Notice of Privacy Practices

XRHEALTH USA INC. NOTICE OF PRIVACY PRACTICES

Effective Date 10.16.2020

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 of Privacy Practices (“Notice”), we use terms like “we,” “us” or “our” to refer to XRHealth USA Inc., its physicians, employees, staff, and other personnel. All of the sites and locations of XRHealth USA Inc. follow the terms of this Notice.

This Notice describes how we may use and disclose your protected health information(“health information”) . This Notice also outlines our legal duties for protecting the privacy of your health information and it explains your rights concerning your health information. This Notice is provided to you pursuant to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”).

We will create a record of the services we provide you, and this record will include your health information. We need to maintain this information to ensure that you receive quality care and to meet certain legal requirements related to providing you care. We understand that your health information is personal, and we are committed to protecting your privacy and ensuring that your health information is not used inappropriately.

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. Specifically, you have the right to request the following:

Inspect and get a copy of your medical record

  • You can ask to inspect or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this using the contact information below.
  • 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. Ask us how to do this using the contact information below.
  • We may say “no” to 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, at a home or office phone) or to send mail to a different address. You can make such a request using the contact information below.
  • We will say “yes” to all reasonable requests.

Ask us to limit what health information we use or share

  • You can ask us not to use or share certain health information for treatment, payment, or our health care operations. We are not required to agree to your request, and we may say “no” if it would affect your care. If we agree to your request, we will not use or disclose your health information in violation of that request unless it is needed to provide emergency treatment. You can request that we not use or share such health information using the contact information below.
  • If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our health care 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 information

  • You can ask for a list (accounting) of the times we’ve shared your health information for 6 years prior to the date you ask, who we shared it with, and why. You can request such a list using the contact information below.
  • 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. We will provide you with a paper copy promptly. You can ask us for a copy of this Notice using the contact information below.

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 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 at:

Michal Zuckerman

1330 Beacon Street Suite 209, Brookline, MA 02446

855-878-4193

contact@xr.health

  • 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 http://www.hhs.gov/ocr/privacy/hipaa/complaints/.
  • We will not retaliate against you for filing a complaint.

To exercise any of your rights described above, please contact:

Privacy Officer: Sagit Sade Attia

ph: +1 855-878-4193

Email: compliance@xr.health

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 health information in the situations described below, contact us via the contact information provided above. Tell us what you want us to do, and we will follow your instructions unless a law prohibits us from doing so.

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

  • Share information with your family, friends, or others involved in your care.
  • Share information in a disaster relief situation.
  • Include your information in a hospital directory. 

If you do not, or are not able, to tell us your preference, for example if you are unconscious, we may go ahead and share your health 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 health information unless you give us written permission:

  • Marketing purposes.
  • Sale of your health information.
  • Most sharing of psychotherapy notes. 

Our Uses and Disclosures Without Your Authorization

How do we typically use or share your health information?

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

For Treatment: We may use your health information to provide you with medical treatment or services. For example, your health information will be disclosed to the nurses who participate in your care. We may disclose your health information to another oncologist for the purpose of a consultation. We may also disclose your health information to your physician or another health care provider to be sure those parties have all the information necessary to diagnose and treat you.

For Payment: We may use and disclose your health information to others so they will pay us or reimburse you for your treatment. For example, a bill may be sent to you, your insurance company, or a third-party payer. The bill may contain information that identifies you, your diagnosis, and treatment or supplies used in the course of treatment. We may share your health information with pharmaceutical company patient assistance programs and patient support organizations in order to assist you in obtaining payment for your care or payment for certain parts of your care.

For Health Care Operations: We may use and disclose your health information in order to support our business activities. For example, we may use your health information for quality assessment activities, training of medical students, necessary credentialing, and for other essential activities. We may ask you to sign your name to a sign-in sheet at the registration desk and we may call your name in the waiting room when we call you for your appointment. We may disclose your health information to a third party that performs services, such as billing and collection, on our behalf. In these cases, we will enter into a written agreement with the third party to ensure they protect the privacy of your health information.

For Appointment Reminders: We may use and disclose your health information in order to contact you and remind you of an upcoming appointment for treatment or health care 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 may use and disclose your health information for public health activities, including the following:

  • To prevent or control disease, injury, or disability.
  • To report suspected abuse, neglect, or domestic violence.
  • To report adverse reactions to medications.
  • To assist with product recalls.
  • To prevent or reduce 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.

Work with medical examiner or funeral director

We can share health information with a coroner, medical examiner, or funeral director when an individual dies. This disclosure may be necessary to identify a deceased person or determine the cause of death. We may also disclose health information, as necessary, to funeral directors to assist them in performing their duties.

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.

Other Uses and Disclosures Require Your Authorization

If we wish to use or disclose your health information for a purpose not set forth in this Notice, we will seek your authorization. Specific examples of uses and disclosures of health information requiring your authorization include: (i) most uses and disclosures of your health information for marketing purposes; (ii) disclosures of your health information that constitute the sale of your health information; and (iii) most uses and disclosures of psychotherapy notes (private notes of a mental health professional kept separately from a medical record).  You may revoke an authorization in writing at any time, except to the extent that we have already taken action in reliance on your authorization.

State Law

We will not use or share your health information if state law prohibits it.  Some states have laws that are stricter than the federal privacy regulations, such as laws protecting HIV/AIDS information or mental health information.  If a state law applies to us and is stricter or places limits on the ways we can use or share your health information, we will follow the state law.  If you would like to know more about any applicable state laws, please ask us using the contact information provided above.

Our Responsibilities

  • We are required by law to maintain the privacy and security of your protected health information.
  • We are required to notify you if a breach occurs that may have compromised the privacy or security of your health information.
  • We are required to follow the legal duties and privacy practices described in this Notice and give you a copy.

Changes to this Notice

We reserve the right to change the terms of this Notice at any time. We reserve the right to make the new Notice provisions effective for all health information we currently maintain, as well as any health information we receive in the future. If we make material or important changes to our privacy practices, we will promptly revise our Notice. Each version of the Notice will have an effective date listed on the first page. Updates to this Notice are also available at our web site, www.xr.health