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Privacy Policy

How we collect, use, and protect your personal and health information

1. Introduction

First Choice Medicine Concierge (“FCMC,” “we,” “us,” or “our”) is committed to protecting your privacy and the security of your personal and health information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our medical services, website, or communications channels. This policy complies with the Health Insurance Portability and Accountability Act (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH), and applicable Nevada state privacy laws.

2. Information We Collect

2.1 Personal Information

We collect personal information that you provide to us directly, including:

• Identifying Information: Full name, date of birth, address, phone number, email address
• Demographic Information: Gender, age, ethnicity, preferred language
• Contact Preferences: Communication preferences (SMS, email, phone calls)
• Financial Information: Payment method, billing address, insurance information (if applicable)
• Emergency Contact Information: Name, relationship, phone number of emergency contacts

2.2 Health Information (Protected Health Information - PHI)

We collect health information necessary for providing medical care, including:

• Medical history and current health conditions
• Symptoms, complaints, and health concerns
• Physical examination findings
• Laboratory and diagnostic test results
• Medications and treatment plans
• Allergies and adverse reactions
• Family medical history
• Immunization records
• Mental health information

2.3 Usage Information

We automatically collect certain information when you interact with our digital services:

• Device Information: IP address, browser type, device type, operating system
• Usage Data: Pages visited, time spent, features used, click patterns
• Communication Data: Timestamp and content of messages through our patient portal or SMS
• Location Information: General geographic area derived from IP address (not precise GPS location)

3. How We Use Your Information

We use your information for the following purposes:

3.1 Healthcare Operations

• Providing medical care and treatment
• Scheduling appointments and reminders
• Coordination of care with specialists and other healthcare providers
• Quality assessment and improvement
• Training and education of healthcare professionals
• Administrative and billing functions

3.2 Communication

• Sending appointment reminders via SMS, email, or phone
• Providing health information and educational content
• Responding to your inquiries and requests
• Sending billing and payment notifications
• Marketing communications (with your consent or where permitted by law)

3.3 Legal and Regulatory Compliance

• Complying with legal and regulatory requirements
• Responding to subpoenas, court orders, and lawful requests
• Reporting to public health authorities as required by law
• Protecting our rights, property, and safety

4. TCPA Communications & Consent

5. SMS/MMS Communications

We send SMS text messages for the following purposes:

• Appointment reminders and confirmations
• Lab result notifications
• Prescription refill reminders
• Health tips and educational content
• Service updates and announcements
• Promotional messages (with your consent)

Message Frequency: Message frequency varies based on your appointment schedule and communication preferences. You may receive 2-4 messages per week on average.

Message and Data Rates: Message and data rates may apply. You are responsible for any charges from your wireless carrier. Check your mobile plan for details.

Opt-Out: To opt out of SMS messages, reply STOP or UNSUBSCRIBE to any message. For help, reply HELP or contact us.

6. Email Communications & CAN-SPAM Compliance

We send email communications that comply with the CAN-SPAM Act of 2003. Our emails include:

• Clear Subject Lines: Accurate, truthful subject lines that reflect the content of the message
• Opt-Out Mechanism: A clear and conspicuous unsubscribe link in the footer of every email
• Physical Address: Our valid physical postal address: 11251 S Eastern Ave Suite 150, Las Vegas, NV 89052
• Identification: Clear identification that the message is from First Choice Medicine Concierge

Unsubscribe Process: You may unsubscribe from marketing emails by clicking the unsubscribe link in any email or by contacting us. Opt-out requests will be processed within 10 business days. You will continue to receive essential healthcare-related communications (appointments, test results, billing) even after unsubscribing from marketing emails.

7. Information Sharing & Disclosure

7.1 With Your Consent

We may share your information with third parties when you give us explicit authorization, such as when we refer you to a specialist or share information with a family member you have designated.

7.2 For Treatment, Payment, and Healthcare Operations

We may share your PHI with healthcare providers, hospitals, laboratories, and other entities involved in your care, treatment, payment, or healthcare operations as permitted by HIPAA.

7.3 Business Associates

We may share your information with business associates that perform services on our behalf (e.g., billing services, IT services, cloud storage providers). These business associates are contractually required to protect your information and comply with HIPAA privacy and security requirements.

7.4 Legal Requirements

We may disclose your information when required or permitted by law, including:

• In response to a subpoena, court order, or lawful request
• To public health authorities for disease reporting or public health investigations
• To health oversight agencies for audits, investigations, or compliance
• To law enforcement authorities as required by law
• To protect our rights, property, or safety, or that of our patients or staff

7.5 De-identified Information

We may use and disclose de-identified health information (information that does not identify you) for research, quality improvement, or other purposes without restriction.

8. Data Security

We implement reasonable and appropriate administrative, physical, and technical safeguards to protect your information from unauthorized access, use, disclosure, alteration, or destruction. Our security measures include:

• Encryption: Data encryption in transit and at rest
• Access Controls: Role-based access controls and authentication requirements
• Training: Privacy and security training for all staff members
• Audits: Regular security audits and vulnerability assessments
• Breach Response: Policies and procedures for responding to data breaches

Despite our safeguards, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security.

9. Data Retention

We retain your health information in accordance with legal and regulatory requirements. Generally, we retain medical records for:

• Adults: 10 years from the date of last service or 10 years after the patient reaches age 21, whichever is longer
• Minors: Until age 23, or 10 years after the last date of service, whichever is longer
• Nevada Law: Per Nevada medical record retention requirements

After the retention period expires, records are securely destroyed in accordance with applicable laws and regulations.

10. Your Rights

You have the following rights regarding your personal and health information:

10.1 Right to Access

You have the right to request access to a copy of your personal and health information, including a complete medical record. You may inspect and copy your records during regular business hours.

10.2 Right to Correction

You have the right to request that we correct or amend your health information if you believe it is inaccurate or incomplete. We may deny your request under certain circumstances.

10.3 Right to Deletion

You have the right to request deletion of your personal information, subject to certain exceptions. Medical records generally cannot be deleted if required for medical treatment, legal compliance, or public health purposes.

10.4 Right to Opt-Out

You have the right to opt out of:

• Marketing communications (SMS, email, phone calls)
• Sale of personal information (if applicable)
• Certain sharing of information for healthcare operations (with limitations)

10.5 Right to Restrictions

You have the right to request restrictions on how we use or disclose your health information. We are not required to agree to your request unless you are asking us to restrict the use and disclosure of your PHI to a health plan for payment or healthcare operation purposes, and the information you wish to restrict pertains solely to a healthcare item or service for which you have paid us out-of-pocket in full.

10.6 Right to Notification of Breach

You have the right to be notified of any breach of your unsecured PHI in accordance with HIPAA breach notification requirements and Nevada law.

11. Nevada-Specific Privacy Protections

In addition to federal privacy laws, we comply with Nevada privacy laws, including:

• Nevada Revised Statutes (NRS) Chapter 603A: Nevada’s data security law requiring reasonable security measures to protect personal information
• NRS 41.685-41.699: Nevada’s medical records privacy act
• NRS 603A.040: Notification requirements for security breaches

Under Nevada law, you have the right to request access to your personal information and to opt out of the sale of your personal information. Nevada law requires us to implement reasonable security procedures to protect your personal information from unauthorized access, destruction, use, modification, or disclosure.

12. Do Not Track

Our website does not respond to Do Not Track (DNT) signals. We do not track your behavior across third-party websites for advertising purposes.

13. Children’s Privacy

Our services are not directed to individuals under the age of 18. If we learn that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information. For minors seeking medical care, we require parental or guardian consent and follow applicable laws regarding minors’ medical records and privacy rights.

14. Third-Party Links

Our website or communications may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these third parties. We encourage you to review the privacy policies of any third-party websites you visit.

15. Cookies & Tracking

We may use cookies and similar tracking technologies to improve your experience, analyze usage, and provide personalized content. You may control cookies through your browser settings. However, disabling cookies may affect the functionality of our website.

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website, sending you an email notification, or providing notice through other reasonable means. Your continued use of our services after the effective date constitutes acceptance of the updated policy.

17. Contact Information

To Exercise Your Rights: You may exercise your privacy rights by contacting us at the information above. We will respond to your request within 30 days (or as required by law).

To File a Complaint: If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer or with the U.S. Department of Health and Human Services Office for Civil Rights.