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Privacy Policy

Last updated: April 16, 2026 · Effective: April 16, 2026

This Privacy Policy describes how Borderly Tech LLC, a Florida limited liability company ("Borderly," "we," "us," or "our") collects, uses, stores, and shares your information when you use the Borderly iOS application, web dashboard at borderly.day, and API (collectively, the "Service"). This Privacy Policy is incorporated into and subject to our Terms of Service.

By using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, do not use the Service.

1. Definitions

Terms defined in our Terms of Service (Section 1) have the same meaning in this Privacy Policy. Additionally:

  • "Personal Information" — Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
  • "Sensitive Personal Information" — Categories of personal information that require heightened protection under applicable law, including precise geolocation data.
  • "De-identified Data" — Data that cannot reasonably be used to identify, relate to, describe, or be associated with any individual. Once data is de-identified, it is no longer Personal Information.

2. Information We Collect

2.1 Account and Identity Data. When you create an account, we collect: email address, display name (optional), password (stored as an argon2 hash — never in plaintext), and Apple User ID (if you use Apple Sign-In). If you enable call verification, we collect your phone number. We also record your account role, subscription tier, and how you found the Service (signup source and referral context).

2.2 Professional Metadata. If you create a Professional account, you may provide: license number, firm name, bar state, and specialization. This information is self-reported and not verified by Borderly (see Terms of Service Section 3.4).

2.3 Location Data. When you grant location permissions, the Service collects precise GPS data from your device, including: latitude and longitude coordinates, horizontal and vertical accuracy, timezone (IANA format), local date, and location source type (automatic, manual, imported, or other). Location data is collected via the iOS CoreLocation framework at approximately 100-meter accuracy. Background location updates may occur when you have enabled this in your device settings. Location data is classified as Sensitive Personal Information under the CCPA. We use your location data solely for creating Presence Records to provide the Service — not for advertising, profiling, or any other purpose.

2.4 Evidence and Documents. When you upload evidence, we collect: the file itself (photos, receipts, documents, and other files across 13 evidence types), file metadata (size, MIME type, capture timestamp), photo geotag data (latitude, longitude, and accuracy from EXIF metadata, if present), extracted text (from OCR processing of receipts and documents, where applicable), and a SHA-256 cryptographic hash of each file for integrity verification.

2.5 Call Verification Data. If you enable call verification, we collect: your phone number, call schedule configuration (timezone, call window start and end times), your TCPA consent timestamp, and call logs (date, time, duration, status, attempt number, telephony provider call identifier, TTS message content, and telephony provider webhook data). This data is collected only when you explicitly enable the feature and provide consent.

2.6 Device and Session Data. We collect: User-Agent string, device type (app or web), and session tokens. We do not use analytics SDKs, tracking pixels, advertising identifiers, or device fingerprinting technologies.

2.7 Billing Data. We store: Stripe customer ID, Stripe subscription ID, Stripe price ID, Apple transaction IDs, billing cycle dates, and subscription status. We do not store payment card numbers, CVVs, expiration dates, or bank account details — these are handled entirely by our payment processors.

2.8 Tax Planning Data. We collect data you enter about: jurisdiction selections and tracking priorities, residency goals (type, thresholds, time periods), domicile history (effective dates, end dates, reasons, notes), and planning scenarios with planned future days.

2.9 Access and Audit Data. We collect: IP addresses (stored in sanitized form), audit log entries recording who accessed data and what actions were taken (for delegated access scenarios), and share permission configurations (access levels, jurisdiction scope, expiration dates).

2.10 Cryptographic Data. The Service generates and stores: SHA-256 hashes of Presence Records, hash chain links (connecting each record to the previous one), device signatures (ECDSA from iOS), RFC 3161 timestamp tokens (from third-party Timestamping Authorities), and blockchain anchor data (Merkle roots and transaction hashes, where applicable). These are used solely for data integrity and tamper-evidence purposes.

2.11 Firm and Organization Data. For firms, we collect: firm name, website, phone number, mailing address, brand color, and logo. For firm creation requests, we collect supporting documents uploaded during the application process.

