Privacy Policy
Last updated: March 2026
1. Data Controller
The data controller is:
- WebGlobalBuild — a brand of Global Svapo S.r.l.s.
- Registered office: Via Dino Buzzati 3, 91026 Mazara del Vallo (TP), Italy
- VAT / Tax ID: 02717040816 — REA: TP-191921
- Share capital: €500.00 fully paid
- Legal representative and data protection contact: Ivo Guccione
- Email: info@webglobalbuild.it
- Certified email (PEC): salvatoreguccione6@pec.it
2. Types of data collected
This website collects personal data in connection with the following features. For each, we indicate the type of data, purpose, legal basis, and retention period.
2.1 Contact form
| Data collected | Name, email, project type, message, phone number (optional) |
| Purpose | Respond to user inquiries and create a support ticket |
| Legal basis | Consent (Art. 6.1.a GDPR) — mandatory checkbox before submission |
| Retention | Data is retained until ticket closure and for a maximum of 24 months after closure, unless legally required otherwise |
| Third parties | Resend (confirmation and notification emails) |
2.2 Cost estimator
| Data collected | Email, project description, target audience, urgency, budget, selected features, contact preference, AI-generated estimate, additional notes |
| Purpose | Generate an indicative AI-powered estimate and create a quote request ticket |
| Legal basis | Consent (Art. 6.1.a GDPR) — mandatory checkbox before submission |
| Retention | Up to 24 months from ticket creation |
| Third parties | Resend (confirmation email) |
The project description is processed by Claude (Anthropic) to generate the estimate. No personal data (email, name) is transmitted to the AI — only the project description and selected preferences. Anonymous data may be saved for internal statistical purposes.
2.3 Support ticket system
| Data collected | Name, email, phone, request type, title, description, budget, timeline, technologies, attachments (PDF, JPEG, PNG, WebP — max 5 MB each, max 3 files) |
| Purpose | Manage support and quote requests |
| Legal basis | Performance of pre-contractual measures (Art. 6.1.b GDPR) |
| Retention | Up to 24 months after ticket closure |
| Third parties | Resend (email notifications), Supabase Storage (file storage) |
2.4 AI chat
| Data collected | Name (optional), email (optional), message text, conversation history |
| Purpose | Provide automated assistance via AI chatbot |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — providing immediate support to visitors |
| Retention | Chat sessions are retained for up to 12 months |
| Third parties | Anthropic (Claude API) — conversation text is transmitted to Anthropic's servers in the United States for response generation. See section 5 for extra-EU transfer safeguards |
2.5 Live chat with human operator
| Data collected | Name (optional), email (optional), message text |
| Purpose | Provide direct assistance through a human operator |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) |
| Retention | Up to 12 months after session closure |
| Third parties | None — operator messages are handled internally |
2.6 Client portal
| Data collected | Email, password (bcrypt hash), project data, invoices, quotes, messages, reviews |
| Purpose | Contract management, project progress monitoring, billing |
| Legal basis | Performance of a contract (Art. 6.1.b GDPR) |
| Retention | For the duration of the contractual relationship and for 10 years thereafter for tax obligations |
| Third parties | Resend (invitation emails, password reset), Anthropic (portal AI chat — see section 5) |
Portal access uses a session cookie (wgb-portal-session) containing a signed JWT with the minimum data necessary for authentication (client ID, account ID). The cookie lasts 7 days and is HttpOnly, Secure, and SameSite Strict.
When a client accepts or declines a quote, their IP address is recorded as proof of contractual acceptance under Art. 6(1)(b) GDPR (contract performance). This data is retained for the duration of the contractual relationship and for 10 subsequent years for tax and evidentiary obligations.
2.7 AI-powered quote generation (admin area)
| Data transmitted | Project description, project type |
| Purpose | Automatically generate quote line items |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — internal operational efficiency |
| Third parties | Anthropic (Claude API) — description text is transmitted to Anthropic's servers in the USA |
2.8 Rate limiting and security
| Data collected | IP address (SHA-256 hashed with a cryptographic salt before storage) |
| Purpose | Abuse prevention, protection against automated attacks |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — website security |
| Retention | Rate limit records expire automatically at the end of the configured time window |
2.9 IMAP email client (admin area)
| Data collected | Content of emails sent to info@webglobalbuild.it (sender, subject, body, attachments) |
| Purpose | Managing correspondence with clients and prospects through the admin panel |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — operational management of communications |
| Retention | Emails are stored on the Aruba IMAP server and accessible only by the administrator through the admin panel |
| Third parties | Aruba S.p.A. (IMAP email hosting) — data is not shared with any other third parties |
2.9bis — AI email reply suggestions (admin area)
| Data transmitted | Email subject, sender, message body |
| Purpose | Generate AI-powered reply suggestions for received emails |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — internal operational efficiency |
| Third parties | Anthropic (Claude API) — email content is transmitted to Anthropic's servers in the USA for suggestion generation |
2.10 Push notifications (Web Push API)
| Data collected | Push subscription endpoint, browser encryption keys |
| Purpose | Send push notifications to the site administrator for relevant events (new tickets, messages, etc.) |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — internal operational efficiency |
| Retention | Subscription endpoints are stored in Supabase until revocation or deactivation |
| Third parties | No public user data is involved — push notifications are intended exclusively for the administrator |
2.11 Demo account
The website provides a demo account (demo@webglobalbuild.it) with entirely fictitious data to allow evaluation of the client portal features. No real data is associated with this account.
2.12 Google Analytics 4
| Data collected | Anonymous browsing data (pages visited, session duration, scroll depth, UI interactions), IP address (automatically anonymized) |
| Purpose | Statistical analysis of traffic and user behavior on the website |
| Legal basis | Consent (Art. 6.1.a GDPR) — activated only after explicit acceptance via cookie banner |
| Retention | According to Google Analytics retention policies (default 14 months) |
| Third parties | Google LLC (Google Analytics 4) — data is transferred to Google servers in the USA. Google Signals and ad personalization are disabled. See section 5 |
2.13 Vercel Analytics and Speed Insights
| Data collected | Pages visited, referrer, browser, operating system, device type, Core Web Vitals metrics (LCP, FID, CLS, TTFB) |
| Purpose | Website performance monitoring and aggregate traffic analysis |
| Legal basis | Consent (Art. 6.1.a GDPR) — activated only after explicit acceptance via cookie banner |
| Retention | According to Vercel retention policies |
| Third parties | Vercel, Inc. — see section 5 |
2.14 Public reviews
| Data collected | Name, email, company name (optional), role (optional), review text (max 500 characters), rating (1-5 stars) |
| Purpose | Collect and publish testimonials on the website. Reviews are moderated by the administrator before publication |
| Legal basis | Consent (Art. 6.1.a GDPR) — voluntary form submission |
| Retention | Until the user requests deletion |
| Third parties | None — data is not shared with third parties |
The name and optional company name are published on the website once the review is approved.
2.15 Google Indexing API (admin area)
| Data transmitted | URLs of published, updated, or removed site pages (blog posts, portfolio projects) |
| Purpose | Notify Google for timely content indexing |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — search engine visibility |
| Third parties | Google LLC (Indexing API) — only public URLs are transmitted, no personal data |
2.16 — AI content generation and translation (admin area)
| Data transmitted | Portfolio project descriptions, blog article content |
| Purpose | Generate portfolio case studies and translate content from Italian to English |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — operational efficiency, multilingual publishing |
| Third parties | Anthropic (Claude API) — texts are transmitted to Anthropic's servers in the USA for processing and translation |
2.17 — AI usage logging and transparency
All interactions with AI systems are logged internally (ai_usage_log) tracking: feature name, token count, and estimated cost.
The log contains no personal data — it only records the feature identifier and a truncated prompt preview (maximum 100 characters). The purpose is cost monitoring, transparency, and compliance with EU Regulation 2024/1689 (AI Act).
2.18 Sentry (error monitoring)
| Data collected | JavaScript error messages, stack traces, page URL, user agent, anonymized IP address |
| Purpose | Detection and resolution of technical errors to improve website stability |
| Legal basis | Consent (Art. 6.1.a GDPR) — "Functional" category in the cookie banner |
| Retention | 90 days (Sentry default policy) |
| Third parties | Functional Software, Inc. (Sentry) — San Francisco, USA |
2.19 Cloudflare Turnstile (anti-bot protection)
| Data collected | Verification token, IP address, user agent, widget interaction data |
| Purpose | Protection of login pages from automated access and bot attacks |
| Legal basis | Legitimate interest (Art. 6.1.f GDPR) — service security |
| Retention | The cf_clearance cookie lasts 30 minutes. Cloudflare does not retain personal data beyond the time necessary for verification |
| Third parties | Cloudflare, Inc. — San Francisco, USA |
3. Cookies
This website uses technical cookies necessary for its operation and, with user consent, analytics cookies (Google Analytics 4) and performance monitoring tools (Vercel Analytics, Speed Insights). No profiling or advertising cookies are used. For detailed information, please see our Cookie Policy.
4. Third parties
| Service | Data received | Privacy policy | DPA |
|---|---|---|---|
| Resend | Email, name, message content for transactional email delivery | resend.com/legal/privacy-policy | DPA |
| Anthropic | Chat conversation text, project descriptions for AI response and quote generation | anthropic.com/privacy | DPA |
| Supabase | All stored personal data (database and file storage) | supabase.com/privacy | DPA |
| Google LLC | Anonymous browsing data for traffic analysis (Google Analytics 4), public URLs for indexing (Indexing API) | policies.google.com/privacy | DPA |
| Vercel | IP address, user agent, HTTP request logs (hosting and CDN), performance metrics and anonymous browsing data (Vercel Analytics and Speed Insights) | vercel.com/legal/privacy-policy | DPA |
| Aruba | Inbound and outbound emails (IMAP server for info@webglobalbuild.it mailbox) | aruba.it/informativa-privacy | — |
| Functional Software, Inc. (Sentry) | Error messages, stack traces, URL, user agent, anonymized IP for error monitoring | sentry.io/privacy | DPA |
| Cloudflare, Inc. | Verification token, IP address, user agent for anti-bot protection (Turnstile) | cloudflare.com/privacypolicy | DPA |
5. Extra-EU data transfers
Some personal data is transferred to the United States to the following providers:
- Anthropic, PBC (San Francisco, USA) — receives chat conversation text and project descriptions for response generation via the Claude API. The transfer is based on the Standard Contractual Clauses (SCC) adopted by the European Commission (Decision 2021/914). Anthropic does not use data submitted via API to train its models. (DPA)
- Vercel, Inc. (San Francisco, USA) — website hosting and distribution. The transfer is covered by SCCs and Vercel's Data Processing Agreement. (DPA)
- Resend, Inc. (USA) — transactional email delivery. The transfer is covered by SCCs. (DPA)
- Google LLC (Mountain View, USA) — receives anonymous browsing data via Google Analytics 4 and public URLs via the Indexing API. The transfer is based on SCCs and Google's Data Processing Terms. (DPA)
- Functional Software, Inc. (Sentry) (San Francisco, USA) — receives technical error data (stack traces, URLs, user agent) for website stability monitoring, subject to user consent. The transfer is based on SCCs. (DPA)
- Cloudflare, Inc. (San Francisco, USA) — receives anti-bot verification data (token, IP, user agent) via the Turnstile service on login pages. The transfer is based on SCCs and Cloudflare's DPA. (DPA)
Data stored in Supabase (database and file storage) is hosted in the EU region (AWS eu-west-1, Ireland). No extra-EU transfer occurs for data stored in the database.
6. Data subject rights
Under Articles 15-22 of the GDPR, users have the right to:
- Access — obtain confirmation of the existence of their personal data and access its content
- Rectification — update or correct inaccurate or incomplete data
- Erasure — request deletion of data, within the limits provided by law
- Restriction — request restriction of processing in certain cases
- Portability — receive their data in a structured, commonly used, and machine-readable format
- Objection — object to processing on legitimate grounds
- Withdrawal of consent — withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal
To exercise your rights, please contact:
- Email: info@webglobalbuild.it
- Certified email (PEC): salvatoreguccione6@pec.it
7. Right to lodge a complaint
Users have the right to lodge a complaint with the competent supervisory authority:
- Garante per la protezione dei dati personali (Italian Data Protection Authority)
- Piazza Venezia 11, 00187 Rome, Italy
- Email: garante@gpdp.it
- PEC: protocollo@pec.gpdp.it
- Website: www.garanteprivacy.it
7bis. Artificial intelligence systems — AI Act compliance
This website uses artificial intelligence systems in compliance with EU Regulation 2024/1689 (AI Act). All systems used are classified as minimal or limited risk under the regulation.
AI systems used include: public chatbot for visitor assistance, client portal chat, quote line item generation, email reply suggestions, portfolio content generation, and article translation. All are based on Anthropic's Claude model.
The chatbot is clearly identified as AI in the interface. All AI-generated content is reviewed by a human operator before publication.
For detailed information, see our dedicated AI Disclosure page.
7ter. Data Protection Officer (DPO)
The Data Controller has not appointed a Data Protection Officer (DPO) as it does not fall within the cases required by Art. 37 of the GDPR. The data protection contact is the company's legal representative, Ivo Guccione, reachable at:
- Email: info@webglobalbuild.it
- Certified email (PEC): salvatoreguccione6@pec.it
7quater. Automated decision-making (Art. 22)
This website uses artificial intelligence systems (chatbot, content generation, quote assistant) that do not produce decisions with legal effects or that significantly affect the data subject. AI-generated responses are informational and non-binding in nature. Every commercial decision (quotes, invoices, project management) is always subject to human review and approval.
7quinquies. Special categories of data (Art. 9)
The Data Controller does not collect or process special categories of personal data as referred to in Art. 9 GDPR (data concerning health, racial or ethnic origin, political opinions, religious beliefs, genetic or biometric data). Should users voluntarily include such information in contact messages, chat, or tickets, the Data Controller will proceed with their deletion.
8. Changes to this policy
The data controller reserves the right to modify this policy at any time. Changes will be published on this page with an updated date shown at the top. Continued use of the website after the publication of changes constitutes acceptance thereof.