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NOTICE OF PRIVACY PRACTICES


WHAT IS THIS NOTICE?

This notice describes how medical information about you may be used and
disclosed and how you can get access to this information. Please review it
carefully. We also describe your rights and certain obligations we have
regarding the use and disclosure of medical information.

This notice applies to all of the records received, used, or disclosed by Solera
Health. Non-Solera health providers may have different policies or notices
regarding their uses and disclosures of your medical information.

We reserve the right to change this notice. We reserve the right to make the
revised or changed notice effective for medical information we already have
about you as well as any information we receive in the future. The notice will
contain the effective date on the first page, in the top right-hand corner. In
addition, each time you use our services, we will offer you a copy of the
current notice in effect.


SOLERA’S PLEDGE REGARDING MEDICAL INFORMATION

We understand that confidential medical information about you (“you” or “your”
used throughout refers to the patient) and your health is personal. We are
committed to protecting medical information about you.

We are required by law to:

 * Make sure that medical information that identifies you is kept private (with
   certain exceptions)
 * Give you this notice of our legal duties and privacy practices with respect
   to medical information about you’ and
 * Follow the terms of the notice that is currently in effect


WHY DOES SOLERA COLLECT YOUR MEDICAL INFORMATION?

We create a record of the care and services you receive. We need this record to
provide you with quality care and to comply with certain legal requirements.


HOW DOES SOLERA USE AND DISCLOSE YOUR MEDICAL INFORMATION?

The following categories describe different ways that we use and disclose
medical information. For each category of uses or disclosures we will explain
what we mean and try to give some examples. Not every use or disclosure in a
category will be listed. However, all of the ways we are permitted to use and
disclose information will fall within one of the categories.


FOR TREATMENT

We may use medical information about you to provide you with health care
coordination and health management services. Our communications to you may be by
telephone, cell phone, email, or mail. For example, we may use your information
to facilitate appointment scheduling with your provider. We may disclose medical
information about you to healthcare providers who are involved in taking care of
you. We may also disclose medical information about you to people outside Solera
Health who may be involved in your continued care, such as a disease management
or prevention program.


FOR PAYMENT

We may use and disclose medical information about you so that the services you
receive may be billed and payment collected from you, an insurance company or a
third party, if applicable. For example, we may need information about your
treatment history to facilitate benefits claims.


FOR HEALTH CARE OPERATIONS

We may use or disclose your health care information for health care operations.
For example, we may use your information to determine the quality of care you
received from one of our partners. If the activities require disclosure outside
of our organization we will request your authorization before disclosing that
information.


AS REQUIRED BY LAW

We will disclose medical information about you when required to do so by
federal, state or local law.


TO AVERT A SERIOUS THREAT TO HEALTH OR SAFETY

We may use and disclose medical information about you when necessary to prevent
a serious threat to your health and safety or the health and safety of the
public or another person. Any disclosure, however, would only be to someone able
to help prevent the threat.


APPOINTMENT REMINDERS

We may use and disclose medical information to contact you as a reminder that
you have an appointment for care.


ATTENDANCE REMINDERS

We may use and disclose medical information to contact you to remind you about
your attendance obligations.


PREVENTIVE HEALTH AND HEALTH-RELATED BENEFITS AND SERVICES

We may use and disclose medical information to tell you about changes or
lifestyle options or alternatives that may be of interest to you. We may also
use and disclose medical information to tell you about health-related benefits
or services that may be of interest to you.


PUBLIC HEALTH ACTIVITIES

We may disclose medical information about you for public health activities.
These activities generally include:

 * To prevent or control disease, injury or disability
 * To report births and deaths
 * To report regarding the abuse or neglect of children, elders and dependent
   adults
 * To report reactions to medications or problems with products
 * To notify people of recalls of products they may be using
 * To notify a person who may have been exposed to a disease or may be at risk
   for contracting or spreading a disease or condition
 * To notify the appropriate government authority if we believe a patient has
   been the victim of abuse, neglect, or domestic violence. We will only make
   this disclosure if you agree or when required or authorized by law.
 * To notify emergency response employees regarding possible exposure to
   HIV/AIDS, to the extent necessary to comply with state and federal laws


WORKERS’ COMPENSATION

We may release medical information about you for workers’ compensation or
similar programs. These programs provide benefits for work-related injuries or
illness.


LAWSUITS AND DISPUTES

If you are involved in a lawsuit or a dispute, we may share medical information
about you in response to a court or administrative order. We may also share
medical information about you in response to a subpoena, discovery request, or
other lawful process by someone else involved in the dispute, but only if
efforts have been made to tell you about the request (which may include written
notice to you) or to obtain an order protecting the information requested.


FUNDRAISING ACTIVITIES

You may want to make contributions to support the services we provide. You have
the right to opt out of (stop) receiving fundraising messages. If you receive a
fundraising message, it will tell you how to opt out.


MARKETING AND SALES

Most uses and sharing of medical information for marketing purposes, and sharing
that constitute a sale of medical information, require your authorization.
Solera health will not share your health information for marketing or sales
purposes without getting your authorization.


