OUR PRIVACY OBLIGATIONS

We understand that your health information is personal, and we at Lotus Health Medical Inc. (“we” or “us”) are committed to protecting your privacy. This Notice of Privacy Practices (“Notice”) applies to the medical records and other protected health information that we maintain about you (“PHI”). Your PHI may consist of paper, digital, or electronic records but could also include photographs, videos, and other electronic transmissions or recordings that are created during your care and treatment.

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 notify you in the event of a breach of your unsecured PHI. When we use or disclose your PHI, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).

CHANGES TO 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 PHI 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 www.lotushealth.ai. You also may obtain any new notice by contacting us using the contact information at the end of this Notice.

PERMISSIBLE USES AND DISCLOSURES WITHOUT YOUR WRITTEN AUTHORIZATION

We typically use and disclose your PHI without your written authorization in the following ways:

• Treatment. We use and disclose your PHI to provide treatment and other services to you. For example, we may use your information to direct or recommend alternative treatments, therapies, health care providers, or settings of care to you or to describe a health-related product or service. We may also disclose PHI to other providers involved in your treatment.

• Payment. We may use and disclose your PHI to obtain payment for health care services that we provide to you. For example, we may disclose PHI to claim and obtain payment from Medicare, Medicaid, your health insurer, HMO, or other company or program that arranges or pays the cost of your health care. We may also disclose PHI to your other health care providers when such PHI is required for them to receive payment for services they render to you.

• Health Care Operations. We may use and disclose your PHI for our health care operations, which include internal administration and planning and various activities that improve the quality and cost-effectiveness of the care that we deliver to you. For example, we may use PHI to evaluate the quality and competence of our health care providers or to resolve any complaints you may have and ensure that you are satisfied with our services.

We are allowed or required to disclose your PHI 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 disclose your information for these purposes, which may include:

• Disclosure to Business Associates. We also may disclose your PHI with certain of our “business associates” or other third parties that perform various activities (e.g., billing, coordinating care, transcribing records) for us. We contractually require our business associates to implement safeguards to protect the privacy of your PHI.

• Disclosure to Relatives, Close Friends, and Other Caregivers. We may use or disclose your PHI to a family member, other relative, a close 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 (e.g., when we receive a telephone call from a family member or other caregiver), we may exercise our professional judgment to determine whether a disclosure is in your best interest. If we disclose information under such circumstances, we would only disclose information that is directly relevant to the person’s involvement with your care.

• As Required by Law. We may use and disclose your PHI when required to do so by any applicable federal, state, or local law.

• Public Health Activities. We may disclose your PHI: (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.

• Victims of Abuse, Neglect or Domestic Violence. We may disclose your PHI 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.

• Health Oversight Activities. We may disclose your PHI to an agency that oversees the health care system and is charged with responsibility for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.

• Judicial and Administrative Proceedings. We may disclose your PHI in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.

• Law Enforcement Officials. We may disclose your PHI to the police or other law enforcement officials as required by law or in compliance with a court order.

• Decedents. We may disclose your PHI to a coroner or medical examiner as authorized by law.

• Organ and Tissue Procurement. We may disclose your PHI to organizations that facilitate organ, eye or tissue procurement, banking, or transplantation.

• Clinical Trials and Other Research Activities. We may use and disclose your PHI 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 PHI may be disclosed without your authorization to researchers preparing to conduct a research project, for research or decedents or as part of a data set that omits your name and other information that can directly identify you.

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

• Specialized Government Functions. We may use and disclose your PHI to units of the government with special functions, such as the U.S. military or the U.S. Department of State under certain circumstances.

• Workers’ Compensation. We may disclose your PHI as authorized by and to the extent necessary to comply with state law relating to workers’ compensation or other similar programs.

Some state and federal laws may apply more stringent privacy protections to certain health information about you, such as mental health or developmental disability treatment information or substance use disorder records. We must obtain your consent or authorization in order to use such information for a purpose unless otherwise permitted by law.

USES AND DISCLOSURES REQUIRING YOUR WRITTEN AUTHORIZATION

For any purpose other than the ones described above, we only use or disclose your PHI when you give us your written authorization. Notably:

• Marketing. We must obtain your written authorization prior to using your PHI for purposes that are marketing under the HIPAA privacy rules. For example, we will not accept any payments from other organizations or individuals in exchange for making communications to you about treatments, therapies, health care providers, settings of care, case management, care coordination, products, or services unless you have given us your authorization to do so, or the communication is permitted by law.

• Sale of PHI. We will not make any disclosure of PHI that is a sale of PHI without your written authorization.

• 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.

If you provide us with authorization to use or disclose your PHI and later change your mind, you may revoke your authorization by delivering a written revocation statement to us using the contact information at the end of this Notice. However, your revocation will not have any effect on uses or disclosures we made in reliance on your authorization prior to receiving your written revocation statement.

USE AND DISCLOSURE OF PHI RELATED TO REPRODUCTIVE HEALTHCARE

HIPAA provides special protections for PHI related, or potentially related, to reproductive

healthcare. Where the reproductive healthcare (a) is lawful under the laws of the state where

it was provided, (b) is protected, required, or authorized by federal law (regardless of the

state in which it was provided), or (c) was provided by a person other than us, HIPAA

prohibits us from using or disclosing PHI related, or potentially related, to such reproductive

healthcare in furtherance of an investigation or imposing of liability on any person for the

mere act of seeking, obtaining, providing, or facilitating reproductive healthcare. If we

receive a request for PHI related to reproductive healthcare, a signed attestation may be

required.

YOUR INDIVIDUAL RIGHTS

When it comes to your PHI, you have certain rights. This section explains your rights and

some of our responsibilities to help you.

• Right to Request Additional Restrictions. You may request restrictions on our use and

  disclosure of your PHI (1) for treatment, payment 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 with payment related to 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 for additional

  restrictions carefully, we are not required to agree to a requested restriction unless

  the request is to restrict our disclosure to a health plan 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 other than the health plan) have paid us out of pocket in full. If you

  make a request, we will send you a written response.

• 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.

• Right to Inspect and Copy Your Health Information. You may request access to your

  medical record file and billing records maintained by us in order 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

  contact us using the contact information at the end of this Notice. If you request

  copies, we may charge you a reasonable copy fee.

• Right to Amend Your Records. You may request that we amend your PHI maintained

  in your medical record file or billing records. We will comply with your request unless

  we believe that the information that would be amended is accurate and complete or

  other special circumstances apply.

• Right to Receive an Accounting of Disclosures. You may request an accounting of

  certain disclosures of your PHI made by us during any period of time 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.

• 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.

FOR ADDITIONAL INFORMATION AND COMPLAINTS

If you desire additional information about your privacy rights, disagree with a decision that

we made about access to your PHI, or are concerned that we have violated your privacy

rights, you may contact us using the contact information at the end of this Notice. You may

also file written complaints with the Office for Civil Rights of the U.S. Department of Health

and Human Services (“OCR”). Upon request, we will provide you with the correct contact

information for OCR. We will not retaliate against you if you file a complaint with us or OCR.

Contact Us:

You may contact us at:

Lotus Health Medical Inc.

440 N Barranca Ave #4094, Covina, CA 91723

support@lotushealth.ai