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Notice of Privacy Practices

Effective Date: 7/7/2025

This Notice describes how medical and health information about you may be used and disclosed and how you can access this information. Please review it carefully.

1. Our Legal Duty

Reframe (“we,” “us,” “our”) is committed to protecting your health information. We create and maintain records about you and your use of Ultra We are required by law to:

  • Maintain the privacy and security of your protected health information (“PHI”)
  • Provide you with this Notice explaining our legal duties and privacy practices
  • Notify you promptly if a breach occurs that compromises the privacy or security of your PHI
  • Follow the practices described in this Notice

2. What Information We Collect

When you use Ultra, we may collect health information about you, including:

  • Biometric signals (e.g., heart rate variability, glucose readings, sleep data)
  • Lab results from third-party labs
  • Health-related goals and habits you share with us
  • Coaching session notes

This information is called Protected Health Information (PHI).

3. How We May Use and Share Your PHI

We are permitted to use and share your PHI in these ways:

Treatment

To provide coaching services to you, including reviewing your biometric and lab data, and communicating recommendations.

Payment

To bill you or collect payment for services provided.

Healthcare Operations

For activities necessary to operate Ultra, such as:

  • Quality assessment
  • Staff training
  • Customer service
  • Internal administration

We may also share your PHI without your written authorization in limited situations, including:

  • Public health reporting (e.g., to prevent disease)
  • Health oversight activities (e.g., audits, investigations)
  • As required by law (e.g., in response to a valid court order)
  • To prevent a serious threat to health or safety
  • To comply with workers’ compensation laws

All other uses and disclosures of PHI require your written authorization. If you give authorization, you may revoke it at any time in writing.

4. Your Rights

You have the following rights regarding your PHI:

Right to Inspect and Copy

You may request to see or get a copy of your PHI. We may charge a reasonable fee for copies.

Right to Amend

You may request corrections to your PHI if you believe it is inaccurate or incomplete.

Right to an Accounting of Disclosures

You may ask for a list of times we shared your PHI for purposes other than treatment, payment, or healthcare operations.

Right to Request Restrictions

You may ask us not to use or share certain PHI. We are not required to agree, but will consider your request.

Right to Request Confidential Communications

You may ask us to contact you in a specific way (e.g., via email) or to send mail to a different address.

Right to Receive a Copy of This Notice

You can request a paper copy of this Notice at any time.

5. Our Responsibilities

We are required by law to:

  • Maintain the privacy of your PHI
  • Provide this Notice describing our legal duties and privacy practices
  • Notify you if a breach occurs that affects the security of your PHI
  • Follow the terms of this Notice

6. Changes to This Notice

We reserve the right to change this Notice at any time. If we make significant changes, we will update the effective date and post the new Notice on our website and app. The revised Notice will apply to all PHI we maintain.

7. Complaints

If you believe your privacy rights have been violated, you can file a complaint with us or with the U.S. Department of Health & Human Services. We will not retaliate against you for filing a complaint.

To file a complaint with us or request more information, contact:

Privacy Officer
Reframe Ultra
Email: support.ultra@reframeapp.com
Mailing Address: 6120 Windward Pkwy, #165, Alpharetta Ga 30005
Phone: +14044800022

To file a complaint with the Department of Health and Human Services:

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

8. Contact Information

If you have any questions about this Notice, please contact our Privacy Officer:

Email: support.ultra@reframeapp.com
Phone: +14044800022
Mailing Address: 14675 Timber Point
Alpharetta, GA 30004, US

Acknowledgment of Receipt

We may ask you to sign an acknowledgment confirming you received this Notice.