This Privacy Policy describes how Borderless, Inc. and its affiliates and subsidiaries (“Borderless”, “we”, “us” and “our”) processes information about you in connection with our business.  It covers personal information that is provided to us via websites that link to this Privacy Policy (the “Websites”) and your use of our products and services (collectively, the “Services”). It also covers certain information (such as account data and usage data, as described below) that is provided to us via your use of our Software-as-a-Service (SaaS) offering.  This Privacy Policy also describes certain rights that you have with regard to our processing of your personal information. We provide the Services to authorized users pursuant to a customer license agreement between Borderless and the applicable customer.  

This Privacy Policy does not apply to data that authorized users upload or otherwise ingest into the Services or otherwise provide to us in connection with support or professional services (collectively, “Content”).  We process such Content pursuant to instructions provided by the customer (i.e., the customer is the “controller”, and we are the “processor”) and our processing is governed by the applicable customer agreement.  To the extent that your personal information is included as Content that is provided to us by a customer, you should refer to the applicable customer privacy statement regarding the customer’s processing of your personal information and your rights with respect to such processing.

Personal Information We Collect

Information you provide to us, such as:

• Website Use – We collect some or all of the following personal data about you when you use or otherwise interact with any of our websites, social media pages, mobile applications, online advertisements, or marketing or sales communications:

  • name

  • email address

  • phone number

  • country and region

  • other information you choose to provide to us when you contact us with your inquiries.

• Identity Verification – In addition to the Personal Data described under “Website Use,” we may collect the following Personal Data for identity verification for use of partner financial institution financial services:

  • country of citizenship

  • Social Security Number

  • tax ID number

  • video call footage to verify your identity,

  • copies of your government-issued identification,

  • proof of residency documentation (e.g., copies of utility bills), and

  • other information you choose to provide to us as part of identity verification.

• Job Applications – If you apply for a job with Borderless, in addition to the Personal Data described under “Website Use,” we may collect the following Personal Data about you:

  • mailing address

  • job history

  • resume/CV

  • information about your references

  • any other Personal Data you choose to submit along with your application including your LinkedIn profile or U.S. Equal Opportunity Employment Information.

• Marketing Activities – If you attend our events, business meetings, or visit our booth at industry conferences, in addition to the Personal Data described under “Website Use,” we may collect one or more of the following business contact information about you:

  • company

  • job title/role

  • other information that may be contained on your business card, if you choose to provide one

  • other information you choose to provide with us.

Information We Collect from Third Parties. When you use our services, we collect the following information from third parties:

• Referrals and Account Participant Invitations – We receive information about you, such as your name and email address, if a Borderless user refers you to our platform or invites you to participate on their account as an administrator, viewer, or spender.

• Integrations – We receive information about you via services you choose to integrate, such as where you link accounts from other service providers.

• Third Party Sign In – If you log in to our services using credentials from a third party (for example, Google), we will receive information that you have made public via your privacy settings with that third party.

Publicly Available Information. We collect information about you via the following publicly available resources when you use our services:

• ZoomInfo

• Social Medias

• Google search

• Blockchain

• Public digital address

Note that we may combine information received from third parties or publicly available resources with information we have collected directly from you. We will also combine information from an Individual’s profile with information submitted from surveys. 

Information We Collect. When you use our websites, with your consent, we use cookies and other tracking technologies to collect the following information about you:

• Browser and Device Information – Using cookies and other tracking technology, we collect:

  • unique device identification numbers

  • device type

  • operating system version

  • browser type

  • pages viewed

  • links clicked

  • IP address

  • date and time of visit

  • number of times you return to our website.

For information on how to manage your cookies preferences, please see our Global Privacy Notice or visit www.aboutcookies.org.

Third party sources. We may also obtain personal information about you from other sources, such as:

• Marketing and/or Business Partners, such as contact information from business partners with whom we operate co-branded events or other data providers, search results and links from third-party advertisers, and credit history information from credit bureaus.

• Integrated Services Providers, such as transaction information from our payment service provider.

• Resellers, Distributors, Joint Marketing/Co-Hosted Event Providers,  such as contact information and conference attendance information from events providers.  

• Social Media Platforms, such as search results and links, including paid listings (such as sponsored links).
  
  

Automatic data collection. We may automatically log information about you when you visit the Websites and/or when you use our Services.

When you visit our Websites, we may automatically collect device data such as the type of computer or mobile device that you are using or your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 5G), and general location information such as city, state or geographic area.

