Notice of Privacy Practices

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.

Ethos Holding Corp dba Ethos Laboratories (“Ethos Laboratories”) is committed to protecting the privacy of your identifiable health information. This information is known as “protected health information” or “PHI.” Examples of documents that may contain your PHI include laboratory test orders, test results and invoices.

Our Responsibilities

Ethos Laboratories is required by law to maintain the privacy of your PHI. We are also required to provide you with this Notice of our legal duties and privacy practices upon request. It describes our legal duties, privacy practices and your patient rights as determined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). We are required to follow the terms of this Notice currently in effect. We are required to notify affected individuals in the event of a breach involving PHI that is unsecured. PHI is stored electronically and is subject to electronic disclosure. This Notice does not apply to certain services that we perform, such as some drugs of abuse testing services and insurance applicant services.

How We May Use or Disclose Your Health Information

We use your PHI for treatment, payment, or healthcare operations purposes and for other purposes permitted or required by law. Not every use or disclosure is listed in this Notice, but all of our uses or disclosures of your PHI will fall into one of the categories listed below.

We need your authorization to use or disclose your PHI for any purpose not covered by one of the categories below. With limited exceptions, we will not use or disclose psychotherapy notes, use or disclose your PHI for marketing purposes or sell your PHI unless you have signed an authorization. You may revoke any authorization you sign at any time. If you revoke your authorization, we will no longer use or disclose your PHI except to the extent we have already taken action based on your authorization.

We may use and disclose your PHI for the following purposes:

• For treatment — Ethos Laboratories  may use or disclose PHI for treatment purposes, including disclosure to physicians, nurses, medical students, pharmacies, and other health care professionals who provide you with health care services and/or are involved in the coordination of your care, such as providing your physician with your laboratory test results.
• For payment — Ethos Laboratories may use or disclose PHI to bill and collect payment for laboratory or genetic counseling services we provide. For example, Ethos Laboratories may provide PHI to your health plan to receive payment for the health care services provided to you.
• For health care operations — Ethos Laboratories may use or disclose PHI for health care operations purposes. These uses and disclosures are necessary, for example, to evaluate the quality of our laboratory testing, accuracy of results, accreditation functions and for Ethos Laboratories’ operation and management purposes. Ethos Laboratories may also disclose PHI to other health care providers or health plans that are involved in your care for their health care operations. For example, Ethos Laboratories may provide PHI to manage disease, or to coordinate health care or health benefits.
• Appointment reminders and health-related benefits and services — Ethos Laboratories  may use and disclose PHI to contact you as a reminder that you have an appointment with us and may use and disclose PHI to tell you about health-related benefits and services that may be of interest to you. For example, Ethos Laboratories may contact you about a new patient service center in your area or about new testing services available at Ethos Laboratories based on services ordered by your physician.
• Disclosure of PHI to you — Ethos Laboratories may disclose PHI to you or as directed by you to a third party. Your right to see and receive a copy of your PHI is listed below under patient rights regarding PHI.
• Emergency circumstances and notifications — If you are present and capable, Ethos Laboratories  will obtain your agreement to use and/or disclose PHI about you during an emergency event to notify, or assist in the notification of a family member, your personal representative, or another person responsible for your care regarding your location, general condition, or death. Otherwise, Ethos Laboratories may exercise its professional judgment based on the circumstances and use and disclose PHI for your safety.
• Individuals involved in your care or payment for your care — Ethos Laboratories may disclose PHI to a person who is involved in your care or helps pay for your care, such as a family member or friend. We also may notify your family about your location or general condition or disclose such information to an entity assisting in a disaster relief effort. As allowed by federal and state law, we may disclose the PHI of minors to their parents or legal guardians.
• Business associates — Ethos Laboratories may disclose PHI to its business associates to perform certain business functions or provide certain business services to Ethos Laboratories. For example, we may use another company to perform billing services on our behalf. All of our business associates are required to maintain the privacy and confidentiality of your PHI. In addition, at the request of your health care providers or health plan, Ethos Laboratories may disclose PHI to their business associates for purposes of performing certain business functions or health care services on their behalf. For example, we may disclose PHI to a business associate of Medicare for purposes of medical necessity review and audit.
• Disclosure for judicial and administrative proceedings — under certain circumstances, Ethos Laboratories may disclose your PHI in the course of a judicial or administrative proceeding, including in response to a court or administrative order, subpoena, discovery request, or other lawful process.
• Law enforcement — Ethos Laboratories may disclose PHI for law enforcement purposes, including reporting of certain types of wounds or physical injuries or in response to a court order, warrant, subpoena or summons, or similar process authorized by law. We may also disclose PHI when the information is needed: 1) for identification or location of a suspect, fugitive, material witness or missing person, 2) about a victim of a crime, 3) about an individual who has died, 4) in relation to criminal conduct on Ethos Laboratories premises, or 5) in emergency circumstances to report a crime, the location of the crime or victims, or the identity, description, or location of the person who committed the crime.
• As required by law — Ethos Laboratories must disclose your PHI if required to do so by federal, state, or local law.
• Public Health — Ethos Laboratories may disclose PHI for public health activities. These activities generally include: 1) disclosures to a public health authority to report, prevent or control disease, injury, or disability; 2) disclosures to report births and deaths, or to report child abuse or neglect; 3) disclosures to a person subject to the jurisdiction of the Food and Drug Administration (FDA) for purposes related to the quality, safety or effectiveness of an FDA-regulated product or activity, including reporting reactions to medications or problems with products or notifying people of recalls of products they may be using; 4) disclosures to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition; and 5) disclosures to an employer about an employee to conduct medical surveillance in certain limited circumstances concerning work-place illness or injury.
• Disclosure about victims of abuse, neglect, or domestic violence — Ethos Laboratories  may disclose PHI about an individual to a government authority, including social services, if we reasonably believe that an individual is a victim of abuse, neglect, or domestic violence.
• Health oversight activities — Ethos Laboratories  may disclose PHI to a health care oversight agency for activities authorized by law such as audits, civil, administrative, or criminal investigations and proceedings/actions, inspections, licensure/disciplinary actions, or other activities necessary for appropriate oversight of the health care system, government benefit programs, and compliance with regulatory requirements and civil rights laws.
• Coroners, medical examiners, and funeral directors — Ethos Laboratories  may disclose PHI to a coroner, medical examiner, or funeral director for the purpose of identifying a deceased person, determining cause of death, or for performing some other duty authorized by law.
• Organ and Tissue Donation — if requested, Ethos Laboratories may disclose PHI to organizations that handle organ procurement, or eye and tissues donation banks, or other health care organization as needed to make organ and tissue donation and transplantation possible.
• Personal Representative — Ethos Laboratories may disclose PHI to your personal representative, as established under applicable law, or to an administrator, executor, or other authorized individual associated with your estate.
• Correctional institution — Ethos Laboratories may disclose the PHI of an inmate or other individual when requested by a correctional institution or law enforcement official for health, safety, and security purposes.
• Serious threat to health or safety — Ethos Laboratories is allowed to disclose PHI when it has a good faith belief that the disclosure (1) is necessary to prevent or lessen a serious and/or imminent threat to the health or safety of the patient or others and (2) is to a person or persons reasonably able to prevent or lessen the threat.
• Research — Ethos Laboratories may use and disclose PHI for research purposes. Limited data or records may be viewed by researchers to identify patients who may qualify for their research project or for other similar purposes, so long as the researchers do not remove or copy any of the PHI. Before we use or disclose PHI for any other research activity, one of the following will happen: 1) a special committee will determine that the research activity poses minimal risk to privacy and that there is an adequate plan to safeguard PHI; 2) if the PHI relates to deceased individuals, the researchers give us assurances that the PHI is necessary for the research and will be used only as part of the research; or 3) the researcher will be provided only with information that does not identify you directly.
• Government functions — In certain situations, Ethos Laboratories  may disclose the PHI of military personnel and veterans, including Armed Forces personnel, as required by military command authorities. Additionally, we may disclose PHI to authorized officials for national security purposes, such as protecting the President of the United States, conducting intelligence, counter-intelligence, other national security activities, and when requested by foreign military authorities. Disclosures will be made only in compliance with U.S. Law.
• Workers’ compensation — as authorized by applicable laws, Ethos Laboratories may use or disclose PHI to comply with workers’ compensation or other similar programs established to provide work-related injury or illness benefits.
• De-identified Information and Limited Data Sets — Ethos Laboratories  may use and disclose health information that has been “de-identified” by removing certain identifiers making it unlikely that you could be identified. Ethos Laboratories also may disclose limited health information, contained in a “limited data set”. The limited data set does not contain any information that can directly identify you. For example, a limited data set may include your city, county and zip code, but not your name or street address.

