BARKLE PRIVACY POLICY

Welcome to the Barkle Group Privacy Policy. Whether you’re ready to help your furry friend make connections or just looking for dog-friendly activities, at Barkle, we believe every relationship and opportunity should start with respect and equality… especially when it comes to your personal information.

BARKLE WAS ORIGINALLY FOUNDED TO CREATE SAFE CONNECTIONS FOR DOGS AND THEIR OWNERS.

And now, we’ve evolved into a tool that empowers dog owners to connect safely and build community.

When we talk about Barkle Group, we refer to Barkle Holding Limited, Barkle Trading Limited and Barkle Trading LLC (also known simply as “Barkle”, “we”, “us”, or “our” in this policy). This Policy explains how we process your personal information. It applies any time you’re using the Barkle mobile application or desktop version (“App”), and to your use of our “Sites”, which includes our websites like gogobarkle.com, microsites, and other digital products and services, like our competitions or surveys. We also suggest you read our Terms and Conditions of Use.

Have any questions about this Policy?
Just Contact Us and we’ll be happy to help.

GOOD TO KNOW

We will need to change this Policy from time to time, but the most current version (at http://gobarkle.com/privacy-policy) controls how we use your information. Be sure to regularly check for updates, but we will let you know by email or notice of any material or significant changes.

WHAT DO WE COLLECT?

You Make the First Move by using the Barkle App or Sites, which is when we collect some information about you. While enjoying our App and Sites, you can also choose to share information with people you connect with, such as other members or your friends and contacts.

We are responsible for taking care of all the personal information we collect and you share with us. According to the General Data Protection Regulation (“GDPR”) of 27 April 2016 and other applicable personal data laws, we are the data “controller” for all personal information collected and processed through our App and Sites.

What you’ll find in this section

1. Registration Information
2. Linked Social Media Information
3. Profile Verification and ID Verification Information (including biometric information)
4. Purchase Information
5. Geolocation Information
6. Device Information
7. Photo Information
8. Link Information
9. Messages
10. Barkle Success Stories, Surveys, and Other Contributions Information
11. Customer Support Contact Information
12. Cookies and Similar Technology Information

The type of information collected or shared depends on the specific situation and what exactly you are doing.

You will not be able to change your date of birth and, if you give Barkle access to your location in your device settings, your location is automatically updated based on the location of your device. Others using the App might be able to see some of your Registration Information when they view your profile page, such as your sexual preference, name, and username.

1. REGISTRATION INFORMATION

When you download the App and create a Barkle account, we collect certain information about you to help enhance the App and verify the people using it. This can include:

Name

Username

Gender identity

Location

Email address

Date, time and location of birth

Photographs

Mobile number

Dog Information (name, breed, age, size, temperament, vaccination status, health conditions, behavioral history)

After you register, you can change this information at any time through your account. You are responsible for making sure your account details are kept up to date, particularly if your phone number changes.

2. LINKED SOCIAL MEDIA INFORMATION

We want to help simplify and enhance your connecting. One way we do this is by making it possible for you to use your other social media accounts during your Barkle experience. Just be aware that it means sharing with Us some of the personal data you shared with these social networks.

Using social media accounts to register or sign in to Barkle

Facebook: If you choose to register or sign in using your Facebook account, you give Facebook permission to share your name and profile picture with us. And, unless you choose to opt-out of sharing these details, you also give Facebook permission to share your:

email address (if there is one associated with your Facebook account)
date of birth
other profile photos
gender
pages you like
current town or city

Apple ID: If you choose to register or sign in with your Apple ID, you give Apple permission to share with us:

your Apple login
a name (which you can edit)
an email that will be linked to your Barkle account and used to retrieve it

You can choose to use your personal email, or Apple will create and use a random email address so your personal email can stay private.

We will then use the personal information we receive from Facebook or Apple to form your Barkle account. If you remove the Barkle app from your Facebook settings or Apple ID, we will no longer have updated access to this information.

Linking social media accounts to your Barkle account

You can link your Barkle account with your Instagram, Facebook, or Spotify accounts. This allows you to share some information from those accounts directly to Barkle, like your Instagram photos or top Spotify artists.

You decide with Instagram/Facebook/Spotify what limited information we receive when you first link these accounts to your Barkle account.

If you want to disconnect any linked social media accounts from Barkle, just visit your settings in Instagram, Facebook, or Spotify and follow the instructions to remove the Barkle App access permissions.

GOOD TO KNOW

If you unlink a social media account, this does not automatically delete the information that was already added to your Barkle account. If you’d like this information removed, you must also delete it within your Barkle account.

3. PROFILE VERIFICATION AND ID VERIFICATION INFORMATION (INCLUDING BIOMETRIC INFORMATION)

We want to ensure the safety and security of everyone on our App and Sites, and give people the best possible user experience. To do this, we require every person using our App and Sites to verify their accounts.

This means we might ask for your phone number and, in some cases, ask that you carry out a photo verification or ID verification. This allows us to make sure the people on Barkle are actually people, that are of age, avoid fake accounts that can be used for malicious activities and cybercrime, and prevent fraud – all of which can threaten the Barkle network and spoil things for everyone.

You can also choose to (i) verify your photo voluntarily, which will allow you to add a grey “verified” badge to your profile, and (ii) verify your identity with your ID document, which will allow you to add a blue “verified” badge to your profile. If you choose to verify your profile photo, we will scan each photo that you submit. This scan can include the use of facial recognition technology to compare the submitted photo(s) to your profile photo, which helps us make sure you are who you say you are. If you choose to also verify your ID, our third party partner called Veriff will carry out the ID check on our behalf. Veriff will compare a selfie you take to your ID document. This scan can include the use of facial recognition technology, but you also have the option to request a manual review if you do not want facial recognition technology to be used.

When you choose to verify your photo, we do not add verification photos to your profile, but we do keep the scans to verify you in the future and for our records. We will only keep the scans as long as we need them for these purposes, but never longer than 3 years after your last interaction with us. Once we no longer need the scans or the 3 years have passed, we will take reasonable business steps to permanently and securely delete the scans from our systems. When you choose to also verify your ID, your selfie and your ID are compared by our third party partner, Veriff. Veriff will retain your selfie and the picture of your ID for up to 72 hours. You can read more about Veriff’s privacy practices here. For members in South Korea, ID verification will be conducted manually. Before submitting your government-issued document, please ensure that all information is redacted other than your name, photo, date of birth, sex, and document expiry date. For members in countries where the collection of identification numbers is not permitted, Barkle's verification process automatically redacts any individual identification code from government-issued ID documents immediately upon receipt. The original image is permanently deleted after redaction, ensuring that the code is neither stored nor viewed by a human as part of a manual verification process.

GOOD TO KNOW

If your account is blocked for any reason, our anti-fraud and anti-spam procedures might also block your account(s) on our other platforms and applications, such as Badoo.

4. PURCHASE INFORMATION

If you decide to purchase any of our premium services, we will process your payment information and securely keep it for audit/tax purposes and to prevent fraud.

To prevent fraudulent payments from being processed, we use automated decisions and our systems check payment information and transactions for behaviour that might violate our Terms and Conditions of Use. We may automatically block any transaction that is likely to be fraudulent and meets the relevant criteria suggesting a violation. If a transaction is blocked, the relevant person will be notified that their transaction cannot be processed and can contact us to contest the decision.

GOOD TO KNOW

You can always turn off geolocation if you ever change your mind about giving Barkle access to your location by:

iPhone — go to settings > security and privacy > location services > Barkle
Android — go to settings > location > Barkle > permissions > location

5. GEOLOCATION INFORMATION

If you give Barkle access to your location in your device settings, we will collect information about your location when you use your mobile device. We do this to personalise your App experience and make it easier for you to make connections and interact with others.

This can include information about WiFi access points and your longitude/latitude, and we can save your device’s coordinates to offer certain features to you.

For example, by enabling your general location information to appear to people seeing your profile and show you the profiles of people who are near you.

6. DEVICE INFORMATION

When you use the App, we can collect information about your device for the purposes described in this Policy. This can include your device’s unique identifier, model, and operating system, as well as log and usage data. You can also choose to give our App access to your device’s address book, which will only be used when you want to add someone to your contacts.

7. PHOTO INFORMATION

We want to help you put your best foot forward, so we collect data about your profile photos that allows us to arrange them in a way that is favourable to you. This includes data such as which photos people spend the most time looking at or which have the best lighting, etc. You can opt-out of this feature through our app settings at any time.

8. LINK INFORMATION

You might come across some links while using our App or Sites. If you use them, we can keep track of how you interact with links, including to third-party services that we are not responsible for, by monitoring redirecting clicks or other methods.

9. MESSAGES

We review the content of messages sent in the App to identify topics, sentiments, and trends across our Users. We will take steps to remove personally identifying information from such messages, prior to reviewing them. We will not share the content of User messages or information we derive from them with any third party.

