How we handle personal data

Under Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).

What this notice covers. The website contact form, the AI assistant and the free website and online-presence review, with the providers involved. Retention terms are the effective ones: where a period is not decided yet, this notice says so instead of inventing it.

1. Data controller

Giovanni Caselli, Yaveno, websites and Care for independent businesses. Contact: [email protected].

2. Data we process

• Guided brief: selections and public business description stay in this page until you request an AI draft. The optional Mistral draft uses the selected needs and public description; do not enter personal details. Reloading clears the local brief.
• Contact form: when you choose “Send request”, your business name, email, message, language and source page are saved on Cloudflare D1 and sent by email to Yaveno through Fastmail. These details are not sent to the AI assistant. A request ID and a technical key prevent duplicate submissions. The form keeps your details on screen during retries; reloading clears them. Spam protection uses a keyed hash of the IP address for short-lived counters.
• AI assistant (Concierge chat): your current message and recent verified conversation turns are sent to the model to answer. Do not enter contact details, people’s names, health data or confidential information. Automated filters reject recognised identifiers and sensitive requests; they cannot guarantee detection of every personal detail. Use the brief or email for contact details.
• Chat technical data: request and usage counters, request identifiers and pseudonymous IP-derived fingerprints to contain abuse. Our counter store contains no raw IP addresses or conversation texts. Hourly counters expire after about two hours; reconciled request records after 90 days. Unreconciled reservations remain charged; usage totals are separate. Hosting providers’ technical policies also apply.

2-bis. Free website and online-presence review

• What you enter. Business name, town and, if you provide it, the website address. They identify the business and run the review. The full report is readable without email. Requesting a proposal is a separate, optional step.
• Collection from the website and from public sources. The review reads the public pages of the website you point to and a limited number of linked pages, with an automated browser running from our server. For local information, a sample of recent public reviews and two public questions to Perplexity, we use the Apify service. For those questions we send only the business name, category and town; we receive the response and public citations shown in the report. We do not send Perplexity an email address, IP address or report token/capability. From the review sample we keep the date, the star rating and whether the owner replied; we do not keep the name of the person who wrote the review, nor the review text, and the results show aggregates only. The text is read for the check and does not stay in the result.
• Where this data comes from. The listing information and the reviews come from publicly accessible sources and are not collected directly from the people who wrote them. The categories of data are those in the previous point: publicly visible business information, date, stars and whether the owner replied. Anyone who wrote a review can write to us to exercise their rights (point 9).
• Review result. The link that shows the result is valid for about 30 minutes after it is produced; after that the result can no longer be opened. The review record stays on our server for up to 30 days from production, but cannot be reopened without a valid link; at expiry the report's contents are removed in the service's next automatic pass, while the service is running.
• Service protection. Every request goes through two controls: the Cloudflare Turnstile anti-automation check, which receives the challenge token and the IP address of the request, and a per-origin limit that stores the IP address with daily counters to prevent abusive use of the free service. The IP address is personal data: we process it for this purpose only and do not use it for profiling.
• Proposal request (optional). If you select the contact request and submit the form, we collect your email address and your message. We ask you to enter the address twice to compare the values and catch typing errors; this does not verify control of the mailbox. They are used to answer your request and to handle the stage before a possible engagement. The request is sent from our server through an email service (Cloudflare Email Service) and arrives in our mailbox (Fastmail).

3. Purposes and legal basis

• Answering your request and handling the pre-contractual stage (Art. 6.1.b GDPR).
• Running the AI assistant (legitimate interest, Art. 6.1.f GDPR).
• Running the free review you asked for and showing the result, and answering a proposal request at the pre-contractual stage (Art. 6.1.b GDPR).
• Protecting the free service from abuse: anti-automation check and per-origin limits (legitimate interest, Art. 6.1.f GDPR).

4. Recipients and processors

• Cloudflare, Inc.: site hosting and delivery (Cloudflare Pages), and storage of contact requests (D1), under a data processing agreement.
• Mistral AI SAS (France): generates replies through the Mistral Small API. The provider describes default EU hosting, with possible transfers for specific features and subprocessors. Data use and retention follow the Mistral DPA and organisation controls: a paid API alone does not establish exclusion from model training.
• Fastmail Pty Ltd (Melbourne, Australia): runs the email for yaveno.com. It delivers your brief and stores it in our mailbox, like any other email you write to us.
• Apify (apify.com): collection of public information from the business listing and the review sample, on our behalf and on our instruction.
• Cloudflare, Inc.: besides hosting and delivery, the Turnstile anti-automation check and the Cloudflare Email Service that carries the request notification. For Turnstile, Cloudflare processes the technical signals of the request (IP address, TLS fingerprint, User-Agent header, sitekey and origin): for the check we ask for it is a processor, while for improving its own bot-detection systems it acts as an independent controller under its own legitimate interest. Cloudflare asks its customers to disclose to visitors the cookies set by its services.
• Hetzner: the server running the review and holding the report files.
• Fastmail Pty Ltd: the mailbox that receives the proposal request notification.

