Privacy Policy

Effective Date: June 11, 2024

86Borders LLC (together with its affiliates, “86Borders,” “we,” or “us”) values the privacy of our customers and other users of our services. This Privacy Policy applies to personal information that we collect in the normal course of our business.

We collect certain information and data through our website, located at www.86Borders.com (our “Website”), through our ConnectAllCare communications platform (the “CAC Platform”), through certain mobile applications we offer that operate on the CAC Platform (our “Mobile Apps”), and through other services we provide that use the CAC Platform (”Other Services”). This Website, the CAC Platform, our Mobile Apps and Other Services, together with any related websites, SMS services, 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, handling and use 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 as described herein. It does not apply to any third-party site, third-party service or third-party software application linked to our Services, 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 or use our Services may permit or require the user to provide Personally Identifiable Information, 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. We also provide services to health plans, payer organizations, health care providers and delivery services that may provide us with PII or PHI in order for us to provide services on their behalf. 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 of our Services: name, username, password, address, phone number, e-mail address, IP address, age, date of birth, gender, marital status, government-issued identification number(s), credit card number(s), and similar identifiers. We also may collect any files, data, images, photos, videos, sounds, links, works of authorship, health or medical information, health insurance information, geolocation information, biometrics data, 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. When providing services to or for our customers, such as health plans, payer organizations, health care providers and delivery services, we may also collect from or share this information with our customers solely for the purpose of providing our Services. We may also obtain certain information (e.g., current address information) from other publicly available sources to update and correct our records.

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 or device and then uses to identify your computer or device when you return to our Website, the CAC 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 when using the Services.

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 and/or provide the Services (including Services we provide to you on behalf of our customers), to communicate with you about Services you are using or that we are providing on behalf of our customers, to allow you to utilize software applications and other products and services on the CAC Platform, to offer you additional products and services, to bill you (if applicable), and for other lawful, legitimate business purposes. In providing our Services, we may share or disclose your information at your direction, such as when you authorize us or 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 perform our Services, 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 your device and to improve the functionality of our Services. We may also use information gained through cookies to compile statistical information about use of our Services. Those statistics do not include PII.

When you use our Services, we may collect and process 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 (or your authorized representative or designee) provide for your 86Borders account across all 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 (or your authorized representative or designee) provide us with your phone number, you agree to receive text or SMS messages to that number from us and from third parties you have approved.  We may use your contact information to provide Services, to send you information about our Services, 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 or through SMS messaging.

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.

We may use “pixel tags” (sometimes called “Internet tags,” “web beacons,” or “clear GIFS”), which are tiny graphic images, in our Services. Pixel tags help us analyze our customers’ online behavior and measure the effectiveness of the Services. We work with service providers that help us track, collect, and analyze this information. Pixel tags in our Services may be used to collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Services. This information may include your device’s IP address, your browser type, your operating system, date and time information, and other technical information about your device. We may also track certain information about the identity of the website you visited immediately before coming to our Services. We do not otherwise track any information about your use of other websites. Pixel tags and cookies in our emails may be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us. We may combine the information we collect through cookies and pixel tags with other information we have collected from you. This information may be used to improve our Services, to personalize your online experience, to help us deliver information to you, and for other internal business purposes.

C. Protection of Personal Information

We store your information (including PII and PHI) 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 our Services, nor can we guarantee the security of personal information transmitted to us. By using our Services, you acknowledge and agree that we make no such guarantee, and that you use our Services at your own risk. We are not liable for the illegal acts of third parties such as criminal hackers.

It is your responsibility to safeguard the devices you use to access our Services (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal information using those devices. You should affirmatively log out of your account (i) prior to ending your session, or (ii) if you will be inactive on the Services for more than a few minutes; otherwise, the next user of that computer or device, particularly a public one or one not owned by you, may be able to access your account and the personal information in your account if your session has not ended.

You agree that we are not responsible for any harm that may result from someone accessing your account or personal information on any computer or device where you do not, for any reason, take the necessary steps to log out of your account prior to ending a session on such device or computer.

D. Contractor and Other Third-Party Access to PII

We may give certain independent contractors access to your PII. Those contractors assist us with various Services, including operation of the CAC Platform and Mobile Apps. 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 or similar proceeding.

As noted above, we compile Website and Platform usage statistics from data collected through cookies and pixels. 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 PII we store through your “My Account” page or by notifying us at privacy@86borders.com.

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, payer organization, health care provider, or other “covered entity,” 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, payer organization, health care provider, or other “covered entity.”

G. “Spoofing” and “Phishing”

“Spoofing” or “Phishing” are common Internet scams. These may occur when you receive an email from what appears to be a legitimate source requesting personal information from you. Please be aware that 86Borders will NEVER send you an email or text or SMS message requesting you to verify credit card or bank information or any other Personally Identifiable Information. If you ever receive an email that appears to be from us requesting such information from you, DO NOT respond to it, and DO NOT click on any links appearing in the email. Instead, please forward the email to us at privacy@86borders.com as we endeavor to investigate all instances of possible Internet fraud.

H. 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.

I. Children Under 13

We will not intentionally collect any personal information (as that term is defined in the Children’s Online Privacy Protection Act) from children under the age of 13 through our Online Services without receiving parental consent. If you think that we have collected such personal information from a child under the age of 13 through our Services, please contact us at privacy@86borders.com immediately.

We may receive, transmit, disclose, store or use certain personal information relating to children under the age of 13 received from our clients, such as health plans, payer organizations, and health care providers, solely to provide Services to or on behalf of such clients.

J. Email List/Removal From Lists

If offered and available, you may sign up on the Website or through text or SMS messaging to receive promotional emails or messages from 86Borders, including other informational content such as White Papers or other educational materials. To sign up we may ask for information such as your name, email address, mailing address, phone number, gender, age, and other preferences. Subscriptions to email and messaging lists can be cancelled at any time.

To be removed from our email or messaging lists, please email us at privacy@86borders.com. You may also click the unsubscribe or manage preferences buttons found at the bottom of the emails or messages in order to be removed from emails or messages that we send you. Please allow us up to ten (10) business days from when the request was received to complete the removal.

K. How Long We Retain Your Personal Information

We will retain your personal information (including PII and PHI) for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information (including PII and PHI) to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, requirements or agreements), resolve disputes, and enforce our legal agreements and policies.

L. 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.