Last Modified: October 1, 2026

This Privacy Policy describes how Accord Systems, LLC ("Accord," "we," "us," or "our") collects, uses, shares, and protects information in connection with our Affordable Care Act ("ACA") compliance and reporting services, including Accord and Forms Express (together, the "Services"). It applies to our websites (including www.accord-aca.com), the Accord application, the employee form portal, our APIs and integrations, and any other place where we link to this Privacy Policy.

By accessing or using the Services, you acknowledge that you have read this Privacy Policy. If you use the Services on behalf of an organization, this Privacy Policy also describes how we handle information that organization provides to us. Capitalized terms not defined here have the meanings given in our Terms of Service.

1. Our Role

Accord helps employers meet their obligations under the ACA, including tracking eligibility and offers of coverage, preparing Forms 1094-C and 1095-C, furnishing forms to employees, and filing with the IRS and applicable states. Our customers are employers and the partners that serve them, such as professional employer organizations (PEOs), payroll providers, brokers, and other resellers ("Partners").

We handle two kinds of information:

• Customer Data. Information about an employer's workforce, such as employees and their covered dependents, that an employer or Partner submits to the Services or directs us to collect. We process Customer Data on behalf of, and under the instructions of, the employer or Partner, and in accordance with our agreement with them. The employer is responsible for providing any notices and obtaining any consents required to share that data with us.
• Account and Website Information. Information about the people who create accounts, contact us, or visit our websites, which we handle as described in this Privacy Policy.

If you are an employee or dependent whose information was provided to Accord by your employer, your employer controls that information. Please direct questions or requests about it to your employer. We will assist your employer in responding where required.

2. Information We Collect

Information you provide when you use the Services. When you register, sign up on behalf of an organization, or manage an account, we collect information such as your name, job title, employer name, Employer Identification Number (EIN), business address, email address, phone number, login credentials, and billing and payment information.

Customer Data provided by employers and Partners. To prepare ACA reporting, employers and Partners upload or transmit workforce information to the Services. Depending on the Services used, this may include:

• Employee and dependent names, Social Security numbers or other taxpayer identification numbers, dates of birth, and mailing and email addresses;
• Employment information, such as hire, rehire, and termination dates, employment status, hours of service, pay, job classification, and work location;
• Health coverage information needed for ACA reporting, such as offers of coverage, plan information, employee premium contributions, enrollment, and coverage periods for employees and dependents; and
• Employer information, such as EIN, Aggregated ALE Group members, and contact details for the person responsible for filing.

We collect only the coverage information necessary for ACA reporting. The Services are not designed to receive medical records, diagnoses, or claims information, and you should not submit that information to us.

Information from integrations. When an employer or Partner connects the Services to a payroll, HR, PEO, or benefits administration system, we receive Customer Data from that system as authorized by the employer or Partner. We also receive information from the accounting and payment services we use to invoice our customers.

Information from marketing data providers. When you visit our public websites or submit a form on them, such as a demo request, we may receive business information about you and your company from marketing data providers, such as your company name, industry, company size, job title, and business contact details.

Information from the employee form portal. When an employee accesses their Form 1095-C through our portal, we collect the last digits of their taxpayer identification number to verify their identity, their consent to receive the form electronically, and a record of their access and downloads.

Files. We store the files you upload to, generate in, or download from the Services, including census files, payroll reports, and completed forms.

Communications. When you contact us, chat with us, request a demo, or respond to a survey, we collect the information you provide and the content of your communications.

Information collected automatically. When you use the Services or visit our websites, we automatically collect information about your device and activity, such as IP address, browser type, operating system, referring pages, pages visited, date and time stamps, and actions taken in the Services. We maintain audit logs of activity in the Services to protect accounts and support compliance.

3. Cookies and Analytics

We use cookies and similar technologies to keep you signed in, remember your preferences, secure the Services, and understand how our websites are used. Session cookies are deleted when you close your browser; persistent cookies remain until they expire or you delete them.

On our public websites, we use third-party analytics and marketing tools. These tools are not loaded for signed-in users of the Services. We use them to:

• Understand website visitors. Tracking tools use cookies and your IP address to record the pages you visit and to identify the company you are likely visiting from.
• Enrich form submissions. When you submit a form, such as a demo request, a marketing data provider matches the information you enter against its business database to fill in details about you and your company.

We use this information to measure and improve our websites, plan and run our marketing campaigns, tailor our website content and sales outreach to your organization, and follow up on your requests. These providers may also use this information under their own privacy policies.

Our websites and the Services include a live chat feature provided by third-party chat providers. These providers use cookies to maintain chat sessions and receive the messages you send. When you are signed in, we share your email address and account identifier with our chat provider so our support team knows who they are chatting with.

Most browsers let you block or delete cookies. If you disable cookies, some parts of the Services, such as signing in, may not work.

4. How We Use Information

We use information to:

• Provide the Services, including determining ACA eligibility and affordability, preparing Forms 1094-C and 1095-C, furnishing forms to employees, and filing with the IRS and state agencies as directed by the employer or Partner;
• Create and administer accounts, authenticate users, and verify employees accessing the form portal;
• Validate data, identify errors, and process IRS and state acknowledgements and error reports;
• Provide customer support and communicate with you about the Services, including filing deadlines, service changes, and policy updates;
• Invoice and collect payment;
• Maintain, secure, and improve the Services, including detecting and preventing fraud, abuse, and unauthorized access;
• Plan and run marketing campaigns, personalize our website content and communications for business contacts, and send information about our products and services, which you can opt out of at any time; and
• Comply with legal obligations and enforce our agreements.

We use Customer Data only to provide the Services to the employer or Partner that submitted it, as described in our agreement with them, or as required by law. We do not use Customer Data for marketing, and we do not use employee or dependent information to contact employees for any purpose other than delivering their ACA forms.

5. How We Share Information

We do not sell personal information for money, and we never sell or share Customer Data. We share information only as follows:

• Government agencies. We transmit ACA filings to the IRS and to state agencies, such as California's Franchise Tax Board, when an employer or Partner directs us to file on its behalf.
• Employers and Partners. Customer Data is available to the employer and, where applicable, to the Partner that administers the employer's account. Employees can access their own forms through the employee portal.
• Service providers. We use vendors to host and store data, deliver email, manage website analytics and tags, provide live chat support, and handle invoicing and payments. They may access information only to perform services for us and are required to protect it.
• Marketing data providers. Marketing data providers receive information about visits to our public websites and the forms submitted on them, as described in Section 3, and may use it under their own privacy policies. We never share Customer Data with marketing data providers.
• Integrations you authorize. If an employer or Partner connects a third-party system to the Services, we exchange information with that system as directed. The third party's use of that information is governed by its own terms and privacy policy.
• Affiliates. We may share information with companies under common ownership or control with Accord, such as Zevo Benefits, Inc., to provide and support the Services, consistent with this Privacy Policy.
• Legal requirements and protection. We may disclose information if we believe in good faith that it is reasonably necessary to comply with a law, regulation, subpoena, or other legal process; to protect the safety of any person; to prevent fraud, security incidents, or abuse; or to protect the rights and property of Accord and our customers. Where permitted, we will notify the affected customer before disclosing Customer Data.
• Business transfers. If Accord is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction. We will notify you, for example by email or a prominent notice in the Services, before your information becomes subject to a different privacy policy.
• With consent. We may share information for other purposes with your consent or at your direction.
• Aggregated or de-identified information. We may use and share information that has been aggregated or de-identified so it cannot reasonably be used to identify an individual or employer, for example to report on ACA compliance trends.

6. Data Security

We protect information using administrative, technical, and physical safeguards appropriate to its sensitivity. These include encryption of data in transit and at rest, access controls that limit Customer Data to personnel and service providers who need it, audit logging, and secure transmission to the IRS through its Affordable Care Act Information Returns (AIR) system.

You are responsible for keeping your login credentials confidential, limiting access to your account to authorized individuals, and signing out on shared devices. Please contact us immediately if you believe your account has been compromised.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If we learn of a security incident affecting your information, we will notify you and affected customers as required by law and our agreements. Questions about security can be sent to support@accord-aca.com.

7. Data Retention

We retain information for as long as your account is active and as needed to provide the Services. Because ACA forms may be corrected, audited, or questioned by the IRS for several years after filing, we generally retain Customer Data and filed forms for the period the employer may need them to respond to IRS or state inquiries, unless the employer directs otherwise or a longer period is required by law. We also retain information as needed to comply with legal obligations, resolve disputes, and enforce our agreements.

When information is no longer needed, we delete or de-identify it. Copies may remain in backups for a limited time before they are overwritten.

8. Your Choices

• Account information. You can review and update your account information in the Services or by contacting us.
• Customer Data. Employers and Partners can review, correct, and export Customer Data in the Services. Employees and dependents should contact their employer to access or correct their information.
• Marketing emails. You can opt out of marketing emails using the unsubscribe link in the message or by contacting us. We will still send service-related messages, such as filing deadline reminders and policy updates.
• Website tracking. You can block the website tracking described in Section 3 by blocking cookies in your browser, or ask us to stop using your information for marketing by emailing support@accord-aca.com.
• Cookies. You can manage cookies through your browser settings, as described above.

9. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information, including the right to:

• Know what personal information we collect, use, and disclose, and access a copy of it;
• Correct inaccurate personal information;
• Delete personal information, subject to legal exceptions, such as information we must retain for tax reporting;
• Receive your personal information in a portable format; and
• Opt out of the sale or sharing of personal information, or of its use for targeted advertising or profiling. Some state laws may treat the website tracking and form enrichment described in Section 3 as a "sale" or "sharing" of personal information. You can opt out by emailing us as described below. This never involves Customer Data.

To exercise these rights, email support@accord-aca.com. We will verify your identity before responding, which may require you to confirm information we already have. You may use an authorized agent, who must provide proof of your authorization. If your request concerns Customer Data, we will refer it to the employer that controls that data and assist them in responding. We will respond within the time required by applicable law, and we will not discriminate against you for exercising your rights. If we deny your request, you may appeal by replying to our response.

California residents. In the preceding 12 months, we collected the categories of personal information described in Section 2: identifiers (such as name, email address, Social Security number, and IP address); personal information described in Cal. Civ. Code § 1798.80 (such as address and employment information); characteristics of protected classifications (age, derived from date of birth); commercial information (billing records); internet or network activity; professional or employment-related information; and sensitive personal information (Social Security numbers and account login credentials). We collected this information from the sources and for the purposes described in Sections 2 and 4, and disclosed each category for business purposes to the recipients described in Section 5. Identifiers, internet or network activity, and professional information about visitors to our public websites may be made available to marketing data providers as described in Section 3. We use sensitive personal information only to provide the Services and for other purposes permitted by law, and not to infer characteristics about individuals. We retain personal information as described in Section 7.

10. Children's Privacy

The Services are intended for businesses and are not directed to children. We do not knowingly collect personal information directly from children under 13. ACA reporting can require employers to report covered dependents, including minors. We process that information only on the employer's behalf to prepare required filings. If you believe a child has provided us personal information directly, please contact us and we will delete it.

11. Where Information Is Processed

Accord is based in the United States, and the Services are designed for U.S. employers and U.S. tax reporting. We process and store information in the United States. If you access the Services from outside the United States, your information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those where you live.

12. Third-Party Websites and Services

The Services may link to or integrate with websites and services we do not control, such as the IRS, state agencies, and payroll or HR providers. This Privacy Policy does not apply to them, and we are not responsible for their privacy practices. We encourage you to review their privacy policies.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will update the "Last Modified" date above and summarize the changes in the Revision History below. Your continued use of the Services after the effective date means you accept the revised Privacy Policy.

14. Contact Us

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

Accord Systems, LLC
931 Monroe Drive, Ste 102-#476
Atlanta, GA 30308
support@accord-aca.com

Revision History

Effective: 10/1/2026

• Rewrote the policy for our ACA compliance and reporting services, including Forms Express and the employee form portal.
• Explained that we process employee and dependent data on behalf of employers and Partners, who control that data.
• Listed the specific workforce and coverage information we collect for ACA reporting, and clarified that we do not collect medical or claims information.
• Added disclosure of filings with the IRS and state agencies, and described the categories of service providers we use.
• Added detail on cookies, website analytics and marketing tools, live chat, data security, and data retention.
• Added a section on privacy rights, including disclosures for California residents.
• Added sections on children's privacy, where information is processed, and third-party websites and services.
• Removed outdated references to the U.S.–E.U. Safe Harbor framework and SiteLock, and updated our contact information.

Effective: 3/15/2018

• Expanded the policy to cover Forms Express.