Privacy Notice for StartPrEP.com

Last modified: August 19, 2025

1. Introduction.

Healthvana, Inc. ("Healthvana" or "we" or "us") respects your privacy and is committed to protecting your privacy through our compliance with this privacy notice (our "Privacy Notice"). Please read this Privacy Notice carefully to understand our policies and practices regarding your Personal Information (defined below).

If you do not agree with our Privacy Notice, your sole option is to not use our Website.

By accessing or using our Website, you are agreeing to this Privacy Notice. This Privacy Notice may change from time to time, as we update it to ensure it stays current. Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice each time you access our Website for updates.

This Privacy Notice describes the types of Personal Information we may collect, use, maintain, protect, disclose, or otherwise process about you when you visit our website located at https://StartPrEP.com (our "Website"), and the reasons why and how we collect, use, maintain, protect, disclose, or otherwise process that information.

Throughout this Privacy Notice, the term "Personal Information" means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Information does not include any deidentified or aggregated information.

Important Notice: StartPrEP.com is a marketing website that provides information about Healthvana's services. When you provide your email address on this Website, you will be directed to healthvana.com to complete registration. This Privacy Notice applies only to StartPrEP.com. Once you are redirected to healthvana.com, that platform's separate Privacy Notice and Terms of Use will apply. No data flows back to StartPrEP.com after you proceed to healthvana.com.

When Does Our Privacy Notice Apply?

This Privacy Notice applies to information we collect:

on our Website;
in email and other electronic messages between you and this Website.

When Does Our Privacy Notice Not Apply?

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by Healthvana or any third-party (including our affiliates and subsidiaries);
us or any of our affiliates or subsidiaries related to your or any other individual's employment or potential employment with us;
any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Website;
the healthvana.com platform after you are redirected there (which has its own Privacy Notice).

Our Privacy Notice and Terms of Use

This Privacy Notice is incorporated into our Terms of Use, which also apply when you use our Website.

Who May Use the Website

Access to and use of this Website is limited exclusively to users located in the United States. Accessing the Website from jurisdictions where content is illegal, or where we do not offer the Website, is prohibited.

2. Website Not Intended for Individuals Under the Age of 16.

Our Website is not intended for individuals under 16 years of age and we do not knowingly collect Personal Information from individuals under 16. If you are under 16, do not use or provide any information on our Website or through any of its respective features. This means that if you are under the age of 16, you must not provide any Personal Information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use.

If we learn we have collected or received Personal Information from an individual under 16 without verification of parental consent, we will delete that information. If you believe we might have any information directly from an individual under 16, please contact us at privacy@healthvana.com.

3. Information We Collect About You and How We Collect It.

We collect information directly from you and automatically when you interact with our Website. This Website isn’t intended to collect medical records or test results. Please don’t submit health information here. Care-related activities are provided on healthvana.com, which has its own privacy notice.

We do not collect or use Sensitive Personal Information (as defined by applicable state law) on this Website.

Notice at Collection

Identifiers: Email address
Purposes: Send sign-in link; send follow-up emails; respond to inquiries
Sharing: Disclosed to service providers (e.g., email delivery); not ‘shared’ for cross-context behavioral advertising.
Retention: While you remain subscribed; then only on a suppression list and as needed to comply with law, resolve disputes, and enforce our terms
Internet Activity: Device/browser info, IP address, page views, interactions
Purposes: Improve website; measure campaigns; serve relevant ads (when tracking is enabled)
Sharing: When tracking is enabled: ‘shared’ with Meta for cross-context behavioral advertising (device/usage data only; no email).
Retention: Only as long as needed to measure site performance, prevent abuse, and run or evaluate campaigns; retention varies by provider configuration

Information You Provide to Us

We collect the following types of Personal Information directly from you:

Email address when you submit our form to learn more about our services

Information We Collect Through Automatic Data Collection Technologies

We use automatic data collection technologies to collect certain Personal Information about your interaction with our Website, including:

Device and Network Information: IP address, city/state location (derived from IP), browser type, device type, operating system, referring website/UTM parameters
Analytics Data: Page views and on-site actions (first-party analytics)
Advertising Data: When tracking is enabled, interaction data through Meta Pixel for conversion measurement and ad optimization

We use the following technologies:

First-Party Analytics: We use internal analytics to understand how visitors interact with our Website
Meta Pixel: Only loads when tracking is enabled (see Section 6 for your choices). Automatic Advanced Matching is disabled; we do not send email addresses to Meta.
Cookies: Small data files placed on your device that allow us to collect certain information when you visit our Website

4. How We Use Your Personal Information.

We use information that we collect about you or that you provide to us, including any Personal Information:

to send you a secure sign-in link to continue registration on healthvana.com;
to send follow-up emails if you don't complete the registration process;
to measure campaign effectiveness when tracking is enabled;
to present our Website and its contents to you;
to provide you with information about our services that you request from us;
to notify you about changes to our Website or any services we offer;
to maintain the safety, security, and integrity of our Website;
for internal analytics and website improvement;
to comply with any court order, law, or legal process;
to enforce our Terms of Use and other agreements;
for any other purpose with your consent.

5. Disclosure of Your Personal Information.

We do not sell personal information. When tracking is enabled, we may "share" device and usage data for cross-context behavioral advertising as defined by applicable privacy laws; you may opt out at any time via "Do Not Sell or Share" and we honor GPC.

