Privacy Policy & HIPAA Notice

TC Clinical Services

Effective Date: December 15, 2025

Last Updated: December 15, 2025

TC Clinical Services ("TC Clinical," "we," "us," or "our") is committed to protecting your privacy and safeguarding your personal and health information. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit our website, contact us for services, or receive care through our network of healthcare providers.

We comply with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the HITECH Act, and all applicable federal and state privacy laws governing the protection of health information.

Table of Contents

  1. 1. Information We Collect
  2. 2. How We Use Your Information
  3. 3. How We Share Your Information
  4. 4. Your Rights Under HIPAA
  5. 5. Website Privacy & Cookies
  6. 6. Data Security
  7. 7. Third-Party Links
  8. 8. Children's Privacy
  9. 9. State-Specific Rights
  10. 10. Changes to This Policy
  11. 11. Contact Information

1. Information We Collect

Personal Information

When you contact us, request services, or interact with our website, we may collect:

  • Contact Information: Name, email address, phone number, mailing address
  • Demographic Information: Age, date of birth, gender
  • Insurance Information: Medicare/Medicaid ID, insurance carrier, policy numbers
  • Referral Information: Referring physician name and contact information

Protected Health Information (PHI)

When you seek wound care placement or rehabilitation services through TC Clinical, we may collect health-related information including:

  • Medical history relevant to your wound or mobility condition
  • Current medications and allergies
  • Wound characteristics (location, type, duration, previous treatments)
  • Mobility and gait assessment information
  • Diagnostic information and test results
  • Treatment records and progress notes
  • Information from your referring healthcare providers

Website Usage Information

When you visit our website, we automatically collect:

  • IP address and device information
  • Browser type and operating system
  • Pages visited and time spent on pages
  • Referring website addresses
  • Cookies and similar tracking technologies (see Section 5)

2. How We Use Your Information

For Treatment Purposes

We use your information to:

  • Match you with appropriate specialists in our network
  • Coordinate your wound care or rehabilitation services
  • Communicate with your referring physicians and care team
  • Develop and implement your treatment plan
  • Monitor your progress and outcomes

For Payment Purposes

We use your information to:

  • Verify insurance coverage and eligibility
  • Submit claims to Medicare, Medicare Advantage, or commercial insurance
  • Process billing and payments
  • Respond to insurance inquiries and audits

For Healthcare Operations

We use your information to:

  • Improve the quality of our services
  • Train our staff and network providers
  • Conduct quality assessments and outcomes tracking
  • Comply with legal and regulatory requirements
  • Manage our business operations

For Communication

With your consent, we may use your contact information to:

  • Send appointment reminders and follow-up communications
  • Provide information about your treatment options
  • Notify you of service updates or changes
  • Respond to your inquiries and requests

3. How We Share Your Information

Permitted Disclosures Under HIPAA

We may share your Protected Health Information without your written authorization for:

  • Treatment: Sharing information with specialists, referring physicians, and other healthcare providers involved in your care.
  • Payment: Sharing information with insurance companies, Medicare, and billing services to obtain payment for services.
  • Healthcare Operations: Sharing information for quality improvement, training, accreditation, and business management purposes.
  • As Required by Law: Disclosing information when required by federal, state, or local law.
  • Public Health Activities: Reporting to public health authorities for disease prevention and control.
  • Health Oversight: Disclosing to government agencies for audits, investigations, and compliance activities.
  • Legal Proceedings: Responding to court orders, subpoenas, or other lawful processes.
  • To Prevent Serious Harm: Disclosing information to prevent or lessen a serious and imminent threat to health or safety.

Disclosures Requiring Your Authorization

We will obtain your written authorization before:

  • Using or disclosing your information for marketing purposes
  • Selling your health information
  • Sharing psychotherapy notes (if applicable)
  • Using your information for purposes not described in this policy

Business Associates

We may share your information with third-party service providers ("Business Associates") who perform services on our behalf, such as:

  • Electronic health record systems
  • Billing and claims processing services
  • IT and data security providers
  • Communication platforms

All Business Associates are contractually required to protect your information in accordance with HIPAA and use it only for the purposes specified in our agreements.

Our Network Providers

When we match you with a specialist in our network, we share relevant health information necessary for your treatment. Our network providers include:

  • Plastic surgeons
  • Mohs-trained dermatologists
  • General surgeons
  • Foot and ankle orthopedists
  • Podiatrists
  • Vascular specialists
  • Rehabilitation specialists
  • Midlevel providers

Each provider in our network maintains their own privacy practices and is independently responsible for HIPAA compliance.

4. Your Rights Under HIPAA

As a patient, you have the following rights regarding your Protected Health Information:

Right to Access

You have the right to inspect and obtain a copy of your health information maintained by TC Clinical. To request access, submit a written request to our Privacy Officer (contact information below). We may charge a reasonable fee for copying and mailing.

Right to Amend

If you believe your health information is incorrect or incomplete, you may request an amendment. Submit your request in writing, explaining why the information should be changed. We may deny your request in certain circumstances but will provide a written explanation.

Right to an Accounting of Disclosures

You have the right to receive a list of certain disclosures we have made of your health information. This accounting does not include disclosures for treatment, payment, or healthcare operations, or disclosures you authorized in writing.

Right to Request Restrictions

You may request restrictions on how we use or disclose your health information for treatment, payment, or healthcare operations. We are not required to agree to your request, except in limited circumstances (such as if you pay out-of-pocket in full and request we not bill your insurance).

Right to Confidential Communications

You may request that we communicate with you in a specific way or at a specific location. For example, you may ask that we contact you only at a particular phone number. We will accommodate reasonable requests.

Right to a Paper Copy of This Notice

You have the right to receive a paper copy of this Privacy Policy and Notice of Privacy Practices at any time, even if you previously agreed to receive it electronically.

Right to File a Complaint

If you believe your privacy rights have been violated, you may file a complaint with:

  • TC Clinical's Privacy Officer (contact information below)
  • The U.S. Department of Health and Human Services Office for Civil Rights

You will not be retaliated against for filing a complaint.

5. Website Privacy & Cookies

Information Collection on Our Website

When you visit our website, we collect certain information automatically through cookies and similar technologies.

What Are Cookies?

Cookies are small text files stored on your device that help us recognize you and remember your preferences. We use:

  • Essential Cookies: Necessary for the website to function properly. These cannot be disabled.
  • Analytics Cookies: Help us understand how visitors use our website, which pages are most popular, and how to improve user experience.
  • Functional Cookies: Remember your preferences and settings to enhance your experience.

No PHI on Public Website

Our public website does not collect Protected Health Information. If you submit health information through our contact form, it will be treated as PHI and protected accordingly.

6. Data Security

Our Commitment to Security

We implement administrative, physical, and technical safeguards to protect your personal and health information, including:

Administrative Safeguards

  • HIPAA training for all staff
  • Privacy Officer oversight
  • Regular risk assessments

Physical Safeguards

  • Secure facilities with controlled access
  • Workstation security protocols
  • Secure disposal of records

Technical Safeguards

  • Encryption of data
  • Secure authentication
  • Firewalls & anti-virus

Breach Notification

In the event of a breach of unsecured Protected Health Information, we will notify affected individuals, the Department of Health and Human Services, and (if applicable) the media, in accordance with HIPAA Breach Notification Rules.

Limitations

While we take extensive precautions to protect your information, no data transmission over the internet or electronic storage system is 100% secure. We cannot guarantee absolute security but are committed to protecting your information to the best of our ability.

7. Third-Party Links

Our website may contain links to third-party websites, such as insurance company portals, Medicare.gov, medical information resources, and social media platforms.

We are not responsible for the privacy practices of these external sites. We encourage you to read the privacy policies of any website you visit.

8. Children's Privacy

TC Clinical services are intended for adults. Our PONS Therapy services are specifically for patients 25 years of age and older. We do not knowingly collect personal information from children under 13.

If you believe we have inadvertently collected information from a child under 13, please contact our Privacy Officer immediately so we can delete the information.

9. State-Specific Privacy Rights

California Residents (CCPA/CPRA)

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

  • Right to know what personal information we collect
  • Right to delete personal information
  • Right to opt-out of the sale of personal information
  • Right to non-discrimination for exercising your rights

Note: Health information governed by HIPAA is generally exempt from CCPA/CPRA. However, non-health personal information may be subject to these laws.

Other States

Privacy laws vary by state. We comply with all applicable state privacy laws in addition to federal requirements. Contact our Privacy Officer if you have questions about your state-specific rights.

10. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. When we make material changes, we will:

  • Update the "Last Updated" date at the top of this policy
  • Post the revised policy on our website
  • For significant changes affecting your rights, provide additional notice as appropriate

We encourage you to review this policy periodically to stay informed about how we protect your information.

11. Contact Information

Privacy Officer

For questions about this Privacy Policy, to exercise your privacy rights, or to file a privacy complaint, contact:

TC Clinical Services Privacy Officer

Chris de la Garza

24702 Alamosa Falls

San Antonio, TX 78255

(210) 837-9718

[email protected]

To File a Complaint with HHS

You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights:

U.S. Department of Health and Human Services

Office for Civil Rights

200 Independence Avenue, S.W.

Washington, D.C. 20201

Toll-Free: 1-800-368-1019

www.hhs.gov/ocr/privacy/hipaa/complaints/

Summary of Your Rights

Your Right What It Means
Access You can see and get a copy of your health records
Amendment You can ask us to correct information you believe is wrong
Accounting You can request a list of certain disclosures we've made
Restrictions You can ask us to limit how we use/share your information
Confidential Communications You can ask us to contact you in a specific way
Paper Copy You can get a paper copy of this notice anytime
Complaint You can file a complaint if you believe your rights were violated

Notice of Privacy Practices Acknowledgment

By using TC Clinical services, you acknowledge that you have received and reviewed this Privacy Policy and Notice of Privacy Practices. You understand how your health information may be used and disclosed, and you are aware of your rights regarding your Protected Health Information.