HIPAA Privacy Policy

Authorized date: November 18, 2022

Prescient Medicine Holdings Inc. DBA SOLVD Health (called “SOLVD Health,” “we” or “us”) respects your privacy and is committed to protecting it through its compliance with this Privacy Policy. SOLVD Health is a limited liability company organized in the State of Delaware, with a registered address at The Corporation Trust Company, Corporation Trust Center, 1209 Orange Street, Wilmington, DE 19801, and a place of business located at 176 Hershey Road, Hershey, PA 17033.

We are required under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) to maintain the privacy of health information about you (“Protected Health Information” or “PHI”), and to notify you of our legal duties and privacy practices in relation to your Protected Health Information. This Notice of Privacy Practices (“Notice”) is given in accordance with our obligations under the HIPAA, and in compliance with the HIPPA regulations setting forth the Standards for Privacy of Individually Identifiable Health Information, (“HIPAA Privacy Standards”). We are required under these HIPAA Privacy Standards to abide by the terms of this Notice.

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.

To provide you with laboratory services, we will receive your Protected Health Information from your healthcare provider or another laboratory that asked us to test your sample. The HIPAA Privacy Standards require us to protect any health information that will identify you, such as your name, Social Security Number, telephone number, email address, mailing address, date of birth, or dates of service. We protect this information regardless of the form in which we receive it (e.g. oral, written, or recorded in another media).

Allowable Uses or Disclosures of Your Protected Health Information Without Authorization

1. The HIPAA Privacy Standards allow us to receive and disclose your Protected Health Information for routine purposes without first obtaining your authorization or giving you an opportunity to object. These routine uses include disclosures necessary for treatment, payment, and healthcare operations purposes. Each of these purposes is explained below.

• Treatment: When we receive a request for laboratory services by your healthcare provider or a referring laboratory, it may contain your name, age, and other identifiable information. The disclosure of this information to us is considered treatment, as is our subsequent disclosure of the laboratory results to the referring laboratory or your healthcare provider.
• Payment: We may legitimately use and disclose your Protected Health Information to seek payment for services we provide for you. For example, we may send your information to a billing service to file claims for us with health plans, billing collection
  agencies or other payers.
• Healthcare Operations: We may disclose your Protected Health Information as part of our internal operations to maintain the high quality of our laboratory services and to keep our organization operable. For example, we may use or disclose Protected Health Information for quality assurance, accreditation and certification, licensing, or credentialing activities.

2. The HIPAA Privacy Standards specify certain other non-routine circumstances where we may legally use or disclose your Protected Health Information without your consent. More information about these circumstances is set out below.

• Required by law: We may disclose your Protected Health Information when we are required to do so by law pursuant to a judicial or administrative proceeding (court or administrative orders, subpoena, discovery request or other lawful process.) In the case of a discovery request, we will not disclose the information unless we are satisfied that you have been given notice of the request and have not objected, or the party seeking the information obtains an order protecting the information from further disclosure.
• Personal Representatives: We may disclose Protected Health Information about you to your authorized personal representative, as defined by applicable law, or to an administrator, executor or other authorized person responsible for your estate.
• Minors: As permitted by federal and state law, we may disclose Protected Health Information about minors to their parents or guardians.
• Disclosures to Business Associates: We may disclose your Protected Health Information to other companies or individuals who need your information to provide services to us. For example, we may use another company to perform billing services on our behalf. Our business associates are required to protect the privacy of your Protected Health Information. To protect the information that is disclosed, each business associate is required to sign an agreement whereby they agree to appropriately safeguard the information and not to disclose the information unless specifically permitted by law. Upon your request and unless otherwise required by law, we will not release, and our business associates will not release, to a health care plan or insurance company PHI related to specific services that were self-paid for in full by cash, credit card, money order or check.
• Public health: As required by law, we may disclose your Protected Health Information to public health or legal authorities and other entities charged with preventing or controlling disease, injury, or disability. We may also disclose Protected Health Information for health oversight activities, such as audits, investigations, inspections and licensure activities. For example, we may disclose your Protected Health Information to agencies responsible for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.
• Research: We may disclose Protected Health Information to researchers in connection with a study, if an institution’s review board (a committee that reviews the ethics of research projects) has reviewed the proposed study and established protocols to ensure the privacy of the Protected Health Information to be used in the study, and has determined that the researcher does not need to obtain your authorization prior to using your Protected Health Information for research purposes.
• Organ procurement organizations: We may disclose Protected Health Information consistent with applicable law to organ procurement organizations or other entities for the purposes of tissue donation and transplant. We may disclose to the U.S. Food and Drug Administration Protected Health Information relating to adverse events with respect to FDA approved product that are defective, and we may post marketing surveillance information to enable product recalls, repairs, or replacement.
• Workers’ compensation: We may disclose Protected Health Information to the extent authorized by, and necessary to comply with, laws relating to workers’ compensation or other similar programs established by state law. These programs provide benefits for work-related injuries or illness.
• Correctional institution: If you are an inmate of a correctional institution, we may disclose to the institution or its agents Protected Health Information necessary for the health and safety of other individuals.
• Disclosures to Coroners, Medical Examiners and Funeral Directors: We may disclose Protected Health Information to coroners or medical examiners for identifying an individual, determining cause of death or other duty authorized by law.
• Law enforcement: We may disclose Protected Health Information for law enforcement purposes as required by law. We may also disclose Protected Health Information to appropriate agencies if we believe there is the possibility of abuse, neglect, or domestic violence.
• Genetic Information: Genetic information is considered health information and may be used and disclosed by us in the same fashion as other medical information may be used and disclosed, as described in this Notice. However, health plans are restricted as to the uses or disclosures that they may make with respect to your genetic information.
• Military and Veterans: If you are or were a member of the armed forces, we may release medical information about you to military command authorities as required by law. We may also release medical information about foreign military personnel to the appropriate foreign military authority as required by law.
• Health Oversight Activities: We may disclose medical information about you to governmental, licensing, auditing and/or accrediting agencies for activities authorized by law.

