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Privacy Policy

Your Information. Your Rights. Our Responsibilities.

Effective Date: October 8, 2026

This Notice of Privacy Practices describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Our Pledge Regarding Your Health Information

We understand that information about you and your health is personal. Spiras Health, Inc. (“Spiras,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your health information.

We create and maintain records about the care and services you receive. We use these records to provide you with quality care, coordinate your care and services, obtain payment, operate our organization, improve our services, and comply with applicable legal requirements.

This Notice of Privacy Practices (“Notice”) describes how we may use and disclose your protected health information (“PHI”), your rights regarding your PHI, and certain responsibilities we have regarding the use and disclosure of PHI.

This Notice applies to Spiras Health, Inc. and to our workforce members and individuals and organizations that provide services on our behalf to the extent they are required to follow our privacy practices.

Our Responsibilities

We are required by law to:

Your Rights

When it comes to your health information, you have certain rights.

Get an Electronic or Paper Copy of Your Medical Record

You can ask to inspect or obtain an electronic or paper copy of your medical record and other health information we maintain about you, subject to applicable law.

To request access, contact our Privacy & Compliance Officer using the information at the end of this Notice.

We will process your request within the time required by applicable federal and state law.

We may charge fees only to the extent permitted by applicable law.

Ask Us to Correct Your Medical Record

You can ask us to correct health information about you that you believe is incorrect or incomplete.

Your request must be made in writing and should explain why you believe the information is incorrect or incomplete.

We may deny your request in certain circumstances permitted by law. If we deny your request, we will provide you with a written explanation.

Request Confidential Communications

You can ask us to contact you in a specific way or at a specific location.

For example, you can ask us to contact you at a particular telephone number, by mail at a particular address, or through another reasonable method.

We will accommodate reasonable requests. You do not have to tell us why you are making the request.

Ask Us to Limit What We Use or Share

You can ask us not to use or disclose certain health information for treatment, payment, or health care operations.

We are not required to agree to every request.

If you pay out-of-pocket in full for a health care item or service, you can ask us not to disclose information concerning that item or service to your health plan for payment or health care operations purposes. We will agree to such a request unless disclosure is required by law.

Get a List of Those With Whom We Have Shared Information

You can ask for an accounting of certain disclosures of your PHI made during the six years before the date of your request, subject to applicable law and its exclusions.

The accounting generally will not include disclosures for treatment, payment, or health care operations, certain other disclosures, or disclosures excluded by law.

We will provide one accounting in a 12-month period without charge. We may charge a reasonable, cost-based fee for additional requests as permitted by law.

Get a Copy of This Notice

You may request a paper copy of this Notice at any time, even if you have agreed to receive it electronically.

The current version of this Notice will also be available on our website.

Choose Someone to Act for You

If you have given someone medical power of attorney or if someone is your legal guardian or otherwise legally authorized to act on your behalf, that person may exercise your rights and make choices about your health information to the extent permitted by law.

We will verify the person’s authority before taking action.

File a Complaint

If you believe your privacy rights have been violated, you may file a complaint with us or with the U.S. Department of Health and Human Services Office for Civil Rights.

You will not be retaliated against for filing a complaint.

Your Choices

For certain health information, you may tell us your preferences about what we share.

Individuals Involved in Your Care or Payment

You may tell us whether we may share information with a family member, close friend, or another person involved in your care or payment for your care.

Disaster Relief

We may disclose information to organizations involved in disaster-relief efforts so that your family or other persons responsible for your care can be notified about your condition, location, or status, as permitted by law.

If you are unable to tell us your preference, such as during an emergency, we may use our professional judgment to determine whether a disclosure is in your best interest.

Marketing

Most uses and disclosures of PHI for marketing purposes require your written authorization, subject to limited exceptions provided by law.

We will not use or disclose your PHI for marketing when your authorization is required unless we have obtained that authorization.

Sale of Your Health Information

A sale of PHI generally requires your written authorization when required by law.

We will obtain authorization when required before receiving remuneration in connection with a sale of your PHI.

How We May Use and Disclose Your Health Information

The following describes common circumstances in which we may use or disclose PHI.

Treat You

We may use and disclose PHI to provide, coordinate, or manage your health care and related services.

For example, we may share information with physicians, nurses, clinicians, care coordinators, other members of your care team, or other health care professionals involved in your care.

