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.

WhoMust Follow this Notice

MovingAnalytics, Inc. dba Movn Health (“Company”) provides you with health coachingservices by working with health coaches and other health care providers(referred to as “we,” “our,” or “us”) when you apply for or participate in theMovn Program (the “Services”). This is a joint notice of our informationprivacy practices (“Notice”). The following people or groups will follow thisNotice:

• any health care provider who provides services to you at or from     Company’s locations. These professionals include health coaches and     others;
• any health care provider that utilizes our Services to deliver a     remote coaching program to you; and
• our employees, contractors, and volunteers, including regional     support offices and affiliates. These entities, sites, and locations may     share medical information with each other for treatment, payment, or     health care operations purposes described in this Notice.

Inaddition, we also use and share your information for other reasons as allowedand required by law. If you have any questions about this Notice, please seeour contact information on the last page of this Notice.

OurCommitment to Your Privacy

We arededicated to maintaining the privacy and integrity of the protected healthinformation that we receive from you as part of your application for orparticipation in the Services (“PHI”). PHI is information about you that wereceive from you as part of your application for or participation in theServices that may be used to identify you (such as your name, social securitynumber, or address), and that relates to (a) your past, present, or futurephysical or mental health or condition, (b) the provision of health care toyou, or (c) your past, present, or future payment for the provision of healthcare. In providing services to you, we will receive and create recordscontaining your PHI. We need these records to provide you with quality care andto comply with certain legal requirements.

We arerequired by law to maintain the privacy of your PHI and to provide you withnotice of our legal duties and privacy practices with respect to your PHI. Whenwe use or disclose your PHI, we are required to abide by the terms of thisNotice (or other Notice in effect at the time of the use or disclosure).

ThisNotice applies to the records of services you receive at or from Company,whether created by our staff or your healthcare provider. Your health careproviders may have different practices or notices about their use and sharingof medical information in their own offices, locations or clinics. We willgladly explain this Notice to you or your family member.

How WeMay Use and Disclose Protected Health Information

We arerequired to maintain the confidentiality of your PHI, and we have policies andprocedures and other safeguards to help protect your PHI from improper use anddisclosure. The following categories describe different ways that we use yourPHI within Company and disclose your PHI to persons and entities outside ofCompany. We have not listed every use or disclosure within the categoriesbelow, but all permitted uses and disclosures will fall within one of thefollowing categories. In addition, there are some uses and disclosures thatwill require your specific authorization.

Howmuch PHI may legally be used or disclosed without your written permission willvary depending, for example, on the intended purpose of the use or disclosure.Sometimes we may only need to use or disclose a limited amount of PHI, such asto send you a reminder or to confirm your health insurance coverage. At othertimes, we may need to use or disclose more PHI such as when a doctor isproviding medical treatment.

• Disclosure at your request. We may disclose information when     requested by you. This disclosure at your request may require written     authorization by you.
• Treatment. This is the most important use and disclosure of your     PHI. We may use and disclose your PHI to a physician or health care     provider to provide treatment and other services to you. In addition, we     may contact you to provide reminders or information about treatment     alternatives or other health-related benefits and services that may be of     interest to you. We may also disclose PHI to other providers involved in     your treatment.
• Health care operations. We may use and disclose your PHI for our     health care operations and the health care operations of certain other entities     that have or have had a relationship with you. These health care     operations include internal administration and planning and various     activities that improve the quality and cost effectiveness of the care     delivered to you. Examples include, but are not limited to, using     information about you to improve quality of care, quality assessment     activities, disease management programs, patient satisfaction surveys,     compiling medical information, training, de-identifying PHI and     benchmarking.
• Business associates. Some services in our organization are provided     through our contracts with business associates. Examples of business     associates include accreditation agencies, management consultants, quality     assurance reviewers, and billing and collection services. We may disclose     your PHI to our business associates so that they can perform the job we     have asked them to do. To protect your PHI, we require our business     associates to sign a contract or written agreement stating that they will     appropriately safeguard your PHI.

SpecialSituations that Do Not Require Your Authorization

Thefollowing categories describe unique circumstances in which Company may use ordisclose your PHI without your authorization.

