NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED BY US AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This notice describes the privacy practices of Transdermal Therapeutics (TT).

OUR RESPONSIBILITIES REGARDING YOUR HEALTH INFORMATION

Transdermal Therapeutics is committed to protecting the privacy of your health information.

We are required by law to:

Maintain the privacy of health information about you.
Give you this notice explaining our legal duties and privacy practices with respect to your health information.
Inform you of whom to contact in the case of complaints regarding privacy practices, or an improper disclosure of your health information.

Other than the uses and disclosures of health information described below, we will not use or disclose health information about you without your written authorization. If you do provide such authorization, you may revoke it in writing at any time, except to the extent we have already taken action in reliance on it.

A. Permitted Uses and Disclosures of Treatment, Payment, and Healthcare Operations

We may use and disclose health information about you:

For treatment purposes, including to provide healthcare services to you or to coordinate care with physicians, pharmacists, and other healthcare providers. For example, before filling a prescription for you, we may talk to your physician about other drugs you are taking to avoid harmful drug interactions and to recommend treatment alternatives or to discuss information about your health to ensure the prescribed drug is the correct dosage and is clinically appropriate for you.
For payment purposes, including to bill and collect payment from you, your health plan or a 3rd party for the services you receive. For example, we may need to determine whether you are eligible for health insurance or whether your health plan covers a particular drug. We may also tell your health plan provider information about drugs that have been prescribed for you before filling a prescription to find out whether your plan will cover its cost.
For our healthcare operations, including operating our pharmacy and managing our health programs. For example, we may use health information about you to improve the quality of care you receive, decide whether certain health programs are effective, develop new programs, and provide more cost effective services. We may also use and disclose health information about you for administrative activities, including customer service, cost management, auditing and legal services.
To assist other health plans or providers obtain payment for their services; or in limited circumstances, for purposes of their healthcare operations, but in that case only if they have or have had a relationship with you and the information pertains to that relationship. For example, we may disclose certain health information about you to a new health plan in which you enroll.
To certain contractors we ask to help us provide services to you or to operate our business. For example, we may ask a contractor to send out refill reminders on our behalf, or an accounting firm to audit our books and records. We require these contractors to agree to protect the privacy of any health information they receive in order to perform these services.

We may contact you:

To remind you to refill your prescription or otherwise follow your drug therapy regimen
To tell you about possible treatment option that may be beneficial to you
To tell you about health benefits and services that may be of interest to you

B. Certain Other Permitted Uses and Disclosure

We may also use and disclose health information about you if these circumstances apply:

To a friend or family member who is involved in your care to the extent of their involvement, or to someone who helps pay for your care. This includes disclosure to an organization assisting in disaster relief effort do that your family or those involved in your care can be notified about your condition, status, or location.
If required to do so by federal, state, or local law.
To a health oversight agency for activities related to overseeing the healthcare system, government programs, and complying with laws; such as fraud and abuse investigations and license determinations.
To public health authorities or government authorities for public health purposes, such as reporting adverse events to the Food and Drug Administration.
To an authorized government authority to report incidents of abuse, neglect, or domestic violence.
For legal proceedings in response to a court or administrative order or in certain circumstances a subpoena discovery request or other lawful process.
To comply with laws relating to workers compensation or other similar programs which provide benefits for work related injuries or illness.
For medical research. However, with very limited exceptions; before any health information is disclosed for a research project, the project must be cleared through a special approval process to ensure that the information remains protected.
To coroners, medical examiners or funeral directors to carry out their duties, such as identifying a deceased person or determining the cause of death.
To organizations facilitating organ, eye, or tissue donation or transplantation for donation or transplantation purposes.
To avert a serious and immediate threat to your health and safety or the health and safety of the public or another person.
For specialized government functions such as military or veteran agencies if you receive benefits through them or authorized federal officials for intelligence and other national security activities for provision of protective services to the President or other public officials and to correctional institution or law enforcement officials. If you are an inmate of a correctional institution or under the custody of a law enforcement official in certain circumstances.

C. Your Health Information Rights

You have certain rights regarding health information we maintain about you as described below. Unless otherwise directed below, to exercise any of these rights you must send a request in writing with any additional information to: Transdermal Therapeutics, ATTN: Compliance Officer, 211 Summit Pkwy, Suite 124, Homewood, AL 35209.

Right to Inspect and Copy
You have the right to inspect and copy health information we maintain about you. If you request a copy of the information, we may charge a fee for the costs of copying, mailing-or if you request a summary or explanation of the information, the cost of preparing the summary or explanation. We may deny your request in certain circumstances. If your request is denied, you may ask that we review the denial.

Right to Amend
If you believe that the health information we maintain about you is inaccurate or incomplete, you may ask us to amend it, In your request, you must explain why you believe an amendment is necessary. If we did not create the information, you must explain why you believe the originator of the information is no longer available to amend it. We may deny your request in certain limited circumstances. If so, you may submit a statement disagreeing with the denial, which will be linked to the information in question.

Right to Accounting of Disclosures
You have the right to receive a list of certain non-routine disclosures we make of health information about you. This does not include disclosures described in Section A. In your request for an accounting, you must specify the time period for which you want the accounting. The first list you request in a 12-month period will be free of charge; thereafter we may charge a fee to cover the cost of providing this information to you.

Right to Request Restrictions
You have the right to request a restriction on how we use or disclose health information about you for treatment, payment, or healthcare operations. This includes requesting a restriction on disclosures to someone involved in your care or the payment of your care, such as a family member. If you request a restriction, you must specify what information you want restricted and in what way. We are not required to agree to a requested restriction.

Right to Request Confidential Communications
You have the right to request that we send communications involving health information about you by a certain method of communication or to a certain address. We send drugs and related invoices to you at the address and by the delivery method indicated by you or your prescriber. Collection statements for unpaid invoices will continue to be sent to the primary address. If you wish to receive communication at an alternate address, please notify us at the above address and specify which address and/or alternate delivery method you are requesting. We will accommodate all reasonable requests.

Right to Request a Paper Copy of this Notice
You have the right to obtain a paper copy of this notice at any time, even if you have previously agreed to receive it electronically.

CHANGES TO THIS NOTICE

We reserve the right to change this notice and to make the changes for all health information about you that we maintain; including any health information we collected before we changed the notice.

COMPLAINTS

If you believe your privacy rights have been violated you may file a complaint with the Secretary of the Department of Health and Human Services. To file a complaint against us you must send it in writing to: Transdermal Therapeutics, ATTN: Compliance Officer, 211 Summit Pkwy, Suite 124, Homewood, AL 35209. We will not retaliate against you in any way for filing a complaint and the service you receive from us will be unaltered.

CONTACT INFORMATION

If you have any questions about this notice, please contact Transdermal Therapeutics by telephone at 1-877-581-5444.