We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:

To service providers bound by contract to process data only for the purposes we specify (e.g., email service, hosting, first-party analytics);
To Meta (when tracking is enabled) - page/interaction data only for advertising purposes (we never send your email address to Meta, and Automatic Advanced Matching is disabled);
To our advertising agency - aggregated performance reports only through Meta; they have no access to your individual email or Personal Information and act as our service provider;
to comply with any court order, law, or legal process, including responding to any government or regulatory request;
to enforce or apply our Terms of Use;
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Healthvana, our customers, or others.

6. Choices About How We Use and Disclose Your Personal Information.

We strive to provide you with choices regarding the Personal Information you provide to us:

Tracking and Advertising

Global Privacy Control (GPC): If your browser sends GPC or another recognized universal opt-out signal, we automatically treat it as an opt-out of sale/sharing and do not load third-party trackers.
Location-Based Automatic Opt-Out: Tracking is automatically disabled for visitors from Washington and Nevada.
Manual Opt-Out: You can click "Do Not Sell or Share My Personal Information" available site-wide.
When Tracking is Disabled: We do not load third-party trackers (Meta Pixel). First-party analytics may still operate to run and improve the Website.

Email Communications

Unsubscribe: You can unsubscribe from marketing emails at any time using the link in every email.
Access/Delete: You can request access to or deletion of your email from our marketing systems by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.

7. Jurisdiction-Specific Privacy Rights.

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Information. You may submit requests through privacy@healthvana.com or our privacy request form at https://StartPrEP.com/opt-out; we will verify your request and accept submissions from authorized agents consistent with applicable law.

Appeals: If we decline to act on your request, you may appeal by emailing privacy@healthvana.com with "Privacy Appeal" in the subject line or by using our privacy request form. We'll respond in writing within the timeframes required by applicable law and, if we deny your appeal, we'll explain why and tell you how to contact your state Attorney General.

Your California Privacy Rights

California residents: You have the additional rights described in our California Privacy Addendum.

Colorado, Connecticut, and Other States

We honor universal opt-out mechanisms as they come into force in states with applicable privacy laws.

Washington & Nevada Consumer Health Data

Under Washington's My Health My Data Act and Nevada's consumer health data laws, your email address may constitute consumer health data if it indicates interest in sexual health services. For detailed information about how we handle consumer health data, including your rights and how to withdraw consent, please see Appendix A: Consumer Health Data Notice at the end of this Privacy Notice.

8. Do Not Track Signals and Global Privacy Control Signals.

We recognize and respond to Global Privacy Control (GPC) signals. When we detect GPC or similar recognized universal opt-out signals, we automatically disable third-party tracking and treat it as an opt-out of sale/sharing under applicable state laws.

We do not respond to Do Not Track (DNT) signals as there is no accepted standard for how to respond to such signals.

9. Data Security.

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include administrative, technical, and physical safeguards appropriate to the minimal data we collect on this marketing Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk.

10. Data Retention.

We retain Personal Information based on the following criteria:

Active email addresses: Retained while you remain subscribed to our communications
Inactive/incomplete signup emails: Retained only as long as necessary to follow up on incomplete registrations, then deleted unless required by law
Unsubscribed emails: Kept only on a suppression list to honor opt-out requests and comply with applicable law
Analytics data: Retained only as long as needed to understand website performance and improve our services; retention varies by provider configuration
Advertising event data: Retained only as long as needed to measure and optimize campaigns; retention varies by platform settings

We delete or anonymize Personal Information when it is no longer needed for the purposes outlined above, unless we are required to retain it longer by law or for legitimate business purposes.

11. Third-Party Sites.

Our Website may contain links to third-party websites or services that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or services. We encourage you to be aware when you leave our Website and to read the privacy statements of each website that collects Personal Information.

12. Changes to Our Privacy Notice.

We may change this Privacy Notice at any time. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Notice to check for any changes.

Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

13. Contact Information.

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice, have any requests related to your Personal Information pursuant to applicable laws, or otherwise need to contact us, you may contact us at:

Healthvana, Inc. P.O. Box 480131, Los Angeles, CA 90048 Email: privacy@healthvana.com

To submit a privacy request or opt-out of sale/sharing: https://StartPrEP.com/opt-out

Appendix A: Consumer Health Data Notice (Washington & Nevada)

This notice applies to residents of Washington and Nevada regarding consumer health data collected on StartPrEP.com.

Categories of Consumer Health Data Collected

Email address - which may indicate interest in sexual health services when submitted on a website offering PrEP information

Purposes for Collection

To send you a secure sign-in link to continue registration on healthvana.com
To send follow-up emails if you don't complete registration
To respond to your inquiries

No Third-Party Tracking in WA/NV

We automatically disable all third-party trackers (including Meta Pixel) for visitors from Washington and Nevada
Only first-party analytics operate for basic website functionality

No Sale or Sharing of Consumer Health Data

We do not sell consumer health data
We do not share consumer health data with third parties for advertising

Your Rights

You have the right to:

Access your consumer health data
Delete your consumer health data
Withdraw consent for processing at any time

How to Exercise Your Rights

To withdraw consent: Email privacy@healthvana.com with "Withdraw CHD Consent" in the subject line
To access or delete: Submit a request to privacy@healthvana.com or through our privacy request form
Response time: We will respond within the timeframes required by applicable law
Appeals: If we decline your request, you may appeal following the process in Section 7

Contact

For questions about consumer health data: privacy@healthvana.com