PRIVACY POLICY

Last Updated: October 22, 2024

This Borderfree.com privacy policy (the “Privacy Policy”) governs your activity when using Borderfree.com Services, provided by Global-e group (collectively “Borderfree“, “we“, “us” or “our“).

This Privacy Policy details the personal identifiable information (“Personal Information”) we collect about you, the means through which we collect that information, with whom we share it, how we secure that information, and how you can change your preferences regarding how we use Personal Information you provide to us when using borderfree.com website and additional services (collectively, “Borderfree Websites”).  This Privacy Policy applies only to our Borderfree Websites. We do not control the privacy practices or the content of any of our business partners, advertisers, sponsors, or other third parties we link to from our Borderfree Websites.

To the maximum extent permitted by law, by using the Borderfree Websites, you are consenting to the collection, use, disclosure, storage and processing of Personal Information (as defined below) as described in this Privacy Policy. “Store Owner” means the merchant and e-commerce website from which you purchase.

You are not legally required to provide us with any Personal Information, but without it we will not be able to provide you with the full range of services or with the best user experience when using our services.

Summary of Policy/Notice at Collection

For your convenience, we include below a summary of this Privacy Policy. This will give you an overview of our practices. Please take the time to read our full Privacy Policy for detailed information on each section.

Categories of Personal Information we collect. The Personal Information we collect depends on your use of our services. If you are subscribed to Borderfree.com newsletter, we need your Personal Information such as your full name, email address and phone number. If you created user account with Borderfree.com, we will collect the product or services purchased, IP address, billing details, delivery address, and if you choose to, we will also collect your payment details (e.g. credit card number) in order to enable the feature of Express Checkout when applicable. If you contact our customer support, we may need any other relevant Personal Information for solving your the inquiry in full.‍

Why we collect your Personal Information and for what purposes. We collect your Personal Information only when we need to in order to provide you with our services and/or following your consent.

How we use your Personal Information. We use your Personal Information for various reasons related to our services, including to offer and share with you products and promotions relevant to you. We also use your data for other related legitimate interests (including to improve the services and our products, supporting Store Owner, testing new features and protecting our Services from any misuse and legal violations). We may, subject to obtaining your consent or otherwise subject to taking all required legal measures, use your information for communicating specific offers, promotions or market activities related to our Services. If you have agreed to such communication, you will be able to unsubscribe from them at any time.

Sharing your Personal Information. We will share your Personal Information with third parties for fulfilling the Services requested by you, including other entities of the Global-e group and the Store Owner operating the site where you placed your order. If you provided your specific consent and instructed us to do so, we would provide the Store Owner with your Personal Information for the Store Owner own marketing purpose.

We will also share your Personal Information with third party service providers including those who provide us analytic tools, as detailed in our Cookie Policy, provided that any such third party will commit to protect your privacy as required under applicable law and this Privacy Policy.

Data Retention. Your Personal Information will be stored until we no longer need it to provide our services, and therefore, delete our records, or if you send a valid deletion request.

Sale of Personal Information. You may request that we do not ‘sell’ or ‘share’ your Personal Information, as such terms are defined broadly by applicable privacy laws, even though we don’t technically sell your information in the traditional sense. However, we may share certain categories of Personal Information with third parties, and you have the option to opt out of this if you wish.

1. WHAT TYPES OF PERSONAL INFORMATION DOES BORDERFREE COLLECT AND FOR WHAT PURPOSES?

The type of Personal Information we collect from you depends on your interaction with Borderfree Website. We collect Personal Information to provide you with our Services or to answer any of your questions. We collect Personal Information is different ways, as you can see below:  

1.1. Personal Information collected directly from you

• When you create a Borderfree member account, and sign-in, we collect the following Personal Information: Contact information, including name, street address, email address, telephone number, username, password, information about your website usage, and any other information you choose to provide us with. We use this data to provide you with the Services, including unique features saved for registered members. For example, to allow you to manage your account, to offer products shipped to your locations, and to prepopulate your details when using Global-e’s checkout. We use your information in order to provide you with our services, including sending relevant offers and promotions. We will collect your orders from us, and you will be able to view, and track them in your account. We will use this information to share offers and new products that fit your taste and style. If you would like, you can share with us more information on your general preferences and the categories of products you are interested in. Marketing communications are sent with your consent (where required by applicable law).
• When you subscribe to Borderfree.com newsletter, we collect your full name, email address, location and gender. This information is used for sending your marketing communications that are relevant to you, and you will benefit from. You can subscribe from the newsletter any time from the email directly, or from your account, if you are registered member.
• When asking for support or submitting inquiries. If you reach out to our customer services and support via the website or through email, we will need to collect Personal Information for communicating with you. We will ask for name and email address, and other necessary information such as order number, identification number, or any other relevant information you agree and choose to provide us, to solve your inquiry as quickly as possible. The information shared will help us to track our level of services to you, and to improve our services to you and our general customers in the future.
• When you participate in any Borderfree questionnaires and contests, we collect your contact information, including name, location and email address, and other information which may be relevant for the specific questionnaire and contest you choose to participate in. This can include, for example, your age, for making sure you can legally participate in sweepstakes, or other information about your experience with Borderfree website. We will use this information to enter into a contract with you, and to assess your experience with Borderfree website, which is necessary for improving our services and keeping them up to date.

1.2.Personal Information We Collect in Other Ways. 

• Global-e Group. The Borderfree services and website are operated and provided to you by the Global-e group of companies. When you complete purchases through the Borderfree website, you are shopping directly from the Store Owners, with Global-e acting as the cross-border merchant of record for the transaction. In certain cases, we may need to collect Personal Information provided by you to Global-e during the checkout, in order to provide you with the services. For example, to allow you to track orders receive cashbacks or to use specific coupons. If you completed a purchase, and use Borderfree services, please also review Global-e- Privacy Policy
• When you interact with our Websites, we will collect certain information through Cookies and log files. This includes web browser and device information, and information on your website usage, including, without limitation, to your IP address, location data, the time and length of your visit, your language preferences, products and any other Personal Information you choose to provide us with as for example, your preferences, “pins”, “likes” and “dislikes”. Another example would include confirmations that we receive when you open an email from us or our partners (if your computer or other device supports supports). You can read more about it in our Cookies Policy.

For residents of the EU and UK, we use this data for our legitimate interests of making sure the Borderfree Websites works properly, including debugging, to be able to deliver you content, and improving our Borderfree Websites, and to perform statistical analyses for optimizing our Borderfree Websites. The used for such purposes is used in aggregated manner. For more information, please visit our Cookies Policy, and read below.

2.HOW DOES BORDERFREE USE AGGREGATED CONTENT?

We use aggregated statistical data, inferred non-Personal Information or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services. By way of example, and not limitation, we analyze transaction data for the purpose of identifying trends, statistics and measurements that could contribute to the enhancement of Borderfree services. Such use could include identifying market sensitivities, and relative market interest in specific product categories.

By “aggregated/blinded” information we mean, information from multiple users that does not contain Personal Information. We may also send you satisfaction questionnaires or other surveys and send you marketing information. Another example would be if you place an order with us through one of our merchant suppliers, we (our merchant supplier or other entity on our behalf) may contact you if there is an issue with the order. 

3.HOW DOES BORDERFREE SHARE PERSONAL INFORMATION?

