Privacy Policy & Practices

Last revised: August 5, 2025

INTRODUCTION

The purpose of this Privacy Policy is to describe how ASL TeleMed collects, uses and shares information about you through our website located at www.asltelemed.com (the “Site”). ASL TeleMed respects your privacy and is committed to protecting it as outlined in this Privacy Policy. If you do not agree with our policies and practices, you may not use our services. By accessing or using our services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our services after we make changes is deemed to be acceptance of those changes. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

While this Privacy Policy describes how we collect, use, and disclose your information, it does not address any PHI submitted by you in relation to services by ASL TeleMed, which is covered by the Notice of Privacy Practices in accordance with the Health Insurance Portability and Accountability Act.

Our Privacy Policy explains:

Information That We Collect
How We Use and Share Your Information
Access to Your Information and Choices
Security of Your Information
California Privacy Rights
Consent to Processing of Personal Data in United States
Changes to Our Privacy Policy
Questions and How Contact Us

Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the Site. Our Site also contains links to third party sites that are not owned or controlled by ASL TeleMed. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

NFORMATION THAT WE COLLECT

Information You Provide to Us

Through your use of our Site, we may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a visitor. We collect information you provide to us, for example when you create or modify your account, register to use our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us or use our Site in commerce. This information may include:

Name
Address
Email address
Telephone number
Payment information (credit card or debit card number, expiration date and credit card security code – solely for payment purposes)
Date of birth
Username and password

If you sign up to use our service you may also be asked to submit certain confidential information during the sign-up process, as well as demographic and other information relevant to diagnosis and treatment, such as lifestyle and general medical history (e.g. conditions, allergies etc.). You will be able to send confidential messages and communicate with a doctor regarding your diagnosis and treatment. ASL TeleMed will keep these messages private and confidential. The information that we collect varies depending upon how you use our Services. When you request a visit, you will need to provide us with health-related information (“Protected Health Information” or “PHI”) that a Physician will need to properly provide medical services. We will not use any PHI for any other purpose not in accordance with this Agreement, or any other Agreement between you and ASL TeleMed, without your written authorization, or unless otherwise permitted or required by law. You may revoke, in writing, any such authorization at any time, except to the extent we have taken action in reliance thereon.

Your use of the Site may also include collection of information from your mobile device. For example, the Site may request your permission to collect location data and/or may request access to multimedia (photos or videos) stored on your mobile device. You have the option of declining collection of geolocation data, but this may limit your ability to participate in certain activities through the Site. If you do not wish for your location data to be shared with ASL TeleMed, please respond accordingly when prompted on your mobile device, or visit your mobile device settings. Multimedia will only be collected from your device if you affirmatively select it to upload to the application (i.e. you choose an image or video to store within the Site). Multimedia will not be shared with other Site users (with the exception of your profile photo, to the extent such feature is offered, which will appear in your user profile).

Information We Collect Automatically Through Your Use of our Site

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.

Information Collected Through Cookies and Similar Technologies

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you.

When you visit our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

(See, “Advertising” below.)

No Information from Individuals Under the Age of 18

We support and comply with the Children’s Online Privacy Protection Act (COPPA) if you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. You will be responsible for providing information related to the minor and for paying for the visit requested for the minor.

SPECIAL NOTICE FOR USERS OF THE SITE: IF YOU ELECT TO MAKE YOUR PROFILE (OR THAT OF A MINOR OR FAMILY MEMBER) VIEWABLE BY HEALTHCARE PROFESSIONALS OR PROVIDERS, ALL INFORMATION THAT YOU INCLUDE IN THAT PROFILE MAY BE VIEWED BY THE SAME. YOU SHOULD NOT ENTER ANY INFORMATION IN THE PROFILE THAT YOU (OR ANOTHER PERSON) WISH TO REMAIN CONFIDENTIAL. A HEALTHCARE PROFESSIONAL OR PROVIDER WILL NOT BE ABLE TO CONTACT YOU EXCEPT THROUGH THE PERSONAL CONTACT INFORMATION YOU PROVIDE THROUGH THE SITE.

HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. We collect information from you and use the information to:

provide products and services that you order using the Site;
register and service your online account;
provide information that you request from us;
contact you about our services or information you requested;
process credit card and debit card transactions;
To allow you to participate in interactive features of our services;
send you promotional materials or advertisements about our products and services, as well as new features and offerings;
enforce our Terms of Use or other legal rights and remedies;
For Business Intelligence (as the term is defined in the Terms of Use). For the avoidance of doubt, Business Intelligence shall not include PHI specifically identifiable to any patient.
administer surveys, sweepstakes, promotions and contests;
provide interest-based targeted advertising to you; and,
any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Sharing with Third Parties.

Healthcare Providers. We share your personal information with various healthcare affiliates, doctors and relevant medical staff in connection with your diagnosis and treatment.

Vendors and Services Providers. We may provide information to third-party vendors and service providers that help us operate and manage our Site, process orders, and fulfill and deliver products and services that you purchase or request from us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs, we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Corporate Affiliates. We may share your personal information with our corporate affiliates which are subject to this policy and applicable law.

Advertising. We may use how you browse and shop in order to show you ads for ASL TeleMed or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned by ASL TeleMed.

We belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites. Currently, our Site does not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.

Social Media. If you use third-party services, such as Facebook, Google, or Twitter, through the Site, to login to the Site, or to share information about your experience on the Site with others, these third-party services may be able to collect information about you, including information about your activity on the Site, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.

Public Posts and Activities. If you choose to engage in public activities on the Site, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in these public areas. Any user posting in these public areas understands and acknowledges that there is no expectation of privacy for the information in these public areas.

Your Consent. In addition to the sharing described elsewhere in this Policy, we will share personal information with companies, organizations or individuals outside of ASL TeleMed when we have your consent to do so.

Legal Proceedings. We will share personal information with third-party companies, organizations or individuals outside of ASL TeleMed if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
Enforce applicable Terms of Use, including investigation of potential violations.
Detect, prevent, or otherwise address fraud, security or technical issues.
Protect against harm to the rights, property or safety of ASL TeleMed, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your online account by signing into your account and going to the Account section of our Site. If you have questions about personal information we have about you or need to update your information, you can contact us.

SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

CALIFORNIA PRIVACY RIGHTS

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

Right to Request Access to Information

You have the right to request that ASL TeleMed notifies you of the personal information about you that we have collected and used. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we shared that personal information.
The specific pieces of personal information we collected about you
If we disclosed your personal information for a business purpose a list disclosing:
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Request Deletion of Information

You have the right to request that ASL TeleMed deletes any of your personal information that we collected about you and retained. Once we receive your request and verify who you are, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights

To exercise the rights listed above, please submit a request in writing to ASL TeleMed via the contact information listed in this Privacy Policy.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

You may only make a request for access twice within a 12-month period. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a request does not require you to create an account with us.

We will only use personal information provided in a request to verify your identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once (1) a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).

To obtain this information, please send an email message to contact@asltelemed.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES

This Site is intended for use only by residents of the U.S. If you are a citizen of the European Economic Area (EEA) or other jurisdiction outside of the U.S., please note that in order to provide our Site, products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review. You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, email us at contact@asltelemed.com.

PRIVACY PRACTICES

Effective: August 1, 2024

Telemedicine HIPAA Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This Telemedicine HIPAA Notice of Privacy Practices (the “Notice”) is being provided to you, by ASL TeleMed (each, individually “Medical Group”), as that entity or its subsidiaries and affiliated entities may be formed and incorporated in your state, and the employees and practitioners that work at such entity and/or for such practices (collectively referred to herein as “We” or “Our”). It contains important information regarding your medical information. You also have the right to receive a paper copy of this Notice and may ask us to give you a copy of this Notice at any time. If you received this Notice electronically, you are still entitled to a paper copy of this Notice upon your request. You can request a paper copy of our current Notice on ASL TeleMed Pediatrics’ website at https://www.asltelemed.com/privacy-practices/.

The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) imposes numerous requirements on health care practices such as ours, defined as Covered Entities, regarding how certain individually identifiable health information – known as protected health information (“PHI”) – may be used and disclosed. We understand that medical information about you and your health is personal. We are committed to protecting medical information about you and will use it to the minimum necessary to accomplish the intended purpose of the use, disclosure or request of it. As required by law, this notice provides you with information about your rights and our legal duties and privacy practices with respect to the privacy of PHI. This notice also discusses the uses and disclosures we will make of your PHI. We must comply with the provisions of this notice as currently in effect, although we reserve the right to change the terms of this notice from time to time and to make the revised notice effective for all PHI we maintain.

PERMITTED USES AND DISCLOSURES

We can use or disclose your PHI for purposes of treatment, payment, and health care operations. For each of these categories of uses and disclosures, we have provided a description and examples below. However, not every particular use or disclosure in every category will necessarily be listed.

“Treatment” means the provision, coordination, or management of your health care, including consultations between health care providers, including hospital, and other long-term care providers, relating to your care and referrals for health care from one health care provider to another. For example, an attending physician at the skilled nursing facility where you reside treating you for diabetes may need to know if you have a psychiatric disorder or are taking psychotropic medications because such disorders or medications may have disease-disease or drug-disease interactions with diabetes. In addition, the practitioner may need to contact another provider for purposes of treating a psychiatric disorder or condition when our providers are not available to provide your care

“Payment” means the activities we undertake to obtain reimbursement for the health care provided to you, including billing, claims management, determinations of eligibility and coverage, collections, case management, and other utilization review activities. For example, we may need to provide PHI to your insurance carrier or a party financially responsible for your care in order to determine whether the proposed course of treatment will be covered, to determine appropriate reimbursement, or to obtain payment. Federal or state law may require us to obtain a written release from you prior to disclosing certain specially protected PHI for payment purposes, and we will ask you to sign a release when necessary under applicable law.

“Health Care Operations” means the support functions for our practice and providers, related to referral, facilitating the telemedicine connection and visit, care coordination, compliance reviews, compliance programs, treatment and payment, quality assurance activities, receiving and responding to patient comments and complaints, provider training, audits, business planning, development, management, legal, and administrative activities. For example, we may use your PHI to evaluate the performance of our provider staff when caring for you. We may also combine PHI about many patients to make clinical qualitative review decisions or decide what additional services we should offer, what services are not needed, and whether certain treatments are effective. We may also disclose PHI for review and educational purposes. In addition, we may remove, or de- identify, information that identifies you so that others can use the de-identified information to study health care, conduct research, collect population health data, and determine methods for improved health care delivery without learning who you are.

OTHER USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION

We may also use your PHI in the following ways:

To provide appointment reminders and schedule your availability with staff or affiliates for your treatment.
To tell you about or recommend possible treatment alternatives or other health-related benefits and services that may be of interest to you.
To your family, personal representative, power of attorney, guardian, or any other individual identified by you to the extent directly related to such person’s involvement in your care or the payment for your care. We may use or disclose your PHI to notify, or assist in the notification of, a family member, a personal representative, or another person responsible for your care, of your general condition or death. If you are available, we will give you an opportunity to object to these disclosures, and we will not make these disclosures if you object. If you are not available, incapacitated or unable to make informed consent decisions about your health care we will determine whether a disclosure to your family or personal representative is permitted or required by law, in your best interests, taking into account the circumstances, and act based upon our professional judgment.
When permitted by law, we may coordinate our uses and disclosures of PHI with public or private entities authorized by law or by charter to assist in disaster relief efforts.
We will allow your family and friends to act on your behalf to pick-up filled prescriptions and similar forms of PHI, when we determine, in our professional judgment, that it is in your best interest to make such disclosures.
We may use or disclose your PHI for research purposes, subject to the requirements of applicable law. For example, a research project may involve comparisons of the health and recovery of all patients who received a particular medication. All research projects are subject to a special approval process which balances research needs with a patient’s need for privacy. When required, we will obtain a written authorization from you prior to using your PHI for research.
In certain cases, we will provide your information to contractors, agents and other parties who need the information in order to perform a service for us (“Business Associates”), including, without limitation, obtaining payment for health care services, technology services providers, or carrying out other business operations. In those situations, PHI will be provided to those contractors, agents and other parties as is needed to perform their contracted tasks. Business Associates are required to enter into an agreement maintaining the privacy of the protected health information released to them under certain terms and conditions required of them by state and federal law.
We may share your information with an insurance company, law firm or risk management organization in order to maintain professional advice about how to manage risk and legal liability, including insurance or legal claims. However, in these situations, we require third parties to provide us with assurances that they will safeguard your information under terms and conditions required by applicable state and federal law.
We will use or disclose PHI about you when required to do so by applicable law, only to the extent necessary to meet such a requirement.
In accordance with applicable law, we may disclose your PHI to your employer if we are retained to conduct an evaluation of whether you have a work-related illness or injury. You will be notified of these disclosures by your employer or the provider as required by applicable law.
Incidental uses and disclosures of PHI sometimes occur and are not considered to be a violation of your rights. Incidental uses and disclosures are by-products of otherwise permitted uses or disclosures which are limited in nature and cannot be reasonably prevented.

