A Note on HIPAA

The Health Insurance Portability and Accountability Act (HIPAA) sets privacy and security rules for "covered entities," such as health care providers who bill health plans electronically, and their business associates. Our coaching services are not billed to insurance and are not health care treatment, so we do not believe we are a HIPAA covered entity.

Even so, we know that health information you share with us is sensitive. As a matter of good practice and out of respect for you, we voluntarily follow privacy and security standards modeled on HIPAA for health-related information we receive from clients. This voluntary commitment does not make us a covered entity, and it does not give you rights under HIPAA beyond those described in this policy. If we ever become a covered entity, we will provide a separate Notice of Privacy Practices.

Information We Collect

Information you give us

● Contact details, such as your name, email address, phone number, and WhatsApp number

● Intake or discovery call information, goals, and background you choose to share

● Health-related information you share in sessions or messages, such as your diagnosis (for example, MacTel), symptoms, or care experiences

● Notes, worksheets, and assessments you complete

● Scheduling, communication, and feedback preferences, including accessibility needs

Information created through our work together

● Coaching session notes

● Session recordings, when applicable (see Section 7)

● Records of emails, messages, and scheduling

Payment Information

● Payments are processed by Stripe (including Stripe, Venmo, credit card, Apple Pay, Pay in 4, and Pay Monthly). We do not store your full card or bank details. We receive confirmation of payment and basic transaction details.

Website information

● Technical data such as IP address, browser type, pages viewed, and cookies, collected through standard website tools [list analytics, scheduling, or email tools you use].

You are never required to share health information, but the more you choose to share, the more personalized our coaching can be.

How We Use Your Information

We use your information to:

● Provide, schedule, and personalize coaching services

● Communicate with you between sessions and send session reminders

● Process payments and keep business records

● Improve our programs and website

● Send updates or marketing emails, only with your consent and always with an option to opt out

● Comply with legal obligations and protect our rights

We do not sell your personal information or health information, and we do not use it for third-party advertising. We will not use or share your health information for marketing without your separate written permission.

How We Share Information

We share information only when needed and only as described here:

Service providers who help us deliver services, such as video conferencing, scheduling, email, messaging, payment processing, and secure file storage. We choose providers with reasonable security practices and share only what is necessary. [Where possible, we use providers that offer business associate agreements or equivalent privacy protections.]

● Our contractors or representatives, solely to fulfill our obligations to you, and bound by confidentiality.

● With your written permission, for example, if you ask us to coordinate with another professional.

● Broad, de-identified advocacy themes, as described in Section 5.

● When the law requires it, such as in response to a valid court order or subpoena.

● To prevent serious harm, if we reasonably believe someone is at imminent risk of serious harm.

● Business transfer. If our business is sold or reorganized, information may transfer to the new owner, who must honor this policy.

Our Patient Advocacy Role and Relationship with Neurotech

Please read this section carefully. It describes a financial relationship that you have a right to know about.

Melissa R. Williams is a patient advocate and ambassador for people living with MacTel and does paid contract work with Neurotech Pharmaceuticals, Inc. ("Neurotech"), the manufacturer of Encetlto©

[Confirm the company's legal name and the exact scope of your role.] This work is separate from our coaching services.

What this means for you

● Our coaching programs are not sponsored, run, or endorsed by Neurotech, and Neurotech does not have access to our coaching records.

● Coaching is not medical advice, and we do not recommend any treatment. Decisions about your care, including whether to use Encetlto© or any other treatment, are yours to make with your own health care providers. Your coaching experience will not depend on your treatment choices.

What we may share As part of our advocacy work, we may share broad, general themes about what people with MacTel are experiencing or saying, in order to advocate for better education programs and support for the MacTel community. Any such sharing will:

● Be combined across many people and described in general terms

● Not include your name, contact information, or any details that could reasonably identify you, even indirectly. Because MacTel is rare, we take extra care that general themes could not point to a specific person.

● Not include session recordings, session notes, or your individual stories

What we will not do

● We will not share information that identifies you with Neurotech or any other company without your separate, written authorization, which you may decline or withdraw at any time.

● We will not sell your information or use what you share in coaching to market products to you.

Your choices You may tell us at any time that you do not want your experiences included in any general themes we share, and we will honor that. Opting out will not affect your coaching services in any way.

Safety reporting [Include only if applicable under your contract.] If you tell us about a possible side effect or safety concern involving Encetlto©, we may be required to pass certain details to Neurotech or to regulators. If this applies, we will tell you before doing so and share only what is required.

