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PRIVACY POLICY

Effective Date: January 13, 2014


To understand how we use third party analytic tracking technologies and how you can opt out, click here
To opt-out of email promotions, click here
To opt-out of direct mail promotions, click here
To opt-out of telemarketing, click here
If you have opt-ed in to receive SMS text messages but now wish to opt-out, simply Reply STOP to quit
To understand how advertisers use tracking technologies, click here

BareWeb Interactive, Inc. ("BareWeb", "us", "our" or "we") has developed this Privacy Policy which details important information regarding the use and disclosure of user information collected on the website Barenecessities.com which is owned and operated by BareWeb and any successor websites, (the “Site”), and other interactive properties, including but not limited to our mobile applications (the Site and other BareWeb interactive properties are collectively referred to herein as the BareWeb Applications"). This Privacy Policy also applies to our offline collection of information. BareWeb provides this Privacy Policy to help you make an informed decision about whether to use, continue to use the services provided by BareWeb and/or assessed through the BareWeb Applications or offline ("Services"). This Privacy Policy applies to your use of (1) the BareWeb Applications (however accessed and/or used, whether via personal computers, mobile devices or otherwise); (2) email or electronic catalogs and newsletters; (3) offline means such as direct mail, telephone and postal mail; and (4) any other means or applications in which you connect with us or our products and services.

This Privacy Policy is incorporated into and subject to our Terms of Use. Each time that you access or use BareWeb Applications or our Services you signify that you have read, understand, and agree to be bound by the Terms of Use, and this Privacy Policy. If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using the BareWeb Applications or Services.

I. INFORMATION WE COLLECT

Connecting with the BareWeb Applications and Information Provided by You

Providing Information To Us. When you provide us with information in connection with a particular activity or otherwise sign up for our Services or provide your contact information, including an email address or telephone number in connection with that activity, product or service, you agree that this action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to our communicating with you about BareWeb using the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide us with the authorization to contact you. This means we may contact you, in person or by recorded message, by e-mail, telephone and/or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.

Registration Information. We will collect personal information from you if you register on our Site or place an order ("Personal Information"). You may not use a user/account name that is vulgar or otherwise offensive (as determined by BareWeb), infringes any trademark or other proprietary rights of others, or is used in any way that violates the Terms. BareWeb reserves the right to deny, in its sole discretion, any user access to the BareWeb Applications or Services without notice for any or no reason.

Billing Information. We collect and store billing and credit card information. This information will only be shared with third parties who perform tasks required to complete the purchase transaction. Examples of this include fulfilling orders and processing credit/debit cards.

Surveys and Promotions. From time-to-time we may request information from you and other users via surveys or contests or sweepstakes. Participation in these surveys, contests or sweepstakes is completely voluntary so you and other users have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code). Contact information may be used to notify the winners and award prizes and file winners information as required by law. Survey information will be used for the purpose(s) of the survey, including the monitoring or improvement of the use and satisfaction of BareWeb Applications.

Facebook. You may be given the option to link your Facebook account so that you can comment on the BareWeb Applications or take advantage of other features of the BareWeb Applications. When you comment on the BareWeb Applications using your Facebook username and password and clicking "allow" on the Facebook permission authorization screen, you give us permission to capture, store, use and display your Facebook user ID, your basic Facebook profile information and any other information from your Facebook profile that you specifically allow us to access. The authentication of your Facebook login credentials are conducted solely through Facebook.

User Generated Content. The Services may contain review or chat areas and/or other message, communication or other mechanisms designed to enable you to communicate with others or to post content on the Site (the “Communication Services”). Please remember that any information you disclose while participating with the Communication Services becomes public information, becomes the property of, and is subject to redistribution by, BareWeb. You should exercise caution and discretion when deciding to disclose your personal information in a submission or posting. There is no expectation of privacy when playing, posting, or otherwise participating on the Communication Services. If you post content, such as messages, reviews or photos, please be aware that any personally identifiable information contained in such content is accessible to registered users or visitors to that BareWeb Application or Communication Service and we have no control over how those users may use your personally identifiable information. We have the right, but not the obligation, to monitor any activity and content associated with the Communication Services. We reserve the right to take action in connection with any content we deem to be inappropriate. Please review our Terms of Use for more information regarding your appropriate use of these Communication Services.

