Notice of Privacy Practices

Draft for review — pending counsel. This document describes Saludlink's current practices and is not yet final. It is pending review by qualified legal counsel and may change before it takes effect.

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Scope. This HIPAA Notice of Privacy Practices applies to protected health information (PHI) that Saludlink creates or receives through its connected, licensed telehealth care services. It does NOT apply to the commerce website at saludlinkusa.com, which is a separate store that does not collect, store, or process PHI — that Site is governed by our Privacy Policy. [Counsel to confirm whether Saludlink acts as a HIPAA covered entity or business associate for these services; the description below assumes covered-entity obligations.]

Our duties. We are required by law to: maintain the privacy and security of your PHI; give you this Notice of our legal duties and privacy practices with respect to your PHI; follow the terms of the Notice currently in effect; and notify you promptly if a breach occurs that may have compromised the privacy or security of your PHI.

Uses and disclosures for treatment, payment, and health care operations. Treatment — we may use and disclose your PHI to provide, coordinate, or manage your care and related services (for example, sharing information with the licensed provider treating you). Payment — we may use and disclose PHI to bill and obtain payment for services, including determining eligibility, and to process claims and collections. Health care operations — we may use and disclose PHI for quality assessment and improvement, care coordination, training, credentialing, and general administration.

Other uses and disclosures permitted or required by law (without your authorization). Subject to legal conditions and limits, we may use or disclose PHI: as required by law; for public health activities (such as reporting disease or adverse events); about victims of abuse, neglect, or domestic violence; for health oversight activities (audits, investigations); in judicial and administrative proceedings (for example, in response to a subpoena or court order); for law-enforcement purposes; to coroners, medical examiners, and funeral directors; for organ, eye, or tissue donation; for research approved under a special process; to avert a serious and imminent threat to health or safety; for specialized government functions (such as military, national security, or protective services); for workers’ compensation as authorized by law; and to correctional institutions where applicable. We may also disclose PHI to business associates who perform services for us under a written agreement requiring them to safeguard your PHI.

Optional communications. Where permitted, we may contact you with appointment reminders, information about treatment alternatives, or other health-related benefits and services; you may ask us to stop these. We will obtain your written authorization before any use or disclosure for marketing (beyond limited permitted communications), before any disclosure that is a sale of PHI, and before using or disclosing psychotherapy notes, if any.

Uses and disclosures requiring your written authorization. Any use or disclosure of your PHI not described in this Notice will be made only with your written authorization. You may revoke an authorization in writing at any time, and we will stop the future uses and disclosures it permitted, except to the extent we have already relied on it.

Your rights regarding your PHI. You have the right to: inspect and obtain a copy of your PHI (including an electronic copy where we hold it electronically), subject to limited exceptions and any allowed cost-based fee; request that we amend PHI you believe is incorrect or incomplete; receive an accounting of certain disclosures we have made; request restrictions on how we use or disclose your PHI (and we must agree to your request to restrict disclosure to a health plan for an item or service you paid for in full out of pocket); request that we communicate with you confidentially or at an alternative location; receive a paper copy of this Notice on request even if you agreed to receive it electronically; and be notified following a breach of your unsecured PHI. To exercise any of these rights, contact the Privacy Officer below.

Changes to this Notice. We reserve the right to change this Notice and to make the revised Notice effective for PHI we already have as well as PHI we receive in the future. The current Notice will be posted here with its effective date, and a copy is available on request.

Complaints. If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer at support@saludlinkusa.com, or with the U.S. Department of Health and Human Services, Office for Civil Rights (electronically at ocrportal.hhs.gov, or by mail or phone). We will not retaliate against you for filing a complaint.

Contact and effective date. Privacy Officer: Saludlink, Inc., support@saludlinkusa.com (mailing address on our Contact page). Effective date: [to be set by counsel upon finalization].