• Public health activities. We may disclose your PHI for the following     public health activities to: (1) prevent or control disease, injury or     disability; (2) report births and deaths; (3) report regarding the abuse     or neglect of children, elders and dependent adults; (4) report reactions     to medications or problems with products; (5) notify people of recalls of     products they may be using; (6) 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 (7) notify emergency response employees regarding possible     exposure to HIV/AIDS, to the extent necessary to comply with state and     federal laws.
• Victims of abuse, neglect or domestic violence. If we reasonably     believe you are a victim of abuse, neglect, or domestic violence, we may     disclose your PHI to a governmental authority, including a social service     or protective services agency, authorized by law to receive reports of     such abuse, neglect, or domestic violence.
• Health oversight activities. We may disclose your PHI to a health     oversight agency for activities authorized by law. These oversight     activities include, for example, audits, investigations, inspections, and     licensure. These activities are necessary for the government to monitor     the health care system, government programs, and compliance with civil     rights laws.
• Lawsuits and other legal disputes. We may use and disclose PHI in     responding to a court or administrative order, a subpoena, or a discovery     request. We may also use and disclose your PHI to the extent permitted by     law without your authorization, for example, to defend a lawsuit or     arbitration.
• Law enforcement officials. We may disclose your PHI to the police or     other law enforcement officials as required or permitted by law: (1) in     response to a court order, subpoena, warrant, summons or similar process;     (2) to identify or locate a suspect, fugitive, material witness, or     missing person; (3) about the victim of a crime if, under certain limited     circumstances, we are unable to obtain the person’s agreement; (4) about a     death we believe may be the result of a criminal conduct; (5) about     criminal conduct at Company; and (6) 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.
• Decedents. We may disclose your PHI to a coroner or medical examiner     as authorized by law.
• Research that does not involve your treatment. When a research study     does not involve any treatment, we may disclose your PHI to researchers.     To do this, we will either ask your permission to use your PHI or we will     use a special process that protects the privacy of your PHI. In addition,     we may use information that cannot be identified as your PHI, but that     includes certain limited information (such as your date of birth and dates     of service). We will use this information for research, quality assurance     activities, and other similar purposes and, if we disclose this limited     information, we will obtain special protections for the information     disclosed.
• Specialized government functions. We may use and disclose your PHI     to units of the government with special functions, such as the U.S.     military or the U.S. Department of State, under certain circumstances. We     may use and disclose your PHI to authorized federal officials for intelligence,     counterintelligence, and other national security activities authorized by     law. We may use and disclose your PHI to authorized federal officials so     they may provide protection to the President, other authorized persons or     foreign heads of state, or conduct special investigations.
• Inmates. If you are an inmate of a correctional institution or     under custody of a law enforcement official, we may disclose PHI about you     to the correctional institution or the law enforcement official. This is     necessary for the correctional institution to provide you with health     care, to protect your health and safety and the health and safety of     others, and to protect the safety and security of the correctional     institution.
• Workers’ compensation. We may disclose your PHI as authorized by and     to the extent necessary to comply with state laws relating to workers’     compensation or other similar programs.
• As required by law. We may use and disclose your PHI when required     to do so by any other law not already referred to in the preceding     categories. For example, the Secretary of the Department of Health and     Human Services may review our compliance efforts, which may include seeing     your PHI.

SituationsRequiring Your Written Authorization

Ifthere are reasons we need to use your PHI that have not been described in thesections above, we will obtain your written permission. This permission isdescribed as a written “authorization.” If you authorize us to use or disclosePHI about you, you may revoke that authorization in writing at any time. If yourevoke your authorization, we will no longer use or disclose PHI about you forthe reasons stated in your written authorization, except to the extent we havealready acted in reliance on your authorization. You understand that we areunable to take back any disclosures we have already made with your permission,and we are required to retain our records of the care we provide to you.

YourRights Regarding Your PHI

Youhave the following rights regarding PHI we maintain about you. You may contactus to obtain additional information and instructions for exercising thefollowing rights.

