We, Bare Associates International Incorporated (registered office: US-22030 Fairfax, Pender Drive 3702. #305.; company registration #: 314809) as data controller.
Thank you for visiting our website, www.bareinternational.com
I. WEBSITE USAGE
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 fulfil your specific request or to lead you through our MSP registration process, unless you give us permission to use it in another manner,
We capture personal data through the Company’s website, which is a secure operated by Automattic Inc.’s WordPress service, a company organized and existing under the laws of the United States of America, with its registered address at 60 29th Street #343 San Francisco, CA 94110 USA, represented by Matt Mullenweg. Some personal data we capture through the services of Instapage Inc., a company organized and existing under the laws of the United States of America, with its registered address at 118 King St. Suite 450 San Francisco, CA 94107, represented by Tyson Quick.
We take all reasonable steps to protect information we received 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.
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, investigation or marketing activities. 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; or, (4) sending and following up on marketing campaigns in regards to service advertisement or registration follow up.
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.
In order to comply with legal requirements, we retain the personal data you provided for the period of one year.
II. MYSTERY SHOPPING PORTAL
Upon the registration on our website [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 sets out 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 into 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 those personal data (which are not necessary to be given) 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. Collection and processing of personal data which indicated with * is based on the Main Agreement (to conclude and perform that contract).
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 LiveShopper, 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 129 E Crawford St, Findlay, OH 45840, represented by Tony Felos, Managing Partner. LiveShopper utilizes Amazon’s AWS data centers 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/aws-and-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 7th 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 non-affiliated 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: 1134 Budapest, Váci út 47.; 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. Tiradentes, 998 – 8.º andar São Paulo, SP, 01102-000; company registration number: 21.399.260/0001-51; VAT number: 21.399.260/0001-51),
- Bare International Chile Ltd (registered office: Apoquindo 6410 of 605, Las Condes, Santiago, Chile, company registration number: 76.049.533-0; VAT number: 76.049.533-0),
- Bare Associates India Private Limited. (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: 105 Cecil Street, #18-00 The Octagon (Suite 1826), SINGAPORE 069534; company registration number: 201212250N)
- Bare Associates International (Shanghai) Co. Ltd. (registered office: Suite 704, 757 Mengzi Road, Huangpu District, Shanghai, 200023 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 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 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 www.bareinternational.com or by sending an email to DataPrivacy@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 www.bareinternational.com or by sending an email to DataPrivacy@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 www.bareinternational.com or by sending an email to DataPrivacy@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 www.bareinternational.com or by sending an email to DataPrivacy@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 www.bareinternational.com or by sending an email to DataPrivacy@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: 1055 Budapest, Falk Miksa utca 9-11.; mailing address: 1363 Budapest, Pf.: 9.; telephone: +36 (1) 391-1400; email: firstname.lastname@example.org)
- In Belgium: Commission for the Protection of Privacy (Drukpersstraat 35 1000 Brussels; telephone: +32 (0)2 274 48 78; email: email@example.com)
- In Singapore: Personal Data Protection Commission (460 Alexandra Road #10-02 PSA Building Singapore 119963, telephone: +65 6377 3131; email: firstname.lastname@example.org)
If you have any questions or concerns regarding this policy, please contact DataPrivacy@bareinternational.com