Privacy Policy

This website (this “Site”) is operated by or on behalf of Twin Cities Therapy and Counseling Associates LLC, and its subsidiaries and affiliates (“Twin Cities Therapy and Counseling Associates,” “TCTCA,” “we,” “us,” and “our”). This online Privacy Policy (this “Privacy Policy”) describes our commitment to privacy and reflects the importance we place on earning and keeping your trust.

If you are an TCTCA client, please see our Notice of Privacy Practices.

Scope of this Privacy Policy

This Privacy Policy applies to the information we collect from or about you through this Site. It does not apply to information we collect from you through other channels, such as over the phone or in our clinics.

Some of the information TCTCA collects through this Site may be “personal information” — information that identifies you personally, alone or in combination with other information available to us. Examples of personal information include (but are not limited to):

  1. contact data (such as your email address, phone number and physical address)
  2. demographic data (such as your gender, your date of birth and your ZIP code)
  3. insurance data (such as your insurance carrier and insurance plan)
  4. personal preference data (such as search filters)
  5. health and medical data (such as information you supply in response to assessments, information about health providers you have visited, etc.)
  6. registration data (such as your first name, last name, and password)
  7. credit card or debit card numbers and expiration dates if used so that you can register for events or other activities through this Site

Other information we collect through this Site may be non personally identifiable, such as your IP address and information collected by cookies.

Please note that to the extent you submit “protected health information” (as defined by the Health Insurance Portability and Accountability Act) through this Site, such information is also governed by our Notice of Privacy Practices. To the extent there is a conflict between this Privacy Policy and our Notice of Privacy Practices, the stricter of the two applies.

This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those particular pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with applicable law.

Your consent

By using this Site, you are consenting to the collection, use, disclosure, and transfer of your information as described in this Privacy Policy (and any Privacy Notices that apply to you). If you do not consent to the collection, use, disclosure and transfer of your information as described in this Privacy Policy (and any Privacy Notices that apply to you), you may not use this Site. If you have questions about this Privacy Policy, or any Privacy Notice, please contact us using the information provided below.

Our terms and conditions of use

This Privacy Policy is part of the Terms and Conditions of Use that govern your use of this Site. A link to our Terms and Conditions of Use is provided at the bottom of each page of this Site.

Your choices

We respect your right to make choices about the ways we collect, use, and disclose your information. This Privacy Policy describes some of your choices, such as your choice to opt out of receiving “cookies.” We may ask you to indicate your choices at the time and on the page where you provide your information.

Your browser may deliver a Do-Not-Track (DNT) signal to this Site. Because of the changing state of technology and conflicting views within the technology industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals.

You may change previously expressed preferences regarding how we use your information. You may be able to change preferences through your account. Otherwise, please contact us using the information provided below. You may opt out of promotional emails by clicking the unsubscribe link in the footer of any promotional email we send you.

How to get help or support: To get help, call TCTCA’s office number or email at admin@tctca.com

This policy may change

TCTCA reserves the right to update or modify this Privacy Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Privacy Policy or Privacy Notice on this Site. These changes will only apply to the information we collect after we have posted the revised Privacy Policy or Privacy Notice on this Site.

Your use of this Site following any such change constitutes your agreement that all information collected from or about you after the revised Privacy Policy is posted will be subject to the terms of the revised Privacy Policy. You may access the current version of this Privacy Policy at any time by clicking on the link marked “Privacy” at the bottom of each page of the public areas of this Site.

Information we collect

TCTCA collects the information you manually provide (using your keyboard, mouse, or touchpad) when you use this Site. For example, we collect the information you provide when you create an account, make a purchase, communicate with us, schedule an appointment, sign up for an event, or otherwise interact with this Site.  Some of the information you manually provide may be personal information, such as your name and contact information.

We use “cookies” and other technologies to collect information and support certain features of this Site. For example, we may use these technologies to:

  • collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page
  • support the features and functionality of this Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits
  • personalize your experience when you use this Site
  • improve our marketing efforts, including through use of targeted advertising

The information we collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to personal information that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.

Information about third-party / cookies

In addition to the cookies TCTCA delivers to your computer or mobile device through this Site, certain third parties may deliver cookies to you for a variety of reasons. For example, we use Google Analytics, a web analytics tool that helps us understand how visitors engage with our Sites. See information from Google Analytics about safeguarding your data.

Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across non-affiliated websites and/or delivering targeted advertisements either on this Site or on other websites.

