Healthy Neighbors (“Healthy Neighbors,” “we,” “us”) operates a community-powered patient recruiting platform that connects research studies with community advocates and the people they refer.

We collect information you provide directly, including:

• · Account information — name, email address, phone number, and ZIP code, when you sign up as an advocate.
• · Referral and screening information — when a patient completes a study screener, we collect their name and their answers to eligibility questions.
• · Usage information — such as link clicks, QR scans, and pages visited, used to track referral activity and advocate rewards.

• · To create and manage advocate and patient accounts.
• · To match patients with research studies and share referral outcomes with the sponsoring study team.
• · To calculate and pay advocate referral earnings and rewards.
• · To send account, referral, and study-opportunity notifications by email, SMS, or in-app alert.

If you provide a mobile phone number and opt in, we may send you SMS messages about new study opportunities available in your area and other account-related alerts. Message frequency varies based on activity in your region. Message and data rates may apply.

Reply STOP at any time to opt out of SMS messages, or HELP for help. You can also update your notification preferences from your account settings. We do not sell or share your phone number with third parties for their own marketing purposes.

We share information with the research study sponsor when a referral you make (or a screener you complete) is relevant to their study, and with service providers who help us operate the platform — including cloud hosting, payment/reward delivery, and messaging providers — under agreements that limit their use of your information to providing those services. We do not sell personal information.

We use reasonable administrative, technical, and physical safeguards to protect the information we collect. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

You may update your account information, adjust notification preferences, or request that we delete your account and associated data by contacting us using the information below.

Healthy Neighbors is not directed to children under 18, and we do not knowingly collect information from children.

We may update this policy from time to time. We'll update the “Last updated” date above when we do.

Questions about this policy? Reach us at privacy@healthy-neighbors.com.

Healthy Neighbors takes privacy seriously. Advocates may come into contact with personal information and health-related information while sharing study opportunities and submitting referrals.

These Privacy Rules explain how Advocates must collect, use, protect, and share personal and health information.

By signing up as an Advocate, you agree to follow these Privacy Rules.

The Health Insurance Portability and Accountability Act of 1996, commonly known as HIPAA, includes federal rules that protect certain health information. The HIPAA Privacy Rule applies to covered entities, such as certain healthcare providers, health plans, and healthcare clearinghouses, and to business associates that perform services involving protected health information for covered entities. HHS guidance states that the Privacy Rule protects individually identifiable health information, often called protected health information or PHI. (hhs.gov)

Healthy Neighbors expects all Advocates to handle health-related information carefully and in a manner consistent with HIPAA privacy principles, whether or not a specific interaction is legally subject to HIPAA.

These rules are designed to help protect individuals, support compliance, and maintain trust.

Personal Information

Personal information means information that identifies or could reasonably identify a person, such as:

• · Name
• · Phone number
• · Email address
• · Address
• · Date of birth
• · Photograph
• · Social media profile
• · Emergency contact
• · Any other identifying information

Health Information

Health information means information about a person's health, symptoms, diagnosis, medications, treatment, medical history, healthcare providers, or participation in a health study.

Examples include:

• · “Maria has COPD.”
• · “John uses oxygen.”
• · “My neighbor has cancer.”
• · “My aunt takes insulin.”
• · “This person had a stroke.”
• · “This person wants to join a COPD study.”

Protected Health Information / PHI

Protected Health Information, or PHI, generally means individually identifiable health information that is created, received, maintained, or transmitted by a covered entity or business associate and relates to a person's health, healthcare, or payment for healthcare.

Even if you are unsure whether information is technically PHI, treat all personal and health-related information as private and confidential.

Advocates must collect and share only the minimum information needed to make a referral.

HHS guidance explains that the HIPAA Privacy Rule generally requires covered entities to take reasonable steps to limit uses, disclosures, and requests for PHI to the minimum necessary to accomplish the intended purpose. (hhs.gov)

For Advocates, this means: collect only what Healthy Neighbors asks for, such as:

• · Name
• · Phone number
• · Email address, if required
• · Preferred contact method
• · Basic study interest
• · Basic qualifying information requested by Healthy Neighbors

Do not collect or submit unnecessary information, such as:

• · Medical records
• · Lab results
• · Medication lists unless specifically required
• · Social Security numbers
• · Insurance cards
• · Medicare or Medicaid numbers
• · Photos of prescriptions
• · Driver's license images
• · Detailed medical history
• · Financial information
• · Immigration status

You must obtain permission before submitting anyone's information to Healthy Neighbors or a study team.

Use this script:

“Do I have your permission to share your name and contact information with Healthy Neighbors or the study team so they can contact you with more information about this study?”

If the person says yes, you may submit the referral using the approved Healthy Neighbors system.

If the person says no, do not submit their information.

If the person is unsure, send them your referral link so they can choose whether to complete the form themselves.

Never publicly share another person's health information.

You may not post or say things like:

• · “My neighbor Bob has COPD and should join this study.”
• · “My cousin has cancer and signed up.”
• · “This person uses oxygen.”
• · “This person qualified for the study.”
• · “This person got paid for participating.”

You may post general approved study information, such as:

“A COPD research study may be available for adults age 40+ who have breathing problems or are current or former smokers. Message me or use this link to learn more.”

When discussing study opportunities privately:

• · Be respectful.
• · Keep conversations confidential.
• · Do not discuss one person's health with another person unless you have clear permission.
• · Do not pressure anyone to share medical details.
• · Do not ask for more health information than needed.
• · Direct medical questions to the study team.

All referrals must be submitted through Healthy Neighbors-approved tools, such as:

• · The Advocate portal
• · Approved referral form
• · Approved referral link
• · Approved phone number or email, if provided

Do not submit referrals through unapproved channels, including:

• · Personal spreadsheets
• · Personal email accounts
• · Unsecured notes apps
• · Public social media comments
• · Group chats
• · Shared documents
• · Text messages to unauthorized people

If you use your phone, tablet, or computer for Advocate activities, you must take reasonable steps to protect information.

You agree to:

• · Use a passcode, password, Face ID, fingerprint, or other device lock.
• · Keep your device with you or stored securely.
• · Not share your Advocate login.
• · Not allow others to access referral information.
• · Log out of shared or public devices.
• · Avoid using public computers for referrals.
• · Avoid saving personal or health information outside Healthy Neighbors systems.
• · Delete unnecessary notes or messages containing personal information after submission, unless instructed otherwise.
• · Report lost or stolen devices if they may contain referral information.

Unless Healthy Neighbors gives written permission, you may not:

• · Take screenshots of referral information.
• · Record calls with potential participants.
• · Photograph medical documents.
• · Save copies of completed referral forms.
• · Share screenshots of dashboards, earnings, patient names, or referral status.
• · Post participant conversations online.

When using social media:

• · Use only approved public posts.
• · Do not identify anyone as having a condition.
• · Do not tag people who may have a condition.
• · Do not ask people to comment publicly about their health.
• · Do not discuss referral status in comments.
• · Move interested people to a private message or approved referral link.
• · Include required compensation disclosures when applicable.

If someone comments publicly about their health, do not repeat or expand on their health information. Respond generally:

“Thank you for reaching out. Please message me directly or use the link to learn more.”

Texting can be used for outreach, but it must be respectful and privacy-conscious.

You may:

• · Send approved messages to people you know.
• · Share your approved referral link.
• · Ask if they would like more information.
• · Stop texting if they are not interested.

You may not:

• · Send mass spam messages.
• · Use automated texting tools without Healthy Neighbors approval.
• · Share one person's health information with another person.
• · Send screenshots of someone's referral.
• · Include detailed health information in group texts.
• · Continue contacting someone who asks you to stop.

In group chats, community pages, or online groups:

• · Share only general approved study information.
• · Do not name or identify potential participants.
• · Follow group rules.
• · Do not post where recruitment or promotional posts are prohibited.
• · Do not argue with moderators or members.
• · Remove posts if asked by group administrators or Healthy Neighbors.

Unless Healthy Neighbors specifically authorizes it for a particular study, Advocates may not refer minors.

For adults who may have a legal guardian, caregiver, or power of attorney, Advocates should refer questions to Healthy Neighbors or the study team.

Advocates must not pressure vulnerable individuals or people who may not understand the information being shared.

You may share approved study information with friends, family members, and caregivers.

However:

• · Do not assume someone wants their information shared.
• · Do not submit a referral without permission.
• · Do not share private health information among family members without permission.
• · Be especially careful with sensitive conditions.

Example — you may say: “There may be a COPD study available. If your father is interested, he can use this link or contact the study team.”

You should not say: “I submitted your father because I know he has COPD.”

If someone voluntarily tells you about their health condition:

• · Thank them for sharing.
• · Do not ask for unnecessary details.
• · Do not promise they qualify.
• · Do not share the information with anyone except through the approved referral process, and only with permission.
• · Direct them to the study team for medical questions.

Approved response: “Thank you for sharing that. I'm not able to determine eligibility, but if you'd like, I can send you the link or connect you with the study team.”

When submitting referrals, provide accurate information. You may not:

• · Guess a person's diagnosis.
• · Invent symptoms.
• · Change answers to help someone appear eligible.
• · Submit fake names or fake contact information.
• · Use your own contact information for another person.
• · Submit duplicate referrals.
• · Submit someone who did not give permission.

Referral status information is private. You may not share:

• · Whether someone was contacted.
• · Whether someone qualified.
• · Whether someone enrolled.
• · Whether someone was rejected.
• · Whether someone was paid.
• · Why someone did or did not qualify.

If a person asks about their own status, direct them to Healthy Neighbors or the study team.

You must report any actual or suspected privacy incident immediately. Examples include:

• · You submitted the wrong person's information.
• · You shared someone's information without permission.
• · You lost a phone containing referral information.
• · Someone accessed your Advocate account without permission.
• · You posted someone's health information publicly.
• · You sent a referral screenshot to the wrong person.
• · You suspect another Advocate is misusing information.

Report incidents to: Healthy Neighbors Privacy Contact — privacy@healthy-neighbors.com

Include: what happened, date and time, information involved, who may have received or seen the information, and steps already taken.

Do not try to hide or fix a privacy incident without reporting it.

Advocates should not keep personal or health information longer than needed.

After submitting a referral, delete unnecessary notes, screenshots, or messages containing personal or health information, unless Healthy Neighbors instructs otherwise.

Do not build your own database of potential participants. Do not reuse referral information for other purposes.

You may not sell, trade, rent, share, or misuse any personal or health information obtained through Healthy Neighbors activities.

You may not use referral information for:

• · Marketing unrelated products or services.
• · Insurance sales.
• · Financial products.
• · Political outreach.
• · Fundraising.
• · Other studies not approved by Healthy Neighbors.
• · Personal benefit outside the Healthy Neighbors program.

Some uses or disclosures of health information may require written authorization or other legally valid permission. HHS explains that, under HIPAA, an authorization is generally required for uses and disclosures of protected health information that are not otherwise allowed by the Privacy Rule. (hhs.gov)

Advocates should not attempt to obtain HIPAA authorizations unless Healthy Neighbors specifically provides the approved form and instructions.

The study team, site, sponsor, or authorized Healthy Neighbors personnel will handle formal consent, authorization, eligibility screening, and research participation documents.

If someone says they do not want to be contacted:

• · Stop contacting them about that study.
• · Do not submit their information.
• · Do not pressure them to reconsider.
• · Follow any Healthy Neighbors instructions for recording opt-outs.

If someone asks to be removed from future outreach, notify Healthy Neighbors if required.

Violating these Privacy Rules may result in:

• · Required retraining.
• · Suspension of Advocate access.
• · Termination from the Advocate program.
• · Loss or withholding of referral payments.
• · Removal of referrals.
• · Legal action.
• · Reporting to regulators or affected individuals, if required.

By clicking “I Agree,” signing electronically, or continuing with Advocate registration, I acknowledge and agree that:

• · I have read and understand the Healthy Neighbors Advocate Privacy Rules and HIPAA Guidelines.
• · I will protect personal and health-related information.
• · I will collect and share only the minimum information necessary.
• · I will obtain permission before submitting any referral.
• · I will use only Healthy Neighbors-approved systems.
• · I will not publicly disclose anyone's health information.
• · I will not collect medical records, insurance information, Social Security numbers, or unnecessary medical details.
• · I will promptly report any actual or suspected privacy incident.
• · I understand that failure to follow these Privacy Rules may result in suspension, termination, non-payment, and/or other consequences.