NOTICE OF PRIVACY PRACTICES

BEHAVIORAL HEALTH LINK

Privacy Policy & Notice of Privacy Practices

Effective Date: April 10, 2026

Last Revised: April 10, 2026

Review Cadence: Annually, or upon material regulatory or operational changes

 

Questions or complaints about this policy may be directed to:

BHL Chief Compliance Officer

Email: [email protected]

 

1. Introduction

Behavioral Health Link (“BHL”), an IHR Corp company, is a HIPAA-compliant behavioral health crisis management platform provider operating across multiple U.S. states. BHL operates two business lines: a software-as-a-service (SaaS) clinical platform and clinical mobile crisis response services.

This document serves a dual purpose: (1) it is BHL’s Website Privacy Policy, describing how BHL collects and uses information from visitors to its public marketing website (behavioralhealthlink.com); and (2) it is BHL’s Notice of Privacy Practices under HIPAA, describing how BHL handles protected health information (PHI) in the course of its clinical platform and services operations.

BHL functions as a HIPAA Business Associate with respect to PHI it receives from its government agency customers, and as a HIPAA Covered Entity with respect to PHI it collects and maintains through its own clinical mobile crisis response services.

 

2. Website Privacy Policy

This section applies to the BHL public marketing website at behavioralhealthlink.com and any other BHL-operated informational websites. It does not apply to BHL’s clinical SaaS platform or patient-facing applications, which are governed by separate BAA-based data processing agreements with BHL’s government agency customers.

2.1 Information We Collect

Account Information. When you create or update a BHL account, we collect user-identifiable information such as first name, last name, email address, phone number, postal address, and user passwords. We may also collect system or regional identifiers.

Geolocation Information. We may request permission to collect location-based information from your device. The precision of location data collected depends on your device type and settings. You may modify our access permissions via your device settings, though opting out of location collection may affect certain service features.

Communication Information. We collect the content of messages exchanged between you and other users or groups, including any file attachments.

Website Usage Data. When you visit behavioralhealthlink.com, we automatically collect certain information about your visit, including IP address, browser type, operating system, referring URLs, pages viewed, and time spent on pages. This information is collected via cookies and analytics tools described in Section 2.3 below.

2.2 Data Retention

BHL retains information until it is no longer needed for the purposes for which it was collected or to satisfy legal and contractual obligations. Retention decisions consider: contractual and regulatory compliance requirements, legitimate business interests such as platform improvement and security, and the exercise or defense of legal claims. Website analytics data is retained in accordance with the retention policies of the applicable analytics provider.

2.3 Cookies and Online Tracking Technologies

BHL’s public marketing website (behavioralhealthlink.com) uses cookies and related technologies to understand how visitors interact with the site and to improve our marketing and web experience. The following describes the types of tracking technologies we use and their business purposes:

Analytics Cookies. We use web analytics tools (such as Google Analytics or similar services) to collect aggregated, non-personally identifiable data about website traffic, page performance, and visitor behavior. This helps us understand which content is most useful to visitors and improve the site over time.

Functional Cookies. These cookies enable core website functionality such as session management and user preference retention. They are necessary for the website to operate correctly.

Marketing/Advertising Technologies. We may use tracking pixels or similar technologies on our marketing website to measure the effectiveness of our outreach and understand how visitors arrived at our site. We do not use these technologies to build individual advertising profiles or sell visitor data to third parties.

IMPORTANT: No cookies, tracking pixels, analytics tools, advertising technologies, or session replay tools are deployed on any patient-facing portal, clinician-facing application, or any component of the BHL clinical SaaS platform. All such systems are HIPAA-compliant and operate under strict data handling controls that prohibit third-party tracking technologies.

2.4 Cookie Consent and Opt-Out

When you first visit behavioralhealthlink.com, you will be presented with a cookie consent notice. You may accept all cookies, accept only necessary cookies, or manage your preferences. You may also opt out of analytics tracking at any time by:

  • Adjusting your preferences via the cookie consent banner on the website
  • Using your browser’s built-in cookie controls to block or delete cookies
  • Opting out of Google Analytics tracking at: https://tools.google.com/dlpage/gaoptout

Please note that disabling certain cookies may affect the functionality of the website.

