Effective Date: July 16, 2018
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.
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
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.
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