The following Privacy Policy ("Privacy Policy") applies to every use of the Application (as defined below). This Privacy policy is made by Barterchain Limited, having its registered office at Connaught House, 1 Burlington Road, Dublin 4, Ireland (VAT number: 4029993WH) (referred to as " Barterchain" or "we", "us", "our", "ours").
For the purposes of this Privacy policy, we are the Data Controller.
We are committed to protecting the privacy of every user of Barterchain.
We want to stress that, as a pure intermediary, our mission, when collecting data, is philanthropic, to provide users the best experience possible.
Barterchain is an online platform (through website and application) which connects users with the intention of bartering services with each other.
Barterchain’s Service operation and features are explained in depth in the Barterchain Terms and Conditions, which the user accepts when joining the platform.
Barterchain’s Service can be called, to the extent of this Privacy policy, as “Barterchain” or as the “Service” or as the “Application”.
The purpose of this Privacy policy is to inform you about:
the types of information we collect about you,
how we may disclose it to third parties.
As a consequence, it is your responsibility to check out the applicable privacy policies and/or terms of use.
"Adequate Jurisdiction": a jurisdiction that has been formally designated by the European Commission as having an adequate level of protection for Personal Data.
"Application": the embeddable, downloadable and/or executable Barterchain software application owned by us.
"Content": any audio or video elements as well as any ideas offered by us or third parties, including but not limited to data, film, video, photographs, software, games, graphics and design elements, portraits and images, artistic works, music, sound, information and other services and materials, tangible and intangible, including derivative works, in any and all media and formats, existing or future.
"Data Controller": the entity that decides if how and why to Process Personal Data.
"Data Protection Authority": the independent public authority formally charged with overseeing and ensuring compliance with existing and applicable data protection regulations.
"EEA": the European Economic Area.
"Materials": all Content, Subscribed Content (where applicable and as better defined below), messaging, blogging, chatting, social networking, information, advertising and/or Internet links, etc., accessible or delivered through the Application.
"Personal Data": information about a natural person or information from which a natural person is directly or indirectly identified or identifiable, in particular by reference to an identifying element such as a name, an identification number, geographic locations, online identifiers or by reference to one or more physical, psychological, genetic, mental, economic, cultural or social elements that identify a particular natural person.
"Processing": any operation performed on Personal Data even without the use of electronic means, such as collecting, recording, organizing, storing, processing, modifying, retrieving, consulting, using, communicating, disseminating, or otherwise making available, interconnecting, reducing, erasing, and destroying Personal Data.
"Sensitive Data": any personal data relating to race or ethnicity, political opinions, religious or philosophical beliefs, party or trade union memberships, physical and mental health, sexual habits, judicial information relating to adjudicated or pending criminal proceedings, national identification number, or any other information likely to be considered sensitive under applicable law.
"Site": each and every website operated or maintained by us or on our behalf.
"Standard Contractual Clauses": model transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
"Subscribed Content": any and all content subscribed to, uploaded or "posted" by you, on your behalf, or by other users on or through your Product or Smart Services.
we may collect Personal Data about you from the following sources:
We may process the following categories of Personal Information about you to the extent that such processing is strictly necessary in relation to the processing purposes defined in this Privacy policy (by way of example rather than as an exhaustive list):
We are committed to the protection of Children's Personal Data and recognize that parents, guardians, or other adults may swap a service or talent in the interest of family or in the interest of minors.
In some cases, when it’s not specified who will benefit from the service, particularly where information is collected electronically, we may not be able to determine whether the information was collected from children under the age of eighteen (18) and we will treat such information as if it had been provided by an adult.
In the event that we are informed that a child under the age of eighteen (18) has provided Personal Data, we will use reasonable efforts to remove such information.
We encourage parents and guardians to participate in all of their children's online activities and to prevent them from providing Personal Data to us through the Application.
In processing your Personal Data with reference to the processing purposes defined in this Privacy policy at Section 6, we may refer to one or more of the following legal basis, depending on the circumstances:
with us;
We do not intend to collect or otherwise process your Sensitive Data in the normal course of our business. If, for whatever reason, it becomes necessary to process your Sensitive Data, we refer to one or more of the following legal basis:
We may process your Personal Information for the following purposes:
Financial management: sales; finance; corporate controls; vendor management.
We may combine Personal Data and Non-Personal Data collected to provide and improve the services offered. From time to time, we may also, transfer or combine Personal Data collected off-line with our online databases or electronically store information collected off-line. We may also combine Personal Data collected online with information made available from other sources, including information received from our affiliates, marketing or advertising companies. If we combine Non-Personal Data with Personal Data, the information so combined will be treated as Personal Data in accordance with this Privacy policy for as long as the same data remains combined.
We can share the information indicated in this Privacy policy. This section describes how we share that information. We will disclose your Personal Data only and to the necessary extent:
to comply with applicable law;
to create, exercise or defend our rights;
to the extent necessary in connection with the sale or reorganization of a substantial part of our business.
With our and our affiliates' staff, employees, contract counterparties, agents, to help us provide or improve services related to the Application.
With our professional consultants.
With third parties and their related advisors in connection with mergers, acquisitions, bankruptcy, dissolution, reorganization, total or partial sale of Barterchain's assets, financial activities, total or partial disposal of our assets, or similar transactions or procedures, as well as activities preliminary thereto (for example, due diligence).
Where required or permitted by applicable laws and regulations.
With any party relevant to the prevention, investigation, detection or action with respect to crimes or in execution of criminal convictions, including protection against and prevention of threats to public safety.
With any relevant party, guarantor authority or court, to the extent necessary for the establishment, exercise and defense of rights.
With public or private authorities, upon request, i.e., for the purpose of reporting any actual or potential violations of applicable laws and regulations.
With carefully selected third parties, including suppliers or business partners, where necessary to provide a service to us or to perform a function on our behalf in connection with the Application. Any disclosure by us of your Personal Data to a carefully selected third party or to any third party mentioned in this Privacy policy, we will comply with data protection legislation, ensuring that the third party has put in place all measures to keep your data secure, does not use your Personal Data for purposes other than and in addition to those specified by us and in accordance with our purposes set out in this Privacy policy.
With other third parties solely at your discretion and with your express consent and for the purposes you request.
Third parties that offer Applications, Services or Materials on the Application may collect Personal Data or Non-Personal Data when you access their Applications, Services and Materials. We are not responsible for the data collection and privacy policies in use by such third parties or their services, and they may collect data about you and may share it with us and/or others. Third parties and their services may also track you over time and space, submit their own advertisements (including "interest-based" advertisements) to you, and may or may not have published privacy policies of their own.
In addition, as you use the Application you may be directed to other services that are provided and controlled by third parties and that we do not control. For example, if you browse the Internet and "click" on a link on one website, the link may take you to a different website. We encourage you to note when you access a new website or application and to review the privacy policies of all third parties involved and pay attention in connection therewith. We are not responsible with respect to the availability, completeness and accuracy of such third parties’ privacy policies or disclosures.
We undertake to make every reasonable effort to ensure that:
your Personal Data processed by us is accurate and, where necessary, kept up to date; and
any and all of your Personal Data processed by us that is inaccurate (having regard to the purposes for which it is processed) is deleted or amended without delay.
From time to time, we may ask you to confirm the accuracy of your Personal Data.
We undertake to make every reasonable effort to ensure that your Personal Data processed by us is limited to that which is strictly necessary in relation to the purposes set out in this Privacy policy.
We undertake to put in place all reasonable efforts to ensure that your Personal Data processed by us is Processed for only the minimum period necessary in relation to the purposes set out in this Privacy policy.
The criteria for determining how long your Personal Data is retained are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as necessary in connection with the purposes set forth in this Privacy policy, unless applicable law requires a longer period of retention of your Personal Data. In particular, we may retain your Personal Data for as long as necessary to create, exercise or defend a right of ours.
In relation to applicable law, you may have rights with respect to the Processing of your Personal Data for which we are the Data Controller, which include:
the right not to provide us with your Personal Data (however, please note that in such a case we may not be able to provide you with all the Services that you request if you do not provide us with your Personal Data);
the right to request access to, or copies of, your Personal Data, together with information related to the nature, Processing, disclosure of such Personal Data;
the right to request rectification of any inaccuracies in your Personal Data;
the right to request information about the legitimate basis;
the deletion of your Personal Data;
the limitation of the Processing of your Personal Data;
the right to object, on legitimate basis, to the processing by us or on our behalf of your Personal Data;
the right to obtain certain transfers of Personal Data to other Data Controllers, in a structured, practically used and digitally readable format, within applicable purposes;
where we process your Personal Data on the basis of your consent, the right to withdraw your consent (provided that such withdrawal does not invalidate any Processing lawfully carried out prior to the date on which we receive notice of such withdrawal nor prevent Processing of your Personal Data done in reliance on any other legal basis);
the right to lodge complaints before a Data Protection Authority in connection with the Processing by us or on our behalf of your Personal Data.
The above is without prejudice to your non-derogable rights.
Should you wish to exercise any of the above rights, please contact us through our dedicated e-mail address info@barterchain.io
In this regard, please note that:
we may require proof of your identity before granting effect to the aforementioned rights invoked;
if your request involves the ascertainment of additional facts (for example,, a determination with respect to the non-compliance of certain processing with applicable law) we will evaluate your request in a reasonably short time before deciding what action to take.
If we receive a valid request to grant effect to any of the foregoing invoked rights, we will make every reasonable effort within one (1) month or, to the extent permitted by applicable law, as soon as reasonably practicable.
Should you request removal of your Personal Data, you acknowledge that your Personal Data may continue to exist in a non-deletable form that would be difficult or impossible for us to locate, and that for file storage purposes, we reserve the right to retain any information removed from, or changed in, our active databases for non-commercial purposes including dispute resolution, problem resolution and enforcement of this Privacy policy.
The above rights do not apply to our collection of Non-Personal Data. We reserve the right to deny processing of data removal requests that are impractical or that affect the privacy of others. Refusal to Process data removal requests must be justified by applicable law.
All users of the Application are required to provide true, correct, complete and accurate Personal Data when requested, and we will reject and delete any data that
we in good faith believe to be incorrect, false, falsified or fraudulent, or inconsistent with, or in violation of the Privacy policy.
Our website uses different types of cookies each of which has a specific function, as indicated in the Cookie policy.
We take the security of your Personal Information seriously. We maintain physical, administrative, and organizational protections designed to preserve the confidentiality and security of your Personal Data. Unfortunately, the transmission of information over the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through your use of the Application. Any transmission of Personal Data is at your own risk. We are not responsible for circumventing all privacy settings or security measures for the Application.
We may offer boards or other public features on the Application, and any of your "posts" in those public spaces are considered public information that is available to other users.
We do not control, and are not responsible for, the actions of other users of the Application with respect to any information you "post" in such spaces. In addition, information you release in public spaces may be collected and used by other users to send unsolicited messages to you and for ulterior purposes.
Any "postings" to bulletin boards and public spaces on the Application are governed by the terms and conditions of the applicable third-party websites. Portions of your user profile may also be available to other users, and you should take care not to use Personal Data in your user name or other information that may be publicly available to other users.
We may transfer and store Personal Data that you provide to us in connection with your use of the Application on servers located in countries outside your jurisdiction. We may also transfer Personal Data collected from you in other countries outside your jurisdiction to Barterchain or to third parties mentioned in this Privacy policy to the extent such transfer is necessary for the purpose of fulfilling our obligations under this Privacy policy.
Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in an Adequate Jurisdiction, we do so on the basis of Standard
Contractual Clauses. You may make a request for a copy of our Standard Contractual Clauses using the contact information provided in Section 9 ("Your Rights") of this policy.
We reserve the right to amend this Privacy policy at any time and for any reason, and we will post any amendments to this Privacy policy within a reasonable time after they become effective. This Privacy policy will remain in full force and effect for as long as you remain a user of the Product, even if your use of, or participation in, a particular service, feature, function, or promotional activity, terminates, expires, ceases, is suspended or disabled for any reason.
Please feel free to direct any further questions you may have with respect to this Privacy policy to the e-mail address: info@barterchain.io
Last update 20 December 2022