Run Our Organization

We may use and disclose PHI for health care operations, including activities necessary to operate Spiras, improve the quality and safety of our services, evaluate the performance of our workforce, conduct quality assessment and improvement activities, manage our services, conduct compliance and auditing activities, and coordinate care.

Bill for Your Services

We may use and disclose PHI to bill for services and obtain payment from health plans or other entities.

For example, we may provide information to your health plan so it can determine eligibility or coverage, process a claim, or make payment for services.

Business Associates

We may provide PHI to companies and individuals that perform services on our behalf.

These may include organizations that provide billing, information technology, legal, accounting, auditing, quality assurance, administrative, or other services.

When required by law, we require our business associates to enter into agreements requiring them to appropriately safeguard PHI and use or disclose it only as permitted by law.

Public Health Activities

We may disclose PHI for public health activities as permitted or required by law, including to:

Health Oversight Activities

We may disclose PHI to health oversight agencies for activities authorized by law, including audits, investigations, inspections, licensure activities, and other activities necessary to oversee the health care system and government programs.

Required by Law

We may use or disclose PHI when federal, state, or local law requires us to do so.

We may also disclose PHI to the U.S. Department of Health and Human Services when necessary for purposes of determining our compliance with federal privacy requirements.

To Avert a Serious Threat to Health or Safety

We may use or disclose PHI when necessary to prevent or lessen a serious and imminent threat to the health or safety of you, another person, or the public, as permitted by law.

Workers’ Compensation

We may disclose PHI for workers’ compensation or similar programs as authorized by law.

Lawsuits and Legal Proceedings

We may disclose PHI in response to a court or administrative order and, in certain circumstances, in response to a subpoena, discovery request, or other lawful process, subject to applicable legal requirements.

Law Enforcement

We may disclose PHI to law enforcement officials when permitted or required by law, including in response to certain legal processes and in other circumstances authorized by HIPAA and applicable state law.

Research

We may use or disclose PHI for research purposes when permitted by applicable law, including when appropriate approvals, authorizations, waivers, or other legal requirements have been satisfied.

Coroners and Medical Examiners

We may disclose PHI to coroners or medical examiners as permitted by law, including to identify a deceased person or determine the cause of death.

Organ and Tissue Donation

We may use or disclose PHI for organ, eye, or tissue donation and transplantation purposes as permitted by law.

Special Government Functions

We may disclose PHI for certain special government functions as authorized by law, including authorized military, national security, intelligence, and protective-services activities.

State Privacy Laws

Spiras provides health care services in Tennessee, Kentucky, and Maryland.

Certain state laws may provide additional privacy protections or rights concerning your health information. Spiras will comply with applicable federal and state privacy laws.

Where applicable law provides greater privacy protection or greater rights than federal law, we will comply with the applicable requirements.

Other Uses and Disclosures Requiring Your Authorization

Other uses and disclosures of PHI not described in this Notice or otherwise permitted or required by law will be made only with your written authorization when authorization is required.

If you provide an authorization, you may revoke it in writing at any time to the extent permitted by law.

Revocation will not affect uses or disclosures that we have already made based on the authorization or actions that we have already taken in reliance on the authorization.

Breach Notification

We will notify you as required by law if a breach occurs involving your unsecured PHI.

We will provide notification without unreasonable delay and, where HIPAA applies, no later than 60 calendar days after discovery of the breach.

Changes to This Notice

We reserve the right to change the terms of this Notice.

Any revised Notice will apply to all PHI we maintain, subject to applicable law.

When we make a material change to our privacy practices, we will make the revised Notice available as required by law, including on our website and upon request.

The revised Notice will include its effective date.

Effective Date

This Notice is effective as of October 8, 2026.

How to Contact Us

For questions about this Notice, to exercise your privacy rights, to request a copy of this Notice, or to file a privacy complaint, contact:

Privacy & Compliance Officer

Spiras Health, Inc.
111 Westwood Place, Suite 100
Brentwood, Tennessee 37027
Phone: (629) 204-5840
Email: privacy@spirashealth.com
Website: www.spirashealth.com

You may contact us regarding:

Complaints to the U.S. Department of Health and Human Services

You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, if you believe your privacy rights have been violated.

U.S. Department of Health and Human Services
Office for Civil Rights
200 Independence Avenue, S.W.
Washington, D.C. 20201
Phone: 1-877-696-6775

You may obtain additional information about filing an OCR complaint through the HHS Office for Civil Rights website.

We will not retaliate against you for filing a complaint.

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