NOTICE OF PRIVACY PRACTICES

OPUL CLINIC, a Limited Liability Company (LLC)

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.

In this notice we use the terms "we," "us," and "our" to describe OPUL CLINIC. For more details, please refer to section IV of this notice.

I. WHAT IS "PROTECTED HEALTH INFORMATION"?

OPUL CLINIC respects your confidentiality and privacy. We have policies and procedures in place that protect your protected health information and restrict how it is used. Your protected health information (PHI) is individually identifiable health information, including demographic information, about your past, present or future physical or mental health or condition, diagnosis, healthcare services you receive, and past, present or future payment for your healthcare. Demographic information means information such as your name, Social Security number, address, date of birth, e-mail address.

PHI may be in oral, written, or electronic form. Examples of PHI include your medical record, billing records, and communications between you and your healthcare provider about your care. Your individually identifiable health information ceases to be PHI 50 years after your death.

II. ABOUT OUR RESPONSIBILITY TO PROTECT YOUR PHI

By law, we must

protect the privacy of your PHI;
tell you about your rights and our legal duties with respect to your PHI;
notify you if there is a breach of your unsecured PHI; and
tell you about our privacy practices and follow our notice currently in effect.

We take these responsibilities seriously and have put in place administrative safeguards (such as security awareness training and policies and procedures), technical safeguards (such as encryption and passwords), and physical safeguards (such as locked areas) to protect your PHI and we will continue to take appropriate steps to safeguard the privacy of your PHI.

III. YOUR RIGHTS REGARDING YOUR PHI

Although your medical file and PHI are the property of OPUL CLINIC, the information belongs to you. This section tells you about your rights regarding your PHI

Your privacy rights

Request that we communicate with you concerning your health matters in a specific way (for example, at a cellular or office telephone number or at a different address than we have on file). We will accommodate your request if possible.

You have a right to receive a paper copy of this notice upon request.

Your right to access and amend your PHI

Subject to certain exceptions, you have the right to view or get a copy of your PHI that we maintain in records relating to your care or decisions about your care or payment for your care. Requests must be in writing. After we receive your written request, we will let you know when and how you can see or obtain a copy of your record. If you agree, we will give you a summary or explanation of your PHI instead of providing copies. We may charge you a fee for the copies, summary or explanation.

If we do not have the record you asked for but we know who does, we will tell you who to contact to request it. In limited situations, we may deny some or all of your request to see or receive copies of your records, but if we do, we will tell you why in writing and explain your right, if any, to have our denial reviewed.

If you believe there is a mistake in your PHI or that important information is missing, you may request that we correct or add to the record. Requests must be in writing, tell us what corrections or additions you are requesting, and why the corrections or additions should be made. We will respond in writing after receiving your request. If we approve your request, we will make the correction or addition to your PHI. If we deny your request, we will tell you why and explain your right to file a written statement of disagreement.

Request a list of anyone who received your protected health information without your authorization for the last six years (accounting). The list includes who we shared it with, the date and why. It may include releases to attorneys, law enforcement officials, and government agencies.

Your right to choose how we send PHI to you or someone else

You may ask us to send your PHI to you at a different address (for example, your work address) or by different means (for example, fax instead of regular mail).

If your PHI is stored electronically, you may request a copy of the records in an electronic format offered by the facility. You may also make a specific written request that we transmit the electronic copy to a designated third party.

If the cost of meeting your request involves more than a reasonable additional amount, we are permitted to charge you our costs that exceed that amount.

IV. OPUL CLINIC ENTITIES SUBJECT TO THIS NOTICE

This notice applies to OPUL CLINIC, which includes:

Nurse Sally Bilodeau, RN, BSN, CLT
OPUL CLINIC Medical Director
Independent providers who are providing healthcare services at our facilities as part of the facility's medical staff

Our healthcare delivery sites include patient homes, medical offices, clinics, hospitals and ambulatory surgery centers, any other licensed facilities of OPUL CLINIC, and our website and mobile applications.

To provide you with the healthcare you expect, to treat you, to obtain payment for your care and to conduct our operations, such as quality assurance, accreditation, licensing, and compliance, these OPUL CLINIC companies share your PHI with each other.

Our personnel may have access to your PHI either as employees, physicians, professional staff members of our facilities, and other authorized persons who may need access to PHI.

V. HOW WE MAY USE AND DISCLOSE YOUR PHI

Your confidentiality is important to us. Our physicians and employees are required to maintain the confidentiality of the PHI of our patients, and we have policies and procedures and other safeguards to help protect your PHI from improper use and disclosure. Sometimes we are allowed by law to use and disclose certain PHI without your written permission. We briefly describe these uses and disclosures below and give you some examples.

How much PHI is used or disclosed without your written permission will vary depending, for example, on the intended purpose of the use or disclosure. Sometimes we may only need to use or disclose a limited amount of PHI, such as to send you an appointment reminder or to confirm your identity. At other times, we may need to use or disclose more PHI, such as when we are providing medical treatment.

Treatment: This is the most important use and disclosure of your PHI. For example, our physicians, nurses, and other healthcare personnel, including trainees, involved in your care, use and disclose your PHI to diagnose your condition and evaluate your healthcare needs. Our personnel will use and disclose your PHI in order to provide and coordinate the care and services you need: for example, prescriptions, X-rays, and lab work. If you need care from healthcare providers who are not part of OPUL CLINIC, such as a local hospital or community resources to assist with your healthcare needs, we may disclose your PHI to them.
Payment: Your PHI may be needed to permit us to bill and collect payment for treatment and health-related services that you receive. For example, we may have an obligation to disclose your PHI to your health plan in order to obtain payment. We may also disclose your PHI to third parties for collection of payment.
Healthcare operations: We may use and disclose your PHI for certain healthcare operations, for example, quality assessment and improvement, training and evaluation of healthcare professionals, licensing, accreditation, and other business activities that are part of providing healthcare.
Business associates: We may contract with business associates to perform certain functions or activities on our behalf, such as payment and healthcare operations. These business associates must agree to safeguard your PHI.
Appointment reminders: We may use your PHI to contact you about appointments for treatment or other healthcare you may need.
Photographs, videotapes, and digital or other images may need to be recorded to document your care. OPUL CLINIC retains ownership rights to these photographs, videotapes, and digital or other images. We will store them in a secure manner to protect your privacy. You have the same rights outlined above to see these images or to obtain copies.

