IF YOU ARE EXPERIENCING A LIFE-THREATENING SITUATION

IF YOU ARE EXPERIENCING A LIFE-THREATENING SITUATION SUCH AS CONTEMPLATING SUICIDE, CALL 911 OR THE 988 SUICIDE & CRISIS LIFELINE AT 988.

PURPOSE

The purpose of this consent form ("Consent") is to provide you with information about telehealth and to obtain your informed consent to the use of telehealth in the delivery of healthcare services to you by physicians, physician assistants and/or nurse practitioners ("Providers") using the online platforms owned and operated by Benchline Health, Inc. (the "Service").

Your care is provided by clinicians of Beluga Health, an independent medical practice. Veradene provides the technology and support; your clinician–patient relationship is with Beluga Health, and they are responsible for the medical decisions in your care.

USE OF TELEHEALTH

Telehealth involves the delivery of healthcare services using electronic communications, information technology or other means between a healthcare provider and a patient who are not in the same physical location. Telehealth may be used for diagnosis, treatment, follow-up and/or patient education, and may include, but is not limited to, one or more of the following: electronic transmission of medical records, photo images, personal health information or other data between a patient and a provider; interactions between a patient and provider via audio, video and/or data communications (such as messaging or email communications); use of output data from medical devices, sound and video files. Alternative methods of care may be available to you, such as in-person services, and you may choose an alternative at any time. Always discuss alternative options with your Provider.

ANTICIPATED BENEFITS

The use of telehealth may have the following possible benefits: making it easier and more efficient for you to access medical care or other services and treatment for the conditions treated by your Provider(s); allowing you to obtain medical care or other services and treatment by Provider(s) at times that are convenient for you; and enabling you to interact with Provider(s) without the necessity of an in-office appointment.

POTENTIAL RISKS

While the use of telehealth in the delivery of care can provide potential benefits for you, there are also potential risks associated with the use of telehealth and other technology. These risks include, but may not be limited to the following: the quality, accuracy or effectiveness of the services you receive from your Provider could be limited; technology, including the Service, may contain bugs or other errors, including ones which may limit functionality, produce erroneous results, render part or all of such technology, including the Service, unavailable or inoperable, produce incorrect records, transmissions, data or content, or cause records, transmissions, data or content to be corrupted or lost; failures of technology may also impact your Provider(s) ability to correctly diagnose or treat your condition; the inability of your Provider(s) to conduct certain tests or assess vital signs in-person may in some cases prevent the Provider(s) from providing a diagnosis or treatment or from identifying the need for emergency medical care or treatment for you; your Provider(s) may not be able to provide treatment for your particular condition and you may be required to seek alternative healthcare or emergency care services; delays in medical evaluation/treatment could occur due to unavailability of your Provider(s) or deficiencies or failures of the technology or electronic equipment used; the electronic systems or other security protocols or safeguards used could fail, causing a breach of privacy of your medical or other information; data stored and communicated electronically, for example, through email communications, may be more susceptible to unintended disclosure of protected health information to third parties; given regulatory requirements in certain jurisdictions, your Provider(s) diagnosis and/or treatment options, especially pertaining to certain prescriptions, may be limited; a lack of access to all of your medical records may result in adverse drug interactions or allergic reactions or other judgment errors.

LIFE THREATENING AND OTHER EMERGENCY SITUATIONS; FOLLOW-UP CARE

If you are experiencing a life-threatening situation such as contemplating suicide, call 911 or the 988 Suicide and Crisis Lifeline at 988.

If the situation is an emergency, call 911. In some situations, telehealth is not an appropriate method of care. If you require immediate or urgent care, you must seek care at an emergency room facility or other provider equipped to deliver urgent or emergent care. Providers may not respond promptly to communications you submit through the Service. If you are not experiencing an emergency or do not require immediate or urgent care, you can communicate with Providers through the secure message service in the Service.

DATA PRIVACY AND PROTECTION

The electronic systems used in the Service will incorporate network and software security protocols to protect the privacy and security of your information and will include measures to safeguard data against intentional or unintentional corruption. Personal information that identifies you or contains protected health information will not be disclosed to any third party without your consent, except as authorized by law for the purposes of consultation, treatment, payment/billing, certain administrative purposes, and as required by law, or as otherwise set forth in your Provider's Notice of Privacy Practices. Use of the Service may include email communications to and from you that may include your protected health information. You understand that Benchline does not and cannot guarantee the security or privacy of the services you use to receive communications, including for example your email service provider.

RECORDS AND RESULTS YOU GIVE US

You may give us medical records, laboratory reports, or other health information from outside the Service, including by uploading a document. When you do, you are asking your Provider to read it as part of your care, and this Consent covers that reading — you do not need to sign anything further for us to look at a record you have chosen to give us. You may ask us to stop using a record you provided at any time, though we cannot undo a clinical decision already made.

Records you give us may be reviewed by your Provider, by other licensed clinicians such as nurse practitioners, physician assistants, or registered nurses, and by non-clinical members of our team who support your care, billing, and the operation of the Service. Some members of that team are employees and some are contractors, and some may be located outside the United States. Everyone who handles your information — wherever they are and whatever their role — is bound by written confidentiality and security obligations, may access only the minimum information needed for their task, and may never make a clinical decision about you unless they are a clinician licensed to do so.

We also use automated systems, including artificial intelligence, to help read documents you provide — for example, to transcribe the values on a laboratory report so a clinician does not have to retype them. Those systems only ever produce a draft: a credentialed clinician reviews and confirms every value before it becomes part of your record or informs any decision about your care, and no automated system prescribes for you, diagnoses you, or signs anything.

Some of this technology runs entirely inside Benchline's own protected environment, in which case your information is not sent to another company at all. Where an outside company is involved instead, federal health-privacy law requires that company to be bound by an agreement limiting how it may use your information, and we take reasonable steps to select such companies and to hold them to those obligations, including obligations restricting use of your information for their own purposes. As with any service operated by a third party, Benchline does not and cannot guarantee that an outside company will perform as agreed, and nothing in this section is a warranty of any third party's conduct.

OPEN PAYMENTS NOTICE

For informational purposes only, a link to the federal Centers for Medicare and Medicaid Services Open Payments web page is provided here. The federal Physician Payments Sunshine Act requires that detailed information about payment and other payments of value worth over ten dollars ($10) from manufacturers of drugs, medical device, and biologics to physicians and teaching hospitals be made available to the public. The Open Payments database is a federal tool used to search payments made by drug and device companies to physicians and teaching hospitals. It can be found at https://openpaymentsdata.cms.gov.

YOUR ACKNOWLEDGMENTS

Healthcare services provided to you by Providers via the Service will be provided by telehealth. In some cases, your treating Provider may be a nurse practitioner or physician assistant and not a physician, and you agree to be treated by non-physician providers, if applicable, by using the Service.

No potential benefits from the use of telehealth or other technology or specific results can be guaranteed, including any laboratory testing results or related diagnosis or treatment by your Provider(s). Your condition may not be cured or improved, and in some cases, may get worse. There are limitations in the provision of medical care or other services and treatment via telehealth and technology, including the Service, and you may not be able to receive diagnosis and/or treatment through telehealth for every condition for which you seek diagnosis and/or treatment.