You have choices about the collection of information by third parties on our Sites. For example, if you don’t want information about your visit to this Site sent to Google Analytics, you may download an Opt-out Browser Add-on at tools.google.com. Please note that the Add-on does not prevent information from being sent to TCTCA.

To opt out of having interest-based information collected by certain entities during your visits to this site or other websites, go to aboutads.info/choices. This industry-developed website contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies.

How we use your information

We generally reserve the right to disclose information you submit to us through this Site as set forth below. Please note, however, that disclosure of protected health information submitted through this Site is governed exclusively by our Notice of Privacy Practices.

With third–party vendors

TCTCA shares information collected through this Site with third-party vendors who act for us or on our behalf. For example, we may use third-party vendors to design and operate this Site; to conduct surveys; and to help us with our promotional efforts. These third-party vendors may need information about you to perform their functions, but they are contractually obligated to use your information only to perform contracted-for services.

With our affiliates

As permitted by applicable law, TCTCA may share the information collected through this Site with other entities within the TCTCA corporate structure, such as the Twin Cities Therapy and Counseling Associates, LLC. However, before sharing your information in this fashion, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law.

In aggregate or de-identified form

We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. We may also share with third parties information about how particular individuals use this Site, but only on a de-identified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. We may provide basic demographic information (gender and age) in conjunction with providing Individualized Data. Third parties may use this information for analytical purposes and to market their own products and services, and for such other purposes as we may authorize. We will take reasonable efforts to ensure that third parties cannot and do not re-identify Individualized Data, including by contractually prohibiting them from doing so. 

As part of a business transfer

Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site to another organization, if we merge with or are acquired by another organization, or if we liquidate our assets (such as our user database) and sell them individually. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Privacy Policy and the privacy preferences you have expressed to us.

To comply with laws and protect our rights and the rights of others

We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms and Conditions of Use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

As described in a privacy notice or click-through agreement

We reserve the right to disclose your information as described in any Privacy Notice posted on a page of this Site where you provide that information. By providing your information on that page you will be consenting to the disclosure of your information as described in that Privacy Notice. We also reserve the right to disclose your information as described in any click–through agreement to which you have agreed.

How we protect your information

TCTCA takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control.

A note about children’s privacy

You must be at least 13 years old to have our permission to use this Site. We do not knowingly collect personal information from users under 13 years of age. If you are under the age of 13, you can use this service only in conjunction with your parent’s or guardian’s permission.

Links to other websites

This Privacy Policy applies only to this Site. This Site may also contain links to websites that are not operated by TCTCA or its affiliates. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. Epiphany Health does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any personal information.

Retention of personal information and requests to correct or delete it

In general, TCTCA reserves the right (but does not assume the obligation) to retain the information collected on this Site as long as necessary to provide the services, products and information you request or as permitted by applicable law.

If you would like to review, correct, and/or update the personal information you have provided to us through this Site, you may be able to do so through your account. Otherwise, please contact us using the information provided below. We will respond to your request within a reasonable time or within the time set out by applicable law. When appropriate, or as required by applicable law, we will correct, amend or delete your personal information. We reserve the right to limit or deny access to personal information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by applicable law.

This Site is hosted on servers located in the United States.

TCTCA is a U.S. corporation. The servers that support this Site are located in the United States. While it is in our possession, your information will generally be stored in TCTCA databases or databases maintained by our third-party service providers on servers and data storage devices located in the United States. U.S. data protection laws may not provide as much protection as the data protection laws in force in some other countries. However, we will process your information in accordance with this Policy no matter where our data is stored. If you are located in a country outside the United States, by using this Site you consent to the transfer of your information to the United States.

Governing law

This Policy shall be governed under the laws of the State of Minnesota United States of America without regard to its conflicts of law provisions.

Questions about this Policy or TCTCA’s data practices

If you have questions or concerns about this Privacy Policy, any Privacy Notice, or TCTCA’s data practices, please contact us by email at admin@tctca.com. You may also contact us at:

Twin Cities Therapy and Counseling Associates
5861 Cedar Lake Rd.
St. Louis Park, MN 55416

 

First Published: 12/09/2022
Last Reviewed: 02/09/2026

Patient Privacy and HIPAA Rights

In order to care for you, we must learn many things about you.  To protect your privacy, we follow certain rules about handling your health information.  This Notice of Privacy Practices provides you more details about these rules:

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Twin Cities Therapy and Counseling Associates, PLLC (the “Practice”) is committed to protecting your privacy. The Practice is required by federal law to maintain the privacy of Protected Health Information (“PHI”), which is information that identifies or could be used to identify you. The Practice is required to provide you with this Notice of Privacy Practices (this “Notice”), which explains the Practice’s legal duties and privacy practices and your rights regarding PHI that we collect and maintain.

