Zorva

Privacy Policy

Effective: 2026-06-21. v1 stub — replace with lawyer-reviewed copy before the first paying pilot signs.

1. What this product is

Zorva is an AI-powered billing-audit tool for medical practices. It reviews clinical documentation against billing-rule catalogs and surfaces errors, missing codes, and denial-risk signals before a claim is submitted.

2. What we collect

  • Clinical notes you upload or paste.
  • Claim metadata: CPT, ICD-10, SOMB, or other billing codes, encounter IDs, dates of service.
  • Reviewer actions: which findings were accepted, dismissed, appealed, and the reason code for each dismissal.
  • Tenant metadata: clinic name, billing authority, province or state.
  • Audit-trail events: every action on every encounter, signed with SHA-256.

3. What we do NOT collect

  • Patient names, addresses, phone numbers, email addresses, or other directly identifying information. Patient identifiers in your billing data are pseudonymized at the application boundary using SHA-256 with a tenant-scoped salt.
  • Payment data. We do not process payments; billing is handled by your existing payment processor.
  • Anything you do not specifically upload to Zorva.

4. How we store it

Data is stored in a Canadian data centre; the specific region is confirmed in the executed BAA (Canada (ca-central-1, AWS)). All records are tagged with a tenant ID at write time. The application enforces tenant scoping on every read — a clinic cannot read another clinic's audit trail, claim data, or appeal letters.

Audit-trail events are signed with a SHA-256 chain. The chain signature includes the previous row's signature, the action type, the user identifier, the encounter ID, and a SHA-256 hash of the encounter ID (PHIPA pseudonymization). A privacy officer can verify the chain has not been tampered with by walking the JSONL log and recomputing the signatures.

5. Retention

Audit-trail events and appeal-letter records are retained for the duration of the customer's subscription plus 7 years (the standard retention period for billing records under PIPEDA / HIPAA / PHIPA). Upload-job records are retained for 90 days for debugging, then aged out.

On subscription termination or written deletion request, all tenant data is purged within 30 days. The deletion event itself is recorded in the audit trail before the actual file purge runs.

6. Patient rights (PHIPA s.53 / PIPEDA)

Patients have the right to access their own PHI. To exercise this right, the clinic submits an export request to Zorva; Zorva returns the patient's claim data, audit-trail entries, and appeal-letter records as JSONL with a SHA-256 manifest. Endpoint: GET /api/tenants/{tenant_id}/export.jsonl.

Patients also have the right to deletion. The clinic submits a deletion request; Zorva records a deletion event in the audit trail and queues the file purge. Endpoint: DELETE /api/tenants/{tenant_id}?confirmation=delete-all-my-data.

7. Sub-processors

  • Cloud hosting provider: Canadian data centre operated by a third-party provider. The specific provider, region, and any third-party attestations currently held are written into the executed BAA.
  • Ollama Cloud: large-language-model inference. Patient-identifying fields are pseudonymized before transmission; only clinical notes and claim metadata reach Ollama.

We do not share tenant data with any other party. We do not train models on tenant data. We do not sell or rent tenant data.

8. Breach notification

On confirmed PHI breach, Zorva notifies affected tenants within 60 days, in writing (per HIPAA §164.410). Notification includes the date range, the categories of PHI involved, the number of individuals affected, and the steps taken to mitigate.

9. Security safeguards

  • TLS 1.3 for all transit.
  • AES-256 at rest (managed database encryption; cipher and key custody confirmed in the BAA).
  • Bearer-token authentication on every write endpoint.
  • Tenant-scoped reads on every JSONL log query.
  • SHA-256 audit-trail chain; tamper-evident by construction.
  • Annual third-party penetration test.

10. International transfers

Zorva stores data in Canada by default. For US-based tenants, Zorva stores data in a US-hosted, HIPAA-aligned region under a Business Associate Agreement. The specific region is confirmed in the executed BAA. We do not transfer data between regions.

11. Marketing communications

We do not send marketing email. We may send product-update email to active tenants; tenants can opt out by emailing privacy@ashbi.ca.

12. Children's privacy

Zorva is a billing-audit tool for medical practices. We do not knowingly collect information from children under 16. If a tenant uploads encounter data involving a minor, the data is processed under the same safeguards as adult data but the parent or guardian has the same PHIPA s.53 access rights.

13. Changes to this policy

We notify active tenants at least 30 days before material changes take effect. The current version is always at this URL.

14. Contact

Privacy questions: privacy@ashbi.ca. We respond within 5 business days.

15. Compliance framework

  • Canada: PIPEDA, PHIPA (Ontario), HIA (Alberta), PHIA (Manitoba), HPA (Saskatchewan), PIPEDA + Quebec Law 25.
  • United States: HIPAA, HITECH, 42 CFR Part 2 (substance-use-disorder treatment records).
  • Mexico: NOM-024, SAT CFDI 4.0 (electronic invoicing).
  • Colombia: Ley 1581 de 2012 (data protection), DIAN (electronic invoicing).

v1 stub copy — replace with lawyer-reviewed text before the first paying pilot signs. Last reviewed: 2026-06-21.