Privacy Policy
Preamble and Acceptance
This Privacy Policy explains how the American College of Psychoanalysts, available at https://americancollegeofpsychoanalysts.com, processes personal information associated with access to, navigation of, communication with, and use of the website.
The American College of Psychoanalysts is presented through this website as an international academic-editorial and educational project focused on advanced psychoanalytic knowledge, research, scholarship, intellectual development, and related fields.
The website may publish articles, essays, reference materials, academic-style analyses, historical studies, educational materials, bibliographic resources, research discussions, and other content concerning psychoanalysis, psychology, mental health, psychiatry, neuroscience, humanities, ethics, and related areas.
The website is not a hospital, clinic, medical practice, psychotherapy service, psychoanalytic treatment service, telehealth platform, or emergency mental health service.
The website does not provide medical or psychological diagnoses, psychotherapy, psychoanalytic treatment, prescriptions, clinical assessments, individualized treatment plans, or emergency care.
The use of the words “American College” or “College” in the website's name does not, by itself, constitute a representation that the website is an accredited postsecondary institution, a university, a state-authorized degree-granting institution, a professional licensing board, or an institution eligible to award academic degrees or professional licenses.
Any future representation concerning accreditation, degree-granting authority, governmental approval, professional recognition, institutional affiliation, continuing education credit, or licensing eligibility must be supported by accurate and verifiable documentation applicable to the specific claim.
By accessing or using the website, visitors acknowledge this Privacy Policy. When consent is legally required for a specific processing activity, consent will be requested in an informed, specific, and appropriate manner.
United States federal law and applicable state privacy laws will govern processing activities when their respective jurisdictional requirements are satisfied. This may include, where applicable, the California Consumer Privacy Act as amended by the California Privacy Rights Act, the Children's Online Privacy Protection Act, the Federal Trade Commission Act, and other federal or state laws.
Where the territorial requirements of Regulation (EU) 2016/679, the General Data Protection Regulation, are satisfied, the relevant provisions of the GDPR will also be observed.
Data Controller and Data Protection Officer (DPO)
For transparency purposes, American College of Psychoanalysts is the public editorial designation used for the operation presented through this website.
The name itself does not establish the existence of a corporation, licensed medical organization, physical campus, hospital, professional licensing authority, or accredited degree-granting institution.
The person or entity that actually determines the purposes and means of a specific personal information processing activity will be treated as the relevant controller or business under the law applicable to that activity.
Dr. William Carter is presented as the editorial persona associated with the website. This editorial role does not automatically make Dr. William Carter a formally appointed Data Protection Officer.
The website's privacy contact is dr.williamcarter@americancollegeofpsychoanalysts.com.
United States federal privacy law does not generally require every website to appoint a Data Protection Officer. If Article 37 of the GDPR, the UK GDPR, or another applicable law requires a formal DPO appointment for a specific processing operation, the appropriate designation and contact information will be disclosed as required.
Legal Definitions
For purposes of this Policy, the following terms are used according to applicable privacy law:
- Personal information or personal data: information relating to an identified or identifiable individual, as defined by applicable law.
- Sensitive personal information: information receiving heightened legal protection because of its nature, which may include health information, racial or ethnic origin, religious beliefs, sexual orientation, precise geolocation, biometric information, or other protected categories depending on the applicable jurisdiction.
- Processing: an operation performed on personal information, including collection, use, storage, disclosure, analysis, organization, transmission, and deletion.
- Consumer or data subject: an individual whose personal information is processed and who receives rights under applicable law.
- Controller: the person or organization that determines the purposes and essential means of processing under applicable data protection law.
- Service provider or processor: an organization that processes information on behalf of another entity under applicable legal requirements.
- Consent: an affirmative authorization satisfying the requirements of the law applicable to the particular processing operation.
- Cookies: files, identifiers, or similar technologies used for technical functionality, security, preferences, analytics, advertising, or other disclosed purposes.
- Clinical data: health information generated or collected for diagnosis, treatment, clinical assessment, therapy, patient care, or similar health-service purposes.
- Profiling: automated or systematic analysis used to evaluate or predict aspects concerning an individual where applicable under relevant privacy law.
Information We Collect
Information Voluntarily Provided
When visitors contact the website, submit a question, send correspondence, or use an available form, the website may process information such as name, email address, subject, institutional affiliation voluntarily provided by the visitor, and message content.
