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Effective Date:  August 21, 2023

Ravel Health Privacy Policy

At Ravel Health Provider Network, LLC (“Ravel Health” “we,” “us,” or “our“), we value your trust.   We are committed to acting responsibly when we collect, use and protect your non-personal and personal information.

We believe in being clean and open about how we collect data related to you when you visit our website at https://ravel.health/ (“Website”), participate in our Patient Pilot Program (“Pilot”), access our online library, interact with us (on the Website, via telephone, virtual meeting, etc.), or engage with any pages, features, or content we own, operate and/or provide on the Website (collectively with the Website, the “Services”).

Federal and state laws say that we must tell you how we collect, share and protect your personal information. This Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use, share and safeguard the information you provide to us and to assist you in making informed decisions when using our Services.  Please read this Privacy Policy very carefully.

By accessing and using the Services, you consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. The Services are intended for users located in the United States only, and you hereby expressly acknowledge and agree that if you are accessing and/or using the Services that you reside in the United States and will only access and/or use the Services in the United States.

1. COLLECTION OF INFORMATION

We collect “Non-Personal Information” and “Personal Information” and the information we collect from you depends on how you use the Services. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

We may collect the following types of information when you use the Services:

(a) Information you provide directly to us. For certain activities such as when you apply for and join our Pilot waitlist or contact us directly, email us, complete our online contact form, participate in a survey, or have a Zoom meeting with us for a brief survey about the Pilot, we may collect some or all of the following Personal Information:

  • When you join our waitlist by completing the form on our Website, we will collect your contact information such as your first and last name, email address and the State where you live.
  • When you complete the Contact Form on our Website, we will collect your first and last name, your email address and any comments that you voluntarily include in the comment field. Please do not include any sensitive information in the comment field.
  • When you participate in a hosted Zoom meeting, we will collect your username, if applicable, and email address.
  • We may use your phone number to call you to communicate with you about the Services.

(b) Information we collect automatically. We may collect certain information automatically when you use our Services such as, but not limited to, your computer’s Internet protocol (IP) address, device and advertising identifiers, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, information about the links you click and pages you view within the Services, and other standard server log information. We may also collect certain location information when you use our Services such as your mobile device’s GPS signal or information about nearby WiFi access points and cell towers.

We may use cookies, pixel tags, and similar technologies to automatically collect this information. Cookies are small bits of information that are stored by your computer’s web browser. Pixel tags are very small images or small pieces of data embedded in images, also referred to as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Services, you consent to our use of cookies, pixel tags, and similar technologies.

We may also collect technical data to address and fix technical problems and improve our Services. Your device or browser settings may permit you to control the collection of this technical data. By using the Services, you are consenting to letting us or any party acting on our behalf collect this technical data.

(c) Our Website uses social media connectors. They are social media buttons, such as Facebook, Instagram, LinkedIn and Twitter, you see on our Website or blog posts that allow you to connect and learn more about us and interact with us, our users and marketing partners. These social media third-party providers may combine your information with other information they have about you. The Personal Information that is shared with them will be governed by the third-party provider’s privacy policy and will apply to any Personal Information Ravel Health may access through the third-party provider.

(d) Information we obtain from your health care providers and other sources. In connection with the Pilot, we will have access to your medical records from your past, current, and future health care providers. This may include information about your diagnosis, previous treatments, general health, laboratory and pathology test results and reports, social histories, any family history of illness, and records about phone calls and emails related to your health.

(e) Other Sources.  We may also receive information about you from other sources, including through third-party services and organizations.

We may also use third party analytics services such as Google Analytics to collect information about how you use and interact with our Services. Such third-party analytics services may use Cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and which website referred you to the Website.

To learn more about Google, analytics, please click on the links below.

Google Analytics is an analytics service provided by Google LLC. (US).:

  • https://support.google.com/analytics/answer/7318509?hl=en
  • https://policies.google.com/technologies/partner-sites
  • https://support.google.com/analytics/answer/6004245

You may opt-out of Google Analytics for display advertising or customize Google display network ads by managing your privacy controls on Google's website.

2. USE OF INFORMATION

We generally use the information we collect online to:

(a) Provide and improve the Services;

(b) Contact you and/or if you provide us feedback or contact us via email, we may collect your name, if stated, and email address, as well as any other content included in the email, in order to send you a reply.

(c) Fulfill your requests for products, services, and information;

(d) Send you information about additional services or general wellness from us;

(e) Analyze the use of the Services and user data to understand and improve the Services;

(f) Comply with legal obligations, as part of our general business operations, and for other business administration purposes;

(g) Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection;

(h) Send you administrative email notifications, such as security or support and maintenance advisories;

(i) Give you notices about your subscription, including expiration and renewal notices;(j) Conduct research using your information, which may be subject to your separate written authorization;

(k) In very limited circumstances where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Privacy Policy;

(l) For any other purposes disclosed to you at the time we collect your information or pursuant to your consent: and

(m) In general, we use Non-Personal Information to help us improve the Services and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Services. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, and other third parties at our discretion.

In compliance with the CAN-SPAM Act, all emails sent from our organization will clearly state who the email is from and provide clear information on how to contact the sender. In addition, all email messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.

3. SHARING OF INFORMATION

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. As a general rule, we do not sell, rent, lease or otherwise transfer any information collected either automatically or through your voluntary action. We may disclose your Personal Information as described below and as described elsewhere in this Privacy Policy.

(a) Authorized third-party vendors and service providers. We may share your information with third-party vendors and service-providers that help us with specialized services, including billing, payment processing, providing medical advice, management and hosting of telehealth services, customer service, email deployment, business analytics, performance monitoring, hosting, and data processing. These third-party vendors and service providers may not use your information for purposes other than those related to the services they are providing to us. No information provided by patients during medical consultations is used for marketing purposes. The third-party service providers we are engaged with and/or third-party products and/or services we use to provide the Services include without limitation:

AWS Terms of Service, Privacy: for the purpose of hosting our database server.

Integrations and Third-Party Services. We integrate third-party Application Programming Interface (“API”) in connection with the Services that we offer you. The information collected by Ravel Health when using the API, is processed in compliance with this Privacy Policy. Information collected by third-party API partners is governed by their privacy policies and Ravel Health does not own or control those third parties.

The API third-party partners include:

  • Cerbo, LLC (“Cerbo”) for the purpose of Electronic Health Record (“EHR”) keeping and providing access to a subscription-based service that allows patients to receive telehealth integrative care which includes patient consultations with Lyme-literate Ravel Health Providers. You agree and acknowledge that by signing up and creating an account on Cerbo and using such telehealth and other services, Cerbo’s privacy policy and Cerbo’s terms of use will apply. 
  • Fullscript for supplement orders and fulfillment. You can access Fullscript’s privacy statement here.
  • Rupa Health is a diagnostic lab for ordering and receiving lab results. You can access Rupa Health’s privacy policy here.

Payment Processor. Stripe is our payment processor on Cerbo. We do not process any of your payment information. To learn more about Stripe and it’s privacy policy, please click here.

(c) Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, health, safety, and security of Ravel Health, our affiliates, patients, users, or the public. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.

(d) Business Transfers. If (i) Ravel Health is acquired by, merges with, or receives investment from another company or (ii) if any of the Ravel Health’s assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your Personal Information with lenders, auditors, attorneys and consultants.

(e) Other Disclosures. Regardless of any choices you make regarding your Personal Information (as described below), we may disclose Personal Information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on us; (c) to protect or defend our rights or property, or the rights or property of users of the Services; (d) to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or any agreements you may have with us, as applicable.

(f) With your consent or at your direction. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

If you choose to engage in public activities on the third-party sites that we link to, you should be aware that any information you share there can be read, collected, or used by other users of these sites and forums. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in public areas.

4. SECURITY

We implement security measures designed to protect your information from unauthorized access, alteration, disclosure and/or destruction. Because the internet is not a completely secure environment, we cannot warrant the security of any information a user transmits to us or guarantee that information on the Services may not be accessed, disclosed, altered, and/or destroyed by breach of any of our physical, technical and/or managerial safeguards.  We protect your information from potential security breaches by implementing certain technological security measures; however, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. While we use reasonable efforts to protect your Personal Information, we cannot guarantee the Services are absolutely secure.

5. HOW WE RETAIN YOUR PERSONAL INFORMATION

We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise periods for which we keep your Personal Information vary depending on the nature of the information and why we need it. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use and/or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with a user) for research or statistical purposes in which case we may use this information indefinitely without further notice.  We may retain information (including without limitation your personally identifiable information) for a commercially reasonable time for backup, archival, audit purposes, and/or to comply with legal obligations, resolve disputes and enforce agreements. In some cases, if you choose not to provide us with requested information, you may not be able to use the Services. You can request further details of retention periods for different aspects of your Personal Information by contacting us.

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized, or de-personalized information which we may retain indefinitely.

6. THIRD-PARTY LINKS AND CONTENT

As part of the Services, we may provide links to or compatibility with other websites or applications; however, we are not responsible for the privacy practices employed by those websites or the information or content they contain nor are we liable for third party products, services, acts and/or omissions. This Privacy Policy applies solely to information collected by us in relation to the Services and your use of the Services. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by selecting a link on our Website or via the Services. To the extent that you access or use the Services through or on another website or application, then the privacy policy of that other website or application will apply to such access and/or use. We encourage our users to read the privacy statements of other websites before proceeding to use them.

7. LIMITING DATA COLLECTION AND DO NOT TRACK

(a) Opt-Out. To opt out of interest-based advertising across browsers and devices from companies that participate in the Digital Advertising Alliance or Network Advertising Initiative opt-out programs, please visit their respective websites. You may also be able to opt out of interest-based advertising through the settings within your mobile device, but your opt-out choice may apply only to the browser or device you are using when you opt out, so you should opt out on each of your browsers and devices if you want to disable interest-based advertising for those browsers and devices. If you opt out, you will still receive ads but they may not be as relevant to you and your interests, and your experience on our Services may be degraded to some extent.

(b) Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted or whether they even are aware of them. We currently do not take action in response to these signals.

8. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION

Your Rights and Choices

If applicable privacy laws allow, you may have rights over your Personal Information.  This includes, but is not limited to:

  • Right to Know. You have the right to request disclosure about our Personal Information collection practices during the prior 12 months, including the categories of Personal Information we collected, the sources of the information, our business purposes for collecting or sharing the information and the categories of third parties with whom we shared such information. You may request a copy of the specific pieces of Personal Information we may have collected about you in the last 12 months.
  • Right to Delete.  You may request that we delete (and direct our service providers to delete) your Personal Information, subject to certain exceptions.
  • Right to Opt-Out.  You have the right to opt-out of any ‘sales’ of your Personal Information, if a business is selling your information. For clarity, we do not sell your Personal Information.
  • Non-Discrimination. You have the right to not be discriminated against for exercising these rights.

You can make the following choices regarding your Personal Information:

Access To Your Personal Information. You may request access to your Personal Information by contacting us at the address below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you.  We will provide this information in a portable format, if required.  Note that California residents may be entitled to ask us for a notice describing what categories of Personal Information (if any) we share with third parties or affiliates for direct marketing. 

  • Changes To Your Personal Information. We rely on you to update and correct your Personal Information. Please contact us at the address below immediately if there are any changes to your Personal Information. Note that we may keep historical information in our backup files as permitted by law. 
  • Deletion Of Your Personal Information.  Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law, or as otherwise described in this Privacy Policy. You may, however, request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. 
  • Objection to Certain Processing.  You may object to our use or disclosure of your Personal Information by contacting us at the address below. 
  • Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you communications related to your use of the Services and administrative purposes for reasons such as providing you with updates to this Privacy Policy.
  • Revocation Of Consent.  If you revoke your consent for the processing of Personal Information, then we may no longer be able to provide you Services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address below.

9. Children’s Online Privacy Protection Act (“COPPA”)

COPPA requires that online service providers get parental consent before they knowingly collect personally identifiable information online from children under the age of thirteen (13). Our Services are not designed for children under 13, and we do not intentionally or knowingly collect Personal Information from users who are under the age of 13 or from other websites or services directed at children. If we discover that a child under 13 has provided us with Personal Information, we will delete such information.

10. ACCESSIBILITY

If you are visually impaired, you may access this Privacy Policy through your browser’s audio reader.

11. CROSS-BORDER USE AND INTERNATIONAL LAWS/USERS

Ravel Health is located in the United States. The Services are hosted in an provided from the United Stated and are intended for those that reside in the United States only. 

Personal information that you submit through the Services may be transferred outside of the jurisdiction in which you live.  We may also store Personal Information locally on the devices you use to access the Services. If you access or use the Services from outside the United States, you do so at your own risk and are responsible for compliance with all applicable laws and regulations of your jurisdiction.

We maintain information in the United States of America and in accordance with the laws of the United States, which may not provide the same level of protection as the laws in your jurisdiction. By attempting to use the Services and providing us with information, you understand and agree that your information may be transferred to and stored on servers located outside your resident jurisdiction and, to the extent you are a resident of a country other than the United States, that you consent to the transfer of such data to the United States for processing by us in accordance with this Privacy Policy.

12. CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time at our sole discretion. When we update the Privacy Policy, we will revise the “Effective Date” date first stated above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you use the Services to stay informed of our privacy practices.

13. QUESTIONS?

If you have any questions about this Privacy Policy or our practices, please email jaime@ravel.health or kevin@ravel.health or send correspondence via mail to:

Ravel Health, LLC
2255 Sheridan Blvd., Unit C256
Edgewater, CO 80214

We will attempt to respond to your request and to provide you with additional privacy-related information.