REFERRAL CONDUIT SMS PRIVACY POLICY

Last Updated: November 22, 2025

1. INTRODUCTION

Referral Conduit, LLC ("Referral Conduit," "we," "us," or "our") provides healthcare referral management software that facilitates SMS communications between healthcare providers and patients. This SMS Privacy Policy explains how we collect, use, protect, and share information when you opt in to receive text messages through our platform.

By opting in to receive SMS messages, you consent to this Privacy Policy and our Terms of Service.

2. INFORMATION WE COLLECT

2.1 Information You Provide

When you opt in to SMS notifications through your healthcare provider's use of Referral Conduit, we collect:

• Mobile phone number

• First and last name

• Healthcare provider relationship

• Referral and appointment information

• Responses to text messages (if you reply)

2.2 Automatically Collected Information

• Message delivery status

• Timestamp of messages sent and received

• Opt-in and opt-out status

• Device information (carrier, phone type if available)

2.3 Protected Health Information (PHI)

Referral Conduit may transmit limited Protected Health Information (PHI) as defined under HIPAA, including:

• Appointment dates and times

• Healthcare provider names

• Referral status information

• General appointment instructions

We do not transmit diagnoses, detailed medical histories, or sensitive clinical information via SMS.

3. HOW WE USE YOUR INFORMATION

We use your information to:

• Send appointment reminders and referral status updates

• Facilitate communication between you and your healthcare provider

• Process opt-out requests

• Improve our service quality

• Comply with legal obligations

• Respond to your inquiries

We do NOT use your information for:

• Marketing or advertising (unless separately consented)

• Selling to third parties

• Purposes unrelated to your healthcare referral

4. MESSAGE FREQUENCY & COSTS

• Message Frequency: Varies based on your referral activity. You may receive multiple messages per referral (typically 2-5 messages per active referral).

• Costs: Message and data rates may apply as charged by your mobile carrier. We do not charge for messages, but your carrier's standard rates apply.

• Supported Carriers: Messages are supported on major U.S. carriers including AT&T, Verizon, T-Mobile, Sprint, and others.

5. DATA SHARING & DISCLOSURE

5.1 Healthcare Providers

We share your information with the healthcare provider(s) who are managing your referral. This is necessary to coordinate your care.

5.2 Service Providers

We use third-party service providers to deliver SMS messages, including:

• Twilio (SMS delivery platform)

• Secure cloud hosting providers

These providers are bound by confidentiality agreements and HIPAA Business Associate Agreements where applicable.

5.3 Legal Requirements

We may disclose information when required by law, including:

• Response to court orders or subpoenas

• Compliance with healthcare regulations

• Protection of our rights or safety

• Prevention of fraud or illegal activity

5.4 We Do NOT Sell Your Data

We never sell, rent, or trade your personal information or phone number to third parties for marketing purposes.

6. DATA SECURITY

We implement industry-standard security measures to protect your information:

• Encryption in transit (TLS/SSL)

• Encryption at rest for stored data

• Access controls and authentication

• Regular security audits

• HIPAA-compliant infrastructure

• Staff training on privacy practices

Important: While SMS is convenient, it is not as secure as patient portals. We transmit only necessary information via SMS and avoid sending sensitive medical details.

7. DATA RETENTION

We retain your SMS-related information for:

• Active Referrals: Duration of the referral process plus 90 days

• Opt-Out Records: Permanently (to honor your preferences)

• Compliance Records: As required by law (typically 6-7 years for healthcare records)

You may request deletion of your information subject to legal and regulatory retention requirements.

8. YOUR RIGHTS & CHOICES

8.1 Opt-Out (STOP)

You can opt out at any time by:

• Replying STOP to any message

• Contacting your healthcare provider

• Emailing support@referralconduit.com

You will receive a confirmation message and will not receive further SMS messages.

8.2 Help (HELP)

Reply HELP to any message or contact support@referralconduit.com for assistance.

8.3 Access & Correction

You have the right to:

• Access the information we have about you

• Request corrections to inaccurate information

• Request deletion (subject to legal requirements)

To exercise these rights, contact your healthcare provider or email privacy@referralconduit.com.

8.4 HIPAA Rights

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

• Your healthcare provider

• Referral Conduit: privacy@referralconduit.com

• U.S. Department of Health & Human Services: www.hhs.gov/ocr/privacy

9. HIPAA COMPLIANCE

Referral Conduit operates as a Business Associate under HIPAA. We:

• Execute Business Associate Agreements (BAAs) with healthcare providers

• Implement administrative, physical, and technical safeguards

• Limit PHI transmission to minimum necessary information

• Train staff on HIPAA requirements

• Maintain audit logs

• Report breaches as required by law

Patient Rights Under HIPAA: You have the right to access, amend, and receive an accounting of disclosures of your PHI. Contact your healthcare provider to exercise these rights.

10. CHILDREN'S PRIVACY

Referral Conduit does not knowingly collect information from individuals under 13 years of age without parental consent. Healthcare providers are responsible for obtaining appropriate consent for minors receiving SMS notifications.

11. STATE-SPECIFIC RIGHTS

California Residents (CCPA/CPRA)

You have additional rights including:

• Right to know what personal information is collected

• Right to delete personal information

• Right to opt out of sale (we do not sell data)

• Right to non-discrimination

Other States

Residents of other states may have additional privacy rights under state law. Contact privacy@referralconduit.com for information.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. Changes will be posted at referralconduit.com/privacy and the "Last Updated" date will be revised. Continued use of SMS services after changes constitutes acceptance of the updated policy.

For material changes affecting your rights, we will provide notice via SMS or email when possible.

13. INTERNATIONAL USERS

Referral Conduit services are intended for use in the United States. If you are outside the U.S., your information may be transferred to and processed in the United States, which may have different data protection laws than your country.

14. EMERGENCY DISCLAIMER

IMPORTANT: SMS messages are not monitored in real-time and should NOT be used for medical emergencies. If you have a medical emergency, call 911 immediately or go to the nearest emergency room.

15. CONTACT INFORMATION

Referral Conduit, LLC

Privacy Officer:
 Email: support@referralconduit.com
 Phone: +19045713913

Address: 333 Crockett Blvd #540671

Merritt Island, FL 32953

 Website: www.referralconduit.com

For SMS Support:
 Email: support@referralconduit.com
 Reply HELP to any message

For HIPAA Complaints:
support@referralconduit.com

16. CONSENT & ACKNOWLEDGMENT

By opting in to receive SMS messages through Referral Conduit:

• You acknowledge you have read and understood this Privacy Policy

• You consent to the collection, use, and disclosure of your information as described

• You understand that SMS is not secure for sensitive medical information

• You acknowledge that message and data rates may apply

• You understand you can opt out at any time by replying STOP

17. TERMS OF SERVICE

This Privacy Policy is part of and incorporated into our Terms of Service. By using SMS services, you also agree to our Terms of Service available at referralconduit.com/terms.

END OF PRIVACY POLICY

This policy complies with TCPA, HIPAA, CCPA/CPRA, and federal/state privacy regulations applicable to healthcare SMS communications.