ACA TRACK Privacy Policy

This Privacy Statement explains the manner in which Interactive Health Benefits, LLC d/b/a ACA TRACK, LLC may use and/or disclose Personal Information that we collect from those who engage with us in online business activities.

The Privacy Statement and policies set forth herein also describe the methods through which you can control your data. Additionally, we are committed to meeting the obligations of evolving and complex laws granting individuals more control.

Interactive Health Benefits, LLC d/b/a ACA TRACK, LLC (hereinafter referred to as “ACA TRACK,” “we,” “us” or “our”), are committed to protecting the privacy of those individuals who visit our websites (the “Websites”) and register to use our applications and services (“Services”). This policy describes our privacy practices and how we use and collect the personal information that you share with us when browsing our Website(s) and/or registering an account with us. ACA TRACK is headquartered in the United States of America. Therefore, personal information that we collect and maintain may be transferred to or controlled and processed in the United States of America and/or other countries around the world. By providing us with personal information and by using our Website(s) and Services, you consent to this transfer. We will protect the privacy and security of personal information we collect in accordance with this privacy policy, regardless of where it is processed or stored, however you explicitly acknowledge and consent to the fact that personal information stored or processed in the United States will be subject to the laws of the United States, including the ability of governments, courts, law enforcement and/or regulatory agencies of the United States who have valid jurisdiction over ACA TRACK to obtain disclosure of your personal information subject to a valid subpoena, court order or similar official request.

At this time ACA TRACK is not considered a processor under GDPR and is not subject to its policies.

ACA TRACK’s Privacy Policy applies to all individuals or customers with active or inactive accounts as well as any potential customers or other visitors to our site.

ACA TRACK is integrated with third party applications, including Freshdesk (our help system), the IRS AIR application, SendGrid (system for general email transmission and tracking), and ShareFile (secure file transmission platform). Various other third-party applications may be used in providing services including state reporting services. ACA TRACK’s Privacy Policy does not reflect the privacy practices or policies of those other sites. As we continue to develop our website and take advantage of technologies to improve the services we offer, this policy likely will change. When we change it, we will post the change(s) on our website. You can determine when this version of the privacy notice was adopted by referring to the Effective Date at the end of this document. If you have additional questions about privacy or information security, please contact us at legal@acatrack.net.

Confidentiality, Integrity and Availability / Security

ACA TRACK handles and/or manages information assets which can take various forms, including, but not limited to data printed, stored electronically, transmitted by electronic means, stored on electronic media, and/or spoken in conversation. All information including personal and PHI information will be protected from loss of confidentiality, integrity, and availability relating to internal stakeholders, business partners, clients, and client assets by continually implementing adequate safeguards in place to protect it based on risk assessment and to ensure compliance with all applicable regulations.

Data Privacy

ACA TRACK is committed to ensuring compliance with all applicable data privacy laws and regulations, continually implementing and enhancing the controls based on privacy risk assessments as they pertain to the data that clients give us about themselves and their employees, and which we in turn use to provide our ACA and state reporting services.

HIPAA

It is ACA TRACK’s policy to comply fully with HIPAA’s requirements, as applicable. To that end, all staff members who have access to PHI must comply with the HIPAA Privacy and Security Plan. ACA TRACK will work with your Human Resources and Legal Departments to train our teams on your specific HIPAA governance and to ensure that the requisite documentation and controls are in place through PHI based risk assessment.

Information We Collect

Generally, you can browse through our Website(s) without providing us with any personally identifiable information about yourself. However, as you navigate through our Website(s) and/or use our Services, certain anonymous information may be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, unique IDs, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). Your internet browser automatically transmits some of this anonymous information, such as the URL of the website you just came from and the Internet Protocol (IP) address and the browser version your computer or mobile device is currently using; the date and time you access the Website and the pages that you access while at the Website. This information is used by us for internal business purposes, to analyze trends and to improve upon our Website, products and Services. Other anonymous information may be collected from your computer or mobile device through tracking technologies that we employ on our Websites such as cookies, unique IDs and internet tags or web beacons. You may set your browser to notify you when a tracking cookie is sent or to refuse cookies altogether, but please be aware that certain features of our Website(s) may not work without cookies enabled.

ACA TRACK also collects and uses the personal information that you proactively provide to us when you:

• Register an account with us to use any of our Services;
• Enter any employment and/or coverage data on our website(s);
• Respond to any ACA TRACK templates, emails, questionnaires or similar online forms; or
• Contact us to request information or otherwise correspond with us.

We may also receive personal information from our business partners and vendors and, so long as it has been collected in accordance with applicable laws and acceptable privacy practices consistent with this Policy, we may aggregate such information with the information we collect from you ourselves to help us form a more complete user profile for you. We may record the IP address of users accessing the system for the enhancement of performance and security.

How We Use It

ACA TRACK uses the information we collect for our own general business purposes, which may include:

• to share employment and coverage data with the IRS as authorized under applicable laws;
• in response to an IRS audit, we may be required by law to share actual user login and usage activity;
• to fulfill or meet the reason for which the information is provided;
• to provide you with information, products or services that you request from us;
• to provide you with email alerts and notices about our products or services;
• to facilitate security measures;
• to carry out our obligations and rights arising from any contracts entered into between you and us, including for billing and collections;
• to improve our website;
• for testing, research, analysis and product development;
• as necessary or appropriate to protect the rights, property or safety of us, our customers or others;
• to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

Information Disclosure

ACA TRACK may transfer your personal information or otherwise disclose information collected from and about you for the following purposes:

• conform to the edicts of law or comply with legal process served on ACA TRACK or the site;
• protect or defend the rights or property of ACA TRACK;
• act in urgent circumstances to protect the personal safety, property, or privacy of ACA TRACK’s employees, users of ACA TRACK’s products or service, or members of the public;
• effect a transaction, restructuring or proceeding that transfers to a third party the assets or line of business to which the information pertains;
• to our service providers, suppliers and business associates, if the disclosure will enable them to fulfill or perform your request for products or services on our site;
• to other companies, credit bureaus or government agencies in connection with issues related to fraud, credit or debt collection;
• as necessary if we believe that there has been a violation of our site Terms and Conditions, of the law or of our rights or the rights of any third party.

In addition, we may share non-identifiable aggregate information about our users (for example, the proportion of male and female users) with advertisers, business partners, and other third parties in an effort to customize or enhance the content and advertising on our Website for our users. We may engage third party consultants to review and analyze system information, including user and client data solely for the purpose of security and performance enhancements. We may export user information to other ACA TRACK platforms for purposes of communicating training or services, but in no event shall it include the unlawful transfer of Confidential Information. Our system may, from time to time, interact with ShareFile as part of the exchange of data and user information between the client and ACA TRACK.

Any personal information or content that you voluntarily upload or submit for public posting to the site (for example, comments) becomes publicly available and can be collected and used by others. You may not post any content that requests personally identifiable information.

When you are on our website and are asked for personal information, you are sharing that information with ACA TRACK, our subsidiaries and related companies, and our service providers. We share your information as described in “Information Disclosure” above.

Data Storage

We will retain your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will also keep your personal data for as long as your account is active or as needed to provide you services and to maintain a record of your transactions, unless otherwise specified by applicable data retention laws. We retain archived copies of your information as required by law or for legitimate business purposes. ACA TRACK has a Data Retention policy that enumerates the time and process for retention, archival and destruction of data.

Third-Party Sites

Our Websites may contain links to websites operated by third parties. Some of these third-party sites may be co-branded with an ACA TRACK logo even though they are not operated or maintained by ACA TRACK. Although we choose our business partners carefully, ACA TRACK is not responsible for the privacy practices of websites operated by third parties that are linked to our Websites. Once you have left our Websites, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

Tracking & Cookies

Please see our Cookie Policy.

Modifying or Deleting Your Personal Information

You can request to access, update, correct, and delete the information you provided to us by sending us an email at legal@acatrack.net. Keeping your personal data current helps ensure that we can respect your preferences. When you make a request, we may require certain documentation in order to be able to verify your identity before we are able to process your request. Your cooperation is necessary to exercise your rights under this Privacy Notice.

Data Security

Your personal information is protected for your privacy and security. ACA TRACK safeguards the security and confidentiality of the data you send us with physical, technical, and managerial procedures. Please be aware that, despite our best efforts, we cannot guarantee the absolute security of your data submitted through websites or similar communications.

ACA TRACK encourages individuals to take every precaution to protect personal data. Individuals should utilize current best practices: change passwords, implement complex passwords, multifactor authentication features, software updates, anti-virus, using a secure browser and similar efforts.

Changes to this Policy

ACA TRACK may amend this policy from time to time. If we make any substantial changes in the way we use your personal information, we will make that information available by posting a notice on this site.

Children’s Policy

Our website is a general audience site that does not target and is not intended for children under the age of 13. ACA TRACK does not knowingly solicit children under the age of 13. ACA TRACK services require the collection and processing of data which may, at times, include dependent information which may pertain to individuals under the age of 13.

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org. We have disclosed our collection practices herein, but at this time, we do not honor do-not-track signals. Some of the third parties that we work with may honor such requests.

Contact Information

ACA TRACK welcomes your comments regarding this privacy statement and our privacy practices. If you have reason to believe that ACA TRACK has not adhered to this privacy statement, please contact us electronically at support@acatrack.net or at the address provided below:

ACA TRACK, LLC
Attention: General Counsel
995 North Pontiac Trail
P.O. Box 1285
Walled Lake, Michigan 48390

Effective Date: August 6, 2026