Last updated: March 23, 2021
We are committed to protecting your privacy and respecting it. But we need to use your Personal data to provide and improve the service. By using the service,
- any Bareways app,
- any subscription service provided by or via a Bareways app, and/or
- a Bareways website,
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Account means a unique account created for you to access our service or parts of our service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application means the software program named Bareways or with any other name provided by Bareways GmbH and downloaded by you on any electronic device,
Business, refers to the company as the legal entity that collects consumers’ personal information and determines the purposes and means of the processing of consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information.
Company (referred to as either “the Company”, “We”, “Us”, “Our” or Bareways GmbH in this Agreement) refers to Bareways GmbH, Maria-Goeppert-Str. 3, 23562 Luebeck, Germany.
For the purpose of the GDPR, the company is the data controller.
Consumer , means a natural person.
Country refers to: Schleswig-Holstein, Germany
Data Controller , for the purposes of the GDPR (General Data Protection Regulation), refers to the company as the legal person which alone or jointly with others determines the purposes and means of the processing of personal data.
Device means any device that can access the service such as a computer, a cell phone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Facebook Fan Page is a public profile named Bareways specifically created by the company on the Facebook social network, especially, but not limited to,https://www.facebook.com/bareways
Personal Data is any information that relates to an identified or identifiable individual.For the purposes of GDPR, personal data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA, personal data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
Sale , means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information to another business or a third party for monetary or other valuable consideration.
Service refers to the application, the Bareways app, or any other service provided by Bareways GmbH.
Service Provider means any natural or legal person who processes the data on behalf of the company. It refers to third-party companies or individuals employed by the company to facilitate the service, to provide the service on behalf of the company, to perform services related to the service or to assist the company in analyzing how the service is used. For the purpose of the GDPR, service providers are considered data processors.
Third-party Social Media Service refers to any website or any social network website through which a user can log in or create an account to use the service.
Usage Data refers to data collected automatically, either generated by the use of the service or from the service infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service, as applicable.Under GDPR (General Data Protection Regulation), you can be referred to as the data subject or as the user as you are the individual using the service.
Collecting and Using Your Personal Data
General Service description
Bareways develops and provides data services for routing and navigation with a focus on rural environments. We use a large number of data sources, including but not limited to maps, sensors, road agencies, weather, satellites, GPS- and Wifi-positioning, mobile phones and vehicle sensors, to predict the drivability of roads and other vehicle tracks worldwide as well as provide other location specific services. Our core technology for analytics is artificial intelligence, especially machine learning and deep learning. We use your location information from your mobile phone or other device to provide a specific routing and/or navigation service and/or display your current location on a map or other digital service.
To constantly improve the service provided by Bareways we need to understand our users and the usage of the services. This helps to provide relevant services and improve the provided data to our customers. To do this, we securely and anonymously need to record and store usage data. In order to provide you with relevant services in relevant areas, your location and your destinations you browse may be processed. This data is also used to decide in which regions we should enhance our services and/or which kind of services we should offer.
You can provide us with personal data, as your email address, your contact details, or specifics of your used vehicle so we can manage your account and provide you with more customized services and contact you about your account and new or improved services. We will not use your contact details for any marketing or advertisement if you have not explicitly approved so and, of course, you may opt out of such communications at any time.
Some of your contact information may be part of a public profile on the Bareways service. The amount of data provided publicly can be managed by you, you can add and remove content and you shall have the right to opt out at any time.
If you are part of the Bareways early access Beta program, we will use your contact details to distribute new versions of the service to you. We would encourage and ask you to provide feedback to us on the performance of the Beta release, how you use and like it, how you believe improvements should be made etc. This feedback will be shared solely with our team members to improve the services.
Limitation on age
To use our service you have to be 16 years of age or older. If you are under 16, you may not download or use the service.
Types of Data Collected
While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Usage data, including, but not limited to, your location, routes that you browse, plan or make, other search inquiries, favourites, car details, calendar information, data that you look at etc.
- Data that you choose to share with us, such as but not limited routes, places, screenshots, voice or audio data.
Usage data is collected automatically when using the service.
Usage Data may include information such as your device’s internet protocol address (e.g. IP address and other information from sensors and receivers on or around your device), browser type, browser version, how long you use our services, the pages of our service that you visit, the searches you make, GPS signals (combined with a timestamp), the destinations, venues and routes you browse or take, communication with other users of our services if the communication is done via our services, marked or preferred locations and routes, your views, ratings, and interactions with our service or content, the time and date of your visit, the time spent on the pages, unique device identifiers and other diagnostic data, as well as your activities on other services and apps if you choose to link your Bareways account to them or use them via our services.
When you access the service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your location, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, sensors and diagnostic data.
We may also collect information that your browser sends whenever you visit our service or when you access the service by or through a mobile device.
Information from Third-Party Social Media Services
The company may allow you to create an account and log in to use the service through the following third-party social media services:
If you decide to register through or otherwise grant us access to a third-party social media service, we may collect personal data that is already associated with your third-party social media service’s account, such as your name, your email address, your activities or your contact list associated with that account.
Information Collected while Using the Application
While using our application, in order to provide features of our application, we may collect, with your prior permission:
- Information regarding your location
- Information regarding trips and routes you are browsing
- Pictures and other information from your device’s camera and photo library
We use this information to provide features of our service, to improve and customize our service. The information may be uploaded to the company’s servers and/or a service provider’s server or it may be simply stored on your device.
