Legal & Privacy

Our commitment to transparency and your rights

Our Terms

Effective Date: June 9, 2025

Updated: June 9, 2025

Terms of Use

Please read these Terms of Use ("Terms") carefully before using www.careway.health (the "Site") or any related software, applications, services and/ or products provided in connection with the Site (the "Service"), including without limitation your use of the Platform to obtain services as a "Client" and / or your use of the Platform to perform services as an "Advocate". By using and participating in the Site, you signify that you have read these terms and agree to be bound by and comply with them. If you do not agree to be bound by these terms, please promptly exit all sites. Careway Health, Inc. in association with Careway Health Medical PA and Careway Health Medical West PC, a California Professional Medical Corporation operating under Fictitious Name Permit #559805 issued by the Medical Board of California ("Careway Health", "us," "we," "our," or the "Company") reserves the right to modify these terms at any time and will publish notice of any such modifications online at this site or elsewhere online. By continuing to access a site after notice of such modifications has been published, you signify your agreement to be bound by them. You agree that by using the service you represent that you are at least 18 years old and that you are legally able to enter into this agreement.

Privacy Policy

Careway Health respects your privacy and permits you to control the treatment of your personal information. A complete statement of Careway Health's current privacy policy can be found on our website at www.careway.health/privacy. Careway Health's privacy policy is expressly incorporated into this Agreement by this reference.

Account Registration and Security

When you are required to open an account to use or access the Site or Service, you must complete the registration process by providing complete and accurate information requested on the registration form. You will also be asked to provide a user name and password. You are entirely responsible for maintaining the confidentiality of your password. You may not use the account, username, or password of someone else at any time. You agree to notify Careway Health immediately on any unauthorized use of your account, user name, or password. Careway Health shall not be liable for any loss that you incur as a result of someone else using your password, either with or without your knowledge. You may be held liable for any losses incurred by Careway Health, its affiliates, officers, directors, employees, consultants, agents, and representatives due to someone else's use of your account or password.

Use of Software and User Content

By posting, downloading, displaying, performing, transmitting, or otherwise distributing information or other content ("User Content") to the Site or Service, you are granting Careway Health, its affiliates, officers, directors, employees, consultants, agents, and representatives a license to use User Content in connection with the operation of the Internet business of Careway Health. This includes without limitation, a right to copy, distribute, transmit, publicly display, publicly perform, reproduce, edit, translate, and reformat User Content. You will not be compensated for any User Content. You agree that Careway Health may publish or otherwise disclose your name in connection with your User Content. By posting User Content on the Site or Service, you warrant and represent that you own the rights to the User Content or are otherwise authorized to post, distribute, display, perform, transmit, or otherwise distribute User Content.

Software License

Careway Health may make certain software available to you from the Site. If you download software from the Site, the software, including all files and images contained in or generated by the software, and accompanying data (collectively, "Software") are deemed to be licensed to you by Careway Health , for your personal, noncommercial, home use only. Careway Health does not transfer either the title or the intellectual property rights to the Software, and Careway Health retains full and complete title to the Software as well as all intellectual property rights therein. You may not sell, redistribute, or reproduce the Software, nor may you decompile, reverse-engineer, disassemble, or otherwise convert the Software to a human-perceivable form.

Platform is a Venue

The Platform offers a venue where Users connect for the performance of services (each, a "Engagement"). By using the Platform, you understand and agree that no joint venture, partnership, employment, franchise or agency relationship exists between you and Careway Health or Careway Health and any other User. Further, any information, materials and/or Content available on or through the Platform, whether by Careway Health, Users or third parties, is for informational purposes only and does not constitute medical or professional advice, nor is it intended to constitute medical or professional advice, and is in no way intended to create a provider-patient relationship as defined by state or federal law.

Careway Health makes no representation and assumes no responsibility for the accuracy of information or content contained on or available through the Platform, and such information and content is subject to change without notice. If you have specific concerns or a situation arises requiring medical or professional advice, you should consult with an appropriately trained and qualified professional. NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY SEEKING MEDICAL TREATMENT BECAUSE OF SOMETHING YOU HAVE READ ON OR ACCESSED THROUGH THE PLATFORM. Careway Health does not endorse or make any representation about the efficacy, appropriateness or suitability of any specific tests, practices, products, procedures, treatments, opinions, health care providers or other information that may be contained on or available through the Platform. Your interactions with a Careway Health physician is not intended to replace your relationship with your regular health care practitioners or primary care physician. CAREWAY HEALTH IS NOT RESPONSIBLE NOR LIABLE FOR ANY ADVICE, COURSE OF TREATMENT, DIAGNOSIS OR ANY OTHER THIRD-PARTY INFORMATION, SERVICE OR PRODUCTS THAT YOU OBTAIN THROUGH THE PLATFORM. CAREWAY HEALTH HEREBY EXPRESSLY DISCLAIMS, AND YOU HEREBY EXPRESSLY RELEASE CAREWAY HEALTH FROM, ANY AND ALL DISPUTES ARISING FROM AND/OR IN ANY WAY RELATED TO THE INFORMATION, MATERIALS AND/OR CONTENT PROVIDED ON OR THROUGH THE PLATFORM.

Independent Contractors

Careway Health is not an employment service or employment agency, and Careway Health does not employ Advocates. In all cases, Advocates are independent contractors and not employees of Careway Health. That means Advocates are free to accept or reject any engagements with Clients ("Engagements"), perform services free from supervision or control of Careway Health, and provide their own tools and equipment. All contracts, agreements and arrangements for Engagements are between Clients and Advocates. As such, Careway Health does not withhold taxes including, without limitation, unemployment insurance, workers' compensation, employer's liability, social security or other payroll withholdings. You understand and agree that if Careway Health is found liable for any taxes, other than on Careway Health's income, you will immediately reimburse and pay to Careway Health an equivalent amount, including any interest or penalties thereon.

Connecting Users; No Control

The Platform leverages a proprietary algorithm to connect Users for Engagements based on numerous factors including, without limitation, Client criteria and location, and Advocate experience, specialty and location. Notwithstanding the foregoing, Careway Health does not have control over any aspect of any Engagements including, without limitation, the legality, timing, quality, performance or non-performance thereof. Further, Careway Health does not supervise or control any aspect of any Engagements, and Clients are responsible for supervising and controlling the services performed by Advocates. As such, Careway Health makes no representations, warranties or covenants about any aspect of any Engagements or services performed.

Payment

Advocates are paid for Engagements solely through third-party payors. Advocates do not receive out-of-pocket payments from Clients through the Platform.

Your Responsibilities

(A) Use the Platform solely for its intended, authorized purposes, interacting truthfully, respectfully, and professionally, and ensure all information provided in your profile or any Engagement posting is accurate, current, and free of personal or confidential details you do not intend others to access or view;

(B) Bear exclusive responsibility for all interactions you have with other Users, whether online or offline;

(C) Comply fully with all applicable laws, regulations, and rules, including without limitation those related to privacy, intellectual property, export control, taxation, and other relevant regulatory obligations, and strictly adhere to any notices provided by us concerning the Platform and our operation thereof; and

(D) Refrain from soliciting or encouraging Users to transact outside the Platform or engaging in transactions with Users off the Platform.

Prohibited Uses

Account Misuse

Create or maintain a user account for anyone other than yourself, or use another individual's account.

Misrepresentation and Unauthorized Affiliation

  • Imply affiliation or endorsement by Careway Health, directly or indirectly.
  • Post, upload, email, or initiate content through the Platform that misrepresents your identity, qualifications, affiliations, or positions.

Inappropriate or Unprofessional Behavior

  • Engage in dishonest or unprofessional conduct, including transmitting inappropriate, inaccurate, or objectionable material through the Platform.
  • Engage in harassing, abusive, or harmful behavior toward others, including sending unwanted communications.
  • Post, upload, email, or initiate content that is illegal, libelous, abusive, obscene, discriminatory, or inappropriate.

Unauthorized Use of Content

  • Copy, license, sublicense, publish, broadcast, transmit, distribute, sell, rent, lease, lend, rebrand, exchange, resell, adapt, modify, or create derivative works from Platform content or information, excluding your own content.
  • Use Platform Content to provide services competitive to ours, as solely determined by us.
  • Participate in or operate a pyramid scheme or similar practices.

Unauthorized Access and Competitive Monitoring

  • Access or attempt to access the Platform through unauthorized methods, repeatedly monitor its availability, performance, or functionality manually or automatically for competitive purposes, or use tools to scrape, crawl, spider, harvest, or extract information from the Platform.
  • Engage in framing, mirroring, or otherwise replicating the Platform's appearance or function.

Privacy and Confidentiality Violations

  • Include, collect, utilize, distribute, or disclose confidential, sensitive personal, or personally identifiable information unless explicitly permitted by designated fields, the Terms of Use, or expressly authorized by the data owner.
  • Post, upload, email, or initiate content containing information you are not authorized to disclose due to contractual, fiduciary, or legal restrictions.

Security and Platform Disruption

Attempt to disable, bypass, probe, scan, test, interfere with, or disrupt any security measures, vulnerabilities, components, servers, networks, or proper operation of the Platform, including sending unsolicited communications, forging TCP/IP packet headers or other identifiers, attempting unauthorized access, or transmitting computer viruses or harmful code.

Brand and Intellectual Property Violations

  • Remove, obscure, alter, or infringe upon copyright, trademark, proprietary notices, or branding, including using our brand, logos, or trademarks.
  • Post, upload, email, or initiate content that infringes patents, trademarks, trade secrets, copyrights, or other proprietary rights.

Misuse of Communication Tools

  • Post, upload, email, or initiate content that constitutes unsolicited or unauthorized advertising, spam, chain letters, pyramid schemes, or messages sent to people or groups who do not know you or have not explicitly authorized such communications.
  • Post, upload, email, or initiate content that forges headers or disguises the origin of communications.

Suspension and Termination

Careway Health may suspend or remove you from the Platform at any time for any or no reason at all, and suspension or removal will be effective immediately upon delivery of such notice. If Careway Health suspends or removes you from the Platform, you may not be entitled to rejoin. In addition to suspension or removal, Careway Health reserves the right to take appropriate legal action including, without limitation, pursuing civil, criminal, and injunctive relief. Even after your suspension or removal, the Terms of Use will remain enforceable against you.

Intellectual Property

When accessing the Site or using the Service, you agree to obey the law and to respect the intellectual property rights of others. Your use of the Service and the Site is at all times governed by and subject to laws regarding copyright ownership and use of intellectual property. You agree not to upload, download, display, perform, transmit, or otherwise distribute any information or content (collectively, "Content") in violation of any third party's copyrights, trademarks, or other intellectual property or proprietary rights. You agree to abide by laws regarding copyright ownership and use of intellectual property, and you shall be solely responsible for any violations of any relevant laws and for any infringements of third party rights caused by any Content you provide or transmit, or that is provided or transmitted using your User ID.

Copyright Infringement

Careway Health has in place certain legally mandated procedures regarding allegations of copyright infringement occurring on the Site or with the Service. Careway Health has adopted a policy that provides for the immediate suspension and/or termination of any Site or Service user who is found to have infringed on the rights of Careway Health or of a third party, or otherwise violated any intellectual property laws or regulations.

To report copyright infringement, please provide the following information: (a) A physical or electronic signature of a person authorized to act on behalf of the owner of the exclusive right that is allegedly infringed (b) Identification of the copyrighted work claimed to have been infringed (c) Identification of the material that is claimed to be infringed (d) Contact information for the complaining party (e) A statement that you have a good faith belief that use of the material is not authorized (f) A statement that the information in the notification is accurate and that you are authorized to act on behalf of the owner

You may email any notifications to help@careway.health

No Warranties

CAREWAY HEALTH HEREBY DISCLAIMS ALL WARRANTIES. CAREWAY HEALTH IS MAKING THE SITE AVAILABLE "AS IS" WITHOUT WARRANTY OF ANY KIND. YOU ASSUME THE RISK OF ANY AND ALL DAMAGE OR LOSS FROM USE OF, OR INABILITY TO USE, THE SITE OR THE SERVICE. TO THE MAXIMUM EXTENT PERMITTED BY LAW, CAREWAY HEALTH EXPRESSLY DISCLAIMS ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED, REGARDING THE SITE, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NONINFRINGEMENT.

Release

TO THE EXTENT PERMITTED BY LAW, CAREWAY HEALTH HEREBY EXPRESSLY DISCLAIMS, AND YOU HEREBY EXPRESSLY RELEASE CAREWAY HEALTH FROM, ANY AND ALL DISPUTES FOR DAMAGES, INJURIES, LOSSES AND LIABILITIES ASSOCIATED WITH THE FOLLOWING: (A) CAREWAY HEALTH'S NEGLIGENCE, GROSS NEGLIGENCE AND WILLFUL ACTIONS AND INACTIONS; (B) THAT USE OF THE PLATFORM WILL BE UNINTERRUPTED, SECURE, TIMELY OR ERROR-FREE; (C) THAT ANY SERVICES OBTAINED THROUGH THE PLATFORM WILL BE RELIABLE, ACCURATE, SAFE, TIMELY, ERROR-FREE OR COMPLETE; (D) THE INACCURACY, UNTIMELINESS OR INCOMPLETENESS OF ANY CONTENT INCLUDING, WITHOUT LIMITATION, ANY RELIANCE UPON SUCH CONTENT; (E) ANY MISSTATEMENTS OR MISREPRESENTATIONS; (F) THIRD-PARTY WEBSITES INCLUDING, WITHOUT LIMITATION, RELATED TO AVAILABILITY, TERMS OF USE, PRIVACY PRACTICES, INFORMATION, CONTENT, MATERIALS, ADVERTISING, CHARGES, PAYMENT, PRODUCTS AND/OR SERVICES; (G) THE CONDUCT OF ANY USER ONLINE OR OFFLINE INCLUDING, WITHOUT LIMITATION, DEFAMATION, HARASSMENT, STALKING, PHYSICAL INJURY, ABUSE OR VIOLENCE, AND DAMAGE TO OR DESTRUCTION OF PROPERTY; (G) THE CONDUCT OF THIRD PARTIES INCLUDING, WITHOUT LIMITATION, HACKERS OR OTHERS WHO ENGAGE IN THE UNAUTHORIZED ACCESS, USE OR MISAPPROPRIATION OF ANY CONTENT; AND (H) ANY CONTENT THAT MAY BE MISAPPROPRIATED, INTERCEPTED, DELETED, DESTROYED OR USED BY OTHERS.

Limited Liability

CARWAY HEALTH'S LIABILITY TO YOU IS LIMITED. TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT SHALL CAREWAY HEALTH BE LIABLE FOR DAMAGES OF ANY KIND (INCLUDING, BUT NOT LIMITED TO, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, LOST PROFITS, OR LOST DATA, REGARDLESS OF THE FORESEEABILITY OF THOSE DAMAGES) ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE SITE OR ANY OTHER MATERIALS OR SERVICES PROVIDED TO YOU BY CAREWAY HEALTH. NOTWITHSTANDING ANYTHING ANYWHERE TO THE CONTRARY INCLUDING, WITHOUT LIMITATION, IN THE TERMS OF USE, IF IT IS DETERMINED THAT CAREWAY HEALTH IS LIABLE TO YOU, IN NO EVENT WILL THE AGGREGATE LIABILITY, WHETHER ARISING IN CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, EXCEED FIVE-HUNDRED DOLLARS ($500).

Affiliated Sites

Careway Health has no control over, and no liability for any third party websites or materials. Careway Health works with a number of partners and affiliates whose Internet sites may be linked with the Site. Because neither Careway Health nor the Site has control over the content and performance of these partner and affiliate sites, Careway Health makes no guarantees about the accuracy, currency, content, or quality of the information provided by such sites, and assumes no responsibility for unintended, objectionable, inaccurate, misleading, or unlawful content that may reside on those sites.

Indemnity

You agree to indemnify, defend, and hold harmless Careway Health , its affiliates, officers, directors, employees, consultants, agents, and representatives from any and all third party claims, losses, liability, damages, and/or costs arising from your access to or use of the Site, your violation of these Terms of Use, or your infringement of any intellectual property or other right of any person or entity.

Governing Law

These Terms of Use shall be construed in accordance with and governed by the laws of the State of Delaware . You hereby irrevocably consent to the exclusive jurisdiction of the courts in Delaware in all disputes arising out of or related to the use of the Site or Service.

No Jury; Class Action Waiver

YOU HEREBY IRREVOCABLY WAIVE YOUR RIGHT TO TRIAL BY JURY IN ANY DISPUTE. YOU FURTHER AGREE TO WAIVE ANY RIGHT TO RESOLVE ANY DISPUTE AS A REPRESENTATIVE OR MEMBER IN ANY CLASS OR REPRESENTATIVE ACTION, EXCEPT WHERE SUCH WAIVER IS PROHIBITED BY LAW OR DEEMED BY A COURT OF LAW TO BE AGAINST PUBLIC POLICY. TO THE EXTENT YOU ARE PERMITTED BY LAW OR COURT OF LAW TO PROCEED WITH A CLASS OR REPRESENTATIVE ACTION, YOU AGREE THAT: (I) THE PREVAILING PARTY SHALL NOT BE ENTITLED TO RECOVER ATTORNEYS' FEES OR COSTS ASSOCIATED WITH PURSUING THE CLASS OR REPRESENTATIVE ACTION; AND (II) YOU WILL NOT SUBMIT A CLAIM OR OTHERWISE PARTICIPATE IN ANY RECOVERY SECURED THROUGH THE CLASS OR REPRESENTATIVE ACTION.

Waiver; Severability

Failure by Careway Health to enforce any provision(s) of the Terms of Use will not be construed as a waiver of any provision or right. The Terms of Use constitute the entire agreement between you and Careway Health. If any provision of the Terms of Use is found to be unlawful, void, invalid or unenforceable, such provision shall nonetheless be enforceable to the fullest extent permitted by applicable law, and the unenforceable portion shall be deemed to be severed from the Terms of Use, and the remaining provisions shall be enforced to the fullest extent possible. The Terms of Use will take effect to the benefit of Careway Health, its successors and assigns.

Privacy Policy

Effective Date: June 9, 2025

Updated: June 9, 2025

Privacy Policy

Careway Health, Inc. in association with Careway Health Medical PA and Careway Health Medical West PC ("Careway Health", "us," "we," "our," or the "Company") is committed to respecting the privacy rights of its customers, visitors, and other users of the Careway Health Website (the "Sites"). We created this Privacy Policy (this "Policy") to give you confidence as you visit and use the Sites, and to demonstrate our commitment to fair information practices and the protection of privacy. This Policy is only applicable to all information collected through our Careway Health websites and application sites and/or any related services, sales, marketing or events-related websites (we refer to them collectively in this privacy policy as the "Sites"), and not to any other websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this Policy.

Information Collection Practices

Personal Information We Collect

In operating the Site, we may include registration, online surveys, and other online forms that ask users to provide their names, e-mail addresses, contact information, passwords and security data, and payment information, as well as the following categories of information:

  • Demographics
  • Location
  • Device used

Additional Information We Collect

(a) Automatic Collection

Our servers automatically recognize some information such as visitors' domain names,IP addresses (the number assigned to computers on the Internet), and/or browser and device characteristics. No personal information about you is revealed in this process. The Site may also gather anonymous "traffic data" that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.

(b) Cookies

We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

(c) Other sources

We may collect limited data from public databases, marketing partners, and other outside sources. We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).

Use and Sharing of Information

What We Do With Collected Information

(a) Personal Information

We will not share your personal information with any third parties without your consent, except as necessary to provide you with the services offered by us or to comply with the law. We may use your personal information to:

  • Verify your identity
  • Check your qualifications
  • Follow up with transactions initiated on the Site
  • Inform you of any changes to the Site
  • Send you additional information about our company

If you give your permission during the account registration process, we may share your contact information with our business partners or other companies so that they may send you promotional materials.

(b) Anonymous Information

We use anonymous information to analyze our Site traffic, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.

(c) Use of Cookies

We may use cookies to:

  • Deliver content specific to your interests
  • Save your password so you don't have to re-enter it each time you visit our site
  • Other purposes as needed

Promotions or advertisements displayed on our site may contain cookies. We do not have access to or control over information collected by outside advertisers on our site.

(d) Disclosure of Personal Information

We may disclose personal information that you provide via this Site to the following third parties:

  • Our subsidiaries, affiliates, and joint venture partners
  • Contractors, vendors, and service providers we use to support our business and this Site
  • Third-party advertising companies to serve ads when you visit the Sites

We may disclose your personal information for any other purpose with your consent.

We may also disclose personal information that you provide via this Site in the event of:

  • A merger, acquisition, or any form of sale of some or all of our assets
  • Compliance with any court order or other legal obligation
  • Enforcement of our terms of use and other agreements
  • Protection of the rights, property, or safety of our business, our customers, employees, or others

(e) Access to Information

We do not maintain any procedures for you to review or request changes to the information that we collect about you, except that you may request that we remove all information about you from our database by contacting us in accordance with this Policy.

Security

The Site has security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.

Notice Concerning Children

We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children's privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete any personal information in that user's account.

California Residents

The information in the section California Residents supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents.

Summary of Information We Collect

Under California law, we are obligated to provide transparency regarding the types of personal information we collect about California residents (as defined under the California Consumer Privacy Act, or "CCPA"). This includes disclosing the categories of personal information collected, the sources from which such information is obtained, the business or commercial purposes for collecting the information (as defined under applicable law), and the categories of third parties with whom this information may be shared.

We, along with our service providers, may collect the categories of information listed below for various business or commercial purposes, as defined under applicable law. These purposes may include:

  • Delivering and supporting the Service, for example managing accounts, connecting freelancers with clients, providing customer support, marketing and promotional efforts, conducting analytics, and communicating about the Service
  • Carrying out internal business operations for us or our service providers
  • Auditing user interactions on our platform, such as tracking advertisement performance
  • Identifying and preventing security threats, fraud, or other unlawful activities, and taking enforcement actions when necessary
  • Identifying bugs, reporting errors, and maintaining or enhancing the quality and security of our Service
  • Ensuring compliance with legal obligations, investigating potential violations, and enforcing applicable laws and policies
  • Supporting temporary, short-term activities such as content personalization shown through our Service or by service providers
  • Enhancing our current offerings and creating new features or services through research and development
  • Engaging in activities that support our commercial or business goals, including third-party advertising and notifying you of relevant promotions from us or our partners
  • Other uses about which we notify you

If you are a resident of California, you may be entitled to specific rights under state law. These rights may include the ability to request that we:

  • Disclose the categories of personal information we have collected or shared about you over the past twelve months, including the sources of that information, the business or commercial purposes for its collection or disclosure, and the categories of third parties with whom the information was shared
  • Provide access to, or a copy of, certain personal information we maintain about you
  • Delete specific personal information we have on record about you

You may be entitled to request details regarding any financial incentives we may offer to you, if applicable. Additionally, you have the right to be free from discrimination, as outlined under applicable law, for exercising any of your legal rights.

To exercise any of these rights, you can submit a request using the Data Request Form found in our Privacy Center or by emailing us at help@careway.health. We will need to verify your identity before processing your request. You may also appoint an authorized agent to act on your behalf. In that case, you must provide written permission or a signed power of attorney authorizing the agent to submit the request. Even if you appoint an agent, we will still require you to verify your identity directly with us.

Some types of information may be excluded from these requests under applicable law. For instance, certain data is necessary for us to deliver the Service to you. If you request that this information be deleted, it may impact your ability to access or use the Service.

The California Consumer Privacy Act (CCPA) imposes specific requirements on businesses that "sell" personal information. According to how "sell" is defined under the CCPA and current regulatory guidance, we do not consider our practices to involve the sale of personal information, and we have not engaged in such practices within the past twelve months.

Areas Beyond Company Control

Public Forums

The Site may include interactive forums such as message boards and chat rooms. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.

Third Party Websites

The Site may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

Contact Information and Policy Updates

Contacting Us

If you have any questions about this Policy, our practices related to this Site, or if you would like to have us remove your information from our database, you may email us at help@careway.health or mail to:

Careway Health, Inc.
1111B S Governors Ave STE 29716
Dover, DE 19904

Updates and Changes

We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms.

HIPAA Notice

Effective Date: June 9, 2025

Updated: June 9, 2025

NOTICE OF PRIVACY PRACTICES

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.

Careway Health, Inc. in association with Careway Health Medical PA and Careway Health Medical West PC ("Careway Health", "us," "we," "our," or the "Company") and its employees are dedicated to maintaining the privacy of your personal health information ("PHI"), as required by applicable federal and state laws. These laws require us to provide you with this Notice of Privacy Practices, and to inform you of your rights and our obligations concerning Protected Health Information, or PHI, which is information that identifies you and that relates to your physical or mental health condition. We are required to follow the privacy practices described below while this Notice is in effect.

