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Security report for sanmarinocard.sm

Segreteria Finanze e Bilancio - San Marino Card · Government · San Marino

Medium risk. 4 critical or high findings in GDPR outside view.

Security score

70/100

Risk levelMedium

0–100, higher is better. How it is calculated

The San Marino Card website serves as the official portal for the government-backed SMaC program, offering discount cards and electronic wallet services to residents and businesses within San Marino. The site provides comprehensive information about card benefits, partner merchants, and access to a private client area for transaction tracking. The business model is centered on facilitating government-supported financial incentives and electronic payments, positioning itself as a key public service in the local market. Technically, the website is hosted on an nginx server with a legacy charset and uses jQuery libraries alongside Google Analytics for tracking. While the site includes several security headers and a strict transport security policy, it lacks a valid SSL certificate and does not support HTTPS, which is a critical security gap. Performance metrics are unavailable, and mobile optimization is basic, indicating room for technical modernization. From a security perspective, the absence of HTTPS and modern TLS protocols significantly reduces the site's security posture. Although some security headers are present, the lack of vulnerability disclosure policies, cookie consent mechanisms, and comprehensive privacy compliance measures highlight compliance gaps. The site does provide clear contact information and links to privacy and terms documents, but GDPR compliance is not fully evident. Overall, the website is functional and credible as a government service but requires urgent improvements in SSL deployment, privacy compliance, and security best practices to enhance trust and protect user data. Strategic recommendations include installing a valid SSL certificate, enabling modern TLS versions, implementing cookie consent, and publishing a vulnerability disclosure policy.

Scanned

NIS2 and GDPR posture

GDPR outside view
25/ 100 · Critical
Checks completed
7of 7

NIS2 Art. 21(2)

  1. (a) Risk analysis and security policies: Not visible from outside
  2. (b) Incident handling: One indicator
  3. (c) Business continuity, backups and crisis management: Not visible from outside
  4. (d) Supply chain security: Not visible from outside
  5. (e) Secure acquisition, development and maintenance, including vulnerability handling: Partly checked
  6. (f) Assessing the effectiveness of security measures: Not visible from outside
  7. (g) Cyber hygiene and security training: Not visible from outside
  8. (h) Cryptography and encryption: Partly checked
  9. (i) HR security, access control and asset management: One indicator
  10. (j) Multi-factor authentication and secured communications: Not visible from outside

This scan rated NIS2 with an earlier keyword method that is no longer shown; rescan for the per-article view. Risk management, continuity, supply chain, training, MFA, management oversight (Art. 20) and incident reporting (Art. 23) need internal evidence, and Guard cannot tell whether NIS2 applies to this organisation.

GDPR is indicative only, based on publicly visible signals: Articles 7, 12, 13 and 32 of Regulation (EU) 2016/679 and Article 5(3) of the ePrivacy Directive. Not a certification or legal assessment.

Priority findings

4 findings rated critical or high. Fix these first.

  1. GDPR outside view

    These are the privacy signals visitors and data protection authorities look for under GDPR.

    • High

      No Privacy Policy found

      GDPR requires a clear and accessible privacy policy

      What to do: Add a comprehensive privacy policy page and link to it prominently

    • High

      No Cookie Policy found

      GDPR requires clear information about cookie usage

      What to do: Add a dedicated cookie policy explaining cookie usage and purposes

    • High

      No Cookie Consent Banner found

      GDPR requires explicit consent for non-essential cookies

      What to do: Implement a cookie consent banner that appears on first visit

    • High

      Third-party services without privacy policy

      Detected services: Google Analytics, Facebook, Twitter

      What to do: Document all third-party data sharing in your privacy policy

Need hands-on remediation? Email guard@offseq.com

Keep watching sanmarinocard.sm

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  • TLS certificates and expiry
  • DNS records
  • SPF, DKIM and DMARC
  • Security headers
  • GDPR and NIS2 posture
  • Exposed services
  • Third-party trackers
  • Security score drift

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Results by check

Each check with its score, findings and the evidence it collected.

How this score is calculated

The security score runs 0–100, higher is better. It is the plain average of the security checks that completed in this scan, each counted equally. A check that could not run is left out: it counts neither as a pass nor as a fail.

