Privacy Policy Statement
When you use Brain Integration Therapy & Consulting you trust us with your information. This privacy policy is meant to help you understand what data we collect, why we collect it, and what we do with it. We have tried to make it as simple as possible but if you have any questions please contact us.
Brain Integration Therapy & Consulting assumes the function of data controller and supervises the compliance with General Data Protection Regulation (GDPR) within the business.
1. Information we collect
2. Where we get our information
3. How we use the information we collect
4. Information we share
5. How and when consent is obtained
6. How we protect your data
7. Protecting your rights to data
8. Security of your personal data
1 Information we collect
Brain Integration Therapy & Consulting holds personal data as part of conducting a professional service. The data follows under the following headings: educational records, clinical / training records, general administrative records, financial records.
1.1 Educational records
Relevant Individual Educational Plans (IEPs), progress notes from educational staff and school reports may be held.
1.2 Clinical / training records
Specific data in relation to communication skills may be collected and held such as assessment forms, reports, case notes, e-mails, text messages and transcripts of phone. Audio and video files may also be collected and stored.
1.3 General administrative records
Brain Integration Therapy & Consulting may hold information regarding attendance reports and accident report forms.
1.4 Financial records
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. Brain Integration Therapy & Consulting may hold data in relation to: on-line purchasing history, card payment transactions, receipts and invoices. Information will include name of bill payer, client name, address and record of invoices and payments made.
Brain Integration Therapy & Consulting do not record and keep Credit Card information. Any data given for payment is processed directly via bank transfer, paypal, eventbrite or calendly integrated with paypal.
2 Where we get our information
Personal data will be provided by the client, or in the case of a child (under 16yrs), their parent(s)/guardian(s).
This information will be collected as part of a case history form prior to, or on the date of first contact.
Information may also be provided directly from relevant third parties such as schools, medical professionals and allied health professionals, with prior consent from the parent(s)/guardian(s).
All clients are required to complete and sign either the 1 page Adult, or Child referral form which outlines your data protection rights and our privacy policy.
3 How we use the information that we collect
We use the information we collect to provide assessment, virtual services and teletherapy as per the relevant professional guidelines, as well as to maintain the general running of the business, such as running our electronic booking system, keeping our accounts and updating you of any changes in policies or fees.
3.1 Data retention periods
The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed under confidential means.
3.2 Client Records
3.2.1 Clinical / educational Records
Brain Integration Therapy & Consulting keeps both physical and electronic records of clinical data in order to provide a service.
∙ The preferred format is X for clinical data.
∙ Clinical / educational data is deleted/confidentially destroyed after 2 years from the last invoiced session. (Usually post discharge).
∙ Video records/ voice recordings relating to client care/videoconferencing records may be recorded with consent, analysed and then destroyed. If written consent is provided to use recordings for training purposes, the client will have the option to withdraw consent at any time.
3.2.2 Financial Records
Brain Integration Therapy & Consulting keeps electronic/paper records of financial data from those who use our services. Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be retained for a minimum period of six years after the completion of the transactions, acts or operations to which they relate. These requirements apply to manual and electronic records equally.
∙ Financial Data is kept for 6 years to adhere to Revenue guidelines.
∙ Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.
3.2.3 Contact Data
Contact Data is kept for 6 years to allow processing of Financial Data if required. (This may be retained for longer for safety, legal request, or child protection reasons.)
3.3 Exceptions
If under investigation or if litigation is likely, files must be held in original form indefinitely, otherwise files are held for the minimum periods set out above.
4 Information we share
We do not share personal information with companies, organisations and individuals outside Brain Integration Therapy & Consulting unless one of the following circumstances apply:
4.1 With your consent:
We will share personal information with other relevant health care providers or educational providers when we have your written consent to do so. We require opt-in consent for the sharing of any sensitive information.
4.2 For legal reasons:
We will share personal information with companies or organisations outside of Brain Integration Therapy & Consulting if disclosure of the information is reasonably necessary to:
▪ Meet any applicable law, regulation, legal process or enforceable governmental request.
Confidential. Not for distribution, duplication, or amendment.
