1. Who We Are

CircleLink Health, LLC (“CircleLink Health,” “we,” “us”) provides Chronic Care Management (CCM) and related care coordination services on behalf of your healthcare provider.

CircleLink Health acts as a Business Associate under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and provides services under contract with your physician or healthcare provider.

We receive and use Protected Health Information (“PHI”) to provide care coordination and related services to you.

2. Our Legal Duties

We are required by law to:

• Maintain the privacy and security of your Protected Health Information.
• Provide you with this Notice of our legal duties and privacy practices.
• Follow the terms of this Notice currently in effect.
• Notify you if a breach occurs that may have compromised your unsecured PHI.

3. How We May Use and Disclose Your Health Information

We may use and disclose your PHI for the following purposes:

A. Treatment

We may use and share your information to provide care coordination and communicate with your healthcare provider regarding your treatment.

Example:

• Coordinating follow-up care.
• Documenting chronic care management activities.
• Communicating with your physician about your care plan.

B. Payment

We may use and disclose your PHI so your provider can bill Medicare or other payers for CCM services.

C. Healthcare Operations

We may use PHI to:

• Improve service quality.
• Conduct internal audits.
• Ensure compliance with regulatory requirements.
• Perform care management analytics.

D. As Required by Law

We may disclose PHI when required by federal or state law, including:

• Public health reporting.
• Health oversight activities.
• Law enforcement requests.
• Court orders.

E. Business Associates

We may share PHI with subcontractors who assist us in providing services, provided they agree in writing to safeguard your information in compliance with HIPAA.

4. Uses and Disclosures Requiring Your Authorization

We will not use or disclose your PHI for the following without your written authorization:

• Marketing purposes (outside permitted healthcare communications).
• Sale of PHI.
• Psychotherapy notes (if applicable).

You may revoke authorization at any time in writing.

5. SMS and Electronic Communications

As part of CCM services, we may contact you by:

• Telephone.
• SMS/text message.
• Email (if applicable).

These communications may include limited health-related information necessary to coordinate your care.

Standard message and data rates may apply.

If you wish to stop receiving SMS messages, you may reply STOP at any time. Reply HELP for help.

We take reasonable safeguards to protect electronic communications but note that unencrypted communication may carry inherent privacy risks.

Text Messaging Program

CircleLink Health, LLC provides messaging and care coordination services on behalf of Calvary Medical Clinic. This Privacy Policy applies to the Calvary Medical Clinic text messaging program administered by CircleLink Health on behalf of Calvary Medical Clinic.

As part of patient care and support services, patients may receive text messages related to care coordination, appointment reminders, chronic care management, and related healthcare support services. Message frequency varies. Message and data rates may apply. Reply STOP to opt out and HELP for help.

Consent to receive text messages may be obtained during in-office registration, intake, or other onsite patient communications.

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Text Messaging Privacy

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Text messaging originator opt-in data and consent may be disclosed only to vendors, aggregators, and service providers that support delivery of the text messaging services, and only to the extent necessary to provide those services.

6. Your Rights Regarding Your Health Information

You have the right to:

• A. Access Your Records — Request a copy of your PHI maintained by your healthcare provider.
• B. Request an Amendment — Request correction of inaccurate or incomplete information.
• C. Request Restrictions — Ask us to limit certain uses or disclosures. We are not required to agree but will consider your request.
• D. Request Confidential Communications — Ask us to contact you in a specific way (e.g., different phone number).
• E. Receive an Accounting of Disclosures — Request a list of certain disclosures made outside treatment, payment, and healthcare operations.
• F. Obtain a Paper Copy of This Notice — Even if you agreed to receive it electronically.

To exercise any of these rights, contact your healthcare provider or the Privacy Contact listed below.

7. Complaints

If you believe your privacy rights have been violated, you may file a complaint with:

CircleLink Health Privacy Officer
Email: support@circlelinkhealth.com

You may also file a complaint with:

U.S. Department of Health and Human Services
Office for Civil Rights
200 Independence Avenue, S.W.
Washington, D.C. 20201
1-877-696-6775
https://www.hhs.gov/ocr/privacy/hipaa/complaints/

You will not be penalized for filing a complaint.

8. Changes to This Notice

We reserve the right to change this Notice at any time. Any updated Notice will apply to all PHI we maintain and will be posted on our website.

9. Contact Information

If you have questions about this Notice, contact:

CircleLink Health Privacy Officer
Email: support@circlelinkhealth.com