Counted in this score

SSL/TLS
90
Security headers
80
Email security
50
DNS health
75
Network security
100
GDPR outside view
25
Average
70

Not counted

  • NIS2 outside view: Re-weights evidence from the TLS, email, DNS, network and hygiene checks, so counting it would count that evidence twice. Shown on its own.
  • OffSeq Observations: An AI reading of the site, useful context but not reproducible evidence. Shown on its own.

Findings that cap the score at 49

Each of these is serious on its own, so while any is present the site cannot rate better than high risk, however good the other checks are.

  • The certificate is not trusted by browsers
  • The website is not served over HTTPS
  • A database, remote desktop, file-sharing or Telnet service is reachable from the internet
  • The page loads a script from a compromised source
  • The domain registration has expired
  • SPF authorises every server to send mail as the domain

Partial scans

When the site blocks Guard or most checks cannot run, the score covers only the checks that ran (usually DNS and email), is capped at 75 and is shown as partial, without a risk level.

Risk levels

  • Critical0–25
  • High26–49
  • Medium50–75
  • Low76–100

Technical appendix

Business context, site observations and technical notes gathered during the scan, and the standards behind each reference.

Business context

Business profile

The San Marino Card program is a government initiative aimed at promoting local commerce and providing financial benefits through a discount and electronic payment card. Its market positioning is strong within the Republic of San Marino, supported by partnerships with local banks, postal services, and merchant associations. The business model relies on government funding and collaboration with financial institutions to offer incentives and facilitate electronic transactions. The target customers are residents and businesses within San Marino, with growth potential tied to expanding merchant participation and digital payment adoption. The partnership ecosystem includes key local banks and government agencies, reinforcing the program's legitimacy and reach.

Security posture

The current security maturity level is low due to the lack of HTTPS and valid SSL certificates, which exposes users to potential interception and data integrity risks. Security headers such as HSTS and CSP are partially implemented but insufficient without TLS encryption. No evidence of incident response contacts or vulnerability disclosure mechanisms exists, limiting the organization's ability to manage security incidents effectively. Compliance with GDPR is partial, with privacy policies present but no cookie consent or data protection officer contact. The use of Google Analytics without explicit consent further complicates privacy compliance. Overall, the security posture requires significant enhancements to meet modern standards and protect user data.

Recommendations

  1. Install and maintain a valid SSL/TLS certificate to enable HTTPS across the entire site.
  2. Enable and enforce modern TLS protocols (TLS 1.2 or 1.3) and disable legacy protocols.
  3. Implement a comprehensive cookie consent mechanism to comply with GDPR and inform users about tracking.
  4. Publish a security.txt file and vulnerability disclosure policy to improve transparency and incident response readiness.
  5. Expand Content Security Policy to cover scripts and styles, reducing risk of XSS attacks.

Contact details published on the site

Addresses
Technical notes

Notes

The website runs on an nginx 1.21.4 server and uses multiple jQuery libraries and plugins for UI and validation. Google Analytics is integrated for visitor tracking. The site uses a legacy ISO-8859-1 charset in HTTP headers, which is inconsistent with the UTF-8 charset declared in HTML meta tags. Performance data is missing, indicating no active monitoring or optimization. Mobile optimization is basic, with fixed viewport width and media queries present but limited. The hosting provider appears to be Telecom Italia based on DNS MX and NS records. The absence of SSL/TLS and modern security protocols is a critical technical debt. The site uses custom or unknown CMS technology. Overall, the technical infrastructure is functional but outdated and requires modernization to improve security, performance, and user experience.
Standards and sources

Reference chips under each finding point to the standard, regulation or specification the finding relates to. They are taken from the official datasets below and mapped conservatively: a finding with no defensible link shows none. NIS2 and GDPR references mark where a finding is relevant evidence, not a compliance verdict. Implementing Regulation (EU) 2024/2690 binds digital infrastructure and digital service providers; for other entities it is the most detailed public reading of the Article 21 measures. WCAG, EN 301 549, European Accessibility Act and Web Accessibility Directive references name the requirement an automated accessibility rule relates to; they are not a conformance verdict.

Retrieved 2026-10-25

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