YOUR PRIVACY IS IMPORTANT TO US Therapy 2 Thrive – Psychological & Developmental Services (“Therapy 2 Thrive,” “we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of information entrusted to us by our clients and their families. This Notice of Privacy Practices (“Notice”) explains how we may collect, use, maintain, and disclose personal and health-related information in connection with the services we provide in the British Virgin Islands. Because our services may involve psychological, developmental, occupational, speech and communication, chiropractic, and other healthcare-related services, the information we maintain may include sensitive information about your physical or mental health. Therapy 2 Thrive handles such information with care and in accordance with applicable British Virgin Islands laws and professional confidentiality obligations, including the British Virgin Islands Data Protection Act, 2021. 1. INFORMATION WE PROTECT Information we may maintain about you can include: Your name and contact information Date of birth Parent, guardian, or caregiver information Medical or health history Mental health information Psychological information Developmental information Speech and communication information Occupational therapy information Chiropractic or other healthcare information Assessment results Treatment or service plans Progress notes and clinical records Information provided by healthcare professionals or referral sources Insurance or billing information, where applicable Appointment and service information Other information necessary to provide or coordinate services We recognize that health and mental-health information is particularly sensitive and take reasonable steps to protect it from unauthorized access, use, disclosure, alteration, loss, or destruction. 2. HOW WE MAY USE YOUR INFORMATION We may use your personal and health information for purposes necessary to provide and manage your care. Treatment and Services We may use information to: Assess your needs; Provide psychological and developmental services; Provide occupational therapy; Provide speech and communication services; Provide chiropractic services; Develop and manage treatment or service plans; Monitor progress; Coordinate services; Communicate with you about your care; and Provide other services requested or provided by Therapy 2 Thrive. Administrative Purposes We may use information to: Schedule appointments; Maintain client records; Communicate with clients and authorized representatives; Process applicable billing or insurance matters; Manage our operations; Maintain service quality; Respond to questions or concerns; and Fulfill applicable administrative requirements. Legal and Regulatory Purposes We may use or disclose information when necessary to: Comply with applicable law; Respond to a lawful request from a court, government authority, or regulatory body; Meet professional or regulatory obligations; Protect the safety or rights of a client or another person; or Address suspected unlawful activity or other circumstances permitted by law. 3. DISCLOSURES OF INFORMATION Therapy 2 Thrive will limit disclosures of personal and health information to what is reasonably necessary for the purpose for which the information is being disclosed, subject to applicable law. Information may be disclosed to appropriate persons or organizations when permitted or required by law, including: Individuals Involved in Your Care Where appropriate and authorized, information may be shared with: Parents or legal guardians; Caregivers or authorized representatives; Healthcare professionals; Therapists or other members of your care team; Referring professionals; and Other individuals directly involved in coordinating your services. Healthcare and Service Providers We may share appropriate information with other healthcare or service providers when necessary for coordination of care or related healthcare purposes and where permitted by applicable law. Insurance and Payment Purposes Where applicable, information may be used or disclosed to process claims, verify coverage, obtain authorization, or address payment for services. Legal Requirements We may disclose information where required or permitted by applicable BVI law, including in response to lawful orders, legal proceedings, or requests from authorized government or regulatory authorities. 4. WHEN YOUR AUTHORIZATION MAY BE REQUIRED For certain uses or disclosures that are not otherwise permitted or required by law, Therapy 2 Thrive may request your written authorization. An authorization may specify: What information may be disclosed; Who may receive the information; The purpose of the disclosure; and The period for which the authorization applies. Where applicable, you may withdraw an authorization by providing written notice to Therapy 2 Thrive. Withdrawal of authorization will not affect information that was already used or disclosed based on the authorization before it was withdrawn. 5. INFORMATION ABOUT CHILDREN Therapy 2 Thrive provides services to children and minors. When services are provided to a child, information may be collected from and shared with a parent, legal guardian, caregiver, or other person legally authorized to act on the child's behalf, subject to applicable law and the circumstances of the particular service. We will take reasonable steps to protect the child's information and will consider applicable legal requirements concerning parental or guardian access and confidentiality. In certain circumstances, the law may limit what information can be disclosed to a parent, guardian, or other person. 6. CONFIDENTIALITY Therapy 2 Thrive recognizes that trust and confidentiality are fundamental to effective healthcare and therapeutic services. Access to client information is limited to individuals who have a legitimate need to access the information for their professional or administrative responsibilities. Our staff and service providers are expected to maintain appropriate confidentiality and protect client information. However, confidentiality is subject to applicable legal requirements and recognized exceptions, including circumstances in which disclosure is required or permitted by law. 7. WHEN WE MAY DISCLOSE INFORMATION WITHOUT ADDITIONAL AUTHORIZATION Depending on the circumstances and applicable law, Therapy 2 Thrive may disclose information without obtaining additional authorization when necessary or permitted for purposes such as: Providing or coordinating healthcare services; Maintaining or managing healthcare-related operations; Complying with legal obligations; Responding to lawful legal or governmental requests; Protecting the safety of a client or another person; Preventing or addressing serious unlawful activity; Responding to emergencies; Fulfilling professional or regulatory obligations; or Other circumstances authorized or required by applicable law. We will make disclosures only when legally permitted or required and will take reasonable steps to limit the information disclosed to what is appropriate for the purpose. 