Salus Telehealth, Inc.

VIDEOMEDICINE PRIVACY POLICY

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.

1. DEFINITIONS
“Consumers” are those individuals who elect to communicate with Providers on VideoMedicine.
“Individually identifiable health information” is defined according to 45 C.F.R. § 160.103, and refers to health information, including demographic information, that is (1) created by a Provider or by Us; (2) relates to Your health, the provision of health care to You, or payment for such health care; and (3) either identifies You or could reasonably be used to identify You.
“Patients” are those Consumers who have agreed to accept a VideoMedicine Provider’s services in making diagnoses or in recommending treatment or both for them, including, where the Provider deems it appropriate and lawful, and where it is within the scope of the Provider’s practice, the prescribing of medications exclusive of controlled substances.
“Protected Health Information” (PHI) is defined according to 45 C.F.R. § 160.103, and refers to any individually identifiable health information, as defined above, that is transmitted or maintained in any form or medium, including electronic media, about health status, provision of health care, or payment for health care that is identifiable, meaning it can be linked to a specific individual.
“Providers” are licensed physicians, physician assistants, psychologists, mental health counselors, diabetes educators, nurses, nurse practitioners, chiropractors, health and wellness coaches, personal trainers, dieticians, and nutritionists, who communicate with Consumers using VideoMedicine and who arrange to be listed here, as well as naturopaths, who do the same.
“User Experience Managers” (UEMs) are technicians who contract with VideoMedicine and are available to help Consumers to identify potential specialist candidates. UEMs are not clinically trained and provide their services only upon Consumer request. Identification of a specialist candidate by a UEM does not constitute an endorsement, recommendation, or preference for that candidate by the UEM or by VideoMedicine.
VideoMedicine Services means video, audio, or written communication between a Provider and a Consumer, or some combination of such communications.
“We” or “Our” or “Us” means VideoMedicine or Salus Telehealth, Inc.
“You” or “Your” or “Yourself” or “My” refers to a Consumer or a Patient.

