Notice of Privacy Practices

This Notice of Privacy Practices ("Notice") took effect on December 02, 2023. It will remain in effect until Juno Health replaces it. Juno Health must abide by the terms of this Notice while it is in effect.

Juno Health make up an organized health care arrangement. Juno Health is a clinically integrated care setting in which our members receive health care ("Services") from more than one health care provider. In addition, we are an organized health care system that jointly participates in numerous activities including quality assessment and improvement activities.

Juno Health respects and is committed to protecting the privacy of your medical information. In performing its services, Juno Health will receive, create, and disclose your protected health information ("PHI"). Juno Health is required by law to maintain the privacy and security of your PHI and to provide you with notice of our legal duties and privacy practices with respect to your PHI. For information about our collection, use, and disclosure of personal information other than PHI, please see our privacy policy at www.myjunohealth.com/legal/privacy-policy/ and the privacy policies posted on the websites of the affiliates listed above.

In this Notice, we describe:

• Information We Collect About You
• When We Use and Share Your Information
• When We Must Share Your Information
• When We Need Your Authorization to Use or Share Your Information
• Your Rights Regarding Your Information
• How We Keep Your Information Safe
• Changes to the Terms of This Notice

To provide you with the Juno Health Services, we collect PHI about you from a few sources including directly from you. PHI is information about you that may be used to identify you (such as your name), and that relates to:

• Your past, present or future physical or mental health or condition
• The provision of healthcare to you, or
• Your past, present, or future payment for the provision of healthcare.

Of course, as you use the Juno Health Services you will need to provide Juno Health with information about yourself and your medical history, past treatment, and potential future treatment options. As you communicate with us, your telephone calls, emails, and other communications between you and Juno Health and/or Juno Health's service providers, may be recorded and logged. As such, we will collect and maintain all information discussed during such communications including your identity, the date and time of the communication, and the contents of the communications.

In connection with the Juno Health Services, we may collect information about you from third parties such as:

• Past or current health care providers
• Health insurance and pharmacy benefit management companies
• Your employer or other organization that has contracted with Juno Health to give you access to the Services may provide us with your name and demographic information, so we know you are eligible for the Services

When you register and log in to our secure websites and mobile apps, Juno Health automatically collects information about you. Juno Health must be able to link your activity back to your identity so that changes in our systems can be made and we can track the Services you used. As such, we automatically collect the following types of information about you when you use our secure websites:

• IP address
• Device information
• General geographic information
• Dates and times you accessed and used the secure websites/mobile apps, features you used, and how long you use the secure websites/mobile apps

To provide you with the Services, we will need to use and disclose your PHI for the following reasons:

Treatment Activities

We will use your PHI within Juno Health to treat you and provide you with medical services. We may also disclose your PHI to other physicians or healthcare providers so that they can treat you and provide you with medical services. For example, electronic prescriptions written by Juno Health may be available to your treating physician to ensure your quality of care. When you use our Services, to enhance the continuity and quality of care we provide to you, your PHI may be available to providers within Juno Health for them to provide you with treatment and medical services. For example, your past consults will be available to the provider when you seek a new consult.

Payment Activities

We can use and share your PHI to get paid and for other payment activities. For example, we will send a claim to your health insurer to get paid. We may share PHI with other entities covered by HIPAA, such as health plans, for their payment activities.

Healthcare Operations Purposes

Juno Health may use and disclose your PHI to run our business. For example, to improve medical services, provide customer service, conduct quality review, contact you about the Services available to you and health benefits, monitor the qualifications of providers, and other healthcare operations activities. We may share PHI with other entities covered by HIPAA, such as health plans, for their business operations only if they also have or had a relationship with you.

We may also use PHI to:

• Participate in health information exchanges (HIEs) so that we can share, request, and receive electronic health information from other health care organizations for treatment, payment, and healthcare operations purposes as described above.
• Engage third parties to assist Juno Health with our payment and healthcare operations. If any such third party needs access to PHI to perform its services on behalf of Juno Health, Juno Health will require that third party to enter a written agreement that protects the PHI. We provide only the minimal PHI to accomplish the intended purpose of the use and sharing of the PHI.
• Communicate with family and friends who are involved in your care and payment for care.
• Create deidentified and aggregate information.