General website forms are not intended for medical records, psychotherapy notes, psychoanalytic session transcripts, diagnoses, prescriptions, psychological assessments, patient histories, or other clinical information.
Technical and Navigation Information
Technical information may be processed when users visit the website, including Internet Protocol address, date and time of access, browser type, operating system, device type, requested pages, technical identifiers, approximate traffic source, and security events.
Analytics Information
Where analytics technologies are actually implemented, information concerning page views, approximate session duration, referral sources, clicks, technical performance, and other audience metrics may be processed.
Academic and Professional Communications
Communications relating to academic articles, research proposals, interviews, conferences, educational projects, publications, institutional inquiries, or scholarly collaboration may contain names, professional contact information, affiliations, and information voluntarily supplied by the sender.
Such information will be used only for purposes compatible with the relevant communication and applicable law.
The American College of Psychoanalysts does not intentionally collect clinical data for diagnosis, patient assessment, psychotherapy, psychoanalytic treatment, or other individualized healthcare purposes.
Legal Bases for Processing
In the United States, privacy obligations depend on the nature of the information, the entity involved, the user's location, the purpose of processing, and the scope requirements of the applicable federal or state statute.
Where the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to the responsible business, processing will be conducted consistently with the rights and obligations established in California Civil Code sections 1798.100 and following.
Where COPPA applies, personal information collected online from children under 13 will be processed according to 15 U.S.C. sections 6501 through 6506 and 16 CFR Part 312.
Where processing is subject to the GDPR, a valid legal basis under Article 6 will be identified. Special-category data, including health data, will additionally require a condition permitted by Article 9.
Depending on the specific activity, GDPR bases may include consent, performance of a contract, compliance with legal obligations, protection of vital interests, or legitimate interests where legally permissible and appropriately balanced.
Where UK GDPR applies, the corresponding legal bases and protections will be observed.
Where Peru's Law No. 29733 applies to a particular operation, its applicable consent, transparency, security, and data-subject rights requirements will be observed.
General access to the website from another jurisdiction does not automatically cause every privacy law of that jurisdiction to apply to every website operation.
Purposes of Processing
Personal information may be processed, as appropriate, to:
- operate and secure the website;
- deliver requested pages and educational materials;
- respond to correspondence and inquiries;
- manage editorial and academic communications;
- manage comments if such functionality is offered;
- record privacy and cookie preferences;
- prevent spam, fraud, abuse, unauthorized access, and cybersecurity threats;
- identify technical failures;
- produce audience and website-performance statistics where legally appropriate;
- understand aggregate interest in academic and psychoanalytic topics;
- improve website accessibility and organization;
- maintain appropriate author, source, and publication attribution;
- comply with legal obligations;
- respond to lawful governmental or judicial requests;
- establish, exercise, or defend legal rights;
- investigate security incidents.
Interest in an article concerning depression, trauma, psychosis, anxiety, sexuality, personality, or another mental health topic will not, by itself, be treated by the website as evidence that the visitor has the condition discussed.
Sensitive Data and Mental Health
THE AMERICAN COLLEGE OF PSYCHOANALYSTS DOES NOT INTENTIONALLY COLLECT CLINICAL DATA FOR DIAGNOSIS, PSYCHOANALYTIC TREATMENT, PSYCHOTHERAPY, CLINICAL SCREENING, OR PATIENT CARE.
The website may publish educational materials concerning mental illness, psychological suffering, trauma, depression, anxiety, sexuality, suicide, psychoanalytic concepts, psychiatry, or other potentially sensitive subjects.
READING AN ARTICLE ABOUT A MENTAL HEALTH CONDITION DOES NOT CAUSE THE WEBSITE TO DIAGNOSE THE VISITOR WITH THAT CONDITION.
The website will not use a visitor's reading history alone to characterize that visitor as depressed, psychotic, traumatized, suicidal, narcissistic, anxious, or as having another mental health diagnosis or psychoanalytic structure.
The website is not designed to create patient records or psychotherapy records and is not intended to function as a healthcare record system.
Visitors should not transmit protected health information, psychotherapy notes, identifiable patient case material, medical records, or confidential clinical information through general website contact channels.
If sensitive information is voluntarily and incidentally included in a communication, it will not become a clinical record merely because it was received by the website.
Such information should be minimized, restricted, or deleted where appropriate and legally permissible.
