Privacy Policy

1. Data controller

CBF E-Social S.R.L., an innovative start-up (Art. 4(10-bis), Italian Decree-Law 3/2015), registered office at Via Borgoratto 26, 27031 Candia Lomellina (PV) (Italy), VAT no. IT02773120189. To exercise your rights or ask about processing: email cbfesocial@gmail.com, tel. +39 351 975 2588. This notice covers this website only; the Appusher app or service is governed by its own policy: https://appusher.crd.co/#privacy.

2. Data, purposes and legal bases

The operational contact form sends data to FormSubmit for forwarding to cbfesocial@gmail.com. The chat uses Cloudflare Workers AI. The newsletter remains a demo: no subscription is sent.

• Browsing: technical data such as IP address, date and time, requested page and browser, handled by the hosting infrastructure for security and operation. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
• Contact form: name, email, message, language and acknowledgement of this notice, to reply to your enquiry. Do not include health information or other special-category data. For quotes or services: pre-contractual steps requested by you (Art. 6(1)(b) GDPR); for other messages: legitimate interest in responding (Art. 6(1)(f)). No automatic newsletter subscription.
• Newsletter: demo only; no subscription or submission to a newsletter provider takes place.
• AI assistant: message and limited history to answer service questions; details in the dedicated section below. Do not enter sensitive or contact details: use the form for personal data.

Topic buttons display introductions prepared on the site: clicking sends no data to AI. Only after sending a message are the question and limited history, which may include an introduction summary, transmitted to Cloudflare Workers AI.

3. Recipients

Providers involved: Cloudflare for hosting and delivery, FormSubmit to receive and forward form submissions, and Google/Gmail for the recipient mailbox. FormSubmit may request a Google reCAPTCHA check on its own page after submission. No reCAPTCHA widget is loaded on our form page. The controller does not sell personal data. Provider terms and processing agreements require contractual review by the controller.

4. Transfers outside the EEA

Some providers may process data outside the European Economic Area with the safeguards of Chapter V GDPR (adequacy decisions or standard contractual clauses).

The public FormSubmit documents reviewed do not detail all storage locations or contractual safeguards for international transfers. The controller must verify these before handling special-category data. Questions: cbfesocial@gmail.com.

5. Retention

Browsing data is kept for the technically necessary time. Contact requests for as long as needed to handle them and, if a relationship arises, legal retention periods. The newsletter is a demo and creates no subscriber list.

FormSubmit states in its documentation that submissions are retained in its archive for 30 days. The controller keeps email copies for as long as needed to handle the enquiry and any subsequent legal obligations. Provider technical retention is subject to their respective terms.

6. Your rights

You may request access, rectification, erasure, restriction, portability and objection (Arts. 15-22 GDPR) and withdraw consent. You may complain to a supervisory authority: in Italy, the Garante per la protezione dei dati personali (www.garanteprivacy.it).

7. Provision of data and automated decisions

Providing form data is optional, but without it we cannot reply. We do not profile or take solely automated decisions with legal effects.

8. Children

Our services are not directed to children under 14.

Optional PWA push notifications

CBF E-Social push notifications containing news and promotional offers are optional. They are enabled only by ticking the box and pressing “Enable notifications”, followed by browser or operating-system permission. Legal basis: consent (Art. 6(1)(a) GDPR). Consent is separate from the contact form and newsletter; refusing does not prevent use of the site.

For delivery we process the technical subscription address (endpoint), public keys and subscription authentication secret, language, consent date and version. We do not request a name, email or phone number. These details can indirectly identify a browser subscription and are not treated as anonymous. The IP address is used transiently for abuse limiting and is not stored in the subscription table.

Subscriptions are stored in Cloudflare D1 configured with EU jurisdiction. Delivery uses the browser’s push service, such as Google, Apple or Mozilla; processing or transfers outside the EEA may be needed under each provider’s terms. The EU database setting does not guarantee that the entire delivery path remains in Europe. The controller must review provider roles, contractual terms and safeguards.

You can withdraw consent using “Turn off” in the notifications section, without affecting prior lawful processing. This deletes the subscription from the operational database and browser. You can also block notifications in device settings: this stops delivery but does not necessarily notify this site of withdrawal. Subscriptions are deleted when the push service reports them expired and, in any case, 180 days after the latest activation or renewal. Provider recovery copies follow the provider’s technical retention period.

“Send a test” sends a notification only to the requesting device. Automatic social updates are not yet active: historical posts do not trigger notifications. Badge appearance and push availability depend on the device and permissions.

The invitation to enable notifications may appear automatically, but it does not subscribe you. The technical sessionStorage key cbf-push-prompt-seen prevents repeated invitations during the same tab session and contains neither consent nor profile data.

9. AI chat — Cloudflare Workers AI

The chat is an AI assistant, not a human operator, operated through Cloudflare Workers AI using the Llama 3.1-8B fp8 model. It can make mistakes: verify important answers and use the contact form for personal enquiries, quotes or confirmation.

Only when you press “Send” are your message (maximum 600 characters), language and up to the last four conversation messages (maximum 600 characters each) sent to the site endpoint and Cloudflare Workers AI. Opening the chat sends no messages to AI. Do not enter names, contact details, health information or other special-category data. Using the chat is not marketing consent and does not subscribe you to the newsletter. A link to this notice is always available in the chat.

Purpose: answering service enquiries. Legal basis: pre-contractual steps requested by you for questions about services or quotes (Art. 6(1)(b) GDPR); for other enquiries, legitimate interest in responding (Art. 6(1)(f)).

The conversation remains only in browser page memory, not cookies, localStorage or sessionStorage. You can remove it using “Clear conversation”; it is lost on reloading or closing the page. Closing the panel does not clear the conversation. The site backend does not log prompts.

For standard inference, Cloudflare states that it does not use content to train models and does not retain content once processing completes (zero content retention), subject to the exceptions in its Workers AI data-usage documentation. Necessary technical security and operational logs may remain under provider terms; we do not guarantee absolutely no logs or exclusively EU processing. Section 4 applies to transfers; applicable terms require review by the controller.