Notice of Privacy Practices

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

This Notice is being provided to you on behalf of each health care provider (“HCPs”) with whom you establish a patient-provider relationship on the Twistle website or service. If you ever want to confirm who Twistle has identified as your health care providers based on your (and their) use of Twistle (and thus from whom you have acknowledged receiving this Notice of Privacy Practices (“NPP”), just ask (Twistle contact information is below).

Each of your HCPs (referred to herein as “we” “us” or “our”) is sharing this NPP with you at the time you sign up to use the Twistle website or service because federal law gives you the right to be told ahead of time about certain things regarding your medical information, also referred to as “protected health information” or “health information”:

1. 1. How we will handle your protected health information;
2. 2. Our legal obligations with respect to your protected health information; and
3. 3. Your rights with regard to your protected health information.

Twistle, Inc. is subject to the privacy and security standards set forth by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) by of each of your HCPs and you may reach us through Twistle (contact information is below).

Examples of Uses and Disclosures for Treatment, Payment and Health Care Operations

We will generally only disclose medical information about you for purposes of treatment, payment or health care operations.

Examples of these types of disclosures include, but are not limited to, the following:

1. a. A disclosure of medical information for treatment purposes occurs when we share information, including without limitation test results and interpretation of test results, symptoms or other findings with other HCPs or other health care providers through Twistle or otherwise.
2. b. A disclosure of medical information for payment purposes occurs when we submit medical records and bills concerning your treatment to an insurer for payment.
3. c. A disclosure for health care operations purposes occurs when we perform activities such as quality assessment, quality improvement, training programs, credentialing, and clinical guidelines development.

Examples of Permitted Patient Contact

We may contact you to provide you with appointment reminders, with information about treatment alternatives, or with information about other health-related benefits and services that may be of interest to you.

Examples of Permitted Communications with Family Members

Using our best judgment, we may disclose to a family member, other relative, close personal friend, or any other person you identify, health information relevant to that person's involvement in your care or in payment for such care if you do not object or in an emergency. We may also use or share your health information to notify a family member or other person thought to be responsible for you of your location, your general medical condition or death.

Other Permitted Uses and Disclosures of Protected Health Information.

We may legally use and/or share your protected health information with others for the following purposes without your specific permission:

1. a. As required by state and federal laws and regulations.
2. b. For public health activities, including required reports to the state public health and child protection authorities, and to agencies such as cancer registries.
3. c. For health oversight activities.
4. d. For legal and administrative proceedings.
5. e. For law enforcement purposes under specific conditions.
6. f. To avert a serious threat to health or safety.
7. g. As authorized by applicable workers compensation laws.
8. h. For permissible public health, health care operations, and research purposes involving limited identifiable or de-identified information.

Uses and Disclosures that Require Your Written Authorization

If we desire or are requested to use or disclose your protected health information for other than the purposes listed above, we must first obtain your written permission. If you provide your written permission for the use or disclosure of your protected health information, you may revoke such consent at any time in writing or, in certain cases, verbally, except to the extent that providers have already acted upon your previously provided consent.

Your Health Information Rights

The health and billing records we maintain are the physical property of the provider that rendered medical treatment to you. You have the following rights with respect to your protected health information:

1. a. Request a restriction on certain uses and disclosures of your health information by delivering the request in writing to our office/facility, or by using an on-line form that we may require you to use -- we are not required to grant the request but we will comply with any request granted;
2. b. Obtain a paper copy of the Notice of Privacy Practices for Protected Health Information ("Notice") by making a request at our facility;
3. c. Right to inspect and copy your health record and billing record—you may exercise this right by delivering the request in writing to our facility or by using the on-line form that we may require you to use;
4. d. Right to request that your health care record be amended to correct incomplete or incorrect information by delivering a written request to our facility or by using the on-line form that we may require you to use (please note that we are not required to make such amendments); you may file a statement of disagreement if your amendment is denied, and require that the request for amendment and any denial be attached in all future disclosures of your protected health information;
5. e. Right to receive an accounting of disclosures of your health information made in the six years prior to the date on which the accounting is requested as required to be maintained by law by delivering a written request to our facility or by using the on-line form that we may require you to use. An accounting will not include internal uses of information for treatment, payment, or operations, disclosures made to you or made at your request, or disclosures made to family members or friends in the course of providing care;
6. f. Right to confidential communication by requesting that communication of your health information be made by alternative means or at an alternative location by delivering the request in writing to our office/hospital using the form we give you upon request; and,

If you want to exercise any of the above rights, please contact the privacy officer at the HCP in question, in person or in writing, during normal hours. Please contact the Twistle privacy officer in order to identify the right person to contact. The HCP privacy officer will provide you with assistance on the steps to take to exercise your rights.

You have the right to review this Notice before signing the consent authorizing use and disclosure of your protected health information for treatment, payment, and health care operations purposes.

Our Responsibilities

We are required to:

• Maintain the privacy of your health information as required by law;
• Provide you with a notice as to our duties and privacy practices as to the information we collect and maintain about you;
• Abide by the terms of this Notice;
• Request that you sign an acknowledgement that you have received this notice (to accomplish this, Twistle logs your click on the agreement to the Twistle terms of use, and the establishment of a patient-clinician relationship via Twistle, as acknowledgment of receipt);
• Notify you if we cannot accommodate a requested restriction or request; and
• Accommodate your reasonable requests regarding methods to communicate health information with you.
• Accommodate your request for an accounting of disclosures.

We reserve the right to amend, change, or eliminate provisions in our privacy practices and access practices and to enact new provisions regarding the protected health information we maintain without notification. If our information practices change, we will amend our Notice. You are entitled to receive a revised copy of the Notice by calling and requesting a copy of our “Notice” or by visiting our facility and picking up a copy. We will ensure that Twistle posts a copy of the current version of the NPP on its website.

To Request Information or File a Complaint

If you have questions, would like additional information, or want to report a problem regarding the handling of your information, you may contact our privacy officer directly or Twistle’s privacy officer at privacy@twistle.com.

Additionally, if you believe your privacy rights have been violated, you may file a written complaint at our office by delivering the written complaint to our privacy officer or to the privacy officer of our independent contractor, Twistle, at privacy@twistle.com. Please be sure to be specific in any communication you may make. You may also file a complaint by mailing it to the U.S. Department of Health and Human Services (see the U.S. DHHS Health Information Privacy – How To File a Complaint for more information, including complaint forms and mailing addresses). We will take no retaliatory action against you if you file a complaint about our privacy practices. We cannot, and will not, require you to waive the right to file a complaint with the Secretary of Health and Human Services as a condition of receiving treatment from our affiliated providers.

Revised: March 30, 2012