10. BARKLE SUCCESS STORIES, SURVEYS, AND OTHER CONTRIBUTIONS INFORMATION

From time to time, we may contact you to see if you would like to take part in a research survey, provide feedback or a testimonial, or be part of a marketing campaign. For example, if you let us know you found a match on the App, we might ask if you want to be featured in Barkle advertising. We will provide you with more information when we contact you with any such request.

You can always say no and your participation is completely optional, but if you don’t want to be contacted regarding these requests, just tell our Customer Support Team via our Feedback Page.

11. CUSTOMER SUPPORT CONTACT INFORMATION

If you contact our Customer Support team via our Feedback Page, we can track your IP address and will receive your email address and the information you share with us to help resolve your request.

We keep records of our communications with you for 6 years after your account is deleted, including any complaints from you about other people using the App or Sites.

12. COOKIES AND SIMILAR TECHNOLOGY INFORMATION

When you use our App or visit our Sites, we can collect personal data from you automatically by using cookies or similar technologies.

Some cookies are necessary for the App and Sites to function and cannot be switched off, but you do have choices for others. Check out our Cookie Policy to learn more about cookies, how we use them, and your options for these technologies.

What’s a cookie?

A cookie is a small file placed on your device or internet browser that allows us to recognise and remember your preferences. Cookies generally help us better personalise and improve your experience on our App and Sites.

HOW DO WE USE YOUR INFORMATION?

Our main goal: give you an enjoyable Barkle experience as you connect.

What you’ll find in this section

1. Using Your Information
2. Our Matching Algorithms
3. Moderation Practices
4. Lawful Basis

GOOD TO KNOW

We will only use your information for email direct marketing if you consent when creating your account or in the App settings. If you ever change your mind, you can always withdraw from marketing in the App settings or by using the opt-out tools and links provided in our communications.

1. USING YOUR INFORMATION

To achieve our goal of giving you an enjoyable connection experience, we use your personal information to:

offer our services and features to you
contact you with information about the App, such as updates and new features
personalise the App, Sites, and content we deliver to you
carry out research and analysis about how you use and interact with the App and Sites
test new technologies and processes meant to enhance and improve the App and Sites
resolve disputes, troubleshoot problems, and enforce our Terms and Conditions of Use
investigate fraud and protect our legal rights
protect third parties and the people on our App and Sites from harm

if you’ve signed up for our communications or otherwise consented, send you information by direct marketing and other communication methods about our promotions and offers, such as letting you know the types of goods, services, and offers we provide.

This allows us to understand how close you are to others and show you profiles of people nearby.

2. OUR MATCHING ALGORITHMS

We want to help you find the best possible connections, so we developed matching algorithms to predict your compatibility with others and show you people we think are a good match for you.

To predict your compatibility with others and recommend profiles, our matching algorithms use:

the information you share about yourself in your profile
information about your activity on the App
whether you’ve verified your photo
your device coordinates

To be clear

If you post anything that is inconsistent with our Terms and Conditions of Use, we can restrict your account access or terminate it altogether.

3. MODERATION PRACTICES

Safety on our App and Sites is very important to us, so we take steps to make sure every person follows our Terms and Conditions of Use while connecting. We use a combination of automated systems and a team of moderators to monitor and review accounts and messages for content that suggests a violation of our Terms and Conditions of Use. This process involves some personal information, such as photos and any other information uploaded to a profile or shared in messages.

We will issue a warning to the relevant account if any account or message meets the relevant criteria suggesting a likely violation. We can also restrict or block the relevant user’s access, who can contact Barkle to contest the decision.

GOOD TO KNOW

If the legal basis is consent, you can withdraw your consent at any time. If the legal basis is legitimate interests, you have a right to object to how we use that information.
How? Just contact us or follow the instructions provided in the relevant sections of this Policy.

4. LAWFUL BASIS

According to European Union (“EU”) and United Kingdom (“UK”) data protection laws, processing personal information must always have a specific lawful basis – meaning there must always be a legal reason, which is defined by the GDPR and other relevant laws. Here you will find the legal basis for all of the personal information we collect, use, and process.

What about the CCPA categories?

You will see some of the CCPA’s specific categories of personal information mentioned under the section for Californian residents. You can find more information about these categories here.

