This page is a translation
This is the English translation of our privacy notice. If the two versions differ, the Italian version prevails.
Privacy in brief
- Who handles your data. It is handled by Strategic S.r.l., the San Marino company that offers the Quota Strategica service.
- What data. We collect what you write in the “First move” form or in an email, plus a few technical details of your visit.
- Why. We use it to reply to you, arrange the first meeting and understand which pages are useful.
- What we don't do. We don't profile you, we don't use advertising cookies and we don't sell your data.
- Your rights. To see, correct or delete your data, write to staff@quotastrategica.com.
Who handles your data: the data controller
The data controller is Strategic S.r.l., acting through its legal representative for the time being, meaning whoever represents the company at that moment. The controller is the party that decides why and how personal data is used.
Strategic S.r.l.Via degli Aceri 14, 47892 Acquaviva
Republic of San Marino
Economic Operator Code SM 31552
staff@quotastrategica.com
strategic.sm
Quota Strategica is the name of the service, not a separate company. For any question about this notice or about your data, write to staff@quotastrategica.com.
This notice covers the website. If you become a client after the first meeting, the processing of data for the service is governed by the documents you receive at that point.
What data we collect when you visit the site
The site runs on Cloudflare's infrastructure. To show you the pages and protect them from attacks, Cloudflare processes the technical data of your connection, namely IP address, browser type, pages requested, date and time. The IP address is the number that identifies your internet connection.
The site also keeps a log of pages that were not found. It saves the address that was requested and the name of the site the link came from, so that we can fix broken links. It does not save who made the request.
Visit statistics: no cookies and no outside services
To understand which pages are useful and where visitors come from, we use our own statistics system, which runs on the same servers as the site. It uses no cookies, stores nothing in your browser and passes no data to outside analytics or advertising services.
When you open a page, the site records this data:
- The address and title of the page, and the site you came from, such as a search engine.
- The tags that some links carry in their address to show where you came from, if there are any.
- Your screen size, your browser language and whether the screen is a touchscreen.
- The type of device, the browser and the operating system.
- How long the page stayed in the foreground and how far down you scrolled.
- The approximate country, region, city and postcode, worked out from the connection. They belong to the network provider and are not your address.
- The name of the network you connect from, meaning the operator or the organisation that has its own network.
- Certain actions, such as sending the form or tapping an email address. The site records that the action happened, never what you wrote.
Your IP address is never stored in full. Only the part that identifies the network is kept.
To count the different people who visit in a day, the site calculates a code from the IP address, the browser and two keys. The first key is secret and is not kept with the statistics. The second changes every day and is then deleted. This way we know that two pages were viewed by the same person on the same day, but we cannot recognise you on later days.
Detailed data is kept for 13 months and is then deleted automatically. Daily summaries are kept for 25 months, and they contain no IP addresses and no visitor codes. They show how many visits each page had, from which sites, from which countries, regions and cities and from which networks, including the names of organisations that have their own network.
The statistics do not count the people who run the site, or visits that come from data centres, for example from spam filters that open the links in emails. Robots from search engines and AI assistants are counted separately, with their name and the page they read.
What data the “First move” form collects
The form is for requesting the first introductory meeting. It collects what you write and choose yourself:
- Full name, email and type of project. These are the only required details, together with your consent.
- Phone number and company name, if you give them.
- Your project, meaning sector, the country you are starting from, expected employees and timing.
- Your answer to the question “Will you move to San Marino?”.
- How you heard about us.
- Your message, if you write one.
- The language of the form, the page you started from and the result of the “Is San Marino right for you?” test, if you came from there.
- Your consent to the processing of your data, which you give by ticking the box in the form, with the date and time you gave it.
We give each request a number. The request is saved in the site's database and is read only by the people at Strategic who need to reply to you. When notifications are switched on, a copy is sent by email to staff@quotastrategica.com and you receive a confirmation email.
To stop automated submissions, the site derives a code from your IP address, and the address cannot be worked back from that code. The code is kept with the request. A temporary counter limits submissions from the same connection and is deleted when it expires. The IP address itself is not stored in readable form.
When it is switched on, the form also uses Cloudflare Turnstile, a check that tells people apart from automated programs. Turnstile loads a small program from Cloudflare's servers and reads some technical data about your browser and connection. We use it for this check only.
Please do not enter passwords, health data, confidential documents or other people's data in the form.
The calculators and the “Is San Marino right for you?” test
The calculators and the test work in your browser. The figures you enter in the calculators do not reach us.
For the test, the site may record that it was completed and with what result, without a name, an email or any other data that identifies you. If you go from the test to the form, your answers are already filled in. They reach us only when you send the form.
When you email us
If you write to staff@quotastrategica.com, we process your address, your name and the content of the message in order to reply. The domain's email is run by Zoho, which processes the messages on our behalf.
Why we process data and on what basis
We process data only for the purposes listed below and only for as long as needed. The legal basis is the reason, set out in law, that allows us to process a piece of data. Where a law sets a retention period, that period applies.
Legitimate interest, which appears in the table, is a concrete and lawful reason on the part of whoever processes the data. The law allows it when it does not override your rights.
Purposes, legal bases and retention periods
| Purpose | Legal basis | For how long |
|---|---|---|
| Replying to your request and arranging the first meeting | The consent you give in the form. The request you make to us before any contract | As long as it takes to handle the request. If you become a client, for the length of the relationship |
| Stopping automated submissions and misuse of the form | Our legitimate interest in the security of the site | The code derived from the IP stays with the request. The counters are deleted when they expire |
| Replying to your emails | The request you make to us before any contract | As long as it takes to handle the exchange |
| Showing the site and protecting it | Our legitimate interest in the running and security of the site | Cloudflare's technical retention times |
| Cookie-free visit statistics | Our legitimate interest in understanding how the site is used | Detailed data 13 months. Daily summaries 25 months |
Consent, profiling and automated decisions
You can withdraw your consent at any time by writing to staff@quotastrategica.com. Anything we did before the withdrawal remains valid.
When the request is no longer needed, we delete it. You can ask us to delete it sooner.
We do not use your data for newsletters or promotional messages. We do not profile you, which means we do not build a profile of you to predict what you will do. No decision that affects you is taken by a program. The test gives an indication and the decision stays with you.
Who receives your data
Your data is handled by authorised people at Strategic, who are bound by confidentiality. For some services we use suppliers, who process data on our behalf and on our instructions:
- Cloudflare provides the site's infrastructure, the database of requests and statistics, protection from attacks and, when it is switched on, the Turnstile check.
- Zoho provides the domain's email.
- Legal, tax and technical advisers receive data only when this is needed to meet a legal obligation or to protect one of our rights.
We do not sell your data or hand it over for commercial purposes. We disclose it to the authorities only when the law requires it.
The request you send from the site is for us, so that we can reply to you. Involving professionals, banks or agencies comes later and is decided together with you.
Where the data is kept
Strategic is based in the Republic of San Marino. Requests and statistics are held in the site's database, on Cloudflare's infrastructure. Email is held on Zoho's servers.
Cloudflare and Zoho are international groups and may also process data outside San Marino and the European Union. In that case the transfer takes place with the safeguards required by data protection law. If you want to know which safeguards apply to a supplier, write to us.
How we protect data
Pages travel only over encrypted connections. The site's management area is restricted to authorised people and access is protected by a password.
We collect only the data we need. The site loads no advertising programs and does not keep your IP address in readable form in its database.
Cookies: no banner to accept
The site uses no profiling cookies and no advertising cookies, and the statistics work without cookies. That is why we don't ask you to accept anything when you arrive.
The few technical tools the site uses are listed, with name, purpose and duration, on the Cookies page, which is in Italian.
Your rights and how to exercise them
At any time you can:
- Ask whether we process data about you and receive a copy.
- Have it corrected or completed.
- Have it deleted, when no law requires us to keep it.
- Have its processing restricted.
- Receive it in a commonly used format, so that you can pass it to another controller.
- Object to processing based on our legitimate interest, such as the statistics.
- Withdraw the consent you gave.
To exercise your rights, write to staff@quotastrategica.com. We reply within the time set by law. To protect your data, we may ask you to confirm who you are.
The statistics do not allow us to recognise you on the days after your visit. For this reason we normally cannot trace your past visits.
Where you can complain
If you believe the processing of your data breaks the law, you can lodge a complaint. In San Marino the competent authority is the data protection authority, the Autorità Garante per la Protezione dei Dati Personali.
If you are in the European Union, you can go to the authority of the country where you live or work. In Italy it is the Garante per la protezione dei dati personali.
You can always write to us first. If the problem can be solved, we solve it straight away.
The rules we follow
Strategic processes data in line with Law no. 171 of 21 December 2018 of the Republic of San Marino, which protects individuals in the processing of personal data. For people in the European Union, Regulation (EU) 2016/679, known as the GDPR, also applies.
When this notice changes
We update the notice when the site's services, our suppliers or the rules change. The date of the last update is at the top of the page.