FitCam Health Privacy Policy and HIPAA Privacy Notice

Effective date: September 30, 2026

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.

1. Who we are and how HIPAA applies

Prove Labs Inc., doing business as FitCam Health ("FitCam," "we," "us"), operates the FitCam Care Coach program and the FitCam Health app. The program provides Remote Therapeutic Monitoring (RTM) and Chronic Care Management (CCM) services. Registered nurse care coaches employed by FitCam deliver these services under the direction and supervision of your treating physician or clinic ("your provider").

You can join the FitCam Care Coach program only through a referral from your provider.

Your provider is a "covered entity" under the Health Insurance Portability and Accountability Act (HIPAA). FitCam works on your provider's behalf as a "business associate." This means:

Your provider's own Notice of Privacy Practices also applies to you, and you can ask your provider for a copy.
We use and disclose your Protected Health Information (PHI) only as our written agreement with your provider and HIPAA allow.
When you make a privacy request to us, we act on it or forward it to your provider so it can be handled within the time HIPAA requires.

2. Our responsibilities

We are required by law to protect the privacy and security of your PHI.
We will notify your provider, and you will be notified, if a breach occurs that may have compromised your PHI.
We use and disclose only the minimum PHI needed for each purpose.
We will not use or share your information other than as described here unless you give us written permission. You may revoke that permission in writing at any time, except for actions already taken in reliance on it.

3. How we use and disclose your health information

Treatment. To monitor your therapy and symptoms, coach you, build and update your care plan, and share information with your provider and care team.

Example: your RN care coach reviews your exercise and pain check-ins and alerts your physician to a change.

Payment. To document the time and services required so your provider can bill Medicare, Medicaid, or your health plan for RTM and CCM services.

Example: we record the minutes your care coach spends with you each month so your provider can submit an accurate claim.

Health care operations. To run and improve the program: quality review, nurse training and supervision, audits, compliance, and creating de-identified or aggregated data.

Other uses allowed or required by law. We may disclose PHI when required by law, including for public health and safety, reporting suspected abuse or neglect, health oversight audits, lawsuits and court orders, law enforcement requests that meet legal requirements, preventing a serious threat to health or safety, workers' compensation, and to the U.S. Department of Health and Human Services (HHS) to show compliance.

Family and caregivers. With your agreement, or if you do not object, we may share information with a family member or caregiver involved in your care.

4. Uses that require your written authorization

We will never do the following without your written authorization:

Sell your PHI
Use or share your PHI for marketing
Use your health information for advertising, including targeted or third-party advertising
Share psychotherapy notes (FitCam does not create these)

We do not place third-party advertising or tracking pixels in the logged-in areas of the app or patient portal.

5. Your rights

Get a copy of your records. Inspect or receive a paper or electronic copy of your health information, usually within 30 days. A reasonable, cost-based fee may apply.
Ask us to correct your records. Request a correction if you think information is wrong or incomplete. If we decline, we will tell you why in writing.
Request confidential communications. Ask us to contact you a specific way (for example, a different phone number or mailing address). We will agree to reasonable requests.
Ask us to limit what we use or share. Request limits on use or sharing for treatment, payment, or operations. We are not required to agree, except we must agree not to share with your health plan for a service you paid for in full out of pocket, unless the law requires it.
Get a list of disclosures. Receive a list of certain disclosures made in the past six years, free once every 12 months.
Get a copy of this notice. Request a paper copy at any time, even if you agreed to receive it electronically.
Choose someone to act for you. A legal guardian or person with medical power of attorney can exercise your rights.
Be notified of a breach. You will be notified if your unsecured PHI is breached.
File a complaint. See section 6.

To use any of these rights, contact us using the details in section 17. We will respond directly or coordinate with your provider.

6. Complaints

If you believe your privacy rights have been violated, you may file a complaint with us at contact@fit.cam or with the HHS Office for Civil Rights at hhs.gov/ocr/complaints, 1-877-696-6775, or 200 Independence Avenue SW, Washington, DC 20201. We will not retaliate against you for filing a complaint.

