PRIVACY POLICY

Comprehensive Resource Model (CRM)® Privacy Policy

Comprehensive Resource Model (“CRM®”) is dedicated to supporting trauma healing through professional education and training. In the conduct of business, we may obtain information that is personal to individuals. As an organization committed to protecting the privacy of users, CRM® would like to describe how we collect, use, and handle your information when you use our website and other services. As used in this Privacy Policy (“Policy”), “personal information” refers to any information that may be used to identify you personally, such as name, address, email or telephone number. We respect the value of your privacy and are committed to maintaining the confidentiality of personal information we collect in accordance with this Policy.

I. General Policy

A. Information Collection & Use

CRM® may collect several types of information from and about you when you visit, register for a program/training, or place an order on our website.

  • Information You Give Us. When you sign up for our mailing list, we collect your contact information, which consists of name, email address, city, state, and country/provence. When you register for a training, CRM® stores and uses your personal information to verify completion of each training module and eligibility to attend trainings with specific prerequisites. We also provide CRM® students with access to contact information for approved CRM® Personal Session and Case Consultation Providers. Session and Consult Providers are placed on this list for the purpose of supporting students in their learning and growth of CRM® conceptualization and application. Session Providers and Consult Providers may opt out from the list by sending an e-mail to Carol Muller, carol@comprehensiveresourcemodel.com.

  • Information We Collect Through Our Website. For general visitors to our website, CRM® uses Google Analytics, which collects anonymized data, including page information, browser information, and user information as described below:

    • Page information: Each time a user visits a page on our website, we collect the URL and the title of the page the user is viewing.

    • Browser information: Users of our website also have their browser information collected through Squarespace, which is integrated with Google Analytics. This information includes the name of the user’s browser, the size of the browser window, the resolution of the user’s screen, what version of Flash the user is currently using, and whether or not the user has Java enabled.

    • User information: CRM® collects the user’s location from the IP address where the hit originated, as well as the user’s language from the user’s browser settings.

  • Payment Information: To place an order/purchase a training, intensive, webinar or service on our website. In order to process your payment, we use a third-party payment processor. Your payment will be processed by PayPal, a service which collects, uses and processes your information, including payment information, in accordance with their privacy policies: https://www.paypal.com/us/legalhub/paypal/privacy-full

  • Testimonials, Evaluations, Surveys, and other feedback: CRM® may share personal testimonials on our website, with your consent and your name alongside it. If you wish to update or remove your testimonial, please contact us on our CONTACT page. CRM® does not intend to receive any SENSITIVE PERSONAL INFORMATION (which may include information relating to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, the sex life of the individual, ideological views or activities, social security measures pertaining to an individual, or administrative or criminal proceedings and sanctions). We also do not intend to share any such Sensitive Personal Information with third parties. Neither our vendors or independent contractors nor any individuals should provide any Sensitive Personal Information to us.

  • Information Collected Regarding Mental Health/Trauma History: CRM® may collect mental health/trauma history of select students who explicitly consent to share such information in some of our trainings and workshops for use in the demonstrations (“demos”) part of the training only. The purpose of such information is to provide students with an additional learning tool, so they can observe the application of the concepts being taught. Students are given the option to not to disclose mental health/trauma history information. Every student present where any such information may be introduced is also bound by confidentiality agreements to not disclose any such sensitive information that may be potentially introduced during these events. All such information, whether or not introduced, will be disposed by the faculty member at the conclusion of each training event.

B. Reason for Data Collection

All data and personal information collected through our website and trainings is done in order to provide, protect, and better our services. As such, any information collected through our website may be used for the following purposes:

  • To improve website and customer service based on user feedback;

  • To detect fraud or abuses of our website (in cases where IP addresses are collected);

  • To process payment transactions for business purposes only and provide users with information, products, and services they request

  • For communication purposes, such as periodic emails

  • To allow users to participate in online content, access and/or download materials, and use any of the interactive features on the website; and

  • To fulfill any other purpose for which you provide it or with your consent.

C. Third Parties with Whom We May Share Your Personal Information

CRM® does not sell, trade, or rent your personal information to any third parties. However, we may, in accordance with this Policy, share your Personal Information with the following types of third parties:

  • Service providers: This includes our domestic training coordinators, international training organizers, training assistants, and faculty members who work as employees or contractors for CRM®.

  • Students attending our professional trainings, but only as it pertains to contact information of other training participants and only to the extent of which such information is listed on rosters during the course of the training;

We may share your Personal Information with such third parties for the following purposes:

  • In order for such third parties to provide services to training attendees;

  • For purposes of verifying identity and/or correcting training attendees’ personal information for communication purposes related to the provision of services; and

  • For purposes surrounding Ethical Grievances

CRM® will take reasonable steps to ensure that third parties receiving personal information are subject by contractual obligations to comply with this Policy.

D. Opt Out and Choice

In connection with our use of your personal information for communication purposes, you have the choice of opting out and/or unsubscribing from CRM®’s emails and mailing lists. You may also request to be removed from our database at any time and we will respond to such requests as soon as is reasonably possible. To submit such requests, please send an e-mail to Carol Muller at carol@comprehensiveresourcemodel.com.

E. Demo Library Users: Accessing and Correcting Your Information

If you are a registered user of our video content library, CRM® will store your username. You can update your personal information and change your password by logging into your account. If you need to reset your password, edit or delete your username and account, please email Carol Muller at carol@comprehensiveresourcemodel.com.

II. PROVISIONS APPLICABLE TO CALIFORNIA RESIDENTS

A. Accessing, Correcting, or Updating Your Personal Information

You have the option to review and/or request changes to your Personal Information collected by CRM®. If you would like to do so, please submit a written request providing sufficient identifying information to CRM® at carol@comprehensiveresourcemodel.com.

B. Do Not Track Disclosures

Currently CRM® does not respond to browser “Do Not Track” signals.

C. Cookies

CRM® uses cookies on our website, which enables the site to recognize your browser and capture and remember certain information, such as traffic and site interaction. CRM® uses cookies to detect fraud and other abuses to the website. If you prefer, you can choose to turn off all cookies via your browser settings or have your computer warn you each time a cookie is being sent.

D. Data Security

CRM® takes commercially reasonable efforts, precautions and proactive measures to protect your data against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. However, CRM® cannot guarantee the security of Personal Information on or transmitted via the Internet, since no internet or e-mail transmission is ever fully secure or error free.

E. Onward Transfer

CRM® does not share your Personal Information to any third parties except to fulfill the purposes for which the information was disclosed or for the purposes outlined in this Policy. For more details, see the sectioned of this Policy entitled “Third Parties with Whom We May Share Your Personal Information.”

D. Access

EU individuals have the right to access their Personal Information upon written request to the address provided in the “CONTACT US” section of this Policy below. CRM® will allow individuals to amend, correct or delete any of their Personal Information in its possession that it is inaccurate or processed in a manner inconsistent with this Policy. Please be aware that individuals wanting to access their information will need to provide sufficient identifying information. In addition, CRM® retains limited registration information related to services provided (e.g. name, contact, and training history) as long as the student is active or as needed to provide services, as well as for accounting, audit, and compliance purposes.

F. Data Integrity & Limitations on Data Use

CRM® shall only process and use Personal Information in a way that is compatible with and relevant for the purpose for which it was provided. To the extent necessary for those purposes, CRM® shall take reasonable efforts to ensure that Personal Information in our possession is accurate, complete, current and reliable for its intended use.

G. Opt Out & Sensitive Personal Information

In accordance with this Policy, and except in connection with transfers to third parties performing tasks directly on our behalf and pursuant to specific instructions, we will offer the individual the opportunity to choose (“opt out”) (1) whether such information is disclosed to a third party; or (2) used for a purpose other than the purpose for which consent was provided. Anyone wishing to opt out can do so by contacting CRM® at the contact provided below under the section of this Policy entitled “CONTACT US.” Where CRM®receives Personal Information regarding EU individuals directly from a third-party vendor or independent contractor (and not the individual to whom the Personal Information relates,) we will cooperate with our third parties reasonable requests to:

  • Assist them in informing the impacted individuals about (a) the possibility that we may disclose such individuals’ information to third parties and (b) the individual’s ability to opt out of such disclosures (except for disclosures to third parties performing tasks directly on our behalf and pursuant to our instructions); and

  • Reasonably ensure that CRM® processes the information for purposes compatible with those for which it was originally collected or subsequently authorized by the impacted individuals

Our vendors and/or independent contractors will then inform CRM® if any such individuals have opted out of such disclosures. With the exception of mental health/trauma history in a select number of our programs (see paragraph below for detailed information), CRM® does not intend to receive any SENSITIVE PERSONAL INFORMATION (which may include information relating to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the sex life of the individual, ideological views or activities, social security measures pertaining to an individual, or administrative or criminal proceedings and sanctions). We also do not intend to share any such Sensitive Personal Information with third parties. Neither our vendors or independent contractors nor any individuals should provide any Sensitive Personal Information to us.

  • Information Collected Regarding Mental Health/Trauma History. CRM® collects mental health/trauma history of select students who explicitly consent to share such information in some of our trainings and workshops for use in the demonstrations (“demos”) part of the training only. The purpose of such information is to provide students with an additional learning tool, so they can observe the application of the concepts being taught. Students are given the option of not to disclose mental health/trauma history information and potentially be chosen for the demo. Every student present where any such information may be introduced is also bound by confidentiality agreements to not disclose any such sensitive information that may be potentially introduced during these events. All such information, whether or not introduced, will be disposed by the faculty member at the conclusion of each training event.

III. THIRD PARTY LINKS

We may occasionally offer third party products or services on our website. Please be aware that these third-party sites have separate and independent privacy policies and therefore CRM® has no responsibility or liability for the content and activities of these linked sites.

IV. LEGALLY REQUIRED DISCLOSURES

Please be aware the CRM® may be required to disclose Personal Information pursuant to lawful requests (including subpoenas, warrants, and court or government agency orders) made by public authorities or as otherwise required by law.

V. CONTACT US

If you have questions or concerns about CRM®, our Services, and/or Privacy Policy, please contact us by email at carol@comprehensiveresourcemodel.com.

VI. CHANGES TO OUR PRIVACY POLICY

CRM® reserves the right to amend this policy from time to time. In the event changes are made, we will update the Privacy Policy modification date below. If a revision meaningfully reduces your rights, we will notify you by email so long as you are still on our mailing list. This policy was last modified on August 12, 2025.