This Privacy Policy describes how Creditable, LLC ("Creditable," "we," "our," or "us") collects, uses, discloses, and protects information when you visit our website at joincreditable.com, use our platform for plan level creditable coverage testing, or otherwise interact with our Services.
1. Scope
This Privacy Policy applies to visitors to our website, prospective customers, current customers, and authorized users of our platform. By using the Services, you agree to the practices described here.
Your use of the Services is also governed by our Terms of Service.
This Policy does not apply to the practices of our customers. If your employer, broker, third party administrator, or another organization uses Creditable and has submitted information about you, that organization's own privacy policy governs how it handles your information. See Section 3.
2. Definitions
Personal Information. Information that identifies or can reasonably be linked to a particular individual, such as name, email address, employer, or account credentials.
Usage Data. Technical information collected automatically through your interaction with the Services, such as IP address, device type, browser type, and pages visited.
Customer Content. Plan documents, plan design inputs, testing parameters, determinations, records, and generated notices submitted to or produced by the platform.
Service Provider. A third party that processes information on our behalf to support the Services.
Customer. An organization that has entered into an agreement with Creditable to use the platform.
3. Our Role: Controller and Service Provider
Our obligations depend on which information is involved.
Where we act for ourselves. For information about our website visitors, prospects, customer account contacts, and support communications, we determine how and why the information is used. We are the controller of that information, and this Policy governs it.
Where we act for our Customers. Customer Content is submitted by a Customer for the Customer's own purposes. We process it on that Customer's documented instructions in order to provide the Services. The Customer determines what is submitted and why. For that information we act as a processor and, under U.S. state privacy laws, as a service provider.
If you believe a Customer has submitted information about you and you want to access, correct, or delete it, contact that organization directly. If you contact us instead, we will refer you to the relevant Customer and assist them in responding.
4. Legal Basis for Processing
Where a legal basis is required by applicable law, we rely on one or more of the following: performance of a contract, our legitimate business interests in operating and improving the Services, your consent where we have asked for it, and compliance with legal obligations.
5. Information We Collect
Information you provide directly
- Account information, including name, email address, company name, and credentials
- Plan documents and plan design inputs submitted for testing
- Billing contact details. We issue invoices and process payments through Mercury. We do not store full payment card or bank account numbers.
- Communications with our sales and support teams
Information collected automatically
- IP address, browser type, device identifiers
- Usage and application logs
- Cookies and aggregate usage and performance measurements, as described in Section 9
Information from other sources
We obtain business contact information about individuals at organizations that may have a professional need for our Services. This comes from business data providers, publicly available professional sources, and referrals. It typically includes name, job title, employer, business email address, and business phone number.
We use this information only to contact people in a professional capacity about our Services. If you would prefer not to be contacted, email info@joincreditable.com and we will remove you.
Information we do not collect
We do not seek, and the platform is not designed to receive, Protected Health Information as defined under HIPAA. Creditable coverage testing operates on plan design information rather than information about identified individuals. Customers should not submit individually identifiable health information to the platform.
6. How We Use Information
We use information to operate and secure the platform, authenticate users, produce determinations and generate the records and notices that follow from them, respond to support requests, bill for the Services, communicate about the Services, improve platform performance and reliability, and comply with legal obligations.
We use aggregated and de-identified information, which cannot reasonably be used to identify any individual or Customer, to understand usage patterns and improve the Services.
7. Customer Content and Ownership
Your ownership. Customers retain all right, title, and interest in Customer Content. Creditable claims no ownership of it.
License you grant us. You grant Creditable a limited, non-exclusive license to access, store, process, and transmit Customer Content solely to provide the Services, produce determinations and related records and notices, maintain backups, and, in aggregated and de-identified form, improve the Services.
Confidentiality. We treat Customer Content as confidential business information. We access it only as needed to operate the Services, to provide support at your request, or where required by law.
Your responsibilities. You represent that you have the rights and any consents needed to submit Customer Content, that the information you submit is accurate and complete, and that your submission does not violate any law or third party right.
8. Disclosure of Information
We may disclose information to Service Providers who support the Services, including cloud hosting, application infrastructure, analytics and performance monitoring, email delivery, payment processing, and customer support. We may disclose information to our professional advisors, including attorneys and accountants. We may disclose information where required by law, subpoena, or other legal process, or where we believe disclosure is necessary to protect rights, safety, or property. We may disclose information in connection with a merger, acquisition, financing, or sale of assets, and we will give notice if this Policy would materially change as a result. We may disclose information with your consent.
