This notice supplements our general Privacy Policy and addresses the rights of Washington state residents under the Washington My Health My Data Act (“MHMD Act,” RCW Chapter 70.372), effective March 31, 2024. It applies specifically to personal data that qualifies as “consumer health data” under Washington law. Revana Health, LLC is a management services organization that provides administrative, technology, and care-coordination support; it is not a healthcare provider and does not practice medicine.
What Is Consumer Health Data
Washington law defines “consumer health data” broadly to include any personal information that identifies or is reasonably linkable to a consumer and relates to their health status, condition, treatment, or health-related behaviors — including data derived or inferred from non-health data. Examples we may collect include: health conditions, diagnoses, symptoms, medications, lab results, treatment history, and clinical records collected in connection with HRT, GLP-1/weight management, and peptide therapy; precise geolocation data that could reasonably indicate you are seeking or receiving healthcare; information such as pages viewed, search terms, or product inquiries that could be used to infer a health condition or interest in a treatment; and any other information that may be used to derive or infer health-related attributes about you.
Geofencing Prohibition
We do not implement or use geofencing technology to identify, track, or collect consumer health data from individuals entering a facility that provides in-person health care services, including hospitals, clinics, pharmacies, or mental health facilities, as prohibited under RCW 70.372.060.
How We Collect, Use, and Share Consumer Health Data
We collect consumer health data primarily through information you provide directly when creating an account, completing clinical intake forms, or interacting with our platform. We may also collect limited consumer health data through cookies and analytics tools where you have provided consent through our Cookie Consent tool. We do not collect consumer health data through cookies without your affirmative consent.
We use consumer health data to coordinate and deliver the healthcare services you request, and may also use it for quality improvement, regulatory compliance, and fraud prevention. We will not use it for purposes beyond those disclosed without first obtaining your affirmative consent.
Categories of parties with whom we may share consumer health data: licensed healthcare providers and pharmacies directly involved in your care; service providers contractually prohibited from using your data for their own purposes; affiliated professional entities where access is required for clinical operations; government authorities or law enforcement when required by valid legal process or to prevent serious harm; and successor entities in a merger, acquisition, or business transfer, subject to applicable notification requirements.
Your Rights Under the MHMD Act
Washington residents have the following rights, subject to certain exceptions: Right to access a list of all third parties with whom we have shared your consumer health data and a copy of the data itself; Right to deletion of your consumer health data from our systems and those of our service providers; Right to withdraw consent to the collection, use, or sharing of your consumer health data at any time; and Right to confirm whether we are collecting or sharing your consumer health data. Certain rights may be subject to exceptions where retention or use is required by law, including medical record retention obligations.
How to Exercise Your Rights
Email support@myrevana.com with your full name, email address, and a clear description of the right you wish to exercise. We will respond within 45 days, with a possible 45-day extension where reasonably necessary. To opt out of data collection through Google Analytics, install the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout.
Appeals and Complaints
If we deny your rights request, you may appeal by emailing support@myrevana.com with the subject line “MHMD Appeal,” including your original request and reason for appeal; we will respond within 45 days. If your appeal is unsuccessful, you may file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.