PRIVACY POLICY – TELEDOCTOR OnCall

1. Introduction and Scope of This Privacy Policy

Welcome to TELEDOCTOR OnCall. This Privacy Policy describes how TELEDOCTOR OnCall ("TELEDOCTOR OnCall," "we," "us," or "our"), the operator of the website www.teledoctoroncall.com (the "Platform"), collects, uses, discloses, and protects your Personal Information and Protected Health Information (PHI) when you access or use our Platform and Services.

This Privacy Policy applies to all users of the Platform, including registered users and casual visitors, who are residents of the State of Florida, USA. By accessing or using our Platform, you signify your understanding of and consent to the collection, storage, use, and disclosure of your Personal Information and PHI as described in this Privacy Policy and our Terms of Use. If you do not agree with the terms of this Privacy Policy, you must not access or use the Platform.

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Platform and updating the "Effective Date" at the top of this policy. Your continued use of the Platform following the posting of changes constitutes your acceptance of such changes.

2. Key Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:

• "Healthcare Provider" means physicians, specialists, therapists, and other licensed healthcare professionals or professional entities that are independently contracted with or made accessible through the Platform or integrated Third-Party Systems to provide telehealth Services to Users.
• "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or household. It does not include PHI as defined below, publicly available information from government records, or de-identified or aggregated consumer information.
• "Platform" means the website www.teledoctoroncall.com, its subdomains, associated mobile applications (if any), software, technology infrastructure, content, and all services provided by TELEDOCTOR OnCall in connection therewith.
• "Protected Health Information" (PHI) has the meaning given to it under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as amended, and generally includes individually identifiable health information related to your past, present, or future physical or mental health or condition, the provision of healthcare to you, or the past, present, or future payment for the provision of healthcare to you.
• "Services" means the telehealth consultation facilitation services, information services, and technological resources provided through the Platform, enabling Users to connect with Healthcare Providers.
• "Third-Party System(s)" means external platforms, software, or services integrated with or linked from the Platform, such as the "Athena" medical system (or similar systems), for functionalities including but not limited to Healthcare Provider access, PHI management, information exchange, and payment processing.
• "User" or "You" means any individual who accesses, registers with, or uses the Platform.

3. Information We Collect (and How We Collect It)

We collect information about you in various ways when you use our Platform. This includes information you provide directly to TELEDOCTOR OnCall, information collected automatically by TELEDOCTOR OnCall, and information that is primarily handled by integrated Third-Party Systems.

A. Information You Provide Directly to TELEDOCTOR OnCall:

• Account Registration Data: When you create an account directly on the TELEDOCTOR OnCall Platform (if applicable), we may collect Personal Information such as your name, email address, password, phone number, and other contact details you provide.
• Communications: When you contact TELEDOCTOR OnCall customer support, send us an email, or otherwise communicate with us directly, we may collect records and copies of your correspondence.
• Other Information: Any other information you voluntarily choose to provide to TELEDOCTOR OnCall directly through the Platform.

B. Information Collected Automatically by TELEDOCTOR OnCall:

• Log Files and Usage Data: When you access and use the TELEDOCTOR OnCall Platform, our servers may automatically record certain information, such as your Internet Protocol (IP) address, browser type, operating system, device information, the web pages you visited before or after coming to our Platform, pages viewed on our Platform, access times, and other usage statistics related to your interaction with the TELEDOCTOR OnCall Platform itself.
• Cookies and Similar Tracking Technologies: We use cookies and similar tracking technologies to collect information about your Browse activities on the TELEDOCTOR OnCall Platform. Please see Section 7 ("Cookies, Web Beacons, and Tracking Technologies") for more details.

C. Information Primarily Handled by Integrated Third-Party Systems (e.g., "Athena"):

• Protected Health Information (PHI): TELEDOCTOR OnCall facilitates your connection to Healthcare Providers who utilize integrated Third-Party Systems (such as "Athena" or similar electronic health record and practice management systems) to provide telehealth Services. The comprehensive PHI related to your medical consultations, including your medical history, symptoms, diagnoses, treatments, prescriptions, lab results, and other clinical notes, is primarily collected, processed, and stored by these Healthcare Providers and their chosen Third-Party Systems, in accordance with HIPAA. TELEDOCTOR OnCall generally does not store this detailed PHI on its own primary systems.
• Insurance Information: Your health insurance details, if you use insurance for the Services, are typically collected and processed by the Healthcare Provider through such Third-Party Systems.
• Payment Information: Payment for Services is generally processed by Healthcare Providers through secure, integrated Third-Party Systems (e.g., "Athena" or a designated payment processor). TELEDOCTOR OnCall does not directly collect, store, or process your full payment card information (such as credit card numbers).

