PRIVACY POLICY
Most Recent Update: January 1, 2021
We collect certain information through our website, located
at www.86Borders.com (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 of
our 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.