Privacy Policy

Last updated 11/18/2022

This Privacy Notice is designed to help you understand how Arise Health, Inc. and its affiliates including Arise Health Associates, P.A. (“Arise,” “we,” “us,” or “our”) collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.
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1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL DATA TRANSFERS
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
12. CHILDREN’S INFORMATION
13. OTHER PROVISIONS
14. CONTACT US

1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE

‍This Privacy Notice applies to personal information processed by us, including on our websites, our telehealth services supporting eating disorders and mental health needs and virtual coaching services (collectively, “Virtual Visits”), and other online or offline offerings. Arise provides Virtual Visits through affiliated licensed professionals (“Professionals”) and through unlicensed coaches (“Care Advocates”). To make this Privacy Notice easier to read, our websites, Virtual Visits, and other offerings are collectively called the “Services.”

‍Supplemental Notices. Arise may provide additional privacy notices to individuals at the time we collect their personal information. These additional privacy notices may supplement this Privacy Notice or may apply in lieu of this Privacy Notice.

‍HIPAA Notice of Privacy Practices. This Privacy Notice does not apply to our Covered Entity, Arise Health Associates, P.A.’s, processing of “Protected Health Information” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Where we act as a Covered Entity, Arise Health Associates, P.A.’s processing of “Protected Health Information” is governed by our HIPAA Notice of Privacy Practices attached hereto as Exhibit A.

‍Notice Regarding Customer Data. In some cases, a customer or affiliated professional corporation may enter into a written agreement with us where we process personal information and/or Protected Health Information on their behalf (“Customer Data”). This Privacy Notice does not apply to Customer Data. The customer’s or affiliated professional corporation’s respective privacy policy and/or notice of privacy practices governs their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with the customer or affiliated professional corporation, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to our customer or affiliated professional corporation.

‍Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

2. PERSONAL INFORMATION WE COLLECT
‍The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly
‍We may collect personal information that you provide to us.

- Account Information. We may collect personal information when in connection with the creation and administration of your account, such as name, email address, phone number, professional details, and any other information that you provide.^-‍Health Information. In providing Services to you, we may collect personal information that relates to your health or medical treatment that you have received. This may include, but is not limited to, information about any eating disorders or mental health issues, medical history, information about your diet and wellness activities, and insurance information.

- Virtual Visits – Telehealth. If we connect you with a Professional or Care Advocate via a Virtual Visit, you will need to provide access to your camera and microphone. We and others with whom you video chat (e.g., a Professional or Care Advocate) may collect the content and information you make available.

- ‍Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services with a credit or debit card are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).

- Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter,request customer or technical support, or otherwise communicate with us.

- Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging, chat, and telehealth features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

- Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.‍

B. Personal Information Collected Automatically
‍We may collect personal information automatically when you use our Services.

- Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

- Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

- Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties. See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.‍

- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:

- Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

C. Personal Information Collected from Other Sources
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‍Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

‍Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

3. HOW WE USE YOUR PERSONAL INFORMATION
‍We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services
‍We use your information to fulfill our contract with you and provide you with our Services, such as:

- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Processing applications if you apply for a job we post on our Services; and
- Allowing you to register for events.

Administrative Purposes
‍We use your information for various administrative purposes, such as:
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- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services; Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading, or enhancing our Services;
- Developing new products and services;
- Determining your eligibility for research, trials, or related activities;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions, and other compliance activities;
- Sharing personal information with third parties as needed to provide the Services;
- Enforcing our agreements and policies; and
- Carrying out activities that are required to comply with our legal obligations.

C. To Create De-Identified and/or Aggregated Information
‍We may use your personal information to create de-identified and/or aggregated information, such as demographic information, information about health or wellness results, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, publications, making de-identified and/or aggregated information available to third parties, and any other legally permissible purposes.

D. Marketing and Advertising our Products and Services

‍We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

E. With Your Consent

‍We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

F. Other Purposes
‍We also use your personal information for other purposes as requested by you or as permitted by applicable law.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

‍We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services
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‍The categories of third parties with whom we may share your personal information are described below.
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- Professionals or Care Advocates You Share or Interact With. Our Services may allow you to share personal information or interact with a Professional or Care Advocate (for example, through a Virtual Visit).
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- Other Users You Share or Interact With. Our Services may allow you to share personal information or interact with other Arise end-users.

- Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

- Third-Party Services You Share or Interact With. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (which, for clarity, may include third-party healthcare or other similar providers) (collectively, “Third-Party Services”). Any information shared with or otherwise collected by a Third-Party Service may be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

- Affiliates. We may share your personal information with our affiliated entities including affiliated professional corporations that employ or contract with Professionals.

- Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

- APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to Protect Us or Others
‍We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset TransfersIf we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

‍YOUR PRIVACY CHOICES AND RIGHTS‍

‍Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

- Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Notice).

- Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

- Phone Calls. If you receive an unwanted marketing phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.

- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

- Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

‍Your Privacy Rights. In accordance with applicable law, you may have the right to:

- Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);

- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

- Request Deletion of your personal information;

- Request Restriction of or Object to our processing of your personal information; and

- Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below or as otherwise instructed in the additional privacy notices provided at the time we collect your personal information. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION
‍We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

‍All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

8. RETENTION OF PERSONAL INFORMATION

‍We store the personal information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTSThis Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Arise has collected about them, and whether Arise disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

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Category of Personal Information Collected by Arise

Category of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers

- Professionals or Care Advocates You Share or Interact With
- Other Users You Share or Interact With
- Service Providers
- Third-Party Services You Share or Interact With
- Affiliates
- Advertising Partners

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Protected classification characteristics under California or federal law

Commercial information

- Professionals or Care Advocates You Share or Interact With
- Other Users You Share or Interact With
- Service Providers
- Third-Party Services You Share or Interact With
- Affiliates

Biometric information

- Professionals or Care Advocates You Share or Interact With
- Other Users You Share or Interact With
- Service Providers
- Third-Party Services You Share or Interact With
- Affiliates

Internet or other electronic network activity

Sensory data

- Professionals or Care Advocates You Share or Interact With
- Other Users You Share or Interact With
- Service Providers
- Third-Party Services You Share or Interact With
- Affiliates

Professional or employment-related information

Inferences drawn from other personal information to create a profile about a consumer

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

‍Additional Privacy Rights for California Residents‍

‍“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Arise does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age

‍Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. ‍

‍Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “Contact Us” below for additional instructions.

‍Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

‍Refer-a-Friend and Similar Incentive Programs. As described above in “How We Use Your Personal Information” (“Share Content with Friends or Colleagues”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide your personal information in exchange for a reward, or provide personal information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your personal information to us depends on how you ultimately use our Services, whereas the value of the referred party’s personal information to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered in connection with each program.

‍De-Identified Information. If we create or receive de-identified information, we will not attempt to reidentify such information, except to comply with applicable law.

10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. If applicable, you can exercise this right by contacting us at the email address listed in Contact Us below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

11. CHILDREN’S INFORMATION
The Services are not directed to children under 18, and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

13. OTHER PROVISIONS‍Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

‍Supervisory Authority. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law. EEA Data Protection Authorities (DPAs)Swiss Federal Data Protection and Information Commissioner (FDPIC)UK Information Commissioner’s Office (ICO).

‍CONTACT US
‍Arise is the controller of the personal information we process under this Privacy Notice. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:
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Arise Health, Inc.
228 Park Ave. S PMB 42111
New York, NY 10003
‍privacy@wearise.com

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EXHIBIT A‍

‍Arise HIPAA Notice of Privacy Practices‍
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1. SCOPE AND UPDATES TO THIS NOTICEThis HIPAA Notice of Privacy Practices (“Notice”) describes how Arise Health, Inc. or its affiliated professional corporation (“Arise,” “we,” “us,” or “our”) may use and disclose your protected health information (“PHI”) when it acts as a covered entity under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and how you can get access to this PHI. Please review this Notice carefully.

‍Supplemental Notices. Arise may provide additional privacy notices to individuals at the time we collect their PHI. These additional privacy notices may supplement this Notice or may apply in lieu of this Notice.

