CERNYVA

Privacy notice

Last updated: 19 October 2026

1. Who is responsible

The data controller is CERNYVA di E. W. Guzman Alcala, Monza, Italy, P.IVA 14928010967. For any privacy matter, write to enrique@cernyva.com or call +39 333 851 7763.

2. What is processed, why, on what legal basis, and for how long

Website visits. This website does not use cookies and has no contact forms. To understand which pages are read, it uses GoatCounter, a statistics service that does not use cookies and does not track visitors across websites. It records aggregate information such as pages visited, referring websites, country, browser and screen size. Legal basis: legitimate interest in understanding how the website is used (Art. 6(1)(f) GDPR). These aggregate statistics do not identify anyone and are kept while the service is in use.

Technical logs. The hosting provider records technical access logs, such as IP address and the date and time of each request, for security and to keep the website running. Legal basis: legitimate interest in the security and operation of the website (Art. 6(1)(f) GDPR). The logs are kept for a limited period set by the hosting provider.

When you write or call. If you send an email or a WhatsApp message, or call, your name, contact details and the content of your message are used to reply to you and, where relevant, to prepare an engagement you requested. Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR) and legitimate interest in answering enquiries (Art. 6(1)(f) GDPR). Retention: 24 months after the last exchange, unless an engagement follows.

When you book a conversation. Bookings are handled by Cal.com. The name, email address and answers you provide are used to arrange and prepare the conversation, which takes place on Google Meet. Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR). Retention: 24 months after the conversation, unless an engagement follows.

Clients. For engagements, contact and invoicing data are processed to perform the contract and to meet tax and accounting obligations. Legal basis: performance of a contract (Art. 6(1)(b) GDPR) and legal obligation (Art. 6(1)(c) GDPR). Accounting records are kept for ten years, as required by Italian law. Other engagement material is handled as agreed in the engagement terms and, where one applies, the data processing agreement.

CERNYVA does not sell personal data, does not use it for advertising and does not make automated decisions about you.

3. Who processes data on CERNYVA's behalf

4. Transfers outside the European Economic Area

Some of these providers, or their sub-processors, may process data in the United States. Where this happens, the transfer relies on the safeguards these providers put in place under the GDPR, such as the EU-US Data Privacy Framework or the European Commission's Standard Contractual Clauses.

5. Your rights

Under the GDPR you can ask for access to your data, its correction or deletion, the restriction of its processing and its portability, and you can object to processing based on legitimate interest. Write to enrique@cernyva.com; you will receive an answer within one month. You also have the right to lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali (garanteprivacy.it).

6. Changes

This notice may be updated. The date at the top shows the latest version.