What we collect, why, and what we don’t.

Last updated: 23 May 2026

1. Who we are

Gubernis is a product of Pragticality Ltd — a UK private limited company registered in England and Wales, company number 17207406. Registered office: 71–75 Shelton Street, Covent Garden, London WC2H 9JQ. Pragticality Ltd is the data controller for personal information collected through gubernis.com.

This notice is governed by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where data subjects sit in other jurisdictions, equivalent rights under their local frameworks apply alongside.

Pragticality Ltd is registered with the UK Information Commissioner’s Office (ICO), registration number ZC134066.

For privacy matters specifically, write to privacy@gubernis.com. General contact is hello@gubernis.com.

2. What this site actually collects

The Gubernis marketing site is static reading. There is one place where personal information is collected, plus standard web-server logs.

(a) The early-access list. If you submit the form at the bottom of the page, we capture:

• The email address you typed
• Technical metadata associated with the submission (your IP address and browser user-agent), captured by Formspree, which hosts the form for us

That is the only personal information this site asks you to provide. We do not ask for your name, role, company, or anything else. The form is deliberately minimal.

(b) Standard web-server access logs. Like every web server on the internet, our host records each page request — IP address, page requested, browser user-agent, referring URL, timestamp. These are kept by IONOS, our hosting provider, on a short retention window for operational and security purposes.

That is the entire personal-data picture for this site. We use no behavioural analytics, no advertising trackers, no third-party tracking pixels. The site sets no cookies, of any kind. Not session cookies, not analytics cookies, not consent-banner cookies. The page reloads with no state.

3. Why we collect it

• To write back when the free tier opens. If you joined the early-access list, we hold your email so we can email you exactly once when the product is available to try.
• To respond to inquiries — if you write to one of our addresses, we use your email and the content of your message to reply.
• To operate and secure the website — web-server logs let us detect abuse, debug errors, and keep the site online.
• To meet our audit and legal obligations where required by law.

4. Legal basis for processing

• Consent — you typed your email into the form and submitted it. We rely on consent for adding you to the early-access list and emailing you when the product is available.
• Legitimate interests — operating the website, keeping access logs for security and debugging, and replying to inquiries you initiate are legitimate interests of a B2B software business. The impact on you is minimal because the data is professional-context information you chose to share.
• Legal obligation — where required by law (e.g. responding to a properly-issued regulator request).

You have the right to withdraw consent or object to legitimate-interests processing at any time — see Your rights below.

5. Sub-processors and where data sits

We use a small number of trusted service providers to run the site. Each operates under written terms and processes personal data on our behalf:

• Formspree, Inc. (United States) — hosts the early-access form. When you submit, your email and the associated IP / user-agent are sent to Formspree, which forwards them to our inbox and stores them in their dashboard for our review. Formspree privacy policy
• IONOS SE (Germany / United Kingdom) — hosts the static gubernis.com site files and operates our mailbox. Standard web-server access logs are retained briefly per their policy. IONOS privacy policy
• Google LLC (United States) — serves the Source Serif 4, JetBrains Mono, and Inter web fonts via the Google Fonts CDN. No personally identifiable information is sent beyond what is required to deliver a font file (IP address, browser type) at the moment the page loads. Google privacy policy

We do not sell or rent personal information. We do not share it with anyone outside this list, other than where required by law or by a regulator with proper authority.

6. International transfers

Formspree and Google are based in the United States. Where personal information is transferred to the United States, we rely on the UK Information Commissioner’s International Data Transfer Agreement (IDTA), or on the EU Standard Contractual Clauses with the UK addendum, alongside the provider’s certification under the EU–US Data Privacy Framework where applicable. The transfer surface is deliberately small — the form collects only an email address, and font delivery is a single HTTP request per visitor.

7. How long we keep it

• Early-access list emails — retained from submission until the free tier opens and we have written back, then for a reasonable follow-up window. We will purge anyone we have not heard back from within 12 months of the launch announcement. You can ask us to delete your record at any time, ahead of this schedule — see Your rights.
• Email correspondence — retained for as long as the conversation is reasonably live, then archived for up to two years.
• Web-server access logs — retained briefly by IONOS per their standard policy.
• Records we are legally required to keep (e.g. accounting records) — retained for the period the law requires, typically six years.

8. Your rights

Under UK GDPR you have the right to:

• Access — ask for a copy of the personal information we hold about you
• Rectification — ask us to correct inaccurate information
• Erasure — ask us to delete your information (subject to legal obligations to retain certain records)
• Restriction — ask us to limit how we process your information
• Portability — ask for your information in a portable format
• Object — object to processing based on legitimate interests
• Withdraw consent — where we have relied on consent (e.g. the early-access list)

To exercise any of these, email privacy@gubernis.com. We respond within one calendar month.

9. Cookies and similar technologies

The Gubernis site sets no cookies. It does not use local storage, session storage, IndexedDB, or any other browser-side persistence. There is no cookie banner because there is nothing to consent to. If that changes — for example, if we add a privacy-respecting analytics tool — we will update this notice and add a banner where the law requires.

10. Security

The site is served exclusively over HTTPS. We design the data picture to be as small as it needs to be — the strongest privacy control is data we never collect. Where we do hold personal data (your email, in your Formspree submission), we rely on Formspree’s security controls and limit access to the dashboard to authorised Pragticality staff only.

11. Children

Gubernis is a B2B trade-compliance product. The site is not directed to anyone under 18 and we do not knowingly collect information from children.

12. Changes to this notice

If this notice changes materially we will update the date at the top of the page and, where practical, notify anyone on the early-access list by email. Minor wording revisions don’t merit notification — the date is the source of truth.

13. Complaints

If you are unhappy with how we have handled your information, we would prefer to hear from you first — email privacy@gubernis.com. You also have the right to complain to the UK Information Commissioner’s Office at ico.org.uk or by calling 0303 123 1113.

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