HIPAA Notice
Read the HIPAA Notice of Privacy Practices for Keen, operated by Keen Meds Inc. Learn how your health information is used, disclosed, and protected, and understand your patient rights.
Overview
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.
IF YOU HAVE QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT US AT support@livekeen.co.
1. Who Is Covered by This Notice
This Notice of Privacy Practices ("Notice") is issued by the HIPAA-covered entity that provides clinical services through the Keen platform. This Notice applies to all Protected Health Information ("PHI") created, received, maintained, or transmitted in connection with the healthcare services you receive through the Platform.
The following entities are involved in your care and are bound by obligations to protect your health information:
- Keen Meds Inc. ("Keen," "Keen Meds," "we," "us," or "our") is a Delaware corporation that operates the technology platform at livekeen.co. "Keen" is the brand name under which Keen Meds Inc. operates. Keen Meds serves as a Business Associate to our affiliated medical practice under a Business Associate Agreement ("BAA") and processes PHI solely as permitted by that agreement, HIPAA, and applicable law. Keen Meds provides the technology infrastructure, membership management, billing, customer support, intake coordination, and product fulfillment logistics.
- Our affiliated medical practice is the HIPAA-covered entity responsible for the medical care you receive, including telehealth consultations, clinical assessments, prescribing decisions, and maintenance of your medical records. The medical practice employs or contracts with licensed clinicians who deliver your care.
- Our partner pharmacy is a licensed 503A compounding pharmacy that compounds, verifies, dispenses, and ships prescription medications pursuant to valid, patient-specific prescriptions. The pharmacy also serves as a Business Associate and is bound by a BAA governing its handling of PHI.
The specific medical practice and pharmacy entities are identified in Section 9 (Contact Information) of this Notice.
2. Our Commitment to Your Privacy
Our affiliated medical practice and its Business Associates understand that your medical information is personal and sensitive. We are required by law to maintain the privacy of your PHI, to provide you with this Notice of our legal duties and privacy practices with respect to your PHI, and to abide by the terms of this Notice currently in effect. We are committed to protecting the confidentiality of your health information while providing you with quality telehealth services.
3. How We May Use and Disclose Your Health Information
Under HIPAA, we are permitted to use and disclose your PHI without your written authorization for the following purposes:
3.1 Treatment
We may use and disclose your PHI to provide, coordinate, and manage your healthcare and related services. This includes sharing information among our affiliated medical practice's clinicians, Keen Meds (for care coordination and intake processing), and our partner pharmacy (for prescription compounding and fulfillment). For example, a clinician may access your health intake responses and lab results to make prescribing decisions, and your prescription information is shared with our partner pharmacy to compound and ship your medication.
3.2 Payment
We may use and disclose your PHI to bill and collect payment for the healthcare services and products you receive. This includes activities such as processing membership billing, issuing invoices, and managing collections for unpaid balances. Note: Keen does not accept or bill health insurance. All services and products are paid for directly by the patient.
3.3 Healthcare Operations
We may use and disclose your PHI for activities that support our healthcare operations and ensure the quality and efficiency of the care you receive. These activities include quality assessment and improvement, clinical audits, staff training, credentialing of clinicians, compliance monitoring, fraud and abuse detection, and business planning.
3.4 Appointment and Refill Reminders
We may use your PHI to contact you with reminders about upcoming telehealth consultations, follow-up appointments, required laboratory work, or prescription refill schedules.
3.5 Health-Related Benefits and Services
We may use your PHI to inform you about treatment alternatives, health-related benefits, or services that may be relevant to your care.
3.6 Business Associates
We may disclose your PHI to our Business Associates, including Keen Meds Inc. (technology platform and coordination services) and our partner pharmacy (prescription compounding and fulfillment), who perform functions on behalf of or provide services to our affiliated medical practice. Each Business Associate is contractually required to safeguard your PHI and is permitted to use or disclose it only as authorized by the BAA, HIPAA, and applicable law.
3.7 As Required by Law
We may use or disclose your PHI when required to do so by federal, state, or local law, including laws that require reporting of certain types of wounds, injuries, or diseases.
3.8 Public Health Activities
We may disclose your PHI to public health authorities for purposes such as preventing or controlling disease, injury, or disability; reporting births and deaths; reporting adverse reactions to medications; notifying individuals of potential exposure to communicable diseases; and notifying the appropriate government authority if we believe a patient is a victim of abuse, neglect, or domestic violence.
3.9 Health Oversight Activities
We may disclose your PHI to a health oversight agency for activities authorized by law, including audits, investigations, inspections, licensure actions, and other proceedings necessary for the government to monitor the healthcare system, government programs, and compliance with applicable laws.
3.10 Judicial and Administrative Proceedings
We may disclose your PHI in response to a court order, subpoena, discovery request, or other lawful process, subject to all applicable legal requirements and limitations.
3.11 Law Enforcement Purposes
We may disclose your PHI for law enforcement purposes as required by law or in response to a valid court order, warrant, summons, subpoena, or similar process, or as otherwise permitted under HIPAA.
3.12 Coroners, Medical Examiners, and Funeral Directors
We may disclose your PHI to a coroner, medical examiner, or funeral director as necessary to carry out their duties under applicable law.
3.13 Research
We may use or disclose your PHI for research purposes when the research has been approved by an institutional review board or privacy board that has reviewed the research proposal and established protocols to ensure the privacy of your information, or when the research involves only de-identified information.
3.14 Serious Threats to Health or Safety
We may use or disclose your PHI when we believe, in good faith, that disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.