A. Permitted Disclosures of PHI.

We may disclose your PHI for the following reasons.

1. Treatment.

We may disclose your PHI to a physician or other healthcare provider providing or coordinating treatment you receive. For example, we may disclose medical information about you to physicians, nurses, pharmacists, technicians or personnel who are involved with the administration of your care. We may also disclose your PHI with other third parties, such as hospitals, other pharmacies and other health care facilities and agencies to facilitate the provision of health care services, medications, equipment and supplies you may need. This helps to coordinate your care and make sure that everyone who is involved in your care has the information that they need about you to meet your health care needs.

2. Payment.

We may disclose your PHI to bill and collect payment for the services we provide to you and for other payment activities related to the services that we provide. For example, we may contact your insurer, pharmacy benefit manager or other health care payor to determine whether it will pay for health care products and services you need and to determine the amount of your co-payment. We will bill you or a third-party payor for the cost of health care products and services we provide to you. The information on or accompanying the bill may include information that identifies you, as well as information about the services that were provided to you or the medications you are taking. We may also disclose your PHI to other health care providers or HIPAA covered entities who may need it for their payment activities.

3. Healthcare Operations.

We may disclose your PHI in connection with our healthcare operations. Healthcare operations include quality assessment activities, reviewing the competence or qualifications of healthcare professionals, evaluating provider performance, and other business operations. For example, we may use your PHI to evaluate the performance of the healthcare services you received. We may also provide your PHI to accountants, attorneys, consultants and others to make sure we comply with the laws that govern us. We may also disclose your PHI to other HIPAA covered entities that have provided services to you so that they can improve the quality and effectiveness of the health care services that they provide. We may use your PHI to create de-identified data, which is stripped of your identifiable data and no longer identifies you.

4. Business Associates.

We may contract with third parties to perform certain services for us, such as billing services, copy services or consulting services. These third party service providers, referred to as Business Associates, may need to access your PHI to perform services for us. They are required by contract and law to protect your PHI and only use and disclose it as necessary to perform their services for us.

5. Emergency Treatment.

We may disclose your PHI if you require emergency treatment or are unable to communicate with us.

6. Family and Friends.

We may disclose your PHI to a family member, friend or any other person who you identify as being involved with your care or payment for care, unless you object. Additionally, we may disclose PHI to your "personal representative." If a person has the authority by law to make health care decisions for you, we will generally regard that person as your "personal representative" and treat him or her the same way we would treat you with respect to your PHI.

7. Required by Law.

We may disclose your PHI for law enforcement purposes and as required by federal, state, or local law. For example, the law may require us to report instances of abuse, neglect or domestic violence; to report certain injuries such as gunshot wounds; or to disclose PHI to assist law enforcement in locating a suspect, fugitive, material witness or missing person. We will inform you or your representative if we disclose your PHI because we believe you are a victim of abuse, neglect or domestic violence, unless we determine that informing you or your representative would place you at risk. In addition, we must provide PHI to comply with an order in a legal or administrative proceeding. Finally, we may be required to provide PHI in response to a subpoena discovery request or other lawful process, but only if efforts have been made, by us or the requesting party, to contact you about the request or to obtain an order to protect the requested PHI.

8. Serious Threat to Health or Safety.

We may disclose your PHI if we believe it is necessary to avoid a serious threat to the health and safety of you or the public.

9. Public Health.

We may disclose your PHI to public health or other authorities charged with preventing or controlling disease, injury or disability, or charged with collecting public health data, including the FDA. In certain circumstances, we may also report work-related illnesses and injuries to employers for workplace safety purposes.

10. Health Oversight Activities.

We may disclose your PHI to a health oversight agency for activities authorized by law. These activities include audits; civil, administrative or criminal investigations or proceedings; inspections; licensure or disciplinary actions; or other activities necessary for oversight of the health care system, government programs and compliance with civil rights laws.

11. Research.

We may disclose your PHI for certain research purposes, but only if we have protections and protocols in place to ensure the privacy of your PHI.

12. Coroners, Medical Examiners and Funeral Directors.

We may release your PHI to coroners or medical examiners so that they can carry out their duties. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also disclose PHI to funeral directors consistent with applicable law to enable them to carry out their duties.

