Privacy Policy

Last updated: June 8, 2026

Clear Capitation ("we," "us," or "our") is committed to protecting the privacy of our clients, website visitors, and all individuals whose information we may handle in the course of providing our services. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website or engage our services.

1. Information We Collect

Information you provide directly:

• Contact information (name, email address, phone number, company name) submitted through our website contact form
• Communications you send to us via email or other channels

Information collected automatically:

• Browser type, operating system, and device information
• IP address and approximate geographic location
• Pages visited, time spent on pages, and referral sources

Client data processed under engagement:

• Claims data, Monthly Membership Report (MMR) files, and related enrollment information provided by clients for the purpose of ESRD revenue recovery analysis
• This data may contain Protected Health Information (PHI) as defined under HIPAA and is handled in accordance with our Business Associate Agreement (BAA) and applicable law

2. How We Use Your Information

• To respond to inquiries and provide requested services
• To perform ESRD revenue recovery analysis and related services under client engagements
• To communicate with you about our services
• To improve our website and service offerings
• To comply with legal obligations

3. Data Security

We implement industry-standard security measures to protect the information we handle, including:

• AES-256 encryption for all data in transit and at rest
• SOC 2-aligned controls for access management, monitoring, and incident response
• Role-based access controls limiting data access to authorized personnel
• Regular security assessments and vulnerability testing

4. HIPAA Compliance

When our services involve the handling of Protected Health Information (PHI), we operate as a Business Associate under HIPAA. We execute a Business Associate Agreement (BAA) with each client before any PHI is transmitted. All PHI is handled in strict compliance with the HIPAA Privacy Rule, Security Rule, and Breach Notification Rule.

5. Information Sharing

We do not sell, rent, or trade your personal information. We may share information only in the following circumstances:

• With service providers who assist in our operations, under contractual obligations to protect your data
• When required by law, regulation, or legal process
• With CMS or other government agencies as necessary to process corrections and recoveries on behalf of our clients

6. Data Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Client engagement data is retained in accordance with the terms of our service agreements and applicable regulatory requirements.

7. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or restrict the processing of your personal information. To exercise any of these rights, please contact us at contact@clearcapitation.com.

8. Cookies

Our website may use essential cookies to ensure proper functionality. We do not use advertising or third-party tracking cookies. Analytics, if enabled, use privacy-respecting configurations that do not track individual users across sites.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Continued use of our website or services after changes constitutes acceptance of the revised policy.

10. Contact Us

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

contact@clearcapitation.com