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1. Categories of consumer health data we collect

Individual health conditions, symptoms, status, diagnoses and treatments you tell us about or that arise from your care.
Biomarker and laboratory results, including the full history of your panels over time.
Medications and prescriptions, including dose, adherence, refills and side effects you report.
Reproductive and sexual health information, including menstrual cycle information, pregnancy status and fertility-related markers.
Bodily functions, vital signs and measurements, including any you enter or that come from a device you connect.
Use of services that identify you as seeking healthcare, such as scheduling a blood draw or a consultation.
Information used to infer any of the above.

2. Why we collect and use it

To provide the Prova service, including arranging blood draws, running and presenting panels, and maintaining your account.
To allow licensed clinicians to evaluate you, treat you and monitor your safety.
To fill and ship prescriptions.
To take payment and administer your membership.
To provide customer support and send service messages.
To detect and prevent fraud, and to secure the service.
To comply with legal obligations.

We collect and use consumer health data only with your consent, or where it is necessary to provide a product or service you have requested from us.

3. Where it comes from

You, when you complete an intake, message your care team, or enter measurements.
The clinicians of the medical group, in the course of your care.
Laboratories and phlebotomy partners that draw and analyse your blood.
Pharmacies that dispense your prescriptions.
Wearables and health apps you choose to connect.
Other healthcare providers, where you ask us to obtain your records.

4. What we share, and with whom

We share the categories listed in section 1 only as necessary to provide the service you asked for, or with your consent, with these categories of recipients:

MDI Medical Group PC and its licensed clinicians, who provide your care.
CLIA-certified laboratories and phlebotomy partners.
Licensed pharmacies.
Processors acting on our written instructions, including cloud hosting and storage, secure messaging, customer support tooling, and shipping providers. They may use the data only to perform services for us.
Government agencies, courts or others where the law requires disclosure or valid legal process compels it.
An acquirer or successor in a merger, acquisition or sale of assets, subject to this notice.

We do not share consumer health data with advertisers, advertising networks, data brokers, insurers or employers.

5. We do not sell consumer health data

Prova does not sell consumer health data. Everything we license commercially is de-identified first, and we have committed in section 4 of our privacy policy never to sell information that identifies you. If that ever changed we would first obtain your separate, valid, signed authorisation meeting the requirements of the statute, and we would not condition your membership, your price, or your care on whether you gave it.

We do license and sell de-identified and aggregated information, as described in section 5 of our privacy policy. Information de-identified in accordance with 45 C.F.R. § 164.514(b) is excluded from the definition of consumer health data under these statutes. We rely on that exclusion on the terms the statutes set: reasonable measures to ensure the information cannot be associated with you, a public commitment never to attempt to re-identify it, and a contractual obligation on every recipient to do the same and never to attempt to contact anyone represented in the data.

6. Your rights

If you live in Washington or Nevada, you have the right to:

Confirm whether we collect, share or sell your consumer health data, and access it.
Obtain a list of all third parties and affiliates with whom we have shared your consumer health data, and a contact for each.
Withdraw your consent to our collection and sharing of it.
Have it deleted, including from our archived and backup systems, and to have us notify recipients of your deletion request.
Not be discriminated against for exercising any of these rights.

Email privacy@prova.com, with consumer health data request in the subject line. We will verify your identity and respond within 45 days, and may extend once by a further 45 days where reasonably necessary, telling you if we do.

Some information must be retained after a deletion request where the law requires it, for example medical records that state law obliges the medical group to keep for a set period. We will tell you if that applies and what is being kept.

If we decline a request, you may appeal by replying to our decision. We will respond within 45 days with our reasoning. If we deny your appeal, Washington residents may contact the Washington Attorney General at www.atg.wa.gov/file-complaint, and Nevada residents may contact the Nevada Attorney General.

7. Contact

Email privacy@prova.com, or write to Raven Fitness, Inc., 95 Elizabeth St, B1, New York, NY 10013, attn: privacy.