Privacy Policy

Effective May 29, 2026

This Privacy Policy explains how Healing Momentum LLC ("Healing Momentum," "we," "us") collects, uses, discloses, and protects information in connection with our patient engagement service (the "Service"). It applies to patients enrolled in the Service by a participating practitioner and to practitioners who use the Service to support patient care.

1. Information We Collect

Information you provide

• Account and contact information: name, email address, mobile phone number, and electronic signature.
• Health information: responses to check-ins, intake questionnaires, symptom and lifestyle reflections, and any other content you submit through the Service.
• Consent records: the consents you grant, the date and time of each consent, and the channel preferences you select.

Information from your practitioner

• Demographic and contact information used to enroll you in the Service.
• Appointment, protocol, and clinical context relevant to your care.
• Notes and observations entered by your practitioner.

Information collected automatically

• Log and device data (such as IP address, browser type, and timestamps) used to operate and secure the Service.
• Delivery events for messages we send (for example, whether an email or text message was delivered or failed).

2. How We Use Information

We use information to:

• Provide the Service, including sending care-related communications, check-in reminders, and intake prompts.
• Enable your practitioner to monitor your progress, identify when to intervene, and prepare for visits.
• Generate clinical insights for your practitioner and, where authorized, de-identified analyses for research, platform improvement, and other lawful purposes.
• Authenticate users, secure accounts, prevent fraud, and comply with legal obligations.
• Maintain audit logs required for healthcare compliance.

3. Text Messaging

If you have opted in to text messages, we use your mobile number to send check-in reminders, appointment notifications, intake prompts, and other transactional care-related messages. Message frequency varies, typically 1 to 4 messages per week. Message and data rates may apply. Reply HELP for help or STOP to opt out at any time. Standard SMS data is shared only with our telecommunications service providers and aggregators as necessary to deliver the messages you have requested.

4. How We Share Information

We share information only as described below.

• Your practitioner. The practitioner who enrolled you receives the information you submit and may share it with members of their care team.
• Service providers. We use vetted infrastructure and software providers to host the Service, store data, send messages, and process information on our behalf. Where these providers process protected health information, we maintain Business Associate Agreements with them as required by HIPAA.
• Legal and safety. We may disclose information when required by law, to respond to lawful requests, to enforce our agreements, or to protect the rights, safety, or property of any person.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, information may be transferred subject to confidentiality protections.
• De-identified data. Where you have authorized it, we may use and share de-identified data (data from which your personal identifiers have been removed in accordance with applicable law) for research, platform improvement, and other lawful purposes.

5. HIPAA and Your Health Information

When we process protected health information ("PHI") on behalf of a practitioner who is a HIPAA-covered entity, we act as a Business Associate under the Health Insurance Portability and Accountability Act ("HIPAA"). The practitioner's Notice of Privacy Practices governs your rights with respect to your PHI. Please contact your practitioner for a copy.

6. Your Choices

• Text messages: reply STOP to any message to opt out, or contact your practitioner.
• Email: follow the unsubscribe instructions in transactional emails where applicable, or contact your practitioner.
• Account and care-related consent: you may revoke care-related consent at any time by contacting your practitioner. De-identified data already used or shared cannot be recalled.
• Access and correction: for requests to access, correct, or delete your information, contact your practitioner or email us at the address below.

7. Data Retention

We retain information for as long as needed to provide the Service, comply with our legal obligations (including HIPAA recordkeeping requirements), resolve disputes, and enforce our agreements. Retention periods may be longer where required by law.

8. Security

We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, alteration, and destruction. These include encryption in transit and at rest, access controls, multi-factor authentication for practitioner accounts, and audit logging. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

9. Children

The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13 without parental consent. Where a minor patient is enrolled by a practitioner, enrollment and consent are managed through the patient's parent or legal guardian and the practitioner.

10. International Users

The Service is operated from the United States. If you access the Service from outside the United States, you understand that your information will be processed in the United States, which may have data protection laws different from those of your jurisdiction.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the effective date above. Material changes will be communicated through the Service or by other reasonable means.

12. Contact Us

Questions about this Privacy Policy or our privacy practices can be directed to:

Healing Momentum LLC
1405 Point Street
Baltimore, MD 21231
Email: justin@healingmomentum.com