NOTICE OF PRIVACY PRACTICES (HIPAA)

Precision OT Network (U.S.)

Effective Date: January 12, 2026

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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 and How to Contact Us

This Notice explains how Brainbot Inc. d/b/a Precision OT Network (“Precision OT Network,” “we,” “our,” or “us”) may use and disclose your protected health information (“PHI”), your rights, and our legal duties under HIPAA and other applicable laws.

If you have questions, want to exercise a right, or want to file a complaint, contact:

• Privacy Contact: Adam Shedletzky
• Email: adam@precisionotnetwork.com
• Phone: +1 (647) 213-6591
• Mail: Precision OT Network, PO Box 75301 Toronto, RPO Leslie Street, Toronto, ON M4M 1B3, Canada

General contact: clinic@precisionotnetwork.com +1 (647) 955-4537

Website: https://www.precisionotnetwork.com/notice-of-privacy-practices-us

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 an electronic or paper copy of your medical record

• You can ask to see or get an electronic or paper copy of your medical 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.
• State-specific timeframes and fee rules may apply (see Appendix A).

Ask us to correct your medical 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’ll tell you why in writing within 60 days.

Request confidential communications

• You can ask us to contact you in a specific way (for example, home or office 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 to your request, 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 for the purpose of payment or our operations with your health insurer.
• We will say “yes” unless a law requires us to share that information.

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 the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make).
• We’ll provide one accounting a year for free but may 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 have agreed to receive the notice electronically. We will provide you with 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.

File a complaint if you feel your rights are violated

• You can complain if you feel we have violated your rights by contacting us using the information above.
• You can file a complaint with the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) by visiting the OCR complaint page or by mail/phone (see “Questions and Complaints” below).
• 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 (we do not create psychotherapy notes as that term is used in HIPAA)

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.

Provide your evaluation services (HIPAA “Treatment”)

• We can use your health information and share it with other professionals as needed to provide, coordinate, or manage your occupational therapy functional evaluation services. (HIPAA uses the term “treatment” to include evaluation and assessment services.)
• Example: A clinician evaluating you for an injury asks another clinician about your overall health condition.

Run our organization

• We can use and share your health information to run our practice, improve your care, and contact you when necessary.
• Example: We use health information about you to manage the services we provide.

Bill for your services

• We can use and share your health information to bill and get payment from health plans or other entities.
• Example: We give information about you to your health insurance plan so it will pay for your services.

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
• Helping with product recalls
• Reporting adverse reactions to medications
• Reporting suspected abuse, neglect, or domestic violence
• Preventing or reducing a serious threat to anyone’s health or safety

Do research

• We can use or share your information for health research, as allowed by law.

Comply with the law

• We will share information about you if state or federal laws require it, including with HHS if it wants to see that we’re complying with federal privacy law.

Respond to organ and tissue donation requests

• We can share health information about you with organ procurement organizations.

Work with a medical examiner or funeral director

• 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
• 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, or in response to a subpoena, as allowed by law.

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.

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 office (if applicable), and on our website.

Questions and Complaints

If you have questions about this Notice, contact our Privacy Contact listed above.

If you believe your privacy rights have been violated, you may file a complaint with us and/or with:

• HHS Office for Civil Rights (OCR): Visit the OCR complaint webpage, call 1-877-696-6775, or mail a complaint to 200 Independence Avenue, S.W., Washington, D.C. 20201.
• State-specific complaint pathways may also be available (see Appendix A).

Special Notes for Precision OT Network

• No recording of telehealth functional evaluations: We do not record telehealth functional evaluations. If recording were ever proposed in the future, it would occur only with your separate written consent.
• De-identified information: We may use de-identified information (which neither identifies you nor can reasonably be used to identify you) for quality assurance and to operate and improve our services and platform.
• Timely records: We furnish records timely and without delays for legal review, and we do not withhold records due to unpaid balances, subject to applicable law and narrow exceptions.

This Notice Applies To

This Notice of Privacy Practices applies to:

• Brainbot Inc. d/b/a Precision OT Network; and
• Our workforce members and affiliated occupational therapists and other clinicians who provide services to you through Precision OT Network and who are required to follow this Notice.

Appendix A — State-Specific Rights and Notices

Some states provide privacy/records rights that are more protective than HIPAA. Where state law provides you with additional rights or limits our ability to use or disclose your information, we will follow the more protective law.

Texas

• Electronic disclosures outside of Treatment/Payment/Health Care Operations (TPO): Texas law generally requires a separate patient authorization for each electronic disclosure of PHI outside of TPO (subject to exceptions).
• Electronic copy of records: If we maintain your record electronically and you request an electronic copy, we will provide it within 15 business days of your written request, unless an exception applies.
• How to complain: In addition to HHS OCR, Texas allows complaints to the Texas Office of the Attorney General regarding certain medical privacy issues, and to the Texas Executive Council of Physical Therapy & Occupational Therapy Examiners regarding license-related complaints.

Florida

• Access to records: Florida law requires records be provided timely, without delays for legal review, and records may not be withheld due to unpaid balances.
• No solicitation/marketing use without written release: Florida law restricts use of patient records for solicitation/marketing without a written release/authorization, subject to limited exceptions.
• Record owner/custodian: In Florida, your treating occupational therapist is typically considered the records owner; Precision OT Network may act as records custodian/administrator on the clinician’s behalf. You may submit record requests through our Privacy Contact and we will coordinate fulfillment.

Nebraska

• Access to records: Nebraska law provides specific timelines for inspection and copies (e.g., inspection typically within 10 business days and copies typically within 30 days of a written request, with limited/no extension beyond the statutory timeframe).
• Fees: Nebraska law may set specific caps/limits on fees for copies (including a per-page limit and a handling fee cap), and may limit charges for search/retrieval.
• Telehealth confidentiality: Nebraska telehealth rules emphasize confidentiality and generally prohibit recording telehealth services without consent.