Privacy Policy
OUR COMMITMENT TO PRIVACY
Corvan Health LLC ("Company") respects your privacy and wants to inform you about how and why we collect, use, and share your data. This Privacy Policy applies to all activities engaged in with Company through this website and its related technology platform ("Services"). Protected health information ("PHI") you share in the course of receiving care from affiliated medical practices is governed by the Health Insurance Portability and Accountability Act ("HIPAA") and by the separate Notice of Privacy Practices issued by the affiliated medical practice providing your care.
1. DATA YOU GIVE US Company may collect different data from or about you, depending on how you use Company's Services. Some of the data we may collect includes: (1) data related to your user account, including your e-mail address, phone, password, gender, date of birth, and state of residence; (2) data related to any user profile you create, including comments or posts you submit on Company's website and your testimonials about Company's services; (3) the program(s) you apply for or treatments you express interest in; (4) payment and billing data; (5) communications you have with Company, including your communications with Company support; (6) technical data related to your device, including your IP address, browser type, and device identifiers; and (7) data showing your usage of the Services, including pages you visited and forms you submitted. We may store this information in a manner that associates it with your account.
2. HOW WE RECEIVE YOUR DATA Company and service providers acting on its behalf may use server log files and automated data collection tools (such as cookies, tags, scripts, customized links, and device or browser fingerprints) when you access and use the Services. These methods can automatically track and collect certain data when you use Company's Services. In some cases, Company may tie data gathered through those data collection tools to other data that we collect as described in this Privacy Policy. Company may use cookies (small files that websites send to your device to uniquely identify your browser or device or to store data in your browser) for things like analyzing your use of the Services, personalizing your experience, making it easier to log into the Services, and recognizing you when you return.
Consistent with the December 2022 HHS Office for Civil Rights bulletin on tracking technologies, no third-party advertising trackers (such as Meta Pixel, Google Ads conversion pixels, or TikTok pixels) are deployed on any page where you submit health information, complete the patient application, or interact with patient portal content. Any analytics or marketing-related tracking that Company elects to deploy is restricted to non-PHI marketing surfaces only and is described in our cookie banner where applicable.
3. HOW WE USE & SHARE YOUR DATA Company uses your data in several ways, including but not limited to the following: providing and administering the Services, including to display customized content and facilitate communication with you and others; processing your requests and orders for programs, products, specific services, information, or features; communicating with you about your account; managing your account preferences; facilitating the Services' technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse; soliciting feedback from users; marketing and administering surveys and promotions administered or sponsored by Company; learning more about you by linking your data with additional data through third-party data providers or analyzing the data with the help of analytics service providers; identifying unique users across devices; tailoring advertisements across devices; improving our Services and developing new products, services, and features; analyzing trends and traffic, tracking usage data; advertising the Services on third-party websites and applications; as required or permitted by law; or as Company, in its sole discretion, otherwise determines to be necessary to ensure the safety or integrity of its users, employees, third parties, the public, or Company's Services.
Company may share your data with third parties as follows:
• Company shares your data with third-party companies who perform services on Company's behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
• Company shares limited, necessary data with affiliated medical practices, licensed compounding pharmacies, and laboratories to facilitate the clinical services you have requested. Once that data is in the hands of an affiliated medical practice, it becomes PHI under HIPAA and is governed by that practice's Notice of Privacy Practices.
• Company may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
• Company may disclose your data to third parties if Company (in our sole discretion) has a good faith belief that the disclosure is: permitted or required by law; requested as part of a judicial, governmental, or legal inquiry, order, or proceeding; reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request; reasonably necessary to enforce our Terms of Service, Privacy Policy, and other legal agreements; required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or reasonably necessary in Company's discretion to protect against imminent harm to the rights, property, or safety of Company, its users, employees, members of the public, or its Services.
• If Company undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
• With your consent, Company may share data to third parties outside the scope of this Privacy Policy.
Company does not sell your personal information for monetary consideration.
4. SECURITY Company takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data. Unfortunately, however, no system can be 100% secure, so Company cannot guarantee that communications between you and Company regarding the Services or materials, or any information provided to Company in connection with the data we collect through the Services, will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately.
5. YOUR RIGHTS You can choose not to provide certain data to Company, but you may not be able to use certain features of the Services. To opt out of receiving any promotional communications from Company, you can use the "unsubscribe" mechanism included in the communication. Note that regardless of your email preference settings, we will send you transactional and relationship messages regarding the Services, including administrative confirmations, application confirmations, important updates about the Services, scheduling emails, and notices about our policies. Any other "opting out" would need to be completed by you through your internet browser settings.
After termination of your account with Company, some or all of your data may still be visible to Company and others. Even after your account is terminated, we retain your data for as long as Company has a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce Company's agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.
Access, correction, or deletion requests for non-PHI personal data may be submitted to the email address listed in the site footer. PHI access, amendment, and accounting-of-disclosures requests are handled directly by the affiliated medical practice that created the record — see the Notice of Privacy Practices at /hipaa for that process. Please allow up to 30 days for a response. For your protection, Company may require that the request be sent through the email address associated with your account, and Company may need to verify your identity before implementing your request.
6. JURISDICTION-SPECIFIC RULES & NOTICES If you are a California resident, you have the right to request certain details about what personal information Company shares with third parties for those third parties' direct marketing purposes. To submit your request, send an email to the address listed in the site footer with the phrase "California Shine the Light" or "California CCPA Request" and include your mailing address, state of residence, and email address.
In addition, the California Consumer Privacy Act of 2018 ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), provides California resident consumers with specific rights regarding their personal information.
7. ACCESS TO INFORMATION AND DATA PORTABILITY You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you. • The categories of sources for the personal information we collected about you. • Our business or commercial purpose for collecting or selling that personal information. • The categories of third parties with whom we share that personal information. • The specific pieces of personal information we collected about you (also called a data portability request). • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
8. DELETION REQUEST RIGHTS You have the right to request that we delete any of your personal information that we collected from you and retained (with certain exceptions). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to: complete the transaction for which we collected the personal information; provide a good or service that you requested; take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; debug products to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.); engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; comply with a legal obligation; or make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at the address listed in the site footer. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
9. RESPONSE TIMING AND FORMAT We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
10. NON-DISCRIMINATION We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Corvan Health LLC is headquartered in the United States, and to provide the Services to you we must transfer your data to and process it within the United States. By visiting or using Company's Services, you consent to storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries.
11. UPDATING THE PRIVACY POLICY AND INCORPORATION OF TERMS When Company deems it appropriate, it may update this Privacy Policy to clarify its practices or to reflect new or different practices. Company reserves the right in its sole discretion to modify and/or make changes to this Privacy Policy at any time. If Company makes any material change, it will notify you using prominent means such as by email notice sent to the email address specified in your account or by posting a notice through its website. Modifications will become effective on the day they are posted unless stated otherwise.
Your continued use of our Services after changes become effective shall mean that you accept those changes. Any revised Privacy Policy shall supersede all previous Privacy Policies. The terms and conditions contained within Company's Terms of Service are incorporated herein.