Privacy Policy
Public-facing privacy notice for Nielo. Crux Ledger LLC, doing business as Nielo.
This Privacy Policy explains how Crux Ledger LLC, doing business as Nielo ("Nielo," "we," "us," or "our"), collects, uses, discloses, protects, and retains information in connection with our websites, applications, services, integrations, demonstrations, and customer relationships.
This Policy should be read together with any applicable customer agreement, Business Associate Agreement ("BAA"), payment authorization, and other terms governing use of Nielo. If a BAA or other written agreement imposes more specific requirements for Protected Health Information ("PHI"), that agreement controls for the covered information.
1. Information We Collect
1.1 Account, Business, Ownership, and Authorization Information
We may collect information used to establish, administer, verify, and maintain a Nielo account or customer relationship, including:
- name, business email address, business telephone number, employer or organization, job title, and role;
- business postal address and billing postal address;
- account, permission, authentication, and security information;
- names of business owners, their ownership percentages, and signed ownership attestations;
- the name, title, and typed signature of the person executing a BAA on behalf of a customer;
- the name, title, and other signer information associated with an authorization for payment of Nielo fees from a connected bank account; and
- support, onboarding, and account communications.
Certain executed agreements, attestations, and authorization records are maintained as historical records so Nielo can document the authorization or agreement that was in effect when it was executed. These records are not overwritten when later records are signed.
1.2 Authentication Information
Nielo uses password authentication together with WebAuthn/FIDO2 passkeys. We may maintain information necessary to authenticate users and protect accounts, including:
- password hashes;
- public passkey credential information;
- authentication events;
- session information;
- account-recovery records; and
- security and access logs.
Nielo does not receive or store the private credential key used by a user's passkey authenticator or passkey provider.
1.3 Patient, Billing, and Healthcare Information
At the direction of an authorized healthcare customer, Nielo may receive patient-level billing, claims, payment, insurance, and related information from CollaborateMD or other customer-authorized billing platforms. Some of this information may constitute PHI under HIPAA. Nielo uses this information to provide reconciliation, accounting and, where the customer turns it on, patient billing services to the customer, including sending a patient a statement of their balance and collecting their payment through the customer's payment processor account, and handles it subject to the applicable BAA, customer instructions, and law. Where the customer is a program subject to 42 CFR Part 2, Nielo handles those records as a qualified service organization under that regulation.
1.4 Bank and Financial Information
When a customer connects an eligible financial account through Plaid, Nielo may use that connection for two separate purposes:
- Reconciliation. Nielo receives read-only account and transaction information used to reconcile deposits and accounting records. Nielo does not use this function to move, withdraw, or transfer patient payments, insurance proceeds, or other customer operating funds.
- Payment of Nielo fees. If a customer separately signs an authorization, Nielo may use the connected account to collect fees owed directly to Nielo for Nielo subscriptions or services. This authorization is separate from reconciliation.
Nielo does not store full bank account numbers. Nielo receives and retains only limited account-identifying information made available through the applicable provider, such as the last four digits and provider-generated identifiers necessary to identify or administer the connection.
1.5 QuickBooks Online Information
When a customer connects QuickBooks Online, Nielo may read, create, or manage accounting information needed to configure and provide the service. Depending on the customer configuration, Nielo may:
- read applicable QuickBooks company preferences and accounting configuration;
- create customer records;
- create accounts and sub-accounts under applicable revenue categories;
- create service items and classes;
- create journal entries;
- delete journal entries previously created by Nielo; and
- read accounting information necessary to configure or perform reconciliation.
Nielo is designed so patient-level PHI is not transmitted to or stored in QuickBooks Online through the Nielo integration. Nielo does not use QuickBooks Online as a repository for patient records.
1.6 Payment Information
Certain payments may be completed through payment interfaces hosted by Stripe. When payment-card or bank-account information is entered directly into a Stripe-hosted interface, that information is provided to Stripe. Nielo does not store full payment-card numbers or full bank-account numbers entered through those interfaces. Stripe may provide Nielo with limited transaction, payment-status, customer, and payment-method information needed to administer and document the payment.