Information Collected Through Technology

In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the BareWeb Applications ("Usage Information"). This may include the browser that you are using, the URL that referred you to the BareWeb Applications, all of the areas within the BareWeb Applications that you visit, and the time of day, among other information. We may use the Usage Information for a variety of purposes, including to enhance, or otherwise improve the BareWeb Applications. In addition, we collect your IP address or other unique identifier (“Device Identifier”) for your computer or other device used to access the BareWeb Applications (any, a “Device”). A Device Identifier is a number that is automatically assigned to the Device used to access the BareWeb Applications, and our computers identify your Device by its Device Identifier. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information or a Device Identifier with personally identifiable information, we will treat it as Personal Information.

A few of the tracking technologies that may be used to collect Usage Information include, without limitation, the following:

  • Cookies. A cookie is a data file placed on a Device when it is used to visit the BareWeb Applications. We use cookies to collect information for record keeping purposes, to make it easier to navigate the BareWeb Applications. Cookies are stored on users’ hard drives. We use both “session ID cookies” and “persistent cookies.” Session ID cookies are used to store information while a user is logged into the Site and expire when the user closes his/her browser. Persistent cookies are used to make tasks like logging into the Site easier for returning users by remembering a user’s login information. Persistent cookies stay on a user’s hard drive from one session to the next. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. You can choose to have your computer warn you each time a persistent or session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies.

  • Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our web pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our BareWeb Applications, to monitor how users navigate the BareWeb Applications, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

  • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the BareWeb Applications, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the BareWeb Applications, and is deactivated or deleted thereafter.

  • HTML5. We use HTML5, another form of collection, in our apps for the iphone or iPad (and any other Apple iOS device). HTML5 is another form of collection, tracking and storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies can be used to track users across websites but are not stored in browers' cookie files. To our knowledge there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage.

  • Web Logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) and device identification in order to improve security, analyze trends and administer the BareWeb Applications. We may track your movement within the BareWeb Applications, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the Internet address from which you linked to our BareWeb Applications, the operating system of your computer, the unique IP address of the computer or device identification from the mobile device that you used to access our BareWeb Applications and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our BareWeb Applications, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information. We may also use individual information we collect through web logs to send you targeted offers and other communications.

Information You Provide About a Third Party

If you send someone else a communication from the BareWeb Applications, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. If that person becomes a customer or registers with us, his/her information will be treated in the same manner as all other customers or registered users. Please be aware that when you use any send-to-a-friend functionality on the BareWeb Applications, your e-mail address may be included in the communication sent to your friend.

Information We Collect From Third Parties

We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as information to validate or update your address or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services and offers that may be of interest, and for internal business analysis or other business purposes.

Third Party Analytics Technologies and Software Providers

We use third parties’ analytic tools to better understand who is using the BareWeb Applications, how people are using the BareWeb Applications and how to improve the effectiveness of the BareWeb Applications and its content, and to help those parties serve more targeted advertising to you across the Internet or help us serve more targeted advertising to you. Those third party companies may use cookies, pixel tags or other technologies to collect and store anonymous information such as time of visit, pages visited, time spent on each page of the BareWeb Applications, Device Identifiers, type of operating system used and other web sites you may have visited. They might combine information they collect from your interaction with BareWeb Applications with personal information they collect from other sources. We do not have access to, nor control over, third parties' use of cookies or other tracking technologies. You should consult the respective privacy policies of these third parties to see your options for opting out of their use of such devices.

