NOTICE OF PRIVACY PRACTICES

Effective Date: September 22, 2025

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.

1.  Scope of this Notice

This Notice of Privacy Practices applies to the services provided by the following medical groups: (i) Online Medical Care, P.C., a New Jersey professional corporation that does business in New Jersey and New York, (ii) TMD of Kansas, P.A., a Kansas professional association that does business in Kansas, (iii) TMD of Texas, P.A., a Texas professional association that does business in Texas, and (iv) TMD of CA, P.C., a California professional corporation that does business in all other states (collectively, “we” or “Company”). These provider groups participate in an organized health care arrangement (“OHCA”) as defined in 45 C.F.R. § 160.103, and this Notice is a joint notice under 45 C.F.R. § 164.520(d).
This policy applies to information we collect when you access or use our websites and mobile applications (the service delivery sites for the OHCA), when you use our services, or when you otherwise interact with us. This Notice of Privacy Practices describes the information that Company collects about you, how we use and share that information, and the privacy choices we offer. If applicable, OHCA participants may share protected health information with each other as necessary to carry out treatment, payment, or health care operations relating to the arrangement.

2. Confidentiality of Health Information

Company understands that health information about you and your health is personal. We support your privacy and ensure that the transmission and use of your information comply with all laws, except to the extent that you have authorized Company to transmit information to you by other means. In this regard, where applicable, we comply with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act (“HITECH Act”), and other relevant state laws and regulations.
Company is dedicated to maintaining the privacy of your protected health information (“PHI”), as that term is defined under HIPAA. PHI is information about you that may be used to identify you (such as your name, social security number or address), and that relates to (a) your past, present or future physical or mental health or condition, (b) the provision of healthcare to you, or (c) your past, present, or future payment for the provision of healthcare. In conducting its business, Company may receive and create records containing your PHI. We are required by HIPAA to maintain the privacy and security of your PHI. We are required by law to notify affected individuals following a breach of unsecured PHI.

3. Uses and Disclosures of PHI.

Company may use and disclose your PHI in the following ways:

• Treatment, Payment and Healthcare Operations. Company is permitted to use and disclose your PHI for purposes of (a) treatment, (b) payment and (c) healthcare operations. For example:
  • Treatment. Company may disclose your PHI to a physician in connection with the provision of treatment to you.
  • Payment. Company may use and disclose your PHI to your health insurer or health plan in connection with the processing and payment of claims and other charges.
  • Healthcare Operations. Company may use and disclose your PHI in connection with its healthcare operations, such as providing customer services and conducting quality review assessments. Company may engage third parties to provide various services for Company. If any such third party must have access to your PHI in order to perform its services, Company will require the third party to enter into an agreement that binds the third party to the use and disclosure restrictions outlined in this Notice.
• Authorization. Company is permitted to use and disclose your PHI upon your written authorization, to the extent such use or disclosure is consistent with your authorization. You may revoke any such authorization at any time. We will obtain your written authorization before using or disclosing psychotherapy notes (with limited exceptions), before marketing uses/disclosures, and before any sale of PHI. You may revoke an authorization as provided in 45 C.F.R. § 164.508(b)(5). Other uses and disclosures not described in this Notice will be made only with your written authorization.
• As Required by Law. Company may use and disclose your PHI to the extent required by law.
• Special Circumstances. The following categories describe unique circumstances in which Company may use or disclose your PHI:
  • Public Health Activities. Company may disclose your PHI to public health authorities or other governmental authorities for purposes including preventing and controlling disease, reporting child abuse or neglect, reporting domestic violence and reporting to the Food and Drug Administration regarding the quality, safety and effectiveness of a regulated product or activity. Company may, in certain circumstances, disclose PHI to persons who have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition.
  • Workers’ Compensation. Company may disclose your PHI as authorized by, and to the extent necessary to comply with, workers’ compensation programs and other similar programs relating to work-related illnesses or injuries.
  • Health Oversight Activities. Company may disclose your PHI to a health oversight agency for authorized activities such as audits, investigations, inspections, licensing and disciplinary actions relating to the healthcare system or government benefit programs.
  • Judicial and Administrative Proceedings. Company may disclose your PHI, in certain circumstances, as permitted by applicable law, in response to an order from a court or administrative agency, or in response to a subpoena or discovery request.
  • Law Enforcement. Company may, under certain circumstances, disclose your PHI to a law enforcement official, such as for purposes of identifying or locating a suspect, fugitive, material witness or missing person.
  • Decedents. Company may, under certain circumstances, disclose PHI to coroners, medical examiners and funeral directors for purposes such as identification, determining the cause of death and fulfilling duties relating to decedents.
  • Organ Procurement. Company may, under certain circumstances, use and disclose PHI for the purposes of organ donation and transplantation.
  • Research. Company may, under certain circumstances, use or disclose PHI that is necessary for research purposes.
  • Threat to Health or Safety. Company may, under certain circumstances, use or disclose PHI if necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.
  • Specialized Government Functions. Company may, under certain circumstances, use and disclose PHI of persons who are, or were, in the Armed Forces for purposes such as ensuring proper execution of a military mission or determining entitlement to benefits. Company may also disclose PHI to federal officials for intelligence and national security purposes.
• Reproductive Health Care Privacy
  • Prohibited Uses/Disclosures. Company may not use or disclose PHI to investigate, impose liability on, or identify any person for the mere act of seeking, obtaining, providing, or facilitating reproductive health care. For example, we will not disclose PHI to help investigate a patient for traveling to receive lawful reproductive health care.
  • Applicability & Presumption. This prohibition applies when the care was lawful where provided or is protected/required by Federal law. If the care was provided by another person, we presume it was lawful unless we have actual knowledge it was not, or the requestor provides facts showing a substantial basis that it was not.
  • Attestation Required (Certain Requests). For PHI potentially related to reproductive health care sought for health oversight, court/administrative proceedings, law enforcement, or coroners/medical examiners, Company will not disclose without a signed attestation from the requestor stating the PHI is not sought for a prohibited purpose. Example: Before responding to a subpoena seeking such PHI, we will obtain the required attestation.
• Redisclosure Notice. PHI that we disclose to a third party may be redisclosed by the recipient and may no longer be protected by HIPAA, except where prohibited by other laws.