You acknowledge that when you provide PHI, insurance, or payment information in the context of receiving telehealth services from a Healthcare Provider, that information is subject to the privacy policies and data handling practices of the respective Healthcare Provider and their chosen Third-Party Systems, which are responsible for maintaining HIPAA compliance for such data.

4. How We Use Your Information (Collected Directly by TELEDOCTOR OnCall)

TELEDOCTOR OnCall uses the Personal Information it collects directly from you or automatically through your use of our Platform for the following purposes:

• To Provide and Operate the Platform: To operate, maintain, administer, and improve the TELEDOCTOR OnCall Platform, its features, and functionalities (excluding the direct provision of medical care, which is the responsibility of Healthcare Providers).
• Account Management: To create, manage, and secure your User account on the TELEDOCTOR OnCall Platform.
• Communications: To communicate with you about your TELEDOCTOR OnCall account, provide you with transactional updates (e.g., appointment reminders if scheduled through our Platform features, service announcements, technical notices), and respond to your inquiries, comments, and requests directed to TELEDOCTOR OnCall customer support.
• Customer Support: To provide customer service and support for issues related to the TELEDOCTOR OnCall Platform itself.
• Personalization: To personalize your experience on the TELEDOCTOR OnCall Platform, such as by remembering your preferences.
• Analytics and Improvement: To perform data analytics, understand usage trends, conduct research, and improve the TELEDOCTOR OnCall Platform, our offerings, and user experience.
• Enforcement: To enforce our Terms of Use, this Privacy Policy, and other policies applicable to your use of the TELEDOCTOR OnCall Platform.
• Security and Legal Compliance: For security purposes, to prevent fraud, to protect the integrity and security of the TELEDOCTOR OnCall Platform, and to comply with applicable legal obligations and legal process.

We do not use PHI for purposes other than those permitted by HIPAA and as described in Section 5.

5. Our Role and Practices Regarding Protected Health Information (PHI) and HIPAA

TELEDOCTOR OnCall is committed to protecting the privacy and security of PHI in compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as amended, and applicable state laws, including those in Florida.

• HIPAA Compliance: We have implemented appropriate administrative, physical, and technical safeguards to protect the confidentiality, integrity, and availability of any PHI that we may create, receive, maintain, or transmit on behalf of a HIPAA Covered Entity (such as a Healthcare Provider) or as a conduit.
• Role of Healthcare Providers and Third-Party Systems: Healthcare Providers you connect with through our Platform are typically HIPAA Covered Entities. They, along with the integrated Third-Party Systems they use (e.g., "Athena"), are primarily responsible for collecting, using, disclosing, and safeguarding your PHI in accordance with HIPAA. These systems are designed to support HIPAA compliance for the management of electronic health records and patient interactions.
• TELEDOCTOR OnCall's Handling of PHI: Our Platform facilitates your access to these Healthcare Providers and their systems. While TELEDOCTOR OnCall itself does not aim to be the primary custodian of your comprehensive medical record, we may, in the course of providing our Services, transmit or incidentally handle PHI. In such instances:
  • We will only use or disclose PHI as permitted or required by HIPAA, the applicable BAA, and for the purpose of providing, coordinating, or managing healthcare and related services through the Platform.
• Notice of Privacy Practices (NPP): Your Healthcare Provider is required by HIPAA to provide you with a Notice of Privacy Practices (NPP). Their NPP describes how they may use and disclose your PHI and outlines your rights with respect to your PHI. We encourage you to review the NPP provided by your Healthcare Provider. TELEDOCTOR OnCall does not provide the NPP on behalf of Healthcare Providers, but you can typically request it directly from them or their practice.

6. Disclosure and Sharing of Your Information (Collected Directly by TELEDOCTOR OnCall)

TELEDOCTOR OnCall does not sell your Personal Information. We may disclose or share Personal Information that we collect directly from you or automatically through your use of our Platform under the following circumstances:

• With Service Providers: We may share your Personal Information with third-party vendors, consultants, and other service providers who perform services on our behalf or to help us operate the TELEDOCTOR OnCall Platform (e.g., website hosting, data analytics, email delivery, customer support software). These service providers are contractually obligated to maintain the confidentiality and security of your Personal Information and are restricted from using it for any purpose other than to provide services for us.
• To Facilitate Services with Healthcare Providers and Integrated Systems: We may share your TELEDOCTOR OnCall account information and necessary contact details with Healthcare Providers and the integrated Third-Party Systems (e.g., "Athena") to enable your telehealth consultations, facilitate communication, and ensure the seamless provision of the Services you request.
• Legal Requirements and Safety: We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to: (a) comply with applicable laws, regulations, legal processes (such as a subpoena or court order), or governmental requests; (b) enforce our Terms of Use or other agreements, including investigation of potential violations thereof; (c) detect, prevent, or otherwise address fraud, security, or technical issues; or (d) protect against harm to the rights, property, or safety of TELEDOCTOR OnCall, our Users, Healthcare Providers, or the public, as required or permitted by law.
• Business Transfers: In the event that TELEDOCTOR OnCall is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Information may be shared, sold, or transferred as part of such a transaction, as permitted by law and/or contract. We will notify you of any such business transfer to the extent required by applicable law.
• With Your Consent: We may share your Personal Information for any other purpose disclosed by us at the time we collect the information or pursuant to your explicit consent.
• Aggregated or De-identified Data: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with third parties for various purposes, including for research, analytics, or to improve our Services.

We do not share PHI except as permitted or required by HIPAA and as described in Section 5.

7. Cookies, Web Beacons, and Tracking Technologies

When you interact with the TELEDOCTOR OnCall Platform, we (and our third-party service providers, such as analytics providers) may use cookies, web beacons, and similar tracking technologies to collect certain information automatically.

• Cookies: Cookies are small text files placed on your device (computer, smartphone, etc.) when you visit a website. We use cookies on the TELEDOCTOR OnCall Platform for purposes such as:
  • Essential/Strictly Necessary Cookies: To enable core Platform functionality, such as user authentication and security.
  • Performance/Analytics Cookies: To collect information about how you use our Platform, such as which pages you visit and if you experience any errors. This helps us improve how our Platform works.
  • Functionality Cookies: To allow our Platform to remember choices you make (such as your username or language preference) and provide enhanced, more personal features.
• Web Beacons: Web beacons (also known as pixel tags or clear GIFs) are small electronic files that may be included on our Platform or in our emails to permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics.
• Your Choices: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of some features of the TELEDOCTOR OnCall Platform. For more information on how to manage cookies, please consult your browser's help documentation.
• Analytics: We may use third-party analytics services (such as Google Analytics) to help us understand and analyze how users use the TELEDOCTOR OnCall Platform. These analytics providers may use cookies and other tracking technologies to collect this information.

This section describes cookies and tracking technologies used directly by the TELEDOCTOR OnCall Platform. Integrated Third-Party Systems (e.g., "Athena") or linked websites may have their own cookie and tracking technology practices, which are governed by their respective privacy policies.

8. Data Security

TELEDOCTOR OnCall takes the security of your Personal Information seriously and has implemented administrative, technical, and physical safeguards designed to protect the Personal Information we directly collect and control from unauthorized access, use, alteration, and disclosure. These measures are consistent with applicable laws, including the Florida Information Protection Act (FIPA), which requires reasonable security measures.

These safeguards include, but are not limited to:

• Using encryption technologies for certain data transmissions.
• Implementing access controls to limit access to Personal Information to authorized personnel.
• Maintaining policies and procedures for data handling and incident response.

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information is at your own risk.

As stated elsewhere in this Privacy Policy, the security of your Protected Health Information (PHI) and sensitive payment information, when processed through integrated Third-Party Systems (such as "Athena") utilized by Healthcare Providers, is primarily the responsibility of those systems and the respective Healthcare Providers. These entities are required to implement robust security measures in accordance with HIPAA and other applicable standards (like PCI DSS for payment information). We encourage you to review their security practices.

9. Data Retention (for Data Collected Directly by TELEDOCTOR OnCall)

TELEDOCTOR OnCall will retain the Personal Information we collect directly from you for as long as your User account on our Platform remains active, or as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide you access to our Platform.
• Whether there is a legal obligation to which we are subject (for example, certain laws may require us to keep records of your transactions for a certain period before we can delete them).
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Protected Health Information (PHI) is retained by Healthcare Providers and their integrated Third-Party Systems (e.g., "Athena") in accordance with applicable state and federal laws, including HIPAA, and their own record retention policies. TELEDOCTOR OnCall does not dictate PHI retention policies for Healthcare Providers.

10. Your Privacy Choices and Rights (Regarding Data Controlled by TELEDOCTOR OnCall)

We aim to provide you with choices regarding the Personal Information you provide to us directly or that we collect through your use of the TELEDOCTOR OnCall Platform.

