Privacy.

Bare Associates International, Inc. Online Privacy Policy

We, Bare Associates International Incorporated (registered office: US-22030 Fairfax, Pender Drive 3702. #305.; company registration #: 314809) as data controller.

Hereinafter we are referred to as the “Company” or “We” and have evolved this privacy policy to meet all legal requirements and demonstrate our commitment to the privacy and protection of your data, and furthermore to inform you about the procedure of data processing carried out by the Company. The Company collects and stores your personal data in order to create a program to measure the experience of customers, guests, patients, patrons, riders, fans or clients of our partners with whom we had contracted (hereinafter referred to as ‘partner’), interacting with their services and brand and to have people resources to provide our Company’s services and provide you with information to schedule you to mystery shops/audits and, lastly to pay you for performing said assignments (hereinafter referred to as “Company’s services”).

Thank you for visiting our website, www.BAREInternational.com

This privacy policy tells you how we use personal information collected at this site. Please read this privacy policy before using the site or submitting any personal information.

By using the site, you are accepting the practices described in this privacy policy. These practices may be changed, but any changes will be posted and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review the privacy policy whenever you visit the site to make sure that you understand how any personal information you provide will be used.

Note: the privacy practices set forth in this privacy policy are for this web site only. If you link to other web sites, please review the privacy policies posted at those sites.

Collection of Information
We collect personally identifiable information, like names, postal addresses, email addresses, etc., when voluntarily submitted by our visitors. The information you provide is used to fulfill you specific request. This information is only used to fulfill your specific request, unless you give us permission to use it in another manner, for example, to add you to one of our mailing lists.

Cookie/Tracking Technology
The Site may use cookie and tracking technology depending on the features offered. Cookie and tracking technology are useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help customize the Site for visitors. Personal information cannot be collected via cookies and other tracking technology, however, if you previously provided personally identifiable information, cookies may be tied to such information. Aggregate cookie and tracking information may be shared with third parties.

Distribution of Information
We may share information with governmental agencies or other companies assisting us in fraud prevention or investigation.
We may do so when: (1) permitted or required by law; or, (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; or, (3) investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.

Commitment to Data Security
Your personally identifiable information is kept secure. Only authorized employees, agents, and contractors (who have agreed to keep information secure and confidential) have access to this information. All emails and newsletters from this site allow you to opt out of further mailings.

Privacy Contact Information
If you have any questions, concerns, or comments about our privacy policy you may contact us using the information below:

By e-mail: webmaster@bareinternational.com
By Phone: 800-296-6699

Website registration

Upon the registration on our website [https://www.bareinternational.com] you conclude a contract with the data controller to render the Company’s services (hereinafter referred to as Main Agreement). These partners have shops all around the world. The Main Agreement is a frame agreement which set outs the main obligations and rights of you and the Company. Please be informed that we provide worldwide services, therefore we have worldwide partners. The partner may request to the Company or any of its affiliated companies as defined below to render the Company’s services. The chosen company, in line with the information received from the partner, will choose the appropriate shopper to render the Company’s services for the partner and will conclude an individual agreement under the Main Agreement to specify the rights and obligations of the parties.

When you register we ask for information such as first name*, middle initial, last name*, email*, password*, address line 1*, address line 2, city*, state / province/ region, country*, zip/postal code*, landline phone*, mobile phone, birthdate*, gender*, height, weight, annual household income, hair, education, marital status, number of children, and in Belgium VAT number*. In order to pay you, we ask for your Social Security number (USA only), and your bank account details. Please be informed that we and the affiliate companies may evaluate you whether you are appropriate for and match the requirements written by the partner based on the personal data provided by you.

Once you register with the Company and sign in to our site, you are not anonymous to us as you have created your profile.

The Company does not require you to share all the data mentioned above, however lack of personal data indicated with * may exclude you from being selected to provide Company’s services. Collection and processing of personal data is based on your voluntary and explicit consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Should you withdraw your consent, We apply the processes detailed in this policy yet it leads to the termination of your Main Agreement.
By providing your personal data and clicking “GO”, you freely give your voluntary, explicit consent to the terms of our Online Privacy Policy and to Company’s processing of personal data for the purposes given above. We store and process your personal data based on and in line with the consent. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

We capture this personal data through the Company’s website, which is a secure site held on secure servers located in North America and operated by SurfMerchants, LLC, a SaaS (Software as a Service) company organized and existing under the laws of the United States of America, with its registered address at 29 Winchester St, Boston, MA 02116, represented by Tony Felos, Managing Partner. SurfMerchants utilizes Amazon’s AWS datacenters in the United States (Virginia) and Ireland with proxy servers (transmission only, no data stored) also located in Singapore and Ireland. For information regarding Amazon’s compliance with GDPR please visit the following links: https://aws.amazon.com/compliance/gdpr-center/;

https://aws.amazon.com/blogs/security/awsand-the-general-data-protection-regulation/. We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration and/or destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure such information. The Company only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. We allow you access to your own personal information, please see below.

We aim to collect, process and use as little personal data as possible. When we do collect your personal data, we aim to keep it as accurate and up to date as possible. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete it.

In the light of the above we handle your personal data to conclude and perform the rights and obligations under the Main Agreement and individual agreements; therefore, we retain your personal data for the term of the Main Agreement and individual agreements. However, in order to comply with legal requirements listed below by countries we need to retain your below mentioned personal data (hereinafter referred to as ‘mandatory retention period’):

  • In Hungary: name and address for the end of the 8th year upon termination of the Main Agreement in line with the Hungarian Tax Regime Act
  • In Belgium: name and address for the end of the 7 th year upon termination of the Main Agreement in line with the Belgian Tax Regime Act
  • In India: Under Income Tax Law, documents (books of accounts and other relevant documents) are required to be kept for 8 years.
  • In Chile: Paper documents and full records should be kept for 5 years.
  • In Brazil: name, address, company registration number for the period of 6 years upon termination of the Main Agreement in line with the Brazilian Tax Regime Act. In determined period for Employee data and agreements.
  • In China: Original payment documents should be kept for 10 years.

We work hard to protect your data from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. We implement security safeguards designed to protect your data. We regularly monitor our systems for possible vulnerabilities and attacks.

The Company does not rent, sell, or share ANY personal information about you with other people or nonaffiliated companies or noncontracted persons who are not listed below.

The Company shares your personal data provided by you with the affiliated companies as listed below and with our associates listed under this link which link we keep updated in order to render Company’s services. Affiliated companies and associates (under this policy together referred to as ‘affiliated companies’) act as data processors in the territory thereof:

  • BARE International Hungary Korlátolt Felelősségű Társaság (registered office: 1133 Budapest, Váci út 76. 4. em.; company registration number: 01-09-962318; VAT number: 23368743-2-41),
  • BARE International Inc., Belgium Branch (registered office: Meir 12, Antwerp 2000, Belgium; registration number: USA 314809; VAT number: BE 0829 488 075),
  • Bare Serviços Empresariais Ltda. (registered office: Av. Brigadeiro Faria Lima, 1478 – Conj. 801/808; company registration number: 21.399.260/0001-51; VAT number: 21.399.260/0001-51),
  • Bare International Chile Ltd (registered office: El Coihue 3776, Vitacura; company registration number: 76.049.533-0; VAT number: 76.049.533-0),
  • Bare Associates India Pvt. Ltd. (registered office: A-301, Sunteck Centre Subhash Road, Near Garware, Vile Parle East, Mumbai, Maharashtra 400057 India; company registration number: U74910MH2005PTC156287; VAT number: PAN: AACCB7026L GST:27AACCB7026L2ZJ),
  • Bare Group Singapore Pte Ltd (registered office: 160, ROBINSON ROAD, #17-01 SBF CENTER, SINGAPORE 068914; company registration number: 201212250N),
  • Bare Associates International (Shanghai) Co. Ltd. (registered office: 600 Luban Road Suite 803, Luwan District,Shanghai; Shanghai, 200032 China (People’s Republic of China); ; company registration number: 91310115789515748X; VAT number: 91310115789515748X)

Notwithstanding the above it may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for the Company to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We keep your personal data accurate, complete, and up-to-date however you can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account at https://www.bareinternational.com.
Where we process your personal data, you are entitled to a number of rights and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you. You can exercise your rights via our contact page https://www.bareinternational.com.

Please be informed that we and/or affiliated companies have the right to deactivate your profile if we detect any suspicious action or misconduct or fraud. You also have the right to deactivate your profile by any reason. Following deactivation, we retain your personal data for the same term as written in the mandatory retention period.

The right to access your personal data and correction

You have the right to access, correct or update your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us via our contact page https://www.bareinternational.com or by sending an email to welcome@bareinternational.com indicating the subject of the contact (e.g. ‘request for access to/correct/update my personal data’).

The right to data portability

Your personal data is portable. This means it can be moved, copied or transmitted electronically. However, this right only applies where:

a) The processing is based on your consent;

b) The processing takes place for the performance of a contract;

c) The processing takes place by automated means;

With respect of the above you have the right to receive your personal data provided by you, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

If you wish to exercise your right to data portability, please contact us via our contact page https://www.bareinternational.com or by sending an email to webmaster@bareinternational.com indicating the subject of the contact (e.g.’ request to exercise data portability right’).

