Privacy Policy

The Brook Haven Group – A Stream to Safety (“The Brook Haven Group,” “Company,” “we,” “our,” “us”)

Effective Date: [March 6, 2026]

Last Updated: [March 6, 2026]

1. Scope and Purpose

This Privacy Policy describes how we collect, use, store, share, and protect information obtained through:

1. our website and any pages, forms, and online scheduling tools linked from it (collectively, the “Website”);

2. communications with us by phone, SMS/text, email, social media, or other channels; and

3. services we provide, which may include supervised visitation, respite services, AFL services, family support services, and referrals for therapy, medication management, or related resources (collectively, the “Services”).

This Privacy Policy applies to visitors, prospective clients, clients, parents/guardians, caregivers, family members, and other parties who interact with our Website or Services (“you,” “your”).

Important: This Privacy Policy is not a substitute for professional legal advice. It is intended to provide transparency and set expectations for how information is handled.

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2. Key Definitions

• “Personal Information” means information that identifies or can reasonably be linked to an individual (e.g., name, phone number, email, address, ID numbers where applicable).

• “Sensitive Information” includes information about minors, vulnerable adults, safety concerns, allegations, custody disputes, court matters, protective orders, mental health, developmental needs, medication information, and similar.

• “Protected Information” means Personal Information and Sensitive Information, including any documents or records created in the course of Services (visit notes, incident reports, attendance logs, check-in/out records, communication logs, and other case records).

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3. Information We Collect

We collect information in three main ways: (A) information you provide; (B) information generated through Services; and (C) information collected automatically online.

A. Information You Provide

Depending on your relationship to the Services, you may provide:

• Full name, date of birth (where applicable), and contact information (phone, email, address)

• Relationship to child(ren) or client(s) (parent, guardian, caregiver, agency, attorney, etc.)

• Intake information, scheduling preferences, availability, and service requests

• Emergency contact details

• Copies of court orders, parenting plans, visitation orders, protective orders, and related documents

• Party/participant details needed to coordinate visits (names of parties, children, approved adults, pickup/drop-off instructions)

• Safety concerns and restrictions (e.g., no-contact restrictions, supervised exchange requirements, weapons restrictions, substance restrictions, known triggers, de-escalation strategies)

• Payment-related details (billing address, payment confirmation and receipts). We do not want you to email full payment card numbers. If you pay online, your card information is typically processed by our payment processor (see Section 10).

B. Information Created or Documented During Services

During the delivery of Services, we may create and maintain records such as:

• Sign-in/sign-out logs and attendance records

• Supervised visitation session notes and observation logs

• Incident reports (including safety-related events)

• Communication logs (calls, texts, emails related to scheduling and compliance)

• Internal case notes regarding safety planning and service coordination

• Documentation required by county partners, agencies, or applicable standards

• Records of referrals provided (e.g., therapy or medication management referrals)

C. Information Collected Automatically on the Website

When you visit our Website, we may automatically collect:

• IP address, device type, browser type, operating system

• Approximate location (city/state level) based on IP

• Website interactions (pages viewed, time spent, clicks, referral source)

• Cookies and similar technologies (see Section 8)

We may also receive information about you from:

• County/government agencies, courts, or caseworkers (as authorized)

• Caregivers/guardians or approved parties (as needed for Services)

• Third-party providers used for scheduling, forms, messaging, and payments (see Section 10)

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4. How We Use Information

We use Protected Information for legitimate business and service-related purposes, including:

A. Service Delivery & Safety

• Provide supervised visitation, respite, AFL, and related services

• Coordinate scheduling, check-ins, exchanges, and safety protocols

• Verify visitation requirements and participant eligibility

• Maintain documentation for accountability, safety, and compliance

• Support de-escalation planning and child/vulnerable-adult safety

B. Communication & Support

• Respond to inquiries and requests

• Provide appointment reminders and service updates

• Send administrative messages (policy updates, closures, changes)

• Communicate with approved agencies, guardians, or authorized parties

C. Legal, Compliance, and Operations

• Comply with applicable laws, regulations, subpoenas, and court orders

• Maintain accurate records and handle complaints or disputes

• Prevent fraud, misuse, threats, or safety risks

• Enforce our policies, terms, and service agreements

• Maintain insurance, risk management, and quality assurance

D. Website & Business Improvement

• Improve website performance and user experience

• Analyze traffic and service interest

• Evaluate and improve our Services and operations

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5. Legal Bases for Processing

Where applicable, we process information based on one or more of the following:

• Consent (e.g., you submit an intake form, agree to communication, or provide documents)

• Performance of services (e.g., providing supervised visitation or respite/AFL services)

• Legal obligation (e.g., compliance with a valid legal request)

• Legitimate interests (e.g., safety, operational integrity, recordkeeping, fraud prevention)

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6. Confidentiality, Court-Related Information, and Neutrality

Many of our Services involve sensitive family situations. We treat information with discretion and professionalism.

Neutrality: Our staff and documentation are intended to remain neutral and objective. Documentation may include factual observations related to attendance, behavior, and safety compliance.

No Legal Advice: We do not provide legal advice. Nothing on our Website or in our Services should be interpreted as legal counsel.

