Privacy Policy

1. Who you are dealing with

Raven Fitness, Inc., doing business as Prova Health ("Prova", "we", "us"), is a technology and administrative services company registered in Delaware. Prova is not a medical practice and does not practise medicine.

Clinical care is provided by licensed physicians of MDI Medical Group PC (the "medical group"), an independent professional corporation that Prova contracts with. The medical group makes all clinical decisions, including whether to prescribe anything at all. Prova provides scheduling, laboratory logistics, billing and administrative support, and has no say in what a physician decides.

This distinction changes which rules apply to which information, so it is worth being precise about it:

• Your medical record, your physician's notes and your prescriptions are held by the medical group. That information is protected health information under HIPAA, the medical group is the covered entity responsible for it, and the medical group's notice of privacy practices governs it. Prova is not a covered entity and is not a business associate of the medical group.
• Everything Prova collects from you directly, including your account details, the answers you give before any clinician sees you, your laboratory results, information from devices you connect, and how you use the website, is held by Prova. Because Prova is not a covered entity, that information is not governed by HIPAA. It is governed by this policy, by the Federal Trade Commission Act, and by state consumer health data laws including the Washington My Health My Data Act.

The two sets overlap heavily, and we protect both to the same standard. We describe the difference because it determines who you ask for what: your medical record from the medical group, everything else from us. Section 5 concerns the information Prova holds, which is the larger part.

2. What we collect

Information you give us

• Account and identity: your name, email address, phone number, date of birth, the state you live in, and your shipping and billing address.
• Intake and health history: the answers you give in the questionnaire, including your goals, symptoms, menstrual and reproductive history, pregnancy status, current medications, allergies, past conditions, and family history.
• What you tell your care team: messages, reported side effects, and anything else you share in the course of care.
• Measurements you enter yourself: weight, blood pressure, sleep, cycle dates, and similar.

Information created by using Prova

• Laboratory results: the biomarker values on every panel you take, the date of each draw, and the full history of how those values have moved over time.
• Clinical information: your physician's assessment, what was prescribed, the dose, and the date set for the next draw.
• Treatment and outcome information: refills, adherence, side effects you report, whether you continued or stopped, and what your markers did afterwards.
• Payment information: our payment processor handles your card. We receive only limited details such as the brand, the last four digits and the expiry date.

Information collected automatically

• Device and usage information: ip address, device and browser type, pages viewed, time on page, and the site or advert you arrived from.
• Cookies and similar technologies, described in section 8.

Information from other sources

• The laboratories and phlebotomy partners that draw and run your panels.
• The pharmacies that dispense anything you are prescribed.
• Wearables and health apps, but only the ones you choose to connect, and only the data types you approve.
• Your other healthcare providers, where you ask us to request your records.

3. How we use information

We use information to:

• Create and run your account, and schedule and process your blood draws.
• Make your results legible to you and available to your physician.
• Allow the medical group to assess you, decide what would help, and monitor your safety over time.
• Fill, ship and refill prescriptions through our pharmacy partners.
• Take payment and administer your membership.
• Answer your questions and provide support.
• Monitor the safety of the service, including detecting results that need urgent attention.
• Improve the product, and build and evaluate the models behind it, as described in section 5.
• Send you service messages, and marketing messages you can opt out of at any time.
• Comply with the law, respond to lawful requests, enforce our terms, and prevent fraud and abuse.

4. Four things we do not do

These commitments are binding, and they are the frame for section 5. So that there is no ambiguity:

• We do not sell, license, or otherwise provide for value any information that identifies you. Everything we license commercially is de-identified first, without exception.
• We do not give pharmaceutical companies, data brokers, insurers or employers information that identifies you, unless the law compels us.
• We do not put health information into advertising pixels, trackers or tags, and we do not use your health information to target advertising to you on other companies' platforms.
• We do not use your information to decide your premiums, your employment, or your eligibility for anything outside Prova, and we do not provide it to anyone who does.