Specific types of PHI: There are stricter requirements for use and disclosure of some types of PHI, for example, drug and alcohol abuse treatment records. However, there are still circumstances in which this information may be used or disclosed without your authorization.

Communications with family and others when you are present: Sometimes a family member or other person involved in your care will be present when we are discussing your PHI with you. If you object, please tell us and we won't discuss your PHI or we will ask the person to leave.
Disclosure in case of disaster relief: We may disclose your name, city of residence, age, gender, and general condition to a public or private disaster relief organization to assist disaster relief efforts, unless you object at the time.
Organ donation: We may use or disclose PHI to organ-procurement organizations to assist with organ, eye, or other tissue donations.
Public health activities: Public health activities cover many functions performed or authorized by government agencies to promote and protect the public's health and may require us to disclose your PHI.
- For example, we may disclose your PHI as part of our obligation to report to public health authorities certain diseases, injuries, conditions, and vital events such as births. Sometimes we may disclose your PHI to someone you may have exposed to a communicable disease or who may otherwise be at risk of getting or spreading the disease.
- The Food and Drug Administration (FDA) is responsible for tracking and monitoring certain medical products, such as pacemakers and hip replacements, to identify product problems and failures and injuries they may have caused. If you have received one of these products, we may use and disclose your PHI to the FDA or other authorized persons or organizations, such as the maker of the product.
- We may use and disclose your PHI as necessary to comply with federal and state laws that govern workplace safety.
Health oversight: As healthcare providers, we are subject to oversight conducted by federal and state agencies. These agencies may conduct audits of our operations and activities and in that process, they may review your PHI.
Workers' compensation: We may use and disclose your PHI in order to comply with workers' compensation laws. For example, we may communicate your medical information regarding a work-related injury or illness to claims administrators, insurance carriers, and others responsible for evaluating your claim for workers' compensation benefits.
Military activity and national security: We may sometimes use or disclose the PHI of armed forces personnel to the applicable military authorities when they believe it is necessary to properly carry out military missions. We may also disclose your PHI to authorized federal officials as necessary for national security and intelligence activities or for protection of the president and other government officials and dignitaries.
Required by law: In some circumstances, federal or state law requires that we disclose your PHI to others. For example, the secretary of the Department of Health and Human Services may review our compliance efforts, which may include seeing your PHI.
Lawsuits and other legal disputes: We may use and disclose PHI in responding to a court or administrative order, a subpoena, or a discovery request. We may also use and disclose PHI to the extent permitted by law without your authorization, for example, to defend a lawsuit or arbitration.
Law enforcement: We may disclose PHI to authorized officials for law enforcement purposes, for example, to respond to a search warrant, report a crime on our premises, or help identify or locate someone.
Serious threat to health or safety: We may use and disclose your PHI if we believe it is necessary to avoid a serious threat to your health or safety or to someone else's.
Abuse or neglect: By law, we may disclose PHI to the appropriate authority to report suspected child abuse or neglect or to identify suspected victims of abuse, neglect, or domestic violence.
Coroners and funeral directors: We may disclose PHI to a coroner or medical examiner to permit identification of a body, determine cause of death, or for other official duties. We may also disclose PHI to funeral directors.

VI. ALL OTHER USES AND DISCLOSURES OF YOUR PHI REQUIRE YOUR PRIOR WRITTEN AUTHORIZATION

Except for those uses and disclosures described above, we will not use or disclose your PHI without your written authorization. Some instances in which we may request your authorization for use or disclosure of PHI are:

Marketing: To tell you about or recommend possible treatment options, products or services offered by OPUL CLINIC or by third party providers that may be of interest or benefit to you. Note that marketing communications do not include our contacting you with information about treatment alternatives, prescription drugs you are taking, or health-related products or services that we offer. Marketing also does not include any face-to-face discussions you may have with your providers about products or services.
Sale of PHI: As a trusted health care provider, OPUL CLINIC will not sell your PHI.

When your authorization is required and you authorize us to use or disclose your PHI for some purpose, you may revoke that authorization by notifying us in writing at any time. Please note that the revocation will not apply to any authorized use or disclosure of your PHI that took place before we received your revocation.

VII. HOW TO CONTACT US ABOUT OUR PRIVACY PRACTICES

If you have questions, need more information, disagree with a decision made about access to your PHI, or if you have any concerns regarding a possible violation of your privacy, please let us know by calling or writing to:

Sally Bilodeau at OPUL CLINIC

telephone: (808)344-9798

fax: (808)818-1118

email: sally@opulclinic.com

You also may notify the secretary of the Department of Health and Human Services.

We will not take retaliatory action against you if you file a complaint about our privacy practices.

VIII. CHANGES TO THIS NOTICE

We may change this notice and our privacy practices at any time, as long as the change is consistent with state and federal law. Any revised notice will apply both to the PHI we already have about you at the time of the change, and any PHI created or received after the change takes effect. If we make an important change to our privacy practices, we will promptly change this notice and make the new notice available at the clinics and on the OPUL CLINIC website at www.opulclinic.com. Except for changes required by law, we will not implement an important change to our privacy practices before we revise this notice.