1. CUSTOMER PRIVACY STATEMENT
Barefooters Corp Inc. (“Barefooters”) knows that you care about how your Personal Information (as defined in section 3(2)) is used and shared. This notice describes how we treat your information. We are committed to the important goal of protecting your privacy and personally identifiable information. This privacy notice is applicable to any and all services provided on www.mybarefooters.com (the “Website”) and any other domain name that may be operated and/or owned by Barefooters. By visiting the Website, you agree to the terms of this Privacy Statement.
2. OUR COMMITMENT TO PRIVACY
(1) Barefooters is committed to controlling the collection, use and disclosure of the Personal Information (as defined in section 3(2)) provided by its customers.
3. WHAT IS PERSONAL INFORMATION?
(1) “Personal Information” is personally identifiable information such as your name, residential address and e-mail address and includes information about your product and service inquiries and usage of the Website.
(2) Personal Information is collected by Barefooters only when you specifically and knowingly choose to provide it to us such as when you provide your email address to us through the Website or write an email to us containing Personal Information. We may also receive Personal Information from our business partners and other third parties provided that such third parties confirm to us that they have obtained your consent to the disclosure of your Personal Information to us.
(3) Publicly available information, such as a public directory listing of your name, address, telephone number and electronic address, is not considered Personal Information.
4. COLLECTION AND USE OF PERSONAL INFORMATION
(1) Barefooters collects and uses your Personal Information primarily for the purpose of sending you emails about updates to the Website, about new store openings, about information on new products and services, and in order to respond to your questions concerning Barefooters, our products and services.
(2) Your Personal Information is used to communicate with you about your requests and to provide you with information related to Barefooters and our products and services. If you indicated that you were interested in receiving offers or information from selected sponsors or advertisers, your Personal Information would also be used to contact you or to send you e-mail materials and other mailings about products and services that might be of interest to you. You always have the option, however, to tell us not to share your Personal Information or to exclude you from offers for other products or services or to remove you from our mailing list.
(3) Barefooters may also contact you from time to time to conduct market research and surveys in an effort to continually improve our product and service offerings.
(4) Unless you specifically authorize us to release your Personal Information, or release is required or permitted by law, Barefooters will not sell, lease or trade your Personal Information to other third parties.
(5) Anonymous or “non-personal” information gathered by Barefooters through our Website may be used for technical, research and analytical purposes. Information collected through surveys, existing files and public archives may be used by Barefooters to analyze our markets and to develop or enhance service offerings.
(6) Barefooters will only ask for information about you that we need and will only ask for it when we need it. When we ask you for the information, we will explain to you why we need it and what we are going to do with it.
(7) We will seek your prior consent to the collection, use and disclosure of the information as required by applicable privacy legislation. Subject to legal and contractual requirements, you can refuse to consent to our collection, use or disclosure of information about you. You may also withdraw your consent to any further collection, use or disclosure of information about you at any time by giving us reasonable notice. If our intended disclosures or uses of information change, we will notify you accordingly.
(8) Your Personal Information will not be used for any other purpose without your consent.
To enable us to more efficiently provide the products and services you have requested from us, Barefooters may share your Personal Information with selected third parties who are acting on our behalf as our agents, suppliers or service providers. Such third party service providers are provided only with such information as is necessary in the circumstances. Information provided to third parties may be used only for the purpose stipulated and is subject to strict terms of confidentiality.
(1) Barefooters uses a browser feature called a cookie to collect information anonymously and track user patterns on our Websites. A cookie is a small text file that is placed on your hard disk by a website. “Cookies” contain a unique identification number that identifies your browser, but not you, to our computers each time you visit our Website. Cookies tell us which pages of our Website are visited and by how many people.
Barefooters will try to ensure that information about you is accurate, complete and up-to-date. However, please inform Barefooters of any change of name, address or other information. In the event you have questions about the accuracy of factual information we have collected about you, you will have access to that information in order to verify and update it. If we have disclosed inaccurate information about you to a third party, we will be pleased to contact the third party in order to correct the information.
Barefooters is committed to protecting your privacy. Security measures, such as locked filing cabinets, restricted access or the use of passwords and encryption have been adopted to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Our employees have been trained to respect your privacy at all times and those employees with access to your Personal Information shall use your Personal Information strictly in accordance with our Privacy Statement and the laws applicable to each specific business.
(1) If you have any questions about the collection, use or disclosure of your Personal Information or if you simply want to know whether we have any of your Personal Information on file, you may contact us. Except in limited circumstances, as specifically provided by applicable privacy legislation, Barefooters can tell you whether they hold Personal Information about you. They can tell you the source of the information, allow you access to your Personal Information and find an account of the use that has been made or is being made of the information and the third parties to which it has been disclosed.
(2) Barefooters will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation. If Barefooters refuses access to you, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. Barefooters will respond to your requests for access in accordance with applicable privacy legislation.
10. QUESTIONS OR CONCERNS
(2) Barefooters has procedures in place to receive and respond to complaints or inquiries about its handling of Personal Information. They will describe the complaint procedures to anyone who makes inquiries or lodges complaints.
(3) If you are not satisfied with the response from us after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.
(1) The foregoing policies are effective as of the “Last Update” date stated above. Barefooters reserves the right to change this policy at any time with reasonable notice to users posted on the Website of the existence of a new Privacy Statement. This statement and the policies outlined here are not intended to and do not create any contractual or other legal rights in or on behalf of any party.
12. TEN PRINCIPLES OF FAIR INFORMATION PRACTICES
(1) Accountability. Barefooters is responsible for the Personal Information under its control and shall designate one or more individuals who shall be accountable for the company’s compliance with the procedures and principles set out in our Privacy Statement.
(2) Identifying Purpose. Barefooters will identify the purpose for which Personal Information is collected at or before the time the information is collected. The purposes for which information is collected, used or disclosed by Barefooters must be those that a reasonable person would consider are appropriate in the circumstances.
(3) Consent. The knowledge and consent of the individual are required for the collection, use or disclosure of Personal Information, except where consent is not required by privacy legislation, for example, where the collection, use or disclosure of Personal Information is solely for journalistic, artistic or literary purposes.
(4) Limiting Collection. Barefooters shall limit the collection of Personal Information to that which is necessary for the purposes identified by the company. Personal Information shall be collected by fair and lawful means.
(5) Limiting Use; Disclosure and Retention. Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information shall be retained only as long as necessary for the fulfillment of the purposes for which it was collected.
(6) Accuracy. Personal Information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
(7) Safeguards. Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.
(8) Openness. Barefooters shall make readily available to its customers and employees specific information about its policies and practices relating to the management of Personal Information.
(9) Individual Access. Upon request, an individual shall be informed of the existence, use and disclosure of his or her Personal Information and shall be given access to that information except where Barefooters is permitted or required by law not to disclose Personal Information to the individual customer or employee. An individual customer or employee shall be able to challenge the accuracy and completeness of the information disclosed to him or her and have it amended as appropriate.
(10) Challenging Compliance. An individual customer or employee shall be able to address a challenge concerning compliance with the principles in our Privacy Statement to Barefooters.