13. Organ or Tissue Procurement Organizations.

Consistent with applicable law, we may disclose your PHI to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.

14. Notification.

We may use or disclose your PHI to notify or assist in notifying a family member, personal representative, or another person responsible for your care, regarding your location and general condition.

15. Disaster Relief.

We may use and disclose your PHI to organizations for purposes of disaster relief efforts.

16. Correctional Institution.

If you are or become an inmate of a correctional institution, we may disclose to the institution, or its agents, PHI necessary for your health and the health and safety of other individuals.

17. Workers' Compensation.

We may disclose your PHI to comply with laws relating to workers' compensation or other similar programs.

18. Specialized Government Activities.

If you are active military or a veteran, we may disclose your PHI as required by military command authorities. We may also be required to disclose PHI to authorized federal officials for the conduct of intelligence or other national security activities.

B. Disclosures Requiring Written Authorization.

Not Otherwise Permitted. In any other situation not described in Section A above, we may not disclose your PHI without your written authorization.

Marketing and Sale of PHI. We must receive your written authorization for any disclosure of PHI for marketing purposes or for any disclosure which is a sale of PHI.

C. Your Rights.

1. Right to Receive a Paper Copy of This Notice.

You have the right to receive a paper copy of this Notice upon request.

2. Right to Access PHI.

You have the right to inspect and copy your PHI for as long as we maintain your medical record. You must make a written request for access to the Compliance Officer at the email address listed at the end of this Notice. We may charge you a reasonable fee for the processing of your request and the copying of your medical record pursuant to state law. In certain circumstances we may deny your request to access your PHI, and you may request that we reconsider our denial. Depending on the reason for the denial, another licensed health care professional chosen by us may review your request and the denial

3. Right to Request Restrictions.

You have the right to request a restriction on the use or disclosure of your PHI for the purpose of treatment, payment or health care operations, except for in the case of an emergency. You also have the right to request a restriction on the information we disclose to a family member or friend who is involved with your care or the payment of your care. However, we are not legally required to agree to such a restriction.

4. Right to Restrict Disclosure for Services Paid by You in Full.

You have the right to restrict the disclosure of your PHI to a health plan if the PHI pertains to health care services for which you paid in full directly to us.

5. Right to Request Amendment.

You have the right to request that we amend your PHI if you believe it is incorrect or incomplete, for as long as we maintain your medical record. We may deny your request to amend if (a) we did not create the PHI, (b) is not information that we maintain, (c) is not information that you are permitted to inspect or copy (such as psychotherapy notes), or (d) we determine that the PHI is accurate and complete.

6. Right to an Accounting of Disclosures.

You have the right to request an accounting of disclosures of PHI made by us (other than those made for treatment, payment or health care operations purposes) during the 6 years prior to the date of your request. You must make a written request for an accounting, specifying the time period for the accounting, to the Compliance Officer at the email address listed at the end of this Notice.

7. Right to Confidential Communications.

You have the right to request that we communicate with you about your PHI by certain means or at certain locations. For instance, you may request that we contact you at a different residence or post office box, or via e-mail or other electronic means. Please note if you choose to receive communications from us via e-mail or other electronic means, those may not be a secure means of communication and your PHI that may be contained in our e-mails to you will not be encrypted. This means that there is risk that your PHI in the e-mails may be intercepted and read by, or disclosed to, unauthorized third parties. You must make a written request, specifying how and where we may contact you, to the Compliance Officer at the email address listed at the end of this Notice.

8. Right to Notice of Breach.

You have a right to be notified following a breach of your unsecured PHI, and we will notify you in accordance with applicable law.

D. Changes to this Notice.

We reserve the right to change our practices and this notice and to make the new notice effective for all PHI we maintain. If we do so, the updated notice will be posted on our website. Upon request, we will provide any revised notice to you.

E. Acknowledgment of Receipt of Notice.

We will ask you to sign an acknowledgment that you received this Notice.

F. Questions and Complaints.

If you would like more information about our privacy practices or have questions or concerns, you may contact us via email help@careway.health or by calling us at (413) 438-2273. If you believe your privacy rights have been violated, you can file a complaint with us or with the Secretary of Health and Human Services. There will be no retaliation for filing a complaint.

Effective Date.

This notice is effective as of June 9, 2025.