When you visit our Websites, we may also automatically collect online activity data  such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our Site, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.  

We use standard automated data collection tools such as cookies, web beacons, tracking pixels and the to collect data from our Websites and Service.  For more information on the use of cookies and other tracking technologies, including how to opt out of certain collection, please see our Cookie Policy.   We may share information about your computer or other device with our third-party service providers for information and network security, including fraud detection.

How We Use Personal Information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Site Operation and Services delivery. We use your personal information to:

• Provide, operate, audit and improve our Websites, our Service and our business;

• Communicate with you about our Websites and our Service, including by sending invoices, announcements, updates, security alerts, and support and administrative messages; 

• Provide customer service and support, and respond to your requests, questions and feedback; 

• Maintain your account(s); and

• Detect bugs, report errors and perform activities to maintain the quality or safety of our Websites and Services.
  
  

Research and Development.  To research, develop, create and implement new features and capabilities for our Websites and our Services. 

Marketing and Advertising/Customer Experience. We may use personal information for marketing and advertising purposes and to improve your customer experience, including to: 

• Better understand you and your preferences so that we may personalize your experience when using our Websites and/or Services;

• Conduct contests or other marketing campaigns and process awards or rewards;

• Link or combine it with other personal information we get from third parties, to further develop our understanding of you and your preferences and/or to prevent fraud

• Send you marketing communications about our Websites and our Service; and

• Evaluating the effectiveness of our marketing campaigns.
  
  

Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Service. We and our advertising partners may use cookies, clear gifs and similar technologies to collect information about your interaction (including the data described in the “Automatic data collection” section above) over time across the web, our communications with you and our Websites, and use that information to serve online ads. 

This Privacy Policy does not apply to, and we are not responsible for, cookies or clear gifs in third party ads, and we encourage you to check the privacy policies of advertisers and ad services providers and social media companies to learn about their use of cookies and other technology. You can learn more about your choices for limiting interest-based advertising in the “Online tracking opt out” section below. 

Compliance and protection. We may use personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• Audit our internal processes for compliance with legal and contractual requirements and internal policies;

• Enforce the terms and conditions that govern our Websites and Service; 

• Enhance security and to monitor and verify identity or service access; and

• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, malicious, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Personal Information

We may share your personal information with:

Service providers. Companies and individuals that provide services on our behalf or help us operate our Websites, our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).

Business partners.  Distributors, resellers, referral partners and similar third parties that are involved in the marketing, sales or delivery of our services.  From time to time, we may engage in joint sales or promotional activity with select business partners. If you purchase or specifically express an interest in a jointly offered product, promotion or service, we may share your personal information with the relevant partner. With your consent, these business partners may also send you marketing communications about their own products and services.

Partner Financial Institutions. If you are using on of our partner financial institutions, exchanges or other service providers, will may share our personal information as part of their Know Your Customer (KYC) and Customer Identification Program (CIP) onboarding process.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Other business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Company or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Borderless Affiliates.  If your personal information is shared with our affiliates, the processing of the personal information will remain subject to this privacy statement.

As you instruct us.  We may also share your personal information where you instruct us to do so or where you have provided consent (for example, when you agree to share your information with third parties for their own marketing purposes, subject to their data protection policies).  

Your Choices

Opt out of marketing communications. You may opt out of marketing-related communications by following instructions contained in the marketing communications we send you. If you opt out, we may still send you emails that are not marketing related, such as emails about your accounts or our ongoing business relations. 

Online tracking opt-out.  For a description of how you may opt-out of online tracking (e.g., cookies), see our Cookie Policy . 

Processing Personal Information in the US

We have personnel and use service providers located in the United States. To provide our Service and operate our Websites, it is necessary for us to process personal information in the United States.

Other Websites and Service

Our Websites and Services may contain links to Websites and other online services operated by third parties, including social media Websites such as Facebook. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control Websites or online services operated by third parties, and we are not responsible for their actions. Your use of the third-party Websites, applications and any information you authorize us to send to the third-party will be subject solely to the third-party’s terms and conditions and privacy notice, and will not be subject to any agreements you have with us or this Privacy Policy.

Data Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

The Service are not intended for use by children under 18 years of age. If we learn that we have collected personal information through our Service from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website. 

How to Contact Us

You can reach us by email at Legal@borderless.xyz or at the following mailing address:

Notice to European Residents

Controller. Borderless is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal basis for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.