1.7 Website, Security, and First-Party Event Information
We may automatically collect limited information needed to operate and secure our websites and services, including IP address, date and time of access, authentication events, application activity, error information, security events, and diagnostic or performance information.
When someone arrives through a campaign, referral, or marketing link, we may also record campaign parameters, the referring website or source, and first-party website events. If the person submits a demo request, applicable referral and campaign information may be retained with that request.
Nielo does not collect browser type, device model, or operating-system information as part of its ordinary website or application data collection.
1.8 Demo Requests, Support, and File Uploads
A demo request may include name, work email, company, role, number of active locations, current billing system, current accounting system, stated interests, referral or campaign information, the Nielo staff member handling the request, and relevant dates and times.
If you contact us for support or otherwise communicate with Nielo, we collect the information reasonably necessary to respond to and document the communication. Users should avoid placing unnecessary PHI, passwords, or authentication credentials in routine support communications.
Authorized users may upload files associated with their account. Individual uploads may be limited to 20 MB. Uploaded files are stored with the applicable customer account and may contain information supplied by the customer. Customers are responsible for ensuring they are authorized to provide uploaded information to Nielo.
2. How We Use Information
We use information to provide, secure, maintain, support, and improve Nielo; authenticate users; perform reconciliation; connect authorized banking, billing, payment, and accounting systems; display authorized patient and billing information within Nielo; send a customer's patients statements of their balance and collect their payments on the customer's behalf, where the customer turns patient billing on; create and manage approved non-PHI accounting information in QuickBooks Online; collect authorized fees owed directly to Nielo; administer accounts, permissions, onboarding, ownership records, BAAs, and payment authorizations; respond to demo requests and support inquiries; detect and respond to security incidents; prevent fraud and abuse; maintain audit and security records; comply with legal, regulatory, contractual, and security obligations; and enforce applicable agreements and policies.
Nielo does not use customer data, patient information, or PHI to train artificial intelligence or machine-learning models.
Nielo does not use PHI for advertising or unrelated marketing purposes.
3. Protected Health Information
When Nielo processes PHI on behalf of a healthcare customer, Nielo may act as a business associate or subcontractor under HIPAA, depending on the applicable relationship. Nielo executes a BAA with each healthcare customer at onboarding where the relationship requires one. The connection between Nielo and the customer's billing system remains blocked until an authorized customer Owner signs the applicable BAA.
Nielo records the signer information associated with the BAA, including the signer's name, title, and typed signature, and maintains the executed agreement as part of the customer's compliance records.
Use and disclosure of PHI is governed by applicable law, the applicable BAA, customer instructions, and the applicable services agreement. This Privacy Policy does not expand Nielo's rights to use PHI beyond those authorities.
4. Bank Connections and Plaid
Nielo uses Plaid to support authorized bank connections. For reconciliation, Nielo receives read-only financial account and transaction information. If a customer separately authorizes payment of Nielo fees from the connected account, Nielo may also use the connection to initiate collection of amounts owed directly to Nielo. Nielo does not use Plaid to move patient funds, insurance proceeds, or other customer operating funds.
Plaid processes information under its own applicable terms and privacy practices. Customers should review those terms when connecting an account.
Customers may disconnect supported bank-account integrations through Nielo or the applicable provider.
5. QuickBooks Online and Intuit
Nielo integrates with QuickBooks Online to provide accounting and reconciliation functionality. Nielo may read applicable company preferences and accounting information and may create customer records, accounts and sub-accounts, service items, classes, and journal entries. Nielo may delete journal entries previously created by Nielo.
Nielo does not transmit patient-level PHI to QuickBooks Online and does not use QuickBooks Online to store patient records. Information processed independently by Intuit is subject to Intuit's applicable terms and privacy practices.