Why we use your information	What information we use	Where we get the information	Our legal basis
To provide you with the Barkle social networking service and App.	Name Email address Date of birth Location App activity	You provide us with your name, email address, and date of birth. We get location and app activity data from the device you use to access the service.	Contractual Necessity
To facilitate networking opportunities on the App.	Optional information that you choose to share in your profile, through profile verification, or by adding Barkle badges, which may include information about your: photos interests other similar details you choose to share	You choose to provide us with this optional information	Contractual necessity Our legitimate interests in facilitating or assisting in the making of networking opportunities on the App. Your consent for special category/sensitive personal information.
To verify your identity, prevent fraud, and ensure the safety and security of everyone using the App and Sites.	Phone number If requested or permitted, photo provided for profile verification If requested or permitted, photo of Government ID and selfie for ID verification For users based in countries where age verification is legally required: photo of Government ID geolocation and device information	You provide us with your phone number and photos. We get geolocation and device information from the device you use to access the Barkle social networking service.	Our legitimate interests in making sure accounts are not set up fraudulently and to protect people using our App or Sites.
To take payments for premium services.* *This does not apply if you make payments via the Apple App Store.	Payment card details	You provide us with this information.	Contractual necessity
To send you marketing information about our events, offers, and services.	Name Email address Postal address Instagram handle Mobile phone number	You provide us with this information.	Consent Our legitimate interests in promoting our business and products, while following all laws that apply to our marketing activities.
To carry out research and analysis to help us improve the App, and test new technologies and processes meant to enhance and improve the App and Sites	Log and usage data, including: IP address browser type referring domain pages accessed mobile carrier Search terms, images, and video Registration information Profile information	We get log and usage information from the device you use to access the Barkle social networking service. You provide us with the other information.	Our legitimate interests in analysing how people access and use our services, and testing new technologies so that we can further develop the App, implement security measures, and improve the service.
To respond to correspondence and requests submitted to us, including social media queries.	Email address Social media name Phone number IP address the information you send to us to help resolve your query	You provide us with your email address, social media name, and phone number when you contact us. We get your IP address from the device you use to contact us.	Our legitimate interests in responding to requests and queries, and making sure we provide good service and troubleshoot problems.
To enable a profile-sharing functionality	Name and photo Time and location of a date	When using the profile-sharing functionality with your trusted contact, you provide the time and location of the date and share the matched user's name and profile photo.	Our legitimate interests in preventing unauthorised behaviour, and maintaining the safety of our users and services.
To investigate and block people for reported infringements of our Terms and Conditions of Use.	Name Registration information Profile information Message content Photographs Usage and device data, including: IP address IP session information	You provide us with your registration information, profile information, messages, and photographs. We get the other information from the device you use to access the Barkle social networking service.	Our legitimate interests in preventing unauthorised behaviour, and maintaining the safety and integrity of our App and Sites.
To improve your experience on the App.	Profile photo data, such as whether the: first profile photo is scrolled on or not vote is a yes or a no	We get this information from how people interact with the App and profile photos of other users.	Our legitimate interest in improving the experience of our users.
To allow people using the App to create and enhance their Barkle profile, and log into the App via third-party accounts.	Linked Social Media Information from Facebook and other third-party accounts	We get this information from Facebook or the providers of any other accounts you use to log in to Barkle or connect with your Barkle account.	Our legitimate interests in facilitating access to our App and Sites.
To block payment transactions as part of our anti-fraud procedures.	Name IP address Email address Mobile number Cardholder name Payments received Type of payment User ID User country	You provide us with your name, email address, mobile number, and card details. We get your IP address from the device you use to contact us. We get your payment information from your interactions with our App and Sites.	Our legitimate interests in preventing fraudulent transactions and maintaining the security of our App and Sites.
To share promo cards and advertisements on the App.	Gender Age Optional profile information Location	You provide us with your gender and age. You choose to provide us with optional profile information. We get location data from the device you use to access the Barkle social networking service.	Our legitimate interests in targeting advertisements so that people using our App and Sites see relevant advertisements, and to allow us to generate income from advertising revenue.
To share advertisements on third-party networks and measure their effectiveness.	Gender Age Data about your visit to our App or Sites and the actions you take, for example, if you: downloaded our App created a Barkle account IP address Estimated location based on IP address Device ID	You provide us with your gender and age. We get the other information from the device or browser you use to access the Barkle social networking service.	Consent based on your Privacy or Cookies Settings preferences, or your browser or device privacy preferences. For example, this might be required by your device manufacturer, such as if you use an Apple device operating on iOS 14.5.
To contact you to run research surveys, get feedback, and find out if you want to take part in marketing campaigns.	Email address Mobile phone number	You provide us with this information.	Our legitimate interests in carrying out research so we can further develop the App and improve the Barkle social networking service.
To allow video and audio call functions, and the sending of images and video.	Video and audio call usage data Images Video	We get this information from the device you use to access the Barkle social networking service.	Our legitimate interests in providing these functionalities as part of the App and Sites.
Students To understand which of our users might be in college or university in order to improve services for students.* *This only applies to people who use the App and identified themselves when registering as being from the United States or Canada (except Quebec) and 18 – 24 years old. What exactly does this mean? What we’re doing. We do this by using recent location data of where you opened the App to see if your device’s coordinates match a general university or college area. It’s then a simple “are they at campus? yes/no” result based on what we find. Why we’re doing this. We combine these results with other relevant information we have so that we can: send the right offers, events, and features to the right users understand which Barkle events are popular with students or not working so well improve the App design to meet the needs of students What we don’t do. We do not: track your live, real-time movements as part of this activity identify or store information about where you are studying	Historic location data To be clear: to protect your privacy, we do not keep any of the location data used for this activity. It is permanently deleted once we have the “at campus? yes/no” result.	We get this information from the device you use to access the Barkle social networking service.	Our legitimate interests in providing a more tailored experience for students using the App and optimise their chances of finding the right connections.
BFF Offer the chance to join Hives, which are groups of people and chats based on specific location or topics, and automatically recommend Hives for you to join based on your location, activities, and “my life” and “my interests” information.	Profile information Activity information Location	You provide us with your profile and activity information. We get location information from the device you use to access the Barkle social networking service.	Our legitimate interests (for profile and activity information) in recommending relevant Hives to you. Contractual necessity (for location data).

