Predictable Benefits Inc. – Privacy Policy

1. Introduction

Predictable Benefits Inc. (“Predictable Benefits,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and protect information obtained through our website, platform, and related services (collectively, the “Site” or “Services”). By accessing or using the Site, including during any free trial, you agree to the terms of this Privacy Policy and the Predictable Benefits Terms of Use.

2. Information We Collect

We collect the following categories of information:

• Account Information – Name, company name, email address, phone number, and user role (Administrator, Agency, Broker, Employer, or Employee).
• Employer and Employee Data – Benefits enrollment information, plan details, and other HR-related data entered by Administrators, Employers, or Brokers.
• Usage Data – Information about how you access and use the Site, including IP address, browser type, device identifiers, pages visited, and timestamps.
• Payment Information – Billing contact details and transaction information processed through secure third-party payment processors.
• Support Data – Information provided when you contact us for customer service, feedback, or technical assistance.

f. Sensitive Data. Certain personal data is classified as "sensitive" under state privacy laws, including:

• Data revealing racial or ethnic origin, religious beliefs, or citizenship/immigration status
• Genetic or biometric data used to identify an individual
• Health data, including mental or physical health conditions
• Data concerning sexual orientation or sex life
• Precise geolocation data (within 1,750 feet)
• Personal data of a known child under thirteen (13)

Consent Requirements: Where required by applicable state law, we obtain opt-in consent before collecting or processing sensitive personal data. For states that permit an opt-out approach (California, Iowa, Utah), you may limit our use of sensitive personal data by contacting privacy@predictablebenefits.com. We do not sell sensitive personal data.

If you access the Site on behalf of a company, that company may provide employee or plan participant data to us. In such cases, Predictable Benefits processes that data as a data processor or business associate, depending on the applicable privacy law.

3. How We Use Your Information

We use collected information to:

• Provide, operate, and maintain the Site and Services.
• Create and manage user accounts and authorizations.
• Process transactions, billing, and renewals.
• Respond to inquiries, provide support, and improve the user experience.
• Send service-related communications, product updates, and security alerts.
• Conduct analytics to improve system performance and develop new features.
• Comply with legal obligations and enforce our agreements.

We do not sell personal information to third parties. We do not sell personal data for monetary consideration. Certain state laws define "sale" to include exchanges of personal data for other valuable consideration. To the extent any data sharing described in this Policy constitutes a "sale" under applicable state law, you may opt out as described in Section 10.

4. Free Trials and Demonstrations

If you register for a free trial or demo, we may collect additional information to verify your identity and eligibility. By participating, you agree that Predictable Benefits may use your data to evaluate product performance and prevent competitive misuse. Competitors and their representatives are strictly prohibited from registering for or accessing a free trial.

5. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

• Maintain session authentication and account security.
• Analyze traffic patterns and usage trends.
• Improve Site functionality and personalize content.

You can control cookies through your browser settings; however, disabling cookies may limit certain features of the Site.

We honor browser-based opt-out preference signals, such as the Global Privacy Control (GPC), as valid requests to opt out of the sale of personal data and targeted advertising where required by applicable state law. When we detect a valid opt-out signal from your browser or device, we will process it as a request to opt out of the sale of personal data and processing for targeted advertising purposes. The opt-out applies to the browser or device sending the signal. If you use multiple browsers or devices, enable the signal on each. No additional action is required.

6. Data Sharing and Disclosure

We may share your information in the following limited circumstances:

• Service Providers – With trusted vendors that perform services on our behalf (e.g., hosting, analytics, payment processing).
• Authorized Users – With Brokers, Agencies, or Employers who administer your benefits within the platform.
• Legal Requirements – When required by law, regulation, subpoena, or court order.
• Business Transfers – In connection with a merger, acquisition, or sale of assets, subject to confidentiality protections.

All vendors and subcontractors are bound by confidentiality and data protection obligations consistent with this Policy.

7. Data Protection and Security

Predictable Benefits maintains administrative, technical, and physical safeguards designed to protect your information against loss, misuse, unauthorized access, disclosure, alteration, and destruction. Our platform employs encryption in transit and at rest, access controls, secure data centers, and regular security audits. If you suspect unauthorized access to your account, please notify us immediately at security@predictablebenefits.com.

We conduct and document Data Protection Assessments for processing activities that present a heightened risk of harm to consumers, including processing for targeted advertising, sale of personal data, sensitive personal data, and profiling. These assessments weigh the benefits of processing against potential risks to consumers and document the safeguards we employ.

Predictable Benefits maintains a written privacy program with documented policies and procedures designed to conform to the National Institute of Standards and Technology (NIST) Privacy Framework. Our program addresses privacy risk identification, safeguards implementation, governance, incident response, and continuous improvement.