▪ Meet the requirements of the Children First Act 2015
▪ To protect against harm to the rights, property or safety of Brain Integration Therapy & Consulting, our service users or the public as required or permitted by law.
4.3 For processing by third parties/external processing
The following third parties are engaged for processing data:
Administrative staff - Record keeping, typing, correspondence, updating records
Accountant - Financial, Processing financial accounts
Siteground
Contact & received files encrypted on Brain Integration Therapy & Consulting bespoke CMS system.
Record keeping of client contact, financial and clinical data in encrypted database.
Microsoft
- Email & Calendar Systems.
- Attached files from main Client Management System
- All scheduling and correspondence through the google meet up and calendly domain and email.
- Backup copy of main Client Management System files and notes.
5 Sharing Data
5.1 Legal requirements
Brain Integration Therapy & Consulting is required to share data with external parties in the following circumstances:
- Compliance with local tax and audit laws.
- Compliance with child protection.
- Compliance with law enforcement.
5.2 Other parties
Any transfers outside the above which contain Personal Identifying Information (PII) to third parties such as hospitals, GPs, nursing homes, are only made once the owner of the data has given express written permission by letter or email to do so.
5.3 Transfer of personal data outside the EEA
Brain Integration Therapy & Consulting has chosen to use companies which reside and have data centres based in the EU. Siteground – Amsterdam data centre Microsoft – Dublin data centre.
6 How and when we obtain consent
Prior to initial assessment or consultation, a copy of the data protection policy will be provided to clients along with a client contract. A consent form will need to be signed by the client prior to commencing in the service. Copies of the signed consent forms and client contract will be given to both parties.
A consent form may also be attached onto any initial bookings via our on-line booking system. Users will be directed to read the privacy statement and to tick to agree to the terms. Services cannot be initiated without ticked consent to our set to privacy policy.
Should a client wish to withdraw their consent for data to be processed, they can do so by contacting Brain Integration Therapy & Consulting through: [email protected].
This will send an immediate email outlining the steps you can take immediately to remove consent, as well as allowing us to follow up with you on any specific requests.
7 How we protect your data
In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways:
7.1 By limiting the data that we collect in the first instance
All data collected by us will be collected solely for the purposes set out at 1 above and will be collected for specified, explicit and legitimate purposes. The data will not be processed any further in a manner that is incompatible with those purposes save in the special circumstances referred to in section 5.1. Furthermore, all data collected by us will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected which include, inter alia, the assessment, home programs, in-person and virtual therapy in an area of childhood neurodevelopmental disorders, special education supporting services and therapies.
7.2 By transmitting the data in certain specified circumstances only Data will only be shared and transmitted, be it on paper, electronically only as is required, and as set out in section 3.
7.3 By keeping only the data that is required,
when it is required and by limiting its accessibility to any other third parties.
7.4 By disposing of/destroying the data once the individual has ceased receiving treatment
within 2 YEARS of the completion of this education or virtual services or teletherapy apart from the special categories of personal data as set out at 1.1 above. Where data is required to be held by us for longer than the period of 2 years we will put in place appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These may include measures such as the encryption of electronic devices, pseudonymisation of personal data, and/or safe and secure storage facilities for paper/electronic records.
7.5 By retaining the data for only as long as is required
which in this case is 2 years except for circumstances in which retention of data is required in circumstances set out at part 1.1 above or in certain specific circumstances as set out at Article 23(1) of the GDPR.
7.6 By destroying the data securely and confidentially after the period of retention has elapsed.
This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.
7.7 By ensuring that any personal data collected and retained is both accurate and up-to-date.
You can request your therapist to update the information directly themselves, or submit a request to amend to [email protected]
8 Protecting your Rights to Data
8.1 Adult clients
Adults have the right to request data held on them as per article 15 of GDPR. A request must be made in writing. Further information regarding accessing your personal data are available in the document ‘Rights of Individuals under the General Data Protection Regulation’, downloadable from: www.gdprandyou.ie
8.2 Children
For children under the age of 16, data access requests are made by their guardians. When a child turns 16, then they may make a request for their personal data. However, this is subject to adherence with the Children First Act.