WHO ELSE CAN SOLERA GIVE MY MEDICAL INFORMATION TO?

We may share your medical information with the following people or
organizations, for reasons other than those described in the section above.


PEOPLE INVOLVED IN YOUR CARE OR PAYMENT FOR YOUR CARE

We may release medical information about you to a friend or family member who is
involved in your medical care. We may also give information to someone who helps
pay for your care.

If you’re caught in a disaster such as a hurricane, we may also share medical
information about you to an organization assisting in a disaster relief effort
so that your family can be notified about your condition, status, and location.


GOVERNMENT AUTHORITIES WHO RECEIVE REPORTS OF ABUSE, NEGLECT, OR VIOLENCE

We may disclose your information to a government authority authorized by law to
receive reports of abuse, neglect, or violence relating to children or the
elderly.


MILITARY COMMAND AUTHORITIES

If you are a member of the armed forces, we may release medical information
about you as required by military command authorities. We may also release
medical information about foreign military personnel to the appropriate foreign
military authority.


HEALTH OVERSIGHT AGENCIES

We may disclose medical information to a health oversight agency for activities
authorized by law. These oversight activities include, for example, audits,
investigations, inspections, and licensure. These activities are necessary for
the government to monitor the health care system, government programs and
compliance with civil rights laws. We will only make this disclosure if you
agree or when required or authorized by law.


LAW ENFORCEMENT

We may release medical information if asked to do so by a law enforcement
official:

 * In response to a court order, subpoena, warrant, summons or similar process
 * To identify or locate a suspect, fugitive, material witness, or missing
   person
 * About the victim of a crime if, under certain limited circumstances, we are
   unable to get the person’s agreement
 * About a death we believe may be the result of criminal conduct
 * About criminal conduct at the hospital, and
 * In emergency circumstances to report a crime, the location of the crime or
   victims, or the identity, description, or location of the person who
   committed the crime


CORONERS, MEDICAL EXAMINERS AND FUNERAL DIRECTORS

We may release medical information to a coroner or medical examiner. This may be
necessary, for example, to identify a deceased person or determine the cause of
death.


AUTHORIZED FEDERAL OFFICIALS

We may release medical information about you to authorized federal officials for
intelligence, counterintelligence, and other national security activities
authorized by law. We may disclose medical information about you to authorized
federal officials so they may provide protection to the president, other
authorized persons, or foreign heads of state, or may conduct special
investigations.


CORRECTIONAL INSTITUTIONS OR LAW ENFORCEMENT OFFICIALS

If you are an inmate of a correctional institution or under the custody of a law
enforcement official, we may disclose medical information about you to the
correctional institution or law enforcement official.

This disclosure would be necessary:

 * For the institution to provide you with health care
 * To protect your health and safety or the health and safety of others
 * For the safety and security of the correctional institution


MULTIDISCIPLINARY PERSONNEL TEAMS

We may disclose health information about a child or elderly person and their
caregivers (such as a child’s parents) to a multidisciplinary personnel team
relevant to preventing, identifying, managing, or treating abuse or neglect.


SPECIAL CATEGORIES OF INFORMATION

In some circumstances, your health information may be subject to restrictions
that may limit or preclude some uses or disclosures described in this notice.
For example, there are special restrictions on the use or disclosure of certain
categories of information — such as tests for HIV or treatment for mental health
conditions or alcohol and drug abuse. Government health benefit programs, such
as Medi-Cal, may also limit the disclosure of beneficiary information for
purposes unrelated to the program.


WHAT CONTROL DO I HAVE ABOUT SHARING OF MY MEDICAL INFORMATION?


YOU CAN ASK FOR RESTRICTIONS ON THE USE AND SHARING OF YOUR MEDICAL INFORMATION

You have the right to request a restriction or limitation on:

 * The medical information we use or share about you for services, payments, or
   health care operations
 * The medical information we share about you to someone who is involved in your
   care or the payment for your care, like a family member or friend. For
   example, you could ask that we not use or disclose information about an
   evaluation you had.

We are not required to agree to your request, except if you ask us not to share
information with a health plan or insurer for payment or health care operations
purposes, when you (or someone else on your behalf other than the health plan or
insurer) has paid for the item or service out of pocket in full. Even if you
request this special restriction, we can disclose the information to a health
plan or insurer for purposes of treating you.

If we agree to another special restriction, we will comply with your request
unless the information is needed to provide you emergency treatment.


TO REQUEST RESTRICTIONS:

 1. You must make your request in writing to myprivacy@soleranetwork.com
 2. In your request, you must tell us:
     * What information you want to limit
     * If you want to limit our use, disclosure or both, and
     * To whom you want the limits to apply, for example, disclosures to your
       spouse


REQUESTING CONFIDENTIAL COMMUNICATIONS

You have the right to request that we communicate with you about medical matters
in a certain way or at a certain location. For example, you can ask that we only
contact you at home or by telephone.


TO REQUEST CONFIDENTIAL COMMUNICATIONS:

 1. You must make your request in writing to myprivacy@soleranetwork.com
 2. Your request must specify how or where you wish to be contacted

We will not ask you the reason for your request. We will accommodate all
reasonable requests.


DISCLOSURE AT YOUR REQUEST

We may disclose information when requested by you. This disclosure at your
request may require a written authorization from you.


TO REQUEST INFORMATION DISCLOSURE:

 3. You must make your request in writing to myprivacy@soleranetwork.com
 4. In your request, you must tell us:
     * What information you want to disclose
     * If you want to limit our use, disclosure or both, and
     * To whom you want the disclosure(s) to apply, for example, disclosures to
       your spouse


CAN I SEE THE MEDICAL INFORMATION SOLERA HAS COLLECTED?

Yes, you have the right to inspect and obtain a copy of medical information that
may be used to make decisions about your care. Usually, this includes medical
and billing records, but may not include some mental health information.

To inspect and obtain a copy of medical information that may be used to make
decisions about you:

 1. You must submit your request in writing to myprivacy@soleranetwork.com
 2. You have the right to request that the copy be provided in an electronic
    form or format (such as a PDF saved on a compact disk) if the information is
    readily producible in an electronic form or format

We may charge a fee for the costs of copying, mailing, or other supplies
associated with your request.

We may deny your request to inspect and obtain a copy in certain very limited
circumstances. If you are denied access to medical information, you may request
that the denial be reviewed. A licensed health care professional chosen by us
will review your request and the denial. The person conducting the review will
not be the person who denied your request. We will comply with the outcome of
the review.


CAN I SEE WHOM SOLERA HAS SHARED MY MEDICAL INFORMATION WITH?

You have the right to request an “accounting of disclosures.” This is a list of
the disclosures we made of medical information about you other than our own uses
for treatment, payment, health care operations (as those functions are described
above), and with other exceptions pursuant to the law.

To request an accounting (list) of disclosures:

 1. You must submit your request in writing to myprivacy@soleranetwork.com
 2. In your request, you must tell us:
     * A time period which may not be longer than 6 years and may not include
       dates before April 14, 2003.
     * What format you want the list in (for example, on paper or
       electronically).

The first list you request within a 12-month period will be free. For additional
lists, we may charge you for the costs of providing the list. We will notify you
of the cost involved and you may choose to withdraw or change your request at
that time before we create any costs.


CAN I CHANGE MY MEDICAL INFORMATION?

If you feel that medical information we have about you is incorrect or
incomplete, you may ask us to amend the information. You have the right to
request an amendment for as long as the information is kept by or for Solera
Health.


TO REQUEST AN AMENDMENT TO YOUR MEDICAL INFORMATION:

 1. You must make a written request to myprivacy@soleranetwork.com
 2. You must provide a reason that supports your request

We may deny your request for an amendment if it is not in writing or does not
include a reason to support the request. In addition, we may deny your request
if you ask us to amend information that:

 * Was not created by us, unless the person or entity that created the
   information is no longer available to make the amendment
 * Is not part of the medical information kept by or for Solera Health
 * Is not part of the information which you would be allowed to inspect and
   copy, or
 * Is accurate and complete


WHAT IF I THINK MY PRIVACY HAS BEEN VIOLATED?

If you believe your privacy rights have been violated, you may file a complaint
with Solera Health or the Secretary of the Federal Department of Health and
Human Services. All complaints must be submitted in writing. You will not be
punished for filing a complaint.

To file a complaint with Solera Health, contact: Privacy Officer at Privacy
Officer, Solera Health, 111 West Monroe Street, Suite 300; Phoenix, AZ 85003,
(602) 904-6108; myprivacy@soleranetwork.com.

To file a complaint with the Department of Health and Human Services, contact:
Office for Civil Rights, U.S. Department of Health and Human Services, 200
Independence Ave., S.W., Washington, D.C. 20201, or visit the Office for Civil
Rights website to file a complaint electronically:
http://www.hhs.gov/ocr/filing-with-ocr/index.html.


NOTIFICATION OF A BREACH

Solera Health will notify you as required by law following a breach of your
unsecured protected health information.


YOU HAVE A RIGHT TO A PAPER COPY OF THIS NOTICE

You have the right to a paper copy of this notice. You may ask us to give you a
copy of this notice at any time. Even if you have agreed to receive this notice
electronically, you are still entitled to a paper copy of this notice.

To obtain a paper copy of this notice, please contact: Solera Privacy Officer at
Privacy Officer, Solera Health, 111 West Monroe Street, Suite 300; Phoenix, AZ
85003, (602) 904-6108; myprivacy@soleranetwork.com.

You may obtain an electronic copy of this notice at our website:
www.soleranetwork.com
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Solera Health, Inc. is committed to changing lives by guiding people to better
health in their communities. The company has built a dynamic platform that
provides intensive, evidence-based, lifestyle and behavioral social
interventions to impact the costliest chronic conditions in the country.
Solera’s marketplace strategically matches consumers to curated disease
prevention with a network of community organizations and digital therapeutics
providers delivering the most meaningful health outcomes. Solera is HITRUST
certified, the most prestigious certification for meeting healthcare regulations
and requirements for protecting and securing sensitive private healthcare
information.

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