Protection of personal data policy

In accordance with the General Data Protection Regulation (EU Regulation 2016/679)

In accordance with the Legislative Decree of 06/30 /2003 n. 196 and subsequent amendments and additions, in accordance with the Legislative Decree 101/2018 and in accordance with the Directive 2009/136 / EC, implemented by Legislative Decree of 05/28/2012 n. 69 (Republic of Italy)

In accordance with the Law 171/2018 of the Republic of San Marino (Republic of San Marino)

Dear interested party, according to the legislation indicated, our handlings will be based on the principles of correctness, lawfulness, transparency and protection of your privacy and your rights. In accordance with the articles 7 and 13 of the GDPR 2016/679 we provide you thus with the following information:

By implementing the registration procedure, users voluntarily communicate to the company Pragmata S.r.l., Data Controller, your personal data limited to (please list the requested data)

  • Name;
  • Email;

The user's personal data sent by the users themselves through the registration procedures to our services will be processed in compliance with the principles of personal data protection established by the rules in the introduction to this policy;

The transfer of data is voluntary and not compulsory; however the insertion of some data is essential in order to allow registration to our services (the fields of these data are recognizable by the symbol *); failure to enter such data will prevent correct registration on the site and impede the possibility of using the services of the portal reserved for registered users.


Personal data collected with this registration are processed in order to allow access to the services provided by the portal and reserved for registered users.

Only in the event that the user has freely and unequivocally expressed his consent at the time of activating the service or they will express it subsequently and until its withdrawal, his personal data may be processed by Pragmata S.r.l. to send advertising and commercial communications on their products and services.

Only in the event that the user has freely and unequivocally expressed his consent at the time of activating the service or they will express it subsequently and until its withdrawal, their personal data may be processed by third-party companies, even with automated modes, for direct sales purposes, as well as to send market research and surveys.

Furthermore, in the event that the user gives their consent freely and unequivocally, personal data may also be processed by Pragmata S.r.l. to identify, even with electronic processing, specific consumer behavior and habits in order to improve the services provided and to direct commercial proposals of interest to the User and to offer third party advertisers the opportunity to optimize advertising campaigns.

Pragmata S.r.l. reserves for itself the possibility to process the aforementioned data in aggregate form, ensuring data pseudonymisation, in compliance with the measures prescribed by the Guarantor for Data Protection and by virtue of the specific exemption from the consent provided by the same Authority, for analysis and electronic processing (e.g. classification of all customers in homogeneous categories for levels of services, consumption, expenditure, etc.) aimed at periodically monitoring the development and economic trend of Pragmata Srl's activities, to steer the relative industrial and commercial processes, improve services, design and implement commercial communication campaigns.


The personal data sent through the registration procedures to our services are processed by Pragmata S.r.l. with automated tools, for the period of time which is strictly necessary to achieve the purposes for which they were collected.

Specific security measures are observed by the Data controller to prevent data loss, illegal or incorrect use and unauthorized access.

Personal data are recorded and stored on electronic databases owned by Pragmata S.r.l. Data controller, as well as being stored on servers in the territory of countries belonging to the European Union (EU) or extra EU in compliance with the legislation on the protection of personal data. Personal data are processed by Pragmata S.r.l. by those appointed to manage its site and its marketing activities where consent is expressed.

The list of all data processors is available at the request of the site’s users.

TRANSFER OF DATA IN NON-EU COUNTRIES: data can be transferred to non-EU countries to a third party SUPPLIER only for the purposes indicated above and in full compliance with the handling expressed by the user. Pragmata S.r.l. is based in a non-EU country as indicated in the personal data of the site.

In order to safeguard the right that the European Union considers fundamental, the data collected within European territory must be transferred to international organizations or non-EU countries according to the strict rules established by Chapter V of the Regulation: the transfer must take place in compliance with the principles underlying correct treatment and where there are sufficient and adequate guarantees to protect all concerned.

The Data Controller of Pragmata S.r.l. guarantees, in accordance with art. 46 and 49 of the EU Regulation 2016/679, that any transfer to a SUPPLIER Third party residing outside the EU will take place in compliance with these rules and it will always and only concern those data relating to users who have explicitly consented to this transfer and will be processed in such a way as to guarantee adequate security according to the principles of integrity and confidentiality. It will always be possible to withdraw such consent as required by art. 13 GDPR.

C) RIGHTS OF THE INTERESTED PART art. 17 EU Regulation 2016/679 and art. 17 Law 171/2018 (RSM)

The user can exercise, at any time, the rights referred to in art. 17 Law 171/2018 San Marino and the Right to be forgotten in accordance with art. 17 EU Regulation 2016/679, including:

  • The right to access their data;
  • The right to obtain their data;
  • The right to withdraw or modify consent in accordance with art. 6 par. 1 GDPR 2016/679 if there is no other legal basis for the handling;
  • The right to object to the handling based on art. 21 GDPR 2016/679 for direct marketing purposes and/or to the handling with scientific, historical or statistical purposes in accordance with art. 89 par. 1 if their reasons are related to their particular condition.
  • The right to obtain the cancellation without undue delay if the data are no longer necessary with respect to the purposes for which they were collected, if the data have been processed unlawfully, if their cancellation serves to fulfill a legal obligation of the EU or of the Member State to which the data controller is a subject, if the data concern minors under 16 years of age and there is no parental consent.

The right to oppose the processing of one’s own data for the purpose of sending advertising materials, direct sales and commercial communications and to request the updated list of data processors, can be obtained by writing to: Pragmata S.r.l. Data Controller for San Marino, Via Consiglio dei Sessanta, 99 - World Trade Center Tower B - Dogana - Republic of San Marino.

Cookie Policy

What are cookies and how we use them

A cookie is a text file that is stored on computers, tablets, mobile phones and on any device used to surf the Internet, capable of storing the user's browsing information and preferences. Some cookies can be used, as you will see better below, to make navigation easier and personalize your experience on our websites, allowing the user to be identified when using our website and use shopping carts online, as well as they can tell us which parts of our sites are visited and help us evaluate the effectiveness of advertising and analyze users’ behavior to improve our communications and products.

While browsing we can collect information regarding traffic flow and visits to the pages of our website. Any information obtained through cookies will be treated and stored safely.
The purpose of using cookies is to personalize the access to our website, optimizing site navigation and functionality, and to improve our services and provide content and/or advertisement relating to user preferences, by analyzing browsing habits.

Pragmata S.r.l. complies with the provisions contained in the Code regarding the protection of personal data ("Privacy Code"), as amended by Legislative Decree n.69, of 05/28/2012, as transposal of the European directive 2009/136 / EC and EU Regulation 2016/679.

Types of cookies

Cookies can be defined as:

  • Session cookies: which are removed when the user closes the browser and which therefore have a duration limited to your visit;

  • Permanent cookies: they remain on the device used to surf the Internet for a limited amount of time. These cookies have typical expiration dates and, therefore, their lifespan changes according to the type of cookie used.

  • First party cookies and third party cookies: depending on whether they belong to the owner of the website or to a third party.

For our websites and other online services we use the following categories of cookies:

1) Strictly necessary cookies

These cookies are essential for the proper functioning of our websites and for using and/or improving the various functions and services requested.
Without these cookies it would not be possible to manage and remember, by way of example, user authentication, access to the reserved area of the website, the contents of the shopping cart for online purchases, electronic invoicing, the creation of the purchase process of an order. Pursuant to Directive 2009/136/EC, as transposal of the Legislative Decree n. 69 of 05/28/2012, and of the provision of the Privacy Authority for the protection of personal data regarding the "Identification of simplified procedures for the information and the acquisition of consent for the use of cookies" of 05/08/2014, published in the Official Journal n. 126 of 06/03/2014, since technical cookies are essential to the correct functioning of a website, they can also be used without the prior consent of the user, without prejudice to the obligation of disclosure in accordance to art. 13 Gdpr 2016/679 and art. 13 of Law 171/2018 (RSM).

Management of cookies

For more information and/or to disable targeting and advertising cookies, the user is required to visit the following website:

Notwithstanding the above mentioned, it is noted that by disabling cookies it will still be possible to use some parts of our websites, but some of the services may not be available.

Data retention

As noted above, the lifespan of cookies depends on their type: session cookies expire when the user closes the browser; persistent cookies have limited expiration dates which, unless special exceptions, do not exceed 20 years.

Changes to the cookie policy

Pragmata S.r.l. reserves the right to make changes to the present cookie policy. The user agrees to the terms of any such future revisions and therefore agrees to periodically visit this page to be informed of any changes.

Twentyfive years
of crossing opportunities

Pragmata is proud to celebrate 25 years in business as a developer of international relations to institutions and companies worldwide.

We have reached a precious moment of our journey, studded with great challenges, experiences and important goals, ready to continue and even more confident to be able to intercept fruitful paths and new potential, so as to accompany in the right direction all those who want to walk with us.