This Privacy Policy explains how Pasadena Clinical Group, a California professional psychology practice ("Pasadena Clinical Group," "PCG," "we," "us," or "our"), collects, uses, discloses, retains, and protects information about visitors to www.pasadenaclinicalgroup.com (the "Website") and individuals who interact with our outpatient practice located at 301 N. Lake Ave, STE 600, Pasadena, CA 91101. This Policy is designed to satisfy applicable U.S. federal and California state privacy laws, including the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the "CCPA"), and to provide transparent notice of our practices.
Health information collected during the course of clinical care is governed primarily by the Health Insurance Portability and Accountability Act ("HIPAA") and the California Confidentiality of Medical Information Act ("CMIA"); please see our HIPAA Notice of Privacy Practices for a description of how we handle Protected Health Information. This Privacy Policy applies to information collected through the Website, contact forms, electronic communications, telephone inquiries, and general business operations.
1. Scope of This Policy
This Policy applies to: (a) prospective clients, current clients, and former clients of Pasadena Clinical Group; (b) family members, legal representatives, or third parties acting on behalf of a client; (c) job applicants, practicum applicants, internship applicants, and prospective trainees who interact with our recruiting and training processes; (d) website visitors and users of any electronic forms we make available; and (e) other individuals who otherwise contact us, request information, or transact with us.
If you are acting on behalf of another person (for example, a parent acting on behalf of a minor or a legal representative acting on behalf of an incapacitated adult), you represent and warrant that you have the legal authority to provide that person's information to us and to consent to its processing as described in this Policy.
2. Categories of Personal Information We Collect
In the preceding twelve (12) months, we have collected, and may continue to collect, the following categories of "personal information" (as defined by the CCPA) about California residents:
(a) Identifiers
- Name, postal address, telephone number, email address
- Online identifiers including IP address, browser fingerprint, device identifier, and similar identifiers
- Account login or portal credentials, where applicable
(b) Customer-Records Information (Cal. Civ. Code § 1798.80(e))
- Insurance carrier, plan name, member identification number, group number
- Date of birth where required for benefits verification
- Emergency contact information
- Billing and payment information (we do not store full credit-card numbers; payment processing is handled by a PCI-DSS-compliant third-party processor)
(c) Protected Classification Characteristics
We collect protected classification characteristics (such as gender, age, marital status, or veteran status) only to the extent necessary for clinical assessment and care, and only after intake.
(d) Internet or Other Electronic Network Activity Information
- Browsing history on our Website, search history within our Website, pages viewed, and similar interaction data
- Information regarding interaction with our Website, applications, or advertisements
(e) Geolocation Data
We collect approximate location (e.g., city, region) inferred from IP address. We do not collect precise (GPS-level) geolocation through the Website.
(f) Audio, Electronic, or Similar Information
- Voicemails left for our office
- Recordings of clinical sessions, only where the client has provided specific written authorization for recording
(g) Professional or Employment-Related Information
For job applicants, practicum applicants, and internship applicants: résumé, CV, cover letter, work history, education, references, and related materials submitted through our Careers & Training page.
(h) Education Information
For applicants: doctoral program, year in program, accreditation status, training history.
(i) Inferences
We may draw inferences from the information described above to better understand prospective-client interest, refine our website, and serve relevant content.
(j) Sensitive Personal Information (CPRA)
The CCPA, as amended by the CPRA, identifies certain categories of "sensitive personal information." In the course of our practice, we may collect: (i) precise geolocation only where you provide it for in-person scheduling logistics; (ii) information concerning health, mental or physical health diagnoses, prescriptions, or treatment, all of which are governed primarily by HIPAA and CMIA; (iii) Social Security numbers only where required for insurance billing or background checks for trainees; and (iv) account log-in credentials.
We do not use sensitive personal information for purposes other than those that are necessary to perform services, comply with legal obligations, or that are otherwise expressly authorized under California Civil Code § 1798.121.
3. Sources of Personal Information
We collect personal information from the following sources:
- Directly from you: when you complete a Website form, send us an email, call our office, attend an appointment, sign forms at intake, or otherwise interact with us.
