Privacy Policy for Bearstone Global


Last updated: October 14, 2022

This Privacy Policy contains:

I. GDPR Privacy,

II. Cookies and other similar technology Policy,

III. Detective Law Privacy Statement.

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Bearstone Global sp. z o.o., Tytusa Chałubińskiego 8, Warszawa 00-613.

    For the purpose of the GDPR, the Company is the Data Controller.

  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • Country refers to: Poland

  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Personal Data is any information that relates to an identified or identifiable individual.

    For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

  • Service refers to the Website.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Website refers to Bearstone Global, accessible from

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

    Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.


Please be informed that Bearstone Global sp. z o.o. with its registered seat in Warsaw as the Data Controller is committed to protecting Your privacy and ensuring the security of personal data, which it processes.

This information sets out how personal data are collected and used in accordance with the provisions of the GDPR (General Data Protection Regulation, i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016). In particular, it fulfils the obligation to provide a data processing notice under Article 14(5)(b) of the GDPR and national legislation.

Legal Basis for Processing Personal Data Under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.

  • Performance: of a contract: Provision of Personal Data is necessary for the performance of an agreement with You, a third party and/or for any pre-contractual obligations thereof.

  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.

  • Vital interests: Processing Personal Data is necessary to protect Your vital interests or of another natural person.

  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.

  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision or obtaining of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Data Controller

The controller of personal data, i.e., the entity which decides how personal data entrusted and processed in connection with its activities will be used, is the Company.

Processing of Publicly Available Data

In the course of its business activity and for the purpose of proper performance thereof, the Data Controller processes, among others, publicly available personal data, in particular data extracted from public registers. Such data shall be adequate, relevant and limited to what is necessary for the purposes of performance of agreements concluded by the Data Controller.

Waiver of Certain Rights Concerning the Obligation to Provide a Data Processing Notice

Referring to the exceptions indicated in Article 14(5)(b) and (d) of the GDPR, We inform You that it may occur in Your case that We waive some of the rights with regard to the obligation to provide a data processing notice when We obtain personal data by means other than from the data subject.

This is the case if providing You with such information would be impossible or would require a disproportionate effort, or if complying with the obligation to provide a data processing notice would make it impossible or significantly more difficult to achieve the purpose for which We process Your personal data, or if it would involve a breach of professional secrecy binding for licensed detectives.

In Our activity, such cases will primarily, but not exclusively, involve the processing of data obtained in the course of provided detective services or from publicly available sources, where the fulfilment of the obligation to provide a data processing notice would negate the purpose of the processing of Your data, i.e., the purpose of Our clients commissioning Us with particular activities as part of Our activity, or would even violate the statutory obligation to maintain professional secrecy.

Cases in which there is an exemption from the information obligation may be frequent. Given the specific nature of Our business, in the course of executing agreements with Our clients, it often happens that data originating from detective services is combined with data from publicly available sources and reported to the client. As a rule, the data does not originate from the subject. In such a situation, fulfilment of the obligation to provide a data processing notice would defeat the purpose of the entire agreement, the legitimate interest of Our client and would violate the obligation of professional secrecy.

The impossibility to fulfil the obligation may also be related to the lack of sufficient data to fulfil the obligation to provide a data processing notice. In this case, the data minimisation principle of Article 5(1)(c) of the GDPR applies, as to comply with the information obligation, We would have to obtain more personal data than it is necessary for Us to fulfil the purposes for which We process the data, beyond the scope of Your data processed by Us.

We assure You, however, that We treat and analyse each case of exemption from the obligation to provide a data processing notice individually.

The Period in Which Your Data Are Processed

In the event that You are the subject of detective activities, or We process Your publicly available data as part of Our services, We will only process some of Your data for as long as We provide the service to the client associated with You. In each case this period should not exceed a few months. We will subsequently pass on Your data to the client and permanently delete it ourselves. If the client does not receive the data, We will archive the data in an encrypted form for a period of 5 years of the date of termination of the service.