• Right to request additional restrictions. You may request     restrictions on our use and disclosure of your PHI (1) for treatment,     payment and health care operations, (2) to individuals (such as a family     member, other relative, close personal friend or any other person     identified by you) involved with your care or with payment related to your     care, or (3) to notify or assist in the notification of such individuals     regarding your location and general condition. While we will consider all     requests for additional restrictions carefully, we are not required to     agree to a requested restriction, unless the request is regarding a     disclosure to a health plan for a payment or health care operation purpose     and the PHI relates solely to a health care item or service for which we     have been paid out-of-pocket in full. This request must be in writing. We     will send you a written response. If we agree with the request, we will     comply with your request except to the extent that disclosure has already     occurred or if you are in need of emergency treatment and the information     is needed to provide the emergency treatment.
• Right to receive confidential communications. You may request to     receive your PHI by alternative means of communication or at alternative     locations. For example, you can request that we only contact you at work     or by mail. To request confidential communications, you must make your     request in writing. We will not ask you for the reason for your request.     We will accommodate all reasonable requests. Your request must specify how     or where you wish to be contacted.
• Inspection and copies. You may request access to your medical record     file and billing records maintained by us. You may inspect and request     copies of the records. Under limited circumstances, we may deny you access     to a portion of your records. If you are denied access to PHI, you may     request that the denial be reviewed. Another licensed health care     professional chosen by us will review your request and the denial. The     person conducting the review will not be the person who denied your     request. We will comply with the outcome of the review.
• If you desire access to your records, you must submit your request     in writing. If your PHI is maintained in an electronic health record, you     may obtain an electronic copy of your PHI and, if you choose, instruct us     to transmit such copy directly to an entity or person you designate in a     clear, conspicuous, and specific manner.
• If you request paper copies, we will charge you for the costs of     copying, mailing, labor and supplies associated with your request. Our fee     for providing you an electronic copy of your PHI will not exceed our labor     costs in responding to your request for the electronic copy (or summary or     explanation).
• You should take note that, if you are a parent or legal guardian of     a minor, certain portions of the minor’s PHI will not be accessible to you     (e.g., records pertaining to health care services for which the minor can     lawfully give consent and therefore for which the minor has the right to     inspect or obtain copies of the record; or the health care provider     determines, in good faith, that access to the client records requested by     the representative would have a detrimental effect on the provider’s     professional relationship with the minor client or on the minor’s physical     safety or psychological well-being).
• Right to amend your records. You have the right to request that we     amend PHI maintained in your medical record file or billing records. If     you desire to amend your records, your request must be in writing. We will     comply with your request unless we believe that the information that would     be amended is accurate and complete or other special circumstances apply.     If we deny your request, you will be permitted to submit a statement of     disagreement for inclusion in your records.
• Right to addendum. You have the right to add an addendum to your     PHI maintained in your medical record.
• Right to receive an accounting of disclosures. Upon written request,     you may obtain an accounting of certain disclosures of your PHI made by us     during any period of time five years prior to the date of your request.     Your written request should indicate in what form you want the list (for example,     on paper or electronically). If you request an accounting more than once     during a twelve (12) month period, we will charge you for the costs     involved in fulfilling your additional request. We will inform you of such     costs in advance, so that you may modify or withdraw your request to save     costs. In addition, we will notify you as required by law if there has     been a breach of the security of your PHI.

MinimumNecessary

To theextent required by law, when using or disclosing your PHI or when requestingyour protected health information from another covered entity, we will makereasonable efforts not to use, disclose, or request more than the minimumamount of protected health information necessary to accomplish the intendedpurpose of the use, disclosure, or request, taking into consideration practicaland technological limitations.

Changesto this Notice

We maychange the terms of this Notice from time to time. Changes will apply tocurrent PHI, as well as new PHI after the change occurs. We will post the newNotice on our website at   www.movinganalytics.com/hipaa. Uponyour request, you may obtain any revised Notice by calling or emailing us andrequesting that a revised copy be sent to you in the mail.

Concernsor Complaints

If youdesire further information about your privacy rights, are concerned that wehave violated your privacy rights, or disagree with a decision that we madeabout access to your PHI, you may contact our Privacy Officer (listed below).Finally, you may send a written complaint to the U.S. Department of Health andHuman Services, Office of Civil Rights. Our Privacy Officer can provide you theaddress. We will not take any action against you for filing a complaint.

How toContact Us

If youwould like more information about your privacy rights, please contact Companyby calling 833-726-0123 and ask to speak with the Privacy Officer. To theextent you are required to send a written request to Company to exercise anyright described in this Notice, you must submit your request to Company at:

MovingAnalytics, Inc., 16969 Von Karman Ave. STE 175, Irvine, CA 92606

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