PRIVACY NOTICE: This notice describes how your medical information may be used and disclosed, and how you may access this information. Please review it carefully.

What data is collected

• Personally Identifiable Information (PII) is data that identifies an individual or could be used to identify an individual.

• Protected Healthcare Information (PHI) is also PII but in addition contains health data about the individual identified by the data.

How data is used

• Advance Medical, Inc. (Advance Medical) uses and discloses data in creating a medical case and history, identifying physician consultants, and producing the Expert Medical Opinion Report (the “Report”) as the primary component of our Expert Medical Opinion (the “Service”).

• We do not share PHI or PII for any purpose not both defined in this notice and required for the production of the Service and Report.

• Advance Medical complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Advance Medical, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Advance Medical’s certification, please visit http://www.export.gov/safeharbor/

• Advance Medical is registered with the U.S. Department of Commerce Safe Harbor program. We commit to complying with the following ten (10) Safe Harbor principles:

• Notice – Individuals must be informed that their data is being collected and how it will be used.

• Choice – Individuals must have the option to opt out of the collection and forward transfer of the data to third parties. Advance Medical does not share any data with third parties. Renowned expert medical doctors are provided medical data necessary to render an expert medical opinion. They are covered by HIPAA regulations, under contract to Advance Medical (to protect privacy of patients) and in almost all cases the medical history they are provided by Advance Medical has been de-identified. (Experts need the medical facts of the case but do not need the name, address, social security number, telephone number or other identifying data of the patient to render their medical opinion.)

• Onward Transfer – Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles.

• Security – Reasonable efforts must be made to prevent loss of collected information. (Advance Medical uses extensive security controls: electronic, manual, procedural, physical and training of staff.)

• Data Integrity – Data must be relevant and reliable for the purpose it was collected.

• Access – Individuals must be able to access information held about them, and correct or delete it if it is inaccurate.

• Enforcement – There must be effective means to enforce these rules. If you are a citizen of Switzerland or the European Union (EU) the Advance Medical Alternate Dispute Resolution (ADR) agent is: JAMS, 1920 Main Street, Suite 300, Irvine, CA 92614; Telephone 949-224-1810.

• Transparency – Advance Medical will make our privacy commitments easy to find and easy to read.

• Control – Advance Medical does not share PII or PHI with any third parties other than as required by the Service and Report production and documented in this notice. When information is shared with our subsidiaries or trusted service providers, they too must comply with our privacy commitments.

• Accessibility – Advance Medical will listen to your feedback and answer your questions about our Privacy Policy, commitments, and practices.

• Advance Medical reserves the right to change our practices and to make the new provisions effective for all PHI and PII we maintain. We will not use or disclose your health information without your authorization, except as described in this notice.

• If you have a question or would like a copy of this notice or would like additional information, you may contact us. If you believe your privacy rights have been violated, you may file a complaint with Advance Medical, with the U.S. Secretary of Health and Human Services (HHS), or the U.S. Federal Trade Commission (FTC). There will be no retaliation for filing a complaint.

Your Health Information Rights

• Request a restriction on certain uses and disclosures of your information

• Obtain a paper copy of this privacy notice (information practices) upon request

• Inspect and/or receive a copy of your health record (a fee may be applied)

• Request an amendment or correction to your health record

• Obtain an accounting of disclosures of your health information

• Request communications of your health information by alternative means or at alternative locations

• Revoke your authorization to use or disclose health information except to the extent that action has already been taken.

Advance Medical’s Obligations

• Maintain the privacy of your health information

• Provide you with a notice as to our legal duties and privacy practices with respect to information we collect and maintain about you

• Abide by the terms of this notice

• Notify you if we are unable to agree to a requested restriction

• Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations.

Payment Data

Advance Medical does not use PII or PHI for payments.

Access to Advance Medical sites are access-controlled and restricted to registered adult patients, parents or guardians of minor patients, and our own staff of physicians, case managers and medical experts.

Advance Medical has implemented manual and technical, physical and electronic security controls to best ensure that our systems and data are secure. These controls are continuously monitored and upgraded as required by changing business processes, new threats and as better security controls become available.

Details of Advance Medical’s collection and usage of data
Examples of Disclosures for Treatment, Payment and Health Operations (TPO)

• Advance Medical may collect PHI for use in our Service. The information will be used and disclosed in creating a medical case and history, identifying physician consultants, and producing the Report.

• Advance Medical may disclose your health information to case managers, clinical committee members, administrators who will use the information to process your case and other individuals who are involved in providing the Service or generating the Report. In some cases your information may be sent to an outside consulting physician medical professionals. For example, a case manager may share your information with a medical director to identify an appropriate consulting physician for your case. The case manager may share the information with the consulting physician. We will ask these consultants to sign agreements requiring them to preserve the confidentiality of this information.
Other Uses of Data

• Advance Medical may use your health information to review or evaluate the performance of our systems in providing the Service to you and to improve the quality or timeliness of our services.

• Advance Medical may create de-identified information based on information you provided to us. De-identified information is information that does not include your name, address, birth date, or other information that could be used to identify you. This de-identified information may be used for quality improvement, research and other purposes. For example, Advance Medical may use this de-identified information to demonstrate the reliability of our information management systems or to generate medical research information. We would not identify you by name or other personally identifying data in any resulting reports or other information.

• Advance Medical may disclose information to contact you during the course of providing services to you as either part of the ongoing process, as part of an effort to follow-up with you after using the Service or if there is an opportunity to inform you about additional services of interest. We may contact you through the mail, by email or by phone.

Other Disclosures Mandated by Law:
Advance Medical may be called upon to disclose PHI by a duly empowered branch of Government in any country in which our patients are citizens. The following is a list of U.S. government agencies that may require Advance Medical to disclose protected heath information without your authorization:

• Food and Drug Administration (FDA): We may disclose to the FDA health information relative to adverse events with respect to food, supplements, product and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement

• Workers compensation: We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law

• Public health: As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability

• Correctional institution: Should you be an inmate of a correctional institution, we may disclose to the institution or agents thereof health information necessary for your health and the health and safety of other individuals

• Law enforcement: We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena

• Federal oversight agency: Federal law makes provisions for your health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers, or the public

• Victims of abuse: To protect victims of neglect or domestic violence

• Judicial and administrative processes: For judicial proceedings after proper legal process.

Other uses or disclosures about your medical information may require your written authorization. You may revoke that authorization at any time but that revocation will not affect any use or disclosure made prior to revocation.

Advance Medical may disclose information to you, to your representative or to another individual designated by you.

Online Activity Tracking and Advertising

• We collect information about your activity on Our Site using technologies such as cookies and server log files.

• We do not use third-party cookies or non-Advance Medical web beacons (i.e., Web-based data collection by other than Advance Medical. I.E. advertising or tracking links.

• We use this automatically generated information to provide you with an optimal website experience. This includes measuring the effectiveness of our web pages and your interactions with them to make using our pages as easy for you as possible.

• Our site and related applications will generate log files that track who has had access to your PHI and/or PII.

Individual’s Rights

You have the right to inspect, copy, and amend completed medical records maintained by Advance Medical. To inspect your medical records please make a signed and dated written request to: Advance Medical, Privacy Officer, 100 Lowder Brook Drive, Suite 2200, Westwood, MA 02090.

We may charge you a processing fee for these requests. In some cases we may not honor your requests, such as if disclosing records will cause you harm, if they are part of legal proceedings or if they are part of ongoing legal research. In the event that we deny your request you will be notified of any denial within 60 days and be given additional options or information. To make an amendment to your medical records, please make a signed and dated written request to Advance Medical, Privacy Officer, 100 Lowder Brook Drive, Suite 2200, Westwood, MA 02090. In the request please describe the changes that you would like to make and the reason why. In the event that we deny your request you will be notified of any denial within 60 days and be given additional options or information.

You have the right to request restricted disclosures or uses or to request that we limit access to your PHI. Please make a signed and dated written request to Advance Medical, Privacy Officer, 100 Lowder Brook Drive, Suite 2200, Westwood, MA 02090. Include all of the specific information that you wish to have restricted and the person or categories of persons who should or should not have access to the information. We have the right to deny your requests or ask for additional information. In the event that we deny your request you will be notified of any denial within 60 days.

You have the right to an accounting of certain disclosures of your PHI that were made without your written authorization. Please make a signed and dated written request to Advance Medical, Privacy Officer, 100 Lowder Brook Drive, Suite 2200, Westwood, MA 02090. We are only obligated to share disclosure accounting for the preceding six years. This accounting will not include disclosures made in the course of providing the Service or generating the Report, as described in this notice.

You have the right to request to receive confidential communications about your health information, such as having information sent to a particular address or in a particular way. Please make a signed and dated written request to Advance Medical, Privacy Officer, 100 Lowder Brook Drive, Suite 2200, Westwood, MA 02090. In your request specify how you prefer to receive communication.

You have the right to make complaints about any possible violation of your Privacy Rights to Advance Medical. Advance Medical will not penalize you for making a complaint. To make a complaint, please make a signed and dated written complaint to Advance Medical, Privacy Officer, 100 Lowder Brook Drive, Suite 2200, Westwood, MA 02090.

If, for any reason, you would like to discuss any matter concerning our privacy policies or to request copies of our privacy policies, please submit your question or complaint in writing: Privacy Officer, c/o Advance Medical, 100 Lowder Brook Drive, Suite 2200, Westwood, MA 02090.

866 342 1987

privacyofficer@advance-medical.com

Effective as of June 17 2015.

Rev 1 Advance Medical, Inc. 2015 ©