PRIVACY POLICY
Upward Spiral Counseling LLC
Effective Date: February 17, 2026
Last Updated: February 17, 2026
Website: https://www.upwardspiralcounseling.me
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1. INTRODUCTION
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Upward Spiral Counseling LLC ("we," "us," "our," or "the Practice") is committed to protecting your privacy and safeguarding your personal and health information. This Privacy Policy explains how we collect, use, store, share, and protect your information when you visit our website, contact us, or receive counseling services from our practice.
Upward Spiral Counseling LLC is a private-pay psychotherapy practice owned and operated by Christina Pongracic, LLPC (Limited License Professional Counselor), located at 42 Union Street, Hillsdale, MI 49242. We are licensed and regulated under the laws of the State of Michigan, and we comply with applicable federal and state privacy laws, including the Health Insurance Portability and Accountability Act (HIPAA) where applicable.
By using our website, submitting information through our contact forms, or engaging in our counseling services, you acknowledge that you have read and understand this Privacy Policy.
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2. INFORMATION WE COLLECT
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We may collect the following categories of personal information depending on how you interact with us:
Personal Identification Information: Your name, email address, phone number, mailing address, and preferred method of contact (text or call).
Health and Clinical Information: Mental health history, diagnoses, treatment plans, session notes, assessment results, and other clinical records created during the course of therapy. This information is considered Protected Health Information (PHI) under HIPAA.
Appointment Information: Scheduling details, session dates and times, cancellation history, and consultation records.
Payment and Billing Information: Payment method (cash, check, or credit card), transaction records, and billing history. Please note that a 2.75% processing fee applies to credit card payments.
Communications: Any information you provide through our website contact form, email correspondence, phone calls, or text messages.
Website Usage Data: Information automatically collected when you visit our website, such as your IP address, browser type, device type, pages visited, time spent on pages, and referring website. This data is collected through cookies and analytics tools (see Section 9 for details).
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3. HOW WE COLLECT YOUR INFORMATION
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We collect information through the following methods:
Website Contact Forms: When you fill out a contact form on our website, you provide your name, email, phone number, preferred mode of contact, and a message. This information is transmitted to us so we can respond to your inquiry.
Phone and Text Communication: When you call or text (517) 292-3329 to schedule a consultation, ask questions, or communicate between sessions.
Email: When you contact us at upwardspiralcounseling@pm.me.
In-Person Sessions: During your initial diagnostic interview and ongoing therapy sessions, we collect clinical and health information necessary to provide counseling services.
Payment Processing: When you pay for services via cash, check, or credit card at the time of your session.
Cookies and Website Analytics: Our website uses cookies and analytics technologies to collect usage data automatically when you browse our site (see Section 9).
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4. WHY WE COLLECT YOUR INFORMATION (PURPOSE OF DATA COLLECTION)
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We collect and use your personal information for the following purposes:
Providing Counseling Services: To conduct initial diagnostic interviews, deliver individual therapy, couples/dual sessions, mindfulness and stress management services, and trauma-informed counseling.
Appointment Scheduling and Management: To schedule, confirm, reschedule, or cancel appointments, including your free 15-minute consultation.
Communication: To respond to your inquiries, provide appointment reminders, and communicate information relevant to your care.
Payment and Billing: To process payments, issue receipts, apply cancellation or no-show fees per our practice policies, and maintain accurate billing records.
Legal and Regulatory Compliance: To comply with applicable laws, regulations, licensing requirements, and legal obligations, including mandatory reporting requirements under Michigan law.
Improving Our Services: To enhance and optimize your experience on our website, improve our service offerings, and ensure the functionality and security of our website.
Good Faith Estimate Compliance: To provide you with a Good Faith Estimate of expected costs for services as required under the No Surprises Act.
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5. WHO WE SHARE YOUR INFORMATION WITH
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We take your privacy seriously and limit the sharing of your information. We may share your information with the following parties only when necessary and permitted by law:
Payment Processors: We use third-party credit card processing services to handle credit card transactions. These processors receive only the payment information necessary to complete your transaction and are required to protect your data in accordance with applicable regulations.
Website Hosting and Technology Providers: Our website is hosted by a third-party platform provider that may have access to website usage data. Our website also utilizes the UserWay Accessibility Widget (see Section 10 for details).
Legal and Regulatory Authorities: We may disclose your information when required by law, such as in response to a court order, subpoena, or legal process, or when we are required to report under mandatory reporting laws (e.g., suspected child abuse, elder abuse, or threats of harm to self or others as required by Michigan law).
Healthcare Collaborators: If you provide written authorization, we may share relevant clinical information with other healthcare providers involved in your care (e.g., a referring physician or psychiatrist).
Professional Consultants: In rare circumstances, we may consult with other licensed professionals regarding your care. In such cases, your identity is protected and only the minimum necessary information is shared.
Business Operations: We may share information with professional advisors (e.g., legal counsel, accountants) as necessary for the operation and compliance of our practice.
We do NOT sell, rent, or trade your personal information to third parties for marketing purposes.
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6. HOW WE USE YOUR DATA
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Your data is used strictly for the purposes outlined in Section 4 above. Specifically:
Clinical data is used to provide you with effective, personalized counseling services, to create and maintain your treatment plan, and to document your progress.
Contact information is used to communicate with you about appointments, respond to inquiries, and provide information relevant to your care.
Payment information is used solely to process transactions and maintain billing records.
Website data is used to analyze how visitors interact with our website so we can improve functionality, content, and user experience. This data is collected in aggregate and is not used to personally identify you.
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7. HOW LONG WE RETAIN YOUR DATA
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We retain your personal and clinical information in accordance with applicable Michigan state law and professional licensing requirements:
Clinical and Health Records: Client therapy records are retained for a minimum of seven (7) years from the date of the last service provided, or longer if required by law. For minor clients, records are retained for at least seven (7) years after the client reaches the age of 18.
Billing and Payment Records: Financial records are retained for a minimum of seven (7) years for tax and legal compliance purposes.
Website and Communication Data: Inquiries submitted through our website contact form and related communications are retained for as long as necessary to respond to your inquiry and for reasonable business purposes, after which they are securely deleted.
Cookies and Analytics Data: Website analytics data is retained according to the retention periods set by our analytics providers (see Section 9).
When your information is no longer needed for the purposes described above or required by law, it will be securely destroyed. Paper records are shredded, and electronic records are permanently deleted using secure methods.
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8. HOW WE PROTECT YOUR INFORMATION
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We take the security of your personal and health information seriously and have implemented the following safeguards:
Secure Storage: Clinical records and client files are stored securely, whether in physical locked storage or in password-protected electronic systems.
Encryption: Electronic communications and data transfers are encrypted where possible to prevent unauthorized access.
Access Control: Access to your personal and clinical information is limited to Christina Pongracic, LLPC and any authorized personnel directly involved in your care or the administration of the practice. Access is granted on a need-to-know basis only.
Secure Communication: We use a secure, encrypted email service (ProtonMail) for email communication at upwardspiralcounseling@pm.me.
Website Security: Our website uses secure protocols (HTTPS/SSL) to protect data transmitted between your browser and our website.
Professional Standards: We adhere to the ethical standards and guidelines set forth by the State of Michigan licensing board and applicable professional counseling organizations.
Data Breach Procedures: In the event of a data breach that compromises your personal or health information, we will take the following steps:
a. Immediately investigate and contain the breach.
b. Assess the scope and nature of the information affected.
c. Notify affected individuals without unreasonable delay and no later than required by applicable law. Under HIPAA, notification will be provided within 60 days of discovering the breach.
d. Notify the U.S. Department of Health and Human Services (HHS) as required.
e. Provide you with information about what happened, what information was involved, what we are doing to address the breach, and steps you can take to protect yourself.
f. Document the breach and our response for compliance and improvement purposes.
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9. COOKIES AND TRACKING TECHNOLOGIES
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Our website uses cookies and similar tracking technologies to improve your browsing experience and analyze website traffic.
What Are Cookies: Cookies are small text files that are placed on your device when you visit a website. They help the website remember your preferences and understand how you interact with the site.
Types of Cookies We Use:
Essential Cookies: These are necessary for the basic functioning of our website, such as page navigation and access to secure areas. The website cannot function properly without these cookies.
Analytics Cookies: We may use analytics tools (such as those provided by our website hosting platform) to collect information about how visitors use our website. This includes data such as pages visited, time spent on the site, and the referring website. This data is collected in aggregate form and does not personally identify you.
Third-Party Cookies: Some cookies may be set by third-party services that appear on our pages, such as our website hosting provider or embedded content.
Managing Your Cookies: Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all cookies, accept only certain cookies, or notify you when a cookie is being set. Please note that disabling cookies may affect the functionality of our website.
To manage cookies in your browser:
- Chrome: Settings > Privacy and Security > Cookies and Other Site Data
- Firefox: Settings > Privacy & Security > Cookies and Site Data
- Safari: Preferences > Privacy > Manage Website Data
- Edge: Settings > Privacy, Search, and Services > Cookies and Site Permissions
Do Not Track: Our website may not respond to "Do Not Track" signals sent by your browser. However, you can manage your privacy preferences through your browser cookie settings as described above.
