Notice of Privacy Practices

Effective: March 2026 · Last updated: March 2026

Important Note: Acules is a comparison and referral platform, not a covered healthcare provider under HIPAA. However, when Acules acts as a business associate of a covered entity (such as a self-funded employer plan or insurance company that has engaged Acules to coordinate care for their members), Acules may handle protected health information (PHI) as defined by HIPAA. This notice describes our practices in that capacity.

1. How We Use Your Health Information

When Acules handles protected health information as a business associate, we may use or disclose PHI for the following purposes:

Treatment facilitation: Sharing relevant medical history and records with partner hospitals to facilitate your consultation, treatment planning, and care.
Health care operations: Internal quality review, training, and audit activities related to our patient coordination services.
Payment: Communicating with plan administrators or employers about covered services for claims or cost-sharing purposes.
Legal requirements: When required by applicable law, including court orders, subpoenas, or reporting required by law.
Emergencies: Disclosing information to medical personnel in the event of a medical emergency during your medical travel.

We will not use or disclose your PHI for marketing purposes, sell your PHI, or share your PHI in any way not described in this notice or your specific consent, except as required by law.

2. Your Rights Under HIPAA

To the extent HIPAA applies to Acules' handling of your information, you have the following rights:

Right to access:Request a copy of your PHI in Acules' records.
Right to amend: Request amendment of PHI you believe is inaccurate or incomplete.
Right to an accounting of disclosures: Request a list of disclosures we have made of your PHI.
Right to request restrictions: Request restrictions on how we use or disclose your PHI (though we may not always be able to agree to requested restrictions).
Right to confidential communications: Request that we communicate with you through alternative means or at alternative locations.
Right to a paper copy of this notice: Request a paper copy of this notice at any time, even if you have agreed to receive it electronically.

To exercise any of these rights, contact our Privacy Officer at privacy@acules.com.

3. Our Duties

Acules is required to maintain the privacy and security of your PHI. We are required to provide you with this notice of our legal duties and privacy practices regarding PHI. We are required to abide by the terms of this notice currently in effect. We will notify you if a breach occurs that may have compromised the privacy or security of your PHI.

Acules maintains administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of PHI. These safeguards include encryption of data in transit and at rest, access controls, and regular security assessments.

4. Changes to This Notice

Acules reserves the right to change this notice. We may make the revised or changed notice effective for PHI we already have about you as well as any information we receive in the future. We will post the current notice on our website with its effective date. You may request a current copy at any time by contacting our Privacy Officer.

5. Complaints

If you believe your privacy rights have been violated, you may file a complaint with Acules or with the U.S. Department of Health and Human Services (HHS) Office for Civil Rights. To file a complaint with Acules, contact our Privacy Officer. We will not retaliate against you for filing a complaint.

HHS Office for Civil Rights: www.hhs.gov/ocr

6. Contact the Privacy Officer

Privacy Officer, Acules, Inc.
privacy@acules.com