SMS Messaging Policy

1. Introduction

This SMS Messaging Policy ("Policy") describes how Linear Health, Inc. ("Linear Health," "we," "us," or "our") collects, uses, and protects information in connection with SMS and text messaging services provided through our HIPAA-compliant healthcare communication platform on behalf of participating healthcare providers ("Providers").

Linear Health operates as an Independent Software Vendor (ISV) providing healthcare communication technology that enables Providers to send and receive SMS/MMS text messages to and from their patients and clients ("Recipients" or "you"). This Policy applies to all text messaging services facilitated through the Linear Health platform.

By opting in to receive text messages from a Provider using the Linear Health platform, you agree to the terms of this Policy.

2. Mobile Information Privacy

2.1 No Sharing for Marketing Purposes

Your mobile phone number and SMS opt-in data will NOT be shared with third parties or affiliates for marketing or promotional purposes. This is a core commitment of our platform.

Specifically:

• We do not sell your mobile phone number or opt-in information to any third party
• We do not share your mobile information with affiliates for marketing purposes
• We do not use your mobile information for lead generation
• We do not permit Providers to share your opt-in data with third parties for marketing

2.2 Permitted Disclosures

We may disclose your mobile information only in the following limited circumstances:

• To the Provider from whom you are receiving healthcare services
• To subcontractors and service providers who assist in delivering the messaging service (e.g., telecommunications carriers, cloud infrastructure providers), all of whom are bound by confidentiality obligations and Business Associate Agreements where applicable
• As required by law, regulation, legal process, or governmental request
• To protect the rights, property, or safety of Linear Health, our Providers, or others
• With your explicit consent

2.3 Data Security

We implement industry-standard security measures to protect your mobile information, including:

• Encryption of data in transit and at rest
• Access controls limiting who can view your information
• Audit logging of all access to messaging systems
• Regular security assessments and monitoring

3. Types of Messages

Messages sent through the Linear Health platform are healthcare-related communications. Depending on your Provider, you may receive messages including but not limited to:

3.1 Appointment Communications

• Appointment reminders
• Appointment confirmations
• Appointment rescheduling notifications
• Pre-appointment instructions
• Post-appointment follow-up messages

3.2 Care Coordination

• Care plan updates
• Treatment reminders
• Follow-up care instructions
• Referral notifications
• Lab and test result notifications (non-sensitive alerts directing you to contact your Provider)

3.3 Administrative Communications

• Office closure or schedule change notifications
• Practice announcements
• Billing and payment reminders
• Insurance and eligibility notifications
• Patient portal access information

3.4 Prescription and Medication

• Prescription ready notifications
• Medication refill reminders
• Pharmacy pickup notifications

3.5 Patient Inquiries

• Responses to questions you initiate via text
• Two-way conversational messaging with your Provider's staff

Note: Messages will NOT contain detailed Protected Health Information (PHI) such as diagnoses, test results, or treatment details. Such information will only be shared through secure channels or by directing you to contact your Provider directly.

4. Consent and Opt-In

4.1 How You Provide Consent

You may opt in to receive text messages from your Provider through one or more of the following methods:

Written Consent:

• Signing a consent form during patient intake or registration
• Checking a consent checkbox on a web form (checkbox is not pre-selected)
• Completing an electronic consent through a patient portal

Verbal Consent:

• Providing verbal consent during a phone call or in-person visit with Provider staff, which is documented in your patient record

Text-Based Consent:

• Texting a keyword such as START, YES, or SUBSCRIBE to your Provider's phone number

4.2 Consent Disclosure

When you provide consent, you will be informed that:

• You are agreeing to receive text messages from [Provider Name] regarding your healthcare
• Message frequency varies based on your care needs
• Message and data rates may apply
• You can reply STOP at any time to opt out
• You can reply HELP for assistance
• Your mobile information will not be shared with third parties for marketing purposes

4.3 Consent Records

We maintain records of your consent, including:

• Method of opt-in (written, verbal, or text-based)
• Date and time of consent
• The specific consent language you agreed to

5. Opt-Out and Unsubscribe

5.1 How to Opt Out

You may opt out of receiving text messages at any time by:

• Replying STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, QUIT, or REVOKE to any message
• Contacting your Provider directly and requesting to be removed from text messaging
• Contacting Linear Health at the information provided below

5.2 Opt-Out Confirmation

When you successfully opt out, you will receive a confirmation message such as:

"You have successfully been unsubscribed. You will not receive any more messages from this number. Reply START to resubscribe."

