PRIVACY POLICY

Last updated October 18, 2025



This Privacy Notice for Reflective Pathways Counseling Services LLC (doing business as Reflective Pathways Counseling Services) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
  • Use Therapy Intensives, Individual Therapy, and Clinical Consultation. This website provides information about psychotherapy and professional consultation services offered by Melissa Cribb, a licensed professional clinical counselor. These services include: Therapy Intensives Therapy intensives are structured, short-term treatment experiences designed for individuals seeking focused support for trauma, burnout, and emotional distress. These sessions utilize Accelerated Resolution Therapy (ART) and other evidence-based modalities to facilitate rapid healing and transformation. Personal information may be collected to assess clinical fit, schedule sessions, and ensure continuity of care Individual Therapy Individual therapy is available for adults experiencing trauma, substance use concerns, perfectionism, and related emotional challenges. Services are provided in accordance with professional ethical standards and applicable laws. Information collected through this site may be used to initiate contact, schedule appointments, and support therapeutic engagement. Clinical Consultation Clinical consultation is offered to licensed mental health professionals seeking guidance on trauma-informed care, case conceptualization, or integration of ART into their practice. These services are educational in nature and do not constitute supervision or treatment. Information collected may be used to coordinate sessions and maintain professional records.
  • Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at mcribb@reflectivepathways.org.


SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://reflective-melissa-cribb.squarespace.com/contact, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.


TABLE OF CONTENTS

   


1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
  • names
  • phone numbers
  • email addresses
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
  • health data
  • financial data
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.


2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To post testimonials. We post testimonials on our Services that may contain personal information.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://reflective-melissa-cribb.squarespace.com/privacy-policy.

Google Analytics

 We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than we retain personal information collected through this website (such as name, email, and phone number) only as long as necessary to respond to inquiries, coordinate services, or comply with legal and ethical obligations. for clients who engage in therapy or consultation services, health and financial information is stored securely within a hipaa-compliant electronic health record (ehr) platform and retained in accordance with professional licensing requirements, insurance regulations, and applicable laws. we do not retain sensitive information directly on this website..

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at mcribb@reflectivepathways.org.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice: https://reflective-melissa-cribb.squarespace.com/privacy-policy.

If you have questions or comments about your privacy rights, you may email us at mcribb@reflectivepathways.org.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of Minnesota, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"

CategoryExamplesCollected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Protected classification characteristics under state or federal law
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data

YES

C. Commercial information
Transaction information, purchase history, financial details, and payment information

YES

D. Biometric information
Fingerprints and voiceprints

NO

E. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

YES

F. Geolocation data
Device location

YES

G. Audio, electronic, sensory, or similar information
Images and audio, video or call recordings created in connection with our business activities

NO

H. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

YES

I. Education Information
Student records and directory information

NO

J. Inferences drawn from collected personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

NO

K. Sensitive personal Information

NO


We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
  • Category A - We collect personal identifiers such as name, email address, and phone number to coordinate services and respond to inquiries. For clients who engage in therapy, additional identifiers may be collected and stored securely within a HIPAA-compliant electronic health record (EHR) platform. We do not collect sensitive identifiers such as Social Security numbers through our website.
  • Category B - As part of our therapy intake process, we may collect personal characteristics such as age, gender, and other relevant demographic information. This data helps us tailor services to each client’s needs and is stored securely within a HIPAA-compliant electronic health record (EHR) platform. We do not collect this information directly through our website.
  • Category C - We collect limited consumer data related to the services clients have purchased or expressed interest in, such as therapy intensives or consultations. This information helps us tailor offerings and maintain accurate records. All data is stored securely within a HIPAA-compliant platform and is never sold or used for advertising purposes.
  • Category E - Internet Activity Have you collected information regarding a user's internet activity in the last 12 months? This is any tracking or compiling of a person's online activity, for example, to personalize content or advertisements that you want the user to see. Yes No
  • Category F - We do not collect or track your precise physical location or movements. Our website may detect general location (such as city or region) based on your IP address to improve performance, but we do not store or use this information for marketing or profiling purposes.
  • Category H - We may collect professional or employment-related information if you choose to share it with us—such as your work history, job title, or professional experience. This helps us tailor our services to your unique background and needs. For example, understanding your role or career path may inform how we approach therapy goals, intensives, or scheduling preferences. We do not collect this information automatically, and we never use it for profiling, advertising, or any purpose beyond supporting your care. You’re always in control of what you share, and we treat all professional data with the same level of confidentiality and respect as your clinical information.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
  • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota)
  • Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota)

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting https://reflective-melissa-cribb.squarespace.com/contact, by emailing us at mcribb@reflectivepathways.org, by visiting https://reflective-melissa-cribb.squarespace.com/contact, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at mcribb@reflectivepathways.org. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

11. THERAPIST’S PRIVACY COMMITMENT

Here’s a custom clause tailored to your boutique therapy practice, Melissa—warm, clear, and legally sound, with a nod to your ART intensives and high-functioning clientele: 🧘 Therapist’s Privacy Commitment As a trauma-informed therapist specializing in Accelerated Resolution Therapy (ART) intensives, I understand that privacy is more than a legal checkbox—it’s a cornerstone of trust and healing. I do not collect sensitive personal information on this website. Any health, payment, or intake data is securely handled through a separate encrypted Electronic Health Record (EHR) platform. This site only collects your name, phone number, and email address when you choose to reach out. I never use this information for advertising or profiling, and I do not sell or share your data. If you’re a high-functioning professional seeking clarity, transformation, and discretion, know that your privacy is honored at every step. For any questions or requests related to your personal information, please contact me directly via email at mcribb@reflectivepathways.org

12. COOKIES & TRACKING TECHNOLOGIES

 We use cookies and similar technologies to understand how visitors engage with our website, improve functionality, and enhance your experience. These may include tools like Google Analytics, which collect anonymized data such as browser type, pages visited, time spent on the site, and referral sources. This helps us refine our content and better serve our community of high-functioning professionals. We do not use cookies to track sensitive personal data or therapeutic activity. All analytics data is aggregated and used solely to improve site performance and client experience. By continuing to use this site, you consent to our use of cookies as described here. You may adjust your preferences through the cookie banner or by contacting us directly. This website operates in accordance with the laws of the State of Minnesota. If you reside outside Minnesota and have questions about how your local laws may apply, we welcome your inquiry.

13. PRIVACY POLICY TAILORED FOR MINNESOTA THERAPY PRACTICE

 This policy is governed by the laws of the State of Minnesota, where my practice is currently licensed and located. If you reside outside Minnesota, feel free to reach out with questions about how your local laws may apply.

14. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at mcribb@reflectivepathways.org or contact us by post at:

Reflective Pathways Counseling Services LLC
5123 W 98th St #1216
Minneapolis, MN 55437
United States

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://reflective-melissa-cribb.squarespace.com/contact.