Legal document

Privacy Policy

Notice on the processing of personal data under EU Regulation 2016/679 (GDPR) GDPR

1

Data controller

The controller of your personal data is:

Luiter
Company name: [INSERIRE NOME/RAGIONE SOCIALE]
Address: [INSERIRE INDIRIZZO COMPLETO]
VAT / tax code: [INSERIRE P.IVA O CODICE FISCALE]
E-mail: enzopoleo93@gmail.com
Website: https://luiter.pages.dev
2

Personal data collected

luiter.pages.dev only processes data you provide voluntarily. There is no sign-up form and no online payment: the order is recorded by the site and then completed over WhatsApp.

Type of dataHow it is collectedWhere it is storedPurpose
Products, quantities, total, language, order codeWhen you press “Order on WhatsApp”Cloudflare D1 database (EU)Recording and handling the order
IP address in irreversibly hashed formAutomatically, when an order is sent and on admin login attemptsCloudflare D1 database (EU)Abuse limits and security
Phone numberWhatsApp conversation you startCloudflare D1 database (EU), entered manually by the controllerOrder handling
Name (optional) and email addressRequest form when email summaries are enabled, or WhatsApp conversationCloudflare D1 database; Resend for email sending when enabledHandling the request and sending its summary
Shipping addressWhatsApp conversationCloudflare D1 database (EU), entered manually by the controllerOrder fulfilment
Cart and preferred languageUse of the siteBrowser localStorageUser experience — client side only
Note: your cart and language stay in your browser’s localStorage until you submit a request. The site records products, quantities, total, language and reference. When email summaries are enabled, it also records the optional name and email entered in the form for communications about the request. Phone numbers and shipping addresses are supplied on WhatsApp. The email is not used for newsletters or advertising.
3

Purposes and legal basis

PurposeLegal basis (GDPR)
Handling orders via WhatsAppArt. 6(1)(b) — performance of a contract
Replying to enquiriesArt. 6(1)(b) — pre-contractual measures
Tax and accounting obligationsArt. 6(1)(c) — legal obligation
Protecting the site from abuse (order limits, admin lockout)Art. 6(1)(f) — legitimate interest in security
Improving the site (analytics)Art. 6(1)(a) — consent, where applicable
4

Retention period

Personal data is kept only as long as needed for the purposes it was collected for:

5

Disclosure of data

Personal data is never sold or transferred to third parties. It may only be shared with:

Order data is stored in the European Union. Any transfer to third countries by the providers above takes place under the Standard Contractual Clauses approved by the European Commission.

6

Your rights

Under Articles 15–22 GDPR you have the right to:

To exercise your rights write to enzopoleo93@gmail.com. We reply within 30 days.

You also have the right to lodge a complaint with your national data protection authority, or with the Italian Garante per la protezione dei dati personali.

7

Cookies and tracking

The site uses strictly necessary technical storage only:

NameTypePurposeDuration
luiter_cartlocalStorageKeeps the cartPermanent (client side)
luiter_cart_tslocalStorageExpiry of the saved cartPermanent (client side)
luiter_langlocalStoragePreferred languagePermanent (client side)

There are no profiling cookies, third-party analytics or social media cookies without prior consent.

8

Data security

The site is served exclusively over encrypted HTTPS/TLS. No payment data is stored: transactions, where they happen, take place on certified third-party platforms (e.g. PayPal, Stripe).

Orders can only be viewed by the controller, through a password-protected panel. The panel logs every login attempt and automatically blocks anyone who gets the password wrong repeatedly. IP addresses are never stored in clear text, only in irreversibly hashed form.

9

Changes to this notice

The controller may amend this notice at any time. Changes take effect when published on the site. Please check this page from time to time.

Last updated: October 2026

10

Contact

For any question about this notice or about the processing of your personal data:

Contact form and the shared QRWave service

The contact form is prepared but sending is currently disabled. Once enabled, it processes an optional name, email, topic, message and a technical request identifier to forward the communication and allow a reply. There are no attachments or automatic replies.

Cloudflare hosts the site and shared service, applies security protections and manages abuse counters. The counter database records only the UTC day, site and technical identifier: it contains no name, email, message text or IP address. The active database retains approximately three days of counters; any backups follow the provider’s settings. Temporary IP protections use HMAC keys and do not write IP addresses to application logs.

Resend receives the data needed to forward the email. Google/Gmail handles receipt and correspondence in the destination mailbox. The email entered in the form may be used to reply. Resend acceptance does not confirm mailbox delivery. The service retains idempotency keys for 24 hours; every attempt, including failed attempts and retries, counts towards sending limits.

The form uses no CAPTCHA, advertising, analytics or session recordings. Fields are not saved to browser storage or a service worker cache; text stays only in the open page. This notice and the contact page load no analytics or advertising and are readable without consent scripts.

The controller’s full identity and contact details, the legal basis applicable to different requests, actual correspondence retention periods and provider agreements must be completed with the owner before sending is enabled. Order retention periods stated elsewhere do not automatically apply to form messages.

Contact