We do not sell Personal Information, and we do not share Personal Information for cross context behavioral advertising, as those terms are defined under California law.
9. Cookies and Tracking
Cookies are small text files placed on your device that help us operate and improve the Services.
Essential cookies are required for login, session management, and security. Disabling them will prevent the platform from working.
Analytics and performance. We use Vercel Web Analytics and Vercel Speed Insights to understand how the website is used and to monitor performance. These tools do not set cookies, do not track you across other websites, and do not build an advertising profile. They collect limited technical information, such as the page visited, the referring page, device type, and an approximate location derived from your IP address, which Vercel processes in aggregate on our behalf.
We do not use advertising cookies or third party trackers that follow visitors across other sites.
You can disable cookies through your browser settings. General information about cookies is available at https://www.allaboutcookies.org.
Do Not Track. Some browsers send a Do Not Track signal. There is no common industry standard for how to respond to these signals, and we do not currently respond to them.
10. Data Storage and International Transfers
Information is stored primarily on cloud servers located in the United States. Some Service Providers may process limited information outside the United States to support hosting, analytics, customer support, or payment processing. Where information is transferred internationally, we require our Service Providers to maintain appropriate contractual and security protections.
11. Retention
- Account information: for the life of the account, and for up to seven years afterward, to meet tax, accounting, and legal requirements
- Customer Content: for the life of the account. On account closure we retain it for 60 days so you can export your records, then delete it. You may request earlier deletion, and you may request an export at any time during the account term.
- Usage and application logs: up to 24 months
- Prospect and marketing information: until you opt out, or after three years of no engagement
- Support communications: three years
Because a determination may need to be produced years after a plan year closes, we recommend exporting your records before closing an account. We may retain information longer where required for legal compliance, dispute resolution, or protection of our rights.
12. Security
We maintain administrative, technical, and physical safeguards intended to protect information against unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit using TLS 1.2 or higher, encryption at rest, access controls that limit administrative functions to an approved list of accounts, and logging of platform activity.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
You are responsible for using a strong, unique password, keeping credentials confidential, and notifying us promptly at info@joincreditable.com if you suspect unauthorized access to your account.
If a security incident affects your Personal Information, we will notify you and any applicable regulator without undue delay, as required by applicable law.
13. Your Rights and Choices
Depending on where you live, you may have the right to confirm whether we process Personal Information about you, to access it, to correct inaccuracies, to request deletion, to obtain a portable copy, to opt out of targeted advertising, and not to be discriminated against for exercising these rights. These rights are available to residents of states with comprehensive consumer privacy laws, including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others as those laws take effect.
We do not sell Personal Information, we do not share it for cross context behavioral advertising, we do not engage in targeted advertising, and we do not use Personal Information for automated decision making that produces legal or similarly significant effects about an individual.
You may opt out of marketing email at any time using the unsubscribe link in any message, or by emailing us.
How to submit a request. Email info@joincreditable.com with the subject line "Privacy Rights Request."
Verification. We may ask for information to verify your identity before acting on a request, and we will not use that information for any other purpose.
Timing. We respond within 45 days. Where a request is complex we may extend by a further 45 days and will tell you if we do. If we decline a request you may appeal by replying to our response, and we will respond to an appeal within 60 days.
Authorized agents. An authorized agent may submit a request on your behalf with written authorization, and we may contact you to confirm it.
Customer Content. If your request concerns information a Customer submitted about you, see Section 3.
14. Children's Privacy
The Services are intended for business use and are not directed to individuals under 18. We do not knowingly collect Personal Information from anyone under 18. If we learn that we have, we will delete it.
15. Third Party Links
Our website and platform may link to third party websites. We are not responsible for their content or privacy practices, and this Policy does not apply to them.
16. Changes to This Policy
We may update this Policy from time to time. We will post the revised version with a new "Last updated" date. If we make a material change, we will give additional notice, such as an email to account contacts or a notice inside the platform, before the change takes effect.
17. Contact Us
Creditable, LLC
122 W 68th Street
Kansas City, MO 64113
Email: info@joincreditable.com
We aim to respond to inquiries within 10 business days.
Creditable, LLC, 122 W 68th Street, Kansas City, MO 64113. Questions about this document go to info@joincreditable.com.