Ezoic Services

Ezoic Services
This website uses the services of Ezoic Inc. (“Ezoic”), including to manage third-party interest-based advertising. Ezoic may employ a variety of technologies on this website, including tools to serve content, display advertisements and enable advertising to visitors of this website, which may utilize first and third-party cookies.
A cookie is a small text file sent to your device by a web server that enables the website to remember information about your browsing activity. First-party cookies are created by the site you are visiting, while third-party cookies are set by domains other than the one you're visiting. Ezoic and our partners may place third-party cookies, tags, beacons, pixels, and similar technologies to monitor interactions with advertisements and optimize ad targeting. Please note that disabling cookies may limit access to certain content and features on the website, and rejecting cookies does not eliminate advertisements but will result in non-personalized advertising. You can find more information about cookies and how to manage them here.
The following information may be collected, used, and stored in a cookie when serving personalized ads:

IP address
Operating system type and version
Device type
Language preferences
Web browser type
Email (in a hashed or encrypted form)

Ezoic and its partners may use this data in combination with information that has been independently collected to deliver targeted advertisements across various platforms and websites. Ezoic’s partners may also gather additional data, such as unique IDs, advertising IDs, geolocation data, usage data, device information, traffic data, referral sources, and interactions between users and websites or advertisements, to create audience segments for targeted advertising across different devices, browsers, and apps. You can find more information about interest-based advertising and how to manage them here.
You can view Ezoic’s privacy policy here, or for additional information about Ezoic’s advertising and other partners, you can view Ezoic’s advertising partners here.

Privacy Policy

Privacy & Cookie Policy

Last updated: 21 June 2026

This Privacy & Cookie Policy (“Policy”) explains how AccordionChords.com (“we”, “us”, “our”) collects, uses, shares and protects personal data when you visit and use the website https://accordionchords.com (the “Website”) and the interactive tools we provide, such as the Stradella Bass Chord Calculator (“Stradella Explorer”). It also explains your rights under the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), the ePrivacy Directive 2002/58/EC as implemented in Italy (Italian Personal Data Protection Code, Legislative Decree 196/2003 as amended, and the Garante’s “Guidelines on cookies and other tracking tools” of 10 June 2021), and applicable UK and US privacy laws.

Please read this Policy carefully. By using the Website you acknowledge that you have read and understood it. Where we rely on your consent (for example, for non-essential cookies), we only process the relevant data after you have given that consent through our cookie banner.

1. Who is responsible for your data (Data Controller)

The data controller responsible for your personal data is: AccordionChords.com — Giovanni Lucifero Strada Baganzola 84, Parma, Italy Email: [email protected]

We have not appointed a Data Protection Officer (DPO), because our processing does not meet the thresholds of Art. 37 GDPR. You can contact us about any privacy matter using the details above.

2. What personal data we collect, why, and on what legal basis

Under Art. 13 GDPR we must tell you, for each purpose, what we collect, why, the legal basis, and how long we keep it. The table below sets this out.

Data we collect	Why we collect it (purpose)	Legal basis (Art. 6 GDPR)	Retention
Newsletter: email address (and name if you provide it), via our newsletter provider	To send you updates, tutorials and new chord charts you asked for	Consent — Art. 6(1)(a). You can withdraw at any time	Until you unsubscribe or the list is closed
Comments: name, email, website (optional), comment text, IP address, browser user-agent	To publish your comment and detect spam	Consent for publishing; legitimate interest (Art. 6(1)(f)) for spam prevention	Comment and metadata retained indefinitely unless you ask us to delete them
Contact form / email: name, email, message content	To answer your question or request	Legitimate interest (Art. 6(1)(f)) in responding to you, or consent	Until your request is resolved, then archived for a reasonable period
Contact / other forms (Ninja Forms): the fields you fill in (e.g. name, email, message) plus, where stored, the submission’s IP address and date/time	To receive and respond to your form submission	Consent (Art. 6(1)(a)) by submitting the form, and/or legitimate interest (Art. 6(1)(f)) in responding	Submissions stored in our WordPress database are set to auto-expire after 90 days; copies sent to us by email are kept until your request is resolved
Quizzes & surveys (Quiz And Survey Master): IP address and any fields you fill in (e.g. name, email, answers)	To run, score and where relevant respond to quizzes/surveys; quiz results are also emailed to the site administrator	Consent / legitimate interest depending on the quiz	Responses stored on the site until an administrator deletes them; a copy is also delivered to, and retained in, the administrator’s email inbox
Server logs: IP address, browser type, operating system, referring page, date/time of request	To deliver, secure and troubleshoot the Website	Legitimate interest (Art. 6(1)(f)) in security and reliability	Short-term (typically up to a few weeks/months)
Cookies & similar technologies (see Section 6)	Site functionality, analytics, personalised advertising	Consent for non-essential cookies; legitimate interest only for strictly necessary cookies	See the cookie table / your CMP
Account data (only if user registration is enabled): username, email, profile data	To provide and manage your account	Contract (Art. 6(1)(b)) / consent	While the account is open