2.5 Third-Party Data Processors

BHL uses third-party service providers to operate analytics and marketing functions on its public website. These providers process data on BHL’s behalf and are contractually required to protect the data they receive. BHL does not sell visitor data to third parties and does not permit third-party providers to use visitor data for their own independent marketing purposes.

2.6 Privacy Policy Updates

BHL reviews this Privacy Policy at least annually and whenever material changes occur in our data practices, applicable technology, or relevant privacy regulations. When we make material changes, we will update the “Last Revised” date at the top of this document. We encourage users to review this policy periodically. Continued use of our website following the posting of changes constitutes acceptance of the updated policy.

2.7 Applicable Privacy Regulations

BHL’s operations span multiple U.S. states, and we are committed to compliance with applicable federal and state privacy laws including, but not limited to:

  • Health Insurance Portability and Accountability Act (HIPAA), as applicable
  • California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), for California residents
  • Virginia Consumer Data Protection Act (CDPA), for Virginia residents
  • Georgia state privacy laws, including HIV/AIDS confidentiality provisions
  • Other applicable state behavioral health privacy statutes across BHL’s 13-state operating footprint

Residents of states with applicable consumer privacy rights (including the right to access, correct, or delete personal data) may submit requests to BHL’s Compliance Officer at the contact information provided at the top of this policy.

 

3. Notice of Privacy Practices (HIPAA)

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU MAY ACCESS THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

3.1 Understanding Your Health Information

Each visit to a health provider or service is documented in a health information record to support your care. This record typically contains your symptoms, assessments or evaluations, test results, diagnoses, communications among health professionals contributing to your care, and a treatment plan. It describes the BHL services and any referrals you received from BHL or any of its programs, serves as a data source for organizational planning, and helps BHL continually assess and improve services and outcomes.

Understanding what is in your record and how your health information is used helps ensure its accuracy. It also helps you make informed decisions about authorizing disclosure of your health information to others.

An authorization gives written permission for specific disclosures only. In circumstances other than those involving services and healthcare operations, a separate authorization will be required before information is released. Authorization is also required before release of notes from conversations between you and a BHL-licensed clinical staff member during telephone conversations or any private individual, group, joint, or family counseling evaluation or session. These notes are afforded greater protection under law than other health information.

3.2 Your Health Information Rights

BHL will compile a health information record that is the physical property of BHL; however, the information belongs to you. You have the right to:

  • Request a paper copy of this Notice of Privacy Practices
  • Revoke your authorization to use or disclose health information, except when action has already been taken
  • Review the information in your record (which may be denied under certain circumstances)
  • Request an amendment to your health record (which may be denied)
  • Request a restriction on certain uses and disclosures of your information (BHL is not required to agree to all restrictions)
  • Obtain an accounting of disclosures of your health information
  • Request communications concerning your health information by other means or at other locations

A request for any of these modifications should be addressed in writing to the BHL Chief Compliance Officer at [email protected].

3.3 BHL’s Responsibilities

BHL will protect your health information and provide you with a notice about our legal duties and privacy practices regarding the information we collect and maintain. BHL will abide by the terms of this notice and notify you if we cannot agree to a requested restriction or accommodate any requests you may have to communicate health information by other means or at other locations.

BHL reserves the right to change its privacy practices. If practices change, a revised notice will be provided to you upon request.

BHL is subject to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) as a Business Associate when BHL receives your health information from a covered entity customer, and as a Covered Entity when BHL directly delivers clinical mobile crisis response services. BHL complies with HIPAA and all other federal and state privacy laws, and with the privacy provisions of its Business Associate Agreements and other contractual relationships.

BHL will not use or disclose your health information without authorization except as described in this notice or as otherwise authorized by HIPAA. If you believe your privacy rights have been violated, you may file a complaint with the BHL Chief Compliance Officer or with the Secretary of the U.S. Department of Health and Human Services. There will be no retaliation for filing a complaint.

3.4 Disclosures for Treatment and Health Operations

Your health information will be recorded in your record and used to determine the course of treatment that should work best for you. Copies of this record will be provided to a healthcare provider and/or facility to assist you when you are referred for treatment.

Your health information may be used to assess the services and outcomes in your case and others like it. This information will then be used to continually improve the quality and effectiveness of BHL’s services.

3.5 Other Permitted Uses or Disclosures

Child, Elder, Disabled, or Domestic Abuse. If there is reasonable cause to believe that a child, elderly person, or disabled adult has been abused, neglected, or exploited, a report will be filed with the proper authorities.

Threats to Health or Safety. If it is believed that you are a danger to yourself or someone else, your information may be disclosed to provide protection to you or the intended victim.

Legal Proceedings. If you are involved in a court proceeding and there is a question concerning your records or services provided by BHL, that information will not be released without your written consent or a court order. If you are being evaluated pursuant to a court order, you will be informed in advance, and the privilege of confidentiality is not applicable.

Correctional Institution. If you are an inmate of a correctional institution, BHL may disclose to the institution or its agents health information necessary for your health and the health and safety of other individuals.

Health Oversight. If any licensed clinical staff member is investigated by their respective licensing board, disclosure of protected health information may be required.

Business Associates. BHL contracts with Business Associates to provide certain services. When these services are contracted, we may disclose your health information to our Business Associates so they can perform contracted services. Business Associates are required to safeguard and protect your health information appropriately.

Workers’ Compensation. To comply with laws related to workers’ compensation, your protected health information may be disclosed as authorized by law to provide benefits for work-related injuries or illness.

3.6 Confidentiality of Substance Use and HIV/AIDS Records

For individuals who have received treatment, diagnosis, or referral for treatment from substance use programs, the confidentiality of those records is protected by federal and state law (42 U.S.C. § 290dd-2 and 42 C.F.R. Part 2). As a general rule, BHL may not disclose that you attend any such program or disclose information identifying you as a substance user unless:

  • You authorize the disclosure in writing
  • The disclosure is permitted by a court order
  • The disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation
  • You threaten to commit a crime at the program or against any person who works for BHL

A violation of federal law governing substance use record confidentiality is a crime. Suspected violations may be reported to the appropriate U.S. Attorney. Federal law permits BHL to report suspected child abuse or neglect to appropriate state or local authorities.

BHL staff are prohibited by state law from intentionally or knowingly disclosing information regarding the HIV/AIDS status of a consumer. HIV/AIDS confidential information may be disclosed only:

  • To a parent or guardian if the patient is a minor or is incompetent
  • To persons designated by the consumer in writing

Upon consultation among BHL Directors, the Medical Director, and legal counsel, disclosure that a consumer is infected with HIV to a spouse, sexual partner, or child may be considered appropriate under Georgia state privacy standards if: there is agreement among BHL Directors, Medical Director, licensed clinician, coordinating health care providers, and BHL legal counsel that the person is at risk of being infected; and every attempt has been made to contact the infected consumer to discuss disclosure; or when disclosure is otherwise authorized by state or federal law. (Reference: Ga. Code Ann. § 24-9-47.)

 

4. Contact Information

For questions, concerns, or to exercise any of your rights described in this policy, please contact:

 

Behavioral Health Link — Chief Compliance Officer

IHR Corp / Behavioral Health Link

Email: [email protected]

Website: https://behavioralhealthlink.com

 

You also have the right to file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, at:

https://www.hhs.gov/ocr/privacy/hipaa/complaints/

There will be no retaliation for filing a complaint.

 

5. Policy Change Log

BHL maintains a change log to document material revisions to this policy. The most recent revision history is as follows:

 

April 10, 2026 — Initial version incorporating Website Privacy Policy (including cookies and tracking technology disclosures), effective date, last revised date, review cadence, multi-state privacy rights, HIPAA dual-role clarification, and typographical corrections. Policy restructured into unified document.

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