Filled86, LLC · 730 Glenwood Ave SE, Atlanta, GA 30312

Privacy Policy

Effective Date: June 11, 2026 · Last Updated: June 11, 2026

Filled86, LLC ("Filled86," "we," "us," or "our") operates the website www.filled86.com and the Filled86 platform (collectively, the "Platform"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you access or use our Platform, regardless of where you are located.

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

1. Information We Collect

We collect personal information from and about you in three ways: information you provide directly, information collected automatically when you use the Platform, and information we receive from third parties.

1.1 Information You Provide Directly

When you register, create a profile, make or accept a booking, or communicate with us, you may provide:

Account registration data: your full name, email address, phone number, and password.
Professional profile data: work history, certifications, portfolio materials, headshot photograph, availability, and preferred compensation.
Venue profile data: business name, physical location, capacity, venue description, images, and pricing.
Payment and billing data: bank account details, payment card information, billing address, and tax identification numbers, collected and processed through our PCI-compliant payment processors. We do not store full payment card numbers on our systems.
Communications: messages sent through the Platform, support requests, feedback, and responses to surveys.
Background check consent and related data: authorization forms and any information you provide in connection with background verification.
Identity verification data: government-issued identification documents submitted for identity or eligibility verification purposes.

1.2 Information Collected Automatically

When you use the Platform, we and our service providers automatically collect certain information, including:

Device and browser data: device type, operating system, browser type and version, screen resolution, and device identifiers.
Usage data: pages viewed, features accessed, time spent on the Platform, search queries, booking activity, and click patterns.
Log data: IP address, date and time of access, referring URLs, and error logs.
Location data: approximate geographic location inferred from your IP address. We do not collect precise GPS-level location data unless you explicitly grant permission.
Cookies and tracking technologies: as described in detail in Section 8 of this Privacy Policy.

1.3 Information We Receive from Third Parties

We may receive personal information about you from:

Checkr: background check reports, including criminal history, employment verification, and identity confirmation results, subject to your prior written authorization.
Stripe: transaction confirmation, payment status, and fraud signals from our payment processor.
Twilio: delivery status and engagement data related to SMS notifications sent on our behalf.
Resend: delivery status related to transactional email notifications sent on our behalf.
Publicly available sources: professional licensing registries, public business filings, and other lawfully accessible databases used to verify credentials or investigate reported concerns.

2. How We Use Your Information

We use the personal information we collect for the following purposes:

To create and manage your account and authenticate your identity.
To facilitate connections between Sovereigns (professionals) and Establishments (venues).
To process payments, manage escrow, and facilitate payouts via Stripe.
To conduct identity verification and background screening (with your explicit consent).
To send shift confirmations, reminders, and operational communications via SMS (Twilio) and email (Resend).
To operate algorithmic matching systems (Smart Match, Elite Pairings) based on skills, availability, location, and performance metrics.
To calculate and display performance metrics and Sovereign rank tier.
To issue IRS Form 1099-NEC for eligible Sovereigns who earn $600 or more in a calendar year.
To resolve disputes between Platform users.
To maintain Platform security, detect fraud, and prevent abuse.
To comply with legal and regulatory obligations.
To improve Platform functionality through anonymized analytics.

Where required by applicable law, we identify the legal basis for each use (see Section 3 for EU/EEA users). We will not use your personal information for purposes materially different from those described here without providing prior notice and, where required, obtaining your consent.

3. Legal Basis for Processing (EU/EEA and UK Users)

If you are located in the European Union, European Economic Area, or United Kingdom, Filled86 processes your personal data only where we have a valid legal basis under the GDPR or applicable UK data protection law:

Consent (Article 6(1)(a)):

Where you have given clear, specific, and freely given consent, such as for marketing communications, non-essential cookies, or international data transfers. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Contract performance (Article 6(1)(b)):

Where processing is necessary to perform a contract with you or take steps at your request before entering into a contract, such as creating your account, processing bookings, or facilitating payments.

Legal obligation (Article 6(1)(c)):

Where processing is necessary for us to comply with a legal obligation, such as tax reporting, anti-money laundering requirements, or responding to court orders.

Legitimate interests (Article 6(1)(f)):

Where processing is necessary for our legitimate interests — including fraud prevention, Platform security, service improvement, and business analytics — provided those interests are not overridden by your rights. We conduct a balancing assessment to ensure your rights are protected.

Vital interests (Article 6(1)(d)):

In exceptional circumstances, where processing is necessary to protect the vital interests of you or another individual, such as in emergency safety situations.

To understand the specific legal basis for any particular use of your data, contact us at steward@filled86.com.

4. How We Share Your Information

We do not sell your personal information.

4.1 Between Platform Users

To enable the core function of the Platform, limited profile information is shared between Sovereigns and Establishments in connection with a booking inquiry or confirmed engagement. Sovereigns may see venue names, locations, and contact information. Establishments may see professional profiles — including display names, profile photos, and work history — to the extent those fields are made available in the user's profile settings.

Information never shared between users: home address (Sovereigns), travel radius preferences, dependability score, or financial details of either party.

4.2 Service Providers and Sub-Processors

We share personal information with third-party service providers who perform services on our behalf. These providers are contractually prohibited from using your data for any purpose other than providing services to Filled86 and are required to maintain appropriate security measures. Our current sub-processors include:

Stripe, Inc. — payment processing, escrow, payouts, and 1099-NEC generation
Checkr, Inc. — background screening (with your explicit consent)
Twilio, Inc. — SMS and messaging delivery
Resend — transactional email delivery
Base44 — platform infrastructure and hosting

4.3 Legal Requirements

We may disclose personal information if required to do so by law or in good-faith belief that such disclosure is necessary to: (a) comply with a legal obligation, court order, or governmental request; (b) enforce our Terms of Service; (c) protect the rights, property, or safety of Filled86, our users, or the public; or (d) detect, prevent, or address fraud, security, or technical issues.

4.4 Business Transfers

In the event of a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or substantially all of our assets, your personal information may be transferred to the acquiring entity. We will provide notice of such a transfer and any choices you may have regarding your information to the extent required by applicable law.

4.5 With Your Consent

We may share your personal information with third parties not described in this section where we have obtained your prior explicit consent.

4.6 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified information that does not reasonably identify you with third parties for industry analysis, research, and service improvement. We will not attempt to re-identify de-identified data.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, to comply with our legal obligations, resolve disputes, and enforce our agreements. The following retention periods apply:

Active account data: Retained for the duration of your account plus 3 years after closure.

Financial and tax records (Payouts, Invoices): 7 years (IRS requirements).

Background check results: Pass/fail status retained for account duration; detailed reports not stored by Filled86.

Government-issued ID documents: Automatically purged after successful identity verification.

Shift and payment history: 7 years (financial record requirements).

Anonymized analytics data: Retained indefinitely (no personal data).

PII after account closure (30-day rule): Phone, address, photo, and portfolio data anonymized within 30 days of account closure.

Full anonymization: All remaining non-financial personal data anonymized within 3 years of account closure.

You may request deletion of your personal information at any time by contacting us at steward@filled86.com. We will honor such requests subject to any applicable legal retention obligations.

6. Data Protection Officer & Privacy Contact

Filled86 is a US-based platform currently serving US users. We are committed to protecting the privacy of all users regardless of location, including those in the EU/EEA.

Based on the nature and scale of our current data processing activities, Filled86 is not required to designate a formal Data Protection Officer under Article 37 of the GDPR. Filled86 currently serves US-based users only; GDPR Article 37 DPO designation is not presently required. If Filled86 expands to serve EU/EEA users, a formal DPO will be designated and disclosed prior to that expansion.

We have designated an internal privacy point of contact responsible for overseeing data protection matters and responding to inquiries:

Privacy & Data Protection Contact: steward@filled86.com

Mailing Address: Filled86, LLC · 730 Glenwood Ave SE, Atlanta, GA 30312

This role serves as the primary contact for all privacy-related inquiries, data subject access requests, and communications from data protection authorities.

7. International Data Transfers

Filled86 is headquartered in the United States. If you access or use our platform from outside the United States — including from the EU, EEA, UK, or other jurisdictions — your personal data will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence.

7.1 Legal Basis for Transfers

Standard Contractual Clauses (SCCs): We enter into European Commission-approved SCCs with our third-party service providers who process personal data on our behalf.
Contractual necessity: Where the transfer is necessary to perform our contract with you, in accordance with Article 49(1)(b) of the GDPR.
Your explicit consent: Where applicable, we may rely on your explicit, informed consent to transfer data internationally, which you may withdraw at any time.

7.2 Third-Party Sub-Processors

The following US-based service providers may process personal data transferred from outside the United States: Stripe, Checkr, Twilio, Resend, and Base44. We conduct due diligence on all sub-processors to ensure they maintain appropriate technical and organizational security measures.

7.3 Safeguards We Maintain

Encryption of personal data in transit (TLS 1.3) and at rest (AES-256)
Access controls limiting data access to authorized personnel
Contractual obligations on all service providers to maintain confidentiality and security
Regular review of sub-processor compliance with data protection commitments

7.4 Your Rights Regarding International Transfers

If you are located in the EU/EEA or UK, you have the right to:

Request information about the safeguards in place for international transfers of your data
Obtain a copy of the Standard Contractual Clauses or other transfer mechanisms upon request
Lodge a complaint with your local supervisory authority if you believe your data has been transferred unlawfully

To exercise any of these rights, contact us at steward@filled86.com.

8. Cookies, Tracking Technologies & Analytics

Filled86 uses cookies and similar tracking technologies to operate, secure, and improve our platform.

8.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. Similar technologies include web beacons (pixel tags), local storage, and device fingerprinting. Together, these help us recognize your device, remember preferences, and understand how you interact with our platform.

8.2 Types of Cookies We Use

Strictly Necessary Cookies (cannot be disabled):

Authentication session tokens
CSRF protection tokens
localStorage for application state and performance optimization

Analytics Cookies (first-party, Base44 Analytics):

First-party only — no data sent to third-party advertising or analytics companies
Does NOT use third-party cookies or track you across other websites
Does NOT create advertising profiles
Collects only interaction events (clicks, form submissions) — not keystrokes or screen recordings
Used exclusively to improve Platform functionality

8.3 What We Do NOT Use

Google Analytics, Mixpanel, Segment, Amplitude, or any third-party analytics service
Meta Pixel, Google Ads Pixel, TikTok Pixel, or any advertising/remarketing pixel
Hotjar, FullStory, LogRocket, or any session replay/screen recording tool
Cross-site tracking technologies or browser fingerprinting
Third-party advertising cookies of any kind

8.4 Consent

EU/EEA and UK users: Only strictly necessary cookies are set before you provide consent. Analytics cookies require your affirmative opt-in. You may change preferences at any time via the "Cookie Settings" link in our site footer.

California/CCPA users: You may opt out of the sale or sharing of personal information collected via tracking technologies by clicking "Do Not Sell or Share My Personal Information" in the site footer. Note: Filled86 does not sell personal information.

8.5 Do Not Track (DNT) Signals

Filled86 honors Do Not Track browser signals. When we detect a DNT signal, we disable all non-essential cookies and tracking technologies for that session.

8.6 Data Retention for Tracking Technologies

Strictly necessary cookies: Session-based (deleted on logout or browser close)
Analytics data: Aggregated data retained for up to 26 months; raw event data deleted after 14 months

9. Your Privacy Rights

9.1 Rights Available to All Users

Regardless of your location, you may:

Access the personal information we hold about you and request a copy
Correct or update inaccurate or incomplete personal information
Delete your account and request erasure of associated personal data (subject to legal retention requirements)
Object to or restrict certain types of processing
Withdraw consent at any time where processing is based on consent
Request human review of any algorithmic decision affecting your account
Download a copy of your data in a portable format (JSON or CSV)

9.2 EU/EEA and UK Users — GDPR Rights

If you are located in the EU, EEA, or UK, you additionally have the right to:

Data portability — receive your data in a structured, machine-readable format (Article 20)
Restriction of processing in certain circumstances (Article 18)
Object to processing based on legitimate interests (Article 21)
Not be subject to solely automated decision-making that produces legal or similarly significant effects without human review (Article 22)
Lodge a complaint with your local data protection supervisory authority

9.3 California Users — CCPA/CPRA Rights

If you are a California resident, you have the following rights:

Right to know what personal information we collect, use, disclose, and sell
Right to delete personal information we have collected, subject to applicable exceptions
Right to opt out of the sale or sharing of personal information (we do not sell personal information)
Right to correct inaccurate personal information
Right to limit the use and disclosure of sensitive personal information
Right to non-discrimination for exercising your CCPA rights

9.4 How to Exercise Your Rights

To submit a privacy rights request, email steward@filled86.com with the subject line "Privacy Rights Request" or write to us at: Filled86, LLC · 730 Glenwood Ave SE, Atlanta, GA 30312.

We will verify your identity before processing your request and will respond within 30 days for GDPR-covered requests and within 45 days for CCPA-covered requests. We may extend the response period by an additional 30 or 45 days respectively, in which case we will notify you of the extension and reason.

10. Data Security

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, loss, or destruction:

Encryption: data in transit using TLS 1.3 and data at rest using AES-256 encryption. SSN/TIN encrypted with additional field-level encryption.
Access controls: need-to-know basis, role-based permissions, multi-factor authentication, and regular access reviews.
Security assessments: periodic vulnerability assessments and security reviews of our Platform and infrastructure.
Incident response: written incident response procedures; we will notify affected users and applicable supervisory authorities of a confirmed data breach within 72 hours of becoming aware of it, as required under GDPR.
Employee and contractor access: personnel with access to personal data are bound by confidentiality obligations and receive privacy and security awareness training.
Vendor due diligence: we evaluate the security practices of all third-party service providers before engagement and include data protection requirements in all vendor contracts.
PCI-DSS 4.0.1 compliant payment processing through Stripe; we do not store raw card data.

No method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your personal information, we cannot guarantee absolute security.

11. Children's Privacy

The Filled86 Platform is not directed to, and is not intended for use by, children under the age of 16. In the United States, we do not knowingly collect personal information from children under the age of 13 in accordance with the Children's Online Privacy Protection Act (COPPA).

If we discover that we have inadvertently collected personal information from a child under the applicable age threshold, we will promptly delete that information. If you are a parent or guardian and believe that your child has provided personal information to us, please contact us at steward@filled86.com.

12. Third-Party Links and Services

The Platform may contain links to third-party websites, applications, or services not operated or controlled by Filled86. These links are provided for convenience and do not constitute our endorsement of those third parties or their privacy practices.

When you navigate away from our Platform, this Privacy Policy no longer applies. We encourage you to review the privacy policy of any third-party site before providing personal information. Your use of integrated third-party services (such as Stripe's payment portal or Checkr's dispute resolution page) is governed by the respective privacy policies and terms of those third parties.

13. SMS and Communications

13.1 SMS Communications (via Twilio)

By providing your phone number and opting in, you consent to receive SMS messages from Filled86 related to:

Shift confirmations, reminders, and updates
Account verification codes and Magic PINs
Booking confirmation alerts and urgent cancellation notices
Dispute notifications and platform updates

Frequency varies based on your account activity. Standard message and data rates from your carrier may apply.

13.2 Opt-Out

You may opt out of non-essential communications at any time by replying STOP to any SMS, clicking "Unsubscribe" in any non-essential email, or contacting concierge@filled86.com. Essential security and transactional messages cannot be opted out while maintaining an active account.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last Updated" date at the top of this document.

For material changes, we will provide at least 30 days' advance notice through one or more of the following:

A prominent banner or notice on the Platform
An email to the address associated with your account
An in-app notification

Your continued use of the Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. For EU/EEA users, where a material change affects processing based on consent, we will ask you to re-consent before the change takes effect. Prior versions of this Privacy Policy are available upon request by contacting steward@filled86.com.

15. Contact Us

General Inquiries, Privacy Requests & Onboarding: concierge@filled86.com

Disputes, Legal & Data Protection Matters: steward@filled86.com

Automated System Notifications (do not reply): system@filled86.com

Mailing Address: Filled86, LLC · 730 Glenwood Ave SE, Atlanta, GA 30312

We are committed to working with you to resolve any concerns about your privacy promptly and fairly. If you are located in the EU/EEA or UK and are not satisfied with our response, you have the right to escalate your complaint to your local data protection supervisory authority.

This Privacy Policy is incorporated into and subject to the Filled86 Terms of Service.