Skip to main content

VitalGuard Notice of Privacy Practices

Your Information. Your Rights. Our Responsibilities. 

Effective Date: June 26, 2026 

This notice explains how medical information about you may be used and disclosed, the standards VitalGuard LLC follows, and the rights available to you under federal and Commonwealth of Puerto Rico privacy laws.

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. Our Commitment & Duties

VitalGuard LLC is required by law to maintain the privacy of your Protected Health Information (PHI) and to provide you with this notice of our legal duties and privacy practices. We are required to abide by the terms of this notice currently in effect.

2. Specialized Confidentiality (42 CFR Part 2)

Substance Use Disorder (SUD) records are subject to heightened protections. VitalGuard LLC will not disclose SUD records for treatment, payment, or healthcare operations without your specific written consent, except in life-threatening medical emergencies or as otherwise permitted by 42 CFR Part 2.

3. Use and Disclosure of PHI

We may use and disclose your PHI for the following core purposes:

  • Treatment (Clinical Escalation): Your physiological data, including systolic and diastolic readings, heart rate, and oxygen saturation, is processed by our engine to route alerts to your provider.

  • Payment: We use your information to facilitate billing for RPM services, including the generation of contemporaneous documentation for Medicare and CMS.

  • Healthcare Operations: We may use your PHI for internal quality assessment, platform optimization, and ensuring the accuracy of our Escalation Engine.

  • Minimum Necessary: We restrict access to the minimum information necessary to accomplish the intended purpose.

  • Prohibitions: We do not sell your data, use it for commercial profiling, or train third-party AI models with your PHI or metadata.

  • Geofencing: All PHI and proprietary scripts are geofenced strictly to the United States.

4. Permitted Disclosures Without Authorization

In addition to treatment, payment, and operations, federal law permits or requires us to disclose your PHI without your written authorization in specific situations, including:

  • Public Health Activities: To prevent or control disease, report vital statistics, or report suspected abuse, neglect, or domestic violence.

  • Health Oversight Activities: For audits, investigations, and inspections conducted by government agencies (e.g., CMS, OIG, or the Department of Health).

  • Judicial and Administrative Proceedings: In response to a court order, subpoena, or discovery request.

  • Law Enforcement: To identify or locate a suspect, fugitive, material witness, or missing person, or to report a crime.

  • Coroners, Medical Examiners, and Organ Donation: To assist in identifying a deceased person, determining cause of death, or facilitating organ procurement.

  • Averting a Serious Threat: To prevent or lessen a serious and imminent threat to the health or safety of a person or the public.

  • Workers’ Compensation: To comply with laws relating to workers’ compensation or similar programs.

5. General Authorization & Redisclosure Warning

Any uses or disclosures of your PHI not explicitly described in this notice will be made only with your written authorization. If you provide us with authorization, you may revoke it at any time by submitting a written request to our Privacy Officer.

Once PHI is disclosed to a third party pursuant to your authorization, it may be subject to redisclosure by the recipient and may no longer be protected by federal or Commonwealth privacy laws.

6. Your Privacy Rights

You have the following rights regarding the PHI we maintain about you:

  • Access & Paper Copy: You may request to inspect or copy your PHI. You also have the right to receive a paper copy of this notice upon request at any time.

  • Right to Amend: If you believe your PHI is incorrect or incomplete, you may request that we amend the information. Your request must be in writing and include a reason to support the amendment.

  • Right to Request Restrictions: You may request a restriction on how we use or disclose your PHI. We are required to agree to a request to restrict disclosure to a health plan if the disclosure is for payment or healthcare operations and the PHI pertains to an item or service for which you have paid out-of-pocket in full.

  • Confidential Communications: You have the right to request that we communicate with you about medical matters in a certain way or at a certain location (e.g., only by cell phone or mail to a specific address).

  • Accounting of Disclosures: You may request an accounting of electronic disclosures made through our platform for the three years prior to your request.

  • Expedited Puerto Rico Timeline: Under PR Act 194-2011, if the physician-patient relationship is terminated, records will be provided within five working days free of charge.

7. 24-Hour Breach Notification Promise

Consistent with our Business Associate Agreements (BAAs), VitalGuard LLC maintains a Platinum Standard for security. In the event of a discovery of a breach of unsecured PHI, VitalGuard LLC will notify you and our Covered Entity partners within twenty-four hours.

8. Changes to this Notice

We reserve the right to change the terms of this notice at any time. The new provisions will be effective for all PHI that we maintain, including information created or received prior to the change. If we make a material change, we will post the revised notice on our website and make it available upon request.

9. Complaints & Contact Information

If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer or with the Secretary of the U.S. Department of Health and Human Services (HHS). VitalGuard LLC will not retaliate against you for filing a complaint.

To file a complaint or exercise any of your privacy rights, please contact:

VitalGuard LLC

Privacy Officer

1654 Calle Tulipan, Ste 100 San Juan, PR 00927

Email: privacy@myvitalguard.com