MOBILE APP PRIVACY POLICY

Barter Rocket and its corporate affiliates (“Barter Rocket”, “we”, “us”, “our”) respect individual privacy rights and the protection of personal information, while balancing our need to process personal information to operate our business and deliver services to you. This Policy explains our practices for collecting, using, disclosing, retaining, disposing of, and otherwise processing (“processing”) personal information, in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). This Policy applies to personal information you provide as a user of (a) the Barter Rocket mobile app (the “App”), (b) any front‑end software we provide that interfaces with the App (the “Software”), and (c) the services provided through the App and/or Software (collectively, the “Service”). This Policy does not apply to employees’ personal information or anonymized data.

Our App and Software may contain links to third‑party apps, websites, or online resources provided solely for your convenience. When you click such links, you leave our App or Software, and we have no control over—and assume no responsibility for—the privacy practices of those resources. We encourage you to review their privacy policies before providing any personal information.

PLEASE READ THIS POLICY CAREFULLY. By using our App, Software, or Service, or otherwise by providing us with your personal information, you acknowledge and consent to our processing of your personal information in Canada in accordance with this Policy and as further described when personal information is collected. If you reside outside Canada, please be aware that our App, Software, and Service are intended for users in Canada, and Canadian privacy laws may differ from those in your jurisdiction. Through your continued use, you transfer your personal information to Canada and expressly consent to that transfer, which we rely on as our legal basis unless otherwise stated herein. If you do not consent, please do not use the App, Software, or Service or provide personal information to us.

1. Personal Information

For purposes of this Policy, “personal information” means any information about an identifiable individual, including but not limited to name, address, telephone number, email address, social insurance number, gender, income, family status, and other information not exempted by law. Business contact information used solely to communicate about employment or profession is not “personal information” under PIPEDA.

We may collect the following personal information when you use our App, Software, or Service:

  • Demographic: gender, age, marital status, location (city/province/country)

  • Contact: name, email, mailing address, phone number

  • Billing: credit card number, billing address

  • Identifiers: profile photo/video, username, account number, password

  • Professional: employer name, occupation, work location, insurance details

  • Technical: device identifiers (MAC address, advertising IDs), IP address, browser and log data

Collection occurs when you:

  • Register for a Barter Rocket account

  • Connect via social media

  • Use the App (we collect cookies and tracking data)

  • Provide information to us directly or via third parties/public sources

Cookies and Log Files

Our App uses “cookies” and similar technologies (single‑pixel GIFs, web beacons) to track usage patterns (e.g., pages visited, session duration, referring site) and technical details (e.g., IP address, device type). Cookies do not harm your device and identify your browser, not you personally. You may disable cookies in your device settings—note this may affect App functionality.

Information about Minors

Our App is intended for users aged 13 and older. We do not knowingly collect personal information from minors under 13. If you believe we have collected such information, please contact us to have it deleted.

2. Purposes for Processing

We process your personal information for the following purposes:

  1. Specific Purposes

  • Verify and authenticate your identity

  • Enable social media integration

  • Use third‑party services (e.g., Firebase Notifications, Apple Push Notifications) to send timely, relevant content

  1. Generic Purposes

  • Optimize, operate, maintain, and improve the App, Software, and Service

  • Provide features, functionality, and customer support

  1. Boilerplate Purposes

  • Communicate with you via phone, email, or in‑App messages

  • Fulfill contractual obligations

  • Comply with internal policies, legal, accounting, or security requirements

  • Share information with employees, contractors, consultants, and third‑party service providers (e.g., hosting providers, payment processors) to deliver and improve our Service. Personal information may be stored or processed outside Canada and accessible to foreign authorities.

We only process personal information for the purposes for which it was collected or as otherwise consented to by you.

3. Disclosure of Personal Information

We may disclose personal information to:

  • Our employees and contractors

  • Business partners and service providers (e.g., web hosts, advertisers, payment processors)

  • Law enforcement, regulators, or other lawful authorities

Your personal information may be processed or stored outside Canada, and may be accessible to foreign courts or law enforcement under applicable laws.

4. Legal Basis for Processing

Consent: We process personal information with your knowledge and consent, either express (e.g., checking a box) or implied (e.g., providing information in a form) as required by PIPEDA. You may withdraw consent at any time by:

  • Changing your privacy preferences in the App

  • Deleting your account and ceasing use of the App

  • Opting out of specific communications (e.g., newsletters)

Other Legal Bases: We may also process personal information under other legal bases permitted by applicable law.

5. Security

We implement physical, technical, and organizational safeguards to protect personal information against loss, theft, unauthorized access, alteration, or disclosure. We regularly review our security practices to align with industry standards. However, no method of transmission or storage is completely secure; you should exercise caution when disclosing personal information online.

6. Access and Correction

Under Canadian privacy laws, you have the right to access and correct personal information we hold about you. To request access or correction, contact us as described in Section 10. We will respond within 30 days or notify you if we need more time or must refuse under legal exceptions.

7. CASL Policy

We comply with Canada’s Anti‑Spam Legislation (CASL), which governs Commercial Electronic Messages (CEMs) and requires consent, identification, and an unsubscribe mechanism in every message. We obtain express or implied consent before sending CEMs, clearly identify ourselves, and honor unsubscribe requests within 10 business days.

8. Retention

We retain personal information only as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. When no longer required, we securely delete, destroy, or anonymize the information.

9. Updates to this Policy

Last updated: April 14, 2025.

We may update this Policy from time to time. Material changes will be communicated via email or notice in the App before they take effect. Please review this Policy periodically to stay informed of our practices.

10. Contact Information

For questions or concerns about this Policy or our privacy practices, contact our Privacy Officer at:

Email: privacy@barterrocket.ca

Address: 123 Exchange Lane, Toronto, ON, Canada

If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada.

© 2026 Barter Rocket