Privacy Notice

This Notice provides information about the Personal Information Barefoot Technology Corporation collects, uses, and shares, and our commitment to using such Personal Information in a respectful fashion.

OVERVIEW

You expressly consent to the collection, use and disclosure of your information in accordance with this Notice by clicking the “I accept” box upon creating your account with us or by otherwise accessing or using our Platform.

Barefoot Technologies Corporation (“Barefoot”, “we”, “us”, “our”) 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 that could be used to identify a person individually (“Personal Information”).

This Notice details our practices regarding the personal information we obtain from individuals through our website and our SaaS application products, as well as from our mobile applications, other applications, and media channels (all of the foregoing collectively referred to in this Notice as the “Platform”.) In addition, some portions of our Platform, such as our token sale portal or mobile applications, may be subject to additional terms and conditions set forth in a separate privacy notice. If a separate privacy notice applies, we will post it on our website located at www.barefoot.com. 

When you access or use the Platform, you acknowledge that you have read this Notice and understand its contents. Your use of our Platform and any dispute over privacy is subject to this Notice and our Terms of Use (including any applicable limitations on damages and dispute resolution provisions).

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 Notice on our Platform.  Any changes or modifications will be effective immediately upon such posting. You are encouraged to periodically review this 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 Notice by your continued use of the Platform after the date such revised 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:

DPO@barefoot.com

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 Platform;
  • Fulfill transactions related to the Platform;
  • Generate a personal profile about you to make future visits to the Platform 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 Platform 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 Platform is particularly aimed for use in connection with properties listed on and operating through third party platforms (“Third Party Channels”). After you register, you may interconnect your account with each of your accounts on Third Party Channels. Once you connect to a Third Party Channel, the Platform imports the property and guest related data in your account on that Third Party Channel. By connecting to a Third Party Channel, you acknowledge that the Third Party Channel may use that property and guest related data to provide additional services to you for which Barefoot is not responsible.

How Do We Collect Information?

We may collect information that is provided directly by you, automatically from your use of the Platform, or from certain third parties.

  • 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 Platform, 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 Platform, such as our token sale portal and mailing list.
  • Information Provided Automatically:We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Platform to help customize the Platform and improve your experience. For more information on how we use cookies, please refer to our Cookie Policy posted on the Platform, which is incorporated into this Notice. By using the Platform, you agree to be bound by our Cookie Policy. We may also partner with selected third party vendors, such as Google Analytics, Crazy Egg, and Telegram, to allow tracking technologies and remarketing on the Platform by first party cookies and third party cookies, to analyze and track users’ use of the Platform, to determine the popularity of certain content, and to better understand online activity, among other things. By accessing the Platform or any portion thereof, you consent to the collection and use of your information by these third party vendors. You are encouraged to review their privacy policies and contact them directly for responses to your questions. We do not transfer personal information to these third party vendors.

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.  

  • 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), about you from other third parties such as from a list of subscribers to a third party publication.

 

  • Do Not Track Disclosure:Our Platform 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. Additionally 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.  

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 for our own business purposes such as:

  • Compiling anonymous statistical data and analysis for use internally or with third parties;
  • Increasing the efficiency and operation of the Platform;
  • Creating and managing accounts;
  • Emailing you regarding your account or related transactions;
  • Monitoring and analyzing usage and trends to improve your experience with and update the Platform;
  • Notifying you of updates to the Platform;
  • Protecting against the fraudulent use of or theft of our Platform and your information;
  • Complying with applicable law, regulations, and policies;
  • Identifying threats and vulnerabilities and updating our Platform 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 access to and use of our Platform, we may share:

  • Your information with contractors and service providers, to operate, maintain and enhance the Platform, and provide you with the particular features of the Platform that you requested;
  • Your information with Third Party Channels, to maintain your account on the Platform and on those Third Party Channels with which you have integrated your account and to facilitate their provision of services to you, provided that
    • You acknowledge that those Third Party Channels may themselves use and disclose your information to their third party service providers without restriction as required to provide their services to you, and
    • You agree to look solely to those Third Party Channels and not to Barefoot for any claims or remedies in connection with their use and disclosure of your information;
  • Messages you address to guests and prospective guests, which will be sent to them;
  • Your information if the operation of the Platform 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 affiliates, but their use of such information must comply with the Policy.

Other Situations: 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 Platform 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 to honor the commitments we make in this 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 Notice, we reserve the right to use any statistical or other such data that 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 to disclose, share, or otherwise transfer Anonymous Data to third parties, including via the license or sale thereof, at our sole and absolute discretion. By accepting the terms and conditions of this 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 Platform, you have the right to request removal of unwanted data that you publicly post on the Platform. 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 Platform, 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

When using or accessing the Platform, 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 Platform. To this end, Barefoot acts as processor on behalf of such Third Party Channels or other such parties and is deemed a “data processor” as defined in the European General Data Protection Regulation (GDPR).

Our headquarters is in the United States, and we operate there as well as in other countries, either through our affiliates or through 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 transfer your Personal Information to the United States only (a) with your explicit informed consent, (b) for contractual necessity (which means that the processing of your personal information is required for Barefoot to provide services to you), or (c) for other reasons enumerated in Article 49, including:

  • Barefoot’s legitimate interest in the provision of access and use of the Platform 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.

We do not collect or store any sensitive data (under the GDPR) about you and we employ a variety safeguards to help to secure and maintain the privacy of your personal information.

YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION; DATA RETENTION

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. You may at any time access a copy of or terminate your account information by using our deletion or export tools or submitting a request to DPO@barefoot.com to terminate your account. Upon receiving such a request, Barefoot will deactivate and/or delete your account and information from our active databases. However, some Anonymous Data may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with other applicable legal or regulatory requirements.

Emails and Communications. If you no longer wish to receive correspondence, emails, or other communications from Barefoot, 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.

Data Retention. Your choices notwithstanding, 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 Platform; 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) or as permitted by law. The information we collect may be stored and processed in servers in the United States and wherever our service providers and we have facilities around the globe.

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 other login credentials and not to 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.

THIRD PARTY WEBSITES

The Platform 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 Platform, this 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 that you believe are necessary to 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 or applications that may be linked to or from the Platform.

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.

CONTACT US

If you have questions or comments about this Notice or otherwise need to contact us, please contact us at:

DPO@barefoot.com

1-877-799-1110

Last updated: March 16, 2020