Privacy Policy

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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.

This Privacy Notice is being provided to you as a requirement of federal law, the Health
Insurance Portability and Accountability Act (HIPAA). This Privacy Notice describes how
we may use and disclose your protected health information to carry out treatment,
payment, or health care operations and for other purposes that are permitted or
required by law. It also describes your rights to access and control your protected health
information in some cases. Your “protected health information” means any written and
oral health information about you, including demographic data that can be used to
identify you. This is health information that is created or received by your health care
provider, and that relates to your past, present, or future physical or mental health or
condition.

Kentucky Eye Institute (the Practice), and Midwest Eye Center are two (2) separate legal
companies with common ownership or control. Because of this common ownership and
control, these two (2) companies, both of which are health care providers and covered
entities under HIPAA, may designate themselves as a single covered entity for HIPAA
purposes. This means that the Kentucky Eye Institute and Midwest Eye Center follow the
same privacy practices and procedures and have the same privacy officer, even though
they are legally separate companies. They are collectively referred to in this Privacy
Notice as the Company.

I. Uses and Disclosures of Protected Health Information
The Company may use your protected health information for purposes of providing
treatment, obtaining payment for treatment, and conducting health care operations.
Your protected health information may be used or disclosed only for these purposes
unless the Company has obtained your authorization, or the use or disclosure is
otherwise permitted by the HIPAA privacy regulations or state law. Disclosures of your
protected health information for the purposes described in this Privacy Notice may be
made in writing, orally, electronically, or by facsimile.

A. Treatment. We will use and disclose your protected health information to provide,
coordinate, or manage your health care and any related services. This includes the
coordination or management of your health care with a third party for treatment
purposes. We may also disclose protected health information to physicians who may be
treating you or consulting with the Company with respect to your care. In some cases,
we may also disclose your protected health information to an outside treatment provider
for purposes of the treatment activities of the other provider.

B. Payment. Your protected health information will be used as needed to obtain
payment for the services that we provide. We may also disclose protected health
information to your health insurance company to determine whether you are eligible for
benefits or whether a particular service is covered or requires preauthorization under
your health plan. In order to get payment for the services we provide to you, we may also
need to disclose your protected health information to your health insurance company to
demonstrate the medical necessity of the services or, as required by your insurance
company, for utilization review. We may also disclose patient information to another
provider involved in your care for the other providers’ payment activities. If you do not
want us to use your protected health information to obtain payment for the services that
we provide, you may pay in full for your treatment and instruct us not to submit the
services to your health insurance company for payment. If you make this request and
pay in full for your treatment, we will not provide your insurance company with access to
the information for the services that you paid for yourself unless the disclosure is
required by law.

C. Operations. We may use or disclose your protected health information, as necessary,
for our own health care operations of the Company. Health care operations include such
activities as quality assessment and improvement activities, employee review activities,
training programs, including those in which students, trainees, or practitioners in health
care learn under supervision, accreditation, certification, licensing or credentialing
activities, review, and auditing, including compliance reviews, medical reviews, legal
services and maintaining compliance programs, and business management and general
administrative activities.

D. Other Uses and Disclosures. We may also use or disclose your protected health
information for the following purposes: to remind you of your appointment, to inform
you of potential treatment alternatives or options, or to inform you of health-related
benefits or services that we provide. Uses not described in this Privacy Notice will require
your written authorization.

II. Uses and Disclosures beyond Treatment, Payment, and Health Care Operations
Permitted Without Authorization or Opportunity to Object
Federal privacy rules allow us to use or disclose your protected health information
without your permission or authorization for a number of reasons, including the
following:

A. When Legally Required. We will disclose your protected health information when we
are required to do so by any federal, state, or local law. Some examples of this are
described below.

B. When There Are Risks to Public Health. We may disclose your protected health
information for the following public activities and purposes:
“To prevent, control, or report disease, injury, or disability as permitted or required by law.
“To report vital events such as birth or death as permitted or required by law.
“To conduct public health surveillance, investigations and interventions as permitted or
required by law.
“To collect or report adverse events and product defects, track FDA regulated products,
enable product recalls, repairs or replacements to the FDA, and to conduct postmarketing surveillance.
“To notify a person who has been exposed to a communicable disease or who may be at
risk of contracting or spreading a disease as authorized by law.
“To report to an employer information about an individual who is a member of the
workforce as legally permitted or required.

C. To Report Suspended Abuse, Neglect, or Domestic Violence. We may notify
government authorities if we believe that a patient is the victim of abuse, neglect, or
domestic violence. We will make this disclosure only when specifically required or
authorized by law or when the patient agrees to the disclosure.

D. To Conduct Health Oversight Activities. We may disclose your protected health
information to a health oversight agency for activities including audits; civil,
administrative, or criminal investigations, proceedings, or actions; inspections; licensure
or disciplinary actions; or other activities necessary for appropriate oversight as
authorized by law. We will not disclose your health information under this authority if
you are the subject of an investigation and your health information is not directly related
to your receipt of health care or public benefits.

E. In Connection with Judicial and Administrative Proceedings. We may disclose your
protected health information in the course of any judicial or administrative proceeding
in response to an order of a court or administrative tribunal as expressly authorized by
such order. In certain circumstances, we may disclose your protected health information
in response to a subpoena to the extent authorized by state law if we receive satisfactory
assurances that you have been notified of the request or that an effort was made to
secure a qualified protective order.

F. For Law Enforcement Purposes. We may disclose your protected health information to
a law enforcement official for law enforcement purposes as follows:
“As required by law for reporting of certain types of wounds or other physical injuries.
“Pursuant to the court order, court-ordered warrant, subpoena, summons, or similar
process.
“For the purpose of identifying or locating a suspect, fugitive, material witness, or
missing person.
“Under certain limited circumstances, when you are the victim of a crime.
“To a law enforcement official if the Company has a suspicion that your health condition
was the result of criminal conduct.
“In an emergency to report a crime.

G. To Coroners, Funeral Directors, and for Organ Donation. Consistent with applicable
law, we may release medical information to a coroner, medical examiner, or funeral
director. For the purposes of facilitating organ, eye, or tissue donation and
transplantation, we may use or disclose protected health information to organizations
that engage in procurement, banking, or transplantation of cadaveric organ, eye, or
tissue transplantation.

H. For Research Purposes. If a researcher has obtained the required waiver from an
Institutional Review Board or the Privacy Board and has demonstrated that the
information is necessary to the research and possesses a minimal risk of inappropriate
use or disclosure, we may use and disclose protected health information about you for
research purposes. If a researcher has not obtained the required waiver, we will not
disclose your medical information without your written authorization, other than in a
limited data set as described below.

I. Limited Data Set. For purposes of research, public health, or health care operations, it
may be necessary to use or disclose some of your protected health information for
activities or to persons we are not otherwise authorized to give your information to. In
this situation, we may use your protected health information to create a limited data set
in which certain required direct identifiers (such as your name and address) have been
removed. We will disclose the information in the limited data set for these purposes only
if we have obtained satisfactory assurances from the recipient in a written agreement
that the recipient will only use or disclose the information for limited purposes.

J. In the Event of a Serious Threat to Health or Safety. We may, consistent with applicable
law and ethical standards of conduct, use or disclose your protected health information
if we believe, in good faith, that such use or disclosure is necessary to prevent or lessen a
serious and imminent threat to your health or safety or to the health and safety of
another person or the public.

K. For Specified Government Functions. Protected health information may be disclosed
for military and veterans’ affairs, for national security and intelligence activities, or for
correctional facility activities.

L. For Worker’s Compensation. The Company may release your protected health
information to comply with worker’s compensation laws or similar programs that are
established by the law to provide benefits for work-related injuries or illness without
regard to fault.

