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UPPO

Privacy Policy

Last updated: April 14, 2026

UPPO ("we", "our", or "us") is an ICHRA administration platform used by employers, brokers, agents, and employees to manage health benefit enrollment and related workflows. We are committed to protecting personal information that is processed through the platform. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our services.

We are not a health insurance carrier or healthcare provider. In most cases, we process information on behalf of the employer or plan sponsor that offers the ICHRA benefit, and some requests regarding your data may need to be handled by that employer or its benefits administrator.

1. Information We Collect

We may collect the following types of information:

  • Identity data: name, date of birth, employee ID, and other identifiers used to verify eligibility.
  • Contact data: email address, phone number, and mailing address.
  • Employment and eligibility data: employer name, job title, work status, class, and ICHRA eligibility information.
  • Benefit data: plan selections, coverage effective dates, dependents, waiver records, and enrollment elections.
  • Billing and reimbursement data: amounts, carrier information, and other data needed to administer the ICHRA workflow.
  • Account credentials: hashed passwords, authentication tokens, and multi-factor authentication details.
  • Technical data: IP address, browser type, device information, and usage logs.

2. How We Use Your Information

We use the information we collect to:

  • Administer and operate ICHRA enrollment, eligibility, and onboarding workflows.
  • Communicate with employees, employers, brokers, and agents about enrollments, waivers, and plan updates.
  • Support plan selection, benefit administration, and carrier transmittals where applicable.
  • Document elections, waivers, audit trails, and other records needed for compliance and reporting.
  • Detect, prevent, and address fraud, abuse, security incidents, and unauthorized access.
  • Improve platform functionality, reliability, and user experience.

3. How We Share Your Information

We do not sell your personal information. We may share it with:

  • Employers, brokers, and agents who manage the ICHRA benefit and enrollment process.
  • Health insurance carriers to process enrollments or related coverage information.
  • Service providers who assist with hosting, email delivery, identity verification, and analytics under confidentiality obligations.
  • Regulatory bodies or other third parties when required by law, court order, or government authority.

4. Data Security

We implement industry-standard security measures including encryption in transit (TLS) and at rest, role-based access controls, multi-factor authentication, and audit logging. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide services, administer the ICHRA benefit, comply with legal obligations, resolve disputes, and enforce agreements. Enrollment, waiver, and audit records may be retained for the period required by applicable law, employer policy, or contractual obligations.

6. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access the personal information we hold about you.
  • Request correction of inaccurate or incomplete data.
  • Request deletion of your data, subject to legal obligations.
  • Object to or restrict certain processing activities.
  • Receive a copy of your data in a portable format.

To exercise any of these rights, please contact us at support@uppobenefits.com. If your request relates to employer-sponsored ICHRA data, we may ask you to contact your employer or benefits administrator as well.

7. Cookies and Tracking

We use essential cookies to maintain your session and ensure platform security. We do not use third-party advertising cookies. You may configure your browser to refuse cookies, but some features of the platform may not function properly as a result.

8. Children's Privacy

Our platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors except where a dependent is included for benefits administration purposes at the direction of the enrolling employee or employer.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. Continued use of the platform after changes take effect constitutes your acceptance of the updated policy.

10. Contact Us

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

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