We will not weaken these four commitments by quietly updating this policy. If we ever propose to change one, we will tell you before it takes effect, and we will not apply the change to information collected beforehand without your agreement.

5. Research, product development and de-identified data

This section describes a core part of both our product and our business, and we would rather state it directly than bury it.

What we are trying to learn

Prova connects three things that are normally kept apart: what your blood shows, what a physician prescribed in response, and what happened to those markers afterwards. Almost nobody holds all three together for the same person over time, which is why so much of women's health is still guesswork. Analysing that linkage is how we learn which treatments actually move which markers, in whom, and how quickly.

De-identification

Before information is used for the purposes in this section, we de-identify it to the standard set out at 45 C.F.R. § 164.514(b). A repeated panel of many markers measured over months is more revealing than any single result, so for longitudinal datasets we use the Expert Determination method, in which a qualified statistician certifies that the risk of re-identification is very small, rather than relying on the Safe Harbor identifier list alone. We keep that determination on file and repeat it when the dataset materially changes. De-identified information no longer identifies you, cannot reasonably be used to identify you, and is not protected health information, personal information, or consumer health data under the laws described in section 9.

What we do with de-identified information

We use, combine, analyse, retain, publish, license and sell de-identified and aggregated information for any lawful purpose. Specifically, this includes:

• Improving the Prova service, including how we read, rank and present results.
• Developing, training, testing and improving statistical models, algorithms and machine learning systems, including models that estimate how a given marker is likely to respond to a given treatment.
• Research into women's health, including research we publish, and research conducted with academic or clinical collaborators.
• Creating aggregated datasets, benchmarks, analyses and reports that we provide or license to third parties on a commercial basis. Those third parties may include pharmaceutical, biotechnology and diagnostics companies, researchers, and health systems.

In many cases we provide the results of an analysis rather than the data behind it, or allow a collaborator to run an approved analysis against the dataset and receive only aggregate output. Where we do that, no individual record leaves our control at all.

We may earn revenue from these activities. That revenue is part of how Prova is funded, and it is one reason we are able to price the membership the way we do.

Everything we license or sell is de-identified first. Because de-identified information is not consumer health data under Washington's My Health My Data Act, the separate signed authorisation that Act requires before consumer health data may be sold does not arise for us. We rely on that exemption on the terms the Act sets: we take reasonable measures to ensure the information cannot be associated with you, we publicly commit here never to attempt to re-identify it, and we require the same by contract of everyone who receives it.

Limits we accept

• We do not attempt to re-identify de-identified information, except to test that our de-identification works.
• We require every recipient of de-identified information, by contract, not to re-identify it and not to attempt to contact anyone represented in it.
• We do not sell, license or otherwise provide identifiable health information for these purposes.
• If we ever want to use information that identifies you for our own research, we will ask for your specific written consent first, or proceed only under the oversight of an independent institutional review board. We will not sell or license it in identifiable form in either case.

Your choice

You can tell us not to include your information in research or model development, even in de-identified form, by emailing privacy@prova.com. We will honour it going forward. It will not affect your care, your membership, your price, or how you are treated in any way. We cannot withdraw information from analyses already completed or from datasets already provided to a third party, and we cannot retrieve de-identified information once it has left our control, because by design it is no longer linked to you.

6. Who we share information with

We share information that identifies you only as follows:

• MDI Medical Group PC and the physicians in its network, so that you can be assessed and treated.
• Laboratories and phlebotomy partners, so that your blood can be drawn and your panels run.
• Pharmacies, so that anything you are prescribed can be dispensed and shipped.
• M&D Integrations, Inc., which operates the telehealth platform the medical group uses, and which receives the intake answers and laboratory results a physician needs in order to treat you.
• Service providers acting on our instructions and bound by contract. These include cloud hosting, data storage, analytics, customer support, email and SMS delivery, shipping, and payment processing.
• Other people or providers you direct us to share with, such as your own physician.
• Authorities and others where the law requires it, where we must respond to valid legal process, where it is necessary to prevent serious harm, or to establish or defend legal claims.
• A buyer or successor, if Prova is involved in a merger, acquisition, financing, reorganisation or sale of assets, or in bankruptcy. Information, including de-identified datasets, may be transferred as a business asset. Any buyer will remain bound by this policy for information collected before the transfer, unless you are told otherwise and given a choice.

