Privacy Policy

This notice is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (hereinafter, the “Regulation” or “GDPR”), as well as the applicable national data protection legislation, to users who browse and use the website https://webmaster360.it/ (hereinafter, the “Website”).

This notice applies exclusively to the Website and to the processing of personal data carried out in connection with its consultation and the functionalities available therein. It does not apply to other websites, domains or subdomains that may be reached via hyperlinks, nor to publisher websites managed through the Webmaster360 platform, whose processing operations are governed by the notices provided by the respective data controllers.

1. Data Controller

The data controller is:

TAGMOOD S.R.L.
Via Luigi Capuana n. 11
95030 Tremestieri Etneo (CT), Italy
VAT and Tax Code: IT05518210876

The Controller may be contacted at the following email addresses:

• privacy@tagmood.it, for requests relating to the protection of personal data and the exercise of rights under the GDPR;
• info@tagmood.it, for general communications;
• webmaster360@tagmood.it, for communications specifically relating to the Webmaster360 product and services.

The Controller has not designated a Data Protection Officer under Articles 37 et seq. of the GDPR, as the statutory prerequisites are not currently met.

2. Objective Scope of the Notice

This notice exclusively governs the processing operations carried out through the webmaster360.it domain.

The following are therefore excluded from its scope of application:

• any Webmaster360 subdomains;
• administration panels or operational areas of the platform;
• the websites of publishers using the Webmaster360 infrastructure;
• third-party websites and services accessible via links on the Website.

Separate notices, provided by the respective data controllers, may apply to those environments.

3. Categories of Personal Data Processed

3.1. Browsing Data and Technical Information

The computer systems and software procedures responsible for the operation of the Website acquire, during their normal operation, certain information whose transmission is implicit in the use of Internet communication protocols.

This category includes, by way of example:

• IP address;
• date and time of the request;
• method used to submit the request to the server;
• requested resource;
• numerical code indicating the response status;
• referring page address;
• type of browser, operating system and device used;
• technical identifiers and information necessary for security, distribution and proper operation of the Website;
• data relating to technical events, anomalies, attempted abusive access or potentially harmful behavior.

Such information, while not collected for the purpose of directly identifying the user, could enable identification through processing, association or linking with data held by third parties.

3.2. Data Provided Through the Analysis Request Form

The Website provides a form through which the user may request a free analysis of their publishing project.

Through this form, the following may be collected:

• the website domain indicated by the user;
• the email address;
• confirmation that the user has read this notice;
• any technical data related to the submission of the request.

Data transmitted through the form are delivered to webmaster360@tagmood.it and are reviewed by authorized personnel of the Controller.

The analysis is performed by a natural person appointed by the Controller. No artificial intelligence systems, fully automated decision-making processes or automated user profiling activities are employed in this procedure.

3.3. Data Contained in Communications

If the user contacts the Controller by email, the Controller may process:

• the sender’s address;
• any identifying and professional data communicated;
• the content of the request;
• information contained in attachments;
• data necessary to manage and document the correspondence.

Users are advised not to transmit personal data that are irrelevant, excessive or unnecessary in relation to the request made, with particular reference to special categories of personal data under Article 9 of the GDPR and data relating to criminal convictions and offences under Article 10 of the GDPR.

3.4. Data Collected Through Measurement Tools

Subject to consent, where required by applicable law, the Website may collect data relating to page usage through Google Analytics 4, including information about the device, browser, sessions, pages viewed, interactions and approximate traffic source.

Detailed information on cookies and other tracking tools used is set out in the Website’s Cookie Policy and in the preference management panel made available through the consent management platform.

Google Search Console is used by the Controller to monitor the Website’s presence and performance in search engine results. Its use does not result, through the Website’s pages, in the installation of a specific tracking tool on the user’s device.

4. Purposes, Legal Bases and Nature of Provision

4.1. Website Provision, Operation and Security

Browsing data and technical information are processed for the purpose of:

• enabling the display and proper operation of the Website;
• distributing content and optimizing performance;
• ensuring the security of networks, systems and information;
• preventing and combating abuse, fraud, harmful automated activities, cyber-attacks and unauthorized access;
• diagnosing anomalies and ensuring business continuity;
• establishing, exercising or defending a right of the Controller.

The legal basis for processing consists of:

• the performance of measures requested by the user by accessing the Website, pursuant to Article 6(1)(b) of the GDPR, where applicable;
• the pursuit of the Controller’s legitimate interest in making the Website available, protecting it and keeping it efficient, pursuant to Article 6(1)(f) of the GDPR;
• compliance with legal obligations, pursuant to Article 6(1)(c) of the GDPR, where applicable.

The provision of technical data related to browsing is necessary to access the Website. Failure to provide such data may prevent or limit the use of the relevant functionalities.

4.2. Management of the Free Analysis Request

Data provided through the form are processed to:

• receive and handle the user’s request;
• examine the indicated domain;
• prepare an analysis of the publishing project;
• send the analysis results to the email address provided;
• provide clarifications or respond to subsequent communications strictly related to the request.

The legal basis is the performance of pre-contractual measures taken at the data subject’s request, pursuant to Article 6(1)(b) of the GDPR.

Providing the domain and email address is necessary to process the request. Failure to provide them prevents the Controller from preparing and sending the analysis.

Checking the box confirming that the user has read this notice does not constitute consent to processing where processing is based on the performance of pre-contractual measures. It serves to document that the user was able to read this notice before submitting their data.

4.3. Demo Proposal and Organization

Following the analysis request, the Controller may use the email address provided to:

• present the analysis results;
• explore the user’s expressed needs in greater depth;
• propose and organize a Webmaster360 demonstration;
• provide commercial information specifically related to the request and the indicated publishing project.

The legal basis is the performance of pre-contractual measures requested by the data subject, pursuant to Article 6(1)(b) of the GDPR, as well as, limited to activities strictly related to managing the established relationship, the Controller’s legitimate interest in following up on the received request pursuant to Article 6(1)(f) of the GDPR.

Data collected through the form are not used to automatically subscribe the user to newsletters, periodic promotional lists or generalized marketing campaigns.

The data subject may at any time object to the continuation of undesired contacts by writing to privacy@tagmood.it or webmaster360@tagmood.it.

4.4. Management of Unsolicited Communications

Data transmitted by email are processed to:

• respond to requests;
• provide product information;
• manage commercial, technical or administrative communications;
• document correspondence;
• protect the Controller’s rights and legitimate interests.

The legal basis is, depending on the nature of the communication:

• the performance of pre-contractual or contractual measures, pursuant to Article 6(1)(b) of the GDPR;
• compliance with legal obligations, pursuant to Article 6(1)(c) of the GDPR;
• the pursuit of the Controller’s legitimate interest in properly managing its communications and protecting its rights, pursuant to Article 6(1)(f) of the GDPR.

4.5. Statistical Measurement and Website Usage Analysis

Google Analytics 4 is used to understand, in aggregate and statistical form, how the Website is browsed, measure its performance and improve its content, structure and usability.

Where the use of such tools involves accessing or storing information on the user’s device or processing that is not strictly necessary, the legal basis is the data subject’s consent, pursuant to Article 6(1)(a) of the GDPR and the applicable legislation on electronic communications.

Consent is optional, may be refused without affecting access to the essential functionalities of the Website, and may be withdrawn at any time through the preference management panel.

Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

4.6. Compliance with Legal Obligations and Protection of Rights

Data may be processed to:

• comply with obligations under laws, regulations, authority measures or lawful orders;
• respond to requests from competent authorities;
• prevent, detect or prosecute unlawful acts;
• establish, exercise or defend rights in judicial, administrative or out-of-court proceedings.

The legal bases are compliance with a legal obligation, pursuant to Article 6(1)(c) of the GDPR, and the pursuit of the Controller’s legitimate interest in protecting its rights, pursuant to Article 6(1)(f) of the GDPR.

5. Processing Methods

Processing is carried out using computer and electronic tools and, where necessary, organizational and documentary tools, in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality.

The Controller adopts technical and organizational measures appropriate to the risk, aimed at preventing the loss, destruction, alteration, unauthorized disclosure of or abusive access to personal data.

Data are accessible exclusively to personnel and collaborators authorized by reason of their respective duties, as well as to external parties who process data on behalf of the Controller or who act as independent controllers in accordance with applicable law.