6. Billing Platforms and Other Customer-Authorized Integrations
Customers may authorize Nielo to connect with CollaborateMD or other supported billing platforms. Nielo receives only the information made available through those authorized connections and uses it to provide the requested services. Customers are responsible for ensuring they have authority to connect the applicable systems and provide the information to Nielo.
7. How We Disclose Information
7.1 Service Providers and Key Data Processors
Nielo uses third-party providers to operate the service and provide customer-authorized functionality. Our current material providers include:
| Provider | Purpose | Typical data / access | PHI |
|---|---|---|---|
| Amazon Web Services (AWS) | Cloud hosting, encrypted storage, infrastructure, and related services | Application data, stored files, logs, backups, infrastructure data | May process PHI where configured for the Nielo service |
| Cloudflare | DNS, network delivery, and security services | Network traffic, IP addresses, request metadata | May process limited traffic associated with PHI-bearing services depending on request path and configuration |
| Plaid | Authorized bank-account connectivity | Financial institution, account identifiers, transaction data, connection metadata | PHI is not intentionally provided to Plaid by Nielo |
| Intuit / QuickBooks Online | Accounting integration | Accounting data, company preferences, and Nielo-created accounting records | Nielo is designed to prevent patient-level PHI from being sent to QuickBooks |
| Stripe | Payment processing and hosted payment interfaces | Payment status, transaction and payment-method metadata; payment details entered on Stripe-hosted pages | Nielo minimizes PHI in payment processing and does not store full card or bank numbers |
| Google Workspace | Company email and business communications | Business communications and related metadata | PHI should be minimized in routine email and communications |
Nielo may update this list as providers are added, removed, or materially changed. If a service provider creates, receives, maintains, or transmits PHI on Nielo's behalf, Nielo requires appropriate contractual and security protections, including a BAA where required by HIPAA.
7.2 Customer-Authorized Disclosures
We disclose information to integrations, systems, and persons that the customer authorizes or directs us to use in providing the service.
7.3 Legal, Safety, and Security Disclosures
We may disclose information when reasonably necessary to comply with law or legal process; protect the rights, security, or integrity of Nielo, our customers, or others; investigate fraud, abuse, or security incidents; or enforce applicable agreements.
7.4 Business Transactions
Information may be transferred as part of a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, subject to applicable law and contractual obligations.
8. Sale and Advertising-Related Sharing of Personal Information
Nielo does not sell personal information.
Nielo does not share personal information with third parties for cross-context behavioral advertising or similar advertising purposes. Nielo does disclose information to service providers, integrations, customers, and other parties when necessary to provide the service or as otherwise described in this Privacy Policy. These operational disclosures are not sales of personal information by Nielo.
9. Data Separation and Access Controls
Nielo uses access controls intended to restrict customer information to authorized users associated with the appropriate customer organization.
Customer information must not be made available to another unrelated Nielo customer except where expressly authorized or legally required.
Access to sensitive information is restricted according to user identity, role, permissions, and legitimate business purpose. Access to patient-level information requires additional authentication controls within the service.
Customers are responsible for maintaining accurate authorized-user lists and protecting account credentials and authenticators.
10. Data Retention and Deletion
Nielo generally maintains active customer data for the life of the applicable customer account unless a different period is required by law, contract, a BAA, security requirements, or another documented obligation.
When an account or eligible customer data is approved for deletion, Nielo deletes that information from active systems according to its deletion procedures. Encrypted backup archives are subject to a limited retention lifecycle and may retain deleted information for up to 16 days before automatic expiration. Security and audit records may be retained longer where needed for compliance, security, or legal obligations.
Certain executed agreements and historical authorization records, including BAAs, ownership attestations, and payment authorizations, may be retained after account deletion where necessary to document the agreement or authorization that was in effect. Nielo does not use backup systems as an indefinite archive of otherwise deleted customer data.
10.1 Account Termination
When a customer terminates its relationship with Nielo, we may:
- terminate user access;
- terminate active sessions;
- disconnect or revoke applicable integrations;
- delete eligible information from active systems; and
- retain information that must remain available for an applicable legal, contractual, security, or operational reason.
