Privacy Policy

Last updated July 7th, 2025

Barefoot eLearning provides a Learning Management System that enables our customers to create learning pathways and to manage and track staff learning (our "Platform"). We also offer microlearning short form videos and blended learning offerings that combine videos with face-to-face instructors (together with the Platform, our “Services”).

This Privacy Notice for Barefoot eLearning Limited ('we', 'us', or 'our') describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you:

• Visit our website at https://barefootelearning.com/, or any website of ours that links to this Privacy Notice
• Purchase a plan on behalf of your business to use the Platform or otherwise purchase any of our Services (or take advantage of a free trial)
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? If, after reading this Privacy Notice, you still have any questions or concerns, please contact us at contact@barefootelearning.com

Important note:This Privacy Notice only covers personal information that we process as a 'controller' - that is, personal information that we collect and use for our own purposes. When our customers use Platform, they may upload information about their employees or other individuals with training needs.  This is personal information that we process on our customer's behalf, as a 'processor'. This Privacy Notice does not deal with this information.  If you are concerned about how your personal information has been processed by a company that uses the Platform, you should contact that company directly. 

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We sometimes acquire contact information of potential customers from reputable third party providers of sales and marketing data

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We share information with cloud-based IT service providers who host that information on our behalf. On a very occasional basis, we may share personal information with courts, regulators or law enforcement. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? You have rights to access, correct and in some cases erase your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full

TABLE OF CONTENTS

1.WHAT INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

2. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6.DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO WE MAKE UPDATES TO THIS NOTICE?

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

1. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

In Short: We collect personal information that you provide to us when you register to use the Platform or other Services, and/or browse our website.

We collect personal information that you voluntarily provide to us when you register to use the Platform or other Services, which you can do by purchasing one of our plans.  You may also provide us with personal information if you contact us with enquiries or complaints.  We also collect some information automatically, using cookies and related technologies, whenever you browse our website.

For each activity that involves the use of personal information, we rely on a ‘lawful basis’ under data protection law to justify that use. The lawful basis we rely ondetermines which rights may be available to you.

The following table sets out:

(i) each activity we perform using personal information;

(ii) the categories ofpersonal information processed for that purpose; and

(iii) the lawful basis relied upon under data protection law.

Activity	Categories of personal information	Lawful basis
User registration   (Registering you as a user and managing the log-in process for the Platform)	Name; email address; password	Performance of a contract (where you sign up in your own name)   Legitimate interests* (where you sign up on behalf of a company)
Payment and billing   (Taking payment for your subscription plan to the Platform and any other Services purchased)	Name; billing address; payment card or bank account information; invoice number; details of Services purchased	Performance of a contract (where you purchase Services in your own name)   Legitimate interests (where you sign purchase Services behalf of a company)
Maintaining a sales and marketing database   (Building and maintaining a list of actual and prospective customers and sales targets, using a combination of data provided by customers and data obtained from third party commercial providers)	Name; email address; telephone number; job title; industry	Legitimate interests
Marketing communications   (Sending you promotional communications about our Services, including special offers and discounts)	Name; email address; telephone number; order history; marketing preferences; consent record	Legitimate interests (subject to your right to opt‑out)   Consent (where legally required)   You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below
Service communications   (Sending you notifications relevant to your use of the Services, such as notifying you of an upcoming renewal of your subscription or the publication of new Terms and Conditions)	Name; email address; telephone number	Legitimate interests
User surveys   (Sending you surveys to understand your opinion on our Services and to solicit feedback / recommendations for improvements)	Name; email address; telephone number; feedback provided / responses to survey	Legitimate interests
Website functionality and security   (Placing strictly necessary cookies and similar technologies that are required to make the website and the Services function as intended)	Session identifiers; login state; IP address; security flags; tokens; server details; other browser generated information	Legitimate interests
Website analytics   (Placing optional cookies and similar technologies that assess how the website is used so that we can make improvements to it and so that we can understand our user base)	Pages visited; click paths; scroll depth; bounce rate; browser type and version; operating system; language settings; session duration; traffic source; client ID; session ID; timestamp markers	Consent (obtained through our cookie consent management platform)
Enquiries   (Responding to and resolving customer queries and complaints)	Name; contact information; details of enquiry	Legitimate interests
Legal process   (Taking steps to establish, exercise or defend our legal rights (including under our Terms and Conditions) and responding to requests, demands and orders from courts, law enforcement, regulators and other third parties)	Any of the above	Legitimate interests (when establishing, exercising or defending our legal rights)   Legal obligation (when responding to a court order or other binding legal process)

*Where we refer to legitimate interests, this means it is reasonably necessary to achieve a specific, lawful business interest, and that interest does not outweigh your interests and fundamental rights and freedoms. Please contact us if you want to know more about specific legitimate interests under which your personal information is used.

Mandatory vs.non-mandatory personal information. If you want to purchase and use the Services, you need to provide us with some personal information to create a user account and make a payment, as described above, and we will need some personal information to send you service communications.

Also, website functionality and security cookies, to the extent they process personal information, are necessary if you wish to use the website.

Otherwise, all collection of personal information is optional.

2. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Payment Providers Third party payment service providers to whom we outsource the handling and other processing of payment card information. These providers are subject to contracts which require them to comply with our instructions and to only process your personal information in order to provide the service we have requested.

• Cloud IT Service Providers To host our Platform and to store your personal information.  These providers are subject to contracts which require them to comply with our instructions and to only process your personal information in order to provide the service we have requested.

• Legal Processes If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, court or law enforcement request, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property, or safety of us, our customers, or others.

3. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics purposes and for advertising, including to help manage and display advertisements and to tailor advertisements to your interests. These third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Your cookie choices

When you first navigate to our website, you will be presented with our pop-up cookie consent management platform, which will ask you whether you want to accept all non-essential cookies, reject all non-essential cookies, or customise your choices. You can later change your selection by clicking on the cookie icon at the bottom of the page.

The cookie consent management platform contains more information about the specific cookies used on the website.

You can also manage cookies and delete cookies using your browser settings. Browsers such as Chrome, Internet Explorer, Firefox and Safari give you the ability to accept, reject or delete Cookies. Visit the “help center” of your browser to learn more.

You can also take advantage of industry-sponsored programs that allow you to control the way companies advertise to you.  Your Online Choices is run by the European Interactive Digital Advertising Alliance (EDAA).  You can opt out of being targeted by its members by visiting: www.youronlinechoices.eu

The Network Advertising Initiative (NAI) manages an opt-out program for many third-party advertising companies. You can opt out of being targeted by NAI members by visiting https://optout.networkadvertising.org/?c=1

On some websites, you may see an AdChoices icon, which may appear on certain targeted ads. You may click on this AdChoices icon to learn more information about the collection and use of your information or to opt-out of such collection in the future. To learn more about the Digital Advertising Alliance Consumer Choice tool, please visit https://optout.aboutads.info

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout/. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?>

In Short:We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from the Platform and any other Services is at your own risk. You should only access the Platform within a secure environment.

>6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. The Platform and any other Services are only targeted at adults.  By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at contact@barefootelearning.com.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your>Member State data protection authority orUK data protection authority

If you are located in Switzerland, you may contact theFederal Data Protection and Information Commissioner

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at contact@barefootelearning.com.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

9. DO WE MAKE UPDATES TO THIS NOTICE?

>In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@barefootelearning.com or contact us by post at:

Barefoot eLearning Limited
Beckwith Barn,
Warren Estate,
Lordship Road,
Chelmsford,
Essex. CM1 3WT