You have the right to withdraw your consent to the use of telehealth in the course of your care, without prejudice to any future care or treatment and without risking the loss or withdrawal of any health benefits to which you are entitled, but you understand that the Providers who utilize the Service do not offer in-person treatment. Any withdrawal of your consent will be effective upon receipt of written notice to your Providers, except that such withdrawal will not have any effect on any action taken by Benchline or your Provider(s) in reliance on this Consent before it received your written notice of withdrawal.

You understand that it is your duty to provide Benchline and your Provider(s) truthful, accurate and complete information, including all relevant information regarding care that you may have received or may be receiving from healthcare providers.

Your prescription is filled by a licensed pharmacy: either one arranged by Beluga Health, P.A., the medical practice your Provider works for, or one of Benchline's licensed partner pharmacies. Your order record shows which pharmacy fills each order. Benchline does not dispense medication. Benchline pays its partner pharmacies for the medication and shipping they provide and receives no payment from any pharmacy. Benchline has a financial relationship with Beluga Health, P.A., which employs or contracts with your Provider. By accepting, you authorize your Provider's practice to send your prescription, and Benchline to send your order and delivery details, to the pharmacy that fills it, unless you choose another pharmacy. You are free to obtain your medical examination from another healthcare provider that is not associated with Benchline, and you are free to have your prescription filled at any pharmacy of your choice — tell us through the secure message service in the Service and we will send it there instead. Unless you ask otherwise, it is shipped to the address you gave us. You must pay the full amount of the costs associated with use of the Service, including any prescription you may receive, and you will not attempt to submit a claim to Medicare, any other federal payor, or any state or private insurer.

Some medications are compounded: prepared for you by a licensed pharmacy when your clinician prescribes them. Compounded medications are not FDA-approved.

IF YOU HAVE A CONCERN ABOUT A MEDICAL PROFESSIONAL

If you have a concern about a medical professional, you may contact the Medical Board in your state regarding your concerns.

Special Notice to California Clients. Physicians and surgeons are licensed and regulated by the Medical Board of California. To confirm a license or file a complaint, go to www.mbc.ca.gov or call (800) 633-2322.

To contact the medical board in another state, search for that state's medical board directly.

Version 3

Last Updated: Nov 11, 2025

INFORMED CONSENT FOR TELEHEALTH SERVICES

DO NOT USE THIS SERVICE IF YOU MAY BE EXPERIENCING A MEDICAL EMERGENCY. In an emergent situation, you can: (i) call 911; (ii) go to the nearest emergency room; (iii) contact your local crisis center; (iv) if applicable, call the National Suicide Prevention Lifeline (1-800-272-8255); or (v) if applicable, contact the Crisis Text Line (text “GO” to 741-741).

We are pleased you have chosen Beluga Health, P.A. for your telehealth needs. This document is intended to inform you of what you can expect of your clinician in terms of his or her credentials and in connection with your treatment via telehealth. After you have carefully read this document and had an opportunity to have your questions answered, certain state laws mandate that you must sign and date it before commencing services.

YOUR TELEHEALTH PROVIDER’S CREDENTIALS. Your provider’s credentials were made available to you before scheduling an appointment. If you have any questions about these credentials, please direct them to your telehealth provider. For those states that require it, you can find an explanation of the levels of regulation applicable to clinicians under the STATE REGULATIONS section of this document.

IMPORTANT INFORMATION REGARDING YOUR TREATMENT BY TELEHEALTH HEALTH PROVIDERS, INCLUDING POTENTIAL RISKS AND BENEFITS. Beluga Health and its affiliated medical practices offer treatment by various types of healthcare providers, including physicians and equivalent licensed professionals, via telecommunications technology (also referred to as “telehealth”). Beluga’s telehealth services include care provided via asynchronous and synchronous telehealth modalities.

Asynchronous telehealth is one way to deliver telehealth. Asynchronous communication is often referred to as “store-and-forward” communication, where participants submit and collect data at different times. An example of asynchronous communication is a telehealth encounter with a healthcare practitioner that involves sending photos, video, or other communications via email or text message. “Asynchronous” means “not occurring at the same time” and is different from “synchronous” telehealth which generally includes visits conducted in real-time between patients and healthcare practitioners through audio or video means (e.g., live phone calls or video-conferencing). Healthcare practitioners may use asynchronous telehealth to aid in diagnoses and medical consultations when live communication or face-to-face contact is not possible or necessary. Beluga’s platform (“Platform”), in particular, allows for the following asynchronous telehealth services: 1) text-based healthcare practitioner-patient interactions through short message service (“SMS”) and multimedia messaging service (“MMS”) communications; and 2) secure information collection through asynchronous store-and-forward patient questionnaires.

The services provided may also include chart review, remote prescribing, appointment scheduling, refill reminders, health information sharing, non-clinical services, such as patient education and other electronic transmission for the purpose of rendering care to you. The electronic communication systems we use will incorporate network and software security protocols to protect the confidentiality of patient identification and imaging data and will include measures to safeguard the data and to ensure its integrity against intentional or unintentional corruption. There are various benefits associated with telehealth services, including improved access to care by enabling you to remain in your home while the provider consults with you, more efficient care evaluation and management, and obtaining expertise of a specialist as appropriate. Possible risks include delays in evaluation and treatment could occur due to deficiencies or failures of the equipment and technologies, and in rare events, our provider may determine that the transmitted information is of inadequate quality, thus necessitating a rescheduled telehealth consult or a meeting with your local primary care doctor.

At times, your clinician may seek supervision or consultation with other Beluga Health or non-Beluga Health clinicians regarding your treatment, to enhance the services being provided to you given the multiple perspectives, experiences, and treatment philosophies. All team members are ethically and legally bound to maintain your privacy and confidentiality in this scenario and none of your personal information will be shared or disclosed with any other individual without your consent. Exceptions to confidentiality do exist in certain situations, such as: threat of serious harm to self or others; reasonable suspicion of abuse or neglect of a child, or abuse, neglect, or exploitation of an incapacitated or dependent adult; court order and/or subpoena; permission from the client or guardian (i.e. voluntary release signed by the client or guardian); during supervisory consultations; diagnosis and dates of service shared with an insurance company to collect payments; information released as outlined in the Beluga Health’s Notice of Privacy Practices and Privacy Policy; and as otherwise required by law.

By consenting to the telehealth services, You confirm that You have read and agreed to the terms outlined in the Notice of Privacy Practices and the Privacy Policy. You understand how your personal and health information will be collected, used, and protected in accordance with applicable laws.

By consenting to this Informed Consent, You acknowledge that You understand and agree with the following:

1. You hereby consent to receiving Beluga Health’s services via telehealth technologies. You understand that the Telehealth Provider and its providers offer telehealth-based medical services, but that these services do not replace the relationship between your and your primary care doctor. Our clinicians are an addition to, and not a replacement for, your local primary care provider. Responsibility for your overall medical care should remain with your local primary care provider, if you have one, and we strongly encourage you to locate one if you do not. You also understand it is up to the Beluga Health provider to determine whether or not your specific clinical needs are appropriate for a telehealth encounter.

