privacy, security and confidentiality policy
Effective date: 9 November 2025
Company: Pansyer LLC
Address: Sofia, Bulgaria
Website: pansyer.com
about this policy
Pansyer LLC provides digital strategy, marketing, design, and technical services for businesses. Trust, discretion, and operational integrity are core to how we work.
This Privacy, Security and Confidentiality Policy explains how we collect, use, protect, and disclose personal data and confidential information when you interact with our website, communicate with us, or engage our services.
If a contract, data processing agreement, or confidentiality agreement applies to your relationship with us, that document will take precedence where it provides additional or stricter protections.
scope and roles
This policy applies to personal data processed by Pansyer in connection with:
• Our website and online properties
• Sales and partnership communications
• Client projects and service delivery
• Marketing and business development activities
• Administrative, legal, and operational processes
This policy does not apply to third-party platforms, tools, or websites that we do not control, even if they are linked from our website.
Depending on the context, Pansyer may act as:
• A data controller when determining how and why personal data is processed
• A data processor when acting on behalf of a client under their instructions
Where we act as a processor, the client remains responsible for determining the purpose and legal basis of processing.
data we collect
Information you provide
When you contact us or engage our services, we may collect personal and business information such as your name, email address, phone number, company, role, and country. We also process information you voluntarily provide in inquiries, briefs, proposals, feedback, meetings, or communications.
If you share project materials, credentials, files, documents, or access to systems, this information is processed strictly for service delivery and handled confidentially.
Where applicable, we also process billing and invoicing information required for contractual and legal purposes.
Information collected automatically
When you visit our website or use our digital services, we collect limited technical information necessary to operate and secure our systems. This may include IP address, approximate location derived from IP, browser and device information, operating system, language preferences, referral data, page interactions, and error logs.
We use cookies and similar technologies only for essential functionality, security, and performance measurement. Where required by law, optional cookies are used only with your consent.
Information from third parties
In limited cases, we may receive business contact information from partners, referrals, or publicly available professional sources where legally permitted. If you authorize access to third-party platforms such as analytics, advertising accounts, or collaboration tools, we process only the data necessary to provide the agreed services.
purpose of processing
We process personal data only for clearly defined and legitimate purposes. This includes delivering and managing services, responding to inquiries, executing projects, coordinating collaboration, and maintaining accurate records of decisions and approvals.
We process data to protect our infrastructure, detect abuse or unauthorized activity, and ensure operational security.
We may use aggregated and non-identifiable data to improve our website, workflows, and services.
We send operational communications related to your engagement and legal or administrative notices when required. Marketing communications are sent only where permitted by law and in accordance with your preferences.
We may also process data to comply with legal obligations, including accounting, tax, regulatory, and legal enforcement requirements.
legal basis for processing
Where applicable under data protection law, we rely on one or more of the following legal bases:
• Performance of a contract or pre-contractual steps
• Legitimate interests, where those interests do not override your rights
• Consent, where required for specific processing activities
• Legal obligations under applicable laws and regulations
We do not use personal data for purposes that are incompatible with those described in this policy.
confidentiality
Confidentiality is fundamental to how we operate.
All non-public information shared with us in the course of an engagement is treated as confidential. This includes business strategies, project materials, creative work, technical documentation, credentials, commercial terms, and communications.
We use confidential information solely for the purpose of delivering services. Access is restricted to authorized personnel who require it to perform their duties. Confidentiality obligations remain in effect after the end of any business relationship.
Client intellectual property remains the property of the client. Pansyer retains rights only to its internal methodologies, know-how, and non-client-specific frameworks.
security measures
We apply technical and organizational measures designed to protect data against unauthorized access, loss, misuse, or disclosure.
These measures include secure hosting environments, encrypted communications where applicable, access controls based on role and necessity, internal confidentiality agreements, and continuous monitoring of systems.
No system can be guaranteed to be completely secure. In the event of a security incident, we act promptly to assess, contain, and remediate the issue and notify affected parties where required by law.
data retention
We retain personal data only for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce agreements.
When data is no longer required, it is securely deleted or anonymized in accordance with industry standards.
international transfers
If personal data is transferred outside the European Economic Area or your country of residence, we ensure appropriate safeguards are in place, including standard contractual clauses or other legally recognized mechanisms.
We take reasonable steps to ensure that international transfers provide an equivalent level of data protection.
your rights
Subject to applicable law, you may have the right to:
• Access your personal data
• Request correction of inaccurate data
• Request deletion where legally permitted
• Restrict or object to certain processing
• Withdraw consent where processing is based on consent
• Request data portability
• Lodge a complaint with a supervisory authority
Requests can be submitted by contacting: start@pansyer.com
We may require identity verification before fulfilling requests.
children
Our services are intended for businesses and adults. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that such data has been collected, it will be deleted promptly.
updates to this policy
We may update this policy from time to time to reflect legal, regulatory, or operational changes. Any updates will be published on this page with a revised effective date.
contact
For questions, requests, or concerns related to privacy, security, or data protection, contact:
Pansyer LLC
Email: start@pansyer.com
Website: pansyer.com