Privacy Policy
Effective Date: January 1, 2024 • Last Updated: September 15, 2026
Introduction
Arizona Healthcare Coverage (“AZHCC,” “we,” “us,” or “our”) is committed to protecting the privacy and security of the personal information you entrust to us. As a 501(c)(3) nonprofit organization and CMS-certified Application Counselor Organization, we handle sensitive personal health and financial information as part of our core mission to provide free health insurance enrollment assistance to Arizona residents.
This Privacy Policy explains how we collect, use, store, protect, and share your personal information when you interact with our organization through our website (arizonahealthcarecoverage.org), in-person consultations, phone appointments, and community events. By using our services, you consent to the practices described in this policy.
Information We Collect
To provide health insurance enrollment assistance, we may collect the following categories of personal information:
Personally Identifiable Information (PII)
- Full legal name, date of birth, and Social Security number
- Home address, phone number, and email address
- Citizenship or immigration status and related documentation
- Marital and household composition information
Financial Information
- Annual household income and income sources
- Employment status and employer information
- Tax filing status and dependent information
- Current health insurance coverage details, if any
Health-Related Information
- Current health conditions relevant to coverage selection (shared voluntarily)
- Current prescription medications (for formulary comparison purposes)
- Preferred healthcare providers and specialists
- Disability status (for program eligibility determination)
Technical Information
- IP address, browser type, and device information when visiting our website
- Pages visited, time spent, and referring website
- Cookies and similar tracking technologies for website functionality
How We Use Your Information
We use the personal information we collect exclusively for the following purposes:
- Enrollment Assistance: To determine your eligibility for health coverage programs (ACA Marketplace, AHCCCS, KidsCare, Medicare), complete your applications, and assist with plan selection and enrollment.
- Appointment Scheduling: To schedule, confirm, and prepare for your enrollment consultations.
- Follow-Up Support: To assist with post-enrollment issues such as verification requests, plan changes, coverage renewals, and appeals.
- Program Reporting: To compile anonymized, aggregate data for grant reporting, program evaluation, and organizational impact measurement as required by our funding sources.
- Communications: To send you appointment confirmations, enrollment reminders, and coverage renewal notifications. You may opt out of non-essential communications at any time.
How We Protect Your Information
Arizona Healthcare Coverage implements comprehensive administrative, technical, and physical safeguards to protect your personal information:
- Access Controls: Only CMS-certified counselors with a legitimate need-to-know can access client records. All staff members complete annual privacy and security training.
- Encryption: All electronic client data is encrypted at rest using AES-256 encryption and in transit using TLS 1.3 protocols.
- Physical Security: Paper records are stored in locked filing cabinets within our secured office suite. Access is restricted to authorized personnel only.
- Data Retention: Client records are retained for seven (7) years from the date of last service, as required by CMS Navigator program regulations. Records are securely destroyed after the retention period expires through certified shredding services for paper records and cryptographic erasure for electronic records.
- Incident Response: We maintain a data breach notification protocol that complies with Arizona Revised Statutes §18-552 and federal CMS requirements. In the event of a data breach affecting your personal information, we will notify you within 45 days as required by law.
Information Sharing and Disclosure
Arizona Healthcare Coverage does not sell, rent, trade, or otherwise share your personal information with third parties for marketing or commercial purposes. We will never sell your data to advertisers, data brokers, insurance carriers, or any other commercial entity.
We may share your information only in the following limited circumstances:
- Government Agencies: We share application data with the Centers for Medicare & Medicaid Services (CMS), the Arizona Health Care Cost Containment System (AHCCCS), and Healthcare.gov as required to complete your enrollment applications. This sharing is governed by CMS data use agreements and federal privacy regulations.
- Insurance Carriers: Plan selection and enrollment data is transmitted to your chosen insurance carrier solely for the purpose of effectuating your coverage enrollment.
- Grant Reporting: We share anonymized, aggregate program data (enrollment counts, demographic summaries, outcome metrics) with our funding partners. Individual client records are never shared for grant reporting purposes.
- Legal Requirements: We may disclose personal information if required by law, subpoena, court order, or government regulatory authority.
CMS Data Security Requirements
As a CMS-certified Application Counselor Organization, Arizona Healthcare Coverage is bound by the CMS Navigator and Application Counselor privacy and security standards. These requirements include:
- All counselors must pass annual CMS certification training that includes privacy and security modules.
- Personally Identifiable Information collected during Marketplace enrollment must be used solely for authorized purposes under our CMS agreement.
- We must report any suspected or confirmed privacy or security incidents to CMS within 24 hours of discovery.
- We are subject to CMS audits and monitoring of our data security practices.
Your Rights Under CCPA
While Arizona Healthcare Coverage is an Arizona-based organization, we respect the privacy rights of all individuals. Under the California Consumer Privacy Act (CCPA), California residents have the following rights:
- Right to Know: You may request a copy of the personal information we have collected about you.
- Right to Delete: You may request that we delete your personal information, subject to legal retention requirements.
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
- No Sale of Information: We do not sell personal information. We have not sold personal information in the preceding 12 months.
Cookies and Website Analytics
Our website uses essential cookies for site functionality (session management, form state preservation). We do not use third-party advertising cookies or cross-site tracking technologies. We may use anonymized, aggregate website analytics to understand how visitors use our site and improve our online resources. You may disable cookies in your browser settings; however, some website features (such as form submissions) may not function properly without cookies enabled.
Children’s Privacy
Arizona Healthcare Coverage does not knowingly collect personal information from children under the age of 13 through our website. When assisting families with KidsCare or AHCCCS applications for minor children, we collect only the information necessary for application completion, and this information is provided by the child’s parent or legal guardian.
Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or CMS regulations. We will post the updated policy on this page with a revised “Last Updated” date. Material changes will be communicated through a notice on our website homepage or by direct notification to active clients.
Contact Us About Privacy
If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your information has been handled, please contact us:
Privacy Officer
Arizona Healthcare Coverage
3033 North Central Avenue, Suite 900
Phoenix, AZ 85012
Phone: (602) 555-0194
Email: privacy@arizonahealthcarecoverage.org