YOUR RIGHTS AND OUR RESPONSIBILITIES This Notice of Privacy Practices describes how we may use and disclose your Protected Health Information (PHI) to carry out treatment, payment, or healthcare operations, and for other purposes that are permitted or required by law. It also describes your rights to access and control your Protected Health Information. We are required by law to: Maintain the privacy and security of your Protected Health Information Notify you following a breach of unsecured Protected Health Information Follow the duties and privacy practices described in this Notice
OUR ROLE AS A TECHNOLOGY PLATFORM RA Asset Solutions LLC is a technology platform provider, not a healthcare provider. We provide software that enables you to transmit your health data (vitals, meals, and other health information) to your healthcare providers at participating clinics and physician offices. Your healthcare providers use our secure dashboard to view your data and provide medical advice, diagnosis, and treatment. We act as an intermediary to facilitate secure data transmission between you and your healthcare providers. All medical feedback, treatment recommendations, and clinical decisions come from your physician office, not from us. We do NOT provide medical advice, diagnosis, or treatment. Under the Health Insurance Portability and Accountability Act (HIPAA), we are a "Business Associate" to the covered entities (clinics and physician offices) that provide your healthcare services.
HOW WE USE AND DISCLOSE YOUR HEALTH INFORMATION Information We Collect Through the App When you use our Remote Patient Monitoring (RPM) app, we collect and process the following types of health information: Health Data: Vital signs (blood pressure, heart rate, oxygen levels, weight, glucose readings, etc.) Symptoms and health assessments you report Medication adherence information Activity and exercise data Sleep patterns and quality Device readings from connected medical devices Personal Information: Name, date of birth, contact information Insurance and billing information Healthcare provider information Account credentials and authentication data Technical Data: Device information (type, operating system, unique device identifiers) App usage data and analytics IP address and general location (not precise geolocation) Log files and error reports AI-Powered Features: Our app uses artificial intelligence (AI) only for meal tracking and nutritional analysis AI analyzes meal information you provide to generate basic nutritional metrics and insights AI is NOT used for medical decision-making, diagnosis, or providing medical advice All medical advice, treatment decisions, and clinical recommendations are made by your healthcare providers at your clinic or physician office, not by our AI system How We Use Your Information For Treatment: We use your health information to transmit data to your healthcare providers and facilitate remote monitoring: Enable your clinic to monitor your health status remotely through our platform Transmit data to your healthcare providers to inform your care Facilitate communication between you and your care team via our secure platform Alert your healthcare providers to concerning health trends detected in your transmitted data Coordinate your care across different providers For Payment: We may use and disclose your health information: To bill and collect payment from you, your insurance, or third parties To determine insurance coverage and benefits To process claims and reimbursement For Healthcare Operations: We may use your health information to: Improve the quality and effectiveness of our services Evaluate the performance of our staff and services Conduct training and quality improvement activities Perform business planning and development Ensure HIPAA compliance and conduct audits Disclosures We May Make With Your Authorization: We will obtain your written authorization before using or disclosing your PHI for purposes other than treatment, payment, and healthcare operations, except where permitted or required by law. You may revoke any authorization at any time by submitting a written request. Without Your Authorization (As Permitted by Law): To Your Healthcare Providers: We transmit your RPM data to the physicians, nurses, and other healthcare professionals at your clinic who are involved in your care. Your healthcare providers use our dashboard to access this data and provide medical advice and treatment To Business Associates: We share information with vendors who help us operate the app (cloud hosting, analytics, customer support), all of whom sign HIPAA Business Associate Agreements As Required by Law: When required by federal, state, or local law For Public Health Activities: To prevent or control disease, injury, or disability; to report adverse events with medical devices To Avert Serious Threat: When necessary to prevent a serious threat to health or safety For Law Enforcement: In response to a court order, subpoena, warrant, or other legal process For Workers' Compensation: As authorized by workers' compensation laws To Coroners and Funeral Directors: For identification purposes or to determine cause of death
YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION You have the following rights with respect to your Protected Health Information: Right to Access You have the right to inspect and obtain a copy of your health information maintained in the app. To request access, contact us at JeremyAllison@raassetsolutions.com. We will respond within 30 days. Right to Amend If you believe your health information is incorrect or incomplete, you may request that we amend it. We may deny your request under certain circumstances, but we will provide you with a written explanation. Right to an Accounting of Disclosures You have the right to receive a list of certain disclosures we have made of your health information. This does not include disclosures for treatment, payment, healthcare operations, or disclosures you authorized. Right to Request Restrictions You have the right to request that we restrict how we use or disclose your health information for treatment, payment, or healthcare operations. We are not required to agree to your request except in limited circumstances, such as when you have paid out-of-pocket in full for services. Right to Request Confidential Communications You have the right to request that we communicate with you about your health information in a specific way or at a specific location (e.g., by mail instead of email). Right to a Paper Copy of This Notice You have the right to receive a paper copy of this Notice at any time, even if you have agreed to receive it electronically. Right to Opt Out of Mobile App Disclosures You have the right to opt out of having your health information shared through the mobile app. If you choose to opt out, certain features of the app may not function properly, and your healthcare providers may not receive real-time monitoring data. To opt out, contact us at JeremyAllison@raassetsolutions.com or adjust your sharing preferences in the app settings. Note: Some disclosures are mandated by state or federal law and cannot be opted out of, such as disclosures required for public health reporting or court orders. Right to Be Notified of a Breach You have the right to be notified in the event of a breach of your unsecured Protected Health Information.
DATA SECURITY AND PROTECTION We implement administrative, physical, and technical safeguards to protect your PHI: Technical Safeguards: End-to-end encryption for data in transit (TLS 1.2 or higher) Encryption of data at rest using AES-256 encryption Multi-factor authentication options Automatic session timeouts Regular security audits and penetration testing Administrative Safeguards: HIPAA compliance training for all workforce members Business Associate Agreements with all third-party vendors Documented risk assessments and security policies Incident response and breach notification procedures Physical Safeguards: Secure, HIPAA-compliant cloud hosting infrastructure Access controls and audit logs Regular backups and disaster recovery procedures
MOBILE APP-SPECIFIC INFORMATION Platform Permissions The app may request the following permissions on your device: Camera/Photos: To upload images for documentation or identification (optional) Notifications: To send health reminders and alerts Bluetooth: To connect with medical monitoring devices Health App Integration: To sync data with Apple Health or Google Fit (optional) You can manage these permissions in your device settings at any time. Third-Party Services Our app uses the following types of third-party services: Cloud Hosting Providers: For secure data storage (HIPAA-compliant) Analytics Services: To improve app performance (de-identified data only) Communication Services: For secure messaging with your care team All third-party vendors that handle PHI sign Business Associate Agreements and comply with HIPAA requirements. Data Retention We retain your health information for as long as necessary to provide services and as required by law. Typically, health records are retained for 7 years from the date of last service or as required by applicable North Carolina law. You may request deletion of your account and data by contacting us at JeremyAllison@raassetsolutions.com. Some information may be retained as required by law or for legal, regulatory, or operational purposes. Children's Privacy Our app is not intended for individuals under the age of 18. We do not knowingly collect PHI from minors without parental consent. If you believe we have collected information from a minor, please contact us immediately. Advertising and Marketing We do not use your Protected Health Information for advertising or marketing purposes. We will not sell your health data to third parties. Any marketing communications will only be sent with your explicit consent and will not contain PHI.
CHANGES TO THIS NOTICE We reserve the right to change this Notice at any time. Any changes will apply to all PHI we maintain. When we make a material change to this Notice: We will post the updated Notice in the app and on our website at www.raassetsolutions.com We will update the "Effective Date" at the top of the Notice You will be notified through the app and/or by email
COMPLAINTS AND CONTACT INFORMATION If you believe your privacy rights have been violated, you may file a complaint with us or with the U.S. Department of Health and Human Services (HHS). To file a complaint with us: Privacy Officer RA Asset Solutions LLC 4030 WakeForest RD, Raleigh, NC 27609 JeremyAllison@raassetsolutions.com (850) 760-6609 To file a complaint with HHS: Office for Civil Rights U.S. Department of Health and Human Services 200 Independence Avenue, S.W. Washington, D.C. 20201 1-877-696-6775 www.hhs.gov/ocr/privacy/hipaa/complaints/ You will not be retaliated against for filing a complaint.
QUESTIONS OR CONCERNS If you have questions about this Notice or need assistance exercising your privacy rights, please contact: Privacy Officer: Jeremy Allison Email: JeremyAllison@raassetsolutions.com Phone: (850) 760-6609 Mailing Address: 4030 WakeForest RD, Raleigh, NC 27609 You have the right to discuss this Notice with our designated Privacy Officer. To request a meeting, please contact us using the information above.
ACKNOWLEDGMENT By downloading and using this app, you acknowledge that you have received, read, and understand this Notice of Privacy Practices and Privacy Policy. For questions about your care or to access your health information, please contact your healthcare provider directly.
This Notice complies with the Health Insurance Portability and Accountability Act (HIPAA), 45 CFR Parts 160 and 164, and applicable state privacy laws.