- Automatically through the Website: through cookies, server logs, analytics tools, and similar technologies (see Section 11 below and our Cookie Policy).
- From service providers: our scheduling, billing, telehealth, electronic-health-records, and analytics vendors.
- From your insurance carrier or another payor: for benefits verification, claims processing, prior authorization, and reimbursement.
- From referring providers: with your authorization, when another clinician refers you to us or coordinates care with us.
- From publicly available sources: for example, license verification through state professional boards.
4. How We Use Personal Information
We use personal information for one or more of the following business purposes (as defined by the CCPA):
- To provide, manage, and coordinate clinical care, including scheduling, intake, treatment, and follow-up
- To verify insurance benefits and to process billing, claims, and reimbursement
- To respond to inquiries, requests, complaints, and feedback
- To evaluate practicum, internship, and employment applications
- To operate, maintain, secure, and improve the Website and our internal systems
- To detect security incidents, protect against malicious or fraudulent activity, and prosecute those responsible
- To debug and identify and repair errors
- To perform internal research and quality improvement
- To comply with legal, regulatory, professional-licensing, accreditation, audit, and reporting obligations
- To enforce our Terms & Conditions and other agreements
- To exercise or defend legal claims
5. How We Disclose Personal Information
We disclose personal information only as needed for the purposes described above, and only to the categories of recipients listed below:
- Service providers and processors who provide hosting, analytics, secure communications, scheduling, electronic health records, payment processing, billing, payroll, accounting, legal, audit, and similar services, under written contracts that limit their use of personal information.
- Insurance carriers and third-party payors for benefits verification, prior authorization, claims submission, and audits, where you have authorized such disclosures or where they are otherwise permitted by law.
- Healthcare providers and trainees for treatment, care coordination, and supervision, in accordance with our HIPAA Notice.
- Legal, regulatory, accreditation, and licensing authorities where required by law, including under California's mandated-reporting statutes (suspected abuse of a child, elder, or dependent adult), under public-health reporting laws, in response to subpoenas, court orders, or other legal process, or where disclosure is necessary to avert a serious and imminent threat to a person's health or safety.
- Business successors in the event of a merger, acquisition, reorganization, dissolution, or similar event, in which case personal information may be transferred to the successor entity, subject to applicable law.
- Our professional advisors such as attorneys, accountants, insurers, auditors, and consultants under appropriate confidentiality obligations.
6. Sale or Sharing of Personal Information — We Do Not Sell or Share
Pasadena Clinical Group does not sell personal information. Pasadena Clinical Group does not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA. We have not sold or shared the personal information of California residents in the preceding twelve (12) months, including the personal information of any consumers under the age of 16.
We do not engage in profiling for purposes of producing legal or similarly significant decisions about you.
7. Retention of Personal Information
We retain personal information only as long as reasonably necessary for the purpose for which it was collected, to comply with legal obligations, to resolve disputes, and to enforce our agreements. Specifically:
- Clinical health records: retained in accordance with applicable California law (generally a minimum of seven (7) years following the last date of service for adult clients, and as otherwise required for minor clients per the California Code of Regulations, Title 16, § 1397.65 and related provisions).
- Billing and accounting records: retained for at least seven (7) years to satisfy tax, audit, and regulatory requirements.
- Website inquiry forms: retained for up to two (2) years from submission, then deleted or de-identified, unless you become a client (in which case retention is governed by clinical-record rules).
- Cookies and analytics data: retained as described in our Cookie Policy.
- Practicum and internship applicant records: retained for up to two (2) years, then deleted unless the applicant becomes a trainee.
8. Your California Privacy Rights (CCPA / CPRA)
Subject to certain exceptions, California residents have the following rights:
(a) Right to Know
You have the right to request that we disclose what personal information we have collected about you, including the categories of personal information; the categories of sources from which the personal information was collected; the business or commercial purpose for collecting the information; the categories of third parties to whom the information is disclosed; and the specific pieces of personal information we have collected.
