Privacy Policy

This Privacy Policy was last updated December 2022.

Gravie knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. Our Privacy Policy describes the information we collect, how we collect information, and the reasons we collect information. This Privacy Policy also describes the choices you have with the information we collect, including how you can manage, update, or request to delete information.

Please take a moment to review this Privacy Policy. It is important that you understand this Privacy Policy. By using our Platform, you are agreeing to the terms of this Privacy Policy. If you have any questions or concerns about this Privacy Policy, you may contact us at any time.

Who is Gravie?

This Privacy Policy applies to Gravie Agency LLC, Gravie Administrative Services, LLC and Gravie, Inc. Gravie Agency LLC is licensed to sell health insurance to businesses, individuals and families. Gravie Administrative Services LLC is a licensed Third Party Administrator and provides administrative services to groups offering self-funded group plans to their employees or members. Gravie Agency LLC and Gravie Administrative Services LLC are wholly owned subsidiaries of Gravie, Inc. Throughout this Privacy Policy, we will refer to all entities as “Gravie.” Sometimes we will simply say “we,” “us” or “our.”

Section 1312(e) of the Affordable Care Act and the privacy and security standards set forth in the Affordable Care Act and 45 C.F.R. 155.260, establish the scope of our authority to collect Personal Information for the purposes outlined above. Gravie Agency LLC is also a licensed insurance producer in certain states and has entered into agreements with certain health insurance carriers to market and sell their products on and off the exchange. In accordance with state licensing, appointment, and privacy requirements, Gravie Agency LLC collects Personal Information for purposes of providing services under these agreements.

Available products and services on the Platform include personalized online decision support systems to help you review, compare and select policies of insurance, health savings accounts (HSAs), health reimbursement arrangements (HRAs), group health plans, and other products and services made available by Gravie. We will also help you to arrange for payment of insurance policies.

The services described above and other services provided by Gravie are collectively referred to in this Privacy Policy as the “Gravie Services.”

When you register on the Gravie Platform, you become a “Member,” with certain rights and privileges described in this Privacy Policy and the Platform Terms of Service. We may refer to you as a Member, but more often, we will use the terms “you” or “your.

Gravie is regulated by the Health Insurance Portability and Accountability Act and its implementing regulations (collectively, “HIPAA”). Accordingly, Gravie will use, disclose, and safeguard your Personal Information described in this Privacy Policy in accordance with HIPAA to the extent applicable.

Our Relentless Commitment to the Security and Privacy of Your Information

Gravie takes very seriously our responsibility to always ensure the security of member information we collect through the course of doing business. While laws and regulations are in place to protect your privacy, we opt to take additional steps to prevent security breaches, like adopting National Institute of Standards and Technology guidance, performing regular risk assessments and simulations, and maintaining an industry-leading information security and privacy training program for our employees. We know you have enough to worry about, and we aim to take concern over the privacy of your information off of the list.

Below you can find our Privacy Policy, which describes the collection of personal information, how we use your information, and how we share your information.

Applicability of this Privacy Policy

This Privacy Policy applies to your use of the website at www.gravie.com and member.gravie.com and our mobile application, (collectively, the “Platform”). It only applies to information collected via the Platform.

This Platform includes links to other websites. This Privacy Policy does not apply to these linked websites. We do not endorse and are not responsible for the operation or content of these websites. Please consult the privacy policy for each website you visit.

We maintain accounts on third-party websites, such as social media sites, as tools to better interact with the public. The security and privacy policies of third-party websites apply to your activity on those websites. Users of third-party websites often share information with the general public, user community, and/or the third party operating the websites. You should review the privacy policies of all websites before using them and ensure that you understand how your information may be used. You should also adjust privacy settings on your account on any third-party website to match your preferences.

