HIPAA Notice of Privacy Policies

Effective: June 4, 2026

Contact: Privacy Officer | [email protected] | 1-844-401-2229

 

This notice (the “Notice”) outlines your protected health information, as defined under Health Insurance Portability and Accountability Act (“HIPAA”), as may be amended from time to time, and how it may be used, and what your rights are. Please review carefully. Questions about this notice can be directed to Flourish Collective.

OUR PLEDGE REGARDING PROTECTED HEALTH INFORMATION:

We, Flourish Collective understand that protected health information about you and your health is personal. We are committed to protecting health information about you. This Notice applies to all of the records of your care generated by Flourish Collective, whether made by Flourish Collective personnel or your personal doctor or other health care provider. This Notice will tell you about the ways in which we may use and disclose protected health information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of protected health information. The law requires us to:

• make sure that protected health information that identifies you is kept private
• notify you about how we protect protected health information about you
• explain how, when and why we use and disclose protected health information
• follow the terms of the Notice that is currently in effect.

We are required to follow the procedures in this Notice. We reserve the right to change the terms of this Notice and to make new notice provisions effective for all protected health information that we maintain by:

• posting the revised Notice in our office
• making copies of the revised Notice available upon request
• posting the revised Notice on our website.

HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU

The following categories describe different ways that we use and disclose protected health information without your written authorization.

For Treatment: We may use protected health information about you to provide you with, coordinate or manage your medical treatment or services. We may disclose protected health information about you to doctors, nurses, or other personnel who are involved in taking care of you. Flourish Collective staff may also share protected health information about you in order to coordinate the different things you need, such as referrals. We also may disclose protected health information about you to people outside Flourish Collective’s office who may be involved in your medical care. We may use and disclose protected health information to contact you as a reminder that you have an appointment for treatment or medical care at Flourish Collective. We may use and disclose protected health information to tell you about or recommend possible treatment options or alternatives or health-related benefits or services. We may also share your protected health information with hospitals, health systems, or other clinical providers through a secure care coordination platform to support referral management, care triage, and coordination of services between Flourish and your other health care providers. Access is limited to providers with an established relationship to your care and to the minimum information necessary for coordination purposes.

For Payment for Services: We may use and disclose protected health information about you so that the treatment and services you receive at Flourish Collective may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about services you received at Flourish Collective so your health plan will pay us or reimburse you for the service. We may also tell your health plan about the services you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.

For Health Care Operations: We may use and disclose protected health information about you for Flourish Collective health care operations, such as our quality assessment and improvement activities, case management, coordination of care, business planning, customer services and other activities. These uses and disclosures are necessary to support our operations and the quality and coordination of your care, reduce health care costs, and make sure that all of our patients receive quality care. We may also combine protected health information about many Flourish Collective patients to decide what additional services Flourish Collective should offer, what services are not needed, and whether certain new treatments are effective. We may also combine the protected health information we have with protected health information from other health care facilities to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of protected health information so others may use it to study healthcare and health care delivery without learning who the specific patients are. Subject to applicable state law, in some limited situations the law allows or requires us to use or disclose your health information for purposes beyond treatment, payment, and operations. However, some of the disclosures described below may never apply to the services we provide.

As Required By Law: We will disclose protected health information about you when required to do so by federal, state or local law.

Research: We may disclose your PHI to researchers when their research has been approved by an institutional review board or privacy board that has reviewed the research proposal and established protocols to ensure the privacy of your information.

Health Risks: We may disclose protected health information about you to a government authority if we reasonably believe you are a victim of abuse, neglect, or domestic violence. We will only disclose this type of information to the extent required by law, if you agree to the disclosure, or if the disclosure is allowed by law and we believe it is necessary to prevent or lessen a serious and imminent threat to you or another person.

Judicial and Administrative Proceedings: If you are involved in a lawsuit or dispute, we may disclose your information in response to a court or administrative order. We may also disclose health information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made, either by us or the requesting party, to tell you about the request or to obtain an order protecting the information requested.