The website's described editorial activities are not intended to establish a HIPAA-regulated treatment relationship. If a future operation creates obligations under HIPAA, the FTC Health Breach Notification Rule, or another health privacy regime, separate compliance measures will be implemented as required.
Where GDPR Article 9 applies, health information and other special-category personal data will receive the protections required by that provision.
Cookies and Tracking Technologies
The website may use cookies and similar technologies for technical functionality, cybersecurity, privacy preferences, analytics, and other disclosed purposes.
- Strictly necessary cookies: technologies required to operate, secure, or deliver essential website functionality.
- Functional cookies: technologies used to remember requested preferences or features.
- Analytics cookies: technologies used to understand aggregate audience behavior and website performance.
- Advertising or cross-context behavioral technologies: technologies used for advertising or related tracking only where actually implemented and subject to applicable legal requirements.
Optional technologies should not be represented as strictly necessary when they are not essential to the requested service.
Where consent is required under GDPR, UK GDPR, ePrivacy-related requirements, or another applicable law, optional technologies will not be activated until an appropriate choice has been made.
Where the CCPA applies and a technology constitutes a sale or sharing of personal information under California law, users will receive the opt-out mechanisms required by that law.
Where legally required, recognized opt-out preference signals such as the Global Privacy Control will be honored.
The website should not create sensitive advertising audiences based solely on a visitor reading mental health content.
Sharing with Third Parties
The website does not have, as its own stated editorial purpose, the commercial sale of readers' personal information.
Personal information may be disclosed on a limited basis to providers necessary for website operations, such as hosting, cybersecurity, email, forms, content delivery, analytics, backups, and technical infrastructure.
Each provider may act as a service provider, processor, contractor, or independent business or controller depending on the applicable legal framework and the actual service performed.
Information should be limited to what is appropriate and reasonably necessary for the relevant purpose.
If advertising technology or another practice that qualifies as a sale or sharing under California law is implemented, required notices and opt-out rights will be provided where the CCPA applies.
Information may also be disclosed to courts, regulators, law-enforcement agencies, or other parties where required by valid legal process, applicable law, or the establishment or defense of legal rights.
International Data Transfers
Because the website is international in scope, technology providers may process information in the United States or other countries.
Where GDPR applies to a transfer of personal data outside the European Economic Area, appropriate mechanisms under Articles 44 through 49 will be considered, including adequacy decisions, Standard Contractual Clauses, or another legally available mechanism.
Where UK GDPR applies, the corresponding international transfer mechanisms will be used when required.
Where Brazilian LGPD applies to a specific operation, Articles 33 through 36 of Law No. 13,709/2018 and applicable ANPD regulations will be observed.
Where Peru's Law No. 29733 applies, applicable international transfer and data security requirements will be observed.
International processing will not eliminate the obligation to apply reasonable security, transparency, purpose limitation, and data minimization measures.
Retention and Deletion
Personal information will be retained only for as long as reasonably necessary for the purpose for which it was processed, subject to legal, security, archival, evidentiary, and rights-protection requirements.
General communications may be retained for a reasonable period necessary to respond, maintain editorial records, prevent abuse, or protect legal rights.
Academic or editorial records associated with authorship, publication history, licensing, permissions, or source attribution may be retained where necessary to preserve legitimate records.
Sensitive information unnecessarily included in general communications should be minimized or deleted when technically and legally appropriate.
Where COPPA applies, children's personal information will not be retained longer than reasonably necessary for the purpose for which it was collected, subject to the requirements of the COPPA Rule.
Where California law applies, deletion requests will be addressed subject to statutory exceptions.
Where GDPR applies, storage limitation requirements under Article 5 will be observed.
Rights of Individuals
California Privacy Rights
Where the CCPA applies, eligible California consumers may have rights that include:
- the right to know the categories and specific pieces of personal information collected, subject to legal requirements;
- the right to request deletion, subject to exceptions;
- the right to request correction of inaccurate personal information;
- the right to opt out of the sale or sharing of personal information where applicable;
- the right to limit certain uses and disclosures of sensitive personal information where the statutory requirements apply;
- the right to receive information concerning categories of sources, purposes, and recipients as required by law;
- the right not to receive unlawful discriminatory treatment for exercising applicable privacy rights.