Access to and use of the Platform and/or the Gravie Services is limited exclusively to users located in states within the United States where the Platform and/or the Gravie Services is available. The Platform and/or the Services are not available to users located outside the United States. Accessing the Platform and/or obtaining the Services from jurisdictions where content is illegal, or where we do not offer the Platform and/or the Services, is prohibited.

Collection of Personal Information

Personal information is information from and about you that may be able to personally identify you. We treat any information that may identify you as personal information. We collect most Personal Information directly from you. We collect Personal Information from users of this Platform who voluntarily choose to disclose this information in order to access the Gravie Services available through this Platform.

In order to provide the Gravie Services, we need to collect some of your Personal Information, which may include your name, username, banking and financial information, insurance policy number, social security number, date of birth, address, contact information, marital status, information about your sex, gender, gender identity, sex life, and related medical conditions, and medical information, such as whether you use tobacco. If you are considering family coverage, we will need to collect the same information on family members. If you are enrolling in a group health plan, you may be asked to respond to medical questions on an application for coverage. To arrange for payment of individual insurance policies, you will need to provide us with bank information. To determine your eligibility for government subsidies (such as premium tax credits on a state or federal health care exchange), we will need your social security number and financial information.

We collect Personal Information from you when you:

register to become a Member;
use tools on the Platform;
conduct a transaction (e.g., purchase coverage) through the Gravie Service; and
choose to provide us with additional information.

The decision to provide your information is voluntary and is not required. However, if you choose not to provide the requested information, Gravie will not be able to make its products and services available to you.

We will also collect information automatically as you navigate through our Platform. We use the following technologies to automatically collect data:

Cookies: We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Platform through your computer or mobile device. A “cookie” is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. Some of the cookies we use are “session” cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the website and to limit the amount of redundant data that is downloaded during a single session. We also may use “persistent” cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our Platform and/or the Gravie Services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Platform. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
Google Analytics: We also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Platform. Google Analytics uses cookies, to help our Platform analyze how users use our Platform. You can find out more about how Google uses data when you visit our Platform by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). This information can be used to identify you as an individual by Gravie and may be connected to other data Gravie has about you, including Personal Information.
We use other third party tools, such as Datadog, which allow us to track the performance of our Platform. These tools provide us with information about errors, mobile application and website performance, and other technical details we may use to improve our Platform.

We collect Personal Information from all users of this Platform in order to enhance the user’s experience while visiting the Platform and to improve the design and content of the Platform, including:

the date and time of your visit to our Platform;
your location at the time of your visit, down to the city-level;
the number of visitors to this Platform;
the websites from which users enter this Platform;
the pages users visit while on this Platform;
the actions (e.g., button clicks) users take while on this Platform;
the length of these visits;
the names of the users’ Internet providers and internet protocol addresses;
the users’ browser information;
the speed of the users’ connections, and
the search terms used to find this Platform, as applicable.

How We Use Your Personal Information

We may use your Personal Information for the following purposes:

Operate, maintain, supervise, administer, and enhance our Platform or the Gravie Services, including monitoring and analyzing the effectiveness of content on the Platform, aggregate site usage data, and other usage of the Platform and/or the Gravie Services such as assisting you in completing the registration process.
Provide our Gravie Services to you, in a custom and user-friendly way.
Provide you with information Gravie Services that you request from us or that may be of interest to you.
Promote and market our Platform and/or the Gravie Services to you. For example, we may use your Personal Information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about services or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving these emails at any time as described below.
To provide you notices or about your account.
Contact you in response to a request.
To notify you about changes to our Platform and/or the Gravie Services we offer or provide through them.
Fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Anonymize and aggregate information for analytics and reporting.
To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform and the safety of others.
To provide you information about goods and services that may be of interest to you, including through newsletters.
Any other purpose with your consent, such as through the Gravie “Release of Information” form.

How We Share Your Personal Information

We may share Personal Information with third parties in certain circumstances or for certain purposes, including:

Our business purposes: We may share your Personal Information with our affiliates, vendors, service providers, employers, referral partners, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors, in order to coordinate payments, provide products and services, and enable administrative functions related to the services you choose. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
With your consent: We may share your Personal Information if you request or direct us to do so, such as through the Gravie “Release of Information” form.
Compliance with law: We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
Business transfer: We may share your Personal Information to a buyer or other successor in the event of 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 a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
To enforce our rights: We may share your Personal Information to enforce any applicable terms and conditions and Terms of Service , and to ensure the safety and security of our Gravie Services and our users.
De-identified information: We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes.
To market our products and services: We may share your Personal Information with affiliates and third parties to market our products and services. Please note that we will never sell your information for marketing purposes, nor will we share your information with third parties for their direct marketing purposes, and you always have the right to opt-out of receiving communications from us.
Third party analytics: We use Google Analytics to understand and evaluate how visitors interact with our Platform and/or the Gravie Services. These tools help us improve our Platform and/or the Gravie Services, performance, and your experience.

This section of our Privacy Policy provides details and explains how to exercise your choices. We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes. You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative’s (NAI) opt-out page and the Digital Advertising Alliance’s (DAA) opt-out page.

Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies. Please see below for more information.

For other browsers, please consult the documentation that your browser manufacturer provides.

If you do not wish to have your email address used by Gravie to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to Gravie as a result of a product purchase, or your use of our Platform and/or the Gravie Services. You may have other options with respect to marketing and communication preferences through our Platform.

You may also see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests.

Accessing, Correcting, and Deleting Your Personal Information

In addition to any data access capabilities available through the Platform, you may contact us by phone at 800.501.2920 to inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. You may also have certain deletion rights in accordance with applicable law. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Data Retention

We retain the data we collect for different periods of time depending on what it is, how we use it and applicable legal requirements. We may retain some data for longer periods of time than other data when necessary for legitimate business or legal purposes, such as legal retention requirements, security, fraud and abuse prevention, or financial record-keeping.

Data Security

We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use of Gravie data. Where you have been given or you have chosen a password, you agree to protect the confidentiality of your user ID and password, and not to share or disclose your user ID or password to any third party.

We strive to use best practices and industry standard security measures and tools to protect your data. We protect your transactions involving Personal Information over the Internet using Transport Layer Security (TLS) technology. We restrict access to your Personal Information in our database to our authorized employees, our agents and certain of our authorized partners. We are not responsible for the circumvention of any privacy settings or security measures contained in your operating system or mobile device.

Children’s Privacy

This Platform is not designed for, or intentionally targeted at, users under the age of 18. We will not knowingly collect any Personal Information directly from users under the age of 18 online through this Platform. Parents/legal guardians or personal representatives of children under the age of 18 may register on a child’s behalf in order to purchase a child-only plan. If you believe that we have collected Personal Information from a user under the age of 18, please contact us.

Do Not Track Signals

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Platform is not currently set up to respond to those signals.

Contact Us

If you have any questions, comments, complaints or concerns about our Privacy Policy or your privacy please contact us by phone at 800.501.2920 or by email at help@gravie.com.

If you are enrolling for individual insurance through Gravie Agency LLC, you may also submit a complaint to the Centers for Medicare and Medicaid Services (CMS) via the Federally Facilitated Marketplace (FFM) Call Center by calling: 800.318.2596, 24 hours per day, 7 days per week, except holidays.

In accordance with California Civil Code Sec. 1789.3, California residents are entitled to know that they may file grievances and complaints with the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs. Grievances and complaints may be submitted in writing to 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916.445.1254 or 800.952.5210; or by email to dca@dca.ca.gov.

Changes to Our Privacy Policy

We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices, so we encourage you to review our Privacy Policy frequently. We may not provide individual notice to you of changes to our Privacy Policy, but when we make updates to our Privacy Policy, we post these changes in a conspicuous manner on our Platform and update the date in the Privacy Policy.