Sanctifi Health — Notice of Privacy Practices & HIPAA Acknowledgment

Last updated: March 1, 2025

Sanctifi Health — Notice of Privacy Practices and HIPAA Acknowledgment

Effective Date: March 1, 2025

Introduction

This Notice of Privacy Practices ("Notice") describes how Sanctifi Health PC, Sanctifi Health PA, and any affiliated professional associations ("Sanctifi Health," "we," "us," or "our") may use and disclose your protected health information (PHI) to carry out treatment, payment, or healthcare operations, and for other purposes permitted or required by law. It also describes your rights to access and control your protected health information.

"Protected Health Information" or "PHI" is information about you, including demographic information, that may identify you and that relates to your past, present, or future physical or mental health or condition and related healthcare services.

1. Our Obligations

We are required by law to:

  • Maintain the privacy of protected health information
  • Give you this Notice of our legal duties and privacy practices regarding your health information
  • Follow the terms of our Notice that is currently in effect
  • Notify you following a breach of unsecured protected health information

2. How We May Use and Disclose Your Protected Health Information

2.1 For Treatment

We may use and disclose your protected health information to provide, coordinate, or manage your healthcare and any related services. This includes coordination with a third party, consultation with other healthcare providers, or your referral to another provider for your care.

Example: We may disclose your protected health information to a pharmacy when we prescribe medication for you.

2.2 For Payment

We may use and disclose your protected health information to obtain payment for services we provide to you.

Example: We may need to give your health plan information about services you received so your health plan will pay us. As a cash-pay practice, this may occur less frequently, but may be necessary for insurance reimbursement you pursue directly.

2.3 For Healthcare Operations

We may use or disclose your protected health information to support the business activities of our practice. These activities include, but are not limited to, quality assessment, employee review, training of medical students, licensing, fundraising, and conducting or arranging for other business activities.

Example: We may use your health information to evaluate the performance of our staff in caring for you.

2.4 For Coordination with Wellness Platforms

We may use and disclose your protected health information to coordinate your care with approved third-party wellness platforms such as Geviti Inc. This coordination includes:

  • Sharing relevant medical information to enable wellness coaches to provide appropriate non-medical guidance
  • Coordinating overall wellness and medical care for improved health outcomes
  • Ensuring continuity of care between medical and wellness services
  • Enabling integrated care approaches while maintaining appropriate boundaries

You have the right to restrict or withdraw this information sharing at any time by providing written notice to our Privacy Officer. Withdrawing consent may limit our ability to coordinate your care effectively.

Example: We may share your laboratory results or treatment recommendations with your wellness coach at Geviti to help them provide appropriate lifestyle guidance that complements your medical treatment.

2.5 Appointment Reminders, Treatment Alternatives, and Health-Related Benefits and Services

We may use and disclose your PHI to contact you to remind you of appointments or to inform you about treatment alternatives or health-related benefits and services that may be of interest to you.

3. Special Situations

3.1 As Required by Law

We will disclose your protected health information when required to do so by federal, state, or local law.

3.2 Public Health Activities

We may disclose your protected health information for public health activities, including:

  • Preventing or controlling disease, injury, or disability
  • Reporting births and deaths
  • Reporting child abuse or neglect
  • Reporting reactions to medications or problems with products
  • Notifying people of recalls of products they may be using
  • Notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition

3.3 Health Oversight Activities

We may disclose your protected health information to a health oversight agency for activities authorized by law, such as audits, investigations, inspections, and licensure.

3.4 Lawsuits and Disputes

If you are involved in a lawsuit or dispute, we may disclose your protected health information in response to a court or administrative order. We may also disclose your protected health information in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

3.5 Law Enforcement

We may release your protected health information if asked by a law enforcement official:

  • In response to a court order, subpoena, warrant, summons, or similar process
  • To identify or locate a suspect, fugitive, material witness, or missing person
  • About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement
  • About a death we believe may be the result of criminal conduct
  • About criminal conduct on our premises
  • 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

3.6 National Security and Intelligence Activities

We may release your protected health information to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

3.7 Protective Services for the President and Others

We may disclose your protected health information to authorized federal officials so they may provide protection to the President, other authorized persons, or foreign heads of state, or conduct special investigations.

3.8 Inmates or Individuals in Custody

If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release your protected health information to the correctional institution or law enforcement official.

4. Uses and Disclosures That Require Us to Give You an Opportunity to Object

4.1 Family and Friends

We may disclose your protected health information to a family member, relative, close friend, or any other person you identify, if the information is relevant to that person's involvement in your care or payment for your care.

4.2 Disaster Relief

We may disclose your protected health information to disaster relief organizations 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 it is practical to do so.

5. Your Written Authorization Is Required for Other Uses and Disclosures

The following uses and disclosures of your protected health information will be made only with your written authorization:

  1. Uses and disclosures of protected health information for marketing purposes
  2. Disclosures that constitute a sale of your protected health information
  3. Most uses and disclosures of psychotherapy notes
  4. Disclosures to compounding pharmacies beyond what is necessary for treatment and payment
  5. Disclosures to wellness platforms beyond basic care coordination (detailed sharing requires separate authorization)
  6. Use of your information for research or quality improvement studies

Other uses and disclosures not covered by this Notice or the laws that apply to us will be made only with your written authorization. If you provide us with authorization to use or disclose your protected health information, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose your protected health information for the reasons covered by your written authorization. However, we are unable to take back any disclosures we have already made with your permission.