GDPR Rights
Where the GDPR applies, individuals may have rights under Articles 12 through 22, including access, rectification, erasure, restriction, portability, objection, withdrawal of consent, and rights associated with certain automated decisions.
Other Jurisdictions
Where UK GDPR applies, the corresponding rights will be honored.
Where Brazilian LGPD applies, the rights under Article 18 of Law No. 13,709/2018 will be observed.
Where Peru's Law No. 29733 applies, the rights established under that framework will be respected.
How to Exercise Your Rights
Privacy requests may be submitted to dr.williamcarter@americancollegeofpsychoanalysts.com.
Reasonable verification may be required to prevent unauthorized access, alteration, disclosure, or deletion of personal information.
The website will not request excessive information where a less intrusive method is reasonably sufficient to verify the request.
Requests will be evaluated according to the law applicable to the specific user and processing activity.
Where an authorized agent may exercise a right under applicable California law, reasonable evidence of that authority may be requested.
If a request cannot be granted in whole or in part, the reason may be provided where required or appropriate under applicable law.
Information Security
The website seeks to maintain reasonable technical and organizational safeguards appropriate to the nature and risk of the personal information processed.
Measures may include HTTPS, software updates, authentication controls, administrative access restrictions, least-privilege practices, backups, malware and abuse protection, technical logging, and provider review.
Clinical records or identifiable patient case materials should not be used as ordinary website-development, editorial, or artificial intelligence test data.
No Internet-connected system can be guaranteed to be completely secure.
Security is therefore treated as an ongoing process involving prevention, detection, response, recovery, and improvement.
Where a security breach triggers notification duties under applicable federal or state law, affected individuals and competent authorities will be notified in accordance with the applicable legal standard.
Children and Minors
The website is intended for an academic and general adult audience and is not designed as an online service directed primarily to children under 13.
Under the Children's Online Privacy Protection Act, 15 U.S.C. sections 6501 through 6506, and 16 CFR Part 312, specific requirements apply to operators of websites or online services directed to children under 13 and to certain operators with actual knowledge that they are collecting personal information online from a child under 13.
The website does not intentionally solicit personal information from children under 13 through general contact functionality.
If the website learns that personal information was collected from a child under 13 in circumstances requiring parental authorization under COPPA, appropriate steps will be taken consistent with the applicable rule.
Where verifiable parental consent is required, the relevant functionality will not rely on a minor's unsupported representation as a substitute for the legally required process.
Children and teenagers should not be encouraged to publicly disclose diagnoses, abuse, self-harm, sexuality, family conflict, or other sensitive personal information through comments or contact forms.
Where GDPR or UK GDPR provisions concerning children apply to a particular service, the applicable age and parental authorization requirements will also be observed.
Changes to this Policy
This Policy may be revised as laws, regulations, technologies, website functions, educational activities, or editorial practices change.
The Policy should be reviewed before implementing newsletters, accounts, admissions functionality, student portals, paid courses, certification systems, behavioral advertising, artificial intelligence systems, interactive assessments, or other features that materially change personal information processing.
If the website begins offering formal educational enrollment, academic credentials, clinical services, or services specifically directed to children, this Policy must be reassessed before those activities are launched.
The current version will be made available through the website.
Supervisory and Enforcement Authorities
In the United States, privacy and consumer protection matters may fall within the jurisdiction of the Federal Trade Commission, state Attorneys General, the California Privacy Protection Agency where applicable, and other competent regulators depending on the subject matter.
California consumers may also have rights administered or enforced under California privacy law when its scope requirements are satisfied.
Where GDPR applies, an individual may have the right to lodge a complaint with a competent European supervisory authority.
Where UK GDPR applies, the UK Information Commissioner's Office may have supervisory jurisdiction.
Where Brazilian LGPD applies, the Brazilian National Data Protection Authority may have jurisdiction.
Where Peruvian data protection law applies, the competent Peruvian data protection authority may have jurisdiction.
Contact
Questions concerning this Privacy Policy or privacy rights may be submitted to:
American College of Psychoanalysts
Website: https://americancollegeofpsychoanalysts.com
Editorial contact: Dr. William Carter.
Email: dr.williamcarter@americancollegeofpsychoanalysts.com
Nature of the website: international academic-editorial and educational project focused on psychoanalytic knowledge and scholarship.
Primary jurisdiction: USA.
Last Updated
Original effective date: March 17, 2020.
Legal consolidation of this version: August 31, 2026.