9 Security
Brain Integration Therapy & Consulting as with most providers of educational services is aware of the need for privacy. As such, we aim to practice privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service.
All persons working in, and with Brain Integration Therapy & Consulting in a professional capacity are briefed on the proper management, storage and safekeeping of data.
All data used by Brain Integration Therapy & Consulting including personal data may be retained in any of the following formats:
1. Electronic Data
2. Physical Files
The type of format for storing the data is decided based on the format the data exists in.
Where applicable, Brain Integration Therapy & Consulting may convert physical files to electronic records to allow us to provide a better service to clients.
9.1 Data Security
Brain Integration Therapy & Consulting understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which we use to ensure that the data is kept safe.
9.1.1 Electronic Data
All electronic data is contained in the following systems:
[CIT]: CMS System used by Brain Integration Therapy & Consulting
- This system is physically located in the Netherlands.
- This system provider is aware of their requirements for GDPR compliance.
- The system has an internal administrator / Database owner. System provider personnel do not have access to CIT data.
- This system has a Live Update for security enabled.
- All persons working in Brain Integration Therapy & Consulting have READ/WRITE/ DELETE access to records.
- All persons require a Log on and Password in order to access the records.
- A copy of the files are made on the users’ computer when in use.
- The data controller can remove or delete users.
- The data controller can change users passwords.
[Microsoft 365]:
- This system is physically located in Ireland.
- This system provider is aware of their requirements for GDPR compliance.
- The system has an internal administrator. System provider personnel do not have access to password data.
- This system has a Live update for security enabled.
- All persons have READ/WRITE/ DELETE access to their own emails.
- All persons have READ access to their colleagues calendars.
- All persons require a Log on and Password in order to access the records.
- A copy of the files are made on the users’ computer when in use.
- The data controller can remove or delete users.
- The data controller can force user password changes.
9.1.2 Physical Files
All physical data is located in:
Dublin
- This system is physically located at Dublin
- Only Brain Integration Therapy & Consulting have access to these records.
- These records are kept in a secured location within the building.
9.2 Security Policy
9.2.1 Brain Integration Therapy & Consulting understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the data controller in Brain Integration Therapy & Consulting reviews the electronic and physical storage options available at Brain Integration Therapy & Consulting every 6 months.
9.2.2 All physical devices (including mobile phones) used by persons working in Brain Integration Therapy & Consulting which may contain any identifiable PII are enabled with loss theft tracking and remote wipe abilities.
9.2.3 All persons working in Brain Integration Therapy & Consulting are aware and briefed on and refresh the requirements for good data hygiene every 12 months. This briefing compliance is monitored by Brain Integration Therapy & Consulting data controller and includes, but is not limited to:
▪ Awareness of client conversations in unsecure locations.
▪ Enabling auto-lock on devices when leaving them unattended.
▪ Use of non-identifiable note taking options. (initials, not names).
▪ The awareness of Brain Integration Therapy & Consulting procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files.
Date of document: 01/05/2023
When you use Brain Integration Therapy & Consulting you trust us with your information. This privacy policy is meant to help you understand what data we collect, why we collect it, and what we do with it. We have tried to make it as simple as possible but if you have any questions please contact us.
Brain Integration Therapy & Consulting assumes the function of data controller and supervises the compliance with General Data Protection Regulation (GDPR) within the business.
1. Information we collect
2. Where we get our information
3. How we use the information we collect
4. Information we share
5. How and when consent is obtained
6. How we protect your data
7. Protecting your rights to data
8. Security of your personal data
1 Information we collect
Brain Integration Therapy & Consulting holds personal data as part of conducting a professional service. The data follows under the following headings: educational records, clinical / training records, general administrative records, financial records.
1.1 Educational records
Relevant Individual Educational Plans (IEPs), progress notes from educational staff and school reports may be held.
1.2 Clinical / training records
Specific data in relation to communication skills may be collected and held such as assessment forms, reports, case notes, e-mails, text messages and transcripts of phone. Audio and video files may also be collected and stored.
1.3 General administrative records
Brain Integration Therapy & Consulting may hold information regarding attendance reports and accident report forms.
1.4 Financial records
A financial record pertains to all financial information concerning the practice, e.g. invoices, receipts, information for Revenue. Brain Integration Therapy & Consulting may hold data in relation to: on-line purchasing history, card payment transactions, receipts and invoices. Information will include name of bill payer, client name, address and record of invoices and payments made.
Brain Integration Therapy & Consulting do not record and keep Credit Card information. Any data given for payment is processed directly via bank transfer, paypal, eventbrite or calendly integrated with paypal.
2 Where we get our information
Personal data will be provided by the client, or in the case of a child (under 16yrs), their parent(s)/guardian(s).
This information will be collected as part of a case history form prior to, or on the date of first contact.
Information may also be provided directly from relevant third parties such as schools, medical professionals and allied health professionals, with prior consent from the parent(s)/guardian(s).
All clients are required to complete and sign either the 1 page Adult, or Child referral form which outlines your data protection rights and our privacy policy.
3 How we use the information that we collect
We use the information we collect to provide assessment, virtual services and teletherapy as per the relevant professional guidelines, as well as to maintain the general running of the business, such as running our electronic booking system, keeping our accounts and updating you of any changes in policies or fees.
3.1 Data retention periods
The retention periods are the suggested time periods for which the records should be held based on the organisation’s needs, legal and/or fiscal precedence or historical purposes. Following the retention deadline, all data will be destroyed under confidential means.
3.2 Client Records
3.2.1 Clinical / educational Records
Brain Integration Therapy & Consulting keeps both physical and electronic records of clinical data in order to provide a service.
∙ The preferred format is X for clinical data.
∙ Clinical / educational data is deleted/confidentially destroyed after 2 years from the last invoiced session. (Usually post discharge).
∙ Video records/ voice recordings relating to client care/videoconferencing records may be recorded with consent, analysed and then destroyed. If written consent is provided to use recordings for training purposes, the client will have the option to withdraw consent at any time.
3.2.2 Financial Records
Brain Integration Therapy & Consulting keeps electronic/paper records of financial data from those who use our services. Section 886 of the Direct Tax Acts states that the Revenue Commissioners require records to be retained for a minimum period of six years after the completion of the transactions, acts or operations to which they relate. These requirements apply to manual and electronic records equally.
∙ Financial Data is kept for 6 years to adhere to Revenue guidelines.
∙ Financial Data (including non-payment of bills) can be given to Revenue at Revenue’s request.
3.2.3 Contact Data
Contact Data is kept for 6 years to allow processing of Financial Data if required. (This may be retained for longer for safety, legal request, or child protection reasons.)
3.3 Exceptions
If under investigation or if litigation is likely, files must be held in original form indefinitely, otherwise files are held for the minimum periods set out above.
4 Information we share
We do not share personal information with companies, organisations and individuals outside Brain Integration Therapy & Consulting unless one of the following circumstances apply:
4.1 With your consent:
We will share personal information with other relevant health care providers or educational providers when we have your written consent to do so. We require opt-in consent for the sharing of any sensitive information.
4.2 For legal reasons:
We will share personal information with companies or organisations outside of Brain Integration Therapy & Consulting if disclosure of the information is reasonably necessary to:
▪ Meet any applicable law, regulation, legal process or enforceable governmental request.
Confidential. Not for distribution, duplication, or amendment.
▪ Meet the requirements of the Children First Act 2015
▪ To protect against harm to the rights, property or safety of Brain Integration Therapy & Consulting, our service users or the public as required or permitted by law.
4.3 For processing by third parties/external processing
The following third parties are engaged for processing data:
Administrative staff - Record keeping, typing, correspondence, updating records
Accountant - Financial, Processing financial accounts
Siteground
Contact & received files encrypted on Brain Integration Therapy & Consulting bespoke CMS system.
Record keeping of client contact, financial and clinical data in encrypted database.
Microsoft
- Email & Calendar Systems.
- Attached files from main Client Management System
- All scheduling and correspondence through the google meet up and calendly domain and email.
- Backup copy of main Client Management System files and notes.
5 Sharing Data
5.1 Legal requirements
Brain Integration Therapy & Consulting is required to share data with external parties in the following circumstances:
- Compliance with local tax and audit laws.