We may share your Personal Information:

• With the Store Owner and Merchant Partner. Borderfree Services includes display with selection of brands, including information on such brands current sales and promotions exclusively saved to Bordeerfee members. If you have Borderfree account, Borderfree offers you to express checkout by redirecting you to the Store Owner checkout and prepopulate your transaction details. In order to provide such services, we may share you details with the Store Owners you shop with for allowing the fulfillment of your order. In such circumstances, it will be very clear to you that a third party is involved in your experience.
• Between the entities of our group. Borderfree website and services are operated and provided to you by Global-e Online Ltd., which includes group of affiliated companies. For the purposes explained in this Privacy Policy, we may transfer your Personal Information to Global-e group companies (including service providers operating on their behalf) and other third parties in countries which do not have the same level of data protection laws as those in the country where you are located.
• With Service Providers.Borderfree may provide Personal Information to certain service providers relevant to our services. Borderfree will always limit the Personal Information to be what is reasonably necessary for those service providers to carry out their responsibilities as they relate to the services. Our service providers are required to keep the Personal Information they received from us confidential and secure and they may not use it for any purpose other than the purpose for which Borderfree provided it.
• For Business Transitions.In the event Borderfree goes through a business transition, such as a proposed or actual merger with or acquisition by another company, sale of all or a portion of our assets or brands, reorganization, bankruptcy, or other similar events.
• With Your Consent.We may of course share your Personal Information in other ways that you specifically consent to, and to subscribe you to any Borderfree and/or third-party marketing messages you opt-in to receive.  Where you consent to share your Personal Information with a third party, that third party’s Privacy Policy may apply to how they use and share Personal Information.
• For Other Disclosures.We may disclose Personal Information to law enforcement, government officials, or other third parties if: (i) we are compelled to do so by subpoena, court order, judicial proceeding or other legal process, (ii) we must do so to comply with laws, statutes, rules or regulations, including credit card rules, or (iii) we believe in good faith that the disclosure is necessary to prevent physical harm, financial loss or otherwise to protect Borderfree’s rights, to report suspected illegal activity, or to investigate violations of any rules, regulations, laws, our Terms & Conditions set forth on the Borderfree Websites or this Privacy Policy.
• Aggregated Content. In addition, we may share aggregated or de-identified Content/blinded information with our merchant partners, and other third parties at our sole discretion.

Opting-In with Third Parties or Use of Third-Party Features. If and when you opt-in as described in the Section “How Can You Make Choices About Receiving Marketing, Promotions and Other Personal Information?”, we may supply Personal Information to third parties. Also, if and when you use third party items that interact with the Borderfree Websites, including third party Social Media Features, third party blogs or other third-party applications or items, we may supply Personal Information to those third parties if you opt in to share your Personal Information with a third party.

4.HOW DOES BORDERFREE SECURE AND RETAIN PERSONAL INFORMATION?

We use a variety of generally accepted standards, technologies, and processes to protect your data, including encryption at both the storage and transport level. However, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. The security of your password is key to the security of your data. We recommend that you do not share, reuse, or store any of your passwords with anyone else. We may retain Personal Information for as long as needed to provide you with services, comply with our legal obligations, resolve disputes, and enforce our agreements.

Your Personal Information will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

Information Sharing within Global-e Group

Borderfree uses several legal mechanisms, including EU Standard Contractual Clauses, to help ensure that your rights and protections are respected by all companies of the Global-e group. We use efforts to ensure that each Global-e group company will comply with the key data protection principles of fair handling of Personal Information and ensuring adequate level of protection of Personal Information. This may be the case if you purchased a product through Borderfree services and website. We will also share and transfer Personal Information to our affiliated companies for storing or processing information on our behalf in connection with our provision of the services. They may combine this Personal Information with other details they hold about you, as detailed under Global-e Privacy Policy.

5. HOW CAN YOU MAKE CHOICES ABOUT RECEIVING MARKETING, PROMOTIONAL, AND OTHER INFORMATION?

If you are a Borderfree customer, you will receive transactional communications about your account and the products and services to which you subscribe. In some jurisdictions, you may have to opt-in to receive any marketing, promotional or other communications from us. In the event you opt-in, we will use and share your Personal Information as described in this Privacy Policy.

