Privacy Policy

Effective Date: July 15, 2025

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 web-based platform and healthcare engagement hub (the “CAC Platform”), through certain mobile applications we offer that operate on the CAC Platform (our “Mobile Apps”), and through other services we provide including those that use the CAC Platform (”Other Services”). This Website, the CAC Platform, our Mobile Apps and Other Services, together with any related websites, SMS/MMS 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, or could be used to contact or locate, an individual user (“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.

We collect information for our use in providing the Services we provide, for the proper management and administration of our business, and to carry out our legal and contractual responsibilities.

This Privacy Policy applies only to our Services as described herein. It does not apply to any third-party website, third-party service or third-party software application linked to our Services, or any website, service or software application 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, including any white-labeled product or service, 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:

• Contact Information, including name, address, email address(es), IP address(es), phone number(s) and other contact information provided to us.
• Identification Documentation, including social security number, driver’s license and/or other government-issued identification documents or identifiers.
• Other Personal Information, including age, date of birth, gender, marital status, other family members, and emergency contacts.
• Health and Medical Information, including health insurance information, healthcare providers, medical conditions, medications, biometric data, health records, and other health-related information.
• Geolocation Information.
• Other Information you (or third parties you have authorized) may provide to us, or which we may collect from the provision of our Services, including any files, data, images, photos, videos, sounds, links, and other communications.

When providing Services to or for our customers, such as health plans, payer organizations, healthcare providers and delivery services, we may also collect from or share this information with our customers and authorized third parties 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. We refer you to our Cookie Policy for a more detailed discussion of our use of cookies. You may “opt-out” from our use of cookies at any time by clicking here or by contacting us at privacy@www-stg.86borders.com.

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, email address(es) and/or phone number(s) with your internal 86Borders account.

B. Our Use of PII

Our use of your PII is determined by the Services we are providing. Where applicable, we may use your PII to create your internal 86Borders account, to operate and/or provide the Services (including Services we may provide on behalf of our customers for your benefit), to communicate with you about Services you are using (including Services we may provide on behalf of our customers for your benefit), to allow you to utilize mobile apps or other software applications on the CAC Platform, 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 use, transmit or disclose your information, or when you authorize us to act on your behalf. 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.

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information. Unless you give us permission to do so, we will not share your PII other than as specified in this Privacy Policy.

Our website provides general information about the Services we provide and other information that may be of interest. We do not include or offer third-party products or services on our website, and we do not use any information we collect for third-party marketing or advertising purposes.

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 (e.g., Google Analytics). Those statistics do not include PII. We do not permit third-party tracking cookies for marketing or advertising purposes. You may review our Cookie Policy here.

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.

If you (or your authorized representative or designee) provide us with your phone number, you agree to receive text or SMS/MMS 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 contact you 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 through SMS messaging.

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.

D. Contractor and Other Third-Party Access to PII

We may disclose your PII to certain third parties in connection with the Services we provide. We may give certain contractors that we work with 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 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, or a bankruptcy or similar proceeding.

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 described in this Privacy Policy, we do not share PII with third parties.

E. Correcting Your PII

You can request or change any PII we store by notifying us at privacy@www-stg.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, healthcare 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.” When acting as a business associate, we are generally exempt from state consumer privacy laws.

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 a communication 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@www-stg.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 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@www-stg.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 customers, such as health plans, payer organizations, and health care providers, solely to provide Services to or on behalf of such customers.

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 informational or promotional emails or messages from 86Borders, including 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@www-stg.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 contractual 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.