Notice of Privacy Practices

1. Our Commitment

The clinical entity operating through the Ignite Health & Wellness telehealth platform, together with its business associates (collectively, “we,” “our,” and “us”), is required by law to maintain the privacy of protected health information (“PHI”), to provide you with this Notice of our legal duties and privacy practices with respect to PHI, to notify you in the event of a breach of unsecured PHI, and to abide by the terms of the Notice currently in effect. This Notice is provided pursuant to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations, including 45 C.F.R. § 164.520.

2. Uses and Disclosures for Treatment, Payment, and Health Care Operations

We may use and disclose your PHI without your written authorization for the following purposes:

• Treatment: we may use and disclose PHI to provide, coordinate, or manage your health care, including sharing information with clinicians, laboratories, compounding pharmacies, e-prescribing services, and other providers involved in your care.
• Payment: we may use and disclose PHI to obtain payment for services, including processing payments through our payment processor and producing receipts and billing records.
• Health Care Operations: we may use and disclose PHI for activities necessary to run our practice, including quality review, training, credentialing, audits, compliance, and general administration.

3. Other Uses and Disclosures That Do Not Require Your Authorization

We may use or disclose your PHI without your authorization in the following circumstances, subject to the limits of applicable law:

• As required by law, including Florida law where it provides greater protection.
• For public health activities, such as reporting communicable diseases, adverse events, or product recalls.
• To report suspected abuse, neglect, or domestic violence.
• For health oversight activities, such as audits, investigations, and inspections.
• For judicial and administrative proceedings in response to a valid subpoena or court order.
• For law enforcement purposes as permitted by law.
• To coroners, medical examiners, and funeral directors as permitted by law.
• For organ, eye, or tissue donation purposes.
• For approved research that meets applicable privacy and ethical safeguards.
• To avert a serious and imminent threat to health or safety.
• For specialized government functions, such as military and veterans’ activities and national security.
• For workers’ compensation, to the extent necessary to comply with applicable law.

4. Uses and Disclosures That Require Your Authorization

The following uses and disclosures require your written authorization:

• Most uses and disclosures of psychotherapy notes, where applicable.
• Uses and disclosures of PHI for marketing purposes, other than face-to-face communications or a promotional gift of nominal value. You may opt in to receive educational or promotional communications, and you may opt out at any time.
• Any sale of PHI.
• Any other use or disclosure not described in this Notice or otherwise permitted or required by law.

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

5. Your Rights With Respect to Your PHI

You have the following rights:

• Right of access: right to inspect and obtain a copy of PHI maintained in a designated record set, in the form or format you request if readily producible, including an electronic copy where PHI is maintained electronically. Reasonable cost-based fees may apply as permitted by law.
• Right to amend: right to request an amendment of PHI you believe to be incorrect or incomplete. We may deny the request in limited circumstances, in which case you may submit a written statement of disagreement.
• Right to an accounting of disclosures: right to receive a list of certain disclosures of PHI made in the six years before your request (or a shorter period selected by you), excluding disclosures for treatment, payment, health care operations, and certain other categories permitted by law.
• Right to request restrictions: right to request restrictions on certain uses and disclosures for treatment, payment, or health care operations. We are not required to agree to most restriction requests. We are required to agree to a request to restrict disclosure of PHI to a health plan for payment or health care operations when the PHI relates solely to a service for which you or another person on your behalf has paid in full out of pocket.
• Right to confidential communications: right to request that we communicate with you in a specific way or at a specific location, for example a particular email address or phone number. We will accommodate reasonable requests.
• Right to a paper copy of this Notice: right to obtain a paper copy of this Notice upon request, even if you previously agreed to receive it electronically.
• Right to notification of a breach: right to be notified in the event of a breach of your unsecured PHI as required by law.

To exercise any of these rights, submit a written request to the Privacy Officer using the contact information at the end of this Notice. We may ask you to complete a form and verify your identity before responding.

6. Our Duties

• We are required by law to maintain the privacy and security of your PHI.
• We are required to notify you promptly if a breach of your unsecured PHI occurs.
• We must abide by the terms of the Notice currently in effect.
• We reserve the right to change this Notice and apply the revised Notice to all PHI that we maintain, including information created or received before the change. A current copy of this Notice will be posted on our website and provided upon request.

7. Medical Record Retention

We retain medical records in accordance with applicable Florida law, which generally requires retention for at least seven (7) years from the last patient contact. See, for example, Florida Statutes section 395.3025 and related Board of Medicine rules.

8. Complaints

If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer at the contact information below, or with the Secretary of the U.S. Department of Health and Human Services, Office for Civil Rights. We will not retaliate against you for filing a complaint.

9. Contact the Privacy Officer

To exercise your rights, request a paper copy of this Notice, or file a complaint, contact: