Privacy Policy

Revela Holdings, Inc. and its telehealth subsidiary Revela Care (collectively, "Revela," "we," "us," or "our") are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit Revela.care, use our mobile application, or receive telehealth services through our platform (collectively, the "Services"). Please read this policy carefully. If you do not agree with its terms, please do not access or use our Services.

1. Information We Collect

We collect information in three ways: information you provide directly, information collected automatically, and information received from third parties.

Information You Provide Directly

• Account Information: Name, date of birth, email address, phone number, mailing address, and account credentials.

• Health Information: Medical history, current medications, allergies, symptoms, lab results, and other health-related information you share during intake or consultations.

• Payment Information: Credit or debit card details, billing address, and transaction history. Payment data is processed by our third-party payment processor and is not stored on our servers.

• Communications: Messages exchanged with our clinical team, customer support, and any feedback or reviews you submit.

• Government-Issued ID: In certain circumstances, we may collect a copy of your government-issued identification to verify your identity, as required by applicable law.

Information Collected Automatically

• Usage Data: Pages visited, features used, time spent, clicks, and navigation paths within our Services.

• Device Information: IP address, browser type, operating system, device identifiers, and referring URLs.

• Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies to personalize your experience, analyze usage, and support our advertising efforts. You may manage cookie preferences through your browser settings or our cookie consent tool.

Information from Third Parties

• Affiliated Healthcare Providers: Licensed physicians and clinicians who treat you through our platform may share clinical notes, prescriptions, and treatment records with us as part of care coordination.

• Compounding Pharmacies: Our pharmacy partners may share dispensing records, shipping status, and refill information.

• Analytics and Advertising Partners: We may receive aggregated or de-identified data from advertising platforms (such as Meta, Google, and TikTok) to measure the effectiveness of our campaigns.

2. How We Use Your Information

We use the information we collect to:

• Provide, operate, and improve our telehealth Services.

• Facilitate consultations between you and licensed healthcare providers.

• Process payments and manage subscriptions.

• Communicate with you about your care, account, and Services - including appointment reminders, prescription refills, and clinical follow-ups.

• Send marketing communications about Revela products and services, where you have provided consent or where permitted by applicable law. You may opt out at any time.

• Conduct research, analytics, and quality improvement activities (using de-identified data where possible).

• Comply with legal and regulatory obligations, including applicable state and federal healthcare laws.

• Detect, investigate, and prevent fraudulent transactions and other illegal activities.

3. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

• Healthcare Providers: We share relevant health information with the licensed clinicians who provide care through our platform. These providers are independent contractors operating under agreements with our affiliated management services organization.

• Compounding Pharmacies: To fulfill your prescription, we share necessary information (name, address, prescription details) with our partner compounding pharmacies.

• Service Providers and Technology Partners: We engage third-party vendors to assist with platform operations, payment processing, customer communications, analytics, and marketing. These vendors are contractually prohibited from using your information for any purpose other than providing services to us.

• Business Transfers: If Revela is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

• Legal Requirements: We may disclose your information to comply with applicable law, legal process, or governmental requests; to enforce our agreements; or to protect the rights, property, or safety of Revela, our users, or the public.

• With Your Consent: We may share your information for other purposes with your explicit consent.

4. Protected Health Information and HIPAA

To the extent that our Services involve the creation, use, or disclosure of Protected Health Information ("PHI") as defined under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), such PHI is governed by our HIPAA Notice of Privacy Practices, which is incorporated herein by reference and available on our website. In the event of any conflict between this Privacy Policy and our HIPAA Notice, the HIPAA Notice shall govern with respect to PHI.

5. Data Retention

We retain your personal and health information for as long as necessary to provide Services, comply with our legal obligations (including applicable medical record retention requirements), resolve disputes, and enforce our agreements. Medical records are retained in accordance with applicable state law, which typically requires retention for a minimum of seven (7) years from the date of service, or longer for minors.

6. Data Security

We implement administrative, technical, and physical safeguards designed to protect your information against unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption of data in transit and at rest, access controls, and regular security assessments. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Your Rights and Choices

Depending on your state of residence, you may have certain rights regarding your personal information, including:

• Access: The right to request a copy of the personal information we hold about you.

• Correction: The right to request correction of inaccurate or incomplete information.

• Deletion: The right to request deletion of your personal information, subject to certain exceptions (including our legal obligation to retain medical records).

• Opt-Out of Marketing: The right to opt out of receiving marketing communications at any time by clicking "Unsubscribe" in any email or contacting us directly.

• Data Portability: Where applicable, the right to receive your data in a portable, machine-readable format.

• Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

Residents of California, Virginia, Colorado, Connecticut, and other states with comprehensive privacy laws may have additional rights under applicable law. To exercise any of these rights, please contact us at [email protected].

8. Cookies and Advertising

We use cookies and similar tracking technologies for functional, analytical, and advertising purposes. Our website may use pixels and other tracking tools provided by advertising platforms (including Meta, Google, and TikTok) to measure ad performance and optimize our campaigns. You can manage your cookie preferences through our cookie consent banner or your browser settings. Opting out of advertising cookies will not affect your ability to use our Services, but may result in less relevant advertising.

9. Children's Privacy

Our Services are intended for adults aged 18 and older. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected information from a minor without parental consent, we will take steps to delete that information promptly.

10. Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties and encourage you to review their privacy policies before providing any information.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date above and, for material changes, notify you by email or by a prominent notice on our website. Your continued use of the Services after such changes constitutes your acceptance of the updated policy.

12. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

Email: [email protected]

Mailing Address: Revela Holdings, Inc., 1309 Coffeen Ave Ste 1200, Sheridan, WY, 82801

Phone: 808-749-1333