Legal

Privacy Notice

Information on the processing of personal data in accordance with Articles 13 and 14 of the General Data Protection Regulation (EU) 2016/679 (GDPR).

Last updated: 15 October 2026

1. Controller

Pensero Ltd, Agias Vryainis 12, Plot 495, 8560 Pegeia, Paphos, Cyprus. Email: eddy@pensero.com.

Pensero Ltd has not appointed a data protection officer, as it is not required to do so.

2. Summary

This website is a static website. It does not use cookies, analytics or tracking tools, social media plug-ins, externally loaded fonts or scripts, or contact forms. Personal data is processed only to the extent described below.

3. Hosting and server log files

This website is hosted by GitHub, Inc., 88 Colin P. Kelly Jr. Street, San Francisco, CA 94107, USA (GitHub Pages). When the website is accessed, the hosting provider’s servers automatically process technical data transmitted by the browser in order to deliver the website and to ensure its security and stability. This may include the IP address, date and time of the request, the page requested, the referring URL, the browser type and version and the operating system.

Legal basis: Article 6(1)(f) GDPR (legitimate interest in the secure and reliable provision of the website). Log data is retained by the hosting provider for a limited period in accordance with the GitHub Privacy Statement and then deleted. The hosting provider acts as processor on behalf of Pensero Ltd. Where the provider processes data outside the European Economic Area, this is based on an adequacy decision or on standard contractual clauses pursuant to Article 46 GDPR.

4. Contact by email

If you contact Pensero Ltd by email, the data you provide (such as your name, email address and the content of your message) is processed in order to deal with your enquiry. Legal basis: Article 6(1)(b) GDPR where the enquiry relates to a contract or pre-contractual measures, otherwise Article 6(1)(f) GDPR (legitimate interest in responding to enquiries). The data is deleted once it is no longer required for this purpose, unless statutory retention obligations apply.

5. Recipients

Personal data is not sold or transferred to third parties. Recipients are limited to the hosting provider and the email service provider used by Pensero Ltd (Microsoft Ireland Operations Limited, Microsoft 365), acting as processors, and to authorities where required by law.

Transfers outside the EU

GitHub, Inc. is located in the United States and is certified under the EU-U.S. Data Privacy Framework. Transfers are based on the European Commission’s adequacy decision of 10 July 2023 (Article 45 GDPR) and, where applicable, standard contractual clauses (Article 46 GDPR).

6. Your rights

Under the GDPR you have the right of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20) and the right to object to processing based on legitimate interests (Article 21). To exercise these rights, please contact Pensero Ltd at the email address above.

7. Right to lodge a complaint

You have the right to lodge a complaint with a supervisory authority. The competent authority in Cyprus is the Office of the Commissioner for Personal Data Protection, Nicosia (www.dataprotection.gov.cy). You may also contact the supervisory authority in your country of residence.

8. Changes

This notice may be updated if the website or the applicable legal requirements change. The current version is published on this page.