HIPAA Notice of Privacy Practices

1. Our Commitment

PulseCare, Inc. (“PulseCare,” “we,” “our,” or “us”) is committed to protecting the privacy of Protected Health Information (PHI) in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH Act).

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.

2. Information We Collect

In the course of providing healthcare services through our platform, we may collect the following categories of Protected Health Information:

• Patient demographics: name, date of birth, address, phone number, email, and emergency contacts
• Medical records: clinical notes, diagnoses, treatment plans, and referral information
• Lab results: diagnostic test results, pathology reports, and imaging data
• Prescription history: current and past medications, dosages, and pharmacy information
• Billing information: charges, payments, account balances, and payment methods
• Insurance details: policy numbers, coverage information, and pre-authorization records
• Appointment records: scheduling history, cancellations, and provider assignments
• Telehealth session data: session logs, connection metadata, and in-session clinical documentation

3. How We Use and Disclose PHI

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

3.1 Treatment

We use PHI to coordinate your care between healthcare providers, including sharing clinical information with specialists, referring physicians, pharmacies, and other members of your care team.

3.2 Payment

We use PHI to process insurance claims, verify coverage, obtain pre-authorization, and manage billing and collections activities.

3.3 Healthcare Operations

We use PHI for quality improvement programs, staff training and competency assessment, compliance auditing, and other internal operations necessary to run our practice.

4. Your Rights Under HIPAA

You have the following rights regarding the PHI we maintain about you:

• Right to access your records: You may request copies of your PHI in paper or electronic format. We will provide the requested information within 30 days of your request.
• Right to request amendments: If you believe your PHI is inaccurate or incomplete, you may request that we amend it. We may deny the request in certain circumstances but will provide a written explanation.
• Right to an accounting of disclosures: You may request a list of instances in which we disclosed your PHI for purposes other than treatment, payment, or healthcare operations.
• Right to request restrictions: You may request restrictions on how we use or disclose your PHI. We are not required to agree to all requests, except when disclosure is to a health plan for payment purposes and you have paid in full out of pocket.
• Right to confidential communications: You may request that we communicate with you about health matters through a specific method or at a specific location (e.g., only by mail to a particular address).
• Right to file a complaint: If you believe your privacy rights have been violated, you may file a complaint with us or with the U.S. Department of Health and Human Services (HHS). We will not retaliate against you for filing a complaint.

5. Minimum Necessary Standard

We limit the use, disclosure, and request of PHI to the minimum amount necessary to accomplish the intended purpose. Our role-based access control system ensures that workforce members can access only the PHI required for their specific job functions.

6. Business Associates

We may share PHI with third-party vendors (“Business Associates”) who perform services on our behalf that involve access to PHI. All Business Associates are required to sign a Business Associate Agreement (BAA) that obligates them to safeguard your information in accordance with HIPAA requirements.

We maintain a current list of sub-processors and Business Associates. You may request this list by contacting our Privacy Officer at the address below.

7. Breach Notification

In the event of a breach of unsecured PHI, we will notify affected individuals without unreasonable delay and no later than 60 calendar days following discovery of the breach. For breaches affecting 500 or more individuals, we will also notify the U.S. Department of Health and Human Services (HHS) and prominent media outlets in the affected jurisdiction, as required by the HITECH Act.

8. Contact

If you have questions about this Notice, wish to exercise any of your rights, or want to file a complaint, please contact our HIPAA Privacy Officer:

You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, at www.hhs.gov/ocr.