Effective: October 2, 2026
Notice of Privacy Practices
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.
Who We Are
Halftime Health LLC ("Halftime Health," "we," "us," or "our") is a telehealth platform that connects members with licensed clinicians for clinical evaluation and, where appropriate, the prescribing of compounded medications. Halftime Health is not a medical practice.
Halftime Health LLC is not a HIPAA Covered Entity, because it does not conduct the standard electronic transactions, such as insurance claims, that make a health care provider a Covered Entity. Arora Health (and its affiliated professional entities) is the HIPAA Covered Entity and the practice. Halftime Health is a Business Associate of Arora Health. This Notice describes how Halftime uses and discloses PHI for Arora Health, including the lab results for a one-off blood test that an Arora clinician authorizes and the PHI in Halftime's own electronic medical record, and how you can use your HIPAA rights. GEN Health is Arora Health's electronic medical record vendor. GEN Health is not a medical practice.
This Notice applies to all protected health information (PHI) we create, receive, maintain, or transmit in connection with our services, including PHI in Halftime Health's electronic medical record.
Our Legal Duty
As Arora Health's Business Associate, we are required by law and by our Business Associate Agreement to:
- protect the privacy and security of your protected health information (PHI);
- follow the terms of this Notice; and
- report a breach of unsecured PHI to Arora Health, and make sure you are notified as the law requires.
How We May Use and Disclose Your Health Information
Treatment
We may use and disclose your PHI to provide, coordinate, and manage your health care. For example, we share your intake information and lab results with licensed clinicians at Arora Health, the Covered Entity and the practice for your clinician visit, who review your case, design your personalized protocol plan, and write prescriptions. GEN Health is Arora Health's electronic medical record vendor and is not a medical practice. For a one-off blood test, we send your order to the laboratory under the authorizing clinician's standing order, and we deliver the result to you.
Payment
We may use and disclose your PHI to bill and collect payment for services. This includes sharing information with payment processors to process your subscription and any one-time fees.
Health Care Operations
We may use and disclose your PHI for our internal operations, including quality assessment, training, compliance, and business planning. For example, we may review clinician notes and secure messages to evaluate and improve our clinical protocols.
As Required by Law
We will disclose your PHI when required to do so by federal, state, or local law, including in response to a court order or subpoena.
Public Health Activities
We may disclose your PHI to public health authorities authorized to collect information for the prevention or control of disease, injury, or disability.
Serious Threats to Health or Safety
We may use or disclose your PHI if we believe in good faith that doing so is necessary to prevent or lessen a serious and imminent threat to your health or safety, or the health or safety of the public.
Business Associates
We share PHI with third-party vendors ("Business Associates") who perform services on our behalf, including our pharmacy partners, lab providers, technology vendors, and communication platforms. All Business Associates are contractually required to protect your PHI under a HIPAA-compliant Business Associate Agreement (BAA).
Our current Business Associates include (non-exhaustive):
- Licensed 503A compounding pharmacy (Wellsync/BoomRx — medication dispensing)
- Amazon Web Services (cloud infrastructure)
- Anthropic (AI clinical support, under BAA)
Arora Health is the Covered Entity and the practice for your clinician visit, not a Business Associate of Halftime Health. GEN Health is Arora Health's electronic medical record vendor and a business associate or subprocessor of Arora Health. GEN Health is not a medical practice.
Disclosures We Will Not Make Without Your Authorization
The following uses and disclosures require your written authorization:
- Most uses of psychotherapy notes
- Marketing communications, except those HIPAA allows without an authorization, such as a message about health-related services that Arora Health or Halftime provides
- Sale of your PHI
- Any other use or disclosure not described in this Notice
You may revoke an authorization at any time in writing, except to the extent we have already relied on it.
Your Rights
Right to Access Your PHI
You have the right to inspect and receive a copy of your medical records and other PHI we maintain. Submit a written request to privacy@halftime.health. We will respond within 30 days. A reasonable fee may apply for copies.
Right to Request Amendment
If you believe your PHI is inaccurate or incomplete, you may request an amendment. We may deny the request if we determine the record is accurate and complete, but we will document your request and our response.
Right to an Accounting of Disclosures
You have the right to receive a list of disclosures we made of your PHI in the six years prior to your request (or since our effective date, whichever is shorter), other than disclosures for treatment, payment, health care operations, and certain other exceptions.
Right to Request Restrictions
You may request restrictions on how we use or disclose your PHI for treatment, payment, or health care operations. We are not required to agree to all requests, but we will consider them in good faith.
Right to Request Confidential Communications
You may request that we communicate with you in a specific way (e.g., by email only) or at a specific location. We will accommodate reasonable requests.
Right to a Paper Copy of This Notice
You may request a paper copy of this Notice at any time, even if you previously agreed to receive it electronically.
Right to Be Notified of a Breach
We will notify you if there is a breach of your unsecured PHI, as required by federal law.
Special Protections
State Law
Where applicable state law provides greater privacy protections than HIPAA, we comply with the more protective law.
California Residents (CCPA/CPRA)
California residents have additional rights under the California Consumer Privacy Act and California Privacy Rights Act, including the right to know what personal information we collect, the right to delete personal information, and the right to opt out of the sale or sharing of personal information. See our Privacy Policy for details. Note: PHI subject to HIPAA is exempt from CCPA in certain respects.
Washington Residents (My Health My Data Act)
Washington residents have rights under the My Health My Data Act. PHI that we handle as Arora Health's Business Associate is governed by HIPAA and is exempt from that Act. Our Consumer Health Data Notice and our Privacy Policy explain your rights.
Substance Use Disorder Records
If applicable, records relating to substance use disorder treatment may be subject to additional federal protections under 42 CFR Part 2.
Changes to This Notice
We reserve the right to change the terms of this Notice and to make the new Notice effective for all PHI we maintain. We will post the revised Notice on our website and provide a copy upon request.
Complaints
If you believe your privacy rights have been violated, you may file a complaint with:
Halftime Health Privacy Officer
Email: privacy@halftime.health
Address: 600 W. 6th Street, Suite 400, Fort Worth, TX 76102
U.S. Department of Health and Human Services
Office for Civil Rights
200 Independence Avenue, S.W., Washington, D.C. 20201
1-877-696-6775 | www.hhs.gov/ocr/privacy
You will not be penalized for filing a complaint.
Contact Us
For questions about this Notice or your privacy rights:
Halftime Health LLC
Privacy Officer: privacy@halftime.health
600 W. 6th Street, Suite 400, Fort Worth, TX 76102