Group Coaching

In group sessions, other participants will see and hear you and may learn health-related details you choose to share. We ask all participants to sign a group confidentiality agreement and keep what they hear private. However, we cannot guarantee that other participants will honor it. Please share only what you are comfortable sharing with the group. You can always raise sensitive topics in a private session instead.

Session Recordings

Some sessions may be recorded to provide your services. We will tell you in advance when a session is recorded, why, how it will be used, and who can access it. Group sessions will not be recorded without participants' consent. You may ask us not to record, or ask us to delete a recording, subject to any legal obligation to retain it.

Communication Channels and Their Risks

We offer email, WhatsApp, and video calls for convenience. These tools may not be fully secure. To protect your privacy:

● Please do not send urgent medical information, passwords, or financial account numbers by email or WhatsApp.

● Use a private device and network for sessions when possible.

● Contact us if you would prefer a different method. By using these channels, you acknowledge the inherent risks. These channels are not monitored for emergencies. In an emergency, call 911 or, for a mental health crisis, call or text 988.

How We Protect Your Information

We use administrative, technical, and physical safeguards that are reasonable for our size, including:

● Limiting access to people who need it to provide services

● Using strong passwords, multi-factor authentication where available, and device encryption

● Storing records in secured, access-controlled systems

● Training anyone who works with us on confidentiality

● Keeping only the information we need

Data Breaches

If we learn of a breach that affects your personal or health information, we will investigate promptly. We will notify you and any regulators without unreasonable delay, as required by applicable laws, including Ohio law and any federal or state health breach notification rules that apply.

.

How Long We Keep Information

We keep client records only as long as needed for the purposes described in this policy, to meet legal, tax, and accounting requirements, and to resolve disputes. [Insert retention period, for example, 7 years after your last session.] After that, we securely delete or de-identify them.

Your Rights and Choices

You may ask us to:

● Access the personal information we hold about you and receive a copy

● Correct information that is inaccurate or incomplete

● Delete your information, subject to legal retention requirements

● Limit how we use or share your information

● Receive a list of disclosures we have made of your health information, other than those you authorized or that were needed to provide services

● Withdraw consent for optional uses, such as marketing, at any time

● Request communications in a certain way or at a certain location

To make a request, contact us using the details in Section 16. We may need to verify your identity, and we will respond within [30] days. Depending on where you live, you may have additional rights under state privacy laws, and we will honor them as required

Cookies and Website Tracking

Our website uses cookies and similar tools to make the site work and to understand how it is used. You can control cookies in your browser settings. [If you use tracking pixels or analytics, disclose them here and confirm they are not placed on pages where health information is collected.] We do not respond to "Do Not Track" signals.

Children's Privacy

Our services are intended for adults 18 and older. We do not knowingly collect information from children. If you believe a child has given us information, please contact us and we will delete it.

Clients Outside Ohio and Outside the United States

We are based in Ohio, and information is stored and processed in the United States. If you live elsewhere, your information will be transferred to the U.S. By using our services, you consent to this transfer. Some states and countries give residents additional privacy rights, and we will comply with them where they apply to us.

16. Patient Advocacy Role and Disclosure of Relationship

Melissa R. Williams is a patient advocate and ambassador for people living with MacTel and does paid contract work with Neurotech Pharmaceuticals, Inc. ("Neurotech"), the manufacturer of Encetlto©©. This work is separate from, and not part of, the coaching services offered by Point of Light Life Coaching.

By using our services, you acknowledge that:

● Our coaching programs are not sponsored or endorsed by Neurotech, and nothing we say is a recommendation for or against any medical treatment, including Encetlto©. Decisions about your care should be made with your own health care providers.

● As part of her advocacy work, the Coach may share broad, general themes about what people with MacTel are experiencing or saying, in order to advocate for education and support programs. These themes are combined and described in general terms, and they will not include your name, contact details, session recordings or notes, or any information that could reasonably identify you.

● We will not share information that identifies you with Neurotech or any other company without your separate written authorization.

● You may tell us at any time that you do not want your experiences included in these general themes. Doing so will not affect your coaching services in any way

Contact Us

For questions, requests, or privacy concerns:

Melissa R. Williams, Privacy Contact Stellar Effects LLC, DBA Point of Light Life Coaching Email: [email protected]/[email protected]

If you believe your privacy rights have been violated, you may contact us first, and you also have the right to file a complaint with the Ohio Attorney General or the U.S. Federal Trade Commission. We will not retaliate against you for filing a complaint.

Changes to This Policy

We may update this policy from time to time. We will post the updated version with a new "Last updated" date and, for material changes, notify you by email.