Privacy policy

Your brokerage (the "Tenant") is the data controller for the personal information of plan members, dependents, and other natural persons whose data you upload or generate within ABB. We are your data processor and act under your authority. We are the data controller for information about your Broker users (your authorized employees and partners who log in to ABB).

• Broker users: name, work email, password hash, role, audit log of actions.
• Plan member & dependent data: identifying details (name, DOB, address), coverage class, dependents, salary range, claims information — whatever you choose to upload.
• Operational data: service threads, agent drafts, carrier bulletins, opportunity records, generated enrollments.
• Technical telemetry: agent token usage, error reports (no PII content), basic page-view logs.

We process personal information only to operate the Service for your tenant: classify and action service mail, draft enrollments and communications, parse carrier bulletins, match client impacts, and generate the artifacts the agent produces for your review. We do not use your data for training any AI model. We do not sell your data.

• Anthropic, PBC — model inference. Contractual commitment that customer data is not used for training.
• Neon Inc. — Postgres hosting; Canadian region for tenant data.
• Cloudflare, Inc. — content delivery, edge runtime, object storage.
• Vercel Inc. — application hosting and edge functions.
• Microsoft Corporation — only when you connect a Microsoft 365 mailbox to your tenant.

Subprocessor list is kept current; we notify Tenants 14 days before adding a new one.

Tenant data is currently stored and processed in the United States (Neon Postgres and Cloudflare R2, US/North-American regions), and model inference is performed in the United States via Anthropic. Migration of primary storage to a Canadian region is planned. By using ABB you consent to this cross-border processing for the operational purpose of running the service and generating agent outputs. We will update this notice when Canadian-region storage is in place.

We retain tenant data for the active life of the tenancy plus 30 days following termination, during which we make a final export available on request. After that window we delete operational data on request, and an automated retention schedule that performs this on a rolling basis is being implemented. We intend to retain audit-log entries for seven (7) years as a regulatory record; automated enforcement of that schedule, and tamper-evident audit logging, are on the roadmap (see our Security page).

If you are a plan member or other natural person whose data is processed in ABB through a broker tenant, you can request access, correction, or deletion of your personal information. Direct your request to the broker you work with — they are the data controller. If you cannot reach your broker, contact us at the address below and we will route the request.

See the Security page for technical and organizational measures.

We follow a standing incident-response process. In the event of a real risk of significant harm under PIPEDA Section 10.1, we will notify affected Tenants without unreasonable delay and assist with notifications to the Office of the Privacy Commissioner of Canada and affected individuals.

We will notify Tenants at least 30 days before material changes. Continued use after the effective date constitutes acceptance.

Privacy questions: privacy@eastcoastemployeebenefits.com
Postal: East Coast Employee Benefits, Halifax, Nova Scotia, Canada