8. International Data Transfers

If you access the Site from outside the United States, your information may be transferred to and processed in the U.S. or other jurisdictions with different data protection laws. Predictable Benefits ensures appropriate safeguards, including Standard Contractual Clauses where required under GDPR.

9. GDPR Compliance (EU and UK Users)

For users located in the European Union or United Kingdom:

a. Predictable Benefits acts as a Data Controller for account and marketing information, and as a Data Processor for employer-provided employee data.

b. You have the following rights:

• Access to your data.
• Correction of inaccurate data.
• Deletion (“Right to be Forgotten”).
• Restriction or objection to processing.
• Data portability.

Requests can be submitted to privacy@predictablebenefits.com. We will respond within 30 days. Our lawful bases for processing include contract performance, legitimate interests, consent, and legal compliance.

10. US State Privacy Rights

Residents of certain U.S. states have specific privacy rights under applicable state consumer privacy laws. This section applies to residents of California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, and any other state that enacts comprehensive consumer privacy legislation.

a. Consumer Rights. Depending on your state of residence, you may have the right to:

• Access – Confirm whether we are processing your personal data and obtain a copy of that data.
• Correction – Request correction of inaccuracies in your personal data.
• Deletion – Request deletion of personal data we have collected from or about you.
• Data Portability – Obtain a copy of your personal data in a portable, readily usable format.
• Opt-Out of Sale – Opt out of the "sale" of your personal data. (We do not sell personal data for monetary consideration; however, certain data sharing activities may constitute a "sale" under state laws that define the term to include exchanges for other valuable consideration).
• Opt-Out of Targeted Advertising – Opt out of the processing of your personal data for targeted advertising purposes.
• Opt-Out of Profiling – Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Third-Party Disclosure Information – For residents of Oregon, Minnesota, Delaware, and Maryland, request a list of specific third parties or categories of third parties to whom we have disclosed your personal data.

Not all rights are available in all states. We will apply the rights available under your state's law.

b. How to Exercise Your Rights. To submit a request, contact us at privacy@predictablebenefits.com or via mail to: Predictable Benefits Inc., Attn: Privacy Officer, 1340 Sumner Ave., Cleveland, OH 44115.

c. Response Timeframe. We will respond to verified requests within forty-five (45) days of receipt. If we require additional time (up to an additional forty-five days), we will notify you of the extension and the reason within the initial period.

d. Verification. We may need to verify your identity before processing your request. We will match information you provide against information we have on file. If we cannot verify your identity, we may request additional information or deny the request.

e. Appeal Process. If we decline your request, you may appeal by emailing privacy@predictablebenefits.com with the subject line "Privacy Rights Appeal" within sixty (60) days of our response. We will respond to appeals within sixty (60) days.

f. Non-Discrimination. We will not deny you services, charge different prices, or provide a different service level because you exercised your privacy rights.

11. HIPAA Compliance

When acting as a business associate under the Health Insurance Portability and Accountability Act (HIPAA), Predictable Benefits maintains required safeguards to protect Protected Health Information (PHI) and enters into Business Associate Agreements (BAAs) with covered entities and business partners as applicable.

12. Data Retention

Predictable Benefits retains data only as long as necessary to provide the Services, comply with legal obligations, resolve disputes, or enforce agreements. Upon account termination, personal data may be deleted or anonymized after one hundred eighty (180) days, unless retention is required by law.

13. Children’s Privacy

Our Site is not directed to children under thirteen (13), and we do not knowingly collect personal data from children under thirteen without verifiable parental consent as required by the Children's Online Privacy Protection Act (COPPA).

Minors Aged 13–17. We do not knowingly process personal data of consumers between thirteen (13) and seventeen (17) years of age for targeted advertising, sale, or profiling without affirmative consent where required by applicable state law. If you believe a minor has provided personal data to us without appropriate consent, contact privacy@predictablebenefits.com and we will delete it promptly.

14. Your Rights and Choices

You may:

• Access and update your account information directly through the platform.
• Request correction or deletion of your data.
• Withdraw consent to marketing communications at any time.
• To exercise these rights, contact us at privacy@predictablebenefits.com.

15. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in law or our practices. Updates will be posted on this page with a revised “Last Updated” date. Continued use of the Site constitutes acceptance of the updated Policy.

16. Contact Information

If you have questions or concerns regarding this Privacy Policy or our data practices, please contact:

Predictable Benefits Inc.
Attn: Privacy Officer
Email: privacy@predictablebenefits.com
Mailing Address: 1340 Sumner Ave., Cleveland, OH 44115