Privacy Policy & Data Fiduciary Standard

1.1 Corporate Designation: KYNIGOS MANAGEMENT TECHNOLOGY SYSTEMS PRIVATE LIMITED ("Data Fiduciary", "Company", "Bear Systems", "We", "Us"), operating the commercial digital platform bearsystems.in, acts as the primary Data Fiduciary for all personal and technical data collected through our services.

1.2 Statutory Mandates: This Privacy Policy is enacted pursuant to Section 4 of the Digital Personal Data Protection Act, 2023 (DPDP Act), Rule 4 of the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, Regulation (EU) 2016/679 (GDPR), and the California Consumer Privacy Act (CCPA/CPRA).

Client authorizes Data Fiduciary to collect and process the following data streams:

• 2.1 Corporate Identity Data: Corporate legal name, representative names, designation, official email address, phone contact, billing address, and Goods & Services Tax (GST) registration numbers provided during onboarding;
• 2.2 Diagnostic Telemetry: Internet Protocol (IP) addresses, browser HTTP headers, user-agent fingerprints, session duration, sub-resource latency logs, API call error stacks, and system environment parameters;
• 2.3 Payload & Model Ingestion: JSON payload schemas, API request parameters, AI prompt tokens, vector embeddings, and ERP integration logs processed through active Statements of Work (SOW);
• 2.4 Job Applicant & Talent Network Data: Where a person applies through our careers page, we collect the CV and the answers they choose to give: name, contact details, current and past job titles and employers, years of experience, current and expected fixed pay, variable pay, notice period, location and work preferences, education, how they found us, and whether they are open to other roles. This is provided voluntarily, kept in our talent network shared with Helix Human Capital (an operating brand of the same company) only if the applicant ticks the consent box, used to match them to roles and, in anonymised and aggregated form only, to understand the job market. It is never shown to an employer in identifiable form without the applicant's agreement to that specific role. Applicants may ask for access, correction or erasure at any time through the contact address on this page.

Data Fiduciary processes personal data exclusively under valid statutory grounds:

• 3.1 Contractual Fulfillments: Rendering software deliverables, executing AI workflows, provisioning ERP tenants, and processing invoices;
• 3.2 Cybersecurity Defense: Intrusion detection, DDoS mitigation, API rate-limiting enforcement, and prevention of fraudulent activities;
• 3.3 Statutory Compliance: Compliance with mandates issued by the Indian Computer Emergency Response Team (CERT-In), Central Board of Direct Taxes (CBDT), and judicial subpoenas.

Online payment transactions, credit card authorizations, and UPI settlements initiated on our platform are processed exclusively through our authorized payment aggregator partner, Cashfree Payments India Private Limited ("Cashfree").

Client explicitly consents to the cross-border replication, processing, and encrypted storage of telemetry data across secure cloud infrastructure providers (including Amazon Web Services, Microsoft Azure, Google Cloud Platform, and Cloudflare) located internationally. All transfers feature AES-256 bit encryption at rest and TLS 1.3 encryption in transit.

TRANSMISSION OF DATA OVER PUBLIC INTERNET INFRASTRUCTURE IS INHERENTLY VULNERABLE. KYNIGOS MANAGEMENT TECHNOLOGY SYSTEMS PRIVATE LIMITED DOES NOT GUARANTEE THAT TELEMETRY AND DATA TRANSMISSIONS WILL BE 100% IMMUNE FROM UNAUTHORIZED INTERCEPTION, HACKING, OR ZERO-DAY EXPLOITS.

IN NO EVENT SHALL THE DATA FIDUCIARY BE LIABLE FOR UNAUTHORIZED THIRD-PARTY CYBER BREACHES OR EXFILTRATIONS OCCURRING BEYOND THE REASONABLE DIRECT CONTROL OF THE COMPANY.

KYNIGOS MANAGEMENT TECHNOLOGY SYSTEMS PRIVATE LIMITED retains the perpetual, worldwide, unencumbered right to anonymize, aggregate, de-identify, and compile usage telemetry, latency metrics, and AI performance logs. Aggregated de-identified data contains zero Personally Identifiable Information (PII) and may be retained indefinitely for machine learning model training, system diagnostics, and commercial benchmarking.

Bear Systems employs essential technical cookies, session tokens, and local storage mechanisms required strictly for user authentication, CSRF security verification, and Lenis smooth-scroll user interface preferences. Browsers may be configured to block cookies, though core application functionality may be degraded.

Subject to statutory verification under the DPDP Act 2023, Data Principals possess limited rights to request access, correction, or erasure of personal data held directly by the Data Fiduciary. Direct formal grievances to our designated Grievance Officer at info@bearsystems.co.uk.

KYNIGOS MANAGEMENT TECHNOLOGY SYSTEMS PRIVATE LIMITED reserves the right to amend this Privacy Policy at any time. Continued usage of our website or software services following publication of revised terms constitutes full acceptance.