We may also disclose PHI to those assisting in disaster relief efforts so that family or friends can be notified about your condition, status and location.

Incidental Uses and Disclosures

Sometimes, your PHI may be used or disclosed in the course of our primary uses and disclosures, such as for treatment, payment or healthcare operations. For example, we may call your name in the waiting room at one of our Patient Service Centers, or use it in a telephone conversation with a provider. We are permitted to make such incidental uses and disclosures as long as we take reasonable steps to minimize them, and have in place appropriate safeguards to protect them.

Note Regarding State Law

For all of the above purposes, when state law is more restrictive than federal law, we are required to follow the more restrictive state law.

Your Patient Rights

Subject to certain exceptions, HIPAA establishes the following patient rights with respect to PHI:

• Right to Receive a Copy of the Ethos Laboratories Notice of Privacy Practices — You have a right to receive a copy of the Ethos Laboratories Notice of Privacy Practices at any time by contacting us at compliance@ethos-labs.com, calling us at 877-496-2570, ext. 1400 for the Ethos Laboratories HIPAA Privacy Officer, or by sending a written request to: HIPAA Privacy Officer, Ethos Laboratories, 29 East 6^th Street, Newport, Kentucky 41071. This Notice will also be posted on the Ethos Laboratories Internet site at www.ethos-labs.com

• Right to Request Limits on Uses and Disclosures of your PHI — You have the right to request that we limit: 1) how we use and disclose your PHI for treatment, payment, and health care operations activities; or 2) our disclosure of PHI to individuals involved in your care or payment for your care. Ethos Laboratories will consider your request, but is not required to agree to it unless the requested restriction involves a disclosure that is not required by law to a health plan for payment or health care operations purposes and not for treatment, and you have paid for the service in full out of pocket. If we agree to a restriction on other types of disclosures, we will state the agreed restrictions in writing and will abide by them, except in emergency situations when the disclosure is for purposes of treatment.

• Right to Request Confidential Communications — You have the right to request that Ethos Laboratories communicate with you about your PHI at an alternative address or by an alternative means. Ethos Laboratories will accommodate reasonable requests.

• Right to See and Receive Copies of Your PHI — You and your personal representative have the right to access PHI consisting of your laboratory test results or reports ordered by your physician. Within 30 days after our receipt of your request, you will receive a copy of the completed laboratory report from Ethos Laboratories unless an exception applies. Exceptions include a determination by a licensed health care professional that the access requested is reasonably likely to endanger the life or safety of you or another person, and our inability to provide access to the PHI within 30 days, in which case we may extend the response time for an additional 30 days if we provide you with a written statement of the reasons for the delay and the date by which access will be provided. You have the right to access and receive your PHI in an electronic format if it is readily producible in such a format. You also have the right to direct Ethos Laboratories  to transmit a copy to another person you designate, provided such request is in writing, signed by you, and clearly identifies the designated person and where to send the copy of your PHI. To request a copy of your PHI:

• Ask for a courtesy copy when you visit an Ethos Laboratories patient service center for specimen collection.

• Ask an Ethos Laboratories Site Collector or Customer Service for information on how to open an Ethos Laboratories patient portal account to receive your laboratory reports electronically.

• Complete the Ethos Laboratories HIPAA Patient Request Form.

• Contact the Privacy Officer at 877-496-2570, ext. 1400 or by e-mail at compliance@ethos-labs.com.

• Right to Receive an Accounting of Disclosures — You have a right to receive a list of certain instances in which Ethos Laboratories disclosed your PHI. This list will not include certain disclosures of PHI, such as (but not limited to) those made based on your written authorization or those made prior to the date on which Ethos Laboratories was required to comply. If you request an accounting of disclosures of PHI that were made for purposes other than treatment, payment, or health care operations, the list will include disclosures made in the past six years, unless you request a shorter period of disclosures. If you request an accounting of disclosures of PHI that were made for purposes of treatment, payment, or health care operations, the list will include only those disclosures made in the past three years for which an accounting is required by law, unless you request a shorter period of disclosures.

• Right to Correct or Update your PHI — If you believe that your PHI contains a mistake, you may request, in writing, that Ethos Laboratories correct the information. If your request is denied, we will provide an explanation of the reasoning for our denial.

Copy of this Notice

You have the right to obtain a paper copy of this Notice upon request.

How to Exercise Your Rights

You may write or send an email to us with your specific request. Please refer to the Contact Information below. Ethos Laboratories will consider your request and provide you a response.

Complaints/Questions/Contact Information

If you believe your privacy rights have been violated, you have the right to file a complaint with us. You also have the right to file a complaint with the Secretary of the U.S. Department of Health and Human Services, Office for Civil Rights. Ethos Laboratories will not retaliate against any individual for filing a complaint.  To file a complaint with us, or should you have any questions about this Notice, send an email to us at compliance@ethos-labs.com, or write to us at the following address:

Ethos Laboratories

Attention: Privacy Officer
29 East 6^th Street
Newport, KY 41071

You may also contact the Privacy Officer at 877-496-2570, ext. 1400.

Note

We reserve the right to amend the terms of this Notice to reflect changes in our privacy practices, and to make the new terms and practices applicable to all PHI that we maintain about you, including PHI created or received prior to the effective date of the Notice revision. Our Notice is displayed on our website and a copy is available upon request.

Non-Discrimination Notice

We comply with applicable Federal civil rights laws and do not discriminate on the basis of race, color, national origin, age, disability, or sex. Ethos Laboratories does not exclude people or treat them differently because of race, color, national origin, age, disability, or sex.

Ethos Laboratories:

• Provides language services free of charge to people whose primary language is not English, such as:

-Qualified interpreters

• Provides aids and services free of charge to people with disabilities to communicate effectively with us, such as:

-Auxiliary aids and services
-Written information in other formats (audio, accessible electronic formats, other formats)

If you need these services, contact 877-496-2570, ext. 1400 or ask at an Ethos Laboratories Customer Service Center.

If you believe that Ethos Laboratories has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability or sex, you can file a grievance with:

Ethos Laboratories
Civil Rights Coordinator
29 East 6th Street

Newport, KY 41071

877-496-2570, ext. 1400
compliance@ethos-labs.com

You can file a grievance in person or by mail, fax, or email. If you need help filing a grievance, the Ethos Laboratories Civil Rights Coordinator is available to help you.

You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf, or by mail or phone at:

U.S. Department of Health and Human Services
200 Independence Avenue, SW
Room 509F, HHH Building
Washington, D.C. 20201
(800) 368-1019, (800) 537-7697 (TDD)

Language Assistance Services

ATTENTION: If you speak English, language assistance services, free of charge, are available to you. Call 1 877-496-2570.

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注意事項：日本語 (Japanese) を話される場合、無料の言語支援をご利用いただけます。1 (844) 698-1022 まで、お電話にてご連絡ください。

Effective: December 22, 2021