 

YOUR RIGHTS

Your rights regarding PHI are explained below. To exercise these rights, please submit a written request to the Practice at the address noted below.

To inspect and copy PHI.

  • You can ask for an electronic or paper copy of PHI. The Practice may charge you a reasonable fee.

  • The Practice may deny your request if it believes the disclosure will endanger your life or another person’s life. You may have a right to have this decision reviewed.


To amend PHI.

  • You can ask to correct PHI you believe is incorrect or incomplete. The Practice may require you to make your request in writing and provide a reason for the request.

  • The Practice may deny your request. The Practice will send a written explanation for the denial and allow you to submit a written statement of disagreement.


To request confidential communications.

  • You can ask the Practice to contact you in a specific way. The Practice will say “yes” to all reasonable requests.


To limit what is used or shared.

  • You can ask the Practice not to use or share PHI for treatment, payment, or business operations. The Practice is not required to agree if it would affect your care.

  • If you pay for a service or health care item out-of-pocket in full, you can ask the Practice not to share PHI with your health insurer.

  • You can ask for the Practice not to share your PHI with family members or friends by stating the specific restriction requested and to whom you want the restriction to apply.


To obtain a list of those with whom your PHI has been shared.

  • You can ask for a list, called an accounting, of the times your health information has been shared. You can receive one accounting every 12 months at no charge, but you may be charged a reasonable fee if you ask for one more frequently.


To receive a copy of this Notice.

  • You can ask for a paper copy of this Notice, even if you agreed to receive the Notice electronically.


To choose someone to act for you.

  • If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights.


To file a complaint if you feel your rights are violated.

  • You can file a complaint by contacting the Practice using the following information:


    Twin Cities Therapy and Counseling Associates, PLLC
    Attn: Lauren Paulbick, Director of Operations, Privacy Officer
    5861 Cedar Lake Road
    Saint Louis Park, MN 55416
    612-202-8703

  • You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.

  • The Practice will not retaliate against you for filing a complaint.


To opt out of receiving fundraising communications.

  • The Practice may contact you for fundraising efforts, but you can ask not to be contacted again.

 

OUR USES AND DISCLOSURES

1. Routine Uses and Disclosures of PHI. The Practice is permitted under federal law to use and disclose PHI, without your written authorization, for certain routine uses and disclosures, such as those made for treatment, payment, and the operation of our business. The Practice typically uses or shares your health information in the following ways:

To treat you.

  • The Practice can use and share PHI with other professionals who are treating you.

  • Example: Your primary care doctor asks about your mental health treatment.


To run the health care operations.

  • The Practice can use and share PHI to run the business, improve your care, and contact you.

  • Example: The Practice uses PHI to send you appointment reminders if you choose.


To bill for your services.

  • The Practice can use and share PHI to bill and get payment from health plans or other entities.

  • Example: The Practice gives PHI to your health insurance plan so it will pay for your services.


2. Uses and Disclosures of PHI That May Be Made Without Your Authorization or Opportunity to Object. The Practice may use or disclose PHI without your authorization or an opportunity for you to object, including:

To help with public health and safety issues.

  • Public health: To prevent the spread of disease, assist in product recalls, and report adverse reactions to medication.

  • Required by the Secretary of Health and Human Services: We may be required to disclose your PHI to the Secretary of Health and Human Services to investigate or determine our compliance with the requirements of the final rule on Standards for Privacy of Individually Identifiable Health Information.

  • Health oversight: For audits, investigations, and inspections by government agencies that oversee the health care system, government benefit programs, other government regulatory programs, and civil rights laws.

  • Serious threat to health or safety: To prevent a serious and imminent threat.

  • Abuse or Neglect: To report abuse, neglect, or domestic violence.


To comply with law, law enforcement, or other government requests

  • Required by law: If required by federal, state or local law.

  • Judicial and administrative proceedings: To respond to a court order, subpoena, or discovery request.

  • Law enforcement: For law locate and identify you or disclose information about a victim of a crime.

  • Specialized Government Functions: For military or national security concerns, including intelligence, protective services for heads of state, or your security clearance.

  • National security and intelligence activities: For intelligence, counterintelligence, protection of the President, other authorized persons or foreign heads of state, for purpose of determining your own security clearance and other national security activities authorized by law.

  • Workers’ Compensation: To comply with workers’ compensation laws or support claims.


To comply with other requests.

  • Coroners and Funeral Directors: To perform their legally authorized duties.

  • Organ Donation: For organ donation or transplantation.

  • Research: For research that has been approved by an institutional review board.

  • Inmates: The Practice created or received your PHI in the course of providing care.

  • Business Associates: To organizations that perform functions, activities or services on our behalf.


3. Uses and Disclosures of PHI That May Be Made with Your Authorization or Opportunity to Object. Unless you object, the Practice may disclose PHI:

  • To your family, friends, or others if PHI directly relates to that person’s involvement in your care.

  • If it is in your best interest because you are unable to state your preference.


4. Uses and Disclosures of PHI Based Upon Your Written Authorization. The Practice must obtain your written authorization to use and/or disclose PHI for the following purposes:

  • Marketing, sale of PHI, and psychotherapy notes.


You may revoke your authorization, at any time, by contacting the Practice in writing, using the information above. The Practice will not use or share PHI other than as described in Notice unless you give your permission in writing.

 

SUBSTANCE USE DISORDER RECORDS (42 C.F.R. PART 2)

The Practice does not provide substance use disorder (“SUD”) treatment services and is not a program subject to the federal confidentiality regulations at 42 C.F.R. Part 2 (“Part 2”). Discussions of substance use or co-occurring conditions that occur as part of general mental health treatment are not considered SUD treatment and are not subject to Part 2.

However, in some circumstances, we may receive records from another provider that are subject to Part 2 (for example, if you previously received SUD treatment from a Part 2 program and authorize that provider to send records to us).

If we receive SUD records that are subject to Part 2:

  • Those records are protected by federal law and may only be used or disclosed as permitted by Part 2 and consistent with your written consent or a valid court order.

  • Each disclosure made with your consent must include either a copy of the consent or a clear explanation of the scope of the consent and must be accompanied by the written notice required by 42 C.F.R. § 2.32(a).

  • Disclosure generally requires your explicit written consent, except in limited circumstances permitted by law, such as:

    • Medical emergencies, to the extent necessary to treat you

    • Reporting crimes on program premises

    • Child abuse or neglect reporting to appropriate authorities

    • Certain fundraising activities, for which you will be given an opportunity to opt out

You may revoke any such consent at any time, except to the extent action has already been taken in reliance on it.

 

OUR RESPONSIBILITIES

  • The Practice is required by law to maintain the privacy and security of PHI.

  • The Practice is required to abide by the terms of this Notice currently in effect. Where more stringent state or federal law governs PHI, the Practice will abide by the more stringent law.

  • The Practice reserves the right to amend Notice. All changes are applicable to PHI collected and maintained by the Practice. Should the Practice make changes, you may obtain a revised Notice by requesting a copy from the Practice, using the information above.

  • The Practice will inform you if PHI is compromised in a breach.


This Notice is effective on the date signed.

If you have questions about our privacy practices, please contact us:

  • If you think your privacy rights have been violated, or if you disagree with a decision about any of your rights, please know you will not be penalized for filing a complaint.
    • You may file a complaint with the TCTCA Privacy Office by email at admin@tctca.com. You may also submit your complaint in writing and mail it to: Twin Cities Therapy and Counseling Associates, Attention: Privacy Office, 5861 Cedar Lake Rd, St. Louis Park, MN 55416.
    • You also may send a written complaint to the U.S. Department of Health and Human Services – Office for Civil Rights. For more information, go to gov/ocr/privacy/hipaa/complaints.
  • If you have any questions or concerns about our privacy practices, please call 612.202.8703.

 

RELEASE OF INFORMATION

To request a copy of your health records, please complete a Release of Information form and follow the instructions on the form.

If you have release of information questions, call 612.202.8703 or email admin@tctca.com

 

Changes to your medical record

If you would like to request a change to your medical record, please complete a Patient Request for Record Amendment form and send the completed form to the address on the form. You may also email the form to admin@tctca.com  However, if you choose to email the completed form, please note that unencrypted email is not secure and could be intercepted and viewed by a third party. TCTCA is not responsible for unauthorized access to your health information while in transmission.

 

If you are looking to only update outdated information, please contact our office at 612.202.8703 or ask your provider to update the information during your next visit.