5.3 Opt-Out Processing

• Opt-out requests are processed immediately upon receipt
• You will not receive further messages after opting out, except for the opt-out confirmation
• Opting out of text messages does not affect your healthcare relationship with your Provider
• You may re-subscribe at any time by texting START or contacting your Provider

6. Help and Support

6.1 How to Get Help

You may request help or information at any time by:

• Replying HELP or INFO to any message
• Contacting your Provider directly
• Contacting Linear Health at the information provided below

6.2 Help Response

When you text HELP, you will receive a response such as:

"Reply STOP to unsubscribe. Msg&Data Rates May Apply. For help, contact your healthcare provider or visit linear.health/sms-messaging-policy"

7. Message Frequency and Rates

7.1 Message Frequency

Message frequency varies based on your healthcare needs, appointment schedule, and the services provided by your Provider. You may receive anywhere from occasional messages to multiple messages per week, depending on your care plan and communications preferences.

7.2 Message and Data Rates

Standard message and data rates from your mobile carrier may apply to messages you send and receive. Linear Health is not responsible for any fees charged by your mobile carrier. Contact your carrier for details about your messaging plan.

7.3 Carrier Support

Our messaging services are designed to work with all major U.S. mobile carriers. However, some carriers may not support all message types. If you experience issues receiving messages, please contact your Provider or Linear Health.

8. HIPAA Compliance

8.1 Business Associate Status

Linear Health operates as a Business Associate under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health (HITECH) Act. We maintain Business Associate Agreements (BAAs) with all Providers using our platform.

8.2 Protected Health Information

We are committed to protecting the privacy and security of Protected Health Information (PHI) in accordance with HIPAA regulations. This includes:

• Implementing administrative, physical, and technical safeguards
• Limiting use and disclosure of PHI to the minimum necessary
• Training personnel on HIPAA requirements
• Maintaining audit trails of PHI access
• Reporting security incidents as required by law

8.3 SMS and PHI Limitations

Standard SMS text messages are not encrypted end-to-end and may be stored on mobile devices and carrier systems. For this reason:

• Messages sent through our platform do not contain detailed PHI
• Sensitive health information is communicated through secure channels
• Recipients are directed to contact their Provider for detailed health information
• We recommend Recipients do not include sensitive health information in text message replies

9. Terms of Service for SMS Messaging

9.1 Acceptance of Terms

By opting in to receive text messages through the Linear Health platform, you agree to:

• Receive recurring automated text messages from your Provider
• The terms of this SMS Messaging Policy
• Your Provider's Notice of Privacy Practices and terms of service

9.2 Eligibility

To receive text messages, you must:

• Be at least 18 years of age, or have parental/guardian consent
• Have a valid mobile phone number capable of receiving SMS/MMS messages
• Provide consent as described in this Policy

9.3 Accuracy of Information

You are responsible for:

• Providing accurate contact information to your Provider
• Notifying your Provider if your mobile phone number changes
• Updating your consent preferences as needed

9.4 Prohibited Uses

You agree not to:

• Use the messaging service for any unlawful purpose
• Send harassing, abusive, or threatening messages
• Attempt to gain unauthorized access to our systems
• Interfere with the operation of the messaging service

9.5 Service Availability

We strive to provide reliable messaging services, but we do not guarantee:

• Uninterrupted or error-free service
• Delivery of all messages (carrier filtering may affect delivery)
• Compatibility with all mobile devices or carriers

10. Children's Privacy

Our messaging services are not intended for children under the age of 13. We do not knowingly collect mobile phone numbers or consent from children under 13 without verified parental consent. If you believe we have collected information from a child under 13, please contact us immediately.

For Recipients between the ages of 13 and 18, consent must be provided or authorized by a parent or legal guardian.

11. Data Retention

11.1 Retention Period

We retain messaging records, including consent records and message logs, for the period required by:

• Applicable healthcare record retention laws
• HIPAA requirements
• Our contractual obligations to Providers
• Legal and regulatory requirements

11.2 Deletion Requests

You may request deletion of your messaging data by contacting your Provider or Linear Health. Please note that certain data may be retained as required by law or for legitimate business purposes, such as:

• Compliance with legal obligations
• Resolution of disputes
• Fraud prevention
• Enforcement of agreements

12. Changes to This Policy

We reserve the right to modify this Policy at any time. If we make material changes, we will:

• Update the "Last Updated" date at the top of this Policy
• Notify Providers of significant changes
• Where required, obtain renewed consent from Recipients

Your continued receipt of messages after changes to this Policy constitutes acceptance of the updated terms. We encourage you to review this Policy periodically.

13. California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to:

• Know what personal information we collect about you
• Request deletion of your personal information
• Opt out of the sale of your personal information (note: we do not sell personal information)
• Non-discrimination for exercising your privacy rights

To exercise these rights, please contact us using the information below.

14. Contact Information

15. Additional Disclosures

15.1 Carrier Disclaimer

Carriers are not liable for delayed or undelivered messages.

15.2 Program Description

This is a recurring message program for healthcare-related communications between Providers and their patients/clients.

15.3 Compatible Carriers

Service is available on all major U.S. carriers including AT&T, Verizon, T-Mobile, Sprint, and others.

16. Acknowledgment

By providing your mobile phone number and opting in to receive text messages from a Provider using the Linear Health platform, you acknowledge that you have read, understood, and agree to this SMS Messaging Policy.