6. Telehealth-Specific Privacy Considerations

6.1 Electronic Communications

Our telehealth services involve electronic communication of your personal medical information. While we implement security measures, no electronic transmission system is entirely secure, and there is a risk that your information could be accessed by unauthorized persons.

6.2 Recording and Storage

Telehealth consultations may be recorded and stored electronically as part of your medical record. We maintain reasonable and appropriate technical, administrative, and physical safeguards to protect your information.

6.3 Third-Party Applications

Our telehealth services may utilize third-party applications which have their own privacy policies. While we select these vendors carefully, we cannot guarantee their security measures.

7. Compounding Pharmacy Privacy Considerations

7.1 Third-Party Pharmacy Relationships

When we prescribe compounded medications, we may share your protected health information with independent compounding pharmacies. These pharmacies:

  • Operate independently from Sanctifi Health with their own privacy policies
  • Require certain health information to safely compound and dispense medications
  • May contact you directly regarding prescriptions, delivery, and payment
  • Maintain their own records of your prescription and payment information

7.2 Information Shared with Pharmacies

Information shared may include:

  • Prescription details and medical necessity
  • Contact information for delivery and communication
  • Relevant medical history necessary for safe compounding
  • Insurance information if applicable for your reimbursement

7.3 Your Rights Regarding Pharmacy Disclosures

  • You may request restrictions on information shared with pharmacies beyond what is required for treatment.
  • You may request to use different pharmacies if you have privacy concerns.
  • You should review the privacy policies of compounding pharmacies directly.

8. Your Rights Regarding Your Protected Health Information

8.1 Right to Inspect and Copy

You have the right to inspect and obtain a copy of your protected health information that may be used to make decisions about your care or payment for your care. This includes medical and billing records, other than psychotherapy notes. To inspect and copy your protected health information, you must submit your request in writing to our Privacy Officer. We have up to 30 days to make your protected health information available to you, and we may charge a reasonable fee for the costs of copying, mailing, or other supplies associated with your request. We may deny your request in certain limited circumstances. If we 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.

8.2 Right to an Electronic Copy of Electronic Medical Records

If your protected health information is maintained in an electronic format, 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 protected health information in the form or format you request if it is readily producible in such form or format. If it 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.

8.3 Right to Amend

If you feel that the protected health information 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 practice. To request an amendment, you must submit your request in writing to our Privacy Officer. You must provide a reason that supports your request for amendment. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:

  • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment
  • Is not part of the health information kept by or for our practice
  • Is not part of the information which you would be permitted to inspect and copy
  • Is accurate and complete

8.4 Right to an Accounting of Disclosures

You have the right to request a list of certain disclosures we made of your protected health information for purposes other than treatment, payment, healthcare operations, or for which you provided written authorization. To request an accounting of disclosures, you must submit your request in writing to our Privacy Officer. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (e.g., paper or electronic). The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved, and you may choose to withdraw or modify your request at that time before any costs are incurred.

8.5 Right to Request Restrictions

You have the right to request a restriction or limitation on the protected health information we use or disclose for treatment, payment, or healthcare operations. You also have the right to request a limit on the protected health information 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. To request a restriction, you must submit your request in writing to our Privacy Officer. We are not required to agree to your request unless you are asking us to restrict the use and disclosure of your protected health information to a health plan for payment or healthcare operation purposes and such information you wish to restrict pertains solely to a healthcare 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.

8.6 Out-of-Pocket Payments

If you paid out-of-pocket (or in other words, you have requested that we not bill your health plan) in full for a specific item or service, you have the right to ask that your protected health information with respect to that item or service not be disclosed to a health plan for purposes of payment or healthcare operations, and we will honor that request.

8.7 Right to Request Confidential Communications

You have the right to request that we communicate with you about medical 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. To request confidential communications, you must submit your request in writing to our Privacy Officer. Your request must specify how or where you wish to be contacted. We will accommodate reasonable requests.

9. Contact Information

For questions about this Notice or to exercise your privacy rights, contact our Privacy Officer:

  • Address Letter To: Privacy Officer
  • Email: privacy@sanctifi.health
  • Mailing Address:
    Sanctifi Health Privacy Officer
    2162 E Williams Field Rd Unit 111
    Gilbert, AZ 85296

10. Changes to This Notice

We reserve the right to change this Notice and make the new Notice apply to protected health information we already have as well as any information we receive in the future. We will post a copy of our current Notice at our office and on our website. The Notice will contain the effective date on the first page.

11. Complaints

If you believe your privacy rights have been violated, you may file a complaint with our office or with the Secretary of the Department of Health and Human Services. To file a complaint with our office, contact our Privacy Officer. All complaints must be made in writing. You will not be penalized for filing a complaint.

12. Electronic Acknowledgment of Receipt of Notice of Privacy Practices

By checking the "I Acknowledge Receipt" box, clicking "Accept," or otherwise indicating your acceptance electronically:

  1. You acknowledge that you have been provided with a copy of Sanctifi Health's Notice of Privacy Practices.
  2. You understand that Sanctifi Health reserves the right to change its privacy practices and to issue a revised Notice of Privacy Practices.
  3. You understand that by engaging with Sanctifi Health, whether directly through our website or application, or through any third-party platform through which Sanctifi Health provides services, you acknowledge receipt of this Notice of Privacy Practices.
  4. You understand that you may request a copy of this Notice for your records at any time by contacting Sanctifi Health.
  5. You consent to the coordination of care with approved wellness platforms as described in this Notice, with the understanding that you may withdraw this consent at any time.

Your electronic acknowledgment is legally binding and equivalent to a handwritten signature.