Cookie Policy

1. Data Controller

The webpage at

https://www.bareinternational.com/,

https://www.bareinternational.eu/,

https://www.bareinternational.br/,

https://www.bareinternational.cn/,

https://www.bareinternational.in/,

https://www.bareinternational.ph/,

https://www.bareinternational.sg/ internet addresses is operated by

Bare Associates International, Inc.

Registration number: 314809

Headquarters: 9990 Fairfax Boulevard, Suite 115., 22030 Fairfax VA, USA

Postal address: 9990 Fairfax Boulevard, Suite 115., 22030 Fairfax VA, USA

Telephone: +1 800 296 6699

E-mail address: info-us@bareinternational.com

(Controller hereafter).

We inform you that available at the above domain addresses website (hereafter: website) uses “cookies” in order to improve the quality of its services and to make the usage of the website easier, and also in case of your approval to present advertisements. Below you can read more about cookies in general, and subsequently about the processing of data by cookies on our website.

2. Cookies in general

2.1. What are cookies?

A cookie is such a group of data (alphanumerical information packet with changing content) that is sent to your device by the server of the website you are visiting. Cookies are stored in the browser program of your computer, telephone or tablet, which can be read later by sending server. Cookies cannot be read by other websites, only the one that has placed them. Cookies inform us about the way visitors use our website. Cookies can be used for various purposes, such as to measure the number of visits to the website or to facilitate browsing by remembering pages previously visited within the website.

No cookies contain personal information that could enable anyone to reach You through e-mail, telephone or post. Cookies themselves are not able to identify users, but to identify users’ devices. In case You do not want to accept the usage of cookies on the website You can set the browser You are using to send You a message about or to prevent placing them.

2.2. How can you regulate the operation of cookies?

We place cookies on the device you use to visit our website (your computer, phone or tablet). When you start browsing our website, you will be informed of this in a pop-up window when the home page loads.

Your approval does not have to be asked to implement cookies on your device which are necessary to ensure the functions and comfortable usage of our website. As anonymous visit analysis does not involve personal data processing, no consent is required. We have to ask your approval for other purposes such as data collecting from marketing purposes. Your permission will be asked in the pop-up window mentioned above. You can call up this window at any time by clicking on “Cookie preferences” at the bottom of the page, and you can change your consent to certain data collections at a later date.

Apart from the above-mentioned setting option provided by us You can decide to ban and delete Cookies any time in the settings of your browser. However, we inform You that without using cookies, You will not be able to reach several functions which make browsing easier, even some of our services will probably not function properly.

2.3. Handling settings of cookies in browsers

You can modify your setting of cookies through a pop-up window or your browser. You can ban the use of cookies by activating a setting in your browser which enables refusing all or certain cookies. These settings can usually be reached at the ”Settings” or ”Preferences” menu of your browser. You can get more information by using the following references.

Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/hu/kb/sutik-informacio-amelyet-weboldalak-tarolnak-szami?redirectlocale=en-US&redirectslug=Cookies

EDGE: https://support.microsoft.com and write the word ‘cookies’ into the URL bar.

Safari: https://support.apple.com/ and write the word ‘cookies’ into the browser.

Opera: https://help.opera.com/en/latest/web-preferences/#cookies

2.4. Types of cookies

Cookies can be either session cookies or temporary cookies that are valid at the time of processing  or persistent cookies, where we distinguish between first-party cookies (internal) and third-party cookies (external). Below you can read what these terms mean to better understand what cookies we use and why we use them.

2.5. Cookies valid during work process

Cookies appearing during work process make it possible for us to recognize You while visiting our website, so browser can memorize every site change or choice made from site to site during browsing inside the website. These cookies enable You to progress through and backwards various pages of a website fast and smoothly, without having to identify yourself at every page, or having to repeat processes (e.g. filling in a form). After finishing browsing a website, or closing a browser, cookies are automatically erased from your device.

2.6. Permanent cookies

Permanent cookies stay „permanent” on your computer for a certain period of time (days, weeks, months or years) after finishing browsing process, so they can help to recall preferences or activities of users when visiting the website later as well (e.g. by using them some data entered on the form at the given page might be stored). Until the end of expiry of validity period, saved cookies are stored on your device, however, You can delete them before determined deadlines.

