Privacy notice for website visitors

In brief

• This notice applies to people who visit www.cumino.com, including the job-offer pages, and to people who write to us through the contact form or request the report from the return-on-investment calculator.
• If you use Cumino's virtual assistant or mini-app to create your CV or to apply, you will find the information in the Cumino Privacy Notice for Candidates.
• Website statistics are switched on only if you click “Accept” in the cookie banner.
• For any request: [email protected].

1. Who processes the data

The controller is ALFERCOM SRL (hereinafter “ALFERCOM”), Via Altinate 125, 35121 Padova (PD), P.IVA IT05068010288, certified e-mail (PEC) [email protected].

ALFERCOM's Data Protection Officer (DPO) can be contacted at [email protected].

2. Which data, why, on what basis and for how long

2.1 Browsing and website security

• Data: IP address, browser and device type, pages requested, date and time.
• Purpose: to display the pages, protect the site from attacks and find errors.
• Legal basis: ALFERCOM's legitimate interest in running the website securely, Art. 6(1)(f) GDPR.
• Retention period: technical logs are deleted automatically after 30 days at most.

2.2 Website usage statistics

• Data: pages viewed, clicks and recordings of visits, with form fields masked.
• Purpose: to understand how the site is used and to find errors. Never for advertising.
• Legal basis: consent, which you give by clicking “Accept” in the cookie banner (Art. 6(1)(a) GDPR and Art. 122 of the Codice privacy (Italian Data Protection Code)). Without consent, the statistics tool (PostHog) collects nothing. You can change your choice at any time on the Cookie Settings page.
• Retention period: events are kept for 24 months; recordings of visits for 30 days.

2.3 Contact form

• Data: name, company (optional), e-mail, telephone (optional), subject and message.
• Purpose: to reply to your request and, if you ask for it, to prepare an offer for you.
• Legal basis: pre-contractual measures taken at your request, Art. 6(1)(b) GDPR; for requests that do not concern a contract, ALFERCOM's legitimate interest in replying, Art. 6(1)(f) GDPR.
• Retention period: 24 months from the last contact. If a contract results, the necessary data are kept for the duration of the contract and for the 10 years required by law for accounting records.

2.4 Return-on-investment calculator

• Data: e-mail and the figures entered in the calculator.
• Purpose: to send you the report at the address provided and to answer the questions that arise from it. A copy of the report goes to ALFERCOM's sales office.
• Legal basis: pre-contractual measures taken at your request, Art. 6(1)(b) GDPR.
• Retention period: 24 months from the last contact.

The addresses collected through the contact form and the calculator are not used for newsletters or advertising without your consent.

2.5 Protecting forms from spam

• Data: IP address and technical browser data, when you submit a form.
• Purpose: to verify that the form is submitted by a person and not by an automated program (Cloudflare Turnstile service).
• Legal basis: ALFERCOM's legitimate interest in protecting its forms from abuse, Art. 6(1)(f) GDPR.

3. Who receives the data

The data are processed by the people at ALFERCOM who need them, and by the providers who work on behalf of ALFERCOM as processors:

ALFERCOM does not sell the data and does not pass them on to third parties for advertising.

4. Transfers outside the European Union

Vercel, Cloudflare and Resend are based in the United States. The transfer is based on the European Commission's adequacy decision for companies that adhere to the EU-US framework for the protection of personal data (Data Privacy Framework) and, in addition, on the European Commission's standard contractual clauses contained in the contracts with the providers. A copy of the safeguards can be requested from [email protected].

5. Rights

You may at any time ask to access your data, to have it corrected, to have it erased, to restrict its processing and to receive it in a computer-readable format (Arts. 15–20 GDPR). You may object to processing based on legitimate interest (Art. 21 GDPR) and withdraw your consent to statistics at any time, without affecting what was done before.

To exercise your rights, write to [email protected]. We reply within one month.

If you believe that the processing violates the law, you may lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority), Piazza Venezia 11, 00187 Roma (www.garanteprivacy.it).

6. Is providing the data mandatory?

No. Without the mandatory data in the contact form, however, we cannot reply to you; without the e-mail, we cannot send you the calculator report.

7. Changes

If this notice changes, the new version appears on this page, with the date.