If You are Our client or client's representative, We will process Your data for the duration of the performance of the agreement on Your behalf or on behalf of the entity You represent and until expiry of the statute of limitations for mutual claims arising from the performance of the agreement.

If You are Our subcontractor, We will process Your data for the duration of the service provided to Us and until the expiry of the statute of limitations for mutual claims arising from the performance of the service. If You have given separate consent, We will include You in Our internal subcontractor database until You withdraw Your consent.

Categories of Personal Data Processed

In performance of Our business activity, We process the following (non-sensitive) categories of personal data depending on the case: first name, surname, age, domicile, registered address, PESEL, ID card/other document series and number (e.g. passport), tax identification number, date and place of birth, telephone number, profession, salary, marital status, nationality, education, e-mail address, internet identifiers, IP addresses, cookie identifiers - generated by devices, applications, tools and protocols, voice recording of a telephone conversation, vehicle licence plates, gender, information about being in a specific place, image (not as biometric data).

We only ever process data that are necessary in a specific case and never as ‘back-up’.

Information on Recipients of Personal Data

The recipients of the personal data collected by Us as part of the services We provide as part of Our business activities are Our customers who use the services.

Your Rights Under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, You can request Us for an access, update or delete of Your Personal Data This also enables You to receive a copy of the Personal Data We hold about You.
  • Request restriction of processing Your Personal Data. You have the right to request restriction of Your Personal Data processing if We process them too widely, without due justification.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to Our processing of Your Personal Data on this ground.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using Your Personal Data. This right exists where We are relying on Your consent as the legal basis for Our processing.

Transfer of Personal Data Outside the European Economic Area

Personal data may be transferred outside the European Economic Area, including within the group to which the Data Controller belongs, i.e. to Bearstone Global Ltd. with its registered seat in Great Britain.

The European Commission has confirmed that Great Britain provides an adequate level of protection for personal data in Decisions C (2021) 4800 final - under Regulation (EU) 2016/679 and C (2021) 4801 final - under Directive (EU) 2016/680 of 28 June 2021, which allows for the free transfer of personal data to entities based in Great Britain.

Your personal data may also be transferred outside the EEA as part of the performance of contracts for Our customers outside the EEA - but always within the limits of and in compliance with the relevant data protection legislation, i.e. only if possible and in compliance with the relevant data processing rules.

Entrustment of Personal Data Processing

The Data Controller may entrust the processing of Your personal data to entities cooperating with the Controller on the basis of written agreements, in particular personal data processing entrustment agreements, in order to perform certain tasks and services for the Data Controller.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that We may ask You to verify Your identity before responding to such requests. If You make a request, We will try Our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.


Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: All About Cookies by TermsFeed.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

  • Tracking and Performance Cookies

    Type: Persistent Cookies

    Administered by: Third-Parties

    Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.


We may use third-party Service providers to monitor and analyze the use of our Service.

  • Google Analytics

    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

  • Albacross

    Their Privacy Policy can be viewed at


  • Processing of personal data collected through activities defined as detective services per the Detective Services Act of 6 July 2001 is not subject to the provisions set forth by article 13 paragraphs 1 and 2 and article 15 paragraph 1 points (a), (c), and (g) 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 (General Data Protection Regulation) (Official Journal of the European Union L 119/1).

  • Do przetwarzania danych osobowych zebranych w toku wykonywania czynności rozumianych jako usługi detektywistyczne zgodnie z Ustawą o usługach detektywistycznych z dnia 6 lipca 2001, nie stosuje się przepisów art. 13 ust. 1 i 2 oraz art. 15 ust. 1 lit. a, c i g rozporządzenia Parlamentu Europejskiego i Rady (UE) 2016/679 z dnia 27 kwietnia 2016 r. w sprawie ochrony osób fizycznych w związku z przetwarzaniem danych osobowych i w sprawie swobodnego przepływu takich danych oraz uchylenia dyrektywy 95/46/WE (ogólne rozporządzenie o ochronie danych) (Dz. Urz. UE L 119 z 04.05.2016, str. 1, z późn. zm.1).


We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


If you have any questions about this Privacy Policy, You can contact us: