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Notice of Privacy Practices

Apple Specialty Pharmacy LLC · Version 1.0.0 · Effective 2026-05-30

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 Notice describes how Apple Specialty Pharmacy LLC ("ASP," "we," "us") may use and disclose your Protected Health Information ("PHI") to provide treatment, obtain payment, conduct healthcare operations, and for other purposes permitted or required by law. It also describes your rights and our obligations under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), as amended.

Our pledge regarding your medical information

We understand that medical information about you is personal. We are committed to protecting it. We create a record of the medications, plans of treatment, and clinical assessments we perform for you. This Notice applies to all PHI we maintain about you, whether in paper, electronic, or oral form.

How we may use and disclose your PHI without your authorization

For Treatment

We may use and disclose your PHI to provide pharmacy services and coordinate with your prescribing physicians, nurses, and other healthcare providers. Example: we may share your medication regimen with your prescriber to discuss adjustments, or with a home-infusion nurse to ensure proper administration.

For Payment

We may use and disclose your PHI to obtain payment for the services we provide. Example: we may submit claims to your health insurance carrier, share necessary information with a billing service, or coordinate with a pharmacy benefit manager.

For Healthcare Operations

We may use and disclose your PHI for activities necessary to run our pharmacy. Example: we may use your information for quality assessment, staff training, accreditation, audits, business management, or to plan and improve our services.

Business Associates

We may share PHI with vendors who perform services on our behalf under a written Business Associate Agreement. Current categories include hosting (Microsoft Azure), AI documentation assistance (Anthropic, on a zero-retention tier), and electronic signature services. A current list is available on request to the Privacy Officer.

Required by law

We will disclose PHI when required by federal, state, or local law, including: public health activities (disease reporting, FDA-mandated adverse event reporting), oversight agencies, law enforcement when required, court orders or subpoenas, organ donation, workers' compensation, threats to health or safety, and military/national security activities.

Uses and disclosures requiring your written authorization

We will obtain your written authorization before:

  • Using or disclosing your PHI for marketing purposes (other than face-to-face communications or promotional gifts of nominal value);
  • Selling your PHI;
  • Disclosing psychotherapy notes (we generally do not create these);
  • Most other uses not described in this Notice.

You may revoke an authorization in writing at any time, except to the extent we have already acted in reliance on it.

Your rights regarding your PHI

Right to access (45 CFR § 164.524)

You have the right to inspect and obtain a copy of your PHI in our designated record set. For electronic records, we will provide a copy in electronic form when readily producible. We may charge a reasonable, cost-based fee. We will respond within 30 calendar days of receiving your written request.

Right to amend (45 CFR § 164.526)

You may request that we amend PHI you believe is inaccurate or incomplete. Your request must be in writing and include a reason supporting the request. We may deny the request in certain circumstances (e.g., the record was not created by us, or it is accurate and complete). If we deny, we will explain in writing and you may submit a statement of disagreement.

Right to an accounting of disclosures (45 CFR § 164.528)

You may request a list of certain disclosures we made of your PHI during the six years preceding your request. This accounting does not include disclosures for treatment, payment, or healthcare operations, or disclosures you authorized. The first accounting in any 12-month period is free; we may charge a reasonable fee for additional requests within that period.

Right to request restrictions (45 CFR § 164.522(a))

You have the right to request a restriction on the PHI we use or disclose for treatment, payment, or healthcare operations, or to a family member or person involved in your care. We are not required to agree, except for one specific case: we must agree to your request not to disclose PHI to a health plan for payment purposes if you have paid out-of-pocket in full for the item or service.

Right to confidential communications (45 CFR § 164.522(b))

You may request that we communicate with you about your PHI in a specific way or at a specific location (e.g., only at work, or by mail rather than phone). We will accommodate reasonable requests.

Right to be notified of a breach (45 CFR § 164.404)

You have the right to be notified following a breach of your unsecured PHI. We will notify you in writing without unreasonable delay and in no case later than 60 days after discovery.

Right to a paper copy of this Notice

Even if you have agreed to receive this Notice electronically, you may request a paper copy at any time. Contact the Privacy Officer.

How to exercise your rights

To exercise any of these rights, submit a written request to:

Privacy Officer
Apple Specialty Pharmacy LLC
Santa Ana, California
Email: privacy@applespecialtypharmacy.com

You may also use our online Data Rights portal to submit a request. We will verify your identity before disclosing or modifying any PHI.

Our duties

We are required by law to:

  • Maintain the privacy and security of your PHI;
  • Provide you this Notice of our legal duties and privacy practices;
  • Notify affected individuals if a breach occurs that may have compromised the privacy or security of their PHI;
  • Follow the terms of the Notice currently in effect.

How we protect your PHI

We maintain administrative, technical, and physical safeguards designed to protect your PHI. These include:

  • Encryption in transit (TLS 1.2+) and at rest;
  • Role-based access controls limiting staff to the minimum necessary;
  • An append-only audit log of every privileged access;
  • A written incident response process;
  • Workforce HIPAA training, including sanctions for violations;
  • Periodic risk analysis and threat modeling.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with us:

Privacy Officer
Apple Specialty Pharmacy LLC
Email: privacy@applespecialtypharmacy.com

You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights:

U.S. Department of Health and Human Services
Office for Civil Rights
200 Independence Avenue, S.W.
Washington, D.C. 20201
1-877-696-6775
www.hhs.gov/hipaa/filing-a-complaint

California residents may also file a complaint with the California Office of the Attorney General. We will not retaliate against you for filing a complaint.

Changes to this Notice

We reserve the right to change this Notice and to make the new Notice effective for all PHI we maintain. We will post a copy of the current Notice on our website. The effective date of this Notice is shown above. You may request a paper copy of the most current Notice at any time.

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