• Accessing and Updating Your Account Information: If you have a User account with TELEDOCTOR OnCall, you may be able to review and update certain Personal Information in your account profile by logging into your account and visiting your account settings page.
• Marketing Communications: If you have opted in to receive marketing or promotional communications from TELEDOCTOR OnCall, you can opt-out of receiving these communications at any time by following the unsubscribe instructions provided in such emails or by contacting us directly. Please note that even if you opt-out of marketing communications, we may still send you transactional or administrative messages related to your account and use of our Platform (e.g., service announcements, important updates to our Terms or this Privacy Policy).
• Cookies and Tracking Technologies: You can manage your preferences for cookies and tracking technologies used by the TELEDOCTOR OnCall Platform as described in Section 7 ("Cookies, Web Beacons, and Tracking Technologies").
• Protected Health Information (PHI) Rights: With respect to your PHI that is collected and maintained by your Healthcare Provider through integrated Third-Party Systems (e.g., "Athena"), you have specific rights under HIPAA. These rights generally include the right to access your PHI, request amendments to your PHI, request an accounting of certain disclosures of your PHI, and request restrictions on certain uses and disclosures of your PHI. To exercise these HIPAA rights, you must contact your Healthcare Provider directly. TELEDOCTOR OnCall does not control your PHI held by Healthcare Providers and cannot directly process these requests on their behalf. Your Healthcare Provider's Notice of Privacy Practices (NPP) will provide more detailed information on how to exercise your HIPAA rights.
• General Requests (Florida Residents): While the Florida Digital Bill of Rights (FDBR) has specific applicability thresholds, TELEDOCTOR OnCall is committed to good privacy practices. If you are a Florida resident and wish to request access to or correction of the Personal Information that TELEDOCTOR OnCall directly controls about you, please contact us using the details in Section 15 ("Contact Us"). We will consider such requests in accordance with applicable law and our internal policies. Please note that these rights are not absolute and may be subject to certain limitations.

11. Children's Privacy

The TELEDOCTOR OnCall Platform and Services are not directed to or intended for use by individuals under the age of eighteen (18). We do not knowingly collect Personal Information from children under 18. If we become aware that we have inadvertently collected Personal Information from a child under the age of 18 without verification of parental consent, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe that your child under 18 has provided Personal Information to TELEDOCTOR OnCall without your consent, please contact us using the information provided in Section 15 ("Contact Us"), and we will take reasonable steps to remove the information from our systems.

12. Third-Party Links and Services

The TELEDOCTOR OnCall Platform may contain links to other websites, applications, or services that are not operated or controlled by TELEDOCTOR OnCall ("Third-Party Sites"). This Privacy Policy does not apply to the practices of Third-Party Sites. Any information you provide to Third-Party Sites will be governed by their respective privacy policies and terms of service.

We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any Third-Party Sites. We encourage you to review the privacy policies of any Third-Party Sites you visit before providing any information to or through them.

13. Data Breach Notification (Compliance with Florida Information Protection Act - FIPA)

TELEDOCTOR OnCall is committed to complying with Florida's data breach notification laws, including the Florida Information Protection Act (FIPA). In the event of a "breach of security system," as defined by FIPA, involving unencrypted Personal Information that TELEDOCTOR OnCall directly collects, stores, or maintains, and which causes, or is reasonably believed to cause, loss, or injury to Florida residents, we will provide notice to affected individuals as required by and in accordance with FIPA.

Such notice may be provided by written notice, electronic notice (if consistent with the provisions regarding electronic records and signatures set forth in 15 U.S.C. s. 7001), or substitute notice if circumstances meet the FIPA criteria for such notice.

14. Changes to This Privacy Policy

TELEDOCTOR OnCall reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated policy on the Platform and update the policy's "Effective Date" at the top of this page.

Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the Personal Information we collect. If we make material changes to how we treat our users' Personal Information, we will notify you through a notice on the Platform's home page or, where feasible and appropriate, by email to the primary email address specified in your account.

15. Contact Us (for Privacy Inquiries)

If you have any questions, comments, or concerns about this Privacy Policy, our data practices concerning information TELEDOCTOR OnCall directly controls, or if you wish to exercise your applicable privacy rights regarding such information, please contact us at:

TELEDOCTOR OnCall Attn: [email protected]

Please include your name, contact information, and the nature of your request or inquiry so that we can respond appropriately and efficiently. For matters concerning your Protected Health Information (PHI) managed by Healthcare Providers, please contact your Healthcare Provider directly.