2. You understand that if you need to receive non-emergent follow-up care related to your treatment, please contact your clinician by sending a message via the modality in which the conversation was initiated (e.g., in the app chat or via SMS).

3. You understand that federal and state law requires health care providers to protect the privacy and the security of health information. You understand that Beluga Health will take steps to make sure that your health information is not seen by anyone who should not see it. You understand that telehealth may involve electronic communication of your personal medical information to other health practitioners who may be located in other areas, including out of state.

4. You expressly consent to allow Beluga or its healthcare practitioners to call, email, or text you (via SMS and/or MMS) with or regarding Personal Data (as defined in the Beluga Privacy Policy), appointments, or similar matters related to your telehealth encounter using the contact information you have provided. Any calls or texts to you may be placed using an auto-dialer or a pre-recorded or artificial voice, even if your number is on a do-not-call list. Your phone carrier’s normal rates may apply. This is consent, not a condition of purchase. You may revoke this consent at any time by emailing us at admin@belugahealth.com.

5. You understand there is a risk of technical failures during the telehealth encounter beyond the control of Beluga Health. You agree to hold harmless the Beluga Health for delays in evaluation or for information lost due to such technical failures.

6. You understand that you may be asked to provide identification and confirm your physical location prior to or during the telehealth visit.

7. You understand that you have the right to withhold or withdraw your consent to the use of telehealth in the course of your care at any time, without affecting your right to future care or treatment. You understand that you may suspend or terminate use of the telehealth services at any time for any reason or for no reason. You understand that if you are experiencing a medical emergency, that you will be directed to dial 9-1-1 immediately and that the Beluga Health providers are not able to connect you directly to any local emergency services. You may request to delete your patient profile at any time by emailing admin@belugahealth.com.

8. You understand that alternatives to telehealth consultation, such as in-person services are available to you, and in choosing to participate in a telehealth consultation, you understand that some parts of the services involving tests may be conducted by individuals at your location, or at a testing facility, at the direction of the Beluga Health provider (e.g., labs or bloodwork). You understand that Beluga Health does not have any in-person clinic locations.

9. You understand that you may expect the anticipated benefits from the use of telehealth in your care, but that no results can be guaranteed or assured.

10. Because Beluga Health does not have access to your complete medical records, if you do not disclose to your telehealthcare practitioner a full list of your medical history including diagnoses, treatments, medications/supplements, and allergies, adverse treatment, drug interactions or allergic reactions, or other negative outcomes may occur.

11. You understand that your healthcare information may be shared with other individuals for scheduling and billing purposes. Persons may be present during the consultation other than the Beluga Health provider in order to operate the telehealth technologies. You further understand that you will be informed of their presence in the consultation and thus will have the right to request the following: (a) omit specific details of your medical history/examination that are personally sensitive to you; (b) ask non-medical personnel to leave the telehealth examination; and/or (c) terminate the consultation at any time.

12. You understand that you will not be prescribed any narcotics.

13. You understand that there is no guarantee that You will be issued a prescription and that the decision of whether a prescription is appropriate will be made in the professional judgement of the Beluga Health Provider.

14. You understand that there is no guarantee that You will be treated by the Beluga Health Provider. Beluga Health's Provider reserves the right to deny care for potential misuse of the Services or for any other reason if, in the professional judgment of the Provider, the provision of the Services is not medically or ethically appropriate.

15. You understand that if you participate in a consultation, that you have the right to request a copy of your medical records which will be provided to you at reasonable cost of preparation, shipping and delivery.

16. You have read and you understand the disclosures set forth next to the state in which you are located at the time of the telehealth encounter, as set forth below:

STATE REGULATIONS:

Alaska: You understand your primary care provider may obtain a copy of your records of your telehealth encounter. (Alaska Stat. § 08.64.364).

Arizona: You understand that all medical records resulting from a telemedicine consultation are part of your medical record. (A.R.S. § 12-2291.)

Colorado: You are informed that if you want to register a formal complaint about a provider, you should file at https://dpo.colorado.gov/FileComplaint.

Connecticut: You understand that your primary care provider may obtain a copy of your records of your telehealth encounter, and that you can revoke your consent at any time. (Conn. Gen. Stat. Ann. § 19a-906).

D.C.: You have been informed of alternate forms of communication between you and a physician for urgent matters. (D.C. Mun. Regs. tit. 17, § 4618.10).

Georgia: You have been given clear, appropriate, accurate instructions on follow-up in the event of needed emergent care related to the treatment. (Ga. Comp. R. & Regs. 360-3-.07(7)).

Iowa: To file a complaint, fill in the form below or fill out the complaint form and email it to the medical board at ibmcomplaints@iowa.gov.

As appropriate your provider will identify the medical home or treating physician(s) for you, when available, where in-person services can be delivered in coordination with the telemedicine services. Your provider shall provide a copy of the medical record to your medical home or treating physician(s). Iowa Admin. Code 653-13.11(147,148,272C)(13.11(11))

Idaho: You have been informed that if you want to register a formal complaint about a provider, you should visit the medical board’s website, here: File a Complaint | Division of Occupational and Professional Licenses

Illinois: You have been informed that if you want to register a formal complaint about a provider, you should visit the Illinois Division of Professional Regulation at Division of Professional Regulation File a Complaint

Indiana: If a prescription is issued to you, and subject to your consent the prescriber shall notify your primary care provider of any prescriptions the prescriber has issued for you if the primary care provider's contact information is provided by you. This requirement does not apply if: (A) The practitioner is using an electronic health record system that your primary care provider is authorized to access. (B) The practitioner has established an ongoing provider-patient relationship with the patient by providing care to the patient at least 2 consecutive times through the use of telehealth services. If the conditions of this clause are met, the practitioner shall maintain a medical record for you and shall notify your primary care provider of any issued prescriptions. Ind. Code Ann. 25-1-9.5-7.

If you are a Medicaid patient, you have the right to choose between an in-person visit or telehealth visit. Indiana Medicaid Manual: Telehealth and Virtual Services.

Kansas: You understand that if you have a primary care provider or other treating physician, the person providing telemedicine services must send within three business days a report to such primary care or other treating physician of the treatment and services rendered to you during the telemedicine encounter. (Kan. Stat. Ann. § 40-2,212(2)(d)(2)(A).

Kentucky: You have been informed that if you want to register a formal complaint about a provider, you should visit the medical board’s website, here: https://kbml.ky.gov/board/Pages/default.aspx. Information related to filing grievances may be found here https://kbml.ky.gov/grievances/Documents/Consumer%20Guide%20and%20Grievance%20Form.pdf

If requested by you, your physician must share the medical record with your primary care physician and other relevant members of your existing care team. Kentucky Board Opinion on the Use of Telemedicine Technologies (2014), as amended September 15, 2022.