Google is one of the companies that we use to serve advertising and perform analytics on some of the BareWeb Applications. We and third party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the BareWeb Applications. To learn about Google Analytics’ currently available opt-outs for the Web, click here. To learn more about how Google use cookies in advertising, you can visit the Google ad and content network privacy policy located here . You can opt out of receiving interest-based Google Ads, or customize the Ads Google shows you, by clicking here.

If you would like more information regarding which third party companies we use to provide these services who may be serving cookies or other tracking tools on our BareWeb Applications or want to know more about your choices about not having this anonymous collected or used by these companies, please click here.

II. HOW WE USE AND SHARE YOUR INFORMATION

Use of Information by Us. We may use Information that we collect about you: (1) to provide you with information or merchandise or process transactions that you have requested or agreed to receive; (2) to provide you with information regarding new features, products or services; (3) to improve the BareWeb Applications or our Services and to customize your experience; (4) to contact you with regard to your use of the BareWeb Applications and, in our discretion, changes to the BareWeb Applications and/or the BareWeb Applications’ policies; (5) for internal business purposes; and (6) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Transactional Communications. We may send you notices from time to time relating to your account or your orders. These may include order confirmations, invoices or customer service notifications. We may also send you service-related announcements when it is necessary to do so; for instance, if our Service is temporarily suspended for maintenance, or the delivery of a product is delayed or there is some service issue with something you may have ordered. You may not opt-out of receiving these communications, which are not promotional in nature.

Service Providers. We may use third party service providers to help us operate our business and the BareWeb Applications or administer activities on our behalf. We may share your information with these third parties for those limited purposes.

Electronic Promotional Offers. We may send you promotional emails regarding special offers about our Services or on behalf of third party marketing partners who we think can offer services and products of interest to you. If you do not want to receive emails from us regarding special promotions or offers, or from any third party you may click the unsubscribe link in the footer of any email, (ii) email us at info@barenecessities.com with "Unsubscribe Promotional Offers" in the subject line or (iii) call customer care at 1-877-728-9272.

If you use more than one email address to shop with us, send your messages from each email account you use.

Please note that even if you opt out of receiving promotional e-mails, we may continue to send you electronic service notifications that are related to your account(s), orders or other services you have requested.

SMS Text Messages. If you opt-in to receive special offers and updates from Bare Necessities via SMS Text Messages your info will never be shared. If you have opt-ed in to receive these messages but wish to opt-out, simply Reply STOP to quit. HELP for help. Message and data rates may apply.

Direct Mail Promotional Offers. We may send you our catalog and/or offers through direct mail that we feel might be of interest to you and/or sell, share or rent your name and mailing address and certain other information, such as what you ordered, with reputable companies that provide marketing offers through direct mail. In addition, we participate in cooperative database services which help us to direct print catalogs, mailings and other marketing initiatives to appropriate purchasers and website visitors. Names and mailing addresses may be shared between participating parties in the cooperative database services, but no credit card information or email addresses are provided to the cooperative.

If you do not want us to send you our catalog or any promotional offers or offers from third parties through direct mail or sell, rent or share your Personal Information with other companies so that they can send you direct mail offers about their products and services, please write to us at the street address set forth at the end of this document and include your mailing address to be removed. If you prefer not to have your name and mailing address shared with third parties or provided to other trusted companies, send an email to info@barenecessities.com with "Direct Mail Opt-Out" in the subject line or write to BareWeb, Inc., 90 Northfield Avenue, Edison, NJ 08837 and include your mailing address to be removed. Please note that even if you opt out of receiving promotional direct mail offers, we may continue to send you service notifications that are related to your account(s) and other products and services you have requested or in which you are currently enrolled by direct mail.

Telemarketing. If you have given us your telephone number, when registering with us or when ordering merchandise from us, we may use your telephone number to reach out to you to follow up on your order of merchandise, including follow-up marketing. If you would prefer not to receive marketing phone calls from us, send an email to info@barenecessities.com with “Do Not Call” in the subject line or call customer care at 1-877-728-9272 or ask to be placed on our do not call list when you receive a call from us. Please note that even if you opt out of receiving promotional telephone calls, we may continue to call you for issues that are related to your account(s), orders or other services you have requested.

Our Advertising. We also use third-party ad servers and ad networks to serve our advertisements when you leave the Site. These companies and the advertisers themselves may use information about your visits on other web sites and our Site in order to provide advertisements about goods and services of interest to you. In the course of serving advertisements to our Site, these third-party ad servers or ad networks use technology to send, directly to your Device, the advertisements and links that appear on the Site. They automatically receive your Device Identifier when this happens. They may also use tracking technologies to measure the effectiveness of their advertisements and to personalize the advertising content. We may also use information collected using third party cookies and Web beacons on BareWeb Applications and in our emails to deliver advertising about our Services displayed to you on third party websites. This Privacy Policy does not apply to, and we cannot control the activities of, such advertisers, ad servers or ad networks. You should consult the respective privacy policies of any advertisers on our Site to see your options for opting out of their use of such devices. In addition, some of the ad servers and ad networks may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. If you opt-out of receiving targeted ads on our Site from ad servers and ad networks, you may continue to receive advertising and promotional messages after you opt-out, but it will not be customized or personalized to you based on your use of our Site and/or third party websites. If you would like more information about advertisers' use of tracking technologies and about your option not to accept the cookies used to track your activities, you can go to www.networkadvertising.org. If you would like to learn more about how interest-based information is collected, whether the companies we use are part of an industry network regarding behavioral advertising and to know your choices about not having information used in this manner you can go to www.aboutads.info.

Browser Do Not Track Signals. Some third party browsers provide "do not track" machine readable signals for websites which are automatically applied by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result we do not respond to these signals. Go to www.networkadvertising.org or www.aboutads.info if you wish to learn more about your options to not accept tracking cookies for the purpose of receiving targeted interest-based advertisements.

Co-branded Areas. Certain areas on our BareWeb Applications may be provided to you in association with third parties such as sponsors or advertisers which provide products and or services, such as digital wallets, payment services, shipping services or rewards programs (“Co-Branded Areas”). Such Co-Branded Areas will identify the third party. If you elect to register for the products and/or services provided at these Co-Branded Areas, you either will be providing your Personal Information to both us and the third party or we might be providing your Personal Information directly to the third party in order for that third party to fulfill their products and services directly with you. Your Personal Information will be subject to this Privacy Policy as well as the privacy policy and practices of such third party. We are not responsible for the privacy practices of those third parties and we suggest you review the individual privacy policies of each company with whom you establish a relationship. You should consult the respective privacy policies of those third party sponsors or advertisers to learn more about their privacy practices.

Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the BareWeb Applications that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion and as required by law or permitted by the Promotion’s official rules.

Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you (including, without limitation, the contents of any chat, messaging, or other communication posted in the Communication Services), and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms of Use or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information and/or communications in situations that we believe to be: (i) emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat; or (ii) your conduct on the BareWeb Applications or when using the Communication Services that we believe is inappropriate and inconsistent with generally accepted norms of behavior.

Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information of our customers and visitors to our BareWeb Applications may be one of the assets sold or merged in connection with that transaction. Information about our customers and registered users may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding. In such transactions, Personal Information will be subject to the promises made in any pre-existing Privacy Policy in effect when the information was obtained.

III. ACCESS TO YOUR INFORMATION

If for any reason you are concerned that the Personal Information or Billing Information you provided to us is not correct and you wish to change it, please contact us at info@barenecessities.com or call our Customer Care Department at 1-877-728-9272. We will be happy to review, update or remove information as appropriate. If you change information in your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, resolve disputes, enforce our Terms of Use or other policies, take actions we deem necessary due to technical and legal requirements and constraints related to the security, integrity and operation of our BareWeb Applications. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies. We may still retain your information in our files however, to resolve disputes and enforce our Terms of Use.

IV. CHOICE AND OPT OUT

You may remove your information from our database so as not to receive future communications or to close your account or opt out of our sharing information with third parties for marketing purposes by emailing us at info@barenecessities.com or sending postal mail (certified mail, return receipt requested is recommended) to the following postal address:

      BareWeb, Inc.
      90 Northfield Avenue
      Edison, NJ 08837
      Attention: Privacy Administrator

If you prefer not to receive electronic promotional communications, you can also opt-out by following the unsubscribe instructions included in each communication.

If you've signed up for mobile text messaging offers from Bare Necessities but later decide you no longer wish to receive these offers simply follow the opt-out instructions included in the mobile message (Reply STOP to quit.)

Please note that changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personally identifiable information removed from our database. We will endeavor to comply with your request as soon as reasonably possible. Note that despite any request for removal of or change to personally identifiable information, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. Finally, we are not responsible for informing third parties (including without limitation our third party service providers or strategic partners) with whom we have already shared your personally identifiable information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.

V. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Links to other Site and Communities. To the extent hyperlinks may be utilized to access external or third party sites and communities, you should be aware that these external or third party site and communities are not controlled by us and, therefore, are not subject to this Privacy Policy. We recommend that you check the privacy policies of each such site and community to determine how your personal information will be utilized by their proprietors.

Security. We implement safeguards to help protect against the loss, misuse and alteration of information under our control. However, despite our efforts, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and your use of the Site indicates that you are willing to assume this risk.

Your California Privacy Rights (As provided by California Civil Code Section 1798.83)

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. If you do not want us to send you emails regarding special promotions or offers or share your Personal Information with other companies so that they can send you emails about their products and services, simply follow the unsubscribe instructions that are located at the bottom of those emails or you can click here to manage your email marketing preferences. If you do not want us to send you any offers from third parties through direct mail or share your Personal Information with other companies so that they can send you direct mail offers about their products and services, please write to us at the street address set forth at the end of this document or email us at info@barenecessities.com. California customers may request further information about our approach to this law by writing to us at the address provided in the "Contact Us" section above or by email at info@barenecessities.com and requesting further information.

A Note To International Users. The BareWeb Applications are operated in the United States. If you are located anywhere outside of the United States, please be aware that information we collect will be transferred to, processed and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the BareWeb Applications or providing us with any information, you consent to this transfer, processing and storage of your information in the United States. You are also consenting to the application of United States federal, and New Jersey state law in all matters concerning the Site and this Privacy Policy.

Children's Privacy. The BareWeb Applications are intended for a general audience and are not directed or intended for children under 18 years of age. We do not knowingly collect Personal Information from individuals under 18 years of age. If you are under 18 years of age, you should not register or provide Personal Information on the BareWeb Applications. If we later obtain actual knowledge that a user is under 18 years of age, we will take steps to remove that user’s Personal Information from our systems.

Changes to the Privacy Policy. We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on our Site, with the "Effective Date" posted at the top of the Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new BareWeb Applications or Community Services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your Personal Information, you will know because the Effective Date of the Privacy Policy will change. If we are going to use any Personal Information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. If you do not consent, your Personal Information will be used as agreed to under the terms of the privacy policy in effect at the time we obtained that information. By accessing the BareWeb Applications after the Effective Date, you are deemed to consent to our then-current privacy policy. We will use information previously obtained in accordance with the privacy policy in effect when the information was obtained from you.

Disputes. If you choose to visit the BareWeb Applications your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, resolution of disputes, and application of the laws of the United States, and the State of New Jersey.

No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of the Site.

Contacting Us. If you have any questions about this Privacy Policy, or the practices of the BareWeb Applications and Community Services, please send your email queries to info@barenecessities.com or write to us at:

      BareWeb, Inc.
      90 Northfield Avenue
      Edison, NJ 08837
      Attention: Privacy Administrator

Copyright ©2013 BareWeb, Inc. All rights reserved.



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