If a backup is restored, applicable deletion or restriction requirements will be reapplied where reasonably feasible before the restored information is returned to ordinary use.
11. Security
Nielo maintains administrative, technical, and organizational safeguards designed to protect information against unauthorized access, acquisition, disclosure, alteration, or destruction.
Depending on the system and information involved, safeguards may include:
- multi-factor authentication;
- phishing-resistant WebAuthn/FIDO2 passkeys;
- role-based access controls;
- additional authentication before access to readable PHI;
- encryption in transit;
- encryption at rest;
- audit logging;
- access monitoring;
- vulnerability scanning and management;
- secure development practices;
- backup and recovery controls;
- tenant separation;
- restricted administrative access; and
- incident-response procedures.
No method of electronic transmission, storage, or security control can be guaranteed to be completely secure.
12. Cookies, First-Party Events, and Tracking
Nielo may use cookies and similar technologies necessary to authenticate users, maintain secure sessions, protect application security, remember necessary application settings, and operate or diagnose the service.
Nielo does not currently use third-party advertising pixels, cross-site behavioral tracking, third-party advertising analytics, or third-party tracking technologies for behavioral advertising. Nielo may record first-party events on its own website, including referral sources, campaign parameters, and which link led to a demo request.
If Nielo later introduces materially different analytics, advertising, or cross-site tracking practices, this Privacy Policy and any required consent mechanisms will be updated as appropriate.
13. Children
Nielo is a business service and is not directed to children. Healthcare customers may provide patient information concerning minors where they are legally permitted to do so. Such information is processed on behalf of the healthcare customer under the applicable agreement and BAA rather than collected from minors for consumer marketing purposes.
14. Privacy Rights and Requests
Depending on applicable law and the type of information involved, individuals may request information about personal information Nielo maintains about them, access to applicable personal information, correction of inaccurate information, deletion of eligible information, or information about how applicable personal information is used or disclosed.
Requests may be submitted to [email protected]. The request should contain enough information for Nielo to understand the request and identify the relevant account or relationship.
14.1 Verification
Before providing, correcting, or deleting personal information, Nielo may require reasonable verification of the requester's identity, email address or account, customer organization, and authority to act for another person or organization. Nielo will not disclose sensitive information solely because a request was submitted from an email address when additional verification is reasonably necessary.
14.2 Response Timing
Nielo will respond to verified privacy requests within the period required by applicable law. Where no specific legal response period applies, Nielo will seek to respond within 30 days after receiving a reasonably complete and verified request. If additional time is reasonably necessary, Nielo may inform the requester of the delay and expected response period.
14.3 Healthcare Provider Records
When Nielo processes patient or billing information solely on behalf of a healthcare provider, that healthcare provider generally controls the underlying patient record. Requests to access, amend, delete, restrict, or otherwise exercise rights concerning those healthcare records should ordinarily be directed to the applicable healthcare provider. Where required, Nielo will assist the healthcare provider according to applicable law and the BAA.
15. Security Incidents and Required Notices
Nielo maintains procedures for investigating suspected security and privacy incidents.
Where an incident affects customer information, Nielo will notify affected customers as required by applicable law, contract, or Business Associate Agreement.
Customers remain responsible for any notifications or actions assigned to them under applicable law and contract.
16. United States Operations and International Use
Nielo is operated from the United States. Information may be processed and stored in the United States by Nielo and its service providers, subject to applicable contractual and legal requirements.
Nielo is primarily intended for use by customers in the United States unless otherwise expressly agreed.
Customers must not use Nielo in jurisdictions where doing so would cause Nielo to violate applicable law or contractual restrictions.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our services, providers, legal obligations, or practices. We will update the effective date when a revised policy is published. Where required, we will provide additional notice of material changes.
18. Contact Us
Crux Ledger LLC, doing business as Nielo
Privacy and Security Contact: [email protected]
General Contact: [email protected]
Website: https://nielobooks.com