Health Information Privacy Policy

Effective Date: December 31, 2025

This Health Information Privacy Policy (the "Notice") describes how our affiliated medical practice ("Pascal Medical", "we", and "our"), operating with non-clinical support from Pascal (dba Roundtable Diagnostics, LLC) (collectively, "Pascal"), may use and disclose your protected health information to carry out treatment, payment, or health care operations and for other purposes that are permitted or required by applicable law.

We understand that information about you and your health is personal. We will abide by applicable state and federal privacy laws with respect to your health information and maintain your health information as set forth in this Notice.

Please review this Notice carefully. Capitalized terms not defined herein shall have the respective meanings given to them in the Terms of Service.

What Health Information Do We Collect and Maintain?

The health information that we collect or maintain may include:

• Your name, age, phone number, date of birth, email address, username, password, and other registration information.
• Health information that you provide us, which may include information or records relating to your medical or health history, health status and laboratory testing results, photos, diagnostic images, and other health related information.
• Health information about you prepared or obtained by the clinical professionals and support staff who provide clinical services through Pascal Medical such as medical records, treatment notes, and other health related information.
• Billing information that you provide us, such as credit card information.

How Do We Use and Disclose Health Information?

We use and disclose your health information for the normal business activities falling in the categories of treatment, payment, and healthcare operations. Generally, we do not need your permission for these disclosures under applicable laws. Below we provide examples of those activities:

• Treatment – We keep a record of the health information you provide us. This record may include your test results, diagnoses, medications, your response to medications or other therapies, and information we learn about your medical condition through our services. We may disclose this information so that other doctors, nurses, and entities such as laboratories can meet your healthcare needs.
• Payment – We document the services and supplies you receive when we are providing care to you so that you or another third party can pay us.
• Health Care Operations – Health information is used by Pascal Medical and Pascal operating on behalf of Pascal Medical to improve the services we provide, to train staff, for business management, quality assessment and improvement, and for customer service.

We may also use and disclose your health information to:

• Provide the services and customer support
• Comply with federal, state, or local laws and regulations
• Assist in public health activities such as tracking diseases
• Inform authorities to protect suspected victims of abuse or neglect
• Comply with federal and state health oversight activities such as fraud investigations
• Respond to law enforcement officials or to judicial orders, subpoenas, or other processes
• Avert a serious threat to health or safety
• Recommend treatment alternatives
• Tell you about health-related products and services
• Enforce compliance with our agreements and policies
• Communicate within our organization for treatment, payment, or healthcare operations
• Communicate with other providers, health plans, or their related entities for their treatment or payment activities
• For business analytics purposes

All other uses and disclosures, not previously described, may only be done with your written authorization. We will also obtain your authorization before we use or disclose your health information for marketing purposes or before we would sell your information. You may revoke your authorization at any time; however, this will not affect prior uses and disclosures.

How Will Health Information Be Communicated?

We use standard physical, electronic, and business security methods to help prevent access to your health information by people who should not see it. But we cannot promise that data sent over the Internet or through a data storage facility will be secure. So, although we try to protect your personal information, we cannot guarantee the security of any information you send to us.

As part of providing services, our Care Team will primarily communicate with you, including for clinical, clinical triage, and treatment purposes, via the Spruce Health mobile application. By using the Services and providing us your contact information, you permit us to communicate with you through these channels.

Telehealth Communication Consent

By using our Services, you acknowledge and consent to the following regarding our telehealth communication practices:

Text-Based Service Acknowledgment

You understand that our Services are provided primarily through text-based (asynchronous) communication. This means clinical assessments and recommendations are made based on information you provide via text, without the benefit of a physical examination.

Limitations of Text-Based Diagnosis

Audio/Video Consultation

In certain circumstances, our providers may determine that a video or audio consultation is clinically necessary for proper assessment. You agree to participate in such consultations when requested by your Care Team.

Not for Emergencies

Our text-based Services are not designed for medical emergencies. If you are experiencing a medical emergency, call 911 or go to your nearest emergency room immediately. Please refer to the "Conditions NOT Appropriate for Text-Based Care" section in our Terms of Service for a complete list.

Right to In-Person Care

You have the right to request a referral for in-person care at any time. If our providers determine that your condition requires in-person evaluation or treatment, we will provide appropriate referral recommendations.

What Are Pascal Medical's Responsibilities?

Pascal Medical will:

• Maintain the privacy of your health information
• Provide this Notice of our duties and privacy practices
• Abide by the terms of the Notice currently in effect
• Tell you if there has been a breach that compromises your health information

We reserve the right to change our privacy practices and make the new practices effective for all the information we maintain. Revised notices will be posted on the Site.

Your Rights

By contacting us at pascal@textpascal.com, you may:

• Inspect and copy certain portions of your health information. We may deny your request under limited circumstances. You may request that we provide your health records to you in an electronic format.
• Request amendment of your health information if you feel the health information is incorrect or incomplete. However, under certain circumstances we may deny your request.
• Receive an accounting of certain disclosures of your health information made for the prior six (6) years, excluding certain disclosures for treatment, payment, and health care operations.
• Request that we restrict how we use or disclose your health information. However, we are not required to agree with your requests.
• Request that we communicate with you at a specific telephone number or address.
• Obtain a paper copy of this notice even if you receive it electronically.

We may ask that you make some of these requests in writing.

What If I Have a Complaint?

If you believe that your privacy has been violated, you may file a complaint with us or with the Secretary of Health and Human Services in Washington, D.C. We will not retaliate or penalize you for filing a complaint with us or the Secretary.

To file a complaint with us or receive more information, contact:

Email: pascal@textpascal.com

To file a complaint with the Secretary of Health and Human Services, write to 200 Independence Ave., S.E., Washington, D.C. 20201, call 1-800-537-7697, or file an online complaint at https://ocrportal.hhs.gov/ocr/smartscreen/main.jsf.

Who Will Follow This Notice?

This Notice describes the health care practices of:

• Any healthcare professional or member of the Care Team authorized to access and/or enter information into your health record through Pascal
• All departments and units of Pascal through which telehealth services are provided or have access to your health information
• All affiliates and volunteers who have access to your health information