Barley Inc. (“Barley”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy to explain the manner in which we collect, use and, disclose personal information through our website located at www.barley.io (the “Website”) and app.barley.io (the “Platform”), and our other interactions with you.
The Platform provides our customers with compensation management and related services, designed to assist with managing compensation structures, conducting analysis on compensation, and facilitating compensation reviews.
How we collect and use personal information on behalf of our Customers
The following are some examples of the personal information we may collect and analyze to provide the Platform to our customers (which, for the purposes of this policy, includes trial customers). In the course of providing the Platform to our customers, we may process limited personal information that our customers provide to us, as set out below:
In order to provide the Platform, we collect certain personal information from our customers’ human resources information system (“HRIS”), applicant tracking system (“ATS”), and other related software, such as employee or candidate names, work email addresses, age, gender, ethnicity, and compensation information.
We may collect certain information from you (such as name, age, work email address, your phone number, and query) when we provide customer support services by phone, email, or within the Platform.
We may monitor use of the Platform by our customers or other authorized users in order to detect, investigate, or prevent any actual or potential violation of our terms and conditions. This information is automatically collected from you when you use the Platform.
We may also generate aggregated, non-identifiable data and use such information to monitor the performance, use and stability of the Platform, to improve the Platform, and to provide our customers with internal and industry insights.
We require our customers to ensure that they have obtained all authority to provide personal information to us in accordance with applicable privacy laws and to not provide us with any sensitive personal information. Except as set out herein, we do not collect or use personal information from our customers for any purpose other than to provide Platform to them.
If you have any questions regarding the personal information we process on behalf of one of our customers, we encourage you to first contact the customer directly and/or review their applicable privacy policy.
How we collect and use personal information through our Website and in our other interactions with you
We may collect personal information when you:
If you sign-up to receive email marketing communications such as newsletters, publications, reports, or other resources, we collect your email address as well as other information on an optional basis to help us tailor our communications to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.
If you apply for a job at Barley, you may provide us with certain personal information about yourself, such as information contained in a resume/CV, cover letter, or similar employment-related materials. We may also collect personal information from third-party social networking websites including but not limited to, your LinkedIn profile, blog, website or similar portfolio. We may use this information when considering and responding to your application and assessing your suitability for current and future career opportunities.
We may collect and use customer feedback and/or reviews about our Platform to better understand our customers and enhance our product and service offerings. With your consent, we may publish your feedback and/or reviews on our Website or other promotional materials.
From time to time, we may offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our users and customers, develop market reports or publications, and to enhance our Platform and service offerings.
When you contact us with a comment, question, or complaint through the contact information provided on our Website or when requesting a meeting or demonstration of our Platform, you may be asked for information that identifies you, such as your name and email address, along with additional information we need to help us promptly answer your question or respond to your comment or inquiry. We may retain this information to assist you in the future and to improve our customer service and service offerings.
As a matter of practice, Barley does not sell or disclose your personal information to third parties without your consent, except as set out in this policy or as required or permitted by law. For clarity, in California Consumer Privacy Act (“CCPA”) terms, we do not “sell” the personal information we handle on behalf of our customers.
Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as host the Website and Platform, process payments, store data and provide back-up services, provide customer support software as a service, provide data analytics services, conduct surveys, and obtain customer feedback. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for any other purposes. Our service providers may be located in the U.S., Canada, or other foreign jurisdictions. Our list of trusted service providers (also known as sub-processors) is available upon written request, please contact us at privacy@barley.io.
Personal information may be maintained and processed by Barley or its third-party service providers at a destination outside the European Economic Area (“EEA”) or outside the jurisdiction in which you reside, including the United States of America and Canada. Where personal information is transferred (including information transferred outside the EEA), we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy and applicable law. We may transfer your personal information outside the EEA to store it, to enable us to provide our services, to fulfill our contract with you or your employer, to provide the Platform and related support services, where we are legally required to do so, in order to facilitate the operation of our group of businesses, and where it is in our legitimate interest to do so and be have concluded these are not overridden by your rights.
Barley and our Canadian and US and other service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, US or other law or legal process, which may include lawful access by US or foreign courts, law enforcement, or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property. Where a disclosure of our customers’ information is required by applicable law, we promptly notify our customer prior to complying with such requirements (to the extent we are not prohibited from doing so) and fully cooperate with our customer’s instructions with respect to our response.
We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Barely or as part of a corporate reorganization or other change in corporate control.
In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to monitor and improve our Website.
Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the relevant features. We also use a third-party analytics service offered on our Website to evaluate your use of the Website, generate reports on your activities and use of the Website, and improve your experience.
We may also use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
Our Website may contain links to other websites that Barely does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure, and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.
We may work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content, and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.
Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioral ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices.
Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.
We have implemented reasonable administrative, technical, and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification, and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their designated requirements.
If we receive a request from an individual to access or update personal information we maintain on behalf of a customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests.
Subject to applicable law, you have the right to access, update, and correct inaccuracies in your personal information in our custody or control. You may request access, updates, and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at privacy@barley.io. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.
If you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to our collection of your personal information, please contact us at privacy@barley.io.
Last Update: November 7, 2022