7. Changes to this notice

We may change this notice, and the changes will apply to all information we hold about you. The current version and its effective date will always be posted in the app and at fit.cam. We will notify you in the app or by email of material changes.

8. Information we collect

From you and your provider: name, date of birth, sex, contact details, insurance and Medicare information, diagnoses and care plan, medications, and visit information your provider shares with us.

Through the program: pain and symptom check-ins, exercise and therapy adherence, messages and chat with your care coach, notes from phone and video calls, and the time spent on your care.

From connected devices and apps, with your permission: activity data such as steps from Apple Health or Google Health Connect, and workout performance. When you use your camera for exercise feedback, the video is used only in real time and is not stored. You can turn these connections off in your phone's settings at any time. Health data from Apple Health or Google Health Connect is never used for advertising or sold.

Automatically: device type, operating system, app version, IP address, crash logs, and in-app usage, used to keep the app secure and working.

9. Artificial intelligence in your care

FitCam uses artificial intelligence (AI) tools to help our clinical team work efficiently. For example, AI may help draft a summary of your care plan or estimate how engaged you are with your therapy, so your care coach and provider can follow up with you sooner.

A licensed clinician reviews AI-assisted content before it is used in your care. AI does not diagnose you or make treatment decisions.
AI vendors that process PHI do so under a Business Associate Agreement and may not use your information to train their own models.
You can ask your care coach how AI was used in your care, or ask that we not use AI-assisted tools for your care where a manual alternative is available.

10. Who we share information with

Your provider and care team, for treatment, payment, and operations.
Service providers that help us run the program, such as secure cloud hosting, phone and text messaging, video visits, and EHR connections. Each signs a Business Associate Agreement that requires it to protect your information.
De-identified data: we may create data that meets HIPAA's de-identification standard (45 CFR 164.514) to measure and improve the program and for research. We do not attempt to re-identify it.
Legal and safety reasons, as described in section 3.
Business transfers: if FitCam is part of a merger or sale, your information would transfer only under the same protections described here.

11. Calls, text messages, and email

By enrolling in the FitCam Care Coach program and giving us your phone number, you agree to receive calls and text messages from FitCam Health or on its behalf about your care, including check-ins, appointment reminders, and program updates. Message frequency varies. Message and data rates may apply.

Reply STOP to any text to opt out of texts. Reply HELP for help.
To change how we contact you (phone, text, email, app notifications, or mail), email contact@fit.cam or tell your care coach.
Mobile carriers are not liable for delayed or undelivered messages.
Your mobile number, text-message opt-in, and consent are never shared with or sold to third parties or affiliates for marketing or promotional purposes. We share your number only with the messaging provider that delivers our texts.

Text messages and email are not fully secure. By choosing to communicate this way, you accept that risk; you may request a different method at any time.

12. How we protect your information

We use administrative, technical, and physical safeguards required by the HIPAA Security Rule, including encryption in transit and at rest, role-based access, staff training, and audit logs. No system is completely secure. If a breach occurs, we will act promptly to contain it and notify affected individuals and your provider as required by law.

13. How long we keep information

We keep records of the services we provide for at least 10 years from the date of service. This meets Medicare and Medicare Advantage record-keeping requirements and the medical-record laws of the states where we operate. If our agreement with your provider ends, we return your PHI to your provider or securely destroy it as that agreement requires. Any copy we must keep to meet a legal record-keeping obligation stays protected under this policy and is used only for that purpose.

14. State privacy rights

Depending on where you live, state law may give you additional rights, such as stronger protections for consumer health data. We honor these rights as required. Contact us to make a request.

15. Children

The FitCam Care Coach program and app are for adults 18 and older. We do not knowingly collect information from children.

16. Terms of Use

Use of the app is also governed by our Terms of Use. FitCam Health supports, but does not replace, care from your physician. In an emergency, call 911.

17. Contact us

FitCam Health (Prove Labs Inc.)
Privacy Officer: Jeremie Leroyer
174 MacDonough Street, Brooklyn, NY 11216
Email: contact@fit.cam
Phone: (917) 268-7568