5. Transfers outside the European Union

The chat uses the standard Mistral API endpoint and does not enable web search, connectors or alternative AI providers. We do not claim that the entire processing chain excludes all transfers outside the EU. The providers of the review (Apify and Cloudflare, for Turnstile and for sending the notification) may also process data outside the European Union under their own data processing agreements. The review server is in the European Union. Cloudflare hosting may involve transfers to the United States, covered by Standard Contractual Clauses and/or the Data Privacy Framework. Email is run by Fastmail, an Australian company that may process data in the United States, the United Kingdom, Australia, India and Austria: those transfers too are covered by the Standard Contractual Clauses in its data processing agreement. Measures we take: a request not to enter personal data, filters before the model, no server-side application archive of conversations and usage limits.

6. Retention

Contact form details in D1 expire after 90 days and are removed by the next daily cleanup. Technical IDs, hashes and delivery status remain to prevent duplicates; they do not contain the text of the request. Spam counters expire after 20 minutes and are removed during cleanup. Email copies follow the mailbox retention described below.

Free review. The link to the result works for about 30 minutes; after that the report cannot be opened. The report record stays in the deposit until the review expires (30 days from production): at expiry the report's personal data, its private dossier and the local copies of the request are removed in the next automatic pass while the service is running, and only a minimal accounting and reconciliation skeleton remains (identifiers, states, technical amounts) with no text or contact details. The IP address used for the anti-abuse limits stays in the counters for a 35-day window from its last recorded activity; removal happens at the service's periodic cleanup passes and at the next write, not at a fixed hour. The proposal request is kept in the service register (D1) for a planned period of 90 days from registration and then reduced to technical identifiers without the text; the copy delivered to our mailbox is not deleted by this service. From the review sample we keep date, stars and whether the owner replied, without the name of the person who wrote it and without the text.

Your brief sits in our mailbox like any other message, for as long as it takes to handle your request and to meet legal obligations; if nothing comes of it, we delete it. You can ask us to delete it at any time (point 9). Mistral APIs normally retain inputs and outputs for 30 days for abuse monitoring, subject to applicable settings or provider obligations; we do not claim active Zero Data Retention. YAVENO does not archive chat texts on the server. Browser sessions and counters follow points 2 and 7.

Request origin. If you arrive through a campaign link, selected link references are sent only when you ask for a proposal. The server checks them against our campaign register and retains source and campaign identifiers, the date and a link to the request; unrecognised references remain unknown. The internal origin register, including any reviewed customer links, is removed after 90 days from request registration at the next service cleanup (every 6 hours while running). This path does not use cookies, device fingerprints, IP addresses or automatic email matching to assign a customer. In the browser, the references remain only in page memory.

7. Cookies and local storage

The chat uses sessionStorage to keep recent messages and a signed conversation token while moving between pages, separately for Italian and English (yaveno-concierge-v1:it/en). The token expires after 30 minutes of inactivity. It is signed, not encrypted, and contains only the conversation already visible to you, never credentials or internal instructions. An expired conversation is not reused; local data is cleared when the tab closes or through browser settings. When you continue chatting, the verified conversation is sent to the AI provider. The free review also uses sessionStorage (yaveno.report-sessione.v1): it keeps the job identifier and the read token needed to resume the report after a page refresh, plus a confirmation request whose response may have been lost. It expires when the job expires and is never reused afterwards; it does not contain the result or extra data. The theme preference (yaveno-candidate-theme) stays in localStorage. These tools support site functionality, not profiling.

8. AI assistant (EU Artificial Intelligence Act)

The assistant is an artificial intelligence system: we tell you so when the panel opens (Art. 50 AI Act). Answers are generated automatically, may contain inaccuracies and do not replace direct contact. To talk to a person: [email protected]. The site is not intended for children under 14.

9. Your rights

You can request access, rectification, erasure, restriction, objection and portability by writing to [email protected]. You also have the right to lodge a complaint with the Italian Data Protection Authority.

Versione italiana: Informativa privacy.