Privacy policy

This notice explains how The First S.p.A. processes the personal data of visitors to www.thefirst.it and of people who write to us through the contact form, under Article 13 of Regulation (EU) 2016/679 ("GDPR") and Italian Legislative Decree 196/2003. The online shop shop.thefirst.it has its own privacy notice, published on the shop. The Italian version of this notice prevails.

1. Data controller

The First S.p.A., Via Festa del Perdono 10, 20122 Milan, Italy, Tax code and VAT No. 01786440154.
E-mail: info@thefirst.it - PEC (certified e-mail): thefirst@pec.net

2. What data we process

• Data sent through the contact form: name, e-mail address and the content of your message, including any other data you choose to include. Please do not include special categories of data (for example health data).
• Technical browsing data: IP address, browser and device type, pages visited, date and time of the request. These are collected automatically by the systems hosting the site to run and protect it.
• Visit statistics: we use Vercel Web Analytics, which produces aggregated visit statistics without placing cookies on your device.

3. Why we process it and on what legal basis

• To answer your requests sent through the form or by e-mail: processing is necessary to act on your request (Art. 6(1)(b) GDPR) and, for business enquiries, is based on our legitimate interest in replying to those who contact us (Art. 6(1)(f) GDPR).
• To run the site, keep it secure and measure its use in aggregate form: legitimate interest of the controller (Art. 6(1)(f) GDPR).
• To comply with legal obligations or requests from authorities, and to protect our rights in court: Art. 6(1)(c) and 6(1)(f) GDPR.

Providing the form data is optional, but without your name, e-mail and message we cannot reply. We do not use your data for marketing or profiling, and we do not make decisions based solely on automated processing.

4. How long we keep it

• Form data and correspondence: for as long as needed to handle the request and in any case no longer than 24 months from the last contact, unless a contractual relationship arises (in that case the retention periods required by law for that relationship apply).
• Technical browsing data: for the period set by our hosting providers.

5. Who we share it with

Data is processed by authorised staff of The First S.p.A. and may be shared with other group companies when needed to handle your request. It is also processed, as data processors, by the providers of the technical services we use:

• Vercel Inc. (site hosting and visit statistics);
• Google (e-mail service used to forward contact form messages to us).

Data is not published or sold to third parties.

6. Transfers outside the European Union

Some providers are based in the United States. In these cases transfers rely on the EU-US Data Privacy Framework, for providers certified under it, or on the standard contractual clauses approved by the European Commission (Articles 45 and 46 GDPR).

7. Cookies

The site does not use profiling cookies or third-party advertising cookies. For this reason no cookie consent banner is shown.

8. Your rights

You may at any time request access to your data, its rectification or erasure, restriction of processing, data portability, and object to processing based on legitimate interest (Articles 15-22 GDPR), by writing to info@thefirst.it or to the PEC address thefirst@pec.net.

You also have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (www.garanteprivacy.it).

9. Changes

We may update this notice. The version in force is always the one published on this page, with the date of the last update.