We collect personal data directly from you (when you fill in a form, comment, subscribe, or contact us) and automatically (server logs and cookies) when you browse.

We do not knowingly use your data for automated decision-making or profiling that produces legal or similarly significant effects on you. Interest-based advertising (Section 7) involves profiling for ad selection, but only with your consent and without legal/significant effects.

3. The Stradella Explorer / Chord Calculator

The Stradella Bass Chord Calculator (“Stradella Explorer”) is an interactive tool that runs in your browser. The chord calculations themselves are performed locally and we do not require you to create an account or submit personal data to use it. Standard server logs and the cookies described in this Policy may still apply while the page loads. If we later add features that store your settings or send data to our servers, we will update this Policy and, where required, ask for your consent first.

4. Children’s data

The Website is intended for a general audience of accordion players and is not directed at children. Where we rely on consent for an information-society service, the minimum age is 16 (the threshold set in Italy under Art. 8 GDPR). If you are under 16, please do not subscribe to the newsletter, leave comments, or otherwise submit personal data without the consent of a parent or guardian. If you believe a child has provided us with personal data, contact us and we will delete it.

5. Who we share your data with (recipients)

We do not sell your personal data. We share it only with the categories of recipients needed to run the Website:

Hosting provider — InterServer, Inc. (servers located in the United States) hosts and serves the Website (see Section 9 on the international transfer this involves).
Newsletter provider — [e.g. MailerLite] processes your email to deliver the newsletter on our behalf.
WordPress / Gravatar (Automattic) — comment functionality and avatars. An anonymised hash of your email may be sent to Gravatar to check whether you have an account. See Automattic’s privacy policy: https://automattic.com/privacy/
Image optimisation (Smush / WPMU DEV) — images may be sent to WPMU DEV servers and served via a CDN; EXIF data may be transferred and is either stripped or returned, not stored.
Analytics provider — Google Analytics and Google Tag Manager (see Section 6).
Advertising partners — Ezoic, Google AdSense/AdManager and their downstream partners (see Section 7).
Spam-detection service — comments may be checked automatically for spam.
Form submissions (Ninja Forms) are stored in our own WordPress database on our hosting (Section 9); they are not sent to the Ninja Forms company. A copy of each contact-form message is also emailed to our administrator inbox (delivered via Google — see the next bullet).
Email delivery — Google (Gmail / Google Workspace API) sends the Website’s outgoing email (such as quiz-result notifications and form notifications) on our behalf via the WP Mail SMTP plugin. A copy of these messages is delivered to and stored in our administrator email inbox. Google is based in the USA (see Section 9 on international transfers).
Authorities or legal advisers — only where we are legally required to disclose data, or to establish, exercise or defend legal claims.

These third parties act either as our processors (under a data-processing agreement, on our instructions) or as independent controllers for their own purposes (notably advertising partners). Please review their own privacy policies for details.

6. Cookies and similar technologies

6.1 What cookies are

Cookies are small text files placed on your device when you visit a website. We also use “similar technologies” such as pixels, local storage and device identifiers — under EU law these are treated the same way as cookies. We use both session cookies (deleted when you close your browser) and persistent cookies (which remain until they expire or you delete them), and both first-party and third-party cookies.

