NOTICE OF PRIVACY PRACTICES

Virtual Physical Therapists INC (VPT) respects the privacy of each and every person and is committed to protecting all of your personal and PHI. This notice describes how personal information and health information (PHI) about you may be used, how it may be disclosed and how you can obtain access to this information. This page will serve as a summary of your privacy rights. The law (45 CFR Part 160 and Part 164, Subparts A and E) requires that your PHI be kept private. We must give you this Notice about our privacy practices and follow the terms of this Notice while it is in effect. Your use of VPT’s Services indicates your acceptance of the terms of this Notice.

1. INTRODUCTION

VPT is engaged in the business of providing internet healthcare resources to connect individuals with licensed physical therapists in real time, via live streaming video, text and/or secure e-mail for the diagnosis and treatment of patients over the Internet, as well as providing other types of administrative services (the “Services”).

2. INFORMATION THAT MAY BE COLLECTED

In order to use the Services, you are asked to enter an e-mail address and password, which we refer to as your VPT ID or credentials. After you create your ID, you can use the same credentials to log in to VPT’s website and utilize the Services. This log in process will allow you to manage your account, it will allow you to search physical therapists, make appointments, attend appointments, etc.

The first time you log in to VPT’s website to utilize the Services, you will be asked to create an account also known as your profile. To create an account, you must provide personal information such as name, address, telephone number, date of birth, e-mail address, gender, and other pertinent data that will be available for you to share with your Provider.  VPT will use the e-mail address you provide when you create your account to send you an e-mail requesting that you validate your account. Your e-mail address may also be used by VPT to provide appointment reminders, changes in appointments, messages from your therapist, or Health Related Programs as described in this Notice and the Terms of Use. VPT will use your e-mail address as the primary means to reset your username and password. Your e-mail address will not be shared with any other third parties and will not be used for advertising or sales purposes.

VPT creates a record of the care and services you receive.  An electronic medical record is created as a result of the assessment and treatment advise you are given.  We will collect credit card or billing/payment account information which we maintain in encrypted form on secure servers.  In order to participate in the Services, you will need to provide Personal Health Information about yourself. Here are examples of the types of Personal Health Information we gather

• Information You Give Us – Examples of the types of information you may provide us include medications, health history and demographic Information, such as age, gender, and Zip Code.

VPT may gather PHI primarily to share with Providers for the purposes of diagnosis, treatment, and health care operations. However, in limited circumstances VPT may use de-identified, non-personal information for statistical analysis, improvement of the Services, and customization of web design and content layout.

Uses and Disclosures of PHI

VPT is permitted to use and disclose your PHI for purposes of (i) Treatment, (ii) Payment, and (iii) Health Care Operations as follows:

For Treatment. VPT may use or disclose your PHI to facilitate treatment or the provision of health care services to a Provider for purposes of a consultation or in connection with the provision of follow-up treatment. VPT may share your PHI with people not at VPT including, but not limited to, referring physicians and home health care nurses who are treating you or providing follow-up care.

For Payment. VPT may use and disclose your PHI with others who help pay for your care such as health insurers or health plans in connection with the processing and payments of claims and other charges.

For Health Care Operations. VPT may use and disclose your PHI for its health care operations. These uses and disclosures help us run our programs and make sure VPT’s patients receive quality care. For example, VPT may use PHI to review the treatment and provision services. VPT may use PHI to measure the performance of its staff and how they care for you. VPT may share PHI with third parties who VPT engages to provide various services for VPT and you such as doctors, therapists, and other health care workers for educational purposes. If any such third party requires access to your PHI in order to perform the agreed upon services, VPT will require that third party be bound to the terms outlined in this Privacy Notice.

Business Associates. VPT may contract with outside businesses to provide some services. For example, VPT may use the services of transcription, IT or collection agencies. Each contracted party must enter into a Business Associate agreement with VPT, which requires said third party businesses to protect PHI that is shared with them in accordance with the restrictions outlined in this Privacy Notice. Furthermore, PHI will only be provided to third party businesses for the limited scope of performing required services to help facilitate treatment, payment, and health care operations to you.

For Appointment Reminders. VPT may contact you to remind you about your appointment for medical care.

Treatment Alternatives. VPT may use and disclose PHI to tell you about different types of treatment available to you. VPT may use and share PHI to tell you about other benefits and services related to your health.

Authorization. VPT is permitted to use and disclose your PHI upon your written authorization, submitted on our form which will be provided to you upon request, to the extent that such use or disclosure is consistent with your authorization. VPT is required to keep records of the care that we provided to you. Be assured that any uses or disclosures not described in this notice will require your written authorization.

People Involved In Your Care. With your permission, VPT may share your PHI with a family member or friend who helps with your medical care.

Research. In support of telemedicine and ehealth initiatives, VPT may use and disclose your PHI for research. VPT will only use and disclose information for research if VPT receives your written consent, or if a review committee that meets Federal standards says VPT does not need your consent.

As Required By Law. VPT may use and disclose your PHI when required to do so by federal, state or local law.

To Prevent A Serious Threat To Health Or Safety. VPT may use and disclose your PHI to prevent a serious threat to your health and safety and that of others. VPT will only disclose your PHI with persons who can help prevent the threat.

Testimonials. We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name.

How VPT May Use and Disclose PHI – Special Situations

Military. If you are in the U.S. or foreign armed services, VPT may share your PHI as required by the proper military authorities.

Workers’ Compensation. VPT may share your PHI for workers’ compensation or programs like it. VPT may do this to the extent required by law.

Public Health Risks. VPT may share your PHI for public health activities, as required by federal, state or local law.

For example, we may share your PHI:

• to prevent or control disease, injury or disability;
• to report child abuse or neglect;
• to tell the proper government department if VPT believes a patient has been the victim of abuse, neglect or domestic violence. VPT will only share this information when ordered or required by law.

De-identified Information. VPT may use, disclose, and request PHI if the Health Information to be used or disclosed is de-identified pursuant to the procedures set forth in 45 CFR 145.514(a)-(c).

Health Oversight Activities and Registries. VPT may share your PHI with government agencies that oversee health care. VPT may do so for activities approved by law. These activities include, but are not limited to, audits, investigations, inspections and licensure surveys.

Lawsuits and Disputes. If you are in a lawsuit or a dispute, VPT may share your PHI in response to a court order, legal demand or other lawful process.

Law Enforcement. VPT may share PHI if asked to do so by a law enforcement official under limited circumstances to respond to a court order, subpoena, warrant, summons or similar process.

3. HOW SECURITY IS HANDLED AT VPT

The importance of security for all personal information including, but not limited to, PHI associated with you is of utmost concern to us. At VPT, we exercise state of the art care in providing secure transmission of your information from your PC or mobile device to our servers. PHI collected by our web site is stored in secure operation environments that are not available or accessible to the public. Only those employees who need access to your information in order to do their jobs are allowed access, each having signed confidentiality agreements. Any employee who violates our privacy or security policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.

VPT is not only HIPPA compliant but additionally utilizes the latest technologies to ensure utmost security. VPT uses several layers of firewall security and different degrees of encryption for each customer’s sensitive PHI to ensure the highest level of security which meets or exceeds the requirements promulgated under HIPAA (defined below)

VPT is the sole owner of the information collected on its site.  VPT will not sell, share or lease this information to others. VPT does not sell any customer lists, e-mail addresses, cookies or other data without your written authorization.

Cookies and Tracking Technologies

Cookies are text information files that your web browser places on your computer when you visit a website. Cookies assist in providing non-personal information from you as an online visitor. It can be used in the customization of your preferences when visiting our website. Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. VPT uses Google Analytics, a third-party tracking service, which uses cookies to track non-personal identifiable information about our visitors to our main site in the aggregate to capture usage and volume statistics. VPT has no access to or control over these cookies. This privacy policy covers the use of cookies by VPT only and does not cover the use of cookies by any third-party.

Security on our Website

Secure interaction. When you interact on our web site, all of your PHI including, but not limited to, your credit card number and delivery address, is transmitted through the Internet using Secure Socket Layers (SSL) technology. SSL technology causes your browser to encrypt your entered information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our web site from capturing and viewing your personal information. VPT also takes the following measures to protect your PHI online:

Passwords. To provide you with an increased level of security, online access to your PHI is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. VPT will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls, or E-mail messages).

Information. Since any entered information you provide to us on our website will be transmitted using a secure connection, if your web browser cannot support this level of security, you will not be able to order products through our website. The most recent versions of Safari, Netscape Navigator, Microsoft Internet Explorer and Firefox can support a secure connection and can be downloaded for free from their respective websites.

No data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your PHI from unauthorized access, use or disclosure, VPT cannot ensure or warrant the security of any information you transmit to us on our web site.

4. Privacy Rights

We are required by law to make sure that PHI that identifies you is kept private, give you this Notice of our legal duties and privacy practices concerning your PHI, and follow the terms of this Notice currently in effect.

Your Rights Regarding Your PHI

You have the following rights regarding PHI VPT maintains about you:

Right to Inspect and To Receive Copies. You have the right to view and receive copies of the PHI and can download your assessment at any time.

Right to Amend. If you think that personal information VPT has about you is wrong or incomplete, you have the right to ask for an amendment to your record. To request deletion of any personal information or ask for a change to your record, you must make your request in writing and submit it to Customer Service. If we are not able to comply with your request, we will respond with an explanation. VPT may, under the following limited circumstances:

VPT may deny your request for an amendment to your record. VPT may Deny your request if it is not submitted in writing or does not include a reason to support the request. VPT may also deny your request if you ask VPT to amend information that:

• VPT did not create, unless the person or entity that created the information is no longer available to make the amendment;
• is not part of the records used to make decisions about you;
• is not part of the information which you are permitted to inspect and to receive a copy; or is accurate and complete.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Right to Request Restrictions. You have the right to ask for a restriction or limitation on the PHI VPT uses or discloses for treatment, payment or health care operations. You also have the right to ask for a limit on the PHI VPT discloses with someone who is involved in your care or in the payment for your care. Such a person may be a family member or friend. VPT is not required to comply with your request. If VPT does agree, we will fulfill your request unless the information is needed to provide you with emergency treatment or if otherwise required by law. To ask for restrictions, you must make your request in writing on a form that we will give you upon request. You must tell us:  what information you want to limit, how you want us to limit the information, and to whom you want the limits to apply.

Right to Request Confidential Communications. You have the right to request confidential communications of your PHI or medical matters. You may request that VPT communicate with you through specific means or at a specific location. You must make your request in writing on a form that will be provided to you upon request. VPT will fulfill all reasonable requests.

Right to a Paper Copy of This Notice. You may ask VPT to give you a written copy of this Notice at any time. Even if you have agreed to get this Notice electronically, you still have a right to a paper copy of this Notice.

If you click on a link to a third party site, you will leave the VPT site you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your PHI by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as VPT. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to our site, you should read that site’s privacy policy before providing any personal information.

5. Revisions to This Notice

VPT is constantly innovating and implementing new features as part of its Services. As a result, our privacy practices may change. We may revise this Notice to reflect any changes in our privacy practices. We reserve the right to make the revised Notice effective for PHI we already have about you. It also will be effective for any information we receive in the future. We will post a current version of the Notice on this Site prior to the change becoming effective, as well as in the places where you receive the Services. The effective date of this Notice is on the first page, in the top, right-hand corner. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective.

VIII. Social Media Widgets

Our Web site includes Social Media Features, such as the Facebook button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

6. Complaints

If you think your privacy rights have been violated, you may file a complaint with legal@vptsapp.com.  You may also file a complaint with the Secretary of the Department of Health and Human Services. You will not be penalized for filing a complaint.

ACCEPTANCE

By using this site and VPT’s Services, you acknowledge your acceptance of VPT’s privacy policy and agree to the terms described herein. If you do not agree with this policy, you should not use VPT’s Services. It is recommended that you read this privacy policy before use of Services to ensure that you have not missed any changes to the privacy policy. Your continued use of the Services following any changes to the privacy policy signifies your acceptance of those changes.