California Privacy Addendum (StartPrEP.com)
Effective Date: August 19, 2025
This California Privacy Addendum (“California Addendum”) supplements the StartPrEP.com Privacy Notice and applies only to California residents. It uses the CPRA’s definitions. It describes what we collect on StartPrEP.com (your marketing site) and the rights California residents have. It does not cover the healthvana.com platform, which has its own privacy notice.
1) Scope
This Addendum covers Personal Information collected on StartPrEP.com when you visit the Website or interact with us by email about the Website. It does not apply once you go to healthvana.com to continue registration.
2) Notice at Collection (what we collect, why, sharing, and retention)
Identifiers (email address) • Purposes: send sign-in link to continue registration at healthvana.com; follow-up if you don’t complete registration; respond to inquiries • Sharing: disclosed to service providers (e.g., email delivery); not “shared” for cross-context behavioral advertising • Retention: while subscribed; then suppression-list only and as needed for compliance/disputes/terms
Internet / network activity (device + browser info, IP address, page views, on-site interactions) • Purposes: improve the site; measure campaigns; serve relevant ads only when tracking is enabled • Sharing: when tracking is enabled, we may “share” device/usage data with Meta for cross-context behavioral advertising (no email) • Retention: only as needed for measurement/abuse prevention/campaigns; varies by provider configuration
Sensitive Personal Information (SPI) We do not collect or use SPI on StartPrEP.com.
3) Tracking, ads, and your choices
• GPC honored: If your browser sends Global Privacy Control, we treat it as a “do not sell/share” signal and do not load third-party trackers. • Manual opt-out: “Do Not Sell or Share My Personal Information” link is available site-wide. • When tracking is disabled: we do not load third-party trackers (Meta Pixel). First-party analytics (Matomo) may still run to operate/improve the Website.
• Meta Pixel configuration: loads only when tracking is enabled; Automatic Advanced Matching is disabled and we do not send emails to Meta.
4) Sale/Sharing disclosure
We do not sell Personal Information. When tracking is enabled, we may “share” device/usage data for cross-context behavioral advertising as defined by law; you can opt out anytime (including via GPC).
5) How we use your information (summary)
Operate the Website, send sign-in links and follow-ups, measure campaigns (when tracking is enabled), maintain security, comply with law, and similar purposes described in the main Privacy Notice.
6) Your California privacy rights
California residents have the right to know, access/portability, correct, delete, and opt-out of sale/sharing, and the right to non-discrimination for exercising these rights. (StartPrEP.com already lists these rights in your main policy.)
7) How to exercise your rights
Submit a request to privacy@healthvana.com or use https://StartPrEP.com/opt-out. We verify requests and accept submissions from authorized agents consistent with applicable law. Appeals are supported as described in the main policy.
Verification & authorized agents (summary): We’ll verify identity (or agent authority) with reasonable information before fulfilling a request. (Modeled on the workflow in the Healthvana California addendum.)
8) Non-discrimination
We will not discriminate against you for exercising CPRA rights. (Modeled on Healthvana’s addendum and consistent with the rights listed in StartPrEP.com’s main policy.)
9) Retention
We keep Personal Information only as long as needed for the purposes above (e.g., active emails while subscribed; suppression lists for opt-outs; analytics/ads data per provider settings), then delete or de-identify it, unless law permits/ requires longer retention. See Section 10 of the main policy for details.
10) Changes to this California Addendum
We may update this Addendum; the Effective Date will be revised when we do.
11) Contact
Healthvana, Inc. • P.O. Box 480131, Los Angeles, CA 90048 • privacy@healthvana.com • Opt-out/requests: https://StartPrEP.com/opt-out