Privacy Policy

360 Harmony — Registered Dietitian Support

Revella Health Inc. | Effective Date: February 26, 2026

100 Queen Street West, Suite 100N, Brampton, ON L6X 1A4
privacy@revellahealth.ca | 1-844-394-4206

1. Introduction

Revella Health Inc. ("Revella Health," "we," "us," or "our") operates the 360 Harmony registered dietitian support service. This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information and personal health information when you use our services, visit our website at revellahealth.ca/harmony, or interact with us.

We are committed to protecting your privacy in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Ontario's Personal Health Information Protection Act, 2004 (PHIPA), as well as any other applicable provincial health privacy legislation.

By using 360 Harmony, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our services.

2. Definitions

"Personal Information" means information about an identifiable individual, as defined under PIPEDA. This includes your name, email address, phone number, and insurance details.

"Personal Health Information" (PHI) means identifying information about an individual in oral or recorded form that relates to the individual's physical or mental health, the provision of health care, or a plan of service, as defined under PHIPA.

"Services" means the 360 Harmony registered dietitian consultation services, including video consultations, personalized meal plans, and related nutritional guidance.

3. Information We Collect

3.1 Information You Provide Directly

• Full name, email address, and phone number
• Medavie Blue Cross member ID and policy number
• Primary nutrition concern and health goals
• Health history, dietary needs, food allergies, and medical conditions disclosed during consultations
• Personalized meal plans and session notes created by your dietitian

3.2 Information Collected Automatically

• Device type, browser type, operating system, and IP address
• Pages visited, time spent on pages, and referral sources
• Cookies and similar tracking technologies (see Section 9)

We use Google Analytics to collect website usage data. Google Analytics uses cookies to help us understand how visitors interact with our website. This information is aggregated and anonymized where possible.

3.3 Information from Third Parties

We may receive coverage verification and eligibility information from Medavie Blue Cross in connection with your insurance plan.

4. How We Use Your Information

We use your personal information and PHI for the following purposes:

• To verify your Medavie Blue Cross coverage and eligibility
• To match you with an appropriate registered dietitian
• To provide video consultations and deliver personalized nutrition plans
• To maintain clinical records within our electronic health record (EHR) system
• To process billing and submit claims to Medavie Blue Cross on your behalf
• To communicate with you about appointments, follow-ups, and service updates
• To improve our services, website functionality, and user experience
• To comply with legal and regulatory obligations

We will not use your personal information or PHI for marketing purposes without your express consent.

5. How We Share Your Information

We do not sell your personal information or PHI. We may share your information with the following parties, only as necessary:

5.1 Medavie Blue Cross

We share your member ID, policy number, and relevant session information with Medavie Blue Cross for coverage verification, claims processing, and direct billing.

5.2 Registered Dietitians

Your health information is shared with the registered dietitian you select so they can provide clinical services. Dietitians are bound by professional regulatory obligations and confidentiality requirements.

5.3 Service Providers

We may engage trusted third-party service providers who assist us in operating our platform, including hosting, analytics (Google Analytics), and video conferencing (Zoom, Google Meet). These providers are contractually obligated to protect your information and may only use it for the purposes we specify.

5.4 Legal Requirements

We may disclose your information where required by law, regulation, court order, or governmental authority, or where necessary to protect the rights, safety, or property of Revella Health, our users, or the public.

6. Consent

We obtain your consent before collecting, using, or disclosing your personal information and PHI, except where permitted or required by law. By submitting the 360 Harmony intake form and engaging in our services, you consent to the collection and use of your information as described in this Privacy Policy.

You may withdraw your consent at any time by contacting us at privacy@revellahealth.ca. Please note that withdrawing consent may affect our ability to provide you with certain services. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

7. Data Storage and Security

Your personal information and PHI are stored on secure servers operated by Revella Health. Our EHR system is custom-built and maintained by Revella Health with appropriate technical and organizational safeguards, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Role-based access controls limiting access to authorized personnel only
• Regular security assessments and vulnerability testing
• Secure authentication mechanisms

While we implement industry-standard security measures, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security but are committed to taking all reasonable steps to protect your information.

8. Data Retention

We retain your personal information and PHI for a period of seven (7) years following your last interaction with 360 Harmony services, in accordance with applicable regulatory and professional record-keeping requirements under Ontario law.

After the retention period expires, your information will be securely destroyed or de-identified in accordance with PIPEDA and PHIPA requirements.

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience and collect analytics data. The types of cookies we use include:

• Essential Cookies: Required for website functionality, such as session management and security.
• Analytics Cookies: Used by Google Analytics to collect aggregated data about website usage, including pages visited, session duration, and traffic sources.

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect website functionality. For more information on how Google Analytics processes data, please visit Google's privacy policy.

10. Your Rights

Under PIPEDA and PHIPA, you have the following rights regarding your personal information and PHI:

• Access: You may request access to the personal information and PHI we hold about you.
• Correction: You may request correction of any inaccurate or incomplete information.
• Withdrawal of Consent: You may withdraw your consent for the collection, use, or disclosure of your information, subject to legal or contractual obligations.
• Complaint: You may file a complaint with the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario if you believe your privacy rights have been violated.

To exercise any of these rights, please contact our Privacy Officer at privacy@revellahealth.ca or by mail at the address listed in Section 13.

11. Children and Minors

360 Harmony services are intended for individuals aged 18 years and older. We do not knowingly collect personal information from individuals under 18. If you believe a minor has provided us with personal information, please contact us immediately at privacy@revellahealth.ca and we will take steps to delete such information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Effective Date" at the top of this document and notify you by email or through a prominent notice on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Privacy Officer:

14. Regulatory Contacts

If you are not satisfied with our response to a privacy concern, you may contact: