Last updated: 10/2/2018
This Notice provides information about what Personal Information we collect, use, and share, and our commitment to using such Personal Information in a respectful fashion.
- Data Protection Officer
- Collection of Your Information
- Why Do We Collect Your Information?
- What Kind of Information Do We Collect?
- Use and Disclosure of Your Information
- How Do We Use Your Information?
- When Do We Share Personal Information?
- California Privacy Rights – Shine the Light Law
- EU to US Data Transfer
- Your Choices Regarding Your Personal Information
- Controls for Do-Not-Track Features
- Security of Your Information
- Data Retention
- Tracking Technologies
- Third-Party Websites
- Policy for Children
- Contact Us
You expressly consent to the collection, use and disclosure of your information in accordance with this Privacy Notice by clicking the “I accept” box upon creating your account with us or by otherwise accessing or using our Site.
Barefoot Technologies Corporation (“Barefoot”, ‘we”, “us”, “our(s)”) cares about your privacy, security, and online safety. The purpose of this Privacy Notice (“Notice”) is to inform you about how we collect, use, and share any data shared with us which could be used to identify an individual (“Personal Information”).
This Privacy Notice details our practices regarding the personal information we obtain from individuals through our website, mobile, other applications, and media channels. In addition, some portions of our Site, such as our token sale portal or mobile applications, may be subject to additional terms and conditions. If a separate privacy notice applies, for example our Mobile App Privacy Statement, we will post it on our website located at www.barefoot.com. Our website and mobile applications are collectively referred to in this Notice as the “Site”.
We may update this Notice, or other privacy notices that we may publish, at any time. We will alert you about any changes by posting the updated version of this Privacy Notice on our Site. Any changes or modifications will be effective immediately upon such posting. You are encouraged to periodically review this Privacy Notice to stay informed of any updates. You will be deemed to have been made aware of, accepted, and will be subject to such changes in any revised Privacy Notice by your continued use of the Site after the date such revised Privacy Notice is posted.
DATA PROTECTION OFFICER
Barefoot is headquartered in the State of New Hampshire, USA. We have established the position of data protection officer in our organization to help protect your information and to respond to any questions or concerns that you may have about our data practices and policies. Our data protection officer’s contact information is as follows:
COLLECTION OF YOUR INFORMATION
Why Do We Collect Your Information?
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use your data to:
- Provide the Site;
- Fulfill transactions related to the Site;
- Generate a personal profile about you to make future visits to the Site more personalized;
- Investigate, respond to, and manage inquiries or events;
- Provide you with customer support;
- Cooperate with law enforcement and regulators; and
- Perform other business activities as needed, such as analyzing security threats and vulnerabilities.
What Personal Information Do We Collect?
The Personal Information we may collect through the Site includes:
- Contact information (such as name, email address, mailing address, and phone number);
- Your transaction history;
- Account log-in credentials;
- Your location;
- Integration data: The Service is particularly aimed for properties listed on and operating through third party platforms (“Third Party Channels”). After you register, you may interconnect the Service with each of your accounts on Third Party Channels. Once you connect to an Integration, the Service imports the property and guest related data in your accounts on the respective Third-Party Channel, such as listings, reservations, past guests, etc.
How Do We Collect Information?
We may collect information that is provided directly by you. automatically from your use of the Site, or from certain third-parties.
You should be aware that getting a new computer or device, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.
Do Not Track Disclosure: Our Site does respond to Do Not Track signals. You may also disable certain tracking as discussed above (e.g., by disabling cookies) or visiting the applicable third-party vendor’s website or by using the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool. OR [Most web browsers and some mobile operating systems and our mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. If you set the DNT signal on your browser, we will respond to such DNT browser signals.]
Information from Other Third-Parties: We may collect information, either ourselves or via third-parties, (e.g. page view, search term and search result information, etc.) about you from other third-parties such as from a list of subscribers to a third-party publication.
Information That You Provide: The information that you provide directly to us generally consists of your contact details. Except for certain minimum data (e.g. your name and e-mail address) which is required to establish your account on the Site, you are under no obligation to provide us with personal information of any kind, however your refusal to do so may prevent you from using certain features or portions of the Site; for example or token sale portal and mailing list.
USE AND DISCLOSURE OF YOUR INFORMATION
How Do We Use Your Information?
We use your Personal Information to protect you from security and other risks and our own business purposes such as:
- Compile anonymous statistical data and analysis for use internally or with third-parties;
- Increase the efficiency and operation of the Site and Site;
- Create and manage accounts;
- Email you regarding your account or related transactions;
- Monitor and analyze usage and trends to improve your experience with and update the Site;
- Notify you of updates to the Site;
- To help prevent the fraudulent use of or theft of our Site and your information;
- Comply with applicable law, regulations, and policies;
- Identify threats and vulnerabilities and update our Site accordingly;
- Data processing (including data encryption); and
- Enforcement of applicable polices.
When Do We Share Personal Information?
As a Part of our Services: To provide you with our services we may share:
- Your information with contractors and service providers, to operate, maintain and enhance the Service, and provide you with the particular features of the Service you requested;
- Your information with Third Party Channels, to maintain your account on the Service and on Third Party Channel updated that you request to work with;
- Messages you address to guests and prospective guests will be sent to them;
- Your information if the operation of the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition); and
- Your information with our corporate group entities, but their use of such information must comply with the Policy.
We may also share information we have collected about you in certain situations. Your information may be disclosed or as follows:
By Law or to Protect Rights. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.
Marketing Communications. With your consent, we may share your information with third parties for marketing purposes, as permitted by law.
Social Media Contacts. If you connect to the Site through a social network, your contacts on the social network may see your name, profile photo, and descriptions of your activity.
Sale or Bankruptcy. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur, and that the transferee may decline honor commitments we make in this Privacy Notice.
Anonymous Data. While we would never disclose your personally identifiable information to any third-party without your express consent, except as provided for in this Privacy Notice, we reserve the right to use any aggregated statistical or other such data, which is transmitted and stored separately from any of your Personal Information and cannot be reasonably used to identify you (“Anonymous Data”), collected and/or aggregated for any purpose and disclose, share, or otherwise transfer Anonymous Data to third parties, including via the license or sale thereof, at its sole and absolute discretion. By accepting the terms and conditions of this Privacy Notice, you are expressly consenting to such sharing, disclosure, or transfer.
California Privacy Rights – Shine the Light Law: California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.
Please Note. We are not responsible for the actions of third-parties with whom you share personal or sensitive information, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third-parties, you are responsible for contacting the third party directly.
EU TO US DATA TRANSFERS
Our headquarters is in the United States, and we operate there as well as in other countries; either through our own subsidiaries or third-parties. Therefore, we, ourselves or via third-parties, may transfer your Personal Information to, or process or gain access to it from, jurisdictions that may not provide the same level of protections as your home jurisdiction. We are relying on the derogations in Article 49 of the GDPR as the United States has not received a designation of adequacy under Article 45 of the GDPR. Therefore, it is important to note that we may, only upon your consent, collect and transfer your Personal Information to the U.S. to perform a contract with you or to fulfill our own compelling legitimate business interest that does not outweigh your personal rights and freedoms. We do not collect or store any sensitive information about you and we employ a variety safeguards to help to secure and maintain the privacy of your personal information.
Legal basis. Barefoot is a Data Processor as defined in the European General Data Protection Regulation (GDPR). The processing of your Personal Information described in this policy is based on your consent or on the contractual necessity (which means that the processing of your Personal Information is required for Barefoot to provide services to you).
When using or accessing the Barefoot services, you agree that Barefoot collects, stores, processes and transfers your Personal Information to the relevant Third-Party Channels or other such parties necessary to facilitate your use of and access to the Barefoot Services. To this end, Barefoot acts as processor on behalf of such Third-Party Channels or other such parties.
The processing of your Personal Information described in this Policy is based on Barefoot’s legitimate interests for the following:
- The provision of the Barefoot Services as agreed between you and Barefoot;
- As may be required by applicable law or regulation;
- Where the processing of Personal Information is strictly necessary and proportionate for the purposes of ensuring network and information security.
YOUR CHOICES REGARDING YOUR INFORMATION
Account Information. You may at any time review or change the information in your account by Logging into your account settings and updating your information.
Emails and Communications. If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by logging into your account settings and updating your preferences.
If you no longer wish to receive any correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.
SECURITY OF YOUR INFORMATION
We use a variety of industry standard administrative, technical, and physical security measures to help protect your personal information. We also require you to enter a password to access your account information. It is your responsibility to safeguard your password and pother login credentials, please do not disclose your account password to unauthorized people. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
Notwithstanding the “Your Choices” section above, the time periods for which we retain your Personal Information may vary dependent upon the reason for its collection and use. Generally, we will retain Personal Information: (i) for as long as you are using our products or Site; or (ii) for as long as we have a legitimate business purpose (such as those described in the “How Do We Use Personal Information” section above), but we will do so only as is necessary to meet our legitimate business needs and obligations or as permitted by law. The information we collect may be stored and processed in servers in the United States and wherever we and our service providers have facilities around the globe.
The Site may contain links to third-party websites and applications of interest including advertisements, website analytics providers, social network sites, and other external sites, that are not affiliated with us. Once you have used these links to leave the Site, this Privacy Notice does not cover any information you provide to these third-parties, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, Site or applications that may be linked to or from the Site.
POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.
If you have questions or comments about this Privacy Notice or otherwise need to contact us, please contact us at: