Notice of Privacy Practices

1. Who we are

{{PC_NAME}}(“we,” “us,” or “our”) is a professional corporation that delivers clinical services to patients through the Livozo telehealth platform. We are a “covered entity” under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). {{ENTITY_NAME}} (Livozo) is our business associate and operates the Platform on our behalf under a written Business Associate Agreement.

2. Our privacy obligations

We are required by law to:

• Maintain the privacy of your protected health information (PHI).
• Give you this Notice of our legal duties and privacy practices regarding your PHI.
• Notify you following a breach of unsecured PHI.
• Follow the terms of the version of this Notice currently in effect.

3. Permitted uses: treatment, payment, and healthcare operations (TPO)

We may use and disclose PHI for treatment, payment, and healthcare operations without your specific authorization:

• Treatment: e.g., a Livozo clinician reviewing your intake answers, lab results, or messages and writing a prescription routed to a pharmacy partner.
• Payment: e.g., billing you or your payment card, processing refunds, coordinating with HSA/FSA administrators.
• Healthcare operations: e.g., quality improvement, clinician training, audits, business planning, credentialing, and compliance reviews.

4. Other permitted uses without authorization

The following categories may be disclosed without your authorization as permitted by 45 CFR 164.512:

1. Public health activities (e.g., reporting adverse drug events to FDA).
2. Victims of abuse, neglect, or domestic violence.
3. Health oversight activities (e.g., audits, investigations).
4. Judicial and administrative proceedings (e.g., in response to a subpoena or court order).
5. Law enforcement purposes.
6. Decedents (coroners, medical examiners, funeral directors).
7. Organ, eye, or tissue donation.
8. Research (subject to IRB or privacy-board approval).
9. Serious threat to health or safety.
10. Specialized government functions (military, national security, protective services).
11. Workers' compensation.
12. Required by law (federal, state, or local).
13. To you or your personal representative.

5. Uses that require your written authorization

Per 45 CFR 164.502(a)(5)(iii) and 164.508, the following uses require your written authorization:

• Marketing communications, except for face-to-face marketing or a promotional gift of nominal value.
• Sale of PHI.
• Disclosure of psychotherapy notes, except as permitted for treatment, training, or required-by-law purposes.
• Most other uses not described elsewhere in this Notice.

You may revoke an authorization in writing at any time, except to the extent we have already relied on it.

6. Your rights

• Right of access: you may request to inspect or receive a copy of your PHI in our records, including in electronic form. We will respond within 30 days (with one 30-day extension if needed).
• Right to amend: if you believe PHI we have is incorrect or incomplete, you may request amendment. We may deny the request in limited circumstances.
• Right to an accounting of disclosures: a list of certain disclosures we made of your PHI for purposes other than TPO.
• Right to request restrictions on certain uses and disclosures. We are required to agree if you pay in full out of pocket and ask us not to disclose to a health plan.
• Right to confidential communications: receive communications at an alternate address or phone number.
• Right to a paper copy of this Notice, even if you have agreed to receive it electronically.
• Right to be notified of a breach of unsecured PHI.
• Right to file a complaint with us and the U.S. Department of Health and Human Services (HHS) without retaliation.

7. Our duties

We are required by law to maintain the privacy and security of your PHI, to provide notice of our legal duties, to follow the terms of this Notice while in effect, and to notify you of a breach of unsecured PHI.

8. How to file a complaint

If you believe your privacy rights have been violated, you may file a complaint with us at:

• Privacy Officer, {{PC_NAME}}
  [email protected]
  {{PC_ADDRESS}}

You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services:

• HHS Office for Civil Rights complaint portal
• 1-800-368-1019 (TDD: 1-800-537-7697)

We will not retaliate against you for filing a complaint.

9. Changes to this notice

We reserve the right to change this Notice at any time. We will make any revised Notice available on the Livozo Platform and provide a paper copy on request. The revised Notice will apply to all PHI we maintain.

10. Effective date

This Notice is effective as of the date set on launch.