The right to deletion of your personal data

You have the right to request the deletion of your data if:

a) your personal data is no longer necessary in relation to the purposes for which we collected it; or

b) you withdraw the consent that you had previously given us to process your personal data, and there is no other legal ground to process that personal data; or

c) any time if you wish to do so; or

d) the personal data is not being processed lawfully; or

e) your personal data needs to be deleted to comply with the law.

If you wish to delete the personal data we hold about you, please let us know via our contact page https://www.bareinternational.com or by sending an email to webmaster@bareinternational.com indicating the subject of the contact (e.g. ‘request for deletion of my personal data’) and we will respond to your request in 25 days.

If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete it.

The right to restriction of processing

You have the right to restrict the processing of your personal data if

a) you do not believe the personal data we have about you is accurate; or

b) the personal data is not being processed lawfully, but instead of deletion of the personal data, you would prefer us to restrict processing thereof; or

c) we no longer need your personal data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims; or

d) you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.

If you wish to restrict our processing of your personal data, please let us know via our contact page https://www.bareinternational.com or by sending an email to webmaster@bareinternational.com indicating the subject of the contact (e.g. ‘request for restriction of the processing of my personal data’) and we will respond to your request in 25 days.

The right to object You have the right to object to the processing of your personal data at any time. Please contact us via our contact page https://www.bareinternational.com or by sending an email to webmaster@bareinternational.com indicating the subject of the contact (e.g. ‘request for exercise right to object) and we will respond to your request in 25 days.

The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint directly with competent supervisory data protection authority about how we process personal data.

Furthermore, in case of infringement of any of your rights or if you are not satisfied with answer, information received by the Company you are entitled to seek remedy at the competent supervisory data protection authority and/or court.

Please find below the address of competent data protection authorities:

  • In USA: Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580; telephone: +1 (202) 326-2222
  • In Hungary: Hungarian National Authority for Data Protection and Freedom of Information (in Hungarian: Nemzeti Adatvédelmi és Információszabadság Hatóság; registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; mailing address: 1530 Budapest, Pf.: 5.; telephone: +36 (1) 391-1400; email: ugyfelszolgalat@naih.hu)
  • In Belgium: Commission for the Protection of Privacy (Drukpersstraat 35 1000 Brussels; telephone: +32 (0)2 274 48 78; email: commission@privacycommission.be)
  • In Singapore: Personal Data Protection Commission (460 Alexandra Road #10-02 PSA Building Singapore 119963, telephone: +65 6377 3131; email: info@pdpc.gov.sg)

If you have any questions or concerns regarding this policy, please contact webmaster@bareinternational.com

The English version of BARE’s Privacy Policy is considered to be legally binding!

Privacy Policy to contact third person

1) General legal statement

This privacy policy informs you about the rules of the processing your personal data in relation to contact you in order to inform you about our services and to conclude a contract with you.

We hereby inform you that we handle your data upon your consent. Should you wish to know more about us or to conclude contract with us, please give us your consent to do so. You can give your consent by replying to the email we sent you or contacting us via contact details below. The consent may be withdrawn at any time for free of charge. Should you wish to withdraw your consent, please contact us by using any of the contact information set out in section 2. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

2) Details of data controller:

Bare Associates International Incorporated

Registered office: US-22030 Fairfax, Pender Drive 3702. #305.;

Company registration #: 314809Email: dataprivacy@bareinternational.com

3) Lawfulness of processing:

We contact you in order to provide you information about our services in order to conclude a contract with you. Should you give us your consent, we keep in touch.

In the light of the above, the data processing of contacting you is based on ss. a) of s. 1 of Article 6 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR).

4) Source of data

The data described below is provided either directly by you (business card or through any of our employees) or indirectly via companies/persons with which we have concluded a contract (such as shoppers or any third parties which provide our services) or via public websites, databases.

5) Purpose of data processing

We contact you to provide you information about our service and to conclude a contract thereto.

6) Categories of personal data:

We process your following personal data:

  • name,
  • company you are working for,
  • job title,
  • email address,
  • PHONE NUMBERS.

We do not ask for any other personal data, including special categories of personal data, therefore please do not provide us with any of those.

7) Data processor, data transfer

We do not rent, sell, or share ANY personal information about you with other people or non-affiliated companies or noncontracted persons who are not listed below.