2.12 Marketing and Communications Data. If you create an account or subscribe to a waitlist, newsletter, or other marketing communication, we collect: your email address, the topics or interests you subscribe to, your IP address (for abuse prevention), your browser User-Agent string, and a confirmation status. We also generate and store a unique unsubscribe token associated with your subscription to enable one-click unsubscribe functionality.

3. How We Collect Information

3.1 Directly from You. We collect information you provide during: account registration, manual data entry (presence records, goals, domicile changes), evidence uploads, phone number submission and call schedule configuration, profile completion, and firm creation applications.

3.2 Automatically from Your Device. We automatically collect: GPS coordinates via CoreLocation (only when you have granted location permissions), device type and User-Agent string from your browser or app, and EXIF metadata from photos you upload (including geotag data).

3.3 From Third-Party Services. We receive information from: Apple (authentication identity during Sign-In), Stripe (subscription status and payment event notifications via webhooks), Twilio (call status, duration, and delivery information via webhooks), and DigiCert (RFC 3161 timestamp responses — DigiCert receives only SHA-256 hashes, never your raw data or personal identifiers).

3.4 What We Do Not Collect. We do not use analytics SDKs or tracking pixels. We do not purchase data from data brokers. We do not collect data from social media profiles. We do not use advertising networks or behavioral profiling tools. We do not use cookie-based tracking beyond our single authentication session cookie. Error tracking is limited to server-side console logging and does not transmit data to third-party error tracking services.

4. How We Use Your Information

We use your Personal Information for the following purposes:

  • Providing the Service — Creating Presence Records, generating reports, facilitating data sharing with authorized Professionals and Verifiers, enabling planning scenarios, managing subscriptions, and delivering the core functionality of the Service
  • Authentication and Security — Verifying your identity, managing sessions, preventing unauthorized access, and detecting circumvention and abuse
  • Data Integrity — Creating cryptographic hash chains, obtaining RFC 3161 timestamps, generating device signatures, and anchoring data to blockchain (where applicable)
  • Call Verification — Placing automated calls to your verified phone number at your configured schedule and creating call-based evidence records
  • Billing — Processing payments through our payment processors, managing subscriptions, and enforcing tier limits
  • Communications — Sending transactional emails (password resets, account notifications), push notifications (when you enable them), and marketing and promotional emails (when you create an account or subscribe to a mailing list). You may unsubscribe from marketing emails at any time via the link in each email or through the email preferences page
  • Legal Compliance — Responding to legal process, enforcing our Terms of Service, and complying with applicable law
  • De-identified Analytics — We may use de-identified, aggregate data to improve the Service, as described in our Terms of Service Section 15.4

We do not use your Personal Information for advertising, behavioral profiling, or selling to third parties.

5. How We Share Your Information

5.1 At Your Direction. When you create Share Permissions or Verification Tokens, authorized Professionals and Verifiers can access your data within the scope you define. You control the scope, duration, and revocation of all access grants.

5.2 Service Providers. We share information with third-party service providers who process data on our behalf:

  • Cloud infrastructure provider — All data necessary to operate the Service (infrastructure provider may change without notice)
  • Cloud object storage (S3-compatible) — Evidence files, generated report PDFs, and RFC 3161 timestamp tokens
  • Stripe — Customer ID, subscription data, and payment amounts for billing purposes. Stripe does not receive your location data, evidence, or presence records.
  • Twilio — Phone number and call data for call verification. Twilio does not receive your location data or evidence.
  • DigiCert — SHA-256 hashes only, for RFC 3161 timestamping. DigiCert never receives raw data, location information, or personal identifiers.
  • Apple — Authentication tokens (for Sign-In with Apple), push notification tokens, and in-app purchase transaction data
  • Email provider — Email address for transactional messages (password resets, notifications) and marketing communications (waitlist confirmations, product announcements) when you create an account or subscribe

5.3 Professional and Firm Access. When you grant a Professional or Firm access to your data, they may view data within the scope you authorize. Borderly does not control how Professionals use data they access (see Terms of Service Section 10).

