Privacy Policy

1. Information Collection. Personal information means any information that may be
used to identify an individual, including, but not limited to, a first and last name,
email address, a home, postal or other physical address, other contact information,
title, birth date, gender, occupation, industry, personal interests, medical conditions
or other information when needed to provide a service you requested.
When you browse Qwell LLC’s website, (the “Site”), you do so
anonymously, unless you have previously indicated that you wish Qwell LLC
(“Qwell”) to remember your login and password or you submit a registration form.
We do not collect personal information for the purpose of reselling or distributing
that information. We may log your IP address (the Internet address of your
computer) to give us an idea of which part of the Site you visit and how long you
spend there. However, we do not link your IP address to any personal information
unless you have logged in to our website. Like many other commercial websites, the
Site may use a standard technology called a “cookie” to collect information about
how you use the Site. Qwell collects personal information when you register with
Qwell for an appointment, for a Qwell account or when you submit your information
to Qwell for any other reason.

2. Notification. When personal information is collected, we will inform you at the
point of collection the purpose for the collection. Qwell will not transfer your
personal information to third parties without your consent. We will always give you
the opportunity to “opt out” of receiving direct marketing or market research
information. This means we assume you have given us your consent to collect and
use your information in accordance with this Policy unless you take affirmative
action to indicate that you do not consent, for instance by clicking or checking the
appropriate option or box at the point of collection. In some cases, when applicable,
we will provide you with the opportunity to “opt in.” This means we will require
your affirmative action to indicate your consent before we use your information for
purposes other than the purpose for which it was submitted.

3. Cookies and Tracking Technology. A cookie is a small data file that certain Web
sites write to your hard drive when you visit them. A cookie file can contain
information such as a user ID that the website uses to track the pages you’ve visited,
but the only personal information a cookie can contain is information you supply
yourself. A cookie can’t read data off your hard disk or read cookie files created by
other websites. Some parts the Site use cookies to understand user traffic patterns.
We do this in order to determine the usefulness of the Site information to our users
and to see how effective our navigational structure is in helping users reach that
information. If you prefer not to receive cookies while browsing the Site, you can set
your browser to warn you before accepting cookies and refuse the cookie when
your browser alerts you to its presence. You can also refuse all cookies by turning
them off in your browser, although you may not be able to take full advantage of the
Site if you do so. You do not need to have cookies turned on to use/navigate
through many parts of the Site, except access to certain of Qwell’s web pages require
a login and password.

4. Information Sharing and Disclosure. Inside Qwell, data is stored in controlled
servers with limited access. Your protected health information (“PHI”) may be
stored and processed in the United States or any other country where Qwell, its
subsidiaries, affiliates or agents are located. Your personal information is never
shared outside Qwell without your permission, except under conditions explained
a) For Treatment: We may use and disclose PHI for your treatment and to
provide you with treatment-related health care benefits and services. For
example, we may disclose PHI to doctors, nurses, technicians, pharmacists, or
other personnel, including those who are involved in your medical care and
need the information to provide you with medical care.
b) For Payment: We may use and disclose PHI so that we or others may bill and
receive payment from you, an insurance company or a third party for the
treatment, products and/or services you received. For example, we may give
your health plan information about you so that they will pay for your
treatment. When appropriate, we may share information with a person who
is involved in your medical care or payment for your care, such as your
family or a close friend. Additionally, we may disclose PHI to your personal
representative designated by you or any other person who has the auth
a) As Required by Law: We will disclose PHI when required to do so by
international, federal, state or local law.
b) To Avert a Serious Threat to Health or Safety: We may use and disclose
PHI when necessary to prevent a serious threat to your health and safety or
the health and safety of the public or another person. Disclosures, however,
will be made only to someone who may be able to help prevent the threat.
c) Business Associates: We may disclose PHI to our business associates that
perform functions on our behalf or provide us with services if the
information is necessary for such functions or services. For example, we may
use another company to perform billing services on our behalf. All of our
business associates are obligated to protect the privacy of your information
and are not allowed to use or disclose any information other than as
specified in our contract.
d) Public Health Risks: We may disclose PHI for public health activities. These
activities generally include disclosures to prevent or control disease, injury
or disability; report births and deaths; report child abuse or neglect; report
reactions to medications or problems with products; notify people of recalls
of products they may be using; 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 notify the appropriate government authority if we believe a
patient has been the victim of abuse, neglect or domestic violence. We will
only make this disclosure if you agree or when required or authorized by
e) Health Oversight Activities: We may use or disclose your PHI to provide
legally required notices of unauthorized access to or disclosure of your PHI. f)
Data Breach Notification Purposes: We may use or disclose your PHI to
provide legally required notices of unauthorized access to or disclosure of
your PHI. g) Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may
disclose PHI in response to a court or administrative order. We also may
disclose PHI in response to a subpoena, discovery request, or other lawful
process by someone else involved in the dispute.
h) Law Enforcement: We may release PHI if asked by a law enforcement
official if the information is: (1) in response to a court order, subpoena,
warrant, summons or similar process; (2) limited information to identify or
locate a suspect, fugitive, material witness, or missing person; (3) about the
victim of a crime even if, under certain very limited circumstances, we are
unable to obtain the person’s agreement; (4) about a death we believe may
be the result of criminal conduct; (5) about criminal conduct on our
premises; and (6) in an emergency to report a crime, the location of the
crime or victims, or the identity, description or location of the person who
committed the crime.
i) Coroners and Medical Examiners: We may release PHI to a coroner or
medical examiner. This may be necessary, for example, to identify a deceased
person or determine the cause of death.
j) Transfer of Records: We may release PHI to transfer your records as part of
a sale of the pharmacy business when permitted by law.

6. Uses and Disclosures that Require Us to Give You An Opportunity to Object and
a) Individuals Involved in Your Care or Payment for Your Care: Unless you
object, we may disclose to a member of your family, a relative, a close friend
or any other person you identify, your PHI that directly relates to that
person’s involvement in your health care. If you are unable to agree or object
to such a disclosure, we may disclose such information as necessary if we
determine that it is in your best interest based on our professional judgment.
b) Disaster Relief: We may disclose your PHI to disaster relief organizations
that seek your PHI to coordinate your care, or notify family and friends of
your location or condition in a disaster. We will provide you with an
opportunity to agree or object to such a disclosure whenever we practically
can do so.
DISCLOSURES: The following uses and disclosures of your PHI will be made
only with your written authorization:
i. Uses and disclosures of PHI for marketing purposes; and
ii. Disclosures that constitute a sale of your PHI. d) Other uses and disclosures of
PHI not covered by this Notice or the laws that
apply to us will be made only with your written authorization. If you do give
us an authorization, you may revoke it at any time by submitting a written
revocation to our Director of Operations and we will no longer disclose PHI
under the authorization. But disclosure that we made in reliance on your
authorization before you revoked it will not be affected by the revocation.

7. Your Rights. You have the following rights regarding PHI we have about you:
a) Right to Inspect and Copy: You have a right to inspect and copy PHI that
may be used to make decisions about your care or payment for your care. To
inspect and copy this PHI, you must make your request, in writing, to {insert
person}. We have up to 30 days to make your PHI available to you and we
may charge you a reasonable fee for the costs of copying, mailing or other
supplies associated with your request. We may not charge you a fee if you
need the information for a claim for benefits under the Social Security Act or
any other state of federal needs-based benefit program. We may deny your
request in certain limited circumstances. If we do deny your request, you
have the right to have the denial reviewed by a licensed healthcare
professional who was not directly involved in the denial of your request, and
we will comply with the outcome of the review.
b) Right to an Electronic Copy of Electronic Medical Records: If your PHI is
maintained in an electronic format (known as an electronic medical record or
an electronic health record), you have the right to request that an electronic
copy of your record be given to you or transmitted to another individual or
entity. We will make every effort to provide access to your PHI in the form or
format you request, if it is readily producible in such form or format. If the
PHI is not readily producible in the form or format you request, your record
will be provided in either our standard electronic format; or, if you do not
want this form or format, a readable hard copy form. We may charge you a
reasonable, cost-based fee for the labor associated with transmitting the
electronic medical record.
c) Right to Get Notice of a Breach: You will be notified upon a breach of any of
your unsecured PHI.

d) Right to Amend: If you feel that PHI we have is incorrect or incomplete, you
may ask us to amend the information. You have the right to request an
amendment for as long as the information is kept by or for our office.
e) Right to an Accounting of Disclosures: You have the right to request a list
of certain disclosures we made of PHI for purposes other than treatment,
payment and health care operations or for which you provided written
f) Right to Request Restrictions: You have the right to request a restriction or
limitation on the PHI we use or disclose for treatment, payment, or health
care operations. You also have the right to request a limit on the PHI we
disclose to someone involved in your care or the payment for your care, like
a family member or friend. For example, you could ask that we not share
information about a particular diagnosis or treatment with your spouse. We
are not required to agree to your request unless you are asking us to restrict
the use and disclosure of your PHI to a health plan for payment or health care
operation purposes and such information you wish to restrict pertains solely
to a health care item or service for which you have paid us “out-of-pocket” in
full. If we agree, we will comply with your request unless the information is
needed to provide you with emergency treatment.
g) Out-of-Pocket-Payments: If you paid out-of-pocket in full for a specific item
or service, you have the right to ask that your PHI with respect to that item or
service not be disclosed to a health plan for purposes of payment or health
care operations, and we will honor that request.
h) Right to Request Confidential Communications: You have the right to
request that we communicate with you about health related matters in a
certain way or at a certain location. For example, you can ask that we only
contact you by mail or at work. Your request must specify how or where you
wish to be contacted. We will accommodate reasonable requests
i) Right to a Paper Copy of This Notice: You have the right to a paper copy of
this notice. You may request us to give you a copy of this notice at any time.
Even if you have agreed to receive this notice electronically, you are still
entitled to a paper copy of this notice.

8. Data Security. Your Qwell account information is password-protected for your
privacy and security. Qwell safeguards the security of the data you send us with
physical, electronic, and managerial procedures. While we strive to protect your
personal information, we cannot ensure the security of the information you transmit
to us, and so we urge you to take every precaution to protect your personal data
when you are on the Internet. Change your passwords often, use a combination of
letters and numbers, and make sure you use a secure browser.

9. Children and Privacy. The Site does not target and is not intended to attract
children under the age of 13. Qwell does not knowingly solicit personal information
from children under the age of 13 or send them requests for personal information.

10. Third Party Sites. The Site contains links to other websites. Qwell does not share
your personal information with those websites and is not responsible for their
privacy practices. We encourage you to learn about the privacy policies of those

11. Changes to This Privacy Policy. Qwell may amend this policy from time to time. If
we make any substantial changes in the way we use your personal information we
will make that information available by posting a notice on this Site.