- Compliance with child protection.
- Compliance with law enforcement.
5.2 Other parties
Any transfers outside the above which contain Personal Identifying Information (PII) to third parties such as hospitals, GPs, nursing homes, are only made once the owner of the data has given express written permission by letter or email to do so.
5.3 Transfer of personal data outside the EEA
Brain Integration Therapy & Consulting has chosen to use companies which reside and have data centres based in the EU. Siteground – Amsterdam data centre Microsoft – Dublin data centre.
6 How and when we obtain consent
Prior to initial assessment or consultation, a copy of the data protection policy will be provided to clients along with a client contract. A consent form will need to be signed by the client prior to commencing in the service. Copies of the signed consent forms and client contract will be given to both parties.
A consent form may also be attached onto any initial bookings via our on-line booking system. Users will be directed to read the privacy statement and to tick to agree to the terms. Services cannot be initiated without ticked consent to our set to privacy policy.
Should a client wish to withdraw their consent for data to be processed, they can do so by contacting Brain Integration Therapy & Consulting through: [email protected].
This will send an immediate email outlining the steps you can take immediately to remove consent, as well as allowing us to follow up with you on any specific requests.
7 How we protect your data
In accordance with the General Data Protection Regulation (GDPR), we will endeavour to protect your personal data in a number of ways:
7.1 By limiting the data that we collect in the first instance
All data collected by us will be collected solely for the purposes set out at 1 above and will be collected for specified, explicit and legitimate purposes. The data will not be processed any further in a manner that is incompatible with those purposes save in the special circumstances referred to in section 5.1. Furthermore, all data collected by us will be adequate, relevant and limited to what is necessary in relation to the purposes for which it is collected which include, inter alia, the assessment, home programs, in-person and virtual therapy in an area of childhood neurodevelopmental disorders, special education supporting services and therapies.
7.2 By transmitting the data in certain specified circumstances only Data will only be shared and transmitted, be it on paper, electronically only as is required, and as set out in section 3.
7.3 By keeping only the data that is required,
when it is required and by limiting its accessibility to any other third parties.
7.4 By disposing of/destroying the data once the individual has ceased receiving treatment
within 2 YEARS of the completion of this education or virtual services or teletherapy apart from the special categories of personal data as set out at 1.1 above. Where data is required to be held by us for longer than the period of 2 years we will put in place appropriate technical and organisational measures to ensure a level of security appropriate to the risk. These may include measures such as the encryption of electronic devices, pseudonymisation of personal data, and/or safe and secure storage facilities for paper/electronic records.
7.5 By retaining the data for only as long as is required
which in this case is 2 years except for circumstances in which retention of data is required in circumstances set out at part 1.1 above or in certain specific circumstances as set out at Article 23(1) of the GDPR.
7.6 By destroying the data securely and confidentially after the period of retention has elapsed.
This could include the use of confidential shredding facilities or, if requested by the individual, the return of personal records to the individual.
7.7 By ensuring that any personal data collected and retained is both accurate and up-to-date.
You can request your therapist to update the information directly themselves, or submit a request to amend to [email protected]
8 Protecting your Rights to Data
8.1 Adult clients
Adults have the right to request data held on them as per article 15 of GDPR. A request must be made in writing. Further information regarding accessing your personal data are available in the document ‘Rights of Individuals under the General Data Protection Regulation’, downloadable from: www.gdprandyou.ie
8.2 Children
For children under the age of 16, data access requests are made by their guardians. When a child turns 16, then they may make a request for their personal data. However, this is subject to adherence with the Children First Act.
9 Security
Brain Integration Therapy & Consulting as with most providers of educational services is aware of the need for privacy. As such, we aim to practice privacy by design as a default approach, and only obtain and retain the information needed to provide you with the best possible service.
All persons working in, and with Brain Integration Therapy & Consulting in a professional capacity are briefed on the proper management, storage and safekeeping of data.
All data used by Brain Integration Therapy & Consulting including personal data may be retained in any of the following formats:
1. Electronic Data
2. Physical Files
The type of format for storing the data is decided based on the format the data exists in.