6. Absence of Automated Decision-Making

In the context of the processing described in this notice, no decisions are made based solely on automated processing that produce legal effects concerning the data subject or similarly significantly affect them, within the meaning of Article 22 of the GDPR.

The domain analysis request is read, assessed and processed by authorized personnel of the Controller. No artificial intelligence systems are used to automatically analyze the request, generate the relevant response or make decisions about the user.

7. Recipients and Categories of Recipients

Personal data may be disclosed, within the limits of the stated purposes and in accordance with the principle of data minimization, to the following categories of parties:

• employees and collaborators of the Controller expressly authorized;
• providers of hosting, distribution, security and web traffic protection services;
• providers of transactional email services;
• providers of statistical measurement and analysis services;
• providers of the consent management platform;
• legal, tax, technical and organizational consultants, where necessary;
• public authorities, supervisory bodies, judicial authorities and law enforcement agencies, where required by law;
• parties to whom disclosure is necessary for the protection of the Controller’s rights.

Data are not subject to indiscriminate dissemination.

8. Specifically Employed Providers

8.1. Cloudflare

The Website is published via Cloudflare Pages and uses Cloudflare services for static page hosting, content distribution, traffic management, security, abuse prevention and performance optimization.

In providing these services, Cloudflare may process technical and network data, including IP addresses, technical identifiers, HTTP request information, device data and security information.

Cloudflare may act, depending on the specific processing carried out, as a data processor on behalf of the Controller and, limited to activities for which it independently determines purposes and means, as an independent controller.

Further information is available in Cloudflare’s privacy and contractual documentation.

8.2. Google Analytics 4

Subject to the user’s consent, the Website uses Google Analytics 4, provided by Google, to compile statistics on page usage and user interactions.

Google may receive data relating to the device, browser, IP address, browsing events and interactions with the Website, depending on the service configuration and the preferences expressed by the user.

The specific technologies used, their durations and how to withdraw consent are described in the Cookie Policy and in the preference panel.

8.3. Google Search Console

The Controller uses Google Search Console to monitor the indexing and performance of the Website in search results. This tool provides the Controller with data and statistics relating to the visibility of the domain on Google search services.

8.4. SFBX – AppConsent®

The Website uses the AppConsent® consent management platform, provided by SFBX, to collect, record and manage the user’s preferences in relation to cookies and similar technologies.

The platform may process technical identifiers, device data, information on the choice expressed, date and time of the preference and additional elements necessary to document and respect the user’s consent or refusal.

Users may change or withdraw their choices via the dedicated preference management command available on the Website.

8.5. Elastic Email

The Controller uses Elastic Email to manage the sending of email communications related to the Website’s functionalities.

In this context, the recipient’s email address, technical data necessary for message routing and delivery, delivery status information and technical events essential for the management of the service may be processed.

Elastic Email acts, for processing carried out on behalf of the Controller, as a data processor, without prejudice to any processing carried out by the provider as an independent controller under its own contractual and regulatory documentation.

9. Data Transfers to Third Countries

The use of providers based, having infrastructure, group companies or sub-processors outside the European Economic Area may result in the transfer of or access to personal data from third countries.

In such cases, the Controller ensures that the transfer takes place in compliance with Chapter V of the GDPR and, as applicable, on the basis of:

• an adequacy decision adopted by the European Commission;
• the recipient’s adherence to a framework recognized by an adequacy decision, where applicable;
• standard contractual clauses adopted by the European Commission pursuant to Article 46 of the GDPR;
• additional safeguards, supplementary measures or derogations provided for by applicable law.

Data subjects may request information on the safeguards applied by writing to privacy@tagmood.it.

10. Retention Periods

Personal data are retained for a period not exceeding that necessary for the purposes for which they are processed, unless a longer period is required or permitted by law.

In particular:

• analysis requests, contact data, indicated domain and pre-contractual correspondence without follow-up: for a maximum period of 24 months from the closure of the communication or the last significant contact;
• data relating to relationships that have become contractual: for the entire duration of the relationship and, thereafter, for the ordinary period of 10 years, subject to longer terms related to disputes, investigations or specific obligations;
• technical and security logs: for the time necessary for the technical management and security of the Website and, as a rule, for a period not exceeding 12 months, except where required for the detection of unlawful acts or legal protection;
• data processed through analytics tools: according to the retention settings configured in the relevant service and the durations set out in the Cookie Policy;
• information relating to preferences and consent: for the period necessary to document the user’s choice and comply with legal obligations, taking into account the duration of the tool and any renewal of the consent request;
• data subject to litigation or necessary for the protection of a right: for the entire duration of the dispute and until the definitive expiry of the applicable appeal or limitation periods.

