Accepting New Patients

Patient Privacy Hub

Privacy Policy Hub

Effective Date: August 30, 2026

Entity: Collaborative Health ("Practice", "we", "us", or "our")

Welcome to the Privacy Policy Hub for Collaborative Health and Dr. Jafrey. We are committed to protecting your privacy and safeguarding your personal information. This Privacy Hub governs data collected through our website, promotional events, and our clinical practice in California.

This Privacy Hub is structured into three main sections:

Online Website Privacy Policy (General web traffic, cookies, forms, and California consumer rights)
Promotional Giveaways & Marketing Privacy Notice (Contest entries via email and text, winner notifications, and voluntary promotional messaging)
HIPAA Notice of Privacy Practices (Clinical medical records and Protected Health Information)

1. Online Website Privacy Policy

This section explains how we collect, use, and protect information gathered from visitors to our website (www.chdrjafrey.com).

Information We Collect Automatically

When you browse our website, our servers automatically collect standard technical log data, including:

Your IP (Internet Protocol) address
Browser type and version
Operating system and device details
Pages visited, referring URLs, time spent on pages, and access timestamps

Information You Provide Voluntarily

If you fill out a contact form, request information, or schedule an inquiry online, we collect the personal details you choose to submit, such as:

Full name
Email address
Phone number
Message contents or inquiry details

How We Use Website Information

We use general website data to:

Respond to your inquiries and customer service requests.
Maintain, secure, and optimize website performance and functionality.
Prevent fraud, cyber threats, and technical glitches.
Comply with legal and regulatory obligations.

Cookies and Tracking Technologies

Our website uses essential and functional cookies to facilitate navigation and site security.

Essential Cookies: Necessary for basic website functionality and secure form submission.
Analytics Cookies: Help us understand site traffic patterns to improve user experience.
Managing Cookies: You can adjust your browser settings to decline or delete cookies. However, disabling cookies may impair certain website features.

Third-Party Service Providers

We do not sell your website usage data. We share website technical data only with essential vendors who perform operational services on our behalf (such as web hosting, website analytics, and secure email delivery). These providers are contractually bound to keep your data confidential and use it only to support our operations.

California Consumer Privacy Notice (CCPA / CPRA / CalOPPA)

Under California law (including the California Consumer Privacy Act, as amended by the California Privacy Rights Act):

No Sale or Sharing of Personal Data: Collaborative Health does not sell your personal information or share it with third parties for cross-context behavioral advertising.
California Privacy Rights: California residents have the right to request access to, correction of, or deletion of their personal information held by us, and to limit the use of sensitive personal information.
Do Not Track Signals: Our website currently responds to web browser "Do Not Track" (DNT) signals or standard preference mechanisms where technically implemented.
Shine the Light: California Civil Code Section 1798.83 permits California residents to request details regarding disclosures of personal information to third parties for direct marketing purposes. We do not disclose personal data to third parties for their direct marketing purposes.

2. Promotional Giveaways & Marketing Privacy Notice

Collaborative Health periodically conducts contests, raffles, sweepstakes, and promotional giveaways. This section governs how data collected through these promotions is handled.

Information Collected for Giveaways

When you participate in a promotional giveaway, we collect only your contact details necessary to administer the entry. Specifically, we collect:

Email address
Phone number (for SMS/MMS text messaging)
Full name (if provided at entry)

We do not collect physical mailing addresses for promotional giveaways.

Primary Use of Giveaway Information

Information collected during giveaway registration is used strictly for the following primary purposes:

Administering the contest, validating entry eligibility, and selecting winners.
Contacting and notifying winner(s) via email or text message and coordinating digital prize delivery or pickup instructions.

Promotional Messages & Voluntary Opt-In

Default Restriction: Entering a giveaway does not automatically enroll you in ongoing marketing lists. We will only send you promotional or marketing communications if you voluntarily and explicitly opt in by checking an un-prechecked consent box at entry.
No Requirement to Win: Opting in to receive marketing messages is entirely voluntary and is never a requirement to enter, participate in, or win a giveaway.

Mobile SMS/MMS Promotional Terms

If you explicitly opt in to receive promotional text messages in connection with a giveaway:

Message frequency may vary. Standard message and data rates may apply.
You may opt out at any time by replying STOP to any promotional text.
Reply HELP for assistance.

Email Unsubscribe & Opt-Out Rights

If you opt in to receive promotional emails, you may revoke your consent at any time by clicking the "Unsubscribe" link located at the bottom of any marketing email, or by contacting us directly.

Data Retention & Non-Sale

Giveaway entry data (email and phone number) for non-winning participants who do not opt into ongoing marketing communications will be deleted once prize distribution and promotional reporting are completed.
We do not sell, rent, trade, or share giveaway entrant data with third parties for their independent commercial or marketing use.

Distinction from Medical Information (HIPAA)

Entering a promotional giveaway is a voluntary public marketing activity. Information submitted for giveaways:

Does not constitute Protected Health Information (PHI).
Does not establish a physician-patient relationship with Collaborative Health or Dr. Jafrey.
Is stored securely in marketing systems completely separate from confidential Electronic Health Records (EHR).

3. Notice of Privacy Practices (HIPAA)

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN ACCESS THIS INFORMATION PURSUANT TO FEDERAL REGULATIONS. PLEASE REVIEW IT CAREFULLY.

Our Commitment to Your Privacy

At Collaborative Health ("Practice"), we understand that medical information about you and your health is personal. We are committed to protecting medical information about you. Each time you visit our clinic, we create a record of the care and services you receive. We need this record to provide you with quality care and to comply with certain legal requirements.

This Notice of Privacy Practices ("Notice") applies to all the records of your care generated by Practice. This Notice will tell you about the ways in which Practice may use and disclose your protected health information ("PHI"). This Notice also describes your rights and certain obligations Practice has regarding the use and disclosure of PHI.

Practice is required by law to maintain the privacy of your PHI, to provide individuals with notice of Practice's legal duties and privacy practices with respect to PHI, and to abide by the terms described in the Notice currently in effect.

How We May Use and Disclose Your Information

Practice may use or disclose your PHI for the purposes described below without obtaining written authorization from you. In addition, Practice and the members of its medical and allied health professional staff who participate in the organized health care arrangement described below may share your PHI with each other as necessary to carry out their treatment, payment, and health care operations related to the organized health care arrangement.

Treatment: Practice may use and disclose PHI while providing, coordinating, or managing your medical treatment, including the disclosure of PHI for treatment activities of another health care provider.
Payment: Practice may use and disclose PHI to bill and collect payment for the health care services provided to you. For example, Practice may need to give PHI to your health plan to be reimbursed for the services provided to you. Practice may also disclose PHI to its business associates, such as billing companies, claims processing companies, and others that assist in processing health claims. Practice may also disclose PHI to other health care providers and health plans for the payment activities of such providers or health plans.
Health Care Operations: Practice may use and disclose PHI as part of its operations, including for quality assessment and improvements, such as evaluating the treatment and services you receive and the performance of staff and physicians in caring for you, patient surveys, provider training, underwriting activities, compliance and risk management activities, planning and development, credentialing and peer review activities, and health care fraud and abuse detection or compliance, and management and administration. Practice may disclose PHI to doctors, nurses, technicians, students, attorneys, consultants, accountants, and others for review and learning purposes, to help make sure Practice is complying with all applicable laws, and to help Practice continue to provide quality health care to its patients.
Business Associates: Collaborative Health provides services through contracts with business associates. Examples of business associates include accreditation agencies, management consultants, quality assurance reviewers, and billing and collection services. We disclose your health information to our business associates so they can perform the job we've asked them to do. To protect your health information, we require our business associates to sign a contract or written agreement that states they will appropriately safeguard your information.
Public Health Activities and Public Health Risks: Practice may disclose PHI to government officials in charge of collecting information about births and deaths, preventing and controlling disease, or notifying a person who may have been exposed to a communicable disease or may be at risk of contracting or spreading a disease or condition.
Health Oversight Activities: Practice may disclose PHI to the government for oversight activities authorized by law, such as audits, investigations, inspections, licensure or disciplinary actions, and other proceedings, actions, or activities necessary for monitoring the health care system, government programs, and compliance with civil rights laws.
Coroners, Medical Examiners, and Funeral Directors: Practice may disclose PHI to coroners, medical examiners, and funeral directors for the purpose of identifying a decedent, determining a cause of death, or otherwise as necessary to enable these parties to carry out their duties consistent with applicable law.
Patient List; Marketing: Unless you object, Practice may use some of your PHI to maintain a list of patients it has served. This information may include your name, treatment facility, and the services Practice provided to you. This patient list and the information on it may be used for marketing purposes.
Disclosures to Individuals Involved in Your Health Care or Payment for Your Health Care: Unless you object, Practice may disclose your PHI to a family member, other relative, friend, or other person you identify as involved in your health care or payment for your health care. We may disclose health information about you to an entity assisting in a disaster relief effort (such as the Red Cross) so that your family can be notified about your condition, status, and location.

