Notice of privacy practices

Notice of privacy practices Last Amended: December 11, 2023

Securing your Personal Information is our priority. This Notice of Privacy Practice (“Notice”) is in addition to, and does not replace our Privacy Policy. Defined terms herein shall have the same meaning as defined in the Privacy Policy.

This Notice describes how we, USARAD Holdings Inc. (collectively with its affiliated companies and subsidiaries shall be referred to herein as the “USARAD”, “we”, “us” or “our”) use and disclose Patient’s (also “you” or “your”) Protected Health Information (PHI) covered and defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and your rights, including filing a complaint if you believe your privacy rights have been violated. PHI may also be referred as “Medical Records” as defined under our Privacy Policy.

Even though we operate as a service provider and our platform is not considered as a covered entity under HIPAA, we take the confidentiality and security of your PHI very seriously. Therefore we choose to adopt the strict HIPAA Rules in maintaining the PHI as further detailed below in this Notice.

1. Permissible uses and disclosures without your written authorization

Treatment and related health care operations	We may use your Medical Records to facilitate the provision of the required second opinion services by the HCP to you. Meaning we will share your Medical Records with applicable HCPs in order to coordinate and facilitate your second opinion consultancy meeting. We may also use your Medical Records to tell you about health-related services available to you, or to perform follow-up calls to monitor your care experience.
Payments	We may use and disclose your Medical Records to get paid for the second opinion services provides to you. For example, if and to the extent applicable, your health plan or Health Insurance Company may ask to see parts of your Medical Record before they will pay us for your treatment.
Practice operations	We may use and disclose your Medical Records if it is necessary to improve the quality of Services we provide to Patients. We may use your Medical Records to conduct quality improvement activities, to obtain audit, accounting or legal services, or to conduct business management and planning. For example, we may look at your Medical Records to evaluate the medical services provided by the applicable HCP.
Imminent danger	We may share your Medical Records with anyone as necessary to prevent or lessen a serious and imminent threat to the health and safety of a person or the public, in consistency with applicable law.
Research	We may use or disclose your Medical Records for internal research purposes, provided such Medical Records will undergo de-identification process which will not allow anyone to identify you.
As required by law	Your Medical Records may be used and disclosed when required to do so by any other law not already referred to in the preceding categories; such as required by the FDA, to monitor the safety of a medical device.
Victims of abuse, neglect or domestic violence	Your Medical Records may be disclosed to a governmental authority, including a social service or protective services agency, authorized by law to receive reports of such abuse, neglect, or domestic violence if there is a reasonable belief that you are a victim of abuse, neglect or domestic violence.
Public safety	We may disclose your Medical Records for public safety purposes in limited circumstances. We may disclose Medical Records to law enforcement officials in response to a search warrant or a grand jury subpoena. We also may disclose Medical Records to assist law enforcement officials to prevent a serious threat to health or safety.

2. Uses and disclosures for which your authorization is required

We will obtain your written authorization before we will disclose your Medical Records in the following circumstances:

Conduct marketing activity	With your authorization, we may use or disclose your PHI for marketing purposes.
To Communicate with you about health-related products and services	We may use or disclose your Medical Records to communicate with you regarding your care and related matters. We provide these services through text or email and solely subject to your consent and approval. You may withdraw your consent and opt-out of these communications at any time as guided in the communication you received.
Using information with additional protection	Certain types of medical information have additional protection under state or federal law. For those types of information, if and to the extent applicable, we are required to get your permission before disclosing that information to others in many circumstances.

3. You have the following rights concerning your medical records

Access PHI and Receive a Copy: You have the right to review or get copies of your PHI and health related information, with limited exceptions. You may request that we provide copies in a format other than photocopies. We will use the format you request unless we cannot practicably do so. Please make such request in writing. You may obtain a paper copy at the site where you obtain health care services from us or by contacting support@secondopinions.com. You have the right to request a copy of your information in electronic format, and to direct us to transmit a copy of your information to a third party designated by you.
Confidential Communications: You have the right to ask us to communicate with you in a way that you feel is more confidential. For example, you can ask us not to call your home, but to communicate only by mail. To do this, please contact us at: support@secondopinions.com.
Restrict Uses and Disclosures of PHI: You have the right to request additional restrictions on our use or disclosure of your PHI. We are not required to agree to these additional restrictions except in the case where the disclosure is to a health plan for purposes of carrying out payment or health care operations, if applicable, or otherwise required by law.
Amendment of PHI: If you feel that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. Your request must be in writing, and it must explain why the information should be amended. We may deny your request under certain circumstances. You may obtain a form to request an amendment to your health information by using the contact information listed at the end of this Notice.
Accounting of Disclosures of PHI: You have the right to receive a list of instances in which we disclosed your PHI for purposes other than the categories listed above under Section 1, where you have provided an authorization and certain other activities, for the last 6 years (or a shorter period if our relationship with you has existed for less than 6 years). If you request this accounting more than once in a 12 month period, we may charge you a reasonable, cost based fee for responding to these additional requests.
PHI Breach Notification: If we become aware that your PHI has been breached and the privacy or security of the information has been compromised, you have the right to be notified of the breach without unreasonable delay and in no event later than 60 days following our discovery of the breach.

4. Complaints and contact us

If you have questions, would like to exercise any right granted to you, would like further information about this Notice or if you feel we have violated your rights, you may file a complaint by contacting us at support@secondopinions.com.

You can also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. A complaint must be made in writing and will not in any way affect the quality of care we provide you with.

5. Changes to this notice

From time to time, we may change our practices concerning how we use or disclose Patients’ Medical Records, or how we implement Patient rights concerning their information. We reserve the right to change this Notice and to make the provisions in our new Notice effective for all Medical Records we maintain. If we change these practices, we will publish a revised Notice of Privacy Practices. You can get a copy of our current Notice of Privacy Practices at any time by contacting us directly as provided above.