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10. WEBSITE ACCESSIBILITY (USERWAY)
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Upward Spiral Counseling LLC is committed to ensuring that our website is accessible to all visitors, including individuals with disabilities.
We use the Accessibility Widget by UserWay, a third-party accessibility tool, to enhance the usability and accessibility of our website. The UserWay widget provides visitors with a range of tools and features to customize their browsing experience, including:
- Screen Reader: Provides auditory feedback for on-screen content, reading aloud text, descriptions, and navigational elements for visually impaired users.
- Contrast Adjustments: Allows users to modify color contrast settings, including invert colors and dark mode, for improved readability.
- Text Resizing: Enables users to increase or decrease the size of on-screen text for better readability.
- Text Spacing: Allows users to adjust line spacing for a more comfortable reading experience.
- Dyslexia-Friendly Fonts: Offers specialized font options designed to improve readability for users with dyslexia.
- Keyboard Navigation Enhancements: Improves navigation for users who rely on a keyboard rather than a mouse.
- Highlight Links: Visually emphasizes hyperlinks so users can quickly identify clickable elements.
- Big Cursor: Enlarges the cursor for better visibility.
- Reading Mask and Reading Guide: Provides visual aids to help users focus on specific areas of text.
- Hide Images: Allows users to remove visual elements and focus solely on text content.
- Tooltips: Displays alt text descriptions when users hover over images.
- Dictionary: Offers definitions and context for words on the page.
The UserWay widget appears as a floating accessibility icon on our website. Clicking this icon opens the accessibility menu where you can customize your settings.
UserWay is designed to help us work toward compliance with the Web Content Accessibility Guidelines (WCAG) 2.1, the Americans with Disabilities Act (ADA), and Section 508 requirements. UserWay does not collect personal information from users who interact with the widget. For more information about UserWay and its privacy practices, please visit https://userway.org.
If you experience any accessibility issues on our website or need assistance, please contact us at upwardspiralcounseling@pm.me or (517) 292-3329. We are committed to making our services accessible to everyone.
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11. NOTICE OF PRIVACY PRACTICES (HIPAA)
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If you receive counseling services from Upward Spiral Counseling LLC, this section describes how your Protected Health Information (PHI) may be used and disclosed, and how you can access this information. Please review it carefully.
Your Rights Regarding Your Protected Health Information:
Right to Access: You have the right to inspect and obtain a copy of your PHI maintained by our practice. To request access, please submit a written request to us. We may charge a reasonable fee for copying and mailing costs.
Right to Amend: If you believe that information in your records is incorrect or incomplete, you have the right to request an amendment. We may deny your request in certain circumstances (e.g., if the information was not created by us or if we determine the records are accurate), and we will provide you with a written explanation if your request is denied.
Right to an Accounting of Disclosures: You have the right to request a list of certain disclosures we have made of your PHI. This does not include disclosures made for treatment, payment, or health care operations, or disclosures you authorized in writing.
Right to Request Restrictions: You have the right to request restrictions on certain uses and disclosures of your PHI. While we will consider your request, we are not required to agree to a restriction.
Right to Request Confidential Communications: You have the right to request that we communicate with you about your health information in a specific way or at a specific location. For example, you may request that we contact you only by email or only at a certain phone number.
Right to a Copy of This Notice: You have the right to obtain a paper copy of this Privacy Policy at any time.
How We May Use and Disclose Your PHI:
For Treatment: We may use your PHI to provide, coordinate, or manage your counseling services. With your written authorization, we may share relevant information with other health care providers involved in your care.
For Payment: We may use your PHI to process payments for services rendered. As a private-pay practice, we do not bill insurance companies. However, if you request a superbill or receipt for insurance reimbursement purposes, limited PHI may be included on those documents.
For Health Care Operations: We may use your PHI for practice management activities such as quality improvement, training, and compliance.
As Required by Law: We may disclose your PHI when required by federal, state, or local law.
For Public Safety: We may disclose your PHI when necessary to prevent a serious and imminent threat to your health or safety or the health or safety of others.
Mandatory Reporting: Michigan law requires mental health professionals to report suspected child abuse, elder abuse, and certain other situations. We are obligated to comply with these reporting requirements.
Judicial and Administrative Proceedings: We may disclose your PHI in response to a court order or subpoena as required by law.
Uses and Disclosures Requiring Your Written Authorization:
We will obtain your written authorization before using or disclosing your PHI for purposes other than those described above. You may revoke your authorization at any time by submitting a written request, although revocation will not affect any disclosures made prior to your request.
