Notice of Privacy Practices for Zyvyo Health

If you are a California resident, please refer to our Privacy Information for California Residents section.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

Effective Date: March 20, 2025

Introduction

Zyvyo Health and its affiliates (collectively, "Zyvyo," "Zyvyo Telehealth," "Zyvyo Health," "we," "our," or "us") are committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit any Zyvyo website that links to this Privacy Policy (collectively, our "Websites"); use any affiliated mobile applications (the "Apps") that link to or contain this Privacy Policy; or otherwise provide data to Zyvyo. We refer to the Websites, Apps, and other services provided by Zyvyo together in this Privacy Policy as the "Services." This Privacy Policy is incorporated into our Terms of Use. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Use.

Your Information. Your Rights. Our Responsibilities.

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.

Your Rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

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 health information we have about you. Please contact our Privacy Officer for instructions on how to submit this request.

• We will provide a copy or a summary of your health information, 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 health information about you that you think is incorrect or incomplete. Please contact our Privacy Officer for instructions.

• We may deny your request, but we'll tell you why in writing within 60 days.

Request confidential communications

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

• We will accommodate all reasonable requests.

Ask us to limit what we use or share

• You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may decline if it would affect your care.

• If you pay for a service or healthcare item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will agree unless a law requires us to share that information.

Get a list of those with whom we've shared information

• You can ask for a list (accounting) of the times we've shared your health information for six years prior to the date you ask, who we shared it with, and why.

• We will include all disclosures except for those about treatment, payment, and healthcare 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 privacy notice

• 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.

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 health information.

• We will verify that 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 our Privacy Officer at:

  • Zyvyo Health LLC

  • Privacy Officer

  • 10493 Jane Eyer Drive
    Orlando, FL 32825

  • privacy@zyvyo.com

• 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.

Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

• Share information with your family, close friends, or others involved in your care

• Share information in a disaster relief situation

• Include your information in a patient directory

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

In these cases, we never share your information unless you give us written permission:

• Marketing purposes

• Sale of your information

• Most sharing of psychotherapy notes

In the case of fundraising:

• We may contact you for fundraising efforts, but you can tell us not to contact you again.

Our Uses and Disclosures

How do we typically use or share your health information?

We typically use or share your health information in the following ways:

Treat you

• We can use your health information and share it with other professionals who are treating you.

• Example: A doctor providing telehealth services through Zyvyo consults with another doctor about your condition.

Run our organization

• We can use and share your health information to run our practice, improve your care, and contact you when necessary.

• Example: We use health information about you to manage your treatment and services, or to evaluate the quality of telehealth services provided through our platform.

Bill for your services

• We can use and share your health information to bill and get payment from health plans or other entities.

• Example: We give information about you to your health insurance plan so it will pay for your telehealth services.

How else can we use or share your health information?

We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.

Help with public health and safety issues

• We can share health information about you for certain situations such as:

  • Preventing disease

  • Helping with product recalls

  • Reporting adverse reactions to medications

  • Reporting suspected abuse, neglect, or domestic violence

  • Preventing or reducing a serious threat to anyone's health or safety

Do research

• We can use or share your information for health research.

Comply with the law

• We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we're complying with federal privacy law.

Respond to organ and tissue donation requests

• We can share health information about you with organ procurement organizations.

Work with a medical examiner or funeral director

• We can share health information with a coroner, medical examiner, or funeral director when an individual dies.

Address workers' compensation, law enforcement, and other government requests

• We can use or share health information about you:

  • For workers' compensation claims

  • For law enforcement purposes or with a law enforcement official

  • With health oversight agencies for activities authorized by law

  • For special government functions such as military, national security, and presidential protective services

Respond to lawsuits and legal actions

• We can share health information about you in response to a court or administrative order, or in response to a subpoena.

Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information.

• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.

• 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 information 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.

Telehealth-Specific Privacy Considerations

At Zyvyo Telehealth, we take additional measures to protect your privacy in the telehealth environment:

• All telehealth sessions are conducted through secure, encrypted platforms.

• We implement technical safeguards to prevent unauthorized access to your telehealth sessions and information.

• Our staff and healthcare providers receive specialized training on privacy practices for telehealth.

• We maintain audit trails of all telehealth activities to monitor and ensure compliance with privacy regulations.

Special Notice for California Residents

If you are a California resident, you have additional rights regarding your health information under the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and the Confidentiality of Medical Information Act (CMIA).

Your California Privacy Rights

In addition to the rights outlined elsewhere in this notice, California residents have the right to:

Right to Know

• You can request that we disclose to you the categories and specific pieces of personal information we have collected about you, the categories of sources from which your information is collected, the business purposes for collecting or selling your information, and the categories of third parties with whom we share your information.

Right to Delete

• You can request the deletion of your personal information that we have collected or maintain, subject to certain exceptions for information needed to complete your healthcare, comply with legal obligations, or other permitted purposes under HIPAA and California law.

Right to Opt-Out of Sale

• Zyvyo Telehealth does not sell your personal information as defined by California law. However, if this practice changes, you would have the right to opt out of such sales.

Right to Non-Discrimination

• We will not discriminate against you for exercising any of your California privacy rights. This means we will not deny you goods or services, charge you different prices, or provide a different level of quality for services based on your exercise of these rights.

How to Exercise Your California Rights

To exercise your California privacy rights described above:

• Email us at: privacy@zyvyo.com

• Visit: zyvyo.com/policies/privacy-policy

We will respond to verifiable consumer requests within 45 days of receipt. We may extend this period by an additional 45 days when reasonably necessary, in which case we will inform you of the extension.

Verification Process

To protect your information, we will take steps to verify your identity before fulfilling your request. We may require you to provide information that matches information we have on file about you.

Authorized Agent

You may designate an authorized agent to make a request on your behalf. We may require you to provide the authorized agent with written permission to do so and to verify your own identity directly with us.

California Medical Information Specific Protections

The Confidentiality of Medical Information Act (CMIA) provides additional protections for medical information beyond what is required by HIPAA. Under CMIA:

• We must obtain your authorization before disclosing your medical information for certain purposes beyond treatment, payment, or healthcare operations.

• We maintain physical, technical, and administrative safeguards to protect the confidentiality of your medical information.

• We provide employee training on privacy and confidentiality practices.

Changes to the Terms of this Notice

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, on our website, and we will mail a copy to you upon request.

This Notice of Privacy Practices applies to Zyvyo and all its healthcare providers, staff, and business associates.