Privacy notice

Data controller

Data controller: PHD SYSTEM. NUIS: M27101203D. Address: Njësia Bashkiake Nr. 5, Rruga Donika Kastrioti 3, Kisha Apostolike e Re, Hyrja 2, Kati 1, Apt. 1, Nr. 1, Tiranë, Shqipëri.

To exercise your rights, write to privacy@pragmakreative.com or to the address above.

Data processed

Through the contact form we process: business, sector, email address, the service (page) from which you send the request, date and time of submission, and a hash (SHA-256) of the IP address. The IP address is not stored in clear.

Purposes and legal basis

Replying to your request for a trial plan: Art. 6(1)(b) GDPR, pre-contractual measures taken at your request.

Site security and abuse prevention (limit on the number of requests through the IP hash): Art. 6(1)(f) GDPR, legitimate interest of the controller.

For processing subject to Albanian law, the corresponding legal bases of Law no. 124/2024 apply.

Legal framework

Regulation (EU) 2016/679 (GDPR), applicable to EU residents under Art. 3(2), and Albanian Law no. 124/2024 «Për mbrojtjen e të dhënave personale» (Law no. 124/2024 On Personal Data Protection).

Retention

If the request does not lead to a relationship with us, the data are kept for 12 months.

Recipients

The data are accessible to: Namecheap, Inc., the hosting provider; the controller's internal management system.

Transfers to third countries

Hosting (Namecheap, Inc., United States). The server hosting the site is located in Phoenix, Arizona (United States). The transfer relies on the European Commission's standard contractual clauses (SCCs) (Implementing Decision (EU) 2021/914, Module Two, controller to processor), incorporated in Namecheap's data processing addendum, which is deemed signed when its terms of service are accepted. You can obtain a copy of the safeguards by writing to privacy@pragmakreative.com.

Telegram. The internal notice sent through the Telegram Bot API contains only the alert "new request from the website" and an internal reference number: it contains no email, name, business or sector, nor any other personal data. For this reason no personal data is transferred to Telegram.

Controller based in Albania. Albania is not among the countries with a European Commission adequacy decision. The data you enter in the form are collected directly from you by the controller, which is subject to the GDPR under Art. 3(2): according to EDPB Guidelines 05/2021 (Example 1) this direct collection is not a transfer under Chapter V GDPR.

Provision of data

Providing data is optional. Without business, sector and email we cannot receive or reply to the request.

Your rights

You have the right of access, rectification, erasure, restriction, portability and objection (Arts. 15-22 GDPR). Corresponding rights are provided by Albanian Law no. 124/2024.

Complaints

You may lodge a complaint with the Albanian Commissioner for the Right to Information and Protection of Personal Data (Komisioneri për të Drejtën e Informimit dhe Mbrojtjen e të Dhënave Personale, IDP): https://idp.al

You may also lodge a complaint with the supervisory authority of the EU country where you live. For Italy, this is the Garante per la protezione dei dati personali: https://www.garanteprivacy.it

Automated decision-making

No automated decision-making takes place (Art. 22 GDPR).

Cookies and browser storage

The site uses no profiling cookies, no statistics or marketing tools, and loads no resources from third-party services. We only set the technical storage listed below, which does not require consent.

List: key «pk-consent» in the browser's localStorage, first party (pragmakreative.com). Purpose: remember your consent choice (necessary, statistics/marketing). Duration: 6 months, then the banner shows again. No data leaves your device.

The «Statistics and marketing» categories are currently empty and off by default: if we enable them in the future they will start only after your consent and this section will be updated.

To withdraw or change your consent use the «Cookie preferences» link at the bottom of every page: you can accept or reject at any time, just as easily. You can also delete the key from your browser. Reference: Italian Data Protection Authority cookie guidelines, 10 June 2021.

Last updated: 18 October 2026.