2.7. Cookies coming from the operator of our website

These cookies come from the server of website being surfed. In this case, we are talking about functional cookies  and cookies that make usage comfortable  that are coming from the server storing website operated by Controller. We gave a description and details of functioning of them above. They possibly (according to your choice) remember IP address of your device, pages visited during browsing on the webpage.

This is to allow you to use the site without having to regularly repeat processes when you open a new page or return to the site after leaving it, opening the same pages or  at your decision  re-entering data. We use cookies in order to provide our registered users appropriate accesses; when users enter the website, they get necessary accesses. These cookies do not store any other information related to this, neither time of entry, nor who entered, we simply check entry entitlement with them.

These cookies are so-called work process cookies valid during browsing time. This means when somebody starts surfing the website, cookies are activated, and are valid until maximum of 15 minutes after the last activity, or are deleted when logging out.

An exception is a cookie that remembers – according to your choice  your log in data on your device, until you deleted it.

2.8. Cookies coming from a third party

Cookies from a third party do not come from Controller or server that stores the website. These cookies are stored by Your computer, telephone or tablet as well during Your visit as follows.

2.8.1. Visit analysis

Tools of Google Analytics©, Clarity (Microsoft), Linkedin and Twitter are used to monitor sites and collect information about the use of websites (number of visitors, visited sites, visitors’ country – from were he/she browses -, what other websites visitors have entered before, which browser they use, which operation system they use, which internet service they use, parameters of monitor visitors use, time of entering to the website and time of leaving it). We use these pieces of information to create statistics and improve our website.

We collect data only on a way which does not make it possible to identify the device you are using for browsing. It also means we are not able to identify you based on your browsing habits. We do not process personal data during visit analysis.

These pieces of anonymous data are also available for

Google Ireland Ltd. (Gordon House, Barrow Street, Dublin 4, Ireland) as Google’s,

Microsoft Ireland Ltd. (70 Sir Rogerson’s Quay, Dublin 2, Ireland), as Clarity’s,

Linkedin Ireland Unlimited Company (Gardner House, Wilton Plaza, Wilton Place, Dublin 2, Ireland), as Linkedin’s, and also

Twitter International Unlimited Company (One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland), as Twitter’s tools’ service providers.

In case you give your approval to collect your browsing data for marketing purposes, the above listed service providers use these data to send targeted advertisements to Users. The above listed service providers put together a group of interests based on browsing habits: they link data collected by cookies and IP address of browser device. Then it forwards specific advertisements to the device.

Cookies that serve marketing purposes can identify Your device during data collecting only if you give your approval.

For further information please visit the following websites:

https://www.google.com/analytics

https://support.google.com/analytics/answer/2838718?hl=en

https://clarity.microsoft.com/

https://www.linkedin.com/legal/l/cookie-table/

https://help.twitter.com/en/rules-and-policies/twitter-cookies

Google Analytics© cookies are so-called persistent cookies, they can be stored for maximum of two years, however, actual periods usually vary between only 2 hours to six months, depending on the type of cookies.

Tools of Clarity can be stored for maximum of 1 year, Linkedin’s tools for maximum of 30 days, Twitter’s tools for maximum of 2 years.

For further information about cookies including viewing, handling and deleting cookies that have been placed please visit http://www.allaboutcookies.org. In order to ban all tracking on any sites, please visit https://tools.google.com/dlpage/gaoptout.

2.8.2. Marketing Cookies

Google Ireland Ltd. (Gordon House, Barrow Street, Dublin 4, Ireland),

Meta Platforms Ireland Ltd. (Facebook  4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland),

Linkedin Ireland Unlimited Company (Gardner House, Wilton Plaza, Wilton Place, Dublin 2, Ireland),

Microsoft Ireland Ltd. (70 Sir Rogerson’s Quay, Dublin 2, Ireland),

Twitter International Unlimited Company (One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland),

UnrulyX  Tremor Group Companies (Tremor International Ltd, Tremor Video, Inc., Unruly, LLC formally known as RhythmOne, LLC, Unruly Group Ltd, 1177 Avenue of the Americas, 9th Floor, New York, NY, 10036)

(called together as Service Providers in the followings) ensure online marketing services through cookies and through so called ‘pixel’. Data processing during the use of the service is carried out by the Service Providers. Through these services, the Service Providers have access to the range of data described above, which are processed to measure website traffic and to map browsing habits.

