purposes

We may share your PD with third parties for similar audience marketing purposes. Similar audience

marketing is also called lookalike audience marketing. The third parties we share your PD

with for this type of marketing include Facebook and/or Google. Using your PD, for similar audience

marketing or lookalike audience marketing helps us find new audiences (users and customers)

based on similar interests to yours, this helps us improve our marketing services. Your

PD is only shared with Facebook and Google for this type of marketing. By using our website

and agreeing to our privacy notice, you are giving your consent for your PD to be used for the

marketing purposes described within this section.

Legally Required Releases of Information

We may be legally required to disclose your PD if such disclosure is (a) required by subpoena,

law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement

agencies; (c) necessary to investigate violations of or otherwise enforce our Legal

Terms; (d) necessary to protect us from legal action or claims from third parties, including you

and/or other users or members; or (e) necessary to protect the legal rights, personal/real prop8

erty, or personal safety of our company, users, employees, and affiliates.

Disclosures to Successors

If our business is sold or merges in whole or in part with another business that would become

responsible for providing the website to you, we retain the right to transfer your PD to the new

business. The new business would retain the right to use your PD according to the terms of this

privacy notice as well as to any changes to this privacy notice as instituted by the new business.

We also retain the right to transfer your PD if our company files for bankruptcy and some or all

of our assets are sold to another individual or business.

Community Discussion Boards

Our website may offer the ability for users to communicate with each other through online

community discussion boards or other mechanisms. We do not filter or monitor what is posted

on such discussion boards. If you choose to post on these discussion boards, you should use

care when exposing any PD, as such information is not protected by our privacy notice nor are

we liable if you choose to disclose your PD through such postings. Also, PD you post on our

website for publication may be available worldwide by means of the Internet. We cannot prevent

the use or misuse of such information by others.

Retaining and Destroying Your PD

We retain information that we collect from you (including your PD) only for as long as we need

it for legal, business, or tax purposes. Your information may be retained in electronic form, paper

form, or a combination of both. When your information is no longer needed, we will destroy,

delete, or erase it.

Updating Your PD

You can update your PD using services found on our website. If no such services exist, you can

contact us using the contact information found at the top of this privacy notice and we will help

you. However, we may keep your PD as needed to enforce our agreements and to comply with

any legal obligations.

Revoking Your Consent for Using Your PD

You have the right to revoke your consent for us to use your PD at any time. Such an opt-out

will not affect disclosures otherwise permitted by law including but not limited to: (i) disclosures

to affiliates and business partners, (ii) disclosures to third-party service providers that

provide certain services for our business, such as credit card processing, computer system services,

shipping, data management services, (iii) disclosures to third parties as necessary to fulfill

your requests, (iv) disclosures to governmental agencies or law enforcement departments, or as

otherwise required to be made under applicable law, (v) previously completed disclosures to

third parties, or (vi) disclosures to third parties in connection with subsequent contests or promotions

you may choose to enter, or third-party offers you may choose to accept. If you want

to revoke your consent for us to use your PD, send us an email with your request to:

Protecting the Privacy Rights of Third Parties

If any postings you make on our website contain information about third parties, you must

make sure you have permission to include that information in your posting. While we are not

legally liable for the actions of our users, we will remove any postings about which we are notified,

if such postings violate the privacy rights of others.

Do Not Track Settings

Some web browsers have settings that enable you to request that our website not track your

movement within our website. Our website does not obey such settings when transmitted to

and detected by our website. You can turn off tracking features and other security settings in

your browser by referring to your browser’s user manual.

Links to Other Websites

Our website may contain links to other websites. These websites are not under our control and

are not subject to our privacy notice. These websites will likely have their own privacy notices.

We have no responsibility for these websites and we provide links to these websites solely for

your convenience. You acknowledge that your use of and access to these websites are solely at

your risk. It is your responsibility to check the privacy notices of these websites to see how they

treat your PD.

Protecting Children’s Privacy

Even though our website is not designed for use by anyone under the age of 16, we realize that

a child under the age of 16 may attempt to access our website. We do not knowingly collect PD

from children under the age of 16. If you are a parent or guardian and believe that your child is

using our website, please contact us. Before we remove any information, we may ask for proof

of identification to prevent malicious removal of account information. If we discover that a

child is accessing our website, we will delete his/her information within a reasonable period of

time. You acknowledge that we do not verify the age of our users nor do we have any liability to

do so.

Our Email Policy

You can always opt out of receiving further email correspondence from us or our affiliates. We

will not sell, rent, or trade your email address to any unaffiliated third party without your permission

except in the sale or transfer of our business, or if our company files for bankruptcy.

Our Security Policy

We have built our website using industry-standard security measures and authentication tools

to protect the security of your PD. We and the third parties who provide services for us, also

maintain technical and physical safeguards to protect your PD. When we collect your credit

card information through our website, we will encrypt it before it travels over the Internet using

industry-standard technology for conducting secure online transactions. Unfortunately, we

cannot guarantee against the loss or misuse of your PD or secure data transmission over the

Internet because of its nature.

We strongly urge you to protect any password you may have for our website and to not share it

with anyone. You should always log out of our website when you finish using it, especially if you

are sharing or using a computer in a public place.

Use of Your Credit Card

You may have to provide a credit card to buy products and services from our website. We use

third-party billing services and have no control over these services. We use our commercially

reasonable efforts to make sure your credit card number is kept strictly confidential by using

only third-party billing services that use industry-standard encryption technology to protect

your credit card number from unauthorized use. However, you understand and agree that we

are in no way responsible for any misuse of your credit card number.

Transferring PD From the European Union

(PD) that we collect from you may be stored, processed, and transferred between any of the

countries in which we operate, specifically in the United States. The European Union has not

found the United States and some other countries to have an adequate level of protection of

PD under Article 45 of the GDPR. Our company relies on derogations for specific situations as

defined in Article 49 of the GDPR. For European Union customers and users, with your consent,

your PD may be transferred outside the European Union to the United States and or other

countries. We will use your PD to provide the goods, services, and/or information you request

from us to perform a contract with you or to satisfy a legitimate interest of our company in a

manner that does not outweigh your freedoms and rights. Wherever we transfer, process or

store your PD, we will take reasonable steps to protect it. We will use the information we collect

from you in accordance with our privacy notice. By using our website, services, or products,

you agree to the transfers of your PD described within this section.

Changes to Our Privacy Notice

We reserve the right to change this privacy notice at any time. If our company decides to

change this privacy notice, we will post those changes on our website so that our users and customers

are always aware of what information we collect, use, and disclose. If at any time we

decide to disclose or use your PD in a method different from that specified at the time it was

collected, we will provide advance notice by email (sent to the email address on file in your account).

Otherwise we will use and disclose our users’ and customers’ PD in agreement with the

privacy notice in effect when the information was collected. In all cases, your continued use of

our website, services, and products after any change to this privacy notice will constitute your

acceptance of such change.

Questions About Our Privacy Notice

If you have any questions about our privacy notice, please contact us using the information at

the top of this privacy notice.

Copyright © Orion Systems. This document or any portion of it may not be copied or duplicated without

a license from