Louisiana: You understand the role of other health care providers that may be present during the consultation other than the telehealth provider. (46 La. Admin. Code Pt XLV, § 7511). Maine: You have been informed that if you want to register a formal complaint about a provider, you should visit the medical board’s website, here: File a Complaint | Maine Board of Licensure in Medicine

Nebraska: If you are a Medicaid recipient, you retain the option to refuse the telehealth consultation at any time without affecting your right to future care or treatment and without risking the loss or withdrawal of any program benefits to which the patient would otherwise be entitled. All existing confidentiality protections shall apply to the telehealth consultation. You shall have access to all medical information resulting from the telehealth consultation as provided by law for access to your medical records. Dissemination of any patient identifiable images or information from the telehealth consultation to researchers or other entities shall not occur without your written consent. You understand that you have the right to request an in-person consult immediately after the telehealth consult and you will be informed if such consult is not available. (Neb. Rev. Stat. Ann. § 71-8505; 471 Neb. Admin. Code § 1-006.05). You have been informed that if you want to register a formal complaint about a provider, you should visit: https://dhhs.ne.gov/Pages/Complaints.aspx

New Hampshire: You understand that the telehealth provider may forward your medical records to your primary care or treating provider. (N.H. Rev. Stat. § 329:1-d).

New Jersey: You understand that you have the right to request a copy of your medical information and you understand your medical information may be forwarded directly to your primary care provider or health care provider of record, or upon your request, to other health care providers. If you do not have a primary care provider or other health care provider of record, the health care provider engaging in telemedicine or telehealth may advise you to contact a primary care provider, and, upon request by you, may assist you with locating a primary care provider or other in-person medical assistance that, to the extent possible, located within reasonable proximity to you. N.J. Rev. Stat. Ann. § 45:1-62. Ohio: You understand that the telehealth provider may forward your medical records to your primary care or treating provider. Ohio Admin. Code 4731-37-01(C)(4).

Oregon: If you have a concern or complaint about the providers providing care to you, you may contact a board agency to assist you. You understand that the provider may ask if you need more detail. ORS 17-52-677.07. See also Or. Medical Board, Statement of Philosophy: Telemedicine (Oct 2, 2020)

Complaints may be filed with:

Oregon Medical Board 1500 SW 1st Ave., Suite 620 Portland, OR 97201-5847 Complaint Resource Staff: 971-673-2702 | complaintresource@omb.oregon.gov

Rhode Island: If you use e-mail or text-based technology to communicate with your provider, then you understand the types of transmissions that will be permitted and the circumstances when alternate forms of communication or office visits should be utilized. You have also discussed security measures, such as encryption of data, password protected screen savers and data files, or utilization of other reliable authentication techniques, as well as potential risks to privacy. You acknowledge that your failure to comply with this agreement may result in the telehealth provider terminating the relationship. (Rhode Island Medical Board Guidelines).

South Carolina: You understand your medical records may be distributed in accordance with applicable law and regulation to other treating health care practitioners. You understand the value of having a primary care medical home and, if requested, we can provide assistance in identifying available options for a primary care medical home. S.C. Code Ann. § 40-47-37.

You also understand that if you are a Medicaid beneficiary, you can withdraw your consent at any time. South Carolina Health and Human Svcs. Dept. Physicians Provider Manual, p. 35 (Feb. 2024).

South Dakota: You have received disclosures regarding the delivery models and treatment methods or limitations. You have discussed with the telehealth provider the diagnosis and its evidentiary basis, and the risks and benefits of various treatment options. (S.D. Codified Laws § 34-52-3).

Tennessee: You understand that you may request an in-person assessment before receiving a telehealth assessment if you are a Medicaid recipient. TN Dept. of Mental Health and Substance Abuse Services. Office of Crisis Services Telecommunications Guidelines, p. 8, (2012) (Accessed Jan. 2024).

Texas: You understand that your medical records may be sent to your primary care physician. (Tex. Occ. Code Ann. § 111.005). You have been informed of the following notice:

NOTICE CONCERNING COMPLAINTS -Complaints about physicians, as well as other licensees and registrants of the Texas Medical Board, including physician assistants, acupuncturists, and surgical assistants may be reported for investigation at the following address: Texas Medical Board, Attention: Investigations, 333 Guadalupe, Tower 3, Suite 610, P.O. Box 2018, MC-263, Austin, Texas 78768-2018, Assistance in filing a complaint is available by calling the following telephone number: 1-800-201-9353, For more information, please visit our website at www.tmb.state.tx.us.

AVISO SOBRE LAS QUEJAS- Las quejas sobre médicos, asi como sobre otros profesionales acreditados e inscritos del Consejo Médico de Tejas, incluyendo asistentes de médicos, practicantes de acupuntura y asistentes de cirugia, se pueden presentar en la siguiente dirección para ser investigadas: Texas Medical Board, Attention: Investigations, 333 Guadalupe, Tower 3, Suite 610, P.O. Box 2018, MC-263, Austin, Texas 78768-2018, Si necesita ayuda para presentar una queja, llame al: 1-800-201-9353, Para obtener más información, visite nuestro sitio web en www.tmb.state.tx.us

Utah: You are able to a (i) access, supplement, and amend your patient-provided personal health information; (ii) contact your provider for subsequent care; (iii) obtain upon request an electronic or hard copy of your medical record documenting the telemedicine services, including the informed consent provided; and (iv) request a transfer to another provider of your medical record documenting the telemedicine services. Utah Admin. Code r. 156-1-602.

Virginia: You acknowledge that you have received details on security measures taken with the use of telemedicine services, such as encrypting date of service, password protected screen savers, encrypting data files, or utilizing other reliable authentication techniques, as well as potential risks to privacy notwithstanding such measures; You agree to hold harmless the Beluga Health for information lost due to technical failures; and you provide your express consent to forward patient-identifiable information to a third party. (Virginia Board of Medicine Guidance Document 85-12).

Vermont: You understand that you have the right to receive a consult with a distant-site provider and will receive one upon request immediately or within a reasonable time after the results of the initial consult.

You have been informed that if you want to register a formal complaint about a provider, you should visit the medical board’s website, here: http://www.healthvermont.gov/health-professionals-systems/board-medical-practice/file-complaint;

IMPORTANT DISCLAIMER - IF YOU ARE ENROLLED IN GOVERNMENT HEALTH PLANS OR PRIVATE INSURANCE

By choosing to receive our Asynchronous telehealth professional medical and related services (our “Services”), you acknowledge and agree to the following:

1. Out-of-Pocket Service. You have selected services for purchase from us on a self-pay basis. In other words, you have directed us to treat your purchase of these services as if you are an uninsured patient and you agree to be 100% responsible for full payment of the listed price of the services. The Services are not covered by, and will not be billed to, any federal or state government health insurance program, including but not limited to Medicare, Medicare Advantage, Medicaid, TRICARE, or any similar plan (collectively referred to as “Government Health Plans”).

2. No Reimbursement. Your insurance policy is a contract between you and your insurance company. It is your responsibility to know your benefits, and how they will apply to your benefit payments, and we take no responsibility to understand or be bound by the terms and conditions of such insurance. You understand and agree that the Services are not covered by Government Health Plans. You further agree that you will not seek reimbursement for the Service from any Government Health Plan, nor will you submit any claim for such reimbursement to any Government Health Plan, directly or indirectly. There is no guarantee your insurance company will make any payment on the cost of the services you have purchased.

3. Voluntary Agreement. You are voluntarily electing to receive and pay for the Services with full knowledge that you will be obligated to pay these charges in full as a self-pay patient, electing not to use an insurance policy benefit are not covered benefits under your Government Health Plan, if applicable. You are not required or obligated to purchase the Services. You understand that your participation in this transaction is not a condition of enrollment in or eligibility for any Government Health Plan. You have been given a choice of different services, along with their costs. You have selected the services and are willing to accept full financial responsibility for payment.

4. Confirmation of Understanding. By proceeding with payment for the Services, you confirm that you understand this disclaimer, and that you knowingly and voluntarily agree to these terms. You further acknowledge that: 1) you do not have any health insurance through a PPO, HMO, Medicaid or Medicare or any other insurance plan; or 2) you have health insurance but you do not want to use any insurance benefit for these services, acknowledging that Beluga Health does not accept any health insurance for these services. You further acknowledge that no representation has been made to you that the Services will be reimbursed by any Government Health Plan.

If you do not agree to these terms, you should not proceed with the Services or purchase.

By choosing to receive our Synchronous telehealth professional medical and related services (our “Services”), you acknowledge and agree to the following:

1. Out-of-Pocket Service. You have selected services for purchase from us on a self-pay basis. We do not bill any federal or state government health insurance program, including but not limited to Medicare, Medicare Advantage, Medicaid, TRICARE, or any similar plan (collectively referred to as “Government Health Plans”).

2. No Reimbursement. Your private insurance policy is a contract between you and your insurance company. It is your responsibility to know your benefits, and how they will apply to your benefit payments, and we take no responsibility to understand or be bound by the terms and conditions of such insurance. There is no guarantee your insurance company will make any payment on the cost of the services you have purchased.

3. Voluntary Agreement. You are voluntarily electing to receive and pay for the Services with full knowledge that you will be obligated to pay these charges in full as a self-pay patient, electing not to use your private insurance policy. You have been given a choice of different services, along with their costs. You have selected the services and are willing to accept full financial responsibility for payment.

4. Confirmation of Understanding. By proceeding with payment for the Services, you confirm that you understand this disclaimer, and that you knowingly and voluntarily agree to these terms. You further acknowledge that: 1) you do not have any health insurance through a PPO, HMO, Medicaid or Medicare or any other insurance plan; or 2) you have private health insurance but you do not want to use any insurance benefit for these services, acknowledging that Beluga Health does not accept any health insurance for these services.

5. If you are a Medicaid Beneficiary - you are not eligible to use our Synchronous visit services. By continuing and receiving this service you are acknowledging that you are NOT a Medicaid beneficiary.

6. If you are a Medicare Beneficiary - you are not eligible to use our Synchronous visit services, unless you sign an ABN and consent that Synchronous telehealth visits are covered by Medicare but are not billed by Beluga Health and you consent to pay for the service out of pocket. For signing an ABN please reach out to our Customer Support at admin@belugahealth.com. By continuing and receiving this service without signing an ABN you are acknowledging that you are NOT a Medicare beneficiary.

If you do not agree to these terms, you should not proceed with the Services or purchase.

You have read this document carefully, and understand the risks and benefits of the telehealth services and have had your questions regarding the services explained and you hereby give your informed consent to participate in a telehealth consultation under the terms described herein.

By using Beluga Health’s Telehealth provider services You hereby state that You have read, understood, and agree to the terms of this Informed Consent

PRIVACY POLICY

FULL PRIVACY POLICY

Version 2

Last Updated: Feb 7, 2025

WE AT BELUGA HEALTH, P.A. (“We”, “Us”, or “Beluga”) VALUE YOUR PRIVACY AND ARE COMMITTED TO KEEPING YOUR (“You/Your”) PERSONAL DATA CONFIDENTIAL. WE USE YOUR DATA SOLELY IN THE CONTEXT OF PROVIDING A WEB PORTAL (“WEB PORTAL”) AND VARIOUS RELATED SERVICES DEFINED BELOW (“SERVICES”) TO SUPPORT THE DELIVERY OF REMOTE CLINICAL CARE AND PRESCRIPTION SERVICES BY QUALIFIED PHYSICIANS (“PROVIDER USERS”) TO PATIENTS OF BELUGA HEALTH (“PATIENT USERS”). YOU ARE EITHER A PATIENT USER OR A PROVIDER USER. THE SERVICES INCLUDE, IN ADDITION TO THE WEB PORTAL, THE FACILITATION OF (1) SECURE INFORMATION COLLECTION, (2) SHORT MESSAGE SERVICE (“SMS”) AND MULTIMEDIA MESSAGING SERVICE (“MMS”) COMMUNICATIONS BETWEEN PATIENTS AND PROVIDERS, AND (3) ELECTRONIC PRESCRIBING OF MEDICATIONS.

THIS PRIVACY POLICY APPLIES TO PERSONAL DATA BELUGA COLLECTS FROM USERS OF THE SERVICES. “PERSONAL DATA” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION IN COMBINATION TO IDENTIFY OR CONTACT ONE OF OUR PATIENT OR PROVIDER USERS. WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL INFORMATION IS OF UTMOST IMPORTANCE. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL DATA. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION.

SOME OF THE PERSONAL DATA WE COLLECT AND TRANSMIT WILL, IN SOME CIRCUMSTANCES, BE CONSIDERED “HEALTH DATA” (data related to a Patient User’s physical or mental health) or “Protected Health Information” (information that relates to the past, present, or future physical or mental health or condition of a Patient User; the provision of health care to a Patient User; or the past, present, or future payment for the provision of health care to a Patient User). THEREFORE, OUR PRIVACY PRACTICES ARE INTENDED TO COMPLY WITH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA“) AND WITH STATE LAW RELATED TO HEALTH DATA, WHERE APPLICABLE. FOR ADDITIONAL INFORMATION RELATED TO YOUR HEALTHCARE INFORMATION, PLEASE CONTACT OUR PRIVACY OFFICER AT security@belugahealth.com. BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS WEB PORTAL OR THROUGH THE SERVICES, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE WEB PORTAL AND DO NOT SUBMIT ANY PERSONAL DATA TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST A LINK TO THE MODIFIED TERMS ON THE WEB PORTAL AND WILL ALSO NOTIFY YOU VIA EMAIL. YOU CAN STORE THIS POLICY AND/OR ANY AMENDED VERSION(S) DIGITALLY, PRINT IT, OR SAVE IT IN ANY OTHER WAY. ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE SERVICES FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case You have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact Us at admin@belugahealth.com. We appreciate Your feedback. If You do not agree or no longer agree to the processing of Personal Data as described in this Privacy Policy, You can delete Your account or request Beluga terminate the processing of your Personal Data by notifying Us by email at admin@belugahealth.com.

Responsible Entity

Beluga is the controller of Your Personal Data and may process Personal Data in accordance with the Privacy Policy. If We are processing Personal Data on behalf of a third party that is not an agent or affiliate of Beluga, the terms of this Privacy Policy do not apply—instead, the terms of that third party’s privacy policy will apply. You can contact Us with any questions about Our Privacy Policy at admin@belugahealth.com.

What Personal Data do We collect?

The types of Personal Data We collect are described below.

Demographic Data

We collect demographic information, such as Your name, birth year, gender, phone number, and email address. Primarily, the collection of Your Personal Data assists us in creating Your account (“User Account”) if You are a Provider User, which You can use to securely receive the Services. If You are a Patient User, the collection of Your Personal Data assists us in securely providing you with the Services.

Payment Data

If you make payments via our Services, We may require that You provide to Us Your financial and billing information, such as billing name and address, credit card number or bank account information.

For Patient Users: Health Data

In addition to demographic information, We will collect information regarding Your health conditions, allergies, medical history, symptoms, and communications between You and the Provider User providing healthcare services to You via the Services. We collect this information to provide You with the Services.

Support Data

If You contact Us for support or to lodge a complaint, We may collect technical or other information from You through log files and other technologies, some of which may qualify as Personal Data. (e.g., Internet Protocol (“IP”) address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Services in accordance with this Privacy Policy. Calls with Beluga may be recorded or monitored for training, quality assurance, customer service, and reference purposes.

For Provider Users: Device, Telephone, and ISP Data

We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data, from Your computer as You navigate Our Services, or interact with emails We have sent You. The information We collect may include Your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files You viewed, Your searches, Your operating system and system configuration information, and date/time stamps associated with Your usage. This information is used to analyze overall trends, to help Us provide and improve Our Services and to guarantee their security and continued proper functioning.

How will We use Your Personal Data?

We process Your Personal Data for purposes based on legitimate business interests, the fulfillment of Our Services to You, compliance with Our legal obligations, and/or Your consent. We only use or disclose Your Personal Data when it is legally mandated or where it is necessary to fulfill the purposes described herein. Where required by law, We will ask for Your prior consent before using or disclosing Personal Data.

Specifically, We process Your Personal Data for the following legitimate business purposes:

● To provide You with Our Services.

● To fulfill Our obligations to You under the Terms of Use (for Provider Users);

● To communicate with You about and manage Your User Account (for Provider Users);

● To properly store and track Your data within Our system;

● To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings or court orders;

● To protect Our rights, privacy, safety, or property, and/or that of You or others by providing proper notices, pursuing available legal remedies, and acting to limit Our damages;

● To handle technical support and other requests from You;

● To enforce and ensure Your compliance with Our Terms of Use or the terms of any other applicable services agreement We have with You;

● To manage and improve Our operations and the Services, including the development of additional functionality;

● To manage payment processing;

● To evaluate the quality of service You receive, identify usage trends, and thereby improve Your user experience;

● To keep Our Services safe and secure for You and for Us;

● To send You information about changes to Our terms, conditions, and policies;

● To allow Us to pursue available remedies or limit the damages that We may sustain; and

● If applicable, to provide access to the authorized Provider User/caregiver (with Your consent), to enable that individual to monitor Your progress and overall condition and to follow up with You, as they deem appropriate.

Where is Your Personal Data processed?

Personal Data Beluga collects through the Services will be stored on secure servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers on Our behalf. These third parties are not permitted to transfer Your Personal Data outside of the United States.

Will We share Your Personal Data with anyone else?

For Patient Users: Yes, with the Provider User with whom You connect via the Services.

We will share information you provide to Us via the Services with the Provider User with whom connect via the Services. If, at any point, you want to deny access to one or more Provider Users, you can do so by emailing admin@belugahealth.com.

Yes, with third parties that help us power Our Services

Beluga has a limited number of service providers and other third parties (“Business Partners”) that help Us run various aspects of Our business. These Business Partners are contractually bound to protect Your Personal Data and to use it only for the limited purpose(s) for which it is shared with Us. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, customer service, and payment processing.

Yes, with third parties and the government when legal or enforcement issues arise

We may share Your Personal Data, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts in violation of this Agreement; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of Beluga or any third party, including other users.

Yes, with third parties that provide advisory services

We may share Your Personal Data with Our lawyers, auditors, accountants, or banks when We have a legitimate business interest in doing so.

Yes, with Payors

We may share Your Personal Data and medical information with payors, including insurance companies and other reimbursement entities, to facilitate billing, claims processing, and payment for the services provided. This sharing is conducted in compliance with applicable laws and regulations, such as the Health Insurance Portability and Accountability Act (HIPAA), to ensure the privacy and security of Your information. Information shared may include, but is not limited to, medical records, treatment details, and other data necessary for reimbursement purposes.

Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Beluga’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings)

If We share Your Personal Data with a third party other than as provided above, You will be notified at the time of data collection or transfer, and You will have the option of not permitting the transfer.

How long do We retain Personal Data?

We will retain Your Personal Data for as long as You maintain a User Account or use Our Services and for the amount of time necessary after the account is closed or Services are terminated, in order to fulfil Our legal obligations. The exact period of retention will depend on the type of Personal Data, Our contractual obligation to You, and applicable law. We keep Your Personal Data for as long as necessary to fulfill the purpose for which it was collected, unless otherwise required or necessary pursuant to a legitimate business purpose outlined herein. At the end of the applicable retention period, We will remove Your Personal Data from Our databases and will request that Our Business Partners remove Your Personal Data from their databases. If there is any data that We are unable, for technical reasons, to delete entirely from Our systems, We will put in place appropriate measures to prevent any further processing of such data. We retain anonymized data indefinitely.

NOTE: Once We disclose Your Personal Data to third parties, We may not be able to access that Personal Data any longer and cannot force the deletion or modification of any such information by the parties to whom We have made those disclosures. Written requests for deletion of Personal Data other than as described should be directed to admin@belugahealth.com.

For Provider Users: What is Our Cookie Policy?

Cookies are small files that a Web server sends to Your computer or device when You visit a web site that uses cookies to keep track of Your activity on that site. Cookies hold a small amount of data specific to that web site, which can later be used to help remember information You enter into the web site (like Your email or other contact info), preferences selected, and movement within the site. If You return to a previously visited web site (and Your browser has cookies enabled), the web site sends the small file to the Web server, which tells it what activity You engaged in the last time You used the web site, and the server can use the cookie to do things like expedite logging in and retrieving user data and keeping Your browser session secure.

We use essential cookies to provide user authentication. and other technologies to, among other things, better serve You with more tailored information, and to facilitate efficient and secure access to the Services. We only use essential cookies. Essential cookies are those necessary for Us to provide Services to You.

We may also collect information using pixel tags, Web beacons, clear GIFs or other similar technologies. These may be used in connection with some Web Portal pages and HTMLformatted email messages to, among other things, track the actions of users and email recipients, and compile statistics about usage and response rates.

For Provider Users: How can You “Opt Out” of Cookies?

If You prefer, You can usually choose to set Your browser to remove cookies and reject cookies. If You enable a do not track (“DNT”) signal or otherwise configure Your browser to prevent Beluga from collecting any cookies, You will no longer be able to access the Web Portal. How can You Manage Your Cookies?

Most web browsers let You choose whether to accept cookies. Most also let You delete cookies already set. The choices available, and the mechanism used, will vary from browser to browser. Such browser settings are typically found in the “options”, “tools” or “preferences” menu. You may also consult the browser’s “help” menu. For example:

Cookie settings in Internet Explorer

Cookie settings in Firefox

Cookie settings in Chrome

Cookie settings in Safari

There are online tools available for clearing all cookies left behind by the websites you have visited, such as www.allaboutcookies.org. Usually, deletion of cookies will anonymize the information associated with the pixel and a website will not receive any further associated information.

How do We protect Your Personal Data?

Beluga is committed to protecting the security and confidentiality of Your Personal Data. We use a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of Your Personal Data, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in Our possession or control that could result in substantial harm or inconvenience to You. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, We cannot ensure the security of information You transmit to Us. By using the Services, You are assuming this risk.

Safeguards

The information collected by Beluga and stored on secure servers, is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, encryption, backups, and access controls. If Beluga learns of a security concern, We may attempt to notify You and provide information on protective steps, if available, through the email address that You have provided to Us or the phone number you have provided Depending on where You live, You may have a legal right to receive such notices in writing.

You are solely responsible for protecting information entered or generated via the Services that is stored on Your device and/or removable device storage. Beluga has no access to or control over Your device’s security settings, and it is up to You to implement any device-level security features and protections You feel are appropriate (e.g., password protection, encryption, remote wipe capability, etc.). We recommend that You take any and all appropriate steps to secure any device that You use to access Our Services.

NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED DESPITE THE IMPLEMENTATION OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US AND YOU TRANSMIT SUCH PERSONAL DATA AT YOUR OWN RISK.

How can You Protect Your Personal Data?

In addition to securing Your device, as discussed above, We will NEVER send You an email requesting confidential information such as account numbers, usernames, passwords, or social security numbers, and You should NEVER respond to any email requesting such information. If You receive such an email purportedly from Beluga, DO NOT RESPOND to the email and DO NOT click on any links and/or open any attachments in the email, and notify Beluga support at admin@belugahealth.com.

For Provider Users: You are responsible for taking reasonable precautions to protect Your user ID, password, and other User Account information from disclosure to third parties, and You are not permitted to circumvent the use of required encryption technologies. You should immediately notify Beluga at admin@belugahealth.com if You know of or suspect any unauthorized use or disclosure of Your user ID, password, and/or other User Account information, or any other security concern.

Your rights

You have certain rights relating to Your Personal Data, subject to local data protection laws. These rights may include:

● to access Your Personal Data held by Us;

● to erase/delete Your Personal Data, to the extent permitted or required by applicable data protection laws;

● to receive communications related to the processing of Your personal data that are concise, transparent, intelligible, and easily accessible;

● to restrict the processing of Your Personal Data to the extent permitted by law (while We verify or investigate Your concerns with this information, for example);

● to object to the further processing of Your Personal Data, including the right to object to marketing;

● to request that Your Personal Data be transferred to a third party, if possible;

● to receive Your Personal Data in a structured, commonly used, and machine-readable format;

● to lodge a complaint with a supervisory authority;

● to rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete; and

● to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making").

Where the processing of Your Personal Data by Beluga is based on consent, You have the right to withdraw that consent without detriment at any time or to exercise any of the rights listed above by emailing Beluga at admin@belugahealth.com.

How can You update, correct, or delete Personal Data?

You can change Your email address and other contact information by contacting admin@belugahealth.com. If You are a Provider User, and You need to make changes or corrections to other information, You may change your password within the account settings on the Web Portal dashboard. Please note that in order to comply with certain requests to limit use of Your Personal Data, We may need to terminate Your account and/or Your ability to access and use the Services, and You agree that We will not be liable to You for such termination or for any refunds of prepaid fees paid by You. You can deactivate Your account or request termination of Services by contacting admin@belugahealth.com.

Although We will use reasonable efforts to do so, You understand that it may not be technologically possible to remove from Our systems every record of Your Personal Data. The need to back up Our systems to protect information from inadvertent loss means a copy of Your Personal Data may exist in a nonerasable form that will be difficult or impossible for Us to locate or remove.

Can You “OPTOUT” of receiving communications from Us?

We pledge not to market third party services to You without Your consent. We may send emails to You regarding Your Beluga account and/or services. You can choose to filter these account and services emails using Your email client settings or, if you are a Patient User, by emailing admin@belugahealth.com, but We do not provide an option for You to opt out of these emails.

Third Party Links

Our Sites may offer links to other websites which may have information policies and practices different from ours. We do not control and are not responsible for the privacy policies, practices, or content of any third-party websites. We encourage you to review the privacy policies of any third-party website prior to providing them with your Personal Information.

Information submission by minors

We do not knowingly collect Personal Data from individuals under the age of 18 and the Services are not directed to individuals under the age of 13. We request that these individuals not provide Personal Data to Us. If We learn that Personal Data from users less than 18 years of age has been collected, We will deactivate the account and take reasonable measures to promptly delete such data from Our records. If You are aware of a user under the age of 13 using the Services, please contact Us at admin@belugahealth.com.

If You are a resident of California, under the age of 18 and have registered for an account with Us, You may ask Us to remove content or information that You have posted to Our Services.

California Residents

California residents may request and obtain from Us, once a year, free of charge, a list of third parties, if any, to which We disclosed their Personal Data for direct marketing purposes during the preceding calendar year and the categories of Personal Data shared with those third parties. If You are a California resident and wish to obtain that information, please submit Your request by sending Us an email at admin@belugahealth.com with “California Privacy Rights” in the subject line. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to admin@belugahealth.com with “California Privacy Rights” in the subject line.

Nevada residents

Nevada residents may contact us to inquire about your right to opt out of the sale of your Personal Information

Contact Us

If You have any questions about this Privacy Policy, please contact Us by email at admin@belugahealth.com or please write to: Beluga Health, P.A., 1321 Upland Dr., Suite 18399, Houston, TX, 77043. Please note that email communications are not always secure; so please do not include sensitive information in Your emails to Us.

Version 1

Last Updated: Feb 7, 2025

NOTICE OF PRIVACY PRACTICES

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.

Effective Date: [2/4/2025]

This Notice of Privacy Practices (the “Notice”) describes how Beluga Health, P.A. (“we” or “our”) including all healthcare professionals allowed to enter or access information in your medical record and all employees with access to your medical or billing records or health information about you, may use and disclose your protected health information to carry out treatment, payment or business operations and for other purposes that are permitted or required by law. We are not a “Covered Entity” as that term is defined in the Health Insurance Portability and Accountability Act (“HIPAA”), but we have elected to voluntarily substantially comply with the standards set forth in HIPAA. “Protected health information” or “PHI” is information about you, including demographic information, that may identify you and that relates to your past, present or future physical health or condition, treatment or payment for health care services. This Notice also describes your rights to access and control your protected health information.

OUR PRIVACY OBLIGATIONS

We understand that your health information is personal and we are committed to protecting your privacy. In addition, we are required by law to maintain the privacy of your Protected Health Information, to provide you with this Notice of our legal duties and privacy practices with respect to your Protected Health Information, and to notify you in the event of a breach of your unsecured Protected Health Information. When we use or disclose your Protected Health Information, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION:

Your protected health information may be used and disclosed by our health care providers, our staff, and others outside of our office that are involved in your care and treatment for the purpose of providing health care services to you, to support our business operations, to obtain payment for your care, and any other use authorized or required by law.

