PersonalCarePath LLC – Privacy Policy & Notice of Privacy Practices

Dated: April 2026

1. Introduction & Our Role

PersonalCarePath LLC (the “Company,” “we,” or “us”) provides comprehensive care management and behavioral health services to patients over the telephone and via SMS/text messaging. We provide these services strictly on behalf of your licensed health care provider.

In our capacity as a Business Associate to your provider, our clinical and administrative staff operate as an extension of your provider’s team. We are legally bound by Business Associate Agreements and the Health Insurance Portability and Accountability Act (HIPAA) to maintain the strict privacy, security, and confidentiality of your Protected Health Information (PHI), Electronic Protected Health Information (ePHI), and Personally Identifiable Information (PII).

This policy explains how your medical information may be used and shared, as well as your rights regarding your health information.

2. How We Use and Share Your Information

We only use or disclose your health information as permitted by law and our agreements with your health care provider. Typically, we use your information to:

  • Help Manage Your Health Care: We use your information to conduct care management calls, behavioral health check-ins, and coordinate your ongoing treatment.

  • Operate Our Organization: We use health information to run our internal operations, evaluate the quality of our care management services, and contact you when necessary.

  • Assist with Payment & Administration: We may share information with your provider or health plan to coordinate payment for the health services you receive.

Other Permitted Disclosures: We are also allowed, or required, to share your information in ways that contribute to the public good or comply with the law, including:

  • Complying with state and federal laws (including HHS privacy audits).

  • Helping with public health and safety issues (e.g., preventing disease, reporting adverse medication reactions, or preventing serious threats to health/safety).

  • Addressing workers’ compensation, law enforcement, or other government requests.

  • Responding to court orders, lawsuits, and subpoenas.

  • Responding to organ/tissue donation requests, or working with a coroner, medical examiner, or funeral director.

  • Conducting health research (subject to strict legal conditions).

3. Your Privacy Rights

When it comes to your health information, you have specific rights. Because we act on behalf of your provider, we will work with your provider’s office to fulfill these requests:

  • Access Your Records: You can ask to see or get a copy of the health records we manage on your provider's behalf. (Your provider may charge a reasonable, cost-based fee).

  • Correct Your Records: You can ask us or your provider to correct health information about you that you think is incorrect or incomplete. We may say "no" to your request, but we will tell you why in writing within 60 days.

  • Request Confidential Communications: You can ask us to contact you in a specific way (for example, only calling a home phone rather than a cell phone) or to send mail to a different address. We will accommodate all reasonable requests.

  • Ask Us to Limit What We Use or Share: You can ask us not to use or share certain health information for treatment, payment, or operations. We are not required to agree to your request, and we may say "no" if it would negatively affect your care.

  • Get a List of Disclosures: You can ask for a list (an accounting) of the times we have shared your health information for six years prior to the date you ask, who we shared it with, and why.

  • Choose a Representative: If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will verify this person’s authority before taking action.

  • Get a Copy of this Notice: You can ask for a paper copy of this notice at any time.

4. Your Choices Regarding Your Information

For certain health information, you can tell us your choices about what we share. If you have a clear preference, please communicate it to our staff or your provider.

You have the right to tell us to:

  • Share information with your family, close friends, or others involved in your care or payment for your care.

  • Share information in a disaster relief situation.

If you are unable to tell us your preference (e.g., if you are unconscious), we may share your information if we believe it is in your best interest or needed to lessen a serious and imminent threat to health or safety.

We will NEVER share your information for the following purposes without your written consent:

  • Marketing purposes.

  • The sale of your patient information.

  • Fundraising activities.

5. Our Responsibilities

  • We are required by law to maintain the privacy and security of your PHI, ePHI, and PII.

  • We will notify you and/or your provider promptly if a breach occurs that may have compromised the privacy or security of your information.

  • We must follow the duties and privacy practices described in this notice and make a copy available to you.

  • We will not use or share your information other than as described here unless you tell us we can in writing. You may change your mind at any time by notifying us or your provider in writing.

6. Complaints & Contact Information

If you believe your privacy rights have been violated, you have the right to file a complaint without fear of retaliation. You can complain by:

•         Contacting your primary medical provider directly.

 

•         Contacting PersonalCarePath, LLC's Compliance Officer.

 

•         Filing a complaint with the U.S. 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/.

Changes to the Terms of this Notice

We reserve the right to change the terms of this privacy notice. Any changes will apply to all information we currently have about you, as well as any information we receive in the future. The new notice will be available upon request and posted on our website.