We also provide de-identified information to third parties, including commercially, as described in section 5.

7. How we protect information

We encrypt information in transit and at rest, restrict access to staff who need it for their role, log access to clinical records, require business associate agreements from vendors who handle protected health information, and review our security practices regularly.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach affects your information, we will notify you and the relevant regulators as the law requires.

8. Cookies, analytics and advertising

We use cookies and similar technologies to keep you signed in, remember your preferences, measure how the site performs, and understand which marketing brings people to Prova.

As stated in section 4, we do not place health information into advertising or analytics tags. Our advertising measurement is limited to non-health events such as visiting a page or starting a membership, and we configure our advertising partners to prevent them using that data for their own purposes.

You can control cookies through your browser. We honour the global privacy control signal as an opt out of sale and sharing where state law recognises it.

9. Your rights and choices

Wherever you live in the united states, you can ask us to:

• Give you a copy of the information we hold about you, including your lab results and medical record.
• Correct information that is wrong.
• Delete information, subject to the medical record retention periods described in section 10.
• Provide your information in a portable format.
• Stop sending you marketing.
• Stop using your information for research and model development, as described in section 5.
• Withdraw a consent or authorisation you previously gave, including your telehealth consent.

Email privacy@prova.com to exercise any of these. We will verify your identity before acting, respond within the time the law allows, and will not treat you differently for asking. If we refuse a request you may appeal by replying to our decision, and we will review it and explain the outcome.

California

California residents have the rights above under the CCPA as amended, plus the right to know the categories of personal information we collect, the sources, the business purposes, and the categories of recipients, all of which are set out in sections 2, 3 and 6. Health information is sensitive personal information, and we use it only for the purposes permitted without a right to limit, or as you have directed. We do not sell or share personal information as those terms are defined by the CCPA; de-identified information is not personal information under that statute. Medical information held by or for the medical group is also protected by the confidentiality of medical information act.

Washington and Nevada

If you live in Washington or Nevada, your consumer health data is covered by a separate notice, the Prova consumer health data privacy policy, which is linked from our homepage and from the footer of every page. It describes the categories we collect, why, who we share them with, and how to exercise your rights, including the right to withdraw consent and to have consumer health data deleted.

Other states

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Minnesota, Tennessee, Maryland, Indiana, Kentucky and Rhode Island have comparable rights of access, correction, deletion, portability, and opt out of targeted advertising, sale and certain profiling, together with a right to appeal. We treat health information in these states as sensitive data requiring your consent.

10. How long we keep information

Medical records, including your lab results, are retained by the medical group for the period required by the law of your state, which is commonly between seven and ten years after your last encounter, and longer where the patient was a minor. We keep account and billing records for as long as needed for tax, accounting and legal purposes.

When information is no longer needed we delete it or de-identify it. De-identified information is retained indefinitely, as described in section 5.

11. Children

Prova is for adults aged 18 and over. We do not knowingly collect information from anyone under 18. If you believe a minor has given us information, email privacy@prova.com and we will delete it.

12. Changes to this policy

We will post any changes here and update the date at the top. If a change materially reduces your privacy or expands how we use your health information, we will tell you before it takes effect and, where the law requires it, ask for your consent.

13. Contact us

Email privacy@prova.com, or write to Raven Fitness, Inc., 95 Elizabeth St, B1, New York, NY 10013, attn: privacy. For questions about your medical record, contact MDI Medical Group PC at the same address.