6.2 Consent — how we handle it

In line with the ePrivacy Directive (Art. 5(3)) and the Italian Garante’s guidelines, non-essential cookies (analytics, advertising, functional/preference, social media) are blocked until you give consent through our Consent Management Platform (CMP). When you first arrive you will see a banner that lets you Accept all, Reject all, or manage your choices by category, with reject being as easy as accept. Strictly necessary cookies do not require consent but are listed for transparency.

You can change or withdraw your consent at any time, as easily as you gave it, by reopening the cookie settings from the link/gear icon on the left side of the screen (e.g. “Cookie settings” / “Manage consent”). Withdrawing consent does not affect processing carried out before withdrawal.

We use the Ezoic Consent Management App as our CMP.

6.3 Categories of cookies we use

Strictly necessary / essential cookies — required for the site to work (e.g. load balancing, security, remembering your cookie choices, and the temporary cookie that checks whether your browser accepts cookies on the login page). No consent required.
Functionality / preference cookies — remember choices such as language or comment details so you do not have to re-enter them (comment-detail cookies last up to one year). Consent required.
Analytics & performance cookies — Google Analytics and Google Tag Manager, to understand aggregate traffic and manage tags so we can improve the site. Google sets its own cookies; more info: https://policies.google.com/privacy and opt-out plugin: https://tools.google.com/dlpage/gaoptout. Consent required.
Advertising / targeting cookies — set by our advertising partners (Section 7) to show and measure ads, including interest-based ads. Consent required.
Social media cookies — set when you use share or “like” buttons or interact with embedded social content. Consent required.

A live, itemised list of the specific cookies, their providers, purpose and duration is available in the cookie settings panel of our CMP, which is kept up to date automatically as cookies change.

6.4 WordPress login/editing cookies (if applicable)

If you log in, we set cookies to remember your login and screen-display choices (login cookies last 2 days, screen-option cookies 1 year; “Remember Me” extends login to 2 weeks; logging out removes them). Editing or publishing a post sets an additional cookie storing only the post ID, expiring after 1 day. These contain no other personal data.

6.5 Managing cookies in your browser

You can also block or delete cookies through your browser settings. If you block essential cookies, parts of the Website may not work properly.

7. Advertising (Ezoic, Google and partners)

This Website is ad-supported. We work with third-party advertising partners — currently Ezoic and Google (AdSense / Ad Manager), together with their respective downstream demand partners — to display advertising. These partners may use cookies, web beacons and similar technologies to collect information such as your IP address, device and browser data, and browsing activity, in order to serve and measure advertising, including personalised (interest-based) advertising.

For visitors in the EEA, UK and Switzerland, personalised advertising and the associated tracking only occur after you consent via our cookie banner. We use Google Consent Mode (v2) so that Google and its partners adjust their behaviour according to your consent choices. If you reject advertising cookies, you may still see ads, but they will be contextual (based on page content) rather than based on your browsing profile.

Ezoic-specific disclosures. Ezoic and its advertising partners process data as described on Ezoic’s privacy and ad-partner pages. Where required, identity partners such as ID5 and LiveRamp may assign or process a pseudonymous (hashed) identifier; you have the right to opt out of such sharing. See Ezoic’s privacy policy and its Advertising Partners page for the current list of partners and their policies:

Ezoic Privacy Policy: https://www.ezoic.com/privacy-policy/
Ezoic Advertising Partners: https://www.ezoic.com/ad-partners/
Google’s advertising policies / how Google uses data: https://policies.google.com/technologies/partner-sites

8. Embedded content from other websites

Articles may include embedded content (e.g. videos, images, social posts). Embedded content behaves as if you had visited the third-party site directly: those sites may collect data about you, set their own cookies, embed additional tracking, and monitor your interaction with that content, especially if you are logged in to them. We do not control these third-party practices.

9. International data transfers (server located in the USA)

The server that hosts this Website is located in the United States and is provided by InterServer, Inc. (Secaucus, New Jersey, USA). When you use the Website, your personal data (for example the IP address in our server logs, or any data you submit through a form) is therefore transferred to and stored in the United States, which is a country outside the European Economic Area (“EEA”). Some of our other providers and advertising partners (Section 5 and 7) are also based in the USA.

Under Chapter V of the GDPR, such transfers are only lawful if an appropriate safeguard is in place. For the transfer of data to our hosting provider, that safeguard is an adequacy decision (Art. 45 GDPR):

InterServer, Inc. is an active participant in the EU–U.S. Data Privacy Framework and the UK Extension to the EU–U.S. DPF, self-certified with the U.S. Department of Commerce (original certification 13 January 2026; data category: non-HR data). This transfer is therefore covered by the European Commission adequacy decision of 10 July 2023 (Art. 45 GDPR), whose validity was confirmed by the General Court of the European Union on 3 September 2025. You can verify InterServer’s active certification on the official list: https://www.dataprivacyframework.gov/list (search “InterServer”). As a result, your data receives a level of protection essentially equivalent to that guaranteed within the EU, and no supplementary measures are required.

InterServer’s own privacy policy and DPF commitments are available at https://www.interserver.net/privacy-policy.html. Under the Framework, InterServer must respond to privacy complaints within 45 days; the independent recourse mechanism is JAMS (https://www.jamsadr.com/DPF-Dispute-Resolution), with the U.S. Federal Trade Commission as the competent statutory body.

Our other US-based service providers and advertising partners (such as Google and Ezoic) likewise either self-certify under the Data Privacy Framework or rely on the Standard Contractual Clauses for the transfers they carry out as part of their services; details are in their respective privacy policies, linked in this Policy.

You have the right to ask us, at any time, which transfer mechanism applies and to obtain information about the safeguards in place, by writing to the contact in Section 1.

10. How we keep your data secure

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, misuse or alteration, including HTTPS encryption in transit. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If you upload images, avoid images containing embedded location data (EXIF GPS), as visitors could extract that data.

11. Your rights under the GDPR

If you are in the EEA or UK, you have the right to:

Access — obtain a copy of the personal data we hold about you;
Rectification — correct inaccurate or incomplete data;
Erasure (“right to be forgotten”) — have your data deleted, subject to legal retention obligations;
Restriction — limit how we process your data in certain cases;
Portability — receive certain data in a structured, machine-readable format;
Object — object to processing based on legitimate interests, and at any time to direct marketing;
Withdraw consent — where processing is based on consent, withdraw it at any time (without affecting prior processing);
Not be subject to solely automated decisions with legal/significant effects (we do not carry these out);
Lodge a complaint with a supervisory authority (see Section 12).

To exercise any of these rights, contact us using the details in Section 1. We will respond within the time limits required by law (normally one month). If you have an account or have left comments, you can request an exported file of your personal data or its erasure (excluding data we must keep for legal, administrative or security reasons).

US visitors (e.g. California): depending on your state, you may have rights to know, delete, correct, and opt out of the “sale”/”sharing” of personal information or targeted advertising. You can exercise advertising opt-outs through our cookie banner, recognised opt-out signals (e.g. Global Privacy Control) where supported, and the industry tools listed in Section 13.

12. How to complain

If you believe we have not handled your personal data lawfully, you can lodge a complaint with your local data protection authority. In Italy this is the:

Garante per la protezione dei dati personali Piazza Venezia 11, 00187 Roma, Italy Web: https://www.garante.it — Email: [email protected]

You also have the right to complain to the supervisory authority in your own EU/EEA country of residence.

13. Opting out of interest-based advertising

In addition to our cookie banner, you can manage interest-based advertising through these industry tools:

Your Online Choices (EU): https://www.youronlinechoices.eu/
Google Ads Settings: https://adssettings.google.com/
Network Advertising Initiative: https://optout.networkadvertising.org/
Digital Advertising Alliance: https://optout.aboutads.info/

14. Links to other websites

The Website contains links to third-party sites and resources (including affiliate links — see our separate Affiliate Disclosure). This Policy does not cover those third parties. Please read their privacy policies before submitting data to them.

15. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, partners or the law. The “Last updated” date at the top shows the latest revision. Where a change materially affects how we use your data, we will take reasonable steps to inform you (for example, via a notice on the Website). Please review this page periodically.

16. Contact

For any question about this Policy or your personal data, contact us at:

[email protected] — or via our contact page: https://accordionchords.com/contact/

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