Privacy Policy — Tagoross CoP

  • Data controller: Agustín Benito Bethencourt
  •  NIF: ES43810716V
  •  Registered address: Paseo de La Marina 13. Torre de Benagalbón. 29738. Rincón de La Victoria. Málaga. Spain
  •  Contact email: [email protected]
  •  Last updated: 2026-06-10

 

1. Who This Policy Applies To

This privacy policy applies to anyone who visits tagoross.com, submits the contact form, or becomes a member or subscriber of Tagoross CoP. It explains what personal data is collected, why, how it is stored, and what rights you have over it.

Tagoross CoP — formally, the Tagoross Circle of Practice — is operated by Agustín Benito Bethencourt, registered self-employed professional (autónomo) under Spanish law, trading professionally as Toscalix. Agustín Benito Bethencourt is the data controller for all personal data described in this policy.

This policy is governed by the EU General Data Protection Regulation (GDPR), Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), and the Spanish Law on Information Society Services and Electronic Commerce (LSSI-CE).

 

2. Tools and Infrastructure Providers

tagoross.com is built and hosted on Kajabi, LLC, a technology company incorporated in the State of Delaware, United States, with its principal place of business at 880 Newport Center Dr, Suite 100, Newport Beach, CA 92660. Kajabi provides the hosting, website analytics, contact form processing, community platform, video sessions, member communications, and payment processing for Tagoross CoP.

Cookie consent on this website is managed by Cookie-Script, operated by Objectis, UAB, company registration number 304037472, Laisvės st. 60, LT-05120 Vilnius, Lithuania. Cookie-Script displays the consent banner on your first visit, records your consent preferences, and ensures that analytics cookies are only activated after your consent has been given.

When you interact with the consent banner, Cookie-Script records: an anonymous random key (not personal data), your consent choice (accept or reject), your anonymized IP address (last digits replaced with zero), the date and time of your choice, the page on which consent was given, and your browser agent. This information is stored in the CookieScriptConsent cookie on your device and is used solely to remember and evidence your consent.

Kajabi acts as a data processor under the instructions of the data controller. Kajabi is based in the United States; its processing of EU visitor and member data is conducted under Standard Contractual Clauses (SCCs) in accordance with GDPR Chapter V. Kajabi's Data Processing Agreement is automatically incorporated by reference upon acceptance of Kajabi's Terms of Service and is in effect for all Kajabi account holders.

Cookie-Script (Objectis, UAB) is based in Lithuania, an EU member state, and is subject to GDPR directly. No international transfer mechanism is required. A Data Processing Agreement with Cookie-Script is in place.

 

3. Data Collected From Website Visitors

When you visit tagoross.com, the following data is collected automatically.

3.1 Kajabi Site Analytics

Kajabi collects standard website usage data to provide the site operator with traffic and performance information. This includes pages visited, time spent on the site, referring website or search term, browser type, device type, and approximate geographic location at country level.

This data does not identify you personally. It is processed under the legitimate interests of the site operator in understanding how the website is used (Article 6(1)(f) GDPR).

3.2 Google Analytics

This website uses Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. Google Analytics collects data about how visitors use the site, including pages visited, session duration, referral source, device and browser information, and approximate geographic location.

Google Analytics cookies are only activated after you give your consent through the Cookie-Script banner that appears on your first visit. You may withdraw or update your consent at any time through the cookie settings link in the website footer.

Google LLC acts as a data processor under a data processing agreement with the site operator. Data is transferred to and processed in the United States under Standard Contractual Clauses.

Data collected through Google Analytics is retained for 14 months from the date of collection, after which it is automatically deleted from Google's systems.

Legal basis: consent (Article 6(1)(a) GDPR; LSSI-CE Article 22.2).

 

4. Cookies

Cookies are small text files stored on your device when you visit a website. tagoross.com uses the following categories of cookies.

Strictly necessary cookies

These cookies are required for the website to function and for the consent management system to operate. They are set by Kajabi for session management and security purposes, and by Cookie-Script to record your consent preferences. No consent is required for strictly necessary cookies.

Analytics cookies

These cookies are set by Kajabi's built-in analytics and by Google Analytics. They collect information about how you use the website in order to help improve it. These cookies are only set after you give consent through the Cookie-Script banner.

Cookie

Provider

Category

Purpose

Duration

CookieScriptConsent

Cookie-Script

Strictly necessary

Stores your cookie consent preferences

1 year

kjb_session

Kajabi

Strictly necessary

Session management

Session

_ga

Google Analytics

Analytics

Distinguishes users

2 years

_gid

Google Analytics

Analytics

Distinguishes users

24 hours

_ga_M1PEZD08X3

Google Analytics

Analytics

Session persistence

2 years

 

You can manage your cookie preferences at any time through the cookie settings link in the website footer. You can also configure your browser to block or delete cookies, though this may affect the website's functionality.