If you wish to opt-out of receiving marketing, promotional or other communications from Borderfree, you may do so by (i) following the instructions provided in our marketing, promotional or other communications, or (ii) indicating your preferences on the relevant account profile/preferences section, or (iii) email us at [email protected] you will be removed from Borderfree promotional/marketing email lists. In the event you opt-out we will share your preference with applicable third parties as appropriate. Kindly note that no matter what your marketing preferences are, we may contact you to respond to you, or for other purposes as set forth in this Privacy Policy. In certain cases, we may give you the option to opt-in to receive marketing, promotional or other information from one of our partners or other third party, for example the Store Owners. If you choose to opt-in for that and instruct us to share your data with such third parties for marketing purposes, we will provide your Personal Information to that third party. By choosing to opt-in to a third party, you acknowledge that once your Personal Information has been shared with that third party, the subsequent safeguarding and usage of your Personal Information will be governed by that third party’s Privacy Policy, and any request for further information with respect to their intended use and/or to change your marketing preferences with that third party shall be directed to that third party (and not to Borderfree). 

6.WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals:

• You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
• You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading;
• You have the right to request the erasure/deletion of your Personal Information (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims; and
• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• Deleting your account. Should you ever decide to delete your account, you may do so by emailing [email protected]. If you terminate your account, any association between your account and Personal Information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.

When requesting us to access or update your Personal Information, we may ask you to verify your identity before we can act on your request. Such additional Personal Information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, and of how each request was handled), in accordance with the above. We may redact from the data which we make available to you any personal or confidential data related to others. Please note that we may reject requests, or limit the Personal Information we provide access to, if we determine it could risk the privacy of others or if unreasonable or repetitive, or if it would require disproportionate effort. Please note, by electing to not share certain Personal Information with us, we may be unable to provide you with all of the functionalities we offer through our Borderfree Websites. If you would like to make a request to Borderfree regarding your Personal Information, you may complete our data request form and we will respond to your request as soon as possible and as required by law.

7. WHAT SHOULD YOU UNDERSTAND ABOUT THIRD-PARTY ADVERTISERS AND LINKS TO OTHER WEBSITES?

The Borderfree Websites may include links to third-party websites. We are not responsible for the content displayed or the practices of any such websites. We recommend that you review the Privacy Policy of those websites and third parties.

8.ARE CHILDREN ALLOWED TO USE BORDERFREE?

Borderfree does not allow anyone under the age of 18 or under the minimum age under local jurisdiction laws to take part in any of its services. If you are under the age of 18, or below such minimum age, you must stop using the Borderfree Websites and taking part in its services. and you may use Borderfree services only with the involvement of a parent or guardian. We do not knowingly collect Personal Information from children under the age of 13 without the consent of the child’s parent or guardian. For the avoidance of doubt, we do not sell Personal Information from children under the age of 16 (as defined under applicable US privacy laws).

9.DOES BORDERFREE TRANSFER PERSONAL INFORMATION CROSS BORDER?

Borderfree adheres to applicable laws and regulations regarding Personal Information moving across geographical and jurisdictional borders. This includes the use of data transfer agreements and model contractual clauses, where available, between our corporate entities, our partners, our service providers and our clients where required.

Personal Information submitted by you may be transferred by us to our other offices and/or to the third parties mentioned in the section ‎3, which may be situated (and may be processed by staff operating) in places other than your home jurisdiction. The countries concerned may not have similar data protection laws to your home jurisdiction. Where we transfer Personal Information, we will take all reasonable steps to ensure that your privacy continues to be protected. By submitting Personal Information via the Borderfree Websites, you agree to the storing, processing and/or transfer of Personal Information by Borderfree.

10.WHAT SHOULD YOU KNOW ABOUT CHANGES TO THIS PRIVACY POLICY?

We reserve the right to modify this Privacy Policy at any time, so please review it on our Websites. If we make significant material changes to this Privacy Policy, we will notify you by means of a notice on the Borderfree Websites. Your continued use of our Borderfree Websites indicates your consent to this Privacy Policy and any amended version of it.

11. WHAT ARE THE TERMS & CONDITIONS AND DISPUTE RESOLUTION?

If you choose to visit Borderfree and/or use any of Borderfree’s services, your visits and actions, and any disputes over privacy shall be governed exclusively by this Privacy Policy and the Terms & Conditions at https://www.borderfree.com/terms/en_us.

12.HOW CAN YOU CONTACT BORDERFREE?

If you have questions or concerns regarding this Privacy Policy, you should first contact us at: [email protected]. You can contact our [email protected].

13.PRIVACY NOTICE FOR EU AND UK

If the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) or the UK General Data Protection Regulation and the UK Data Protection Act 2018 (together the “UK DPA”), applies to the processing of your information that can directly or indirectly identify you, by Borderfree, as a data controller, then the following terms apply.

Legal Basis, Data Transfers to Store Owners

The processing of your Personal Information by Borderfree is based on the fact that it is necessary for the performance of your contract, and otherwise your consent, processing is necessary for compliance with a legal obligation to which the controller is subject; and/or Borderfree legitimate business interest, each as described under this Privacy Policy.

Personal Information will be shared with Store Owners as detailed above to the extent necessary for the processing of your order (i.e. performance of your contract) and also for the purposes of the Store Owners’ legitimate interests in promoting the sale of their products. Personal Information transmitted will be controlled by the Store Owners, so please refer to their privacy policies. Where your consent should be required for a particular form of processing or use, it will be specifically requested.

DPO.

As Borderfree part of Global-e group, our DPO can be contacted at [email protected].

Rights under data protection laws

Privacy Rights

If you are a resident of the EEA or the UK, you are entitled to your rights as detailed under this Privacy Policy.

If you are based on the EEA, you have a right to lodge a complaint with a data protection supervisory authority of your habitual residence, place of work or of an alleged infringement of the GDPR. If UK data processing laws apply to our processing of your Personal Information , you have a right to lodge a complaint with the UK Information Commissioner’s Office. A summary and further details about your rights under EU data protection laws, is available on the EU Commission’s website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity and location. We will ask you to provide us credentials to make sure that you are who you claim to be and will ask you further questions to understand the nature and scope of your request.

Data Transfers outside the EU or the UK

As we are an international company, we may securely share your Personal Information with other Global-e entities and our approved partners located all over the world where necessary for the fulfilment of your purchases and performance of our services, as detailed in this Privacy Policy.

The transfer of your Personal Information, to our own entities of the Global-e group and service providers, outside the EEA and UK is protected by the Standard Contractual Clauses in accordance with the European Commission’s contracts model for the transfer of Personal Information to third jurisdictions, unless the data transfer is to a jurisdiction that has been determined by the European Commission (for transfers from the EEA) or the UK Information Commissioner’s Office (for transfers from the UK) to provide an adequate level of protection for individuals’ rights and freedoms for their Personal Information . When we transfer your Personal Information, we will make sure that our data hosting service providers, or any other third party recipient, provide adequate confidentiality and security commitments required by law.

14.PRIVACY NOTICE FOR CERTAIN UNITED STATES RESIDENTS

This Privacy Notice for certain United States Residents supplements the information contained in Borderfree’s Privacy Policy and applies solely to all visitors, users, and others who reside in a U.S. state that grants consumers rights to their personal information (“consumers” or “you”). We adopt this notice to comply with applicable U.S. state privacy laws.

Collection of Personal Information. 

Borderfree Websites collects Personal Information from U.S. residents. Personal Information does not include: Publicly available information from government records and Deidentified or aggregated consumer information. In particular, Borderfree Websites have collected the following categories of Personal Information from its consumers:

Source of Personal Information.

• We obtain the categories of Personal Information listed above from the following categories of sources: Directly from you, such as when you complete forms, when you participate in any Borderfree questionnaires, panels, contests, or sweepstakes, or when you interact with any of the Borderfree Websites
• From our business partners, third parties, and publicly available sources.

Disclosures for a Business or Commercial Purpose. 

Borderfree has disclosed the types of Personal Information listed above to its service providers for business purposes, except for Internet or other similar network activity.

• Sale or Sharing of Personal Information.Borderfree does not technically sell or share any Personal Information in the traditional sense. However, according to broadly defined applicable privacy laws, sharing certain categories of Personal Information with third parties, may be considered as “selling” or “sharing” of Personal Information. Nevertheless, if you would like to opt-out of such practices, you may contact us at [email protected]. Please read Your Rights and Choices below for more information.
• Your Rights and Choices. Certain U.S. states provide their residents with rights related to their Personal Information. Consistent with these laws, Borderfree gives you options to access, edit, or remove certain information, as well as choices about how we contact you. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances.

Privacy Rights

• Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. You have the right to receive a copy of your electronic Personal Information in a readily-usable format.
• Right to Know. You have the right to receive information from us regarding the categories of Personal Information we collected, the sources from which we collect Personal Information, the purposes for which we collected and used Personal Information, the categories of any Personal Information we sold, if any, as well as the categories of third parties to whom such Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose.
• Right to Correction. You have the right to direct Borderfree to correct any Personal Information collected that may be inaccurate.
• Deletion Request Rights. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

1. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
2. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
3. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.

1. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

• Right to Opt Out. You may opt-out of our use of your Personal Information for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights.
• Deleting your Account. Should you ever decide to delete your account, you may do so by emailing [email protected] . If you terminate your account, any association between your account and Personal Information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
• Marketing emails – opt-out. You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to [email protected]. Please note that the email must come from the email account you wish to block.
• Process. If you wish to exercise these rights, you must submit a request by emailing us at [email protected] or through our online form. We will respond to requests in the time permitted by law. If we deny your rights request, you have the right to request an appeal of our decision. To initiate an appeal, follow the instructions provided in the communication denying your request, or contact us at [email protected] with the subject “U.S. Rights Request Appeal.”

Do Not Track Signals

At this time, we do not respond to Do Not Track signals, but we may allow third parties, such as companies that provide us with analytics tools, to collect Personal Information (e.g., IP address) about an individual consumer’s online activities over time and across different web sites.

Notice of Financial Incentive for California Residents.

• We may offer financial incentives to promote our products and services. These may include: discounts, coupons, and special offers when you sign up for our email list, participate in a marketing promotion, or create an account. The benefits to you are reasonably related to our good-faith estimate of the value provided to us by their Personal Information. The value of Personal Information to us varies by individual and is related to the value of the rewards and discounts provided to you, minus the costs of providing those benefits.
• We may ask you to provide Personal Information in connection with these promotions, including the following personal information: your first and last name and email address. Because we may collect Personal Information, this may be interpreted as a “financial incentive” program under California law. Borderfree uses this information for the purposes described above “Information collected directly from you and used for the purposes below” including for marketing purposes and/or to send you a discount coupon. Borderfree may share your personal information with third parties as described in Section “How does Borderfree Share Personal Information?” above, including with Global-e group of entities, data analytics providers, advertising vendors.
• Participation in any financial incentive is optional. You may withdraw from the program at any time by emailing [email protected]. To stop receiving our coupons or discounts in your email, you may unsubscribe from our emails by clicking the “unsubscribe” button at the bottom of any such email. 
• If you ask us to delete your Personal Information, we will not be able to provide you with access to these programs. We have valued the Personal Information collected and used as being equal to the value of the discount code or financial incentive offered, and the calculation of the value is based upon a reasonable and good-faith estimate often involving the consideration of (i) the categories of Personal Information collected (e.g., email address and/or phone number, as applicable), (ii) the value of the discount offered, and (iii) the value of the total purchase (excluding taxes and fees). The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards. We reserve the right to change our financial incentives in the future and the goals thereof.
• Please note that we may provide additional terms that apply to a particular financial incentive. If applicable, those terms will be presented to you at sign up.

Notice of Right to Consent to or to Limit the Processing of Your Sensitive Personal Information.

To the extent that we collect information which is considered “sensitive personal information” as that term is defined under applicable data protection laws, we limit our use or disclosure of the sensitive personal information for permitted business purposes. We will obtain consent to process sensitive personal information where required by law.