Privacy Notice

Introduction

  1. This privacy statement informs you about how we process information that we record about you, whether provided by you, or by another person or organisation. It applies to information that could identify you as an individual (“personal information”) and information that does not, including that which relates to your business. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
  2. We are committed to the protection of your privacy and confidentiality. We recognise that you are entitled to know that your data will not be used for any unintended purpose, and will not accidentally fall into the hands of a third party.
  3. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  4. We have in place procedures and training for data protection, confidentiality and information security. These are regularly reviewed to ensure that they remain effective.
  5. Our policy complies The General Data Protection Regulation (GDPR) (EU) (2016/679).
  6. All records are in compliance with the Personal Information Protection & Electronic Documents Act (PIPEDA) and the Personal Information Protection Act (PIPA).
  7. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
  8. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

8.          Data we process

We provide a range of services to businesses and personal clients. We aim to process data, whether personal data or not, only to the extent necessary for us to provide our clients with our services and for other agreed purposes.

Often we may aggregate information in a general way and use it to provide class information. If we use it for this purpose, you as an individual will not be personally identifiable.

Clients

If you are a personal client, personal data that we may process may include contact information, information about your business activities, information about your family members, and financial information such as that relating to your income, expenses, taxation and investments. Some of our services may also require us to process information deemed to be “special category” information, such as your race or ethnic origin, information about your health and medical history, information about your sexual life and orientation, criminal records, and information about your political, religious or philosophical beliefs.

In most cases, your personal data will have been provided to us by you. However, with your consent, or if it is necessary in order to provide you with our services, we may have obtained your personal data from a third party source.

When ordering or registering on our site, we may request information from you. To buy from us, you must provide contact information (like name and shipping address) and financial information (like credit card number, expiration date). This information is used for billing purposes and to fill your orders. If we have trouble processing an order, we’ll use this information to contact you.

Third parties connected to clients and suppliers

We may process your personal data if you have a personal or business connection with any of our clients or suppliers. For example, you may be a family member, business partner, other adviser, supplier or transaction counterparty.

The data we process may include contact information, information about business activities, information about partners, directors, employees, information relating to employment remuneration and payroll, and financial information such as that relating to income, expenses, taxation and investments.

We may be given your personal data by our clients or suppliers, or by third parties acting on the instructions of a client or a supplier.

We ask our clients and suppliers to bring this privacy notice to your attention as soon as they become aware that we process your personal data.

Suppliers

If you supply our business with goods or services, including subcontracted services that we supply to our clients, then we may process your personal information. However, we do so only to the extent necessary to contract with you.

In most cases, your personal data will have been provided to us by you. However, sometimes we use third parties such as credit rating agencies to make decisions regarding our relationship.

The bases on which we process personal information

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

9.       Information we process because we have a contractual obligation

We may process personal information when a contract has been formed with our business and processing is necessary to carry out our obligations under that contract, or when processing personal data is necessary in order to form a contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

10.      Information we process with your consent

Only when you have given us explicit permission to do so, do we process your personal information under the basis of consent.

For example, you might have agreed that we may pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us help@barefootbusinesssolutions.com. However, if you do so, you may not be able to use our website or our services further.

11.      Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

  • whether the same objective could be achieved through other means
  • whether processing (or not processing) might cause you harm
  • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

  • record-keeping for the proper and necessary administration of our business
  • responding to communication from you to which we believe you would expect a response
  • protecting and asserting the legal rights of any party
  • insuring against or obtaining professional advice that is required to manage business risk
  • protecting your interests where we believe we have a duty to do so

12.      Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal or tax authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us

13.      Communicating with you

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

14.      Dealing with complaints

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

If the complaint relates to information on our website and we feel it is justified or if we believe the law requires us to do so, we shall remove the information while we investigate.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

We may compile statistics from information relating to complaints to assess the level of service we provide, but not in a way that could identify you or any other person.

15.      Office visitors

If you visit our office you will be required to sign in at reception. We keep a record of your visit in order to maintain the security of our premises, your safety and the safety of other visitors.

We keep the record of your visit only for as long as necessary, and in any case, for [less than one year].

16.      Customer relationship management system

We use a customer relationship management (CRM) system to process personal data.

Data subjects include existing, former and prospective clients and their agents and representatives.

Personal data that we process includes the name of the person, information about his or her employer and job position, and contact information.

We process this data on the basis of consent for purposes that include:

  • managing and developing our business or services
  • informing clients and prospective clients about our services
  • determining relationships between clients and our partners and employees
  • analysing whether we provide clients with a high level of service

We do not sell or share any personal data with third parties unless we have explicit consent to do so from the data subject.

Use of information we collect through automated systems when you visit our website

17.      Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use cookies in the following ways:

17.1.     to track how you use our website

17.2.     to record whether you have seen specific messages we display on our website

17.3.     to keep you signed in our site

17.4.     to record your answers to surveys and questionnaires on our site while you complete them

17.5.     to record the conversation thread during a live chat with our support team

We provide more information about the cookies we use in our cookie policy.

18.      Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information that could identify your location, such as your IP address. We also record information reported by the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website. However, our policy is not to use such data for the purpose of personal identification.

19.      Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Disclosure and sharing of your information

20.      Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

No such information is personally identifiable to you.

21.      Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

22.      Data may be processed outside the European Union

Our websites are hosted in Canada.

We may also use outsourced services in countries outside the European Union (EU) from time to time in other aspects of our business.

Accordingly data obtained within the could be processed outside the EU.

We use safeguards with respect to data transferred outside the EU.

These include:

22.1.     the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.

22.2.     the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.

22.3.     we comply with a code of conduct approved by a supervisory authority in the European Union.

22.4.     we are certified under an approved certification mechanism as provided for in the GDPR

Access to your own information

23.      Access to your personal information

23.1.     At any time you may review or update personally identifiable information that we hold about you.

23.2.     To obtain a copy of any information that is not provided through our website you may send us a request at help@barefootbusinesssolutions.com

23.3.     After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

24.      Removal of your information

If you wish us to remove personally identifiable information, you may contact us at help@barefootbusinesssolutions.com

This may limit the service we can provide to you.

25.      Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

26.      Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

26.1.     to provide you with the services you have requested;

26.2.     to comply with other law, including for the period demanded by our tax authorities;

26.3.     to support a claim or defence in court.

27.      Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

We may use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented Demographics and Interests Reporting

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

28.      California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

·         Users can visit our site anonymously.

·         Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

·         Our Privacy policy link includes the word ‘Privacy’ and can easily be found on the page specified above.

·         You will be notified of any Privacy Policy changes on our Privacy Policy Page.

·         You can change your personal information by emailing us at help@barefootbusinesssolutions.com

29.      How does our site handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

30.      Does our site allow third-party behavioral tracking?

We do not allow third-party behavioral tracking

 

31.      COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

32.      Fair Information Practices

 

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify you via email within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

33.      CAN SPAM Act

 

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

      • Send information, respond to inquiries, and/or other requests or questions

      • Process orders and to send information and updates pertaining to orders.

      • Send you additional information related to your product and/or service

      • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

      • Not use false or misleading subjects or email addresses.

      • Identify the message as an advertisement in some reasonable way.

      • Include the physical address of our business or site headquarters.

      • Monitor third-party email marketing services for compliance, if one is used.

      • Honor opt-out/unsubscribe requests quickly.

      • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at

      • Follow the instructions at the bottom of each email.

         and we will promptly remove you from ALL correspondence.

 

34.      Contacting Us

 

If there are any questions regarding this privacy policy, you may contact us using the information below.

Barefoot Business Solutions / Alison Rose ACMA, CGMA

2139-3151 Lakeshore Rd

Kelowna, BC V1W 3S9, Canada

help@barefootbusinesssolutions.com

Other matters

35.      If you are not happy with our privacy policy

35.1.     If you are not happy with our privacy policy or if have any complaint then you should tell us.

35.2.     If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

35.3.     If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/

36.      Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

37.      Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy policy, please contact us.