Business Associates: We may disclose information to business associates who perform services on our behalf (such as billing companies); however, we require them to appropriately safeguard your information.

Public Health: As required by law, we may disclose your protected health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.

To Avert a Serious Threat to Health or Safety: We may use and disclose protected health information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.

Health Oversight Activities: We may disclose health information to a health oversight agency for activities authorized by law. These activities include audits, investigations, and inspections, which may be necessary for licensure and for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Law Enforcement: We may release protected health information as required by law, or in response to an order or warrant of a court, a subpoena, or an administrative request. We may also disclose protected health information in response to a request related to identification or location of an individual, victims of crime, decedents, or a crime on the premises.

Organ and Tissue Donation: If you are an organ donor, we may release protected health information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank to facilitate organ or tissue donation and transplantation.

Special Government Functions: If you are a member of the armed forces, we may release protected health information about you if it relates to military and veterans’ activities. We may also release your protected health information for national security and intelligence purposes, protective services for the President, and medical suitability or determinations of the Department of State.

Coroners, Medical Examiners, and Funeral Directors: We may release protected health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also disclose protected health information to funeral directors consistent with applicable law to enable them to carry out their duties.

Correctional Institutions and Other Law Enforcement Custodial Situations: If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release protected health information about you to the correctional institution or law enforcement official as necessary for your or another person’s health and safety.

Worker’s Compensation: We may disclose information as necessary to comply with laws relating to worker’s compensation or other similar programs established by law.

Food and Drug Administration: We may disclose to the FDA, or persons under the jurisdiction of the FDA, protected health information relative to adverse events with respect to drugs, foods, supplements, products and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.

De-identified and aggregated data: We may use or disclose your health information in a de-identified and/or aggregated manner to analyze our patients’ experiences and help improve our services as permitted under HIPAA. We may also remove or de-identify information that identifies you so that others can use the de-identified information to study healthcare, conduct research, collect population health data, and determine methods for improved health care delivery without learning who you are.

Health Information Exchanges: We may use, disclose or access your clinical records from authorized health information exchanges (HIEs). Data is used to perform detailed clinical chart reviews and to assess patient risk. Certain charting notes and analysis outcomes may be shared back with the respective HIEs to ensure data accuracy, improve patient care coordination, and maintain the integrity of health records. Please call or write to the contact in the Header of this agreement if you wish to limit our use of your clinical records via health information exchanges. We will accommodate reasonable requests consistent with applicable law and your care needs.

Artificial Intelligence and Automated Tools: We may use automated tools, including algorithms and artificial intelligence, to support our care coordination and operations; for example, to help identify patients who may benefit from additional outreach or support and to assist our care team in coordinating your care. These tools assist our staff; they do not make autonomous care decisions, and all care decisions remain with qualified members of your care team. Any use of your information to develop or improve these tools will be limited to de-identified or aggregated information, will be conducted as research under the oversight of an Institutional Review Board, or will be done only with your authorization. We do not sell your protected health information.

YOU CAN OBJECT TO CERTAIN USES AND DISCLOSURES. Unless you object, or request that only a limited amount or type of information be shared, we may use or disclose protected health information about you in the following circumstances:

• We may share with a family member, relative, friend, or other person identified by you protected health information directly relevant to that person’s involvement in your care or payment for your care. We may also share information to notify these individuals of your location, general condition or death.
• We may share information with a public or private agency (such as the American Red Cross) for disaster relief purposes. Even if you object, we may still share this information if necessary for the emergency circumstances.

If you would like to object to use and disclosure of protected health information in these circumstances, please call or write to the contact in the Header of this agreement.

YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION ABOUT YOU.

You have the following rights regarding protected health information we maintain about you:

Right to Inspect and Copy: You have the right to inspect and receive a copy of the protected health information we maintain about you, including your medical and billing records. To request access, submit your request in writing to Flourish Collective. We will respond within 30 days. If your records are maintained electronically, you may request an electronic copy in your preferred format. If we cannot produce records in the format you request, we will work with you on an alternative. We may charge a reasonable fee that reflects our actual costs. If we deny any part of your request, we will explain why in writing.

Right to Amend: If you feel that protected health information we have about you is incorrect or incomplete, you may ask us to amend or supplement the information. To request an amendment, your request must be made in writing and submitted to Flourish Collective. In addition, you must provide a reason that supports your request. We will act on your request for an amendment no later than 60 days after receiving the request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request, and will provide a written denial to you. In addition, we may deny your request if you ask us to amend information that:

• Was not created by us, unless the person or entity that created the information is no longer available to make the amendment
• Is not part of the protected health information kept by Flourish Collective
• Is not part of the information which you would be permitted to inspect and copy, or
• We believe is accurate and complete.

Right to an Accounting of Disclosures: You have the right to request an "accounting of disclosures." This is a list of the disclosures we made of protected health information about you. To request this list or accounting of disclosures, you must submit your request in writing to Flourish Collective. You may ask for disclosures made up to six years before your request. The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We are required to provide a listing of all disclosures except the following:

• For your treatment
• For billing and collection of payment for your treatment
• For health care operations
• Made to or requested by you, or that you authorized
• Occurring as a byproduct of permitted use and disclosures
• For national security or intelligence purposes or to correctional institutions or law enforcement regarding inmates
• As part of a limited data set of information that does not contain information identifying you

Right to Request Restrictions: You have the right to request a restriction or limitation on the protected health information we use or disclose about you for treatment, payment or health care operations or to persons involved in your care. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment, the disclosure is to the Secretary of the Department of Health and Human Services, or the disclosure is for one of the purposes described above. You have the right to request that we not disclose to your health plan information about a service you paid for in full, out of pocket. We are required to honor this specific request. To request restrictions, you must make your request in writing to Flourish Collective.

Right to Request Confidential Communications: You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing to Flourish Collective. We will accommodate all reasonable requests.

Right to a Paper Copy of This Notice: You have the right to a paper copy of this Notice at any time by contacting Flourish Collective.

Right to Notification of a Breach: If your unsecured protected health information is involved in a breach, we are required by law to notify you. We will do so without unreasonable delay and no later than 60 days after we discover the breach. Our notification will describe what happened, what types of information were involved, steps you can take to protect yourself, and what we are doing to address the situation. If we cannot reach you directly, we may provide notice through our website or other means permitted by law. Questions about a potential breach may be directed to our Privacy Officer.

Additional Rights Under State Law: Depending on the state in which you receive services, you may have additional rights regarding your protected health information under applicable state law. In some states where we operate, state law provides greater privacy protections than federal law, including additional restrictions on how your information may be used or disclosed and additional rights you may exercise. Where state law provides greater protections, we will comply with those requirements. If you have questions about the specific state laws that apply to your care, please contact our Privacy Officer.

OTHER USES AND DISCLOSURES

We will obtain your written authorization before using or disclosing your protected health information for purposes other than those provided for above (or as otherwise permitted or required by law). You may revoke this authorization in writing at any time. Upon receipt of the written revocation, we will stop using or disclosing your information, except to the extent that we have already taken action in reliance on the authorization. Most uses and disclosures for marketing purposes, and any disclosure that constitutes a sale of your protected health information, will be made only with your written authorization.

YOU MAY FILE A COMPLAINT ABOUT OUR PRIVACY PRACTICES

If you believe your privacy rights have been violated, you may file a complaint with Flourish Collective, or file a written complaint with the Secretary of the Department of Health and Human Services. A complaint to the Secretary should be filed within 180 days of the occurrence of the complaint or violation. If you file a complaint, we will not take any action against you or change our treatment of you in any way.