Cookie Policy

1. Data Controller

The webpage at https://www.bareinternational.com/ internet address 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: [email protected]

(Controller hereafter).

We would like to inform you that we use “cookies” on the website available at the above domains (hereinafter: website) in order to improve the quality of its services, facilitate the use of the website and, with your consent, for the purpose of website analytics and the display of online advertisements. Below you can read about cookies in general, following that about the data processing carried out by the 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 programme 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.

Functions similar to cookies can also be implemented with tools that cannot be considered cookies in the IT sense, because they only partially correspond to the above description. However, from the point of view of data protection and data management, the rules regarding cookies must also be observed when using such tools, therefore, the term cookie mentioned in this document should also include such additional tools.

2.2. How can you regulate the operation of cookies?

We place cookies on devices (computer, telephone or tablet) You are using during your visit on our website. We inform You about this at the beginning of browsing our website, when the main page is loading, in a pop-up window.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. We need your consent to start the operation of the cookies used to identify your device and to analyse anonymous visits and to collect data for marketing purposes. Your permission will be asked in the pop-up window mentioned above. This window can be brought up at any time by clicking on ‘Cookie settings’ sing at the bottom of the screen and your permission to each data collecting may be changed later as well.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 ‘necessary/functional’ 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 session 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. Such cookies are automatically deleted from your device after browsing the page or closing the browser, but within a few hours at most.

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 decission – 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 session cookies, so they are valid during the duration of browsing. This means that when someone starts browsing the website, the cookie gets activated and then lasts for a few hours maximum after the user’s last activity, or expires at log 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. Website analytics

Tools of 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.

The website analytics with the settings used by us results in anonymous statistical data on the basis of which your device (and you) cannot be identified. However, Microsoft Ireland Ltd., the providers of analytical cookies, may potentially be able to identify your device and you in view of the additional services provided directly to you. However, we cannot identify you or your device in this case either.

The data collected this way is accessible for Microsoft Ireland Ltd. (70 Sir Rogerson’s Quay, Dublin 2, Ireland) as Microsoft’s service providers.

For further information please visit the following website: https://www.microsoft.com/

Tools of Microsoft can be stored for maximum of 1 year.

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), Microsoft Ireland Ltd. (70 Sir Rogerson’s Quay, Dublin 2, Ireland) (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 13, 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://www.microsoft.com/ (Microsoft).

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

3. The data processing implemented by us in connection with the cookies and log files used on our website

3.1. 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.
Website analytics is made by collecting anonymous data so it does not involve personal data management.
With regard to the data management that enables marketing activities, as well as website analytics, the legal basis for data management is your consent based on point a) of Article 6 (1) of the GDPR. You can contribute to the collection of data for marketing purposes and website analytics by checking the box in the information window that pops up when you start browsing the website. Although we do not process personal data based on the website analytics data, as Google can potentially identify you, we can only use the website analytics with your consent.

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.

The general website analytics is carried out by collecting anonymous data, so we do not manage personal data in this regard.

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:

a) Necessary data processing (‘Essential’ 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.

Essential cookies used on the website

cookie name	provider	purpose of data collection	expiration
TERMLY_API_CACHE	Termly Inc.	Used to store visitor’s consent result in order to improve performance of the consent banner.	1 year
csrf_token	Bare Associates International, Inc.	Protects against hacking and malicious actors.	29 days
_cf_bm	CloudFlare Ltd.	This cookie is used to distinguish between humans and robots (programs). It does not track users, its purpose is specifically to protect against attacks and overloads caused by bots.	29 minutes
_cfuvid	CloudFlare Ltd.	It helps to distinguish real users from automated requests in order to protect against denial-of-service attacks (DoS) and malware.	until the end of browsing session
termly_gtm_template_default_consents	Termly Inc.	Used to store visitor’s consent preferences so that the consent banner does not needto be shown on each visit.	1 year

b) Functional data processing (‘Performance’ categories among pop-up windows):

These cookies are used to enhance the performance and functionality of your website, but are not essential to its use. However, without these cookies, certain functionality may become unavailable.

Performance cookie used on the website:

cookie name	provider	purpose of data collection	expiration
wpEmojiSettingsSupports	Bare Associates International, Inc.	It verifies and supports the correct display of emojis in the user’s browser.	until the end of browsing session

c) Data processing about browsing habits (‘Analytics’ category among pop-up windows):
the following data required for the following purposes are recorded by us anonymously, they cannot be linked to a person. In this case, we do not process your personal data.

• Measuring visits to the website, measuring the frequency of views of individual pages of the website and measuring the duration of browsing on individual pages of the website in order to adapt the website to the needs of users and to learn about their interests.
• Approximate location of the device used for browsing (part of the country), for the purpose of mapping the territorial distribution of interest in our service.
• Identifying the website from which you came to this website in order to learn about other topics of interest to those interested in our service.

