Privacy Policy — pelczynski.net
Version: 1.0
Effective date: 2026-02-04
Last updated: N/A
1. Controller (who is responsible for your personal data)
The controller of personal data processed in connection with the website https://pelczynski.net (the “Website”) is:
Axis LLC
Legal form: Limited Liability Company
Registration number: 402101462
Registered address: Georgia, Tbilisi, Vake District, Besarion Zhgenti Street, N 49, Floor 1, Apartment N20
Privacy contact email: ten.iksnyzclep@ycavirp
Authorized persons / representatives: The Website’s content may be authored and the Website may be operated with support from individuals (including the attorney/author named in the Terms). They act solely on behalf of Axis LLC and not in their own name as data controllers.
EU representative (if applicable under GDPR Art. 27):
Axis LLC is not required to designate an EU representative under GDPR Article 27.
2. What this Privacy Policy covers
This Privacy Policy explains how we process personal data when you:
browse and read Website content,
download materials (e.g., PDFs),
interact with cookie settings and embedded third-party content (e.g., social media),
contact us (by email or via any contact functionality on the Website),
(if enabled in the future) subscribe to our newsletter.
This Policy is an attachment to the Website Terms of Use and should be read together with the Cookie Policy.
3. What data we process (categories)
- A) Device and usage data
IP address, date/time of access, requested URL, referral/previous page, browser/device information (user agent), language, and security/diagnostic events.
- B) Cookie and consent data
Your cookie preferences and the technical record of your consent choices (e.g., categories selected, time, and proof that choices were recorded). - C) Contact/correspondence data
If you contact us: your email address, name (if provided), message content, attachments you send, and technical metadata of communication. - D) Social media / third-party embed data (if you enable it)
If you enable marketing/statistics cookies or load social embeds, third parties (e.g., Meta/Facebook, LinkedIn, Google Fonts) may receive data such as IP address, device/browser data, referrer URL, and cookie identifiers.
4. Purposes of processing and legal bases (GDPR Art. 6)
We process personal data for the following purposes:
Providing and securing the Website (incl. bot protection, performance, troubleshooting)
Legal basis: GDPR Art. 6(1)(f) (legitimate interests: operating and securing the Website, preventing abuse, ensuring availability).
Managing cookie consent and applying your choices
Legal basis:
For storing/accessing information on your device (cookies): we rely on your choices collected via our consent tool, as described in our Cookie Policy (functional cookies may be “strictly necessary”; other categories require opt-in).
Where cookie identifiers constitute personal data, we rely on GDPR Art. 6(1)(a) (consent) for non-essential categories, consistent with EDPB consent guidance.
Responding to inquiries and maintaining correspondence
Legal basis: GDPR Art. 6(1)(f) (legitimate interests: communication and handling requests).
Establishing, exercising, or defending legal claims
Legal basis: GDPR Art. 6(1)(f) (legitimate interests: claims handling).
Newsletter (only if/when enabled)
If newsletter subscription becomes available, we will process subscriber data to send the newsletter you requested.
Educational newsletter delivery: typically GDPR Art. 6(1)(b) (service requested) or Art. 6(1)(a) (consent) depending upon how subscription flow will be implemented (we will specify at sign-up).
Marketing offers (separate consent): GDPR Art. 6(1)(a) (consent), and the relevant electronic marketing consent rules as referenced in our Terms/Cookie Policy bundle.
5. Cookies and similar technologies (summary; details in Cookie Policy)
We use a consent tool (Complianz) and present cookie choices on first visit.
According to our Cookie Policy, cookies/technologies may include:
Functional/technical: WordPress cookies; LiteSpeed/LSCache; Cloudflare’s bot filtering cookie __cf_bm; Complianz consent cookies (e.g., cmplz_*).
Third-party resources/cookies (subject ngs): Google Fonts, Facebook (Meta), LinkedIn (including marketing/statistics cookies when enabled).
Important: You can change your cookie preferences at any time via the Website cookie settings and by using your browser settings. Withdrawing consent does not affect the lawfulness of processing before withdrawal.
6. Social media embeds and “joint controllership” (collection/transmission stage)
If we embed social media elements (e.g., Facebook/LinkedIn content/buttons) and you enable them, your browser may transmit certain data to those providers.
For the collection and transmission of data to a social media provider triggered by embedding a plugin/button, website operators can be regarded as joint controllers with the provider for that initial stage (while the provider is generally controller for subsequent processing on its own platform).
How we handle this in practice: we seek to load such third-party content only after your consent choices (where required) and we refer you to the provider’s own privacy information for their subsequent processing.
7. Recipients of personal data
We may disclose personal data to:
Infrastructure and security providers (e.g., CDN/bot protection such as Cloudflare) to deliver and protect the Website.
Consent management tooling (Complianz) cookie preference record.
Third-party content providers you choose to enable (Google Fonts, Meta/Facebook, LinkedIn).
Authorities where required by law.
Some recipients are processing on our instructions, while others (e.g., major platforms like Meta/LinkedIn) may act as independent controllers for their own purposes.
Our Cookie Policy indicates that some third-party providers (e.g., Facebook and LinkedIn) are located in the United States.
When personal data is transferred to recipients in the US or other third countries, we use appropriate safeguards under GDPR Chapter V, such as:
relying on the EU-US Data Privacy Framework adequacy decision where the recipient is actively certified (Commission Implementing Decision (EU) 2023/1795),
and/or Standard Contractual Clauses (SCCs) with supplementary measures where required, in line with EDPB transfer guidance.
Public evidence of DPF certification (as of the cited sources) exists for Cloudflare, Meta Platforms, and LinkedIn on the official DPF registry.
9. Retention (how long we keep data)
We keep personal data only as long as necessary for the purposes described:
Server/security logs: typically kept for a limited period necessary for security and troubleshooting, then deleted or anonymized unless needed for incident investigation or legal claims.
Correspondence: kept for as long as needed to handle your request, then for a reasonable period to ensure continuity and for claims defense.
Cookie data: cookie lifetimes vary by cookie; the Cookie Policy lists cookie expirations (including long-lived thenabled).
10. Your rights (GDPR Arts. 15–22) and how to exthe right (subject to GDPR conditions) to:
access your data (Art. 15), rectification (Art. 16), erasure (Art. 18), portability (Art. 20),
objecting to processing based on legitimate interests (Art. 21),
withdrawal of consent at any time where processing is based on consent (Art. 7(3)).
To exercise rights, contact: ten.iksnyzclep@ycavirp.
11. Complaints to a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member state of you usual residence, place of work, or place of the alleged infringement (GDPR Art. 77).
12. Whether providing data is mandatory
Browsing: providing data is not a statutory requirement, but some technical data (e.g., IP address) is processed automatically to provide and secure the Website.
Contact: providing your email and message content is voluntary, but necessary if you want a reply.
13. Automated decision-making
We do not use automated decision-making (including profiling) that produces legal or similarly significant effects within the meaning of GDPR Art. 22.
14. Security
We apply appropriate technical and organizational measures proportionate to the risks (GDPR Art. 32), including access controls and security monitoring suitable for a public informational website.
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The current version is published on the Website with the “Last updated” date.