Notice of Privacy Practices

Embrace Pathways to Wellness LLC (Massachusetts) and Embrace Pathways Orlando, LLC (Florida)

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.

Effective date: November 1, 2026

Questions or complaints: Ashley Damascena, Privacy Officer — adama@embracepathways.com — (617) 804-2773 (Massachusetts) or (321) 405-2773 (Florida)

This notice applies to all Embrace clinicians, staff, interns and offices in Massachusetts and Florida, and to telehealth services. In this notice, “we,” “us” and “our” mean Embrace Pathways to Wellness LLC and Embrace Pathways Orlando, LLC.

At a glance

Your rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Get a copy of your health record

• You can ask to see or get an electronic or paper copy of your health record and other health information we have about you. Ask us how to do this.
• We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
• Psychotherapy notes kept separately from your record are not included, as the law allows.

Ask us to correct your health record

• You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
• We may say “no” to your request, but we will tell you why in writing within 60 days.

Request confidential communications

• You can ask us to contact you in a specific way (for example, cell phone instead of home phone) or to send mail to a different address.
• We will say “yes” to all reasonable requests.

Ask us to limit what we use or share

• You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree, and we may say “no” if it would affect your care.
• If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information with your health insurer for payment or operations. We will say “yes” unless a law requires us to share it.

Get a list of those with whom we’ve shared information

• You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
• We will include all disclosures except those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We will provide one list a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice

• You can ask for a paper copy of this notice at any time, even if you agreed to receive it electronically. We will give you a paper copy promptly.

Choose someone to act for you

• If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
• We will make sure the person has this authority and can act for you before we take any action.
• For clients under 18, a parent or legal guardian usually exercises these rights, except where Massachusetts or Florida law lets a minor consent to their own care.

File a complaint if you feel your rights are violated

• You can complain if you feel we have violated your rights by contacting our Privacy Officer, Ashley Damascena, at adama@embracepathways.com or (617) 804-2773.
• You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. You may also file a complaint with HHS if you believe your substance use disorder records were used or shared in violation of 42 CFR Part 2.
• We will not retaliate against you for filing a complaint.

Your choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

• Share information with your family, close friends, or others involved in your care
• Share information in a disaster relief situation

If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

In these cases, we never share your information unless you give us written permission:

• Marketing purposes
• Sale of your information
• Most sharing of psychotherapy notes

Fundraising: Embrace does not use your information for fundraising. If that ever changes, we will tell you first, and you can ask us not to contact you again.

Our uses and disclosures

How do we typically use or share your health information? We typically use or share your health information in the following ways.

How else can we use or share your health information? We are allowed or required to share your information in other ways, usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes.

• Help with public health and safety issues: preventing disease; reporting suspected abuse, neglect, or domestic violence; and preventing or reducing a serious threat to anyone’s health or safety.
• Do research: we can use or share your information for health research, under the conditions the law sets.
• Comply with the law: we will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we are complying with federal privacy law.
• Respond to requests from medical examiners or funeral directors: we can share health information with a coroner, medical examiner, or funeral director when an individual dies.
• Address workers’ compensation, law enforcement, and other government requests: for workers’ compensation claims; for law enforcement purposes or with a law enforcement official; with health oversight agencies for activities authorized by law; and for special government functions such as military, national security, and presidential protective services.
• Respond to lawsuits and legal actions: we can share health information about you in response to a court or administrative order. See the state-law protections below.

Stronger protections under Massachusetts and Florida law

Where state law protects your information more than federal law, we follow the stricter rule.

• Therapy communications are privileged. In both states, what you tell your clinician is confidential and privileged. We will not release your records or testimony in response to a subpoena alone. We need your written authorization or a court order.
• Abuse and neglect reporting. We must report suspected abuse or neglect of children, elders, and adults with disabilities. In Massachusetts, reports go to the Department of Children and Families, Elder Protective Services, or the Disabled Persons Protection Commission. In Florida, reports go to the Florida Abuse Hotline.
• Threats of serious harm to others. In Massachusetts, if you communicate an explicit threat to kill or seriously injure a reasonably identified person, we may take reasonable precautions, including warning that person or notifying police (Mass. Gen. Laws c. 123, §36B). In Florida, if you make a specific threat to cause serious bodily injury or death to an identified person and appear able to carry it out, we are required to notify law enforcement and may warn the person (Fla. Stat. §491.0147).
• Risk of serious harm to yourself. We may share information as needed to protect your safety, including contacting emergency services or starting an involuntary evaluation where the law allows (in Florida, under the Baker Act).
• Couples and family therapy. In Florida, when more than one family member is in therapy, each person must agree in writing before confidential information is released.
• HIV test results and other specially protected information. Some information, such as HIV test results and genetic information, has extra protection under state law and is shared only as those laws allow.

Substance use disorder treatment records (42 CFR Part 2)

If we receive or keep records about your substance use disorder treatment from a program covered by federal law (42 U.S.C. 290dd-2 and 42 CFR Part 2), those records have extra protection.

• No use against you in legal proceedings without your consent or a court order. We will not use or share these records, or testimony about what they contain, in any civil, criminal, administrative, or legislative investigation or proceeding against you unless you give specific written consent, or a court issues an order together with a subpoena after notice and a hearing as Part 2 requires.
• Sharing for treatment, payment and operations. If you signed a single consent allowing your Part 2 records to be used for treatment, payment, and health care operations, we may use and share them for those purposes as HIPAA allows, but never for the legal proceedings described above.
• Fundraising. We will not use your Part 2 records for fundraising unless we first give you a clear and conspicuous chance to say no.
• Complaints. You can file a complaint with us or with the HHS Office for Civil Rights if you believe your Part 2 records were used or shared improperly. We will not retaliate against you.

Our responsibilities

• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this notice and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information, see www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

Changes to the terms of this notice

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our offices, and on our website.

Effective date and offices

This notice takes effect on November 1, 2026.

Fax: (617) 221-5680