 

5. Contact Form

The contact form at tagoross.com/contact collects your name, email address, and the content of your message. This data is submitted to and stored by Kajabi.

The data controller uses this information to respond to your enquiry. If your enquiry leads to a membership invitation, the data may be retained as part of the vetting and onboarding process. If it does not, your contact form data is deleted within 12 months of submission.

Legal basis: legitimate interests of the data controller in responding to enquiries and assessing suitability for membership (Article 6(1)(f) GDPR).

Your contact form data is not shared with any third party other than Kajabi as infrastructure provider, and is not used for unsolicited marketing communications.

 

6. Data Collected From Members and Subscribers

If you accept an invitation to join Tagoross CoP and create an account, additional personal data is collected and processed as part of your membership. This covers the following categories.

Identity and contact data: Name, email address, and professional affiliation collected at registration.

Legal basis: performance of the membership agreement (Article 6(1)(b) GDPR).

Professional profile data: Information you provide during the vetting process — including your role, organisation, years of experience, and relevant professional context. Used to assess suitability for membership and to personalise the platform to your professional context. You control whether your professional affiliation is visible to other members through your Kajabi profile settings.

Legal basis: legitimate interests of the data controller in maintaining the quality and integrity of the circle (Article 6(1)(f) GDPR).

Payment data: Payment card details and transaction records for Circle Layer subscriptions and Focus Sessions. Payment data is processed exclusively by Kajabi Payments and is not stored by the data controller directly. Transaction records (amount, date, package) are retained for accounting and subscription management purposes.

Legal basis: performance of the membership agreement (Article 6(1)(b) GDPR); legal obligation under Spanish tax and accounting law (Article 6(1)(c) GDPR).

Platform interaction data: Posts, messages, and contributions you make within the Tagoross CoP platform on Kajabi. This data is visible to the data controller and, within circle channels, to other members. Focus Sessions are not recorded; no video, audio, or transcript capture is made.

Legal basis: legitimate interests (Article 6(1)(f) GDPR).

Engagement and activity data: Data about how you use the platform — which content you access, session participation, referral activity — used to identify inactivity thresholds and to monitor platform health.

Legal basis: legitimate interests (Article 6(1)(f) GDPR).

7. Data Retention

Data category

Retention period

Website analytics (Kajabi)

Aggregated; no individual retention

Google Analytics data

14 months from collection

Cookie consent records (Cookie-Script)

1 year from consent

Contact form submissions

12 months from submission, unless membership follows

Member identity and contact data

Duration of membership plus 2 years after membership ends

Professional profile data

Duration of membership plus 2 years after membership ends

Payment and transaction records

5 years from transaction date (Spanish tax law requirement)

Platform interaction data

Duration of membership; subject to Kajabi's own retention policies

Engagement and activity data

Duration of membership plus 2 years after membership ends

 

8. Your Rights

Under GDPR, you have the following rights in relation to your personal data. To exercise any of these rights, contact the data controller at [email protected]. Requests will be responded to within 30 days.

  • Right of access: You may request a copy of the personal data held about you.
  • Right to rectification: You may request correction of inaccurate or incomplete data. Members can update most profile information directly within Kajabi.
  • Right to erasure: You may request deletion of your personal data, subject to legal retention obligations. Platform contributions are part of the circle record and are not deleted on request, but your identity associated with those contributions can be anonymised.
  • Right to restriction: You may request that your data be processed only in limited ways while a correction or objection is being assessed.
  • Right to object: You may object to processing based on legitimate interests. Your objection will be assessed on its merits. Objecting to engagement tracking may result in earlier removal from the platform due to inactivity.
  • Right to data portability: You may request your personal data in a structured, machine-readable format.
  • Right to withdraw consent: Where processing is based on consent (analytics cookies), you may withdraw consent at any time through the cookie settings link in the website footer. Withdrawal does not affect the lawfulness of processing before withdrawal.
  • Right to lodge a complaint: You have the right to lodge a complaint with the Spanish data protection authority at any time:
    •  Agencia Española de Protección de Datos (AEPD)
    • C/ Jorge Juan, 6. 28001 Madrid, Spain
    • www.aepd.es

 

9. Changes to This Policy

This policy may be updated from time to time. The date at the top of this page reflects the most recent revision. Members will be notified of material changes through the platform.

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