Upon expiry of the relevant periods, data are erased, anonymized or rendered no longer attributable to the data subject, unless further retention is required by law.

11. Data Relating to Third Parties

If the user communicates personal data relating to third parties, they declare that they are entitled to do so and undertake, where necessary, to provide the data subjects with information about the processing.

The user remains responsible for the relevance, accuracy and lawfulness of third-party data that may be transmitted to the Controller.

12. Minors

The Website and Webmaster360 services are aimed at publishers, companies, professionals and digital industry operators and are not specifically intended for minors.

The Controller does not intend to knowingly collect personal data of minors through the form available on the Website. If a person exercising parental responsibility believes that a minor has transmitted personal data, they may request its erasure by writing to privacy@tagmood.it.

13. Data Subject Rights

In the cases and within the limits provided for by the GDPR, the data subject may exercise the following rights:

• obtain confirmation as to whether or not personal data concerning them are being processed;
• obtain access to personal data and the information provided for in Article 15 of the GDPR;
• request the rectification of inaccurate data and the completion of incomplete data;
• obtain the erasure of data in the cases provided for in Article 17 of the GDPR;
• obtain the restriction of processing in the cases provided for in Article 18 of the GDPR;
• receive the data in a structured, commonly used and machine-readable format and, where technically feasible, transmit them to another controller, in the cases provided for in Article 20 of the GDPR;
• object, on grounds relating to their particular situation, to processing based on legitimate interest, pursuant to Article 21 of the GDPR;
• object at any time to processing carried out for direct marketing purposes;
• withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• not be subject to a decision based solely on automated processing in the cases governed by Article 22 of the GDPR;
• lodge a complaint with a supervisory authority.

The exercise of rights may be subject to the limitations and conditions laid down by applicable law.

14. How to Exercise Your Rights

Requests may be sent to:

privacy@tagmood.it

or, by post, to:

TAGMOOD S.R.L.
Via Luigi Capuana n. 11
95030 Tremestieri Etneo (CT), Italy

The request must contain sufficient information to enable the Controller to identify the data subject and understand the right being exercised.

Where there are reasonable doubts as to the identity of the requester, the Controller may request additional information necessary to confirm it, in compliance with the principle of data minimization.

The Controller shall respond without undue delay and, as a rule, within one month of receipt of the request. This period may be extended by two months, taking into account the complexity and number of requests, with notice to the data subject within one month of receipt.

15. Right to Lodge a Complaint

Data subjects who believe that the processing of their personal data infringes applicable law may lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), in accordance with the procedures indicated by the Authority, or address the competent supervisory authority in the Member State where they habitually reside, work or where the alleged infringement occurred.

The right to bring proceedings before the competent judicial authorities remains unaffected.

16. Cookies and Other Tracking Tools

The Website uses technical cookies and, subject to consent, measurement and analysis tools.

Detailed information regarding:

• categories and purposes of cookies;
• providers thereof;
• duration;
• technical or non-technical nature;
• methods of acceptance, refusal and withdrawal;
• tools for modifying preferences;

is set out in the Cookie Policy, accessible from the Website footer and the consent management panel.

17. Links to Third-Party Websites

The Website may contain links to websites, platforms or services operated by third parties.

The Controller exercises no control over the processing carried out by such parties and is not responsible for their content, security measures or privacy practices.

Users are advised to review the privacy notices of external services before providing personal data or using their functionalities.

18. Changes to This Notice

The Controller reserves the right to update or amend this notice as a result of:

• legislative or regulatory changes;
• measures or guidelines from competent authorities;
• changes to the processing operations carried out;
• introduction, modification or discontinuation of functionalities and providers;
• organizational, technical or security requirements.

The updated version is published on the Website with the date of last update.

Where the changes materially affect the processing operations or the rights of data subjects, the Controller may provide additional notice through announcements on the Website or through other appropriate channels.