List of ‘affiliated companies’

  • BARE International Hungary Korlátolt Felelősségű Társaság (registered office: 1133 Budapest, Váci út 76. 4. em.; company registration number: 01-09-962318; VAT number: 23368743-2-41),
  • BARE International Inc., Belgium Branch (registered office: Meir 12, Antwerp 2000, Belgium; registration number: USA 314809; VAT number: BE 0829 488 075),
  • Bare Serviços Empresariais Ltda. (registered office: Av. Brigadeiro Faria Lima, 1478 – Conj. 801/808; company registration number: 21.399.260/0001-51; VAT number: 21.399.260/0001-51),
  • Bare International Chile Ltd (registered office: El Coihue 3776, Vitacura; company registration number: 76.049.533-0; VAT number: 76.049.533-0),
  • Bare Associates India Pvt. Ltd. (registered office: A-301, Sunteck Centre Subhash Road, Near Garware, Vile Parle East, Mumbai, Maharashtra 400057 India; company registration number: U74910MH2005PTC156287; VAT number: PAN: AACCB7026L GST:27AACCB7026L2ZJ),
  • Bare Group Singapore Pte Ltd (registered office: 160, ROBINSON ROAD, #17-01 SBF CENTER, SINGAPORE 068914; company registration number: 201212250N),
  • Bare Associates International (Shanghai) Co. Ltd. (registered office: 600 Luban Road Suite 803, Luwan District,Shanghai; Shanghai, 200032 China (People’s Republic of China); ; company registration number: 91310115789515748X; VAT number: 91310115789515748X)

8) Period of data processing:

Should you give your consent to contact with you, we use your personal data until we have the purpose to process to do so and you do not ask not to do so (means you did not exercise your right for erasure or to withdraw your consent).

Should you do not give your consent to contact you anymore, we delete your personal by recording anonym record. However, in this case we do not store any personal data which relates to you.

9) Storage of data

Your personal data is stored in electronic format. Servers are hosted in the European Union and in the USA.

We ensure the security of data against accidental or intentional destruction, annulment, alteration, damage, disclosure or unauthorized access during data processing. We ensure that only those employees may have access to your personal data who are obliged by us as employers to have access thereto.

10) Your rights

Where we process your personal data, you are entitled to – in addition to the withdrawal mentioned above – a number of rights and can exercise these rights at any point. You can exercise your rights by using any of the contact information set out in section 2.

The right to access your personal data and correction

You have the right to access, correct or update your personal data at any time.

You have the right to access to your personal data and to the following information:

  1. the purposes of the processing;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  4. where possible, the envisaged period for which the personal data will be stored;
  5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  6. the right to lodge a complaint with a supervisory authority.

We understand the importance of this and should you want to exercise your rights, please contact us. Our contact details are provided in section 2.

The right to data portability

Your personal data is portable. This means it can be moved, copied or transmitted electronically.

If you wish to exercise your right to data portability, please contact us. Our contact details are provided in section 2.

The right to deletion of your personal data

You have right to request that we delete your data if:

  1. a) your personal data is no longer necessary in relation to the purposes for which we collected it; or
  2. b) you withdraw the consent that you had previously given us to process your personal data, and there is no other legal ground to process that personal data; or
  3. c) you object to us processing your personal data for direct marketing purposes; or
  4. d) you object to us processing your personal data for our legitimate interests (such as improving overall user experience on websites);
  5. e) the personal data is not being processed lawfully; or
  6. f) your personal data needs to be deleted to comply with the law.

If you wish to delete the personal data, we hold about you, please let us know. Our contact details are provided in section 2.

The right to restriction of processing

You have the right to restrict the processing of your personal data if

  1. a) you do not believe the personal data we have about you is accurate; or
  2. b) the personal data is not being processed lawfully, but instead of deleting the personal data, you would prefer us to restrict processing instead; or
  3. c) we no longer need your personal data for the purposes we collected it, but you require the data in order to establish, exercise or defend legal claims; or
  4. d) you have objected to the processing of your personal data and are awaiting verification on whether your interests related to that objection outweigh the legitimate grounds for processing your data.

If you wish to restrict our processing of your personal data, please let us know. Our contact details are provided in section 2.

The right to object

You have the right to object to the processing of your personal data at any time. Should you wish to exercise your right to object, please contact us. Our contact details are provided in section 2.

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint directly with

  • In USA: Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, DC 20580; telephone: +1 (202) 326-2222
  • In Hungary: Hungarian National Authority for Data Protection and Freedom of Information (in Hungarian: Nemzeti Adatvédelmi és Információszabadság Hatóság; registered office: 1125 Budapest, Szilágyi Erzsébet fasor 22/c.; mailing address: 1530 Budapest, Pf.: 5.; telephone: +36 (1) 391-1400; email: ugyfelszolgalat@naih.hu)
  • In Belgium: Commission for the Protection of Privacy (Drukpersstraat 35 1000 Brussels; telephone: +32 (0)2 274 48 78; email: commission@privacycommission.be)
  • In Singapore: Personal Data Protection Commission (460 Alexandra Road #10-02 PSA Building Singapore 119963, telephone: +65 6377 3131; email: info@pdpc.gov.sg)

as supervisory authority about how we process personal data.

Dated: Budapest, 30th April 2020

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