Welcome to P R A G M A™ ("we," "our," "us"), and thank you for your interest in our products! We respect your privacy and are committed to protecting your personal data. This Privacy Policy outlines how we collect, use, and safeguard your personal information when you interact with our website, services, and products. This policy complies with the General Data Protection Regulation (GDPR - Regulation (EU) 2016/679) and other applicable privacy laws in the European Union (EU) and European Economic Area (EEA).

For customers from European Union (EU) member states: This Privacy Policy also complies with the General Data Protection Regulation (GDPR) requirements applicable to the processing of personal data of EU residents.

We may collect the following types of personal data:

• IDENTIFICATION DATA: Name, surname, email address, phone number.

• TRANSACTION DATA: Details about payments and purchases.

• TECHNICAL DATA: IP address, browser type, operating system, browser behavior, and device information.

• COMMUNICATION DATA: Messages sent through contact forms or email.

• MARKETING PREFERENCES: Your preferences for receiving marketing communications, including interactions with our emails and campaigns.

We do not collect sensitive personal data (e.g., racial or ethnic origin, political opinions, religious beliefs, health data, etc.) as defined by Article 9 of the GDPR.

We collect your personal data through:

• DIRECT INTERACTIONS: When you fill out forms, send emails, or make purchases on our website.

• AUTOMATED TECHNOLOGIES: This includes website analytics, cookies, and server log files that record IP addresses, browser types, access times, and track your interactions with our site.

• THIRD-PARTY SERVICES: Such as payment processors, marketing platforms, analytics tools, and customer service platforms.

Your data is processed for the following purposes:

• PROVIDING SERVICES: To process your orders, manage payments, and deliver products to you. This also includes enabling you to check your order progress via the ORDER STATUS link by entering your order number and the email used for purchase.

• CUSTOMER SUPPORT: To respond to your inquiries and resolve any issues you may encounter.

• MARKETING: To send you promotional emails (only if you have explicitly opted in) and track engagement with our marketing materials.

• SECURITY: To prevent fraud, ensure website security, and detect unauthorized access.

• LEGAL COMPLIANCE: To fulfill our regulatory requirements under EU tax and commercial law.

• WEBSITE PERFORMANCE: To enhance your user experience through data analytics, performance tracking, and the use of cookies.

We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects, in line with Article 22 of the GDPR.

We process personal data based on one or more of the following legal bases under Article 6 of the GDPR:

• CONTRACTUAL NECESSITY: When it's necessary to process your data to fulfill our obligations arising from a purchase contract with you.

• LEGITIMATE INTEREST: To improve our website, services, and customer interactions (e.g., using analytics for service enhancement, monitoring for security). We ensure that our legitimate interests do not override your fundamental rights and freedoms.

• LEGAL COMPLIANCE: When we are required to process your data by law (e.g., for tax and accounting regulations).

• CONSENT: When you voluntarily subscribe to marketing communications or accept non-essential cookies for tracking. You have the right to withdraw your consent at any time.

We do not sell your personal data. However, we may share it with the following trusted third parties:

• SERVICE PROVIDERS: This includes payment processors, delivery services, IT providers, and analytics platforms. We ensure that these providers operate under strict Data Processing Agreements (DPAs) that comply with GDPR.

• LEGAL AUTHORITIES: If required by law or to protect our legal rights, property, or safety, or the rights, property, or safety of others.

• MARKETING PLATFORMS: If you have consented to receive marketing communications, we may share your data with targeted advertising networks to deliver relevant content.

• INTERNATIONAL TRANSFERS: When processing data, we may transfer personal data to countries outside the EU/EEA. When we do, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission under Article 46 of the GDPR.

We retain your data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law. For example:

• TRANSACTION DATA: Retained for up to 5 years to comply with legal and tax obligations under EU Member State regulations.

• MARKETING DATA: Retained until you opt out or withdraw your consent.

• CONTACT DATA: Retained as long as communication is active or to address ongoing inquiries.

• TECHNICAL LOG DATA: Retained for security and website optimization purposes for a limited period, not exceeding 12 months.

Once the retention period expires, your personal data will be securely deleted or anonymized, making it impossible to identify you, in accordance with Article 5(1)(e) of the GDPR.

Under the General Data Protection Regulation (GDPR), you have the following important rights regarding your personal data:

• RIGHT OF ACCESS (Article 15): You can request a copy of the personal data we hold about you.

• RIGHT TO RECTIFICATION (Article 16): You can request the correction of any inaccurate or incomplete personal data we have.

• RIGHT TO ERASURE ('RIGHT TO BE FORGOTTEN') (Article 17): You can request the deletion of your personal data, except where legal obligations prevent such deletion.

• RIGHT TO RESTRICTION OF PROCESSING (Article 18): You can request that we limit the way we process your personal data under certain conditions.

• RIGHT TO OBJECT (Article 21): You can object to the processing of your personal data where it is based on legitimate interests, including profiling.

• RIGHT TO DATA PORTABILITY (Article 20): You can request to receive your personal data in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller.

• RIGHT TO WITHDRAW CONSENT (Article 7(3)): You can withdraw your consent for marketing communications or cookie preferences at any time.

We will respond to your request within 30 days, in accordance with GDPR requirements. To exercise any of these rights, please contact us through our CONTACT page or at customercare@madebypragma.com.

We are committed to protecting your personal data. We implement robust technical and organizational measures to safeguard your information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• ENCRYPTION: We use SSL/TLS encryption to secure data transmission and storage for sensitive information and transactions.

• ACCESS CONTROLS: We restrict access to personal data to only those employees, agents, contractors, and other third parties who have a legitimate business need to know.

• MONITORING: We continuously monitor our systems to detect and prevent potential security breaches.

• BREACH NOTIFICATION: In the unlikely event of a personal data breach, we have procedures in place to notify affected users and relevant supervisory authorities within 72 hours, as mandated by Article 33 of the GDPR.

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site usage, and support our marketing efforts. Cookies are small text files placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Managing Your Cookie Preferences:

Upon your first visit to our website, you will be presented with a COOKIE CONSENT POP-UP that allows you to manage your preferences. You can choose to accept all cookies, or navigate to COOKIE SETTINGS to make a detailed selection.

You can change your cookie preferences at any time by clicking on the COOKIE SETTINGS link within this Privacy Policy. This will reopen the cookie consent management panel.

You can also manage cookies through your web browser settings. Most browsers allow you to block or delete cookies. However, please note that disabling certain types of cookies may impact your experience on our site and limit the functionalities we can offer, as some features may not work correctly without them.

Types of Cookies We Use and Their Purpose:

• NECESSARY COOKIES: These cookies are essential for our website to function correctly. They enable core functionalities such as page navigation, accessing secure areas of the website, and remembering items in your shopping cart. Our website cannot function properly without these cookies, and they are always active.

• PREFERENCES COOKIES: These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. For example, they can remember your language preferences, region, or currency settings. If you do not allow these cookies, some or all of these services may not function properly.

• STATISTICS COOKIES: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. We use tools like Google Analytics for this purpose.

• MARKETING COOKIES: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. We use tools like Meta Pixel for this purpose.

Our website may contain links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or security practices. We encourage you to review the privacy policy of every website you visit after leaving ours.

We may update this Privacy Policy as needed to reflect changes in our practices, technology, or legal requirements. Any changes will be posted on this page with the updated revision date. If we make significant changes to this policy, we will notify you through a prominent notice on our website. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information.

For any privacy-related inquiries, you can contact us through our CONTACT page or at customercare@madebypragma.com.

Effective from: 1 August 2025