Asembia Privacy Policy

Asembia shares a commitment with the prescribers utilizing gammaCore® website, who are HIPAA covered entities (collectively "Covered Entities"), to protect the privacy and confidentiality of Protected Health Information (PHI) in accordance with applicable HIPAA regulations. Asembia is also committed to protecting Personally Identifiable Information (PII) submitted by users of the gammaCore website. This Policy is provided by Asembia to help you better understand how we disclose and protect PHI in accordance with the terms of the Business Associate (BA) Agreement and how we protect and use PII. PLEASE NOTE, YOUR USE AND CONTINUED USE OF THE gammaCore WEBSITE CONSTITUTES YOUR UNDERSTANDING AND AGREEMENT WITH THIS PRIVACY POLICY.

Safeguards
Asembia's policy is to maintain the confidentiality of PHI received from or on behalf of clients who are HIPAA Covered Entities and with whom we have executed a BA Agreement in accordance with such Agreements and applicable law. Asembia has implemented appropriate administrative, technical and physical safeguards for protecting the privacy of PHI and PII.

Use and Disclosure of Data
We may use PII and PHI for our management, administration, data aggregation and legal obligations to the extent such use of PII and PHI is permitted or required by the BA Agreement and this Privacy Policy and would not violate HIPAA regulations. We may also share de-identified data and select PII with business partners or potential business partners. No PHI information is shared with business partners or potential business partners, except as otherwise permitted by applicable law and the BA Agreement.

In the event that PII and PHI must be disclosed to a subcontractor or agent, we will ensure that the subcontractor or agent agrees to abide by the same restrictions and conditions that apply to us under the BA Agreement and this Privacy Policy with respect to PII and PHI, including the implementation of reasonable and appropriate safeguards. We may also use PII and PHI to report violations of law to appropriate federal and state authorities, as permitted by the BA Agreement and applicable law.