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7. Supervised Visitation Records and Recordings

A. Documentation

Supervised visitation often requires accurate records. We may document:

• Attendance, arrival/departure times

• Compliance with program rules

• Safety concerns and observable behaviors

• Disruptions, incidents, or policy violations

B. Recording (Audio/Video)

If permitted and appropriate, The Brook Haven Group may record supervised visitation sessionsfor quality assurance, safety, training, documentation, or legal compliance purposes, in accordance with applicable North Carolina law and any controlling court orders.

Recording practices (when used) may include:

• Visible recording equipment in designated areas

• Restricted access to recordings

• Retention and deletion schedules (see Section 12)

• Sharing only as authorized in Section 9

Important: Where a court order, program policy, or applicable law prohibits recording, we will not record (or we will limit recording) to comply.

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8. Cookies, Analytics, and Tracking

We may use cookies or similar technologies to:

• Remember preferences

• Understand usage patterns

• Improve site performance and security

You can control cookies through your browser settings. Disabling cookies may limit certain website features.

We may use analytics providers (e.g., website traffic measurement tools). These tools may collect device and usage information to provide aggregated reporting.

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9. How We Share Information

We do not sell your Personal Information. We share information only as necessary and appropriate, including:

A. With Your Authorization or Direction

We may share information when you request or consent to it, such as with:

• a caseworker or agency

• an attorney (if you direct us)

• a caregiver or guardian (as authorized)

B. With Agencies, Courts, and Legal Authorities

We may disclose information:

• to comply with a valid subpoena, court order, or legal process

• to governmental agencies when required by law

• as part of mandated reporting obligations (see Section 11)

C. With Service Providers (“Vendors”)

We may share limited information with vendors who help us operate, such as:

• website hosting providers

• secure form/scheduling platforms

• email/SMS communication platforms

• payment processors

• secure storage providers

These vendors are expected to use information only to provide services to us and to protect it.

D. For Safety, Security, and Rights Protection

We may disclose information if we believe it is necessary to:

• prevent harm or threats to a child, client, staff, or the public

• investigate fraud, abuse, or policy violations

• protect our rights, property, and safety

E. Business Transfers

If we undergo a merger, acquisition, reorganization, or asset sale, information may be transferred as part of that transaction, subject to confidentiality protections.

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10. Third-Party Links and Tools

Our Website may include links to third-party sites or tools (such as scheduling, payment, or forms). We are not responsible for third-party privacy practices.

Payments: If you pay online, your payment card details are typically processed by a third-party processor. We may receive payment confirmations and limited billing information, but we do not store full card numbers in our systems unless explicitly stated.

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11. Mandated Reporting and Safety Disclosures

Because our Services may involve children and vulnerable adults, we may have obligations under applicable law to report concerns involving:

• suspected abuse or neglect

• threats of harm to self or others

• imminent safety risks

If we believe disclosure is necessary to protect a child, vulnerable adult, or the public, we may disclose information to appropriate authorities or emergency contacts.

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12. Data Retention

We retain Protected Information for as long as reasonably necessary to:

• provide Services

• comply with legal obligations

• meet court, county, or contractual requirements

• resolve disputes and enforce agreements

• maintain safety and operational records

Retention periods may vary depending on service type, legal requirements, and contractual obligations. When information is no longer needed, we take reasonable steps to delete or de-identify it.

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13. Data Security

We use reasonable safeguards designed to protect information from unauthorized access, alteration, disclosure, or destruction. These may include:

• access controls and limited staff access

• administrative policies and training

• secure systems and reputable vendors

• secure storage practices for sensitive records

No method of transmission or storage is 100% secure. You use the Website and provide information at your own risk.

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14. Your Choices and Rights

Depending on your location and the nature of the Services, you may have the right to:

• request access to certain information we hold

• request corrections

• request deletion (where legally permitted)

• withdraw consent for certain communications

Limitations: We may deny requests where we must retain information for legal reasons (e.g., court compliance, safety documentation, or contractual obligations).

To make a request, contact us using the details in Section 18.

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15. Communications, SMS/Texting, and Email

If you contact us by text, phone, or email, you understand:

• These methods may not be fully secure.

• We use them primarily for scheduling, updates, and administrative communication.

• You should avoid sending highly sensitive documents by unencrypted email unless instructed to use a secure upload method.

Opt-Out: You may opt out of non-essential messages by replying “STOP” to SMS (if applicable) or contacting us directly. We may still send essential service-related messages (appointments, safety-related updates).

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16. Children’s Privacy

Our Website is not intended for children to use independently. We do not knowingly collect personal information directly from children through the Website without a parent/guardian or authorized adult submitting it.

If you believe a child has provided personal information through the Website, contact us and we will take appropriate steps.

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17. Non-Discrimination

We will not discriminate against individuals for exercising privacy rights.

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18. Contact Us

The Brook Haven Group – A Stream to Safety

107 Gillespie St Suite B

Fayetteville, NC 28301

Phone: (910) 203-1600

Email: info@thebrookhavengrp.com

Website: www.thebrookhavengrp.com

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19. Updates to This Privacy Policy

We may update this policy from time to time. Any changes will be posted on this page with a new “Last Updated” date. Continued use of the Website after updates means you accept the revised policy.

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20. Disclaimer Regarding Court Use of Records

Records created by The Brook Haven Group may be requested by authorized parties, agencies, or courts through lawful process. We do not guarantee that records will be interpreted a certain way, and we do not advocate for either party. Our documentation is intended to support safety, compliance, and accountability.