YOUR PRIVACY & TRUST MATTERS

A message from WithHealth Founder & CEO Cindy Salas Murphy

Your privacy is critical to our success. We take privacy very seriously at WithHealth and through our HIPAA-compliant technology, we’re able to protect our patient’s healthcare information. We are a digital health company, however, we hold ourselves to the same standard as any other medical practice. We are committed to ensuring your experience always includes a HIPAA-compliant platform and lives up to the utmost regulations of protected health information. We have a robust compliance and privacy program at WithHealth that will ensure your privacy every step of the way. We believe your data belongs to you, and because of that, we will not sell your data and we will not broker your data. The data that we have is to deliver Precision Care – the care that you deserve.

Notice of Privacy Practice

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

Our Pledge Regarding Your Health Information

WithHealth will not sell personal data or use personal data for marketing purposes. The only third parties that WithHealth discloses health information to are those listed in the categories that are outlined in the Privacy Policy. Typically, the disclosure to third parties should be limited to the user’s employer, healthcare providers, third parties who help WithHealth power its services, e.g., hosting providers who host the data, and government entities that may require disclosure to them.

We understand that information about you and your health is confidential. We are committed to protecting the privacy of this information. Each time you visit a WithHealth website, engage in our workplace safety protocol or interact with a WithHealth-affiliated clinician, we create a digital record of the data and activity. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all the records of your care generated by any of the WithHealth entities, whether made by health care personnel or your physician. This notice tells you about the ways in which we may use and disclose health information about you, as well as certain obligations we have regarding the use and disclosure of health information. It also describes your rights regarding your health information.

Our Responsibilities

Our primary responsibility is to safeguard your personal health information. We must give you this notice of our privacy practices and follow the terms of the notice currently in effect. We will notify you in the event we become aware of an unauthorized access, use, or disclosure of your unsecured protected health information.

Changes to This Notice

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for health information we already have about you as well as any information we receive in the future. A copy of the current notice is posted on our website at www.withhealth.com. A copy of the notice is available upon registration through the WithHealth website or through any WithHealth application.

How We May Use and Disclose Health Information About You

The following categories describe different ways that we use your health information within WithHealth and disclose your health information to persons and entities outside of WithHealth. We have not listed every use or disclosure within the categories below, but all permitted uses and disclosures will fall within one of the following categories. In addition, there are some uses and disclosures that require your specific authorization.

Treatment: We use and disclose your protected health information to provide, coordinate or manage your health care and any related services. We may disclose health information about you to doctors, nurses, technicians, medical students, interns, or other allied health personnel who are involved in taking care of your medical needs provided through WithHealth. We may communicate information to another non-WithHealth health care provider for the purposes of coordinating your continuing care and may make that information available electronically. If you contact WithHealth to seek information for health care, we may use and disclose the information you provide to us to a care team member to assist in providing quality health care.

Payment: We may use and disclose your information to bill for services provided by WithHealth and to obtain payment from you, an insurance company, a third party, or a collection agency. This may include the disclosure of health information to obtain prior authorization for treatment and procedures from your insurance plan.

Health Care Operations: Uses and disclosures of health information are necessary to operate our telehealth care and to make sure all our patients receive quality care. We may use and disclose relevant health information about you for health care operations. Examples include quality assurance activities, telephone calls to follow up on your health status, medical staff credentialing, administrative activities including WithHealth financial and business planning and development, customer service activities including patient satisfaction surveys, investigation of complaints, and certain marketing activities such as health education options for treatment and services.

Business Associates: WithHealth provides services through contracts with business associates. Examples of business associates include accreditation agencies, protected health information (PHI) and electronic health record (HER)management consultants, quality assurance reviewers, and billing and collection services. We disclose your health information to our business associates so they can perform the job we’ve asked them to do. To protect your health information, we require our business associates to sign a contract or written agreement that states they will appropriately safeguard your information.

How WithHealth Protects Your Genetic Information

To help prevent discrimination based on genetic results, the Genetic Information Nondiscrimination Act (GINA) was passed in 2008. The law prevents discrimination and harassment based on someone’s genetic information and potential for disease. GINA prohibits an employer from using genetic information to make an employment decision as well as retaliation against someone who files a charge of genetic discrimination. The protections GINA offers applies to health insurance.

Your Rights Regarding Medical Information About You

You have the following rights regarding medical information we maintain about you. You may contact a health information representative where services were provided to obtain additional information and instructions for exercising the following rights:

Obtain a Copy of Our Notice of Privacy Practices

You may request a restriction on certain uses and disclosures of your information. This request must be in writing to WithHealth 6370 Lusk Boulevard, Suite F-203, San Diego, California 92121. If we agree to your request, we will comply unless the information is needed to provide you with emergency treatment. However, if our system capabilities will not allow us to comply with your request, we are not required to agree to your request.

Services paid for out of pocket: We must however agree to your request to restrict disclosure of your health information to your health plan (or insurer of healthcare services) for purposes of payment or operations if the PHI pertains solely to a healthcare item or service for which you, or someone else on your behalf (other than the health plan or insurer), had paid for the item or service out of pock in full at the time of service. We can only address requests for WithHealth affiliated facilities. Your request will not extend to a physician’s private practice.

Inspect and Request a Copy of Your Health Record

Your request for inspection or copies, including electronic copies, must be in writing and directed to WithHealth. A reasonable fee for copies will be charged. We may deny your request under very limited circumstances. If you are denied access to health information, you may request that the denial be reviewed by another health care professional chosen by someone on our health care team. We will abide by the outcome of that review. Request an amendment to your health record if you feel the information is incorrect or incomplete. Your request must be made in writing and it must include a reason that supports the request. We may deny your request if the information was not created by our health care team; if it is not part of the information kept by our facility; if it is not part of the information which you are permitted to inspect and copy; or if the information is accurate and complete as stated.

Please note: if we accept your request for amendment, we are not required to delete any information from your health record. Obtain an accounting of disclosures to others of your health information. The accounting will provide information about disclosures made for purposes other than treatment, payment, health care operations, disclosures excluded by law, or those you have authorized.

Request Confidential Communications

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you may ask that we only contact you at work or by mail. We will accommodate all requests that are reasonable for our system capabilities. Your request must be in writing and specify the exact changes you are requesting.

Revoke Your Authorization

You have the right to revoke your authorization for the use or disclosure of your health information except to the extent that action has already been taken. You can complain about any aspect of our health information practices to us or to the United States Department of Health and Human Services.

If you have questions about this notice, contact the WithHealth Privacy Officer at 858-230-6863 or write to us at WithHealth, Inc., 6370 Lusk Boulevard, Suite F-203, San Diego, California 92121.