Privacy Policy

Version 1.1.0 — updated 6 October 2026

1. Data Controller

The Data Controller is:

Fortina.it di Umberto Fortina – PRIMOREGGIMENTO.COM
Via Giovanni Falcone 37
28047 Oleggio (NO) – Italy
VAT No. 02563320031
Italian Tax Code FRTMRT79B23F952Y
REA NO-244044
Email: info@primoreggimento.com
Certified email (PEC): fortinait@pec.it
Telephone / WhatsApp: +39 3423472042

2. Scope of this notice

This notice describes the processing of personal data carried out through PRIMOREGGIMENTO.COM and in connection with the e-commerce services, pre-contractual and contractual relationships, assistance and communications requested by the data subject.

This notice is provided pursuant to Regulation (EU) 2016/679 (GDPR) and the applicable Italian data-protection legislation.

3. Categories of personal data processed

Depending on the services used, the following data may be processed where necessary:

  • identification and contact data, such as first name, surname, address, email address and telephone number;
  • customer-account and credential data;
  • data concerning orders, purchased products, invoicing, shipping, returns, withdrawal, warranty, assistance, repairs and quotations;
  • data necessary to manage payments and information on their outcome, without PRIMOREGGIMENTO.COM directly storing full payment-card data;
  • the content of communications sent through the available channels;
  • technical data necessary for website operation and security, such as IP address, technical logs, browser/device information and technical cookies;
  • only when the user enables Analytics, browsing and website-interaction data collected through Google Analytics 4, such as pages/content viewed, browsing and ecommerce events, technical browser/device information, the IP address communicated by the browser to Google, and identifiers associated with Analytics cookies.

4. Source of personal data

Personal data are mainly collected from the data subject when an account is created, an order is placed, assistance is requested, PRIMOREGGIMENTO.COM is contacted or website functions are used. Certain technical data are generated automatically while the website is being used. Data strictly necessary to carry out payments or shipments may also be received from the relevant service providers.

5. Purposes and legal bases

  • Accounts, requests, quotations, orders, payments, shipping, withdrawal, returns, warranty and assistance: performance of a contract or requested pre-contractual measures.
  • Tax, accounting, administrative and other legal obligations: compliance with legal obligations.
  • Website security, prevention of abuse/fraud and protection of rights: legitimate interests of the Controller.
  • Commercial or promotional communications: only when actually enabled and permitted by law, on the applicable legal basis.
  • Google Analytics 4: statistical analysis of website use and measurement of interactions, including ecommerce interactions handled by the official PrestaShop ps_googleanalytics module. Processing is activated exclusively after consent to Analytics. Refusal or withdrawal does not prevent browsing, cart use or checkout.

6. Requirement to provide personal data

Providing data marked as necessary for an account, order, payment, shipment, invoicing or assistance is necessary to provide the requested service or comply with the related obligations. Failure to provide such data may make it impossible to create or manage an account, conclude or perform an order, make a delivery, issue required documents or provide the requested assistance.

Providing data for optional purposes, where present, is voluntary and refusing consent does not affect purchases or services necessary to perform the contract.

7. Processing methods and security

Personal data are processed using electronic, IT and telematic systems and, where necessary, paper records. The Controller adopts technical and organisational measures appropriate to the risk in order to protect data against unauthorised access, loss, alteration, disclosure or misuse.

Data may be processed by authorised persons and external providers involved in necessary services, according to their respective data-protection roles and, where required, under agreements pursuant to Article 28 GDPR.

8. Payments

Payments may be managed by external payment-service providers available at checkout, including PayPal where selected by the user, as well as the providers that process the card-payment services actually available on the website.

PRIMOREGGIMENTO.COM receives the information necessary to verify and manage the transaction but does not directly store complete payment-card details. The payment provider processes personal data according to its role and privacy notice.

9. Shipping and logistics

In order to prepare and deliver orders, strictly necessary personal data may be disclosed to logistics platforms, couriers and other operators involved in shipping. PRIMOREGGIMENTO.COM also uses Packlink/Auctane logistics services; depending on the selected shipment, the data required for delivery may be transmitted to the appointed carrier.

Data disclosed may include the recipient's name and surname, address, contact details, shipment references and any information necessary for delivery.

10. Communications by email, telephone and WhatsApp

When a user contacts PRIMOREGGIMENTO.COM by email, telephone or WhatsApp, the data and content of the communication are processed to respond to the enquiry and manage the requested service.

For communications made through WhatsApp, services provided to users in the European Region by WhatsApp Ireland Limited are also involved in accordance with its privacy notice.