5.4 Legal Requirements. We may disclose information if required by law, legal process, court order, or government request, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Borderly, our users, or the public.

5.5 Business Transfers. In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity (see Terms of Service Section 28.4).

5.6 De-identified and Aggregate Data. We may share de-identified or aggregate data that cannot reasonably identify you, as described in our Terms of Service Section 15.4.

5.7 No Sale of Personal Information. We do not sell your Personal Information. We do not share Personal Information with third parties for cross-context behavioral advertising.

6. Cookies and Tracking Technologies

6.1 Authentication Cookie. We use a single httpOnly authentication cookie (auth_token) to maintain your login session. This is a strictly necessary cookie required for the Service to function. It cannot be declined while using the Service.

6.2 No Tracking Technologies. We do not use analytics cookies, tracking pixels, web beacons, advertising cookies, device fingerprinting, or any third-party tracking scripts. We do not respond to "Do Not Track" browser signals because we do not engage in the tracking activity that such signals are designed to prevent.

7. Data Retention

7.1 General Retention. Data retention periods vary by Subscription Tier, as described in our Terms of Service Section 9. We retain your data for as long as your account is active and for the retention period associated with your tier. We reserve the right to modify retention periods at any time (see Terms of Service Section 9.1).

7.2 Account Deletion. When you delete your account, all Personal Information is permanently deleted, including Presence Records, evidence files, reports, goals, scenarios, domicile records, share permissions, and verification tokens. This process is irreversible.

7.3 Evidence Deletion. Deleted evidence enters a soft-delete period during which it may be recoverable. After the soft-delete period expires, evidence is permanently deleted from cloud storage.

7.4 Audit Logs. Audit log entries are retained for the period associated with your subscription tier and are deleted when your account is deleted.

7.5 Billing Records. Billing records (Stripe customer ID, subscription history) may be retained as required for accounting, tax compliance, and dispute resolution purposes, even after account deletion.

7.6 Backups. We do not guarantee data recovery. You are responsible for maintaining your own backups of your data (see Terms of Service Section 9.6).

8. Data Security

8.1 Security Measures. We implement technical and organizational measures to protect your data, including: encryption of data in transit, access controls and authentication, session management, and audit logging. Sensitive tokens (verification tokens, password reset tokens) are stored as hashes, not in plaintext.

8.2 No Absolute Guarantee. No method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your data (see Terms of Service Section 16.3).

8.3 Your Responsibilities. You are responsible for: maintaining the confidentiality of your account credentials, distributing Verification Tokens through secure channels, properly configuring device permissions, and reporting any suspected unauthorized access to your account.

9. Children's Privacy

The Service is not directed at children. You must be at least 18 years old or the age of majority in your jurisdiction, whichever is greater, to create an account (see Terms of Service Section 3.1). We do not knowingly collect Personal Information from children under 16. If we become aware that we have collected Personal Information from a child under 16, we will delete it promptly. If you believe a child has provided information to us, contact us at legal@borderly.day.

10. Your Privacy Rights

10.1 All Users. Regardless of your location, you can:

  • Access and export your data through the Service's settings
  • Correct inaccurate data through the Service
  • Delete your account and all associated data
  • Revoke Share Permissions and Verification Tokens at any time
  • Disable location tracking through your device settings
  • Disable call verification at any time by removing your phone number or disabling your call schedule

11. International Data Transfers

Your data is processed and stored on servers that may be located in the United States or other countries. If you are located outside the United States, your data will be transferred to and processed in the United States. By using the Service, you consent to this transfer.

The Service may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party service you interact with. See our Terms of Service Section 18 for more information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page with a revised "Last Updated" date. We may, but are not obligated to, notify you of changes via email or in-app notification. Your continued use of the Service after changes are posted constitutes acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

Email: legal@borderly.day

15. Governing Law

This Privacy Policy is governed by the laws of the State of Florida, United States, without regard to conflict of law provisions. See our Terms of Service Section 26 for additional details.

This Privacy Policy was last updated on April 7, 2026.