‍Notice Regarding Customer PHI. In some cases, our customer may enter into a written agreement with us where we act as a business associate and process protected health information on their behalf through their use of our services (“Customer PHI”). This Notice does not apply to Customer PHI. Our customers’ respective privacy notices govern their use and disclosure of Customer PHI. Our processing of Customer PHI is governed by the business associate agreements that we have in place with our customers, not this Notice. Any questions or requests relating to Customer PHI should be directed to our customer.

‍Changes to our Notice. We can change the terms of this Notice, and the changes will apply to all PHI we have about you. The new Notice will be available upon request, in our office, and on our website.

2. USES AND DISCLOSURES OF YOUR PHI THAT DO NOT REQUIRE YOUR AUTHORIZATION

‍Arise uses and discloses PHI in a number of ways connected to your treatment, payment for your care, and our healthcare operations. Some examples of how we may use or disclose your PHI without your authorization are listed below.

A. Treatment
‍We can use your PHI to treat you and share it with other professionals who are treating you. For example, if a doctor treating you asks another doctor about your overall health condition.

B. Payment
‍We can use and share your PHI to bill and collect payment from health plans or other entities. For example, if we bill your health insurance, we give PHI about you to your health insurance plan so it will pay for your services.

C. Healthcare Operations
We can use and share your PHI to administer and support our business activities or those of other healthcare organizations (as allowed by law), including providers and plans. For example (and without limitation), we may use your PHI to conduct quality analysis, data aggregation, review and improve our services and the care you receive, and to provide training.

D. Other Uses and Disclosures
‍We may use or disclose your PHI without your authorization for legal and/or governmental purposes in the following circumstances:

- As Required by Law: When we are required by laws, including workers' compensation laws.

- Public Health and Safety: To an authorized public health authority or individual to:
- Protect public health and safety.
- Prevent or control disease, injury, or disability.
- Report vital statistics such as births or deaths.
- Investigate or track problems with prescription drugs and medical devices.

- Abuse or Neglect: To government entities authorized to receive reports regarding abuse, neglect, or domestic violence.

- Minors: In general, parents and legal guardians are legal representatives of minor patients. However, in certain circumstances, as dictated by state law, minors can act on their own behalf and consent to their own treatment. In general, we will share the PHI of a patient who is a minor with the minor’s parents or guardians, unless the minor could have consented to the care themselves (except where parental disclosure may be required per applicable law).

- Oversight Agencies: To health oversight agencies for certain activities such as audits, examinations, investigations, inspections, and licensures.

- Legal Proceedings: In the course of any legal proceeding or in response to an order of a court or administrative agency and in response to a subpoena, discovery request, or other lawful process.

- Law Enforcement: To law enforcement officials in certain circumstances for law enforcement purposes. By way of example and without limitation, disclosures may be made to identify or locate a suspect, witness, or missing person; to report a crime; or to provide information concerning victims of crimes.

- Financial Information: We may ask you about income or other financial information to determine if you may qualify for a low income waiver for services where applicable. We may use this information for operations, marketing, and administrative purposes and to improve our service offerings.

- Research: We will not use your PHI to conduct research without your consent. We may use your PHI to determine your eligibility for research, including medical, clinical, and public health research, and/or to contact you to seek your consent to use or share your PHI for research. You will not be paid for this use.

- Military Activity and National Security: To the military and to authorized federal officials for national security and intelligence purposes, to the Department of Veterans Affairs as required by military authorities, or in connection with providing protective services to the President of the United States.

We may also use or disclose your PHI without your authorization in the following miscellaneous circumstances:

- Contacting You Directly: We may use your PHI, including your email address or phone number, to contact you. For example, we may also use this information to send you appointment reminders and other communications relating to your treatment, or let you know about treatment alternatives, research opportunities, or other health related services or benefits that may be of interest to you, via email, phone call, or text message.

- Your Arise Account: We may make certain PHI, such as information about treatment, appointment histories and medication records, accessible to you through online tools, such as email or your Arise online account.