11. Recipients and categories of external parties

To the extent necessary, personal data may be disclosed or made accessible to:

  • payment service providers and financial entities;
  • Packlink/Auctane, couriers, carriers and logistics operators;
  • hosting, infrastructure, email, security, maintenance and IT providers;
  • e-commerce platform and management-software providers;
  • communication service providers, including WhatsApp when used by the data subject;
  • Google, exclusively when the user enables Analytics, for Google Analytics 4 under the applicable terms and privacy information;
  • accountants, tax, administrative and legal advisers and other professionals;
  • public authorities and other parties where disclosure is required or permitted by law.

Personal data are not sold to third parties.

12. Transfers outside the European Economic Area

Certain technology or communication providers may process data outside the European Economic Area. Where an international transfer falls within the GDPR, it must rely on a Chapter V GDPR mechanism, such as an adequacy decision, European Commission Standard Contractual Clauses or another applicable mechanism.

When Google Analytics 4 is activated with consent, Google services applicable to European users are involved and processing or international transfers may occur within the provider's infrastructure. Google describes the applicable protection and transfer mechanisms in its terms and privacy information.

13. Retention periods

Personal data are retained no longer than necessary for the purposes for which they are processed, subject to legal obligations and the need to establish, exercise or defend legal claims.

  • Orders, invoices and tax/accounting records: normally 10 years, subject to applicable requirements.
  • Contractual, warranty, withdrawal, return and dispute records: for the relationship and the period needed for applicable obligations and limitation periods.
  • Customer account: while active and, after closure, only as required by law or to protect rights.
  • Contact, assistance and quotation requests: for handling and a reasonable subsequent documentation period.
  • Technical/security data: for periods proportionate to technical and security needs.
  • Cookie preference: pr_cookie_consent stores the choice for 180 days unless changed or withdrawn earlier.
  • Google Analytics 4: Analytics cookie durations are stated in the Cookie Policy; retention on Google's systems depends on property settings and service rules. Withdrawal prevents further Analytics loading and the CMP removes Analytics cookies found on the website.
  • Other consent-based data: until withdrawal or another period communicated for the purpose.

14. Cookies and tracking technologies

PRIMOREGGIMENTO.COM uses its own consent-management platform, PR Cookie Consent. Cookies and tools strictly necessary for e-commerce operation and privacy-preference storage are active without prior consent where permitted by law.

Analytics is optional and disabled by default. Google Analytics 4, Measurement ID G-PRLFVN6H7J, loads only after a positive choice. Before consent and after rejection, the Google Analytics tag is not loaded, no Analytics requests are sent and related cookies are not created.

The user may change or withdraw the choice at any time through “Review your cookie choices” in the footer. Following withdrawal, Google Analytics is blocked again and the CMP deletes _ga and _ga_PRLFVN6H7J.

The choice is stored through pr_cookie_consent for 180 days. The CMP does not create a centralised consent database containing IP addresses, fingerprints or customer identifiers.

Details are provided in the PRIMOREGGIMENTO.COM Cookie Policy.

15. Automated decision-making

As of the date of this notice, PRIMOREGGIMENTO.COM does not, within the processing described above, make decisions based solely on automated processing that produce legal effects concerning the data subject or similarly significantly affect the data subject within the meaning of Article 22 GDPR.

16. Data-subject rights

In the cases and within the limits provided for by Articles 15-22 GDPR, the data subject may request access to personal data, rectification, erasure, restriction of processing and data portability and may object to processing. Where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

Requests may be sent to info@primoreggimento.com or to the certified email address fortinait@pec.it.

17. Complaint to the supervisory authority

The data subject has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), without prejudice to any other administrative or judicial remedy available under applicable law.

18. Minors and age-restricted purchases

The processing of personal data and the rules concerning legal capacity to purchase or the purchase of specific age-restricted products are separate matters. For products for which the law requires an age requirement, PRIMOREGGIMENTO.COM applies the verification procedures set out in the General Terms and Conditions of Sale and applicable law.

The website is not specifically directed at minors and does not seek to knowingly collect minors' personal data for purposes incompatible with applicable law.

19. Updates to this notice

This notice may be updated following regulatory, technical or organisational changes or changes to the services used. The version and update date are stated at the beginning of the page.

Material changes will be made known in a manner appropriate to their nature. Published versions are managed through PRIMOREGGIMENTO.COM's legal-document management system.

20. Privacy contacts

For requests concerning the processing of personal data:

Fortina.it di Umberto Fortina – PRIMOREGGIMENTO.COM
Email: info@primoreggimento.com
Certified email (PEC): fortinait@pec.it

Contact us on WhatsApp
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