3.15 Specialized Government Functions
We may disclose your PHI for specialized government functions, including military and veterans' activities, national security and intelligence activities, protective services for the President, and medical suitability determinations for the Department of State.
3.16 Workers' Compensation
We may disclose your PHI as authorized by, and to the extent necessary to comply with, workers' compensation laws and other similar programs.
3.17 Correctional Institutions
If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may disclose your PHI to the correctional institution or law enforcement official as necessary for your health and safety, the health and safety of others, or the safety and security of the institution.
5. Your Rights Regarding Your Health Information
You have the following rights with respect to your PHI. To exercise any of these rights, please submit a written request to support@livekeen.co or by mail to the address listed in Section 9 below.
5.1 Right to Inspect and Copy
You have the right to inspect and obtain a copy of your PHI maintained in a designated record set, including medical records, billing records, and other records used to make decisions about your care. We may charge a reasonable, cost-based fee for copies as permitted by HIPAA and applicable state law. We will respond to your request within thirty (30) days. In certain limited circumstances, we may deny your request, and if we do, we will provide you with a written explanation of the denial and information about your right to request a review of the denial.
5.2 Right to Amend
You have the right to request an amendment to your PHI if you believe the information in your records is incorrect or incomplete. Your request must be in writing and must provide a reason supporting your request. We will respond within sixty (60) days. We may deny your request if the information was not created by us, is not part of the designated record set, is not available for inspection, or is already accurate and complete. If we deny your request, we will provide you with a written explanation and your right to submit a statement of disagreement.
5.3 Right to an Accounting of Disclosures
You have the right to request an accounting of certain disclosures of your PHI made by us during the six (6) years prior to your request (or a shorter period if you specify). This accounting will not include disclosures made for treatment, payment, or healthcare operations; disclosures made directly to you; disclosures made pursuant to your authorization; or certain other disclosures permitted by HIPAA. We will respond to your request within sixty (60) days. The first accounting in any twelve-month period will be provided free of charge; we may charge a reasonable fee for subsequent requests.
5.4 Right to Request Restrictions
You have the right to request that we restrict the use or disclosure of your PHI for treatment, payment, or healthcare operations, or restrict disclosures to individuals involved in your care or payment for your care. We are not required to agree to your request, except that we must agree to restrict disclosure of your PHI to a health plan for payment or healthcare operations purposes if you paid for the service or item out of pocket in full. To request a restriction, provide your request in writing specifying the information you wish restricted and to whom the restriction applies.
5.5 Right to Request Confidential Communications
You have the right to request that we communicate with you about your health information by alternative means or at alternative locations. For example, you may request that we contact you only at a specific phone number or send correspondence to a different address. We will accommodate reasonable requests. Your request must be in writing and must specify the alternative method or location for communication.
5.6 Right to a Paper Copy of This Notice
You have the right to obtain a paper copy of this Notice at any time, even if you previously agreed to receive it electronically. To obtain a paper copy, contact us at support@livekeen.co.
5.7 Right to Be Notified of a Breach
You have the right to be notified if there is a breach of your unsecured PHI. A breach is an unauthorized acquisition, access, use, or disclosure of your PHI that compromises the security or privacy of the information. In the event of a breach, we will notify you in accordance with the HIPAA Breach Notification Rule (45 C.F.R. Part 164, Subpart D) and applicable state breach notification laws. Notification will be made without unreasonable delay and in no event later than sixty (60) calendar days from the date the breach is discovered.
6. Our Duties
We are required by law to:
- Maintain the privacy of your PHI and provide you with this Notice of our legal duties and privacy practices.
- Abide by the terms of this Notice currently in effect.
- Notify you if we are unable to agree to a requested restriction on how we use or disclose your PHI.
- Accommodate reasonable requests for confidential communications.
- Notify you in the event of a breach of your unsecured PHI.
- 7. Changes to This Notice
We reserve the right to change the terms of this Notice at any time. Any revised Notice will be effective for all PHI we maintain at that time, including information created or received before the revision. If we make a material change to this Notice, we will:
- Post the revised Notice on the Platform at livekeen.co/hipaa-notice.
- Make the revised Notice available upon request.
- Communicate material changes through the Platform or via email to the address associated with your account.
The effective date of the current Notice is listed at the top of this document.
8. Complaints
If you believe that your privacy rights have been violated, you have the right to file a complaint. You will not be penalized, retaliated against, or otherwise disadvantaged for filing a complaint.
To file a complaint with Beluga Health P.A.:
Contact the Beluga Health Privacy Officer at privacy@belugahealth.com.
To file a complaint with Keen Meds:
Contact us at privacy@livekeen.co or legal@livekeen.co, or write to:
- Keen Meds Inc.
- Attn: Privacy Compliance
- 1550 Wewatta Street, Suite 200
- Denver, CO 80202
To file a complaint with the U.S. Department of Health and Human Services:
- Office for Civil Rights (OCR)
- U.S. Department of Health and Human Services
- 200 Independence Avenue, S.W.
- Washington, D.C. 20201
Complaint Portal: ocrportal.hhs.gov
Toll-Free: 1-877-696-6775
Email: ocrcomplaint@hhs.gov
9. Contact Information
For questions about this Notice, to exercise any of your privacy rights, or for privacy-related concerns:
Beluga Health P.A. Privacy Officer
Email: privacy@belugahealth.com
Keen Meds Inc.
1550 Wewatta Street, Suite 200
Denver, CO 80202
Email: support@livekeen.co
Privacy Inquiries: privacy@livekeen.co
Legal Inquiries: legal@livekeen.co
General Questions: ask@livekeen.co
Website: livekeen.co