M. To Business Associates. We may disclose your information to a person or organization
that performs a function or activity on behalf of the Company that involves the use or
disclosure of protected health information. We will only use or disclose your information
to that person or organization if we have obtained adequate assurances that the
business associate will appropriately safeguard the information. The Company signs
written contracts with its business associates requiring them to follow HIPAA privacy
and security rules. Business associates are also required by law to follow HIPAA privacy
and security rules.

N. To Personal Representative. We may disclose your information to a person who has
the authority, under the law, to act on your behalf in making decisions related to health
care.

O. Inmates. If you are an inmate of a correctional institution or under custody of a law
enforcement official, we may disclose health information about you to the correctional
institution or the law enforcement official. This is necessary for the correctional
institution to provide you with health care, to protect your health and safety and the
health and safety of others, or for the safety and security of the correctional institution.

III. Uses and Disclosures Permitted without Authorization but with Opportunity to Object
We may disclose your protected health information to your family member or a close
friend if it is directly relevant to the person’s involvement in your care or payment related
to your treatment. For example, if you are having surgery at the Surgery Center and the
family member who is picking you up calls to see if you are done with surgery, we will
advise them whether you have left the operating room. We can also disclose your
information in connection with trying to locate or notify family members or others
involved in your care concerning your location, condition, or death.

You may object to these disclosures. If you do not object to these disclosures or we can
infer from the circumstances that you do not object or we determine, in the exercise of
our professional judgment, that it is in your best interests for us to make disclosure of
information that is directly relevant to the persons involvement with your care, we may
disclose your protected health information as described.

IV. Uses and Disclosures That You Authorize
Other than as stated above, we will not disclose your protected health information other
than with your written authorization. For example, we will not use or disclose your
protected health information without your written authorization for marketing purposes,
including subsidized treatment communications, or for what is considered a sale of
protected health information, which includes any payment received for using or
disclosing protected health information. You may revoke your authorization in writing at
any time except to the extent that we have acted in reliance upon the authorization. In
addition, if the authorization was obtained as a condition of obtaining insurance
coverage, the insurer will have a right to contest a claim under the policy.

V. Your Rights
You have the following rights regarding your health information:

A. The right to inspect and copy your protected health information. You may inspect and
obtain a copy of your protected health information that is contained in your medical
record for as long as we maintain the protected health information. Your medical record
contains medical and billing records and any other records that the Company and its
licensed healthcare professionals use for making decisions about you.
Under federal law, however, you do not have the right to inspect or copy the following
records: psychotherapy notes; information compiled in reasonable anticipation of, or for
use in, a civil, criminal, or administrative action or proceeding; and protected health
information that is subject to a law that prohibits access to protected health information.
Depending on the circumstances, you may have the right to have a decision to deny
access reviewed.

We may deny your request to inspect or copy your protected health information if, in our
professional judgment, we determine that the access requested is likely to endanger
your life or safety or that of another person or that it is likely to cause substantial harm to
another person referenced within the information. You have the right to request a
review of this decision.
To inspect and copy your protected health information, you must submit a written
request to the Privacy Officer, whose contact information is listed on the last page of this
Privacy Notice. If your medical record is, in whole or part, maintained electronically, you
may request that we provide you with the information in an electronic format, and we
will provide the record to you in your requested format if it is feasible for us to do so. If
you request a copy of your information, we may charge you a fee for the costs of copying,
mailing, or other costs incurred by us in complying with your request as permitted by
federal and state law.
Please contact our Privacy Officer if you have questions about access to your medical
record or the costs of obtaining copies.

B. The right to request a restriction on uses and disclosures of your protected health
information. You may ask us not to use or disclose certain parts of your protected health
information for the purposes of treatment, payment, or health care operations. You may
also request that we not disclose your health information to family members or friends
who may be involved in your care or for notification purposes as described in this Privacy
Notice. Your request must state the specific restriction requested and to whom you want
the restriction to apply.

