HOPE SPECIALTY PHARMACY PRIVACY STATEMENT

LAST UPDATE: January 1, 2015

Hope Specialty Pharmacy is required to maintain the privacy of Protected Health Information (“PHI”) and to provide individuals with notice of our legal duties and privacy practices with respect to PHI. PHI is information that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services. This Notice of Privacy Practices (“Notice”) describes how we may use and disclose PHI to carry out treatment, payment or health care operations and for other specified purposes that are permitted or required by law. The Notice also describes your rights with respect to PHI about you.

Hope Specialty Pharmacy is required to follow the terms of this Notice. We will not sell your name and address or other identifying information for any purpose without your express written consent. We will not use or disclose PHI about you without your written authorization, except as described in 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. Upon request, we will provide any revised Notice to you.

Your Health Information Rights

You have the following rights with respect to PHI about you: Obtain a paper or electronic copy of the Notice upon request. You may request a copy of the Notice at any time. Even if you have agreed to receive the Notice electronically, you are still entitled to a paper copy. You may obtain a paper copy at Hope Specialty Pharmacy or by calling Hope Specialty Pharmacy at 800-557-5555.

Request a restriction on certain uses and disclosures of PHI

You have the right to request additional restrictions on our use or disclosure of PHI about you for treatment, payment, health care operations, communication with individuals involved in your care or by our Business Associates by submitting a written request for the restriction. We are not required to agree to those restrictions. You have the right to restrict certain disclosures of PHI to a health plan where you pay out of pocket in full for the health care item or service. You may submit your request in person at Hope Specialty Pharmacy or by mail to the attention of Hope Specialty Pharmacy Privacy Department.

Inspect and obtain a copy of PHI

You have the right to access and copy PHI about you contained in a designated record set for as long as we maintain the PHI. You also have the right to an electronic copy of that information. The designated record set usually will include prescription and billing records. To inspect or copy or to receive an electronic copy of PHI about you, you must send a written request. You may submit your request in person at Hope Specialty Pharmacy or by mail to the attention of Hope Specialty Pharmacy Privacy Department.

Request an amendment of PHI

If you believe that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. You may request an amendment for as long as we maintain the PHI. To request an amendment, you must send a written request to the attention of our Privacy Department. You must include a reason that supports your request.

Receive an accounting of disclosures of PHI

You have the right to receive an accounting of the disclosures we have made of PHI about you for purposes other than treatment, payment, or health care operations. The accounting will exclude certain disclosures, such as disclosures made directly to you, disclosures you authorize, disclosures to friends or family members involved in your care, and disclosures for notification purposes. The right to receive an accounting is subject to certain other exceptions, restrictions, and limitations. To request an accounting, you must submit a request in writing to the attention of our Privacy Department. Your request must specify the time period, but may not be longer than six years.

Request communications of PHI by alternative means or at alternative locations

For instance, you may request that we contact you about medical matters only in writing or at a different residence or post office box. To request confidential communication of PHI about you by an alternative means or at an alternative location, you must submit a request in writing. You may submit your request in person at Hope Specialty Pharmacy or by mail to the attention of our Privacy Department. Your request must state how or where you would like to be contacted. We will accommodate all reasonable requests.

Receive Notification of a Breach

You will receive notification of a breach of any unsecured PHI.

Personal Information

Personal information is information about an identifiable individual, for example, their name, date of birth and email address. Personal information also encompasses personal health information, such as your medical records and other information about your health and your prescriptions, that has been collected or generated by your pharmacist.

Consent

You agree that we may collect, use and disclose your personal information in accordance with this Privacy Statement.

Hope Specialty Pharmacy will collect, use and disclose personal information without your consent only in limited circumstances as permitted by law. There have always been, and may continue to be, instances where we may collect, use and disclose your personal information without your consent. These instances are permitted under privacy legislation in order to ensure that the consent requirement is not a hindrance to your health and safety. For example:

- personal information may be collected without consent where the collection is clearly in the interest of the individual and consent cannot be obtained in a timely way;

- personal information may be used without consent where it is used for the purpose of acting in respect to an emergency that threatens the life, health or security of an individual; and

- personal information may be disclosed without consent where the disclosure is made to a person who needs the information because of an emergency that threatens the life, health or security of an individual.

Other than described directly above, we will not collect, use or disclose your personal information for new purposes, unrelated to the purposes described in this Privacy Statement, without first obtaining your prior consent.

If you choose to later withdraw your consent to allow us to collect your personal information, we will still be obliged to comply with all the provincial laws that require us to keep records relating to the medication that we dispense to you. If you chose to not give us consent to disclose certain personal information, we may not be able to provide you with the full range of pharmacy services. For example, if you indicate to the pharmacy staff that you do not consent to communications with your insurance company, you may be required to pay for your prescription and send the information required for reimbursement directly to your pharmacy benefits plan.

Information We Collect

Hope Specialty Pharmacy collects personal information for various purposes, including to:

  • provide healthcare related services;

  • process payments;

  • communicate with individuals involved in your care or the payment of your care;

  • provide health-related education communications;

  • communicate products and services;

  • provide loyalty programs, contests, promotions and other non-pharmacy related activities; and

  • manage the business

Hope Specialty Pharmacy will inform you, when requested, as to why we must collect any of your personal information before the information is collected.

When you first visit Hope Specialty Pharmacy, your personal information will be collected in order to establish your record. Types of information we collect include (but is not limited to), prescription information (e.g. patient, medication and prescriber information), health information (e.g. allergies and medical conditions) and insurance information. Upon request, the pharmacist or one of their pharmacy staff will provide you with information on why your personal information is required and to whom they must disclose it in order to provide you with pharmacy services.

There may be times when you want us to share prescription-related information with a family member or authorized representative or, alternatively, to specifically restrict with whom we may share the information. We will comply with your request upon notification by you. For example, if you would like to have special provisions made for the pick-up or delivery of your prescription, we will follow your instructions upon your request. We will maintain a record of your instructions. Simply contact your pharmacy and they will be pleased to update this information.

How We Use and When We Disclose Your Information

Hope Specialty Pharmacy uses personal information for a number of purposes, including as described below:

Treatment: We may use your personal information to provide you with pharmacy or health-related services. We may use your information to co-ordinate care with other pharmacies and health care providers as we have always done in the past. Examples include filling your prescription or speaking to your doctor regarding your prescription for clarification purposes. In order to provide you with quality health care and in compliance with existing federal and provincial legislation, we keep a record of the medications dispensed to you at our pharmacy. We also include in our records any relevant health information that we require to ensure that you are not given, or advised to take, a medication that is not appropriate for you.

Payment: We may use and disclose your personal information in order to receive payment for the drugs you receive. For example, we need to give information about prescriptions we have filled for you to your health plan, to obtain payment.

Communication with individuals involved in your care or payment for your care: Health professionals such as pharmacists, using their professional judgment, may disclose to your health care designate any personal information that is directly relevant to your designate's involvement in your care or payment for your care.

Health-related educational communications: We may contact you to provide refill reminders or information about treatment alternatives, events in our stores, or other health-related benefits and services that may be of interest to you.

Communication about products and services: We may use and disclose your personal information to tell you about or recommend possible treatment options or alternatives, or to tell you about health-related benefits or services that may be of interest to you.

Non-pharmacy Services and Products: We may collect your personal information in relation to non-pharmacy related services and products, including loyalty programs, contests, promotions.

Law Enforcement: In certain limited circumstances, we may be called upon to release your personal information in response to a court order, subpoena, search warrant, law, or regulation. We will cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our Terms of Use, or other rules or engage in behavior that is illegal or harmful to other users of the Sites/Application.

Product Reports: If you contact us regarding your experience in using products we dispensed to you, we may use limited information you provide to the manufacturer, and as otherwise required of us by law. We also may use the information to contact your pharmacist or prescribing physician to follow up regarding an unexpected event involving use of a product purchased.

Our Security Measures

We are committed to protecting the security of your personal information. We have put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use your personal information and have clearly defined internal policies and practices. We apply security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making personal information accessible only to authorized employees on a need-to-know basis.

Your personal information is stored on our database servers or hosted by third parties who have entered into agreements with us that require them to observe our Privacy Statement. We have implemented technological measures to prevent individuals from accessing personal information without authorization. Data centers are designed to be physically secure and protected from unauthorized access by unauthorized persons.

Although we will make reasonable efforts to protect personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems. If we are made aware of a breach, a notification will be sent to you in writing.

Retention of Personal Information

In order to provide you with quality health care and in compliance with existing federal and provincial legislation, we keep a record of the medications dispensed to you or services provided to you at our pharmacy. We also include in our records any relevant health information that we require to ensure that you are not given, or advised to take, a medicine that is not appropriate for you. We will retain your personal information for the period of time that is required by law (we have to keep prescription files for a designated number of years even though the individual may no longer be a customer). When your personal information is no longer required, it will be destroyed or depersonalized.

Changes in Our Privacy Statement

If we alter our Privacy Statement, any changes will be posted on this webpage so that you are always informed of the personal information that we collect about you, how we use it and the circumstances under which we may disclose it. Please check back from time to time to ensure you are aware of our current policies.

BY PROVIDING YOUR PERSONAL INFORMATION TO HOPE SPECIALTY PHARMACY, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT.

If you have any questions about the Privacy Statement or the handling of your personal information, please contact Hope Specialty Pharmacy at Toll-free: 1-800-557-5555 or email ask@hopesp.com to contact us. You can also contact us by mail at:

Hope Specialty Pharmacy

330 N Brand Blvd. Suite 155

Glendale, California 91203

If you believe your privacy rights have been violated, you can file a complaint with our Privacy Department or with the Secretary of Health and Human Services. There will be no retaliation for filing a complaint.