8. DISCLOSURES RELATED TO SAFETY Confidentiality may be limited when disclosure is necessary to address certain serious safety or legal concerns. For example, information may be disclosed where required or permitted by law in circumstances involving: A serious threat to the safety of a client or another person; Suspected abuse or neglect where reporting is required; A court or lawful government order; Serious unlawful activity; or Other circumstances where disclosure is required or permitted by applicable law. Therapy 2 Thrive will follow applicable legal and professional requirements when determining whether a disclosure is necessary. 9. YOUR RIGHTS REGARDING YOUR INFORMATION Subject to applicable BVI law and any applicable exemptions, you may have rights regarding the personal information we maintain about you. These may include the right to: Request Access You may request access to personal information that Therapy 2 Thrive holds about you. Request Correction If you believe information we hold about you is inaccurate, incomplete, misleading, or outdated, you may request that it be corrected. Ask How Your Information Is Used You may ask questions about how your personal information is collected, used, stored, or disclosed. Withdraw Consent Where processing is based on your consent, you may withdraw that consent, subject to circumstances in which Therapy 2 Thrive is otherwise legally permitted or required to continue processing the information. Make a Complaint You may submit a privacy complaint to Therapy 2 Thrive if you believe your information has not been handled appropriately. These rights are subject to applicable legal requirements and limitations. 10. REQUESTING ACCESS TO YOUR INFORMATION To request access to personal information held by Therapy 2 Thrive, please submit your request in writing. Therapy 2 Thrive – Psychological & Developmental Services BVI Location: Port Purcell | Burt Point| Hazel Point Telephone: 284-542-9277 Email: client@thrivepds.com We may request information necessary to verify your identity before providing access to personal information. Certain information may be withheld where permitted or required by law. 11. CORRECTING YOUR INFORMATION If you believe that information maintained by Therapy 2 Thrive is inaccurate, incomplete, misleading, or outdated, you may request a correction. Please provide sufficient information to identify the information you believe needs to be corrected. We will review the request and take appropriate action in accordance with applicable law. 12. HOW WE PROTECT YOUR INFORMATION Therapy 2 Thrive uses reasonable administrative, technical, physical, and organizational safeguards designed to protect personal information. These safeguards may include: Limiting access to authorized personnel; Confidentiality requirements; Secure recordkeeping practices; Appropriate password and account controls; Physical security measures; Reasonable electronic security measures; and Procedures for addressing suspected privacy or security incidents. No electronic or physical system can be guaranteed to be completely secure. However, we take reasonable measures appropriate to the nature of the information we maintain. 13. THIRD-PARTY SERVICE PROVIDERS Therapy 2 Thrive may use third-party providers to support our healthcare and business operations. Depending on our operations, these providers may include services relating to: Electronic health records; Cloud storage; Information technology; Communications; Appointment management; Billing; Insurance processing; Website services; and Other administrative or healthcare support functions. Where a third party handles personal information on our behalf, Therapy 2 Thrive will take reasonable steps to ensure appropriate privacy and security protections are in place. 14. INFORMATION PROCESSED OUTSIDE THE BVI Some service providers used by Therapy 2 Thrive may store or process information outside the British Virgin Islands. Where personal information is transferred or processed outside the BVI, Therapy 2 Thrive will take reasonable steps to comply with applicable requirements concerning international or cross-border transfers of personal information. This may include appropriate safeguards or other lawful mechanisms required under applicable BVI law. 15. RETENTION OF INFORMATION Therapy 2 Thrive retains client information for as long as reasonably necessary for the purposes for which it was collected and as required or permitted by applicable law, professional requirements, and legitimate business needs. When information is no longer required, we will take reasonable steps to securely destroy, delete, or anonymize it where appropriate. 16. WEBSITE INFORMATION This Notice of Privacy Practices applies primarily to information associated with Therapy 2 Thrive's healthcare and client services. Our public website collects only limited information through general inquiry forms, such as: Name; Telephone number; Email address; and Service of interest. The website does not collect clinical intake information or process payments through the general inquiry form. For information about how we handle information collected through our website, please see our separate Website Privacy Policy. 17. CHANGES TO THIS NOTICE Therapy 2 Thrive may update this Notice of Privacy Practices from time to time to reflect changes in applicable law, our services, technology, or privacy practices. The current version will identify the effective date and date of the most recent update. 18. QUESTIONS OR PRIVACY CONCERNS If you have questions about this Notice or believe your privacy has been violated, please contact us. Therapy 2 Thrive – Psychological & Developmental Services BVI Location: Port Purcell | Burt Point| Hazel Point Telephone: 284-542-9277 Email: client@thrivepds.com We encourage you to contact us first so that we can review and address your concern. You may also have the right to make a complaint to the Information Commissioner of the British Virgin Islands under applicable data protection law. ACKNOWLEDGEMENT OF RECEIPT Upon using this website, I acknowledge that I have been provided with or given access to Therapy 2 Thrive – Psychological & Developmental Services' Notice of Privacy Practices. I understand that this Notice explains how Therapy 2 Thrive may use and disclose my personal and health-related information and describes certain privacy rights available to me under applicable law.