Psychotherapy Notes: Psychotherapy notes (private notes kept by your therapist that are separate from your medical record) receive additional protection under HIPAA. We will not release psychotherapy notes without your specific written authorization, except in limited circumstances permitted by law.
Minimum Necessary Standard: When using or disclosing your PHI, we will make reasonable efforts to limit the information to the minimum necessary to accomplish the intended purpose.
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12. YOUR RIGHTS AND RESPONSIBILITIES
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As a client of Upward Spiral Counseling LLC, you have the following rights:
- The right to be informed about how your personal and health information is collected, used, and shared.
- The right to access and review your personal and clinical records upon written request.
- The right to request corrections or amendments to inaccurate information in your records.
- The right to request deletion of your personal information, subject to legal and regulatory retention requirements.
- The right to request restrictions on how your information is used or disclosed.
- The right to receive a copy of this Privacy Policy.
- The right to file a complaint if you believe your privacy rights have been violated.
To exercise any of these rights, please contact us using the information provided in Section 14 below. We will respond to your request within a reasonable timeframe and no later than required by applicable law.
Exceptions: In some cases, we may not be able to fully comply with your request due to legal obligations. For example, we are required to retain clinical records for the minimum period mandated by Michigan law. We will notify you in writing if we are unable to fulfill a request and explain the reason.
Your Responsibilities:
- Provide accurate and complete information to support your care.
- Notify us promptly if your contact information changes.
- Review this Privacy Policy and ask questions if anything is unclear.
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13. UPDATES TO THIS PRIVACY POLICY
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We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or other factors. When we make changes:
- The "Last Updated" date at the top of this policy will be revised.
- If the changes are significant, we will make reasonable efforts to notify you, such as posting a prominent notice on our website or informing you directly during your next session.
- The updated policy will be available on our website at https://www.upwardspiralcounseling.me.
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
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14. CONTACT INFORMATION
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If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your information is being handled, please contact us:
Upward Spiral Counseling LLC
Christina Pongracic, LLPC
Privacy Officer
Address: 42 Union Street, Hillsdale, MI 49242
Phone: (517) 292-3329
Email: upwardspiralcounseling@pm.me
Office Hours: Monday and Wednesday, 10:00 AM to 5:00 PM
If you believe your privacy rights have been violated, you also have the right to file a complaint with:
U.S. Department of Health and Human Services (HHS)
Office for Civil Rights
Website: https://www.hhs.gov/ocr
Phone: 1-800-368-1019
Filing a complaint will not affect your care or your relationship with our practice. We will not retaliate against you for filing a complaint.
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15. SOCIAL MEDIA POLICY
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Upward Spiral Counseling LLC may maintain a presence on social media platforms for educational and informational purposes. Please be aware of the following:
- We will never disclose that you are a client of our practice on any social media platform.
- We will not accept friend or connection requests from current or former clients on personal social media accounts to protect your confidentiality.
- If you choose to interact with our practice on social media (e.g., liking, commenting, or sharing a post), please be aware that this interaction may be visible to others and could potentially reveal your connection to our practice.
- We do not provide therapy, clinical advice, or crisis intervention through social media. If you are in crisis, please call 988 (Suicide and Crisis Lifeline), call 911, or go to your nearest emergency room.
- Any information shared on social media by our practice is for general educational purposes only and should not be considered a substitute for professional counseling.
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16. DISCLAIMERS
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This Privacy Policy is intended to provide clear and transparent information about our data practices. It does not constitute legal advice. While we make every effort to ensure compliance with applicable privacy laws, including HIPAA and Michigan state regulations, this policy should not be relied upon as a substitute for professional legal counsel.
The information provided on our website, including blog content and resources, is for general educational and informational purposes only and does not constitute professional counseling or medical advice. Always consult a qualified healthcare professional for specific concerns related to your mental or physical health.
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices, content, or security of those external sites. We encourage you to review the privacy policies of any third-party site you visit.
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17. CONSENT
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By using our website, contacting our practice, or engaging in counseling services with Upward Spiral Counseling LLC, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.
If you do not agree with this Privacy Policy, please do not use our website or provide us with your personal information. If you have already provided information and wish to withdraw your consent, please contact us at the information provided in Section 14.
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Thank you for trusting Upward Spiral Counseling LLC with your care. Your privacy is important to us, and we are committed to protecting your personal and health information.
Upward Spiral Counseling LLC
42 Union Street, Hillsdale, MI 49242
(517) 292-3329
upwardspiralcounseling@pm.me
https://www.upwardspiralcounseling.me
Copyright 2026 Upward Spiral Counseling LLC. All Rights Reserved.
