Notice of Privacy Practices

1. Who We Are

This Notice is issued jointly by the two affiliated medical practices under common ownership and management:

• Dr Benjamin Soffer PLLC — a Florida professional limited liability company licensed to provide medical care to Florida residents.
• Benjamin Soffer DO PC — a New Jersey professional corporation licensed to provide medical care to New Jersey residents.

Both practices are owned and operated by Benjamin Soffer, DO. Patients interact with us through one or more of the following brands: Discreet Ketamine (discreetketamine.com), Tovani Health (tovanihealth.com), and Dr. Ben Soffer (drbensoffer.com). For purposes of this Notice we are referred to collectively as “we,” “us,” or “the practice.”

2. Our Pledge to You

We are required by law to protect the privacy of your protected health information (“PHI”), give you this Notice describing our legal duties and privacy practices with respect to your PHI, and follow the terms of the Notice that is currently in effect.

3. How We May Use and Disclose Your PHI Without Your Authorization

The following categories describe the routine ways we are permitted to use and disclose PHI without specific written authorization from you:

• Treatment. We may use your PHI to provide, coordinate, or manage your care. Example: sending your prescription to a pharmacy that fills the medication.
• Payment. We may use your PHI to bill and receive payment for the care we provide. Example: processing your credit card payment through our payment processor.
• Healthcare Operations. We may use your PHI for our internal operations. Example: improving our intake questionnaire, training, quality review, conducting risk assessments, contacting you about appointment availability.
• Appointment Reminders & Treatment Communications. We may contact you by email, phone, or SMS about appointments, prescription renewals, and clinical follow-ups.
• Required by Law. We will disclose PHI when required by federal, state, or local law (e.g., reporting of certain communicable diseases, child or elder abuse, court orders, subpoenas).
• Public Health. Disclosures to public health authorities for purposes such as preventing or controlling disease, injury, or disability.
• Health Oversight. Disclosures to government agencies that oversee the healthcare system.
• Workers' Compensation. Disclosures as authorized by workers' compensation laws if applicable.
• To Avert a Serious Threat. Disclosures necessary to prevent a serious threat to your health or safety or that of another person.

4. Uses and Disclosures That Require Your Written Authorization

The following uses require your written authorization, which you may revoke in writing at any time:

• Marketing communications beyond ordinary treatment-related communications.
• Sale of PHI. We do not sell PHI; if we ever did it would require your written authorization.
• Most uses or disclosures of psychotherapy notes (we currently do not maintain separately-protected psychotherapy notes).
• Patient testimonials, case studies, or success stories that identify you. We never publish a patient's name, photo, or identifying details on our website or in marketing without your specific written authorization. (Reviews you choose to post on third-party platforms such as Google are public submissions made by you, not by us.)
• Any other use or disclosure not described in this Notice or otherwise permitted by law.

5. Your Rights Regarding Your PHI

You have the following rights with respect to PHI we maintain about you. You may exercise any of these rights by contacting us using the information in §9:

• Right to Access. You have the right to inspect and obtain a copy of your PHI, in paper or electronic form, with limited exceptions. We will respond within 30 days.
• Right to Amend. You may request that we amend PHI you believe to be incorrect or incomplete. We may deny your request in certain circumstances; if we do, we will explain why.
• Right to an Accounting of Disclosures. You may request a list of certain disclosures we have made of your PHI.
• Right to Request Restrictions. You may request restrictions on how we use or disclose your PHI for treatment, payment, or healthcare operations. We are not required to agree, except for disclosures to a health plan for services you paid for out of pocket in full, where we will agree.
• Right to Confidential Communications. You may request that we communicate with you only at a specific phone number or email address. We will accommodate reasonable requests.
• Right to a Paper Copy. You have the right to a paper copy of this Notice on request, even if you have agreed to receive it electronically.
• Right to be Notified of a Breach. You have the right to be notified following any breach of unsecured PHI as required by federal and state law.
• Right to File a Complaint. You may file a complaint with us (§9) or with the U.S. Department of Health and Human Services Office for Civil Rights without retaliation.

6. Our Duties

• We are required by law to maintain the privacy and security of your PHI.
• We will let you know promptly if a breach of unsecured PHI may have compromised your privacy.
• We must follow the duties and privacy practices described in this Notice and give you a copy.
• We will not use or share your PHI other than as described here unless you tell us we can in writing.

7. Changes to This Notice

We may change the terms of this Notice at any time. The new Notice will apply to all PHI we maintain. The current Notice is posted on our websites and a paper copy is available on request. The effective date of the latest revision is shown at the top of this page.

8. How to File a Complaint

If you believe your privacy rights have been violated you may file a complaint with us using the contact information in §9. You may also file a complaint with the United States Department of Health and Human Services, Office for Civil Rights:

• Online: www.hhs.gov/ocr/privacy/hipaa/complaints/
• By mail: U.S. Department of Health and Human Services, Office for Civil Rights, 200 Independence Avenue SW, Room 509F HHH Building, Washington, DC 20201
• By phone: 1-877-696-6775

We will not retaliate against you for filing a complaint.

9. Contact Us

For questions, requests, or complaints about this Notice or about how your PHI is handled:

• HIPAA Privacy & Security Officer: Benjamin Soffer, DO
• Email: support@discreetketamine.com
• Phone: 561-468-6981

10. Acknowledgment

By initiating care with the practice, you acknowledge that you have been provided with this Notice. A signed acknowledgment is captured through our online intake flow and stored as a signed PDF in your patient record.