2. PRIVACY POLICY
Both VideoMedicine and the Providers with whom You may communicate through VideoMedicine are subject to laws governing the privacy of Protected Health Information. Any health information that You or Your Provider shares with VideoMedicine is similarly protected by law. We will make reasonable efforts to ensure and maintain the confidentiality of all health information in order to protect both Your privacy and that Your information.
We also make reasonable efforts to monitor VideoMedicine servers for any infiltration or attacks. Some attacks are easier to identify than others. Distributed denial-of-service (“DDos”) attacks, or Brute-force attacks, for example, are much easier to identify than attacks in which someone mimics a user and steals a username and password. Consumers or Patients electing to store PHI on VideoMedicine accept responsibility for securing their usernames and passwords. Should We become aware of a breach in which we know or reasonably believe that Your PHI has been compromised, We shall notify the relevant Providers as soon as possible but in any event within sixty (60) days of learning of that compromise.
PHI provided to VideoMedicine and transmitted between or among mobile devices, the VideoMedicine website, and its servers is encrypted. The passwords that allow access to the VideoMedicine App and website, which may contain PHI, are also encrypted. The VideoMedicine server that PHI may be stored on is protected by a firewall. Human access is limited to that access needed to maintain the server, and excludes access to PHI. VideoMedicine servers require secure shell certificates for access. The servers have all ports closed (deny-all mode) except for a few that remain open because they are vital for VideoMedicine to operate. These are secured with authentication (login/password) and encryption (Hypertext Transfer Protocol Secure/ Secure Socket Layer (“HTTPS/SSL”)). VideoMedicine undertakes reasonable efforts to secure all PHI as it is sent. In the event of a hacker attack, however, it is always possible, despite deployment of reasonable safeguards, that PHI may be exposed. By using VideoMedicine, You acknowledge this risk of unauthorized PHI use or disclosure.
You should be aware that, to improve the quality of Your experience, and to foster compliance with these Terms, we may monitor activity on VideoMedicine, tracking such matters as the number of users, services accessed, time and location services are accessed, search text and filter functionality, and technical data. By using VideoMedicine, You hereby specifically agree to such monitoring.
VideoMedicine may automatically collect information about the mobile or other device You use to access VideoMedicine, including for example the make and model of Your device, and (if applicable) the type of browser software You use, the operating system You are running, and Your Internet Protocol address. In addition, Your location may be collected and stored via the functionality of Your mobile or other device and, if so, VideoMedicine may store and have access to such information. In addition, We reserve the right to use the information We collect about Your mobile or other device (including its location), which may at times be able to identify You, for any lawful business purpose, including without limitation to help identify problems with Our servers, to gather de-identified demographic information, and to otherwise administer VideoMedicine.
We allow access to Our database by third parties that provide Us with services, such as technical maintenance, but only to the extent necessary to provide those services. We will require such third parties to follow privacy policies similar to those VideoMedicine itself follows and will not authorize them to use database information except for the express purpose for which it is provided. VideoMedicine bears no responsibility for any actions or policies of third parties, however. We may also provide access to Our database to comply with legal obligations arising from official investigations or legal proceedings, including, for example, in response to subpoenas, search warrants, court orders, or other legal process.
VideoMedicine may use or disclose Your PHI to the limited extent here described. Examples of uses of Your PHI that We make to enhance the value of VideoMedicine include using Your PHI to help you identify specialist candidates who suit your needs, and allowing Providers to search for you on VideoMedicine so that, if you agree, a Provider with whom you have an existing treating relationship may be be connected to You on VideoMedicine. Additionally, VideoMedicine collects certain PHI to the extent necessary for Us to provide Our services. Examples of such collection include PHI (such as name, email, and date of birth) that You provide at the time of account registration, and the record of Provider-patient encounters that We maintain. Beyond the extent necessary to provide and administer Our services, VideoMedicine does not seek to collect individually identifiable health information. With Your permission, however, and only with Your permission, VideoMedicine will store PHI for Your use and, at Your election, Your Providers’ use. VideoMedicine does not seek to use Your PHI for any purpose except as necessary for providing VideoMedicine’s services and for those uses to which You have consented. You have the option to upload or not to upload PHI, but if You do, You will have access to Your own PHI.
You may also request to amend or resolve errors in uploaded PHI if you believe such errors exist. If We agree, We will amend the PHI. If we do not agree, the PHI will remain as is, but we shall indicate that You disagree with the accuracy of the information recorded. We also offer an optional anonymous mode to further protect Patient identity. Anonymous mode enables You to elect to de-identify Your PHI at any time. You are not required to upload PHI in order to use VideoMedicine.
Providers from whom You have previously received services may also be using VideoMedicine. To better integrate Your experience with such Providers, VideoMedicine allows Providers to search for patients using the patient’s (1) first and last name, (2) date of birth, or (3) email address or (4) some combination of these data points. You may choose to opt out of having VideoMedicine make Your information so searchable either by using VideoMedicine in anonymous mode or indicating below via Info@VideoMedicine.com that you are opting out of this service. If You do not opt out, Providers who are users of VideoMedicine will be able to search for You in the manner described. All Providers will be able to search for You, whether or not You have previously received services from them; You have the discretion, however, to accept or deny contact requests from Providers who find You through this search function. Because accepting a contact request from a Provider may give that Provider access to Your PHI, you should accept contact requests from only those Providers with whom You have an existing treating relationship.
You have the option of disclosing to Us certain information about Your health insurance, health share or other health-coverage plan, including the name of Your insurer, Your member number, and Your group number. Disclosure of this information to Us can facilitate reimbursement that You may seek from Your insurer for services provided through VideoMedicine. By providing Us with Your insurance information, You consent to Our disclosure of that information to the insurer whose information You provide. Additionally, VideoMedicine may allow Your insurer access to your VideoMedicine patient record for purposes including calculation of reimbursement amounts; determination of whether a given service is eligible for coverage; and verifying the accuracy of the classification of any diseases, signs, or symptoms as recorded by Your Provider(s). You may choose to opt out of having VideoMedicine make your record available to Your insurer by so notifying Us through Info@VideoMedicine.com
VideoMedicine creates and maintains a record of all patient encounters. The VideoMedicine interface allows You to request that a copy of Your record be sent via email, fax, or regular mail to You or to another person You designate at the time of Your request. Your request for such a copy of Your record constitutes Your consent to have VideoMedicine prepare and send the copy to You. When You request that Your records be sent to You via email, the records will be attached to the email in unencrypted PDF format. Please note that, even when You request a copy of Your record, You may not be able to receive a copy of parts that pertain to psychotherapy notes, if any, or information being compiled for use in a civil, criminal, or administrative action of proceeding, if any. VideoMedicine may charge You a reasonable fee to cover the cost of labor and supplies necessary to fulfill Your request.
a. User Experience Managers:
User Experience Managers (UEMs) are technicians who contract with VideoMedicine and, with Your permission, will assist You in navigating the VideoMedicine interface and identifying specialist candidates who may fit Your needs. UEMs are not themselves Providers; they have no clinical training. Their expertise is not in selecting Providers but in helping You use VideoMedicine to full advantage by making it easier for You to command VideoMedicine to provide You the information You want. In order to provide this assistance to You, UEMs may need to access Your PHI. For example, a UEM may use Your PHI to help You find information about a Provider whose area of specialization appears to align with Your needs and the services You request. By accepting or requesting the assistance of a UEM, You consent to the UEM’s use of Your PHI for the sole purpose of assisting You in Your use of the VideoMedicine interface. You also acknowledge that (1) the UEM has no clinical, medical or other health or health care expertise, experience, or training; and (2) VideoMedicine does not recommend any Provider that with the UEM’s help You find, nor suggest or imply that any such Provider is in any way superior to, or even necessarily as good as, any other Provider; nor suggest or imply that VideoMedicine is even competent to make any such recommendation or evaluation. You are not required to seek or accept the assistance of a UEM but You are aware that UEM’s may proactively monitor your activity in order to enhance an effective user experience.

3. PRIVACY CONTACT
In the event that you wish to contact VideoMedicine concerning Your private information, make a complaint about the use of Your private information, or amend Your privacy preferences or stored PHI, inquiries may be relayed to:
[Salus Telehealth, Inc. to supply the name and contact information of an employee whose role will be to handle such inquiries.]

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