By collecting the above anonymous data, we can measure the awareness of our service and the effectiveness of our marketing activities, and make them more effective.

We use the tools of Microsoft (Microsoft Ireland Ltd.) to collect this data. When viewing pages that use Microsoft tools, Microsoft cookies remember the preferences and information you indicate, which also means that we learn about anonymous data that is used to measure website traffic and map browsing habits.

Analytics cookies used on the website:

cookie name	provider	purpose of data collection	expiration
_clck	Microsoft Ireland Ltd.	Retains the Clarity user ID and website-specific preferences.	1 year
_clsk	Microsoft Ireland Ltd.	Connects multiple page views into a single Clarity session recording.	1 day
CLID	Microsoft Ireland Ltd.	Identifies when Clarity first encountered a browser on a website using Clarity.	1 year

d) Data processing for marketing purposes (‘Advertising’ category among pop-up windows):

In case you agreed to collect browsing data to use them for marketing purposes we are able to show you targeted advertisements during you are browsing on the Internet.

For the purpose of displaying targeted advertising, we may use tools from Google Ireland Ltd, Microsoft Ireland Ltd to display our own advertising on your device, but the data required to do so is also used by these providers for their own purposes, to display third party advertising. The display of such advertisements is based on your browsing habits and interests. While doing so, the above listed Service Providers set out the possible interests by connecting data of browsing habits and your browser ID of the browser that was used for searching then targeted advertisements are sent to the given device. This means that the data is not directly linked to you, but to the device you use to browse the site, in particular your browser.

Advertising cookies used on the website:

cookie name	provider	purpose of data collection	expiration
_gcl_au	Google Ireland Ltd.	Used by Google Ads for experimenting with advertisement efficiency across websites using their services.	2 months 29 days
test_cookie	Google Ireland Ltd. (DoubleClick)	A session cookie used to check if the users browser supports cookies.	15 minutes
IDE	Google Ireland Ltd. (DoubleClick)	Used to measure the conversion rate of ads presented to the user. Expires in 1.5 years.	13 months
_gcl_ls	Google Ireland Ltd.	Stores Google Ads campaign click IDs (GCLID) in Local Storage to track conversions and ad performance.	13 months
ANONCHK	Microsoft Ireland Ltd. (Microsoft Clarity)	Indicates whether the Microsoft MUID identifier can be transferred for advertising purposes. Clarity normally sets it to 0.	10 minutes
MR	Microsoft Ireland Ltd. (Microsoft Clarity)	Indicates whether the Microsoft MUID cookie should be refreshed.	7 days
MUID	Microsoft Ireland Ltd. (Microsoft Clarity)	Identifies unique browsers across Microsoft services for analytics, advertising and operational purposes.	1 year
SM	Microsoft Ireland Ltd. (Microsoft Clarity)	Synchronises MUID across Microsoft domains.	Until the end of browsing session.
721297562; 747844380; 835655372; 747575397; 978815962	Google Ireland Ltd.	Used to display personalized ads and track conversions.	Up to 13 months

e) The data for the following purposes will be processed in a way that it will make you identifiable, but we will only have access to it when you log in for such technical purposes, otherwise it may be stored on your device:

• your e-mail address or username and password, maybe storing them for making entering easier (based upon your decision, recording them on your device)
• during checking your access rights your e-mail address (as username) or your username and password (on an encrypted way, we do not know them), IP address of your browsing device.

3.5. Period of processing: Controller processes a part of data for the period of browsing, other data is stored for a variable time, but maximum of 1 year 1 month 4 days.

Data necessary for the operation of website in a user-friendly way (IP address, order of web pages visited during browsing) is recorded for the duration of browsing session, they are deleted when browsing finishes. Handling of these data is done by our own IT devices, third party does not have any access to them.

Website analytics is carried out by collecting anonymous data, so we do not process personal data in this connection.

Data which serve as a base for measuring visits and mapping Users’ habits of website is stored for maximum of 13 months. Cookies that make it possible are stored on your device. Deleting these cookies or prohibit their operation can be done at any time by you with the settings of your browser and also with switching off ‘Analytics’ and ‘Marketing’ categories if you click on ‘Cookie settings’ sign at the bottom of our website.

3.6. Way of data storing: on separate lists in our information technology system. Data related to providing a user-friendly services (IP-address, the order of sites visited during browsing session) are not stored by us. Pieces of information provided by cookies are stored on User’s device. Cookies that gives data are stores on your device.

3.7.     For more information about information technology processing using tools from Google, Microsoft, please visit the website of

Google https://policies.google.com/technologies/cookies and
a Microsoft https://www.microsoft.com/.

The above listed Service Providers offer several different functions but we use only those that have already been named above.