These pieces of information are stored on devices of Service Provider’s as permanent cookies which work for no more than two years that are fixed on user’s device which was used for browsing. Users may delete these cookies on their devices in the settings menu of their browsers. During data collecting through pixel nothing is being stored in your browser. Service Providers also use these pieces of data to forward targeted advertisements to users. By linking data  which have been collected by cookies and pixel – and by identifying your browser or by the IP address of the browser, Service Providers gather a group of interests based on browsing habits. Based on these, they forward targeted advertisements to the users device.

For further information, please visit the following websites of the above lister Service Provider:

https://support.google.com/admanager/answer/2839090?hl=hu (Google),

https://developers.facebook.com/products (Facebook),

https://www.linkedin.com/ (LinkedIn),

https://clarity.microsoft.com/ és a https://www.bing.com/ (Microsoft),

https://twitter.com/ (Twitter),

https://unruly.co/legal/privacy/ (Unruly Group Ltd).

Cookies like these work on the page only with your approval.

3. Data processing implemented by log files and cookies applied on our website

3.1. Concerned parties in processing: All Users who visits these websites, regardless of whether they use the offered services or not.

3.2. Legal basis of processing: it is not compulsory to ask Your approval to process information that is technically absolutely necessary to provide services. Log files and certain cookies carry out the procession of such data. For more information about log files, see Chapter 4, and about the cookies involved, see below.

Data processing of technically absolutely necessary information is based on GDPR Article 6, Paragraph (1), Point f) and according to this it is the rightful interest of Controller.

Relying on this legal basis, Controller processes exclusively those types of data that are necessary to ensure a user-friendly operation of the website, and uses them only until it is necessary. These pieces of information are such technical data which are essential to provide an enjoyable appearance of the website, proper and comfortable use of its functions. Data are not forwarded to a third parties and are not used for any other purposes. In connection with these data, the Data Controller shall cooperate with the service providers indicated in Chapter 14 below. The processing does not involve any risks for the user, but without the use of this data the proper use of the website is not possible. It is the rightful interest of Controller to operate the website properly, as it can only provide its services this way, it is an inevitable condition for its functioning. Consequently, Controller processes information mentioned above in order to fulfil this goal as its rightful interest, and based on which rightful interest – as the processing does not pose a high risk to the user – Controller limits User’s autonomy to a proportional extent.

General visit analysis is performed by collecting anonymous data, so there is no need to process personal data. According to GDPR Article 6, Paragraph (1), Point a) the legal basis of marketing activities lies upon the consent of the User. User can give its consent to data collection for data processing and marketing purposes by clicking on the check boxes that pop up when User starts browsing on the website.

3.3. Determining the scope of processed data:

In order to ensure user-friendly browsing the processed data is:

• the websites visited during users visit and the order in which they are opened,
• User’s IP address.

Data involved in online marketing activities:

• The visited pages of the website and their subjects,
• Frequency of viewing the different pages of the website and measuring the time spent with browsing the different pages,
• Conclusions that can be drawn from these above about your interests,
• Your browser ID.

In case of storing data that is processed to check entry rights when entering website (can be stored based on User’s consent):

• User’s e-mail address (as user name) or user name,
• password,
• IP address of User’s device.

We perform visit analysis by collection anonymous data thus there is no need to process personal data.

3.4. Purpose of processing: to provide a user-friendly and safe operation of the website and to do some online marketing activity.

This includes the following:

Necessary and functional data processing (‘Indispensable’ and ‘Functional’ categories among pop-up windows):

• Identification of User’s browser device, and remembering identifying data during browsing time  based on IP address. Surfing the Internet becomes smoother, as without this function, Users would be obliged to identify themselves at each website they visit.

Necessary and preference cookies used on the website