Special Situations That Do Not Require Your Authorization

State or federal law permits the following disclosures of your health information without verbal or written permission from you:

Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order. We may disclose health information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute.
Inmates: If you are an inmate of a correctional institution or under custody of a law enforcement official, we may disclose health information about you to the correctional institution or the law enforcement official. This is necessary for the correctional institution to provide you with health care, to protect your health and safety and the health and safety of others, or for the safety and security of the correctional institution.
Worker's Compensation: We may release health information about you for worker's compensation or similar programs if you have a work-related injury. These programs provide benefits to you for your work-related injuries.
As Required by Law and Law Enforcement: Practice may use or disclose PHI when required to do so by applicable laws and when ordered to do so in a judicial or administrative proceeding. Practice may also use or disclose PHI upon a properly documented and limited request from law enforcement agencies. Reasons may include:
- In response to a court order, subpoena, warrant, summons, or similar process.
- To identify or locate a suspect, fugitive, material witness, or missing person.
- To identify the victim of a crime if, under certain circumstances, we are unable to obtain the person's authorization.
- To release information about a death we believe may be the result of criminal conduct.
- Criminal conduct at our facility.
- Emergency circumstances, to report a crime, the location of the crime or victims, or the identity, description, or location of the person who committed the crime.
Specialized Government Functions: Practice may use and disclose PHI of military personnel and veterans under certain circumstances. Practice may also disclose PHI to authorized federal officials for intelligence, counterintelligence, and other national security activities, and for the provision of protective services to the president or other authorized persons or foreign heads of state or to conduct special investigations.
Averting a Serious Threat to Health or Safety: Practice may use and disclose PHI to law enforcement personnel or other appropriate persons to prevent or lessen a serious threat to the health or safety of a person or the public.
Disclosures to You or for HIPAA Compliance Investigations: Practice may disclose your PHI to you or to your personal representative and is required to do so in certain circumstances described below in connection with your rights of access to your PHI and to an accounting of certain disclosures of your PHI. Practice must disclose your PHI to the secretary of the United States Department of Health and Human Services (the "Secretary") when requested by the Secretary in order to investigate Practice's compliance with privacy regulations issued under the federal Health Insurance Portability and Accountability Act of 1996.

Uses Requiring Your Written Authorization

Other types of uses and disclosures of your PHI not described above will be made only with your authorization, which with some limitations; you have the right to revoke your authorization in writing. If you revoke your authorization, Practice will no longer use or disclose PHI about you for the reasons covered in your written authorization. Please understand that Practice is unable to recover any disclosures already made with your authorization, and that Practice is required to retain records of the care provided to you.

Mental Health and Specially Protected Information: In most cases, federal or state law requires your written authorization or the written authorization of your representative, for disclosure of your information:
- Psychotherapy Notes: Psychotherapy notes are maintained separately from your general medical record. Uses or disclosures of psychotherapy notes—including for routine treatment, payment, or healthcare operations—require your specific written authorization, except in limited circumstances such as use by the originating provider, internal staff training, or legal defense in an action brought by you.
- Mental Health Records: Under the California Confidentiality of Medical Information Act (CMIA) and applicable state laws, mental health records receive heightened privacy protections. Mental health information will only be disclosed with your written authorization or as explicitly permitted by law.
- HIV/AIDS Test Results: Under California law, information and test results regarding Human Immunodeficiency Virus (HIV) or Acquired Immune Deficiency Syndrome (AIDS) receive enhanced confidentiality protections. Disclosures generally require your specific written authorization, except for direct diagnosis, care, or treatment by healthcare providers, or as mandated by public health reporting laws.
- Substance Use Disorder (42 CFR Part 2) Records: If Collaborative Health maintains records protected under 42 CFR Part 2, those records receive additional federal protections. Part 2 records cannot be disclosed without your written consent, nor used or disclosed in civil, criminal, administrative, or legislative proceedings against you without your written consent or a court order issued under Part 2 rules.
- Safety and Required Disclosures: Specially protected information may be disclosed without authorization only when permitted or required by law, such as to avert a serious and imminent threat to health or safety, or to satisfy mandatory legal obligations.
Sale of Health Information: It is not our practice to sell your health information. Sale of your health information would require your written authorization.
Research: When a research study involves your treatment, or, in certain circumstances, records research, we may disclose your health information to researchers only after you have signed a specific written authorization. In addition, an Institutional Review Board (IRB) will have already reviewed the research proposal, established appropriate protocols to ensure the privacy of your health information, and approved the research. You do not have to sign the authorization, but if you refuse you cannot be part of the research study and may be denied research-related treatment.

Mobile (SMS/MMS) Communications Notice

Practice may contact you by SMS/MMS for appointment reminders, health updates, or patient engagement. We will never share, sell, or rent your personal information—including your phone number—to third parties for marketing purposes. Your information is used only to provide services you request and to communicate about your care. Reply HELP for assistance or STOP to opt-out of text communications. Standard message and data rates may apply.

We may use telephone, SMS/MMS, patient portal, or email for appointment reminders, care coordination, health updates, and patient engagement. Electronic communication is not a substitute for emergency services. You may request alternative communication methods or opt out of certain text communications where available.

Your Rights Regarding Your PHI

You have the following rights regarding your PHI:

Restrictions: You may request that Practice restrict the use and disclosure of your PHI. To request restrictions, you must make your request in writing to our Privacy Officer using the applicable Practice form. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure, or both; and (3) to whom you want the restrictions to apply, for example, disclosures to your spouse.
Alternative Communications: You have the right to request that communications of PHI to you from Practice be made by particular means or at particular locations. For instance, you might request that communications be made at your work address, instead of your home address. Your requests must be made in writing using Practice's form and sent to the Privacy Officer. Practice will accommodate your reasonable requests.
Inspect and Copy: Generally, you have the right to inspect and copy your PHI that Practice maintains, provided you make your request in writing to Practice's Privacy Officer. If you request copies of your PHI, we may impose a reasonable fee to cover copying and postage. If we deny access to your PHI, we will explain the basis for denial and your opportunity to have your request and the denial reviewed by a licensed health care professional (who was not involved in the initial denial decision) designated as a reviewing official. If Practice does not maintain the PHI you request and if we know where that PHI is located, we will tell you how to redirect your request.
Amendment: If you believe that your PHI maintained by Practice is incorrect or incomplete, you may ask us to correct your PHI. Your request must be made in writing, and it must explain why you are requesting an amendment to your PHI. We can deny your request if your request relates to PHI: (i) not created by Practice; (ii) not part of the records Practice maintains; (iii) not subject to being inspected by you; or (iv) that is accurate and complete. If your request is denied, we will provide you a written denial that explains the reason for the denial and your rights to: (i) file a statement disagreeing with the denial; (ii) if you do not file a statement of disagreement, submit a request that any future disclosures of the relevant PHI be made with a copy of your request and Practice's denial attached; and (iii) complain about the denial.
Accounting of Disclosures: You generally have the right to request and receive a list of the disclosures of your PHI we have made at any time during the six (6) years prior to the date of your request (provided that such a list would not include disclosures made prior to April 14, 2003). The list will not include disclosures made at your request, with your authorization, and does not include certain uses and disclosures to which this Notice already applies, such as those: (i) for treatment, payment, and health care operations; (ii) made to you; (iii) for Practice's patient list; (iv) for national security or intelligence purposes; or (v) to law enforcement officials. You should submit any such request to Practice's Privacy Officer. Practice will provide the list to you at no charge, but if you make more than one request in a year you will be charged a fee of the costs of providing the list.
File a Complaint: At Collaborative Health, we value the relationships we develop with our patients, our patients' privacy, and the trust our patients have in us. As such, we make every effort to remedy any issues or concerns you may have. You may submit any complaint regarding your privacy rights to Collaborative Health's Privacy Officer at 442-222-1514. You also have the right to file a complaint with the secretary of the Department of Health and Human Services, Office for Civil Rights. You will not be penalized for filing a complaint.
Copy of Notice: You have the right to receive a paper copy of this notice upon request. To obtain a paper copy of this notice, please contact Collaborative Health's Privacy Officer at or email at info@chdrjafrey.com 442-222-1514.

Contact Information

For any privacy questions, exercise of California privacy rights, or HIPAA requests, please contact our Privacy Officer:

Collaborative Health Privacy Officer

Phone: 442-222-1514

Email: info@chdrjafrey.com

Website: www.chdrjafrey.com

Primary Care, Designed Around You.

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