California Residents (CCPA / CPRA)

MEDRe LLC

MEDRe LLC California Residents Section (CCPA / CPRA)

Last Updated: June 17, 2026

This PRIVACY NOTICE IS APPLICABLE TO CALIFORNIA RESIDENTS (“consumers” or “you”) ONLY and supplements the information in MEDRe’s general Privacy Policy. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act (“CPRA”), and other California privacy laws. Any terms defined in the CCPA or CPRA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”).

We have collected the following categories of Personal Information from California consumers on MEDRe’s Platform:

Category A. Identifiers.

Examples: Name, mailing address, email address, phone number, account name, IP address, unique device identifiers.

Collected: Yes

Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: Name, address, telephone number, credit card or debit card number (processed by Shopify Payments).

Collected: Yes

Category C. Characteristics of protected classifications under California or federal law.

Examples: Age, gender (if voluntarily provided).

Collected: Yes (limited)

Category D. Commercial information.

Examples: Records of products or services purchased or considered (subscription orders for wellness peptides), purchase history, payment details.

Collected: Yes

Category E. Biometric information.

Collected: No

Category F. Internet or other similar network activity.

Examples: Interaction with our website, browsing history, search history, information regarding a consumer’s interaction with an internet website, application, or advertisement (including data from Meta Pixel, Google Analytics 4, TikTok Pixel, Attribuly Pro, Klaviyo, and Metricool).

Collected: Yes

Category G. Geolocation data.

Examples: Approximate location data derived from IP address (used for Austin-first launch targeting).

Collected: Yes (limited)

Category H. Sensory data.

Collected: No

Category I. Professional or employment-related information.

Collected: No

Category J. Non-public education information (per the Family Educational Rights and Privacy Act).

Collected: No

Category K. Inferences drawn from other personal information.

Examples: Inferences drawn from purchase history and website activity to improve LTV/refill predictions and marketing performance (used internally in our Supabase Marketing Analyst Dashboard).

Collected: Yes

Sensitive personal information

We do not collect or process sensitive personal information as defined under the CPRA except to the extent necessary to provide the services (e.g., limited health-related data routed exclusively to Ola Digital Health under our Business Associate Agreement).

Important Note on Protected Health Information (PHI): MEDRe does not receive, access, or store Protected Health Information (PHI) on its own systems or servers. All PHI from the intake form and async physician review is processed and retained exclusively by Ola Digital Health under our Business Associate Agreement. Only non-PHI operational and marketing data flows into our n8n/Supabase workflows and Marketing Analyst Dashboard. Please see our separate Notice of Privacy Practices (HIPAA) for details on PHI handling.

Sources of Personal Information

We obtain the categories of Personal Information listed above from the following categories of sources:

  • Directly from you (e.g., information you provide when you create an account, complete the intake form, place an order, or interact with our website).
  • Indirectly from you (e.g., through your activity on our website or from data collected via pixels and analytics tools).
  • From third parties that interact with us in connection with the services we perform (e.g., Shopify Payments, advertising platforms, attribution tools, and Ola Digital Health for order routing).

Personal Information does NOT include:

  • Publicly available information from government records.
  • De-identified or aggregate consumer information.
  • Information excluded from the CCPA/CPRA scope, such as health or medical information covered by HIPAA (which is handled exclusively by Ola Digital Health under our Business Associate Agreement).

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business or commercial purposes:

  • To fulfill or meet the reason for which the information is provided (e.g., processing your subscription order for wellness peptides).
  • To provide you with information, products, or services, including subscription management and customer support.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, payments, and refunds.
  • To improve our website, marketing, and services (including internal analytics and LTV/refill optimization via our Supabase dashboard).
  • For testing, research, analysis, and product development (internal use only).
  • As reasonably necessary and proportionate to protect the rights, property, or safety of us, our customers, or others.
  • To respond to regulatory and/or law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA/CPRA.
  • To third-party service providers who perform services on our behalf (e.g., analytics, advertising, attribution, email marketing, and affiliate program management).

We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose. In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, Personal Information (Cal. Civ. Code § 1798.80(e)), Commercial Information, Internet or other similar network activity, Geolocation data (limited), and Inferences.

We disclose your Personal Information for a business purpose to the following categories of third parties:

  • Our service providers and vendors (e.g., Shopify Payments, Ola Digital Health, n8n/Supabase, analytics and advertising platforms).
  • Third parties to whom you authorize us to disclose your personal information in connection with products or services we provide to you.
  • Advertising and marketing partners (Meta, Google, TikTok, Klaviyo, Attribuly Pro, Metricool).
  • Our affiliate program platform (Rewardful).
  • To other third parties as required or permitted by law.

Selling or Sharing Personal Information

We do not sell your personal information. We do share certain personal information for targeted advertising purposes (as defined under the CPRA). You have the right to opt out of this sharing at any time (see “Your Rights and Choices” below).

Your Rights and Choices

The CCPA/CPRA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. Once we receive and verify your request, we will disclose to you any of the following in accordance with your request: the categories of Personal Information we collected about you; the categories of sources for the Personal Information we collected about you; our business or commercial purpose for collecting that Personal Information; the categories of third parties with whom we share that Personal Information; and the specific pieces of Personal Information we have collected about you (data portability request).

Correction Requests

You have the right to request that we correct inaccurate Personal Information about you.

Deletion Request Rights

You have the right to request that we delete (and direct our service providers to delete) your Personal Information from our records, subject to certain exceptions.

Opt-Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your Personal Information for targeted advertising. We honor Global Privacy Control (GPC) signals and browser-based opt-out preferences.

Opt-Out of Use and Disclosure of Sensitive Personal Information

You have the right to request that we limit the use and disclosure of your Sensitive Personal Information, subject to certain exceptions. We use Sensitive Personal Information only to the extent reasonably necessary to provide the services.

Exercising Access, Data Portability, Correction, Deletion, and Opt-Out Rights

To exercise any of the rights described above, please submit a verifiable consumer request to us by either:

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: provide sufficient information that allows us to reasonably verify your identity or your authority to make a request on behalf of a California resident; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. Personal Information provided will only be used by us to verify the requestor’s identity and/or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will provide you with a cost estimate and rationale before completing your request. We also reserve the right to deny excessive, repetitive, or manifestly unfounded requests.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our website.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your options and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

MEDRe LLC

8 The Green, Suite B

Dover, DE 19901

support@medre.org

(302) 207-0669