You can enable or disable access to this information at any time, through your device settings.
Use of Your Personal Data
The company may use personal data for the following purposes:
- To provide, maintain and improve our service, including, but not limited to, to monitor the usage of our service as well as outages, troubleshooting issues or lack of network coverage, analyse and measure our service performance, handle breakdowns and malfunctions, hacking attempts, denial-of-service-attacks (DOS), and other illegal activities and misuse of the service.
- To manage your account: to manage your registration as a user of the service. The personal data you provide can give you access to different functionalities of the service that are available to you as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the service.
- To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, improvements, surveys and questionnaires, or contracted services, including the security updates, when necessary or reasonable for their implementation. You may be asked to allow us to send you push notifications via the service.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
- To manage your requests: To attend and manage your requests to us.
- For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our service users is among the assets transferred.
- For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our service, products, services, marketing and your experience.
We may share your personal information in the following situations:
- With service providers: We may share your personal information with service providers to monitor and analyze the use of our service, to show advertisements to you to help support and maintain ourservice, for payment processing, to contact you.
- For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- With business partners: We may share your information with our business partners to offer you certain products, services or promotions. This may, without limitation, also include service providers that provide tours, guides, services, access to locations, sites, maintenance, etc. that you can or have accessed through our service.
- With other users: When you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.
- With your consent: We may disclose your personal information for any other purpose with your consent.
Retention of Your Personal Data
The company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including personal data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, the company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the company
- Prevent or investigate possible wrongdoing in connection with the service
- Protect the personal safety of users of the service or the public
- Protect against legal liability
Security of Your Personal Data
The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
The service providers, that we use, may have access to your personal data. These third-party vendors collect, store, use, process and transfer information about your activity on our service in accordance with their Privacy Policies.
The data that we collect may be stored on our own servers located in Germany or on third-party servers located in Germany or a destination outside the European Economic Area (EEA). All data including payment transactions are encrypted in transit and stored and processed on state-of-the-art secure servers. Your data may be transferred to the above mentioned servers and also may be processed by staff operating outside of the EEA working for us or the third-party suppliers.
Unfortunately, the transmission of data via the internet cannot be completely secured. But we promise to do our best to protect your data and cannot guarantee the security of it.
We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may use Email Marketing service providers to manage and send emails to you.
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
Legal Basis for Processing Personal Data under GDPR
We may process personal data under the following conditions:
- Consent: You have given your consent for processing personal data for one or more specific purposes.
- Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which the company is subject.
- Vital interests: Processing personal data is necessary in order to protect your vital interests or of another natural person.
- Public interests: Processing personal data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the company.
- Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests pursued by the company.
In any case, the company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The company undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.
- Request access to your personal data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it.
- Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the service.
Exercising of Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The company is the data controller of your personal data collected while using the service. As operator of the Facebook Fan Page https://www.facebook.com/bareways, the company and the operator of the social network Facebook are joint controllers.
The company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook terms of service: https://www.facebook.com/terms.php
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about our users.
For this purpose, Facebook places a cookie on the device of the user visiting our Facebook Fan Page. Each cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F: Internet or other similar network activity.
Examples: Interaction with our service or advertisement.
Category G: Geolocation data.
Examples: Approximate physical location.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Under CCPA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from the forms you complete on our service, preferences you express or provide through our service, or from your purchases on our service.
- Indirectly from you. For example, from observing your activity on our service.
- Automatically from you. For example, through cookies we or our service providers set on your device as you navigate through our service.
- From service providers. For example, third-party vendors to provide advertising on our service, third-party vendors for payment processing, or other third-party vendors that we use to provide the service to you.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
- To operate our service and provide you with our service.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our service.
- To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- For internal administrative and auditing purposes.
- To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of your Personal Data” section.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category D: Commercial information
- Category F: Internet or other similar network activity
- Category G: Geolocation data
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of personal information:
- Category A: Identifiers
- Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Category D: Commercial information
- Category F: Internet or other similar network activity
- Category G: Geolocation data
Share of Personal Information
We may share your personal information identified in the above categories with the following categories of third parties:
- Service providers
- Payment processors
- Our affiliates
- Our business partners
- Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
Sale of Personal Information of Minors Under 16 Years of Age
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
- The right to notice. You have the right to be notified which categories of personal data are being collected and the purposes for which the personal data is being used.
- The right to request. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom we share that personal information
- The specific pieces of personal information we collected about you
- If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
- The right to say no to the sale of personal data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request please contact us.
- The right to delete personal data. You have the right to request the deletion of your personal data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Exercising Your CCPA Data Protection Rights
In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us:
By email: firstname.lastname@example.org
By visiting this page on our website: https://www.bareways.com
By mail: Bareways GmbH, Maria-Goeppert-Str. 3, 23562 Luebeck, Germany
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.
Your request to us must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it
We cannot respond to your request or provide you with the required information if we cannot:
- Verify your identity or authority to make the request
- And confirm that the personal information relates to you
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period preceding the verifiable request’s receipt.
For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
Do Not Sell My Personal Information
You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our service does not respond to Do Not Track signals.
However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.
Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.