Where applicable, Brain Integration Therapy & Consulting may convert physical files to electronic records to allow us to provide a better service to clients.
9.1 Data Security
Brain Integration Therapy & Consulting understands that the personal data used in order to provide a service belongs to the individuals involved. The following outlines the steps which we use to ensure that the data is kept safe.
9.1.1 Electronic Data
All electronic data is contained in the following systems:
[CIT]: CMS System used by Brain Integration Therapy & Consulting
- This system is physically located in the Netherlands.
- This system provider is aware of their requirements for GDPR compliance.
- The system has an internal administrator / Database owner. System provider personnel do not have access to CIT data.
- This system has a Live Update for security enabled.
- All persons working in Brain Integration Therapy & Consulting have READ/WRITE/ DELETE access to records.
- All persons require a Log on and Password in order to access the records.
- A copy of the files are made on the users’ computer when in use.
- The data controller can remove or delete users.
- The data controller can change users passwords.
[Microsoft 365]:
- This system is physically located in Ireland.
- This system provider is aware of their requirements for GDPR compliance.
- The system has an internal administrator. System provider personnel do not have access to password data.
- This system has a Live update for security enabled.
- All persons have READ/WRITE/ DELETE access to their own emails.
- All persons have READ access to their colleagues calendars.
- All persons require a Log on and Password in order to access the records.
- A copy of the files are made on the users’ computer when in use.
- The data controller can remove or delete users.
- The data controller can force user password changes.
9.1.2 Physical Files
All physical data is located in:
Dublin
- This system is physically located at Dublin
- Only Brain Integration Therapy & Consulting have access to these records.
- These records are kept in a secured location within the building.
9.2 Security Policy
9.2.1 Brain Integration Therapy & Consulting understands that requirements for electronic and physical storage may change with time and the state of the art. As such, the data controller in Brain Integration Therapy & Consulting reviews the electronic and physical storage options available at Brain Integration Therapy & Consulting every 6 months.
9.2.2 All physical devices (including mobile phones) used by persons working in Brain Integration Therapy & Consulting which may contain any identifiable PII are enabled with loss theft tracking and remote wipe abilities.
9.2.3 All persons working in Brain Integration Therapy & Consulting are aware and briefed on and refresh the requirements for good data hygiene every 12 months. This briefing compliance is monitored by Brain Integration Therapy & Consulting data controller and includes, but is not limited to:
▪ Awareness of client conversations in unsecure locations.
▪ Enabling auto-lock on devices when leaving them unattended.
▪ Use of non-identifiable note taking options. (initials, not names).
▪ The awareness of Brain Integration Therapy & Consulting procedure should a possible data breach occur, either through malicious (theft) or accident (loss) of devices or physical files.
Date of document: 01/05/2023
BRAIN INTEGRATION THERAPY & CONSULTING 2026 All Rights Reserved
Registrations with professional bodies:
The Teaching Council of Ireland. Reg. No: 168807, IAFNR - The Interdisciplinary Association of Functional NeuroSciences and Rehabilitation, USA, Melillo Method ™, Interactive Metronome, DPA Developmental Practitioner Association, UK. Professional certification trainings received from a few organisations, such as:
      
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IRELAND'S LOCATION:
Brain Integration Therapy, 69 Windermere, Dublin, D15W2K2, Ireland |
POLAND'S LOCATION:
ul Chrobrego 43, 40-881 Katowice, Poland |
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Brain Integration Therapy and Consulting provides educational therapeutic support services delivered by a registered special education teacher (Teaching Council of Ireland, Reg. 168807) and certified Melillo Method™ and Interactive Metronome practitioner. All services are educational and developmental in nature — not medical services. No medical claims are made. Services are not intended to diagnose, treat, cure, or prevent any disease or condition.
Brain Integration Therapy and Consulting provides educational therapeutic support services delivered by a registered special education teacher (Teaching Council of Ireland, Reg. 168807) and certified Melillo Method™ and Interactive Metronome practitioner. All services are educational and developmental in nature — not medical services. No medical claims are made. Services are not intended to diagnose, treat, cure, or prevent any disease or condition.