(b) Right to Delete
You have the right to request that we delete personal information we have collected from you, subject to certain legal exceptions (for example, when the information is necessary to complete a transaction, comply with a legal obligation, or maintain a clinical record).
(c) Right to Correct
You have the right to request that we correct inaccurate personal information we maintain about you.
(d) Right to Opt Out of Sale or Sharing
As stated above, we do not sell or share personal information. You may nevertheless submit an opt-out request through our Do Not Sell or Share My Personal Information link, which will be respected for purposes of analytics-style tracking.
(e) Right to Limit Use of Sensitive Personal Information
To the extent we collect or process sensitive personal information for purposes other than those expressly authorized by California Civil Code § 1798.121, you may request that we limit such use. As of the date of this Policy, we use sensitive personal information only for permitted business purposes.
(f) Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights, including by denying services, charging different prices, or providing a different level of quality.
(g) Authorized Agents
You may designate an authorized agent to make a CCPA request on your behalf. We will require written authorization from you and may require the agent to verify their own identity directly with us.
9. How to Exercise Your Rights
To exercise any of the rights described in Section 8, you may:
- Call us at 626-354-6440
- Email us at office@pasadenaclinicalgroup.com with the subject line "Privacy Request"
- Mail us at: Privacy Officer, Pasadena Clinical Group, 301 N. Lake Ave, STE 600, Pasadena, CA 91101
We will need to verify your identity before responding to a request. The verification process may include matching identifying information you provide against information in our records, or requesting additional information sufficient to verify your identity. We will respond to verifiable requests within forty-five (45) days of receipt, and may extend that period by an additional forty-five (45) days where reasonably necessary.
If we deny your request in whole or in part, we will explain the basis for the denial and your right to appeal. To appeal, please respond to the denial in writing within thirty (30) days, and we will issue a written response within sixty (60) days.
10. Global Privacy Control and Other Browser Signals
Our Website is configured to recognize and honor opt-out preference signals, including the Global Privacy Control (GPC) signal, in accordance with California regulations. When we detect a GPC signal from your browser, we will treat it as a valid request to opt out of any "sale" or "sharing" of personal information for that browser and device, to the extent applicable.
11. Cookies, Analytics, and Similar Technologies
We use cookies, web beacons, and similar technologies as described in our separate Cookie Policy. You can accept or decline non-essential cookies through our cookie banner and reopen the banner at any time using the Do Not Sell or Share My Personal Information link in our footer.
12. Children's Privacy
The Website is intended for adults. We do not knowingly collect personal information from children under thirteen (13) years of age through the Website. If we learn that we have collected such information, we will delete it promptly. We do not sell or share the personal information of any consumer we know to be under sixteen (16) years of age.
13. Information Security
We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction, including encryption in transit, role-based access controls, secure backups, and staff training. No system is perfectly secure, and we cannot guarantee absolute security. If you believe an unauthorized party has accessed your personal information held by us, please contact our Privacy Officer immediately.
14. Notice of Financial Incentives
Pasadena Clinical Group does not offer financial incentives in exchange for the collection, sale, or retention of personal information.
15. Third-Party Websites and Services
The Website may contain links to third-party websites and services that are not owned or controlled by us. We are not responsible for the privacy practices of those third parties. We encourage you to read the privacy policies of any third-party site you visit.
16. Other State Privacy Rights
Residents of certain other U.S. states may have additional privacy rights under their respective state laws (for example, the Virginia Consumer Data Protection Act, the Colorado Privacy Act, and similar statutes). To exercise rights under those laws, please use the contact information in Section 9.
17. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the most recent revision. Material changes will be communicated through a prominent notice on the Website prior to the change becoming effective.
18. Contact & Privacy Officer
Questions, concerns, requests, or complaints regarding this Privacy Policy or our privacy practices should be directed to:
Privacy Officer
Pasadena Clinical Group
301 N. Lake Ave, STE 600
Pasadena, CA 91101
Phone: 626-354-6440
Email: office@pasadenaclinicalgroup.com