Notice of Privacy Practices

Who we are

This Notice of Privacy Practices is provided by Halo Wellness, LLC(“Halo,” “we,” “us,” or “our”) and the affiliated covered entities (“ACE”) that provide clinical care through the Halo platform. The clinical practice is delivered by OpenLoop Healthcare Partners PC, its state-specific professional corporations, and other independent licensed providers (collectively, the “Halo Provider Network”).

Halo and the Halo Provider Network are designated as a single affiliated covered entityfor purposes of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). That means we share Protected Health Information (PHI) among ourselves as needed to deliver and coordinate your care.

Your rights

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

Get a 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 maintain about you. We will provide a copy or a summary of your 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. We may say no to your request, but we will tell you why in writing within 60 days.

Request confidential communications

You can ask us to contact you in a specific way (for example, by home or office phone) or to send mail to a different address. We will say yes to 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 say no 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 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 (an “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 the disclosures except for those about treatment, payment, and healthcare operations, and certain other disclosures (such as any you asked us to make). We will provide one accounting per year for free but will charge a reasonable, cost-based fee if you ask for another 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 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 using the information at the end of this notice. You can also 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 hhs.gov/hipaa/filing-a-complaint. 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.

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 hospital or facility directory (not applicable to most Halo care, which is delivered remotely)

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

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. For example, your Halo physician may share your medical history with the compounding pharmacy that prepares your prescription, or with a specialist consultant if your protocol benefits from coordinated care.

Run our organization

We can use and share your health information to run our practice, improve your care, and contact you when necessary. For example, we use your health information to manage your treatment and services, to evaluate the quality of care you receive, and to perform care coordination across the Halo Provider Network.

Bill for your services

We can use and share your health information to bill and get payment from you, your health plan, or any third-party payer authorized to receive payment on your behalf. For example, we give information about you to your health plan so it will pay for your services.

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 or neglect, or preventing or reducing a serious threat to anyone’s health or safety.

Do research

We can use or share your information for de-identified health research. Identifiable research uses require your written authorization unless permitted by law.

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

• 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: hhs.gov/hipaa/for-individuals/notice-privacy-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 at tryhalo.co, and we will mail or email a copy to you on request.

Contact us

To exercise any of the rights described in this notice, to ask questions, or to file a complaint, contact our Privacy Officer:

A paper copy of this notice is available on request. This notice applies to the privacy practices of Halo Wellness, LLC and the Halo Provider Network ACE designated above.