4. Your Rights Regarding Your PHI.

You have the following rights regarding the PHI maintained by Company:

• Confidential Communication. You have the right to receive confidential communications of your PHI. You may request that Company communicate with you through alternate means or at an alternate location, and Company will accommodate your reasonable requests. You must submit your request in writing to Company.
• Restrictions. You have the right to request restrictions on certain uses and disclosures of PHI for treatment, payment or healthcare operations. You also have the right to request that Company limits its disclosures of PHI to only certain individuals involved in your care or the payment of your care. You must submit your request in writing to Company. We must agree to your request to restrict a disclosure to a health plan if the disclosure is for payment or health care operations (and not otherwise required by law) and the PHI pertains solely to an item or service for which you (or someone on your behalf) have paid in full. Otherwise, Company is not required to comply with your request. However, if Company agrees to comply with your request, it will be bound by such agreement, except when otherwise required by law or in the event of an emergency.
• Inspection and Copies. You have the right to inspect and copy your PHI. You must submit your request in writing to Company. Company may impose a reasonable, cost-based fee that includes only: labor for copying, supplies (paper/electronic media), postage if mailed, and preparing an explanation/summary if you agree to receive one. Company may deny your request to inspect and/or copy your PHI in certain limited circumstances. If that occurs, Company will inform you of the reason for the denial, and you may request a review of the denial.
• Amendment. You have a right to request that Company amend your PHI if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is maintained by Company. You must submit your request in writing to Company and provide a reason to support the requested amendment. Company may, under certain circumstances, deny your request by sending you a written notice of denial. If Company denies your request, you will be permitted to submit a statement of disagreement for inclusion in your records.
• Accounting of Disclosures. You have a right to receive an accounting of all disclosures Company has made of your PHI. However, that right does not include disclosures made for treatment, payment or healthcare operations, disclosures made to you about your treatment, disclosures made pursuant to an authorization, and certain other disclosures. You must submit your request in writing to Company and you must specify the time period involved (which must be for a period of time less than six years from the date of the disclosure). Your first accounting will be free of charge. However, Company may charge you for the costs involved in fulfilling any additional request made within a period of 12 months. Company will inform you of such costs in advance, so that you may withdraw or modify your request to save costs.
• Breach Notification. You have the right to be notified in the event that Company (or a Company business associate) discovers a breach of unsecured PHI.
• Paper Copy. You have the right to obtain a paper copy of this Notice from Company at any time upon request. To obtain a paper copy of this notice, please contact Company by calling (855) 983-5347. • Complaint. You may complain to Company and to the Secretary of the Department of Health and Human Services if you believe that your privacy rights have been violated. To file a complaint with Company, you must submit a statement in writing to Company at support@telegramd.com. Company will not retaliate against you for filing a complaint.
• Further Information. If you would like more information about your privacy rights, please contact Company by calling (855) 983-5347 and ask to speak to the Privacy and Security Officer. To the extent you are required to send a written request to Company to exercise any right described in this Notice, you must submit your request to 100 N Howard St, Ste R, Spokane, WA 99201.

5. Changes to this Notice of Privacy Practices

This Notice is in effect from the date noted above until Company replaces it. Company reserves the right to change the terms of this Notice at any time, as long as the changes are in compliance with applicable law. If Company changes the terms of this Notice, the new terms will apply to all PHI that it maintains, including PHI that was created or received before such changes were made. If Company changes this Notice, it will post the new Notice on its website and will make the new Notice available upon request. We are required to abide by the terms of the Notice currently in effect.