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Black Snow Report

iubenda

Method v1.6As At 2026-08-1317 Surfaces Read1 Offering Assessed

Your own published record, as at 2026-08-13.

Your Details

The Macro Picture17

Red · Adverse
5
of 17 banded observations across 1 offering band Adverse. 2 were never measured.

What Is Published8

Your Own Words3

iubenda will retain Personal Data collected from the Client for the entire duration of the contract and an additional period of six months after the provision of the services has been completed. [Privacy Controls product:] a maximum period of time of 15 days [for general access data]... a maximum retention period of five (5) years from the date of its collection [for cookie-consent proof].
Consent Database Privacy Policy (six-month post-contract period) and Privacy Controls Privacy Policy (15-day and 5-year periods), both read this session. Scored Period Published at the row level because genuine numeric periods are stated for the specific processor-role products; the separate Corporate Privacy Policy's own general retention language ('for the time necessary to fulfil the purpose') is a criteria-only restatement and is carried in the narrative report as a distinct, weaker data point rather than allowed to average out the stronger product-level figures. · Source
Documents are generated in a fully automated manner and therefore do not constitute or substitute the rendering of legal advice.
Terms of Service, product-description clause. This discloses that the core generator output is automated, which is the relevant automated-processing fact for the product itself, but it is framed as a liability disclaimer about legal-advice status, not as an Article 13(2)(f)/Article 22 automated-decision-making notice addressed to a data subject. No dedicated ADM/Article 22 statement naming logic, significance and consequences was located. Scored Published But Incomplete rather than Absent because the automation itself is disclosed, just not in ADM-notice form. · Source
A list of Subprocessors can be requested by using the ticketing system or the email address info@iubenda.com.
Data Processing Agreement (Art 28 GDPR), sub-processor clause. Scored Published overall because the sub-processors actually relevant to iubenda's processor-role products ARE named on the public, dated privacy notices for those specific products (Consent Database: https://www.iubenda.com/privacy-policy/94654098/legal; Privacy Controls: https://www.iubenda.com/privacy-policy/36700132) -- freely reachable, no login. The DPA's own boilerplate 'request it from us' clause was not updated to point to those pages and therefore contradicts them; this is recorded as a genuine cross-instrument inconsistency (Method Gate G5) and a Breakpoint of its own, not rounded into a general 'Gated' verdict for the whole entity. · Source

Parties You Name18

See which of these are assessed in this register

Register Check3

AI Role By Offering1

Assessment Basis

Produced under Method v1.6 from the entity's fact record. 8 of 8 observations were measured under that generation; the rest read Not Measured, which is a fact about this register's coverage and not a finding about the entity.

Read from 17 first-party surface(s) across 1 assessed offering(s), found by the entity's own link graph and sitemap rather than by guessed paths.

Fact Record
Version 1.0, dated 2026-08-13
Standards Commit
12087d807054
Register Control Quality
One View

Verification And Challenge

Every finding on this record is a statement about what could be read on your own published surfaces as at 2026-08-13. Correspondence route as recorded on this card input: ror@blacksnowintel.com.

What A Machine Could Not Establish3

3 questions are open and 5 are established, read as at 2026-08-13 under method v1.6.

The One Thing To Publish First

Publish it: say whether customer data is used to train AI models.

Red · AdverseTraining On Customer Data

Training Exclusion Instrument: None

Where To Put It

This was read on your own page at https://www.iubenda.com/privacy-policy/252372. That is the page a reader already reaches for and does not find it on, so it is the page to correct first.

Where Others Stand

24 organisations in the register say whether customer data is used to train AI models. You do not.

What A Published Answer Looks Like

We will not use your data to train our AI or language models. We will not store your data except for the purpose of providing you with access to our platform and to the AI Functionality.

A question answered plainly in public, by an organisation read as Strong on it. It is not an endorsement of the position the sentence states — Black Snow reads what is published and never recommends what to practise. Read on published terms. Claim tier Quoted. The organisation that published it is not named. A name in the original is replaced; nothing else in the sentence is changed.

One is named here, and one is deliberate. The rest of the open questions are listed below without a prescription; what to publish for each, in what order, and drafted machine-readable evidence for all of them, is the Deep Dive.

Still Open

Deep Dive

The full assessment, plus consulting on what to fix.

Reviewing your record is free.