- Family and Friends: To a member of your family, a relative, a close friend—or any other person you identify who is directly involved in your healthcare—when you are either not present or unable to make a healthcare decision for yourself and we determine that disclosure is in your best interest. We will also assume that we may disclose PHI to any person you permit to be physically present with you as we discuss your PHI with you.

- Services Description and Alternatives: To communicate with you about our services, options, or alternatives, as well as health-related benefits or services that may be of interest to you, or to describe our services to you.

- De-identified and/or Aggregated Information: We may use your PHI to create de-identified and/or aggregated information, such as demographic information, information about health or wellness, or other analyses we create. De-identified and/or aggregated information is not PHI, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, publications, making de-identified and/or aggregated information available to third parties, and any other legally permissible purposes.

- Coroners, Funeral Directors, and Organ Donation: To coroners, funeral directors, and organ donation organizations as authorized by law.

- Disaster Relief: To an authorized public or private entity for disaster relief purposes. For example, we might disclose your PHI to help notify family members of your location or general condition.

- Threat to Health or Safety: To avoid a serious threat to the health or safety of yourself and others.

3. USES AND DISCLOSURES OF YOUR PHI THAT REQUIRE YOUR AUTHORIZATION
‍Except in the situations listed in the sections above, we will use and disclose your PHI only with your written authorization. This means we will not use your PHI in the following cases, unless you give us written permission:

- Marketing Purposes, except as allowed by HIPAA or applicable law (by way of example, marketing communications allowed by HIPAA without authorization include communications pertaining to care or treatment and/or our products or services.)

- Sale of your PHI.

- Most sharing of psychotherapy notes.In some situations, federal and state laws provide special protections for specific kinds of PHI and require authorization from you before we can disclose that specially protected PHI. In these situations, we will comply with the more stringent state laws pertaining to such use or disclosure. If you have questions about these laws, please contact Arise as set forth below.

4. YOUR RIGHTS
‍Under HIPAA, you have the right to:
- Get an electronic or paper copy of your medical record
- You can ask to see or get an electronic or paper copy of your medical record and other PHI we have about you. Ask us how to do this.
- We will provide a copy or a summary of PHI, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

- Ask us to correct your medical record
- You can ask us to correct PHI about you that you think is incorrect or incomplete. Ask us how to do this.
- We may say “no” to your request, but we’ll tell you why in writing within 60 days of your request.

- Request confidential communications
- You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.

- Ask us to limit what we use or share
- You can ask us not to use or share certain PHI for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
- If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that PHI for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.

- Get a list of those with whom we’ve shared PHI
- You can ask for a list (accounting) of the times we’ve shared your PHI for six years prior to the date you ask, who we shared it with, and why.
- We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

- Get a copy of this Notice
You can ask for a paper copy of this Notice at any time, even if you have agreed to receive the Notice electronically.

- Choose someone to act for you‍
- If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your PHI.
- We will make sure the person has this authority and can act for you before we take any action.

‍File a complaint if you feel your rights are violated
- You can complain if you feel we have violated your rights by contacting us using the information set forth below.
- You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
- We will not retaliate against you for filing a complaint.
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YOUR CHOICES
‍For certain PHI, you can tell us your choices about what we share. If you have a clear preference for how we share your PHI in the situations described below, talk to us. Tell us what you want us to do, and we will aim to follow your instructions.

In these cases, you have both the right and choice to tell us to:
- Share PHI with your family, close friends, or others involved in your care;
- Share PHI in a disaster relief situation; and
- Include your PHI in a hospital directory.

‍If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your PHI if we believe it is in your best interest. We may also share your PHI when needed to lessen a serious and imminent threat to health or safety.‍

‍OUR RESPONSIBILITIES
- We are required by law to maintain the privacy and security of your PHI.
- We are required by law to notify you in the case of a breach of unsecured PHI.
- We must follow the duties and privacy practices described in this Notice and give you a copy of it.
- We will not use or share your PHI other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

‍CONTACT US If you have any questions about our privacy practices or this Notice, or to exercise your rights as detailed in this Notice, please contact us at:

Arise Health Associates, P.A.
228 Park Ave S.PMB 42111
New York, NY 10003
privacy@wearise.com

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