TREATMENT:

We will use and disclose your protected health information to provide, coordinate, or manage your health care and any related services. This includes the coordination or management of your health care with a third party. For example, your protected health information may be provided to a health care provider to whom you have been referred to ensure the necessary information is accessible to diagnose or treat you.

PAYMENT:

Your protected health information may be used to bill or obtain payment for your health care services. This may include certain activities that your health insurance plan may undertake before it approves or pays for your services, such as: making a determination of eligibility or coverage for insurance benefits and reviewing services provided to you for medical necessity.

HEALTH CARE OPERATIONS:

We may use or disclose, as needed, your protected health information in order to support the business activities of this office. These activities include, but are not limited to, improving quality of care, providing information about treatment alternatives or other health-related benefits and services, development or maintaining and supporting computer systems, legal services, and conducting audits and compliance programs, including fraud, waste and abuse investigations.

USES AND DISCLOSURES THAT DO NOT REQUIRE YOUR AUTHORIZATION

We may use or disclose your protected health information in the following situations without your authorization. These situations include the following uses and disclosures:

As Required by Law. We may use and disclose your Protected Health Information when required to do so by any applicable federal, state or local law.

Public Health Activities. We may disclose your Protected Health Information: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse and neglect to a government authority authorized by law to receive such reports; (3) to report information about products under the jurisdiction of the U.S. Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; and (5) to report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance.

Victims of Abuse, Neglect or Domestic Violence. We may disclose your Protected Health Information if we reasonably believe you are a victim of abuse, neglect or domestic violence to a government authority authorized by law to receive reports of such abuse, neglect, or domestic violence.

Health Oversight Activities. We may disclose your Protected Health Information to an agency that oversees the health care system and is charged with responsibility for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.

Judicial and Administrative Proceedings. We may disclose your Protected Health Information in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.

Law Enforcement Officials. We may disclose your Protected Health Information to the police or other law enforcement officials as required by law or in compliance with a court order.

Decedents. We may disclose your Protected Health Information to a coroner or medical examiner as authorized by law.

Health or Safety. We may use or disclose your Protected Health Information to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety.

Specialized Government Functions. We may use and disclose your Protected Health Information to units of the government with special functions, such as the U.S. military or the U.S. Department of State under certain circumstances.

Workers’ Compensation. We may disclose your Protected Health Information as authorized by and to the extent necessary to comply with state law relating to workers’ compensation or other similar programs.

Under the law, we must make certain disclosures to you upon your request, and when required by the Secretary of the Department of Health and Human Services to investigate or determine our compliance with the requirements of the Health Insurance Portability and Accountability Act (HIPAA). State laws may further restrict these disclosures.

USES AND DISCLOSURES THAT REQUIRE YOUR AUTHORIZATION:

For any purpose other than the ones described above, we only use or disclose your Protected Health Information when you give us your written authorization. You may revoke (take back) your authorization, except to the extent that we have taken action in reliance upon it, by submitting a written statement to us using the contact information at the end of this Notice.

Marketing. We must obtain your written authorization prior to using your Protected Health Information for purposes that are marketing under the HIPAA privacy rules. For example, we will not accept any payments from other organizations or individuals in exchange for making communications to you about treatments, therapies, health care providers, settings of care, case management, care coordination, products or services unless you have given us your authorization to do so or the communication is permitted by law.

Sale of Protected Health Information. We will not make any disclosure of Protected Health Information that is a sale of Protected Health Information without your written authorization.

Psychotherapy Notes. We do not create psychotherapy notes about you in connection with our virtual physical therapy services. However, to the extent that we receive any psychotherapy notes about you, we will not use or disclose those psychotherapy notes without your authorization except as permitted by law.

Uses and Disclosures of Your Highly Confidential Information. Federal and state law requires special privacy protections for certain health information about you (“Highly Confidential Information”), including mental health records, substance use disorder treatment records, and other health information that is given special privacy protection under state or federal laws other than HIPAA. However, in order for us to disclose any Highly Confidential Information for a purpose other than those permitted by law, we must obtain your authorization.

YOUR RIGHTS WITH RESPECT TO YOUR PROTECTED HEALTH INFORMATION:

For Further Information; Complaints. If you desire further information about your privacy rights, are concerned that we have violated your privacy rights or disagree with a decision that we made about access to your Protected Health Information, you may contact our us using the contact information at the end of this Notice. You may also file written complaints with the Office for Civil Rights of the U.S. Department of Health and Human Services. Upon request, we will provide you with the correct address for the Director. We will not retaliate against you if you file a complaint with us or the Director.

Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of your Protected Health Information (1) for treatment, payment and health care operations, (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction unless the request is to restrict our disclosure to a health plan for purposes of carrying out payment or health care operations, the disclosure is not required by law and the information pertains solely to a health care item or service for which you (or someone on your behalf other than the health plan) have paid us out of pocket in full. If you wish to request additional restrictions, please contact us using the contact information at the end of this Notice. We will send you a written response.

Right to Receive Communications by Alternative Means or at Alternative Locations. You may request, and we will accommodate, any reasonable written request for you to receive your Protected Health Information by alternative means of communication or at alternative locations.

Right to Inspect and Copy Your Health Information. You may request access to your medical record file and billing records maintained by us in order to inspect and request copies of the records. Under limited circumstances, we may deny you access to a portion of your records. If you desire access to your records, please contact us using the contact information at the end of this Notice. If you request copies, we may charge you a reasonable copy fee.

Right to Amend Your Records. You have the right to request that we amend your Protected Health Information maintained in your medical record file or billing records. If you desire to amend your records, please contact us using the contact information at the end of this Notice. We will comply with your request unless we believe that the information that would be amended is accurate and complete or other special circumstances apply.

Right to Receive an Accounting of Disclosures. Upon request, you may obtain an accounting of certain disclosures of your Protected Health Information made by us during any period of time prior to the date of your request provided such period does not exceed six years. If you request an accounting more than once during a twelve (12) month period, we may charge you a reasonable fee for the accounting statement.

Right to Receive Paper Copy of this Notice. Upon request, you may obtain a paper copy of this Notice, even if you agreed to receive such notice electronically by e-mail.

REVISIONS TO THIS NOTICE: We reserve the right to revise this Notice and to make the revised Notice effective for protected health information we already have about you as well as any information we receive in the future. You are entitled to a copy of the Notice currently in effect. Any significant changes to this Notice will be posted on our web site. You then have the right to object or withdraw as provided in this Notice.

BREACH OF HEALTH INFORMATION:

We will notify you if a reportable breach of your unsecured protected health information is discovered. Notification will be made to you no later than 60 days from the breach discovery and will include a brief description of how the breach occurred, the protected health information involved and contact information for you to ask questions.

COMPLAINTS:

Complaints about this Notice or how we handle your protected health information should be directed to our HIPAA Privacy Officer. If you are not satisfied with the manner in which a complaint is handled you may submit a formal complaint to the 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 www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

We must follow the duties and privacy practices described in this Notice. We will maintain the privacy of your protected health information and to notify affected individuals following a breach of unsecured protected health information. If you have any questions about this Notice, please contact us at [2244840496] and ask to speak with our HIPAA Privacy Officer.