There are limited times when Juno Health may be permitted or required by law to use or disclose your PHI without your authorization. These include the following:

• For public health activities such as reporting certain diseases
• To protect victims of abuse or neglect, such as child abuse and elder neglect
• For judicial and administrative proceedings such as responding to subpoenas
• For workers compensation claims
• To prevent or lessen a serious and imminent threat of harm to a person or the public
• When required by law or for law enforcement purposes
• For state and federal health oversight activities such as physician licensing and disciplinary action
• To coroners, medical examiners, and funeral directors in limited circumstances
• For organ donation and transplantation
• For research approved by an institutional review board
• For specialized government functions such as national security

You have the following rights regarding your PHI maintained by Juno Health. Additionally, your medical power of attorney or legal guardian can exercise these rights on your behalf and make choices about your health information.

Right to Access PHI

Accessing Your Own PHI

Most of your PHI that Juno maintains is available to you directly in the Member Portal. You may find this information under "Past telehealth visits" in the Health Info section of your account by following the instructions below:

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Third-Party Medical Records Requests

Third-party medical records requests may be done:

• By email contactus@junohealth.app
• By mail: Juno Health

Still Need Help Accessing

To request access to information that is not available to you online, you must submit your request in writing to Juno using our Webform found here. Juno may impose a fee for the costs related to copying and mailing. Juno may deny your request to access your PHI in certain limited circumstances. If that occurs, we will inform you of the reason for the denial.

Right to Request Amendment of PHI

You have a right to request that Juno Health amend your PHI if you believe it is incorrect. Some changes to your PHI you can make yourself on the Member Portal. To request an amendment of your PHI that you cannot make yourself online, you must submit your request in writing to Juno Health using our Webform found here. If Juno Health denies your request, you will be permitted to submit a statement of disagreement for inclusion in your records.

Right to Request Restrictions on Uses and Disclosures of PHI

You have the right to request that Juno Health not use or disclose your PHI for treatment, payment, or healthcare operations purposes. To request a restriction, you must submit your request in writing to Juno Health using our Webform found here. Juno Health is not required to agree to your request unless you are requesting that we not disclose your PHI to your insurance company or health plan. In such cases, you will be required to pay for services out of pocket.

Right to Request Confidential Communication

You may request that Juno Health communicate with you through alternate means or at an alternate location. To request confidential communications, you must submit your request in writing to Juno Health using our Webform found here. Juno Health is not required to agree to your request however we will use best efforts to agree to reasonable requests.

Right to Request an Accounting of Disclosures

You have a right to receive an accounting of disclosures Juno Health has made of your PHI. To request for an accounting of disclosures, you must submit your request in writing to Juno Health using our Webform found here. Your right to an accounting of disclosures does not include disclosures made for treatment, payment or healthcare operations, disclosures made pursuant to an authorization, and certain other disclosures. Your first accounting will be free of charge.

You also have the right to:

1. Obtain a paper copy of this Notice from Juno Health at any time upon request;
2. File a complaint with Juno Health and/or the Secretary of Health and Human Services (at www.hhs.gov/ocr/privacy/hipaa/complaints/ ) if you believe that your privacy rights have been violated; and
3. Obtain more information about Juno Health's privacy practices by contacting the Privacy Officer in the following ways:

In writing
Privacy Officer
Juno Health

By email: contactus@Junohealth.app

By phone: (929) 484-2512

Juno Health reserves the right to change the terms of this Notice at any time, as long as the changes are in compliance with applicable laws. If Juno Health changes the terms of this Notice, the new terms will apply to all PHI that it maintains. If Juno Health changes this Notice, it will post the new Notice on its Web site and will make the new Notice available upon request.