WHAT INFORMATION CAN OTHERS SEE?

We think every person deserves meaningful connection, so we have built certain features to help you share what makes you unique with the world. Our App is specifically designed to make it easier for you to connect and interact, which involves making certain information about you available to others on the App.

What you’ll find in this section

1. Important things to know when sharing information
2. BFF Profile Sharing

Because of this and the nature of this type of connecting, we encourage every person on our App and Sites to think carefully about the information you share about yourself with others. Be careful about posting information that may eventually be made public when using the App. You should always assume that anything you post or submit may be publicly-viewable and accessible to people on or off the App.

The information you post about yourself, put on your profile, or share with others is at your own risk – we are not responsible for the information you choose to share with others.

IMPORTANT THINGS TO KNOW WHEN SHARING INFORMATION

We recommend not putting sensitive information that could be used for abuse or misuse on your profile for others to see, such as:
- email addresses
- URLs
- instant messaging details
- phone numbers
- full names
- addresses
- credit card details
- national identity numbers
- driver's licence details
- any other sensitive information
Be careful when posting sensitive details about yourself on your profile or by adding certain Barkle badges to your profile, such as your religious denomination, political leanings, sexual preferences, and health information. Although you can voluntarily choose to provide us with this information when you create your profile, sharing these sensitive details is not required. And remember the photographs you post on Barkle can also reveal information about yourself.

When using the Barkle App, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users and non-users of the App. We want our Users to be mindful about posting information that may eventually be made public. This includes certain information added to your profile by third-party accounts like Facebook, Instagram, or Spotify.
- For example, Barkle’s safety feature ‘Share Date’ allows Users to share their match’s Barkle name, photo, time and location of their date with their trusted contact. Also, a person using the App might recommend you as a match to their Facebook friend by sharing a screenshot of your profile picture, whether or not that friend also uses the App.
Some countries (currently only South Korea) might require that people have the option to download a copy of their conversation history. In this case, we have no control over how this information might then be used or shared after we are required to provide it.
Remember to log out of any app or third-party account you use to log in to or access our App when you are done to keep others from accessing your Barkle account.

TAKE CONTROL OF YOUR DATA

When you choose to share sensitive information about yourself with us, including by adding badges to your profile, to discover others and be discovered, you are explicitly consenting to us processing this information and making it public to other people on the App.

BARKLE BFF

If you use BFF, you should assume that whatever information you share in BFF can be seen by any BFF member. This includes information like which Hives you’ve joined and those conversations. BFF members can only see Hive discussions after they join the specific chat, which then gives them access to the full chat history.

You can choose to provide information like your beliefs, sexuality, and political leanings, but it’s not required. Just know that when you choose to share sensitive information like this about yourself with us for BFF, you are explicitly consenting to sharing that information with other BFF members.

BFF Profile Sharing

If you use BFF and are in a region where our separate Barkle For Friends app is available, your BFF profile will automatically be visible both in BFF mode on the main Barkle App and on the separate Barkle For Friends app. We do this to provide you with a richer pool of potential friends to connect with. If you do not want your BFF profile to be shown on the Barkle For Friends app, just check out this help page.

DO WE SHARE YOUR INFORMATION?

In order to help you make connections and provide an enjoyable Barkle experience, it might sometimes be necessary to share some personal information with others. But rest assured: we will only ever share your personal information in the limited circumstances described in this Policy.

What you’ll find in this section

1. Our commitments to you

GOOD TO KNOW

With this in mind and under these restrictions, you should be aware that some of these trusted third parties might also use the personal information they collect for their own purposes. For example, by aggregating your personal information with other data they hold to inform advertising-related services provided to their other clients.

OUR COMMITMENTS TO YOU

We investigate and verify (also known as carrying out due diligence) all of the trusted third parties we work with, or “Service Providers”, to make sure they have adequate data protection and information security measures in place.

We take steps to make sure the personal information we share is as unidentifiable as possible.

We hold our Service Providers to extensive contractual requirements, including strict limits on keeping personal information.

What is aggregating?

Aggregating personal information and data means combining information from multiple people and sources in a way that does not personally identify you or anyone directly.

When we share information, with who, and why	What information we share
Service Providers To offer some of our functions and services that are made possible by working with our trusted Service Providers. The specific Service Provider we share personal information with depends on various factors, such as which of our App, Sites, and other services a person is using. We will only share your personal information with Service Providers when necessary to perform these functions and provide such services. Each Service Provider will only have access to the personal information necessary for the specific service they are providing. For example, in order to provide our services, we typically use Service Providers like: Billing services to allow customers to purchase paid features of our App (for example, Google Play) Authentication services to allow customers to authenticate their account (for example, Twilio) Social media providers to allow customers to create and connect their Barkle account with their social media accounts (for example, Facebook, Instagram, or Spotify) Customer support services to help us respond to your enquiries (for example, Zendesk, Sierra) Product improvement and market research by working with third-party platforms and agencies to carry out customer surveys and research to improve our products and services (for example, Typeform or Kantar) IT services by working with third-party software providers used in operating our business for technical support (for example, if a person using our App or Sites contacts us via social media with a support inquiry, their inquiry is processed by Khoros, our community management software provider)	Depending on the service or function, this can include any personal information discussed in this Policy that we have related to you.
Moderators To monitor activity on the App and approve content.	Name User registration details Profile information Message content Photographs
Payment Processing and Telecommunications Companies To facilitate payments for our premium services.	Cardholder name Cardholder address Card number Payment amount Transaction date/time
Marketing Service Providers To partner with Service Providers focused on marketing services to: market and advertise our App and services on third-party websites and applications measure the effectiveness of our advertising campaigns For example, this can involve: excluding people who already have a Barkle account from advertising campaigns aimed at finding new users showing Barkle ads to people who have visited our App or Sites but haven’t created an account yet creating an advertisement audience of other potential users with similar characteristics to you based on a Marketing Service Provider’s information (also known as a “lookalike audience”) sending you specific Barkle advertising content by including you on a list of people we think are most likely to be interested in a particular advertisement (also known as a “custom audience”)	Advertising identifier associated with your device (Device ID) Estimated location (based on your IP address) Age Gender Data about your visit to our Sites or App and the actions you take, for example, if you: downloaded our App created a Barkle account made purchases in the App or on the Sites Encrypted (hashed) email address (only to create “custom audiences”)* *When shared with a Marketing Service Provider, hashed emails are deleted after the ads are served.
Facebook To partner with Facebook as a Marketing Service Provider to: measure the effectiveness of our advertising improve our marketing practices deliver more relevant advertising to you and people like you, including on social media When we share personal information with Facebook in this specific context, such as through the Facebook “Like” function, we are considered “Joint Data Controllers” with Facebook Ireland for this data processing. What does this mean? We tell you about this processing of your personal information here in this Policy, but you should contact Facebook if you want to exercise your data protection rights for this processing. To learn more about how Facebook processes your personal information as an independent data controller and allows you to exercise your rights, refer to Facebook Irelandcheck out Facebook Ireland’s Data Policy. If you want more information about our relationship with Facebook, just email#x2019;s Data Policy for details. For more information about our relationship with Facebook, email DPO@gobarkle.com.	Actions you take on our Sites and how you interact with them Information collected from cookies or similar technologies, including the Facebook pixel
Legal Enforcement and Preventing Harm To ensure everyone using the App behaves appropriately and follows our Terms and Conditions of Use. To work with third parties to enforce their intellectual property or other rights. To cooperate with legal requests for information from law enforcement when we are required by law, which can include an investigation into alleged criminal behaviour or to protect a person’s vital interests. What does this mean? We can save or share any of your personal information discussed in this Policy if we believe in good faith that it is necessary to: follow a law or regulation, binding court order or direction, or lawful request protect the safety of any person address fraud, security, or technical issues, such as by working with anti-spam providers to protect the App and Sites from criminal activity protect a third party’s rights or property, or our own In any of these cases, it is our decision alone whether or not to act on any right available to us, such as rejecting a request for information when possible.	Depending on the specific request or issue, this can include any personal information discussed in this Policy that we have related to you.
Our Business Transfers To help bring a smooth changeover in the event one of our companies, a Barkle Group entity, or any of our affiliates goes through a business transition or change of ownership. For example, this can include: merger acquisition by another company re-organisation sale of all or a part of its assets insolvency or administration	Depending on the situation, this can include any personal information discussed in this Policy that we have related to you.
Anti-Spam and Anti-Fraud Procedures To apply our anti-spam and anti-fraud procedures by sharing your personal information with our other companies (Barkle Group companies). For example, to block accounts and suspected fraudulent payment transactions.	Email address Phone number IP address IP session information Social network ID Username User agent string Transaction and payment data
Aggregated Information To carry out analysis of our industry and demographic profiling by sharing aggregated information with third parties for this purpose. For example, we can share aggregate click statistics, such as how many times a particular link was clicked.	Personal information that does not directly identify you, together with other information, including log data

WHAT ARE YOUR RIGHTS?

With all of this in mind, let’s talk about how you can take control of your privacy.

What you’ll find in this section

1. Right to be informed
2. Right to access
3. Right to rectify
4. Right to data portability
5. Right to erase
6. Right to restrict or object
7. Right to complain
8. Rights related to automated decision-making, including profiling
9. How Do You Enforce Your Rights
10. Do You Live in California?

You generally have the following rights regarding your personal information, depending on the specific circumstances:

Right to be informed

Your right to know what personal information we process and why.

Right to access

Your right to request a copy of the personal information we have about you.

Right to rectify

Your right to correct the personal information we have about you if it’s inaccurate.

Right to data portability

Your right to retrieve your personal information from us to easily transfer it to another location.

Right to erase

Your right to have your personal information deleted, except if we have compelling reasons to keep it (like following the law).

Right to restrict or object

Your right to limit or stop how we use your personal information. If processing is restricted, we can still store the information but can’t use it further.

Right to complain

Your right to complain to us or your country’s data privacy authority if you don’t agree with how we handle your data or address your concerns. If you have a concern about how we handle your personal information or a request, we encourage you to first contact us.

Rights related to automated decision-making, including profiling

Your right not to be affected by automatic decisions made without any human involvement, especially if those decisions have significant or legal effects on you. For example, this includes situations like automatic denial of an online credit application or hiring decisions made entirely by computers.

If you live in the UK, you can make a complaint to the Information Commissioner’s Office (ICO).

If you live in the EU or European Economic Area (“EEA”), you can get in touch with your local Data Protection Regulator.

If you live outside the UK, EU, or EEA, reach out to your local privacy data protection regulator.

If you want to learn more or exercise your rights, just visit our Feedback Page, email our Data Protection Officer at DPO@gobarkle.com, or contact us. To protect you and everyone on the App and Sites, we might need to ask you for specific information to help us confirm your identity before we answer your request.

GOOD TO KNOW

Your particular rights depend on your country and this list does not apply everywhere or include every single possible right that might exist around the world. You should always be aware of the rights you have under the privacy laws that apply in your country.

DO YOU LIVE IN CALIFORNIA?

If yes, there’s a bit more information you need to know. In addition to the rights we just described, people living in California have the following rights under the California Consumer Privacy Act (“CCPA”):

Right to exercise your rights

Right to know

Right to delete

Shine the Light Law

Joint promotions

Do not track signals

HOW DO WE HANDLE AND STORE YOUR PERSONAL INFORMATION?

We will only keep your personal information as long as necessary for the relevant purpose and legal basis described in the How do we use your information? section, but never longer than allowed by applicable law.

What you’ll find in this section

1. What happens when you delete your account?
2. Connecting you around the world

And don’t forget:

Profile Verification Information: if you verify your profile, we only keep any biometric scans we receive so that we can verify you in the future and for our record-keeping purposes until we no longer need them for such purposes or for three years after your last interaction with us, whichever occurs first.

Customer Support Contact Information: we keep records of our communications with you for 6 years after your account is deleted.

GOOD TO KNOW

Even after you remove information from your profile or delete your account, copies of that information may still be viewable or accessible if it was previously shared, copied, or stored with or by others. We cannot control this and we are not legally responsible or liable for this.

If you give third-party apps or websites access to your personal information, their own terms of service or privacy policies control how they handle your personal information.

WHAT HAPPENS WHEN YOU DELETE YOUR ACCOUNT?

If you delete your account, we make sure it is no longer viewable on the App. Just in case you delete on accident or change your mind, it’s possible to restore your account for up to 28 days after deleting.

For Example
If you make purchases within the App, we might need to keep some personal information for tax and accounting purposes If an account is blocked, we might need to keep some account information and a record of the behaviour that resulted in blocking the account as evidence for possible queries or legal claims If there is a payment dispute for a paid feature, we might need to keep personal information to resolve it If a user was banned for unsafe behaviour or security incidents, we might need to keep information to prevent them from opening a new account

If you make purchases within the App, we might need to keep some personal information for tax and accounting purposes
If an account is blocked, we might need to keep some account information and a record of the behaviour that resulted in blocking the account as evidence for possible queries or legal claims
If there is a payment dispute for a paid feature, we might need to keep personal information to resolve it
If a user was banned for unsafe behaviour or security incidents, we might need to keep information to prevent them from opening a new account

After these 28 days, we start the process of deleting your personal information, unless:

we must keep it to follow applicable law
we must keep it to prove we followed applicable law
there is an outstanding issue, claim, or dispute that requires us to keep the relevant information until it is resolved
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing safety and security for people using our App and Sites

CONNECTING YOU AROUND THE WORLD

Our App and Sites are global – we want you to be able to access Barkle and make connections wherever you happen to be in the world. To make this possible, we operate a global network of servers to provide the App and Sites, and store your personal information. Our network includes servers in the US, UK, and the EU. Here are some points to keep in mind:

We own the hardware for the servers, even if they’re physically located in a third-party data centre.
Your personal information will be sent to and used in the US and UK, no matter what country you live in.
The personal information collected by our trusted Service Providers and advertising partners might also be held outside the UK and EEA.

In any case, we make sure your personal information is adequately protected – especially when transferred overseas. We make sure that valid, legal mechanisms are in place, such as the EU approved model clauses, and enforce strong contractual standards. If you want more information about the protections we have in place, just email DPO@gobarkle.com.

HOW DO WE KEEP YOUR INFORMATION SECURE?

Here at Barkle, we pride ourselves on taking all appropriate and reasonable security measures to:

help protect your information against loss, misuse, and unauthorised access or sharing
protect the confidentiality of your personal information, such as by using secured servers with firewalls

What you’ll find in this section

1. Tips to keep your data secure
2. Age Restriction Policy

Unfortunately, using a website or the Internet is never 100% secure and even we can’t guarantee that unauthorised access, hacking, data loss, or other breaches will never happen. We can’t guarantee the security of your personal information while it is being transmitting to us, so any transmission is at your own risk.

This being said, here are some tips to help keep your data secure:

Always log out of your account when you’re done.
Never share your password with anyone else.
Regularly change your password.

If you ever think someone has access to your password or account, now or in the past, just follow these steps.

AGE RESTRICTION POLICY

Although we want as many people as possible to enjoy our creation, you must be at least 18 years old to use Barkle.

We do not knowingly collect any information or market to children, minors, or anyone under 18 years old. If we become aware that someone under 18 has registered a Barkle account and shared personal information with us, we will take steps to terminate that person’s registration.

US STATE PRIVACY RIGHTS

Some US states have their own privacy laws, regulations, and rights. If you see your state listed here, we have some extra information to share with you. Please read this information along with our Privacy Policy.

What you’ll find in this section

1. California
2. Colorado
3. Connecticut
4. New Jersey
5. Oregon
6. Texas
7. Utah
8. Virginia

GOOD TO KNOW

Wherever you live, we care about your privacy. You can make a request for your data either through our app or by contacting our support team.

Your US State Privacy Rights

Some US states have their own privacy laws, regulations, and rights. If you see your state listed here, we have some extra information to share with you. We encourage you to review this information carefully, along with this Privacy Policy so you can understand your options and make the choices that are best for you.

1. CALIFORNIA

2. COLORADO

3. CONNECTICUT

4. NEW JERSEY

5. OREGON

6. TEXAS

7. UTAH

8. VIRGINIA

HOW CAN YOU REACH US?

Your experience with Barkle, our App, and our Sites is very important to us.

What you’ll find in this section

1. Our Contact Information

Please let us know if you have any questions or concerns about this Policy, want to exercise your rights, or have a problem or complaint. We will work hard to address it when you get in touch.

You can reach us by:

Our Feedback Page
Email at feedback@team.gobarkle.com