Most Recent Update: January 1, 2021

We collect certain information through our website, located at (our “Website”), through our related communications platform (our “Platform”), and through certain mobile applications we offer that operate on our Platform (our “Mobile Apps”). This Website, our Platform and our Mobile Apps, together with any related websites, SMS, APIs, email notifications, applications, dashboards, embeds, etc., are referred to as “Services.” This page (this “Privacy Policy”) lays out our policies and procedures surrounding the collection and handling of any such information that identifies an individual user or that could be used to contact or locate him or her (“Personally Identifiable Information” or “PII”). When using any of our Services, you consent to the collection, transfer, storage, disclosure and use of your information as described in this Privacy Policy.

This Privacy Policy applies only to our Services. It does not apply to any third-party site, third-party service or third-party software application linked to our Website or operating on our Platform, or recommended or referred by or through our Services, or by our staff. And it does not apply to any other website, product, or service operated by 86Borders, or to any of our offline activities.

Certain third-party software applications and services that operate on our Platform may permit or require the user to provide PII, protected health information (“PHI”) and other information, and we may maintain data or information for the providers of such applications or services in electronic form as a part of our Services for such providers. You should refer to the applicable privacy policies of the providers of such applications and services for information regarding their collection, use, disclosure and management of such PII, PHI and other information.

By using the Services, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Services. Your continued use of the Services following the posting of changes to these terms will mean that you accept those changes.

A. Information We Collect

We may collect the following Personally Identifiable Information from users who buy or use our Services, including users of products or services that utilize our Platform (whether provided by us or a third party): name, username, password, e-mail address, telephone number, address, and credit card number. We also may collect any files, data, images, photos, videos, sounds, links, works of authorship, health or medical information or any other materials containing PII or PHI that you, or third parties with your authorization, provide to, post to, or share via the Services.

We use “cookies” to collect certain information from all users of our Services. A cookie is a string of data our system sends to your computer and then uses to identify your computer when you return to our Website, our Platform or a Mobile App. Cookies give us usage data, like how often you visit, where you go at the site, and what you do on the site or using the Platform or a Mobile App.

In providing our Services, we also maintain web server logs and IP addresses. An Internet Protocol (“IP”) address is a number that automatically identifies the computer or device you have used to access the Internet. The IP address enables our server to send you the web pages, applications or services that you want to visit or use, and it may disclose the server owned by your Internet Service Provider. We may use IP addresses to conduct analyses and performance reviews and to administer the Services.

We may collect device specific information (such as your hardware model, operating system version, browser type, unique device identifiers, and mobile network information including phone number). We may also associate your device identifiers or phone number with your 86Borders account.

B. Our Use of PII

We use your PII to create your 86Borders account, to operate the Services, to communicate with you about Services you are using, to allow you to utilize software applications and other products and services on the Platform, to offer you additional products and services, and to bill you. In providing our Services, we may share or disclose your information at your direction, such as when you authorize a third-party web client or application to access your account or use, transmit or disclose your information. We also use that information to the extent necessary to enforce our terms of service and to prevent imminent harm to persons or property. But we will not sell, rent, license, or trade your PII with third parties for their own direct marketing use unless we receive your express consent to do so. Unless you give us permission to do so, we will not share your PII other than as specified in this Privacy Policy.

We use cookies so that our Services can remember you and provide you with the information you’re most likely to need. For instance, when you return to our Website or an application using our Platform, cookies identify you and prompt the site to provide your username (not your password), so you can sign in more quickly. We may also use information gained through cookies to compile statistical information about use of our Services. Those statistics do not include PII.

Our Services include location-based services and when you use our Services, we may collect, process and share information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers.

We may use the account information you provide for your 86Borders account across all of the services we offer that require an 86Borders account. In addition, we may replace past names associated with your 86Borders account so that you are represented consistently across all our services. If you provide us with your phone number, you agree to receive text messages and notifications to that number from us and from third parties you have approved.  We may use your contact information to send you information about our Services, to market to you, to help prevent spam, fraud or abuse, and to help others find your account including through third-party services and client applications. You may use your settings for email and mobile notifications to control notifications you receive from us. You may also unsubscribe from a notification by following the instructions contained within the notification or instructions on our Website.

We may share or disclose your publicly visible 86Borders profile information, such as your name and photo, to people within public groups or your private groups. Your privacy and visibility settings will control whether your profile information is made public. If other users already have your email, phone number or other information that identifies you, we may show them your publicly visible 86Borders profile information.

C. Protection of PII

We store PII and other information using industry standard physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. Unfortunately, even with these measures, we cannot guarantee the security of PII. By using our Services, you acknowledge and agree that we make no such guarantee, and that you use our Services at your own risk.

D. Contractor and Other Third-Party Access to PII

We may give certain independent contractors access to Personally Identifiable Information. Those contractors assist us with various Services, including operation of our Platform. All those contractors are required to sign contracts in which they promise to protect PII using procedures reasonably similar to ours. We also may disclose PII to attorneys, collection agencies, or law enforcement authorities to address potential AUP violations, other contract violations, or illegal behavior. And we may disclose any information demanded in a court order or otherwise required by law or to prevent imminent harm to persons or property. Finally, we may share or transfer your PII in connection with a corporate transaction, like a merger or sale of our company, or a sale of all or substantially all ofour assets or of the product or service line you received from us, or a bankruptcy.

As noted above, we compile Website and Platform usage statistics from data collected through cookies. We may publish those statistics or share them with third parties, but they don’t include PII.

Except as set forth in this Privacy Policy, we do not share PII with third parties.

E. Accessing and Correcting Your PII

You can access and change any Personally Identifiable Information we store through your “My Account” page.

F. Protected Health Information and HIPAA Compliance

Certain information shared with us through the Services may be protected health information (“PHI”) subject to the privacy and security safeguards of the Health Insurance Portability and Accountability Act and its regulations (“HIPAA”). Where 86Borders is subject to HIPAA privacy and security requirements in its capacity as a “business associate” acting on behalf of a health plan or health care provider, 86Borders’ use and disclosure of your PHI will be governed by HIPAA requirements, as described in the HIPAA Notice of Privacy Practices available from your health plan or health care provider.

G. Law and Harm

Notwithstanding anything to the contrary in this Privacy Policy, we may retain or disclose your information if we believe it is reasonably necessary to comply with a law, regulation, legal process or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

H. Amendment of This Privacy Policy

We may change this Privacy Policy at any time by posting a new version on this page or on a successor page. The new version will become effective on the date it is posted, which will be listed at the top of the page as the new Effective Date.