The Company is not required to agree to a restriction that you may request unless you
pay in full for the treatment provided. We will notify you if we deny your request to a
restriction; however, we cannot deny your request for a restriction if you pay in full for the
services related to the protected health information that you do not want to be
disclosed, except where disclosure is required by law. If the Company does agree to the
requested restriction, we may not use or disclose your protected health information in
violation of that restriction unless it is needed to provide emergency treatment or to
make a disclosure required by law. Under certain circumstances, we may terminate our
agreement to a restriction. You may request a restriction by contacting the Privacy
Officer in writing.

C. The right to request to receive confidential communications from us by alternative
means or at an alternative location. You have the right to request that we communicate
with you in certain ways. We will accommodate reasonable requests. We may condition
this accommodation by asking you for information as to how payment will be handled or
the specification of an alternative address or another method of contact. We will not
require you to provide an explanation for your request. Requests must be made in
writing to our Privacy Officer.

D. The right to request amendments to your protected health information. You may
request an amendment of protected health information about you in your medical
record for as long as we maintain this information. In certain cases, we may deny your
request for an amendment. If we deny your request for amendment, you have the right
to file a statement of disagreement with us, and we may prepare a rebuttal to your
statement and will provide you with a copy of any such rebuttal. Requests for
amendment must be in writing and must be directed to our Privacy Officer. In this
written request, you must also provide a reason to support the requested amendments.

E. The right to receive an accounting. You have the right to request an accounting of
certain disclosures of your protected health information made by the Company. This
right applies to disclosures for purposes other than treatment, payment, or health care
operations as described in this Privacy Notice. We are also not required to account for
disclosures that you requested, disclosures that you agreed to by signing an
authorization form, disclosures for a facility directory, to friends or family members
involved in your care, or certain other disclosures we are permitted to make without your
authorization. In the event that the Department of Health and Human Services expands
your rights to receive an accounting, the Company will comply with those expanded
rights. The request for an accounting must be made in writing to our Privacy Officer. The
request should specify the time period sought for the accounting. Accounting requests
may not be made for periods of time in excess of six years. We will provide the first
accounting you request during any 12-month period without charge. Subsequent
accounting requests may be subject to a reasonable cost-based fee.

F. The right to obtain a paper copy of this Privacy Notice. Upon request, we will provide a
separate paper copy of this Privacy Notice even if you have already received a copy of the
Privacy Notice or have agreed to accept it electronically.

G. The right to be notified of any breach of your unsecured protected health information.
In the event that your protected health information is breached, for example, if a server
containing your protected health information is hacked and your unencrypted
information was accessed by an unauthorized third party, we are required by law to
notify you of the breach.

VI. Our Duties
The Company is required by law to maintain the privacy of your health information and
to provide you with this Privacy Notice of our duties and privacy practices. We are
required to abide by the terms of this Notice as may be amended from time to time. We
reserve the right to change the terms of this Notice and to make the new Notice
provisions effective for all future protected health information that we maintain. If the
Company changes its Privacy Notice, we will make a copy of the revised Privacy Notice
available to you in our office and on our website.

VII. Complaints
You have the right to express complaints to the Company and to the US Secretary of
Health and Human Services if you believe that your privacy rights have been violated.
You may complain to the Company by contacting the Company’s Privacy Officer verbally
or in writing, using the contact information below. We encourage you to express any
concerns you may have regarding the privacy of your information. You will not be
retaliated against in any way for filing a complaint.

VIII. Contact Person
The Company’s contact person for all issues regarding patient privacy and your rights
under the federal privacy standards is the Privacy Officer. Information regarding matters
covered by this Privacy Notice can be requested by contacting the Privacy Officer. If you
feel that your privacy rights have been violated by the Company, you may submit a
complaint to our Privacy Officer by sending it to:

Latonya Izzard, JD
Privacy Officer
5775 Glenridge Drive
Building B, Suite 500
Atlanta, GA 30328
The Privacy Officer can be contacted by telephone at 404-920-8622.

IX. Effective Date
This revised Privacy Notice is effective July 28, 2025.

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