Privacy & HIPAA.

Last Modified: June 23, 2026

I. Who We Are

This Notice describes the privacy practices of WayPax Health, LLC (“WayPax Health,” “we,” or “us”), which provides asynchronous telemedicine services specializing in pre-travel health consultations. WayPax Health is a direct-pay service and does not bill, file claims with, or accept reimbursement from any health insurance plan, Medicare, Medicaid, or any other third-party payor. As a result, WayPax Health does not share your Protected Health Information with insurance companies or payors for payment purposes. This Notice governs:

• All healthcare professionals allowed to enter or access information in your medical record, including independent licensed clinicians (“Providers”) who deliver clinical services through the WayPax Health platform. Providers are independent contractors, not employees or agents of WayPax Health, LLC, and may receive your Protected Health Information as necessary to provide your care.
• All employees and contractors of WayPax Health with access to your medical records or health information (“Protected Health Information”).

II. Our Privacy Obligations

We understand that your health information is personal and we are committed to protecting your privacy. We are required by law to maintain the privacy of your Protected Health Information, to provide you with this Notice of our legal duties and privacy practices with respect to your Protected Health Information, and to notify you in the event of a breach of your unsecured Protected Health Information. When we use or disclose your Protected Health Information, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).

WayPax Health operates in all 50 states and complies with applicable federal and state privacy laws. In addition to the Health Insurance Portability and Accountability Act (“HIPAA”), certain states impose additional or stricter health data privacy protections. To the extent that applicable state law in your state of residence provides greater privacy protections than HIPAA, we will comply with those stricter requirements with respect to your Protected Health Information.

III. Permissible Uses and Disclosures Without Your Written Authorization

In certain situations, which we will describe in Section IV below, we must obtain your written authorization to use and/or disclose your Protected Health Information. However, unless the Protected Health Information is Highly Confidential Information (as defined in Section IV.D below) and applicable law imposes special restrictions, we may use and disclose your Protected Health Information without your written authorization for the following purposes:

A. Treatment

We use and disclose your Protected Health Information to provide treatment and other services to you—for example, to conduct asynchronous pre-travel consultations and to address health concerns you may encounter while traveling abroad. We may use your information to recommend treatments, therapies, preventive measures, health care providers, or settings of care relevant to your travel itinerary or destination. We may also disclose Protected Health Information to independent licensed Providers and other providers involved in your care. Providers operating on the WayPax Health platform are independent contractors who receive your Protected Health Information solely to deliver clinical services to you.

B. Health Care Operations

We may use and disclose your Protected Health Information for our health care operations, which include internal administration, planning, and activities that improve the quality and effectiveness of the care we deliver to you. For example, we may use Protected Health Information to evaluate the quality and competence of our Providers. We may disclose Protected Health Information to our Business Associates to resolve complaints and ensure satisfaction with our services.

WayPax Health does not share your Protected Health Information with insurance companies, health plans, or third-party payors, as WayPax Health is a direct-pay service. Information collected and/or shared via text or automated messages about your treatment or patient account may not be encrypted and secure.

C. Video Visit Recordings

Where WayPax Health offers or is required by state law to conduct synchronous audio-video consultations (“video visits”), audio-video session data may be created. WayPax Health retains video visit recordings only to the extent required by applicable law or necessary for the administration of your clinical care. Recordings are stored using industry-standard security measures and are not shared with third parties except as permitted by this Notice or required by law. You will be informed if your video visit is being recorded and may withdraw consent to recording at any time, subject to applicable legal requirements.

D. Disclosure to Relatives, Close Friends, and Other Caregivers

We may use or disclose your Protected Health Information to a family member, other relative, close personal friend, or any other person identified by you when you are present for, or otherwise available prior to, the disclosure, if: (1) we obtain your agreement or provide you with the opportunity to object to the disclosure and you do not object; or (2) we reasonably infer that you do not object to the disclosure. If you are not present for or unavailable prior to a disclosure, we may exercise our professional judgment to determine whether a disclosure is in your best interests. If we disclose information under such circumstances, we would disclose only information directly relevant to the person’s involvement with your care.

E. As Required by Law

We may use and disclose your Protected Health Information when required to do so by any applicable federal, state, or local law.

F. Public Health Activities

We may disclose your Protected Health Information: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury, or disability; (2) to report child abuse and neglect to a government authority authorized by law to receive such reports; (3) to report information about products under the jurisdiction of the U.S. Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; and (5) to report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance.

G. Victims of Abuse, Neglect, or Domestic Violence

We may disclose your Protected Health Information if we reasonably believe you are a victim of abuse, neglect, or domestic violence to a government authority authorized by law to receive reports of such abuse, neglect, or domestic violence.

H. Health Oversight Activities

We may disclose your Protected Health Information to an agency that oversees the healthcare system and is charged with responsibility for ensuring compliance with applicable health care regulations.

I. Judicial and Administrative Proceedings

We may disclose your Protected Health Information during a judicial or administrative proceeding in response to a legal order or other lawful process.

J. Law Enforcement Officials

We may disclose your Protected Health Information to the police or other law enforcement officials as required by law or in compliance with a court order.

K. Decedents

We may disclose your Protected Health Information to a coroner or medical examiner as authorized by law.

L. Organ and Tissue Procurement

We may disclose your Protected Health Information to organizations that facilitate organ, eye, or tissue procurement, banking, or transplantation.

M. Clinical Trials and Other Research Activities

We may use and disclose your Protected Health Information for research purposes pursuant to a valid authorization from you or when an institutional review board or privacy board has waived the authorization requirement. Under certain circumstances, your Protected Health Information may be disclosed without your authorization to researchers preparing to conduct a research project, for research on decedents, or as part of a data set that omits your name and other directly identifying information.

N. Health or Safety

We may use or disclose your Protected Health Information to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety.

O. Specialized Government Functions

We may use and disclose your Protected Health Information to units of the government with special functions, such as the U.S. military or the U.S. Department of State, under certain circumstances.

P. Workers’ Compensation

We may disclose your Protected Health Information as authorized by and to the extent necessary to comply with state law relating to workers’ compensation or other similar programs.

IV. Uses and Disclosures Requiring Your Written Authorization

For any purpose other than the ones described above in Section III, we only use or disclose your Protected Health Information when you give us your written authorization.

A. Marketing

We must obtain your written authorization prior to using your Protected Health Information for purposes that constitute marketing under the HIPAA privacy rules. We will not accept payments from other organizations or individuals in exchange for making communications to you about treatments, therapies, health care providers, settings of care, products, or services unless you have authorized us to do so or the communication is permitted by law. In addition, we may market to you in a face-to-face encounter and give you promotional gifts of nominal value without obtaining your written authorization.

B. Sale of Protected Health Information

We will not make any disclosure of Protected Health Information that constitutes a sale of Protected Health Information without your written authorization.

C. Psychotherapy Notes

We will not use or disclose psychotherapy notes about you without your authorization except for use by the mental health professional who created the notes to provide treatment to you, for our mental health training programs, or to defend ourselves in a legal action or other proceeding brought by you.

D. Uses and Disclosures of Highly Confidential Information

Federal and state law requires special privacy protections for certain health information about you (“Highly Confidential Information”), including psychotherapy notes, alcohol and drug abuse treatment program records, and other health information given special privacy protection under applicable state or federal laws beyond HIPAA. For us to disclose any Highly Confidential Information for a purpose other than those permitted by law, we must obtain your authorization. Patients in states with stricter protections for specific categories of health information (such as reproductive health, HIV/AIDS status, or mental health records) should be aware that WayPax Health will apply the more protective standard where required by state law.

E. Revocation of Your Authorization

You may revoke your authorization, except to the extent that we have already acted in reliance upon it, by delivering a written revocation statement to the Privacy Office identified below.

V. Your Individual Rights

A. For Further Information; Complaints

If you desire further information about your privacy rights, are concerned that we have violated your privacy rights, or disagree with a decision we made about access to your Protected Health Information, you may contact our Privacy Office. You may also file written complaints with the Office for Civil Rights of the U.S. Department of Health and Human Services. We will not retaliate against you if you file a complaint with us or the Director.

B. Right to Request Additional Restrictions

You may request restrictions on our use and disclosure of your Protected Health Information (1) for treatment and health care operations, (2) to individuals (such as a family member, other relative, close personal friend, or any other person identified by you) involved with your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests carefully, we are not required to agree to a requested restriction unless the request is to restrict disclosure for purposes of carrying out payment or health care operations, the disclosure is not required by law, and the information pertains solely to a health care item or service for which you (or someone on your behalf) have paid us out of pocket in full. If you wish to request additional restrictions, please obtain a request form from our Privacy Office and submit the completed form to the Privacy Office. We will send you a written response.

C. Right to Receive Communications by Alternative Means or at Alternative Locations

You may request, and we will accommodate, any reasonable written request for you to receive your Protected Health Information by alternative means of communication or at alternative locations.

D. Right to Inspect and Copy Your Health Information

You may request access to your medical record file maintained by us to inspect and request copies of the records. Under limited circumstances, we may deny you access to a portion of your records. If you desire access to your records, please obtain a record request form from the Privacy Office and submit the completed form to the Privacy Office. If you request copies, we may charge you a reasonable copy fee.

E. Right to Amend Your Records

You have the right to request that we amend your Protected Health Information maintained in your medical record file. If you desire to amend your records, please obtain an amendment request form from the Privacy Office and submit the completed form to the Privacy Office. We will comply with your request unless we believe that the information to be amended is accurate and complete or other special circumstances apply.

F. Right to Receive an Accounting of Disclosures

Upon request, you may obtain an accounting of certain disclosures of your Protected Health Information made by us during any time period prior to the date of your request, provided such period does not exceed six years. If you request an accounting more than once during a twelve (12) month period, we may charge you a reasonable fee for the accounting statement.

G. Right to Receive Paper Copy of this Notice

Upon request, you may obtain a paper copy of this Notice, even if you agreed to receive such notice electronically.

VI. Communications and Data Security

WayPax Health uses industry-standard security measures to protect your Protected Health Information. However, you should be aware of the following:

• Submissions over the Internet, including information collected and/or shared via text message (SMS) or automated messages about your treatment or patient account, may not be encrypted and secure. Please consider this before providing sensitive health information via text or other unencrypted channels.
• WayPax Health may send you SMS (text) messages for transactional purposes (such as consultation status updates and provider response notifications) and, with your consent, for marketing and promotional purposes. Standard message and data rates may apply. You may opt out of marketing SMS messages at any time by replying STOP. For help, reply HELP or contact privacy@waypaxhealth.com. See our Terms & Conditions for full SMS consent and opt-out details.
• Video visit sessions, where applicable, may involve the transmission of audio and video data. WayPax Health uses encrypted platforms for video consultations to the extent technically feasible, but cannot guarantee the security of data transmitted over public networks.

VII. Effective Date and Duration of This Notice

A. Effective Date

This Notice is effective on June 23, 2026.

B. Right to Change Terms of this Notice

We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all your Protected Health Information that we maintain, including any information created or received prior to issuing the new notice. If we change this Notice, we will post the new notice on our website at waypaxhealth.com. You may also obtain any new notice by contacting the Privacy Office.

VIII. Privacy Office

You may contact the Privacy Office at: