Start Smart Plus — Notice of Privacy Practices 

Effective Date: November 2025

This notice describes how information you share with Start Smart Plus (“SSP”) may be used and disclosed, and how you can access this information.

Although SSP is not a covered entity under HIPAA, we voluntarily follow high privacy standards to protect your health-related information.

Your Rights

You have the right to:

• Access your information

You can ask to see or request a copy of the information you shared with us.

• Correct your information

If something is incomplete or inaccurate, you may request a correction.

• Request deletion

You may ask us to delete your assessment or account information unless we are legally required to retain it.

• Request confidential communication

You may ask us to contact you at a specific phone number or email.

• Restrict disclosures

You may request limits on how your information is shared. We will honor requests whenever possible.

To exercise these rights, Email: privacy@startsmartplus.com

Our Responsibilities

We are committed to:

• Protecting the privacy of your personal and health-related information

• Using your information only for the purposes described in this notice

• Informing you promptly if a data breach occurs

• Following the practices in this notice unless you authorize changes in writing

How We Use and Share Information

For Care Planning

We use your information to create personalized care recommendations, safety insights, and support tools.

For Operations

We may use your information to:

• Improve assessments

• Enhance digital platform functionality

• Train staff members assisting with care reviews

For Communication

We may contact you with:

• Updates about your care plan

• Membership information

• Platform or service improvements

With Your Permission

We may share information with:

• Other family members or caregivers you identify

• Healthcare or community partners only with your written authorization

Without Your Authorization (Rare Cases)

We may disclose information:

• If required by law

• To prevent an immediate threat to health or safety

• To comply with a subpoena or governmental request

Your Choices

You may choose to:

• Share or limit information seen by family or caregivers

• Opt out of newsletters or educational messages

• Withdraw permission at any time

Our Safeguards

We use administrative, physical, and technical safeguards, including:

• Encrypted transmissions

• Password-protected systems

• Limited staff access

• Ongoing monitoring

Changes to This Notice

We may update this Notice of Privacy Practices as our services evolve. Any revisions will apply to existing and future information.

Legal Status and Reservation of Rights

We are not regulated as a covered entity under HIPAA. The privacy practices described in this notice are offered voluntarily and may exceed what applicable law requires. This notice does not create any enforceable rights, obligations, or guarantees. We reserve the right to revise or discontinue all or any part of these practices at any time, except as otherwise required by law.

Contact Us

For questions or privacy requests:

Start Smart Plus – Privacy Office
Email: connect@startsmartplus.com
Website: www.startsmartplus.com