3. No Other Uses and Disclosures Without Authorization

Certain uses of your medical information, such as the use or disclosure of or access to psychotherapy notes or use or disclosure for marketing purposes, are prohibited without your express authorization. We also cannot sell your health information without your permission. Except as otherwise permitted or required under this Notice, we do not use or disclose your PHI without your written, express authorization. When we use your PHI with your authorization, we will only use or disclose it only in a manner consistent with the terms of that authorization. You may revoke the authorization to use or disclose any Protected Health Information at any time, by writing to the Privacy Officer listed at the bottom of this Notice, unless we have already acted under that authorization. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. We are unable to take back any disclosures we have already made with your permission. We will retain our records of the care provided to you as required by law.

• Research: Except as provided above, we may disclose Protected Health Information to researchers in connection with a study, if an institution’s review board has reviewed the proposed study and established protocols to ensure the privacy of the PHI to be used in the study and if you have signed an authorization that permits use of medical information.
• Communications about our Products and Services: We may use and disclose your Protected Health Information to contact you about our products and services which we believe may be of interest to you, only if you have signed an authorization that permits use of medical information.

Your Rights

1. Under the HIPAA Privacy Standards, you or your authorized designated personal representative have certain rights with respect to your Protected Health Information. As a clinical laboratory, we are also governed by the Clinical Laboratories Improvement Amendments (“CLIA”) Pursuant to CLIA, SOLVD Health does not, as a matter of practice, deal directly with patients. Our contact for PHI is usually your healthcare provider or anotherclinical laboratory that ordered the specific testing.

2. Please note that CLIA allows laboratories to disclose PHI including test reports directly to a patient in both hard copy and electronic version. We may inform the patient’s healthcare provider of any request for PHI made and filled by SOLVD Health.

3. We will accommodate requests for PHI from our healthcare provider clients and/or patients, if legally permissible. Your rights are listed below.

• Right to Inspect and Copy Personal Health Information: You have the right to request a copy of your Protected Health Information as we have received it.
• Right to Receive Personal Health Information via Confidential Communications: You have the right to request that we communicate with you about your Protected Health Information by alternative means or to an alternative address. Your request must be in writing and must specify the alternative means or location. We will accommodate reasonable requests for confidential communications.
• Right to Receive this Notice of Privacy Practices: You can request and receive a free copy of this Notice in printed or electronic form, by contacting our Privacy Officer listed at the bottom of this Notice.
• Right to Request Restrictions or Limitations on Use or Disclosure: You can request restrictions or limitations on certain uses and disclosures of your Protected Health Information. We are not required to agree with the request. If we do agree, we will not violate that restriction except when required by law. However, if you pay for your treatment in full, you have the right to restrict, unless otherwise prohibited by law, the disclosure of your medical information to your insurance company or health plan in connection with the services that are paid for in full by you and we must abide by your request in such circumstances.
• Right to Amend Protected Health Information: You can request that we amend your Protected Health Information or your clinical record. The HIPAA Privacy Standards provide that we can deny the request for amendment under certain specified circumstances. If we do deny your request to amend, we will explain to you why, and explain your rights to seek review of that decision, if required under the HIPAA Privacy Standards.
• Right to Receive an Accounting of Disclosures of Protected Health Information: You can get a written accounting of all of our disclosures of your Protected Health Information made by us or our business associates for purposes other than treatment, payment, healthcare operations and certain other activities. Your request must be in writing and made to our Privacy Officer. If such disclosures are made through an electronic health record, you have the right to receive a list of these types of disclosures as well. Unless you designate a shorter period of time, the list will include disclosures made within the prior six years, provided, however that with respect to disclosures through an electronic health record, the period is no longer than three (3) years. You may
  receive one free accounting in any 12-month period. We may charge you for additional requests.
• Right to Complain: We are committed to complying with the privacy practices described in this Notice. If you believe that we have violated any of them, you may file a complaint with us and/or with the Department of Health and Human Services, Office of Civil Rights. To file a complaint with us, please send a letter to the Privacy Officer listed at the bottom of this Notice. We will not retaliate in any way if you file a complaint with the Office of Civil Rights or with us.
• Right to Notice of a Breach: You have the right to be notified of a data breach.

Future Amendments to Privacy Policy

1. We may amend this Notice from time to time, provided such amendments are permitted by applicable law. Notice of any such amendments will be announced on the websites and will be effective immediately, unless we state otherwise. You should review the websites regularly to obtain timely notice of any such amendments.

2. If we amend this Notice, we may make the amended Notice terms effective for all Protected Health Information that we maintain, including any information created or received prior to issuing the amended Notice.

3. You may also request a copy of the current Notice by contacting Customer Service or our Corporate Privacy Officer listed at the bottom of this Notice.

Contacting our Corporate Privacy Officer
If you have any questions about this Notice or our Privacy Policy for Protected Health Information practices; or want to make a request under this Notice, please contact our Corporate Privacy Officer:

1600 Faraday Avenue
Carlsbad, CA 92008
Phone: (717) 304-6819
privacyoffice@solvdhealth.com

This Privacy Policy is effective as of November 21, 2016.