Privacy Policy

1. Who we are

Choice Arrangement Deck (“we,” “us”) provides a web-based tool that helps health insurance brokers and agencies (“Customers”) analyze CHOICE Arrangement (ICHRA) affordability and prepare proposals for employers. The service is operated by [LEGAL ENTITY NAME], [ADDRESS], Minnesota, USA.

2. Scope

This policy covers (a) visitors to choicearrangementdeck.com, (b) Customers and their users, and (c) information about employers and employees that Customers upload (“Census Data”). For Census Data, we act on behalf of, and under the instructions of, the Customer who uploads it.

3. Information we collect

• Contact information: name, work email, agency name, phone number, state, and messages you send us (for example, through the contact form).
• Broker account information: when you create an account, we store only your email address, display name, your agency (if you add one), your account role and status, and when your account was created and when you last signed in. Sign-up and sign-in are handled by Microsoft Entra External ID: your password is managed by Microsoft Entra, and we never see or store it.
• Census Data: employee-level information a Customer uploads for an employer client: the employer-assigned employee ID, first and last name, date of birth, mailing address, full-time or part-time status, and annual salary or hourly rate (see section 5). The service does not ask for Social Security numbers, and Customers should not upload them.
• Employer information: the employer's name and address and, for each plan year, the start date, number of employees, single-person monthly allowance, the location used for the benchmark plan, and the income safe harbor chosen.
• Usage and technical information: IP address, browser type, pages visited, and similar log data used to operate and secure the service.
• Payment information: handled by our payment processor, [PAYMENT PROCESSOR]; we do not store full card numbers.

4. How we use information

• To provide the service: running affordability analyses and generating proposals requested by Customers.
• To respond to inquiries, provide support, and manage accounts and billing.
• To secure the service, prevent abuse, and comply with legal obligations.
• To improve the service using aggregated or de-identified information that does not identify any employee, employer, or Customer.

We do not sell personal information or Census Data, and we do not use Census Data for advertising or marketing.

5. Employee census data

A Customer can upload a spreadsheet listing an employer client's employees (an employee “census”) for a specific plan year. This is how we handle it:

• What we store: for each employee, the employer-assigned employee ID, first and last name, date of birth, mailing address (street, optional apartment or suite, city, state, and ZIP code), whether the employee is full-time or part-time, and either an annual salary or an hourly rate. We also record which broker account saved the list and when.
• Why: to calculate CHOICE Arrangement (ICHRA) affordability and prepare proposals for that employer.
• Who provides it: the Customer (the broker), on the employer's behalf. Employees do not enter information into the service themselves.
• Uploaded files are not kept: the spreadsheet is read in memory so the Customer can review a preview. If the Customer approves it, only the resulting employee rows are saved; the file itself is never written to disk or to file storage. A preview that isn’t approved is discarded when the Customer discards it or uploads another file, or after 30 minutes.
• Remembered column choices: the service remembers column choices for each employer (which column position holds which kind of information, identified by a one-way fingerprint of the spreadsheet’s layout, with no spreadsheet contents or column names) so the next upload with the same layout doesn’t need them again; they are deleted with the employer, and the Customer can delete them at any time.
• Where it’s stored: in a Microsoft Azure SQL database in Azure’s Central US region (United States). The database is encrypted at rest with Azure’s transparent data encryption (using Azure-managed keys), and connections to the website and between the website and the database are encrypted with TLS (version 1.2 or later). Automatic database backups are kept in the same region.
• Who can see it: within the service, only the broker account that uploaded it. Our personnel with administrative access to the database may access it only when needed to operate, support, or secure the service. We do not sell Census Data or share it for marketing.
• How long we keep it: until the Customer deletes the employee list, the plan year, or the employer, or until the Customer’s account is deleted (contact us to delete your account). Any of these deletes the related employee records from the database immediately. Deleted records can remain in Azure’s automatic database backups for up to 7 days, after which those backups expire.
• Responsibility: Customers are responsible for having the right to share Census Data with us for this purpose. Customers should not upload Social Security numbers or use them as employee IDs.

6. Sharing

We share information only with service providers that help us run the service (for example, cloud hosting and application monitoring on Microsoft Azure, account sign-in through Microsoft Entra External ID, email delivery, and payment processing), under contracts that limit their use of it; when required by law; or in connection with a merger or acquisition, subject to this policy. A list of subprocessors is available on request.

7. Cookies

We use cookies that are necessary for the site to work, such as security (anti-forgery) cookies on forms and, if you sign in, a session cookie that keeps you signed in plus short-lived cookies used while Microsoft Entra signs you in. [Describe any analytics cookies, if added.]

8. Security

We use administrative, technical, and physical safeguards designed to protect information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your choices and rights

You may ask to access, correct, or delete your contact or account information. Employees whose information appears in Census Data should contact the broker or employer that provided it; we will assist our Customers in responding. Depending on where you live, you may have additional rights under state privacy laws.

10. Children

The service is intended for business use and is not directed to children. Census Data includes employees’ dates of birth (the service only accepts employees who are at least 14 at the start of the plan year) and does not include information about employees’ dependents.

11. Changes

We may update this policy. We will post the updated version here and change the “Last updated” date; material changes will be communicated to Customers.

12. Contact

Questions about this policy: use our contact form or write to [MAILING ADDRESS].