SPECIAL SITUATIONS

Subject to the requirements of applicable law, we will make the following uses and disclosures of your PHI:

Involuntary patients: Information regarding patients who are being treated involuntarily, pursuant to law, will be shared with other treatment providers, legal entities, third party payors and others, as necessary to provide the care and management coordination needed in compliance with state and federal law.
Emergencies: In life threatening emergencies, we will disclose information necessary to avoid serious harm or death.
Organ and Tissue Donation. If you are an organ donor, we may release PHI to organizations that handle organ procurement or transplantation as necessary to facilitate organ or tissue donation and transplantation.
Public Health Activities. We may disclose PHI about you for public health activities, including disclosures:
to prevent or control disease, injury or disability;
to report births and deaths;
to report child abuse or neglect;
to persons subject to the jurisdiction of the Food and Drug Administration (FDA) for activities related to the quality, safety, or effectiveness of FDA-regulated products or services and to report reactions to medications or problems with products;
to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
to notify the appropriate government authority if we believe that an adult patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if the patient agrees or when required or authorized by law.
Health Oversight Activities: We may disclose PHI to federal or state agencies that oversee our activities (e.g., providing health care, seeking payment, integrity agreements, audits, and civil rights).
Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, or a guardianship proceeding, we may disclose PHI subject to certain limitations and only to the extent permissible by law.
Law Enforcement: We may release PHI if asked to do so by a law enforcement official:
In response to a court order, warrant, summons or similar process;
To identify or locate a suspect, fugitive, material witness, or missing person;
About the victim of a crime under certain limited circumstances;
About a death we believe may be the result of criminal conduct;
About criminal conduct on our premises; or
In emergency circumstances, to report a crime, the location of the crime or the victims, or the identity, description or location of the person who committed the crime.
Coroners, Medical Examiners and Funeral Directors: We may release PHI to a coroner or medical examiner. We may also release PHI about patients to funeral directors as necessary to carry out their duties.

CONFIDENTIALITY OF PATIENT RECORDS

Federal law and regulations do not protect any information about suspected child or elder abuse or neglect from being reported under applicable state law to appropriate state or local authorities.

OTHER USES OF YOUR HEALTH INFORMATION

Certain uses and disclosures of PHI will be made only with your written authorization;

Use that constitute a sale of PHI under the Privacy Rule. Other uses and disclosures of PHI not covered by this notice or the laws that apply to us will be made only with your written authorization. You have the right to revoke that authorization at any time, provided that the revocation is in writing, except to the extent that we already have taken action in reliance on your authorization.

YOUR RIGHTS

You have the right to request restrictions on our uses and disclosures of PHI for treatment, payment and health care operations. However, we are not required to agree to your request unless the disclosure is to a health plan in order to receive payment, the PHI pertains solely to your health care items or services for which you have paid the bill in full, and the disclosure is not otherwise required by law. To request a restriction, you may make your request in writing to the Privacy Officer.

You have the right to reasonably request to receive confidential communications of your PHI by alternative means or at alternative locations, including electronically. To make such a request, you may submit your request in writing to the Privacy Officer.

You have the right to inspect and copy the PHI contained in our provider records, except for:

psychotherapy notes, (i.e., notes that have been recorded by a mental health professional documenting counseling sessions and have been separated from the rest of your medical record);
information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding;
PHI involving laboratory tests when your access is restricted by law;
if we obtained or created PHI as part of a research study, your access to the PHI may be restricted for as long as the research is in progress, provided that you agreed to the temporary denial of access when consenting to participate in the research;
PHI contained in records kept by a federal agency or contractor when your access is restricted by law; and
PHI obtained from someone other than us under a promise of confidentiality when the access requested would be reasonably likely to reveal the source of the information.

In order to inspect or obtain a copy of your PHI, you may submit your request in writing to the Privacy Officer. If you request a copy, we may charge you a fee for the costs of copying and mailing your records, as well as other costs associated with your request.

We may also deny a request for access to PHI under certain circumstances if there is a potential for harm to yourself or others. If we deny a request for access for this purpose, you have the right to have our denial reviewed in accordance with the requirements of applicable law.

You have the right to request an amendment to your PHI but we may deny your request for amendment, if we determine that the PHI or record that is the subject of the request:

was not created by us, unless you provide a reasonable basis to believe that the originator of PHI is no longer available to act on the requested amendment;
is not part of your medical or billing records or other records used to make decisions about you;
is not available for inspection as set forth above; or
is accurate and complete.

In any event, any agreed upon amendment will be included as an addition to, and not a replacement of, already existing records. In order to request an amendment to your PHI, you must submit your request in writing to the Privacy Officer, along with a description of the reason for your request.

You have the right to receive an accounting of disclosures of PHI made by us to individuals or entities other than to you for the six (6) years prior to your request, except for disclosures:

to carry out treatment, payment and health care operations as provided above;
incidental to a use or disclosure otherwise permitted or required by applicable law;
pursuant to your written authorization;
to persons involved in your care or for other notification purposes as provided by law;
for national security or intelligence purposes as provided by law;
to correctional institutions or law enforcement officials as provided by law;
as part of a limited data set as provided by law.

To request an accounting of disclosures of your PHI, you must submit your request in writing to the Privacy Officer. Your request must state a specific time period for the accounting (e.g., the past year). The first accounting you request within a twelve (12) month period will be free. For additional accountings within twelve (12) months of the first request, we may charge you for the costs of providing the list. We will notify you of the costs involved, and you may choose to withdraw or modify your request at that time before any costs are incurred.

You have the right to receive a notification, in the event that there is a breach of your unsecured PHI, which requires notification under the Privacy Rule.

NOTICE REGARDING USE OF TECHNOLOGY

We may use electronic software, services, and equipment, including without limitation email, video conferencing technology, cloud storage and servers, internet communication, cellular network, voicemail, facsimile, electronic health record, and related technology (“Technology”) to share PHI with you or third-parties subject to the rights and restrictions contained herein. In any event, certain unencrypted storage, forwarding, communications and transfers may not be confidential. We will take measures to safeguard the data transmitted, as well as ensure its

integrity against intentional or unintentional breach or corruption. However, in very rare circumstances security protocols could fail, causing a breach of privacy or PHI.

CHANGES TO THIS NOTICE

We reserve the right to change this Notice at any time, for any reason permissible by law. We reserve the right to make the revised or changed Notice effective for PHI and medical information we already have about you as well as any information we receive in the future. We will post a copy of the current Notice at https://www.asltelemed.com/privacy-practices/. and provide copies to the facilities we provide care at.

COMPLAINTS

If you believe that your privacy rights have been violated, you should immediately contact us at contact@asltelemed.com. We will not take action against you for filing a complaint. You also may file a complaint with the Secretary of the U. S. Department of Health and Human Services by sending a letter to: 200 Independence Avenue, S.W, Washington, D.C., 20201. Or calling: 1-877-696-6775, or visiting: www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

CONTACT PERSON

If you have any questions or would like further information about this Notice, please contact us at contact@asltelemed.com.

Privacy Policy & Practices

Effective: August 1, 2024

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