Privacy Policy

You are reading the policy related to the service:


A. Type of Personal Data Processed
B. Personal Data Processing of Children below the Age of 18 Years
C. Purposes of the Personal Data Processing
D. Lawful Basis for Processing Personal Data, Mandatory/Discretionary Provision of Personal Data and Consequences in case of not providing
E. Personal Data Sharing
F. Personal Data Transfer
G. Personal Data Retention
H. Data Subject Rights
I. Privacy Policy Amendments

The following Privacy Policy is written by Panini UK Limited, registered office at Brockbourne House, 77 Mount Ephraim, Tunbridge Wells, Kent, TN4 8BS, U.K. Business Registered in England No. 1275893 - VAT Number GB244971344 (hereinafter "Panini") as Data Controller of the personal data collected in our website (referred to in this Privacy Policy as the “Website”), provided directly by you or however received or generated by us in connection with the services and subscriptions we may provide (“Services”).

Panini considers your privacy essential. We therefore ask you to read this information carefully in order to make a freely given, specific, informed and unambiguous choice when you are requested to give your personal data to Panini.

In general, all the personal data (hereinafter "Personal Data" and/or "Data") collected by Panini through the Website or received by Panini in relation to the Services as fully described in the following section "C. Purposes of Personal Data Processing" of this Privacy Policy, will be processed lawfully and in a transparent manner in accordance with the principles stated in the current legislation on the protection of personal data, such as transparency, fairness, lawfulness, data minimisation, purpose limitation, accuracy, storage limitation, integrity and confidentiality.

This Privacy Policy is written on the basis of the transparency principle using simple and not too legal language to increase the level of understanding of the statements given.

This Privacy Policy is divided into sections (hereinafter collectively "Sections" and/or individually "Section"), each of them dealing a specific topic, so that you can immediately find what you are looking for and concentrate your attention on the topic of interest.

The Panini Website may contain links to other websites and/or smartphone applications. Panini is not responsible for privacy practices or the content of such websites and/or smartphone applications.


Personal Data collected through the Website or otherwise in relation to the Services are listed below.

Name, Last name, Contact Details and other Personal Data

When you create an account to log into the Website, Panini may ask your personal information such as: name, last name, gender, contact details, month and year of birth of the purchaser and of the reader, county or state and country of residence.

In the same way, you may be asked to indicate other Data such as: shipping address, the choice of payment method and the age of the reader on the occasion of each purchase of goods and/or services. Data coming from your submission of texts or registration information, on the occasion of participation in competitions, promotions, interactive games and initiatives of any kind. Further Personal Data may be collected during the management of each relationship through the Website itself or may consist of those that you decide to provide to Panini through the use of the Customer Service area of ​​the Website.

With regard to the Data relating to the payment that you have transmitted to us, Panini undertakes to process only the data received by digital payment companies and credit card payment organisations, which consists exclusively of information relating to the payment status (accepted/refused). All additional information relating to bank accounts, prepaid cards or credit cards is recorded by the company that manages the corresponding service, and it is not authorised to use the Personal Data received through it for other purposes.

With reference to the collection of payment data for orders processed via the Website by Elavon Opayo payment gateway, please refer to the following link for the Elavon Opayo privacy policy: For the privacy information relating to the order payments processed by PayPal, please refer to the following link:

Some sections of the Website can include free text fields in which it is possible to provide Panini with information that may contain Personal Data. Being free fields, you may choose to communicate (even inadvertently) particular categories of Personal Data, such as those revealing political opinions, religious or philosophical beliefs, or union membership, as well as genetic data, biomedical data which can be used to identify a specific person, data related to health or sex life or sexual orientation.

Panini asks you not to disclose any of these types of data, unless you consider it strictly necessary to pursue the request you forward to us. Since the indication of such information is, as said, totally optional, if you choose to do so, Panini will consider this to have been made public by you to us for these purposes (but Panini will not further publicise or use such data). You may request the removal or deletion of this data at any time by contacting us.

Personal Data of Third Parties

As mentioned in the previous paragraph, by providing in the Website’s free text fields in which it is possible to forward any type of message, these could in fact contain Personal Data relating also to other people. We ask that you do not submit any Personal Data relating to third parties without first obtaining their express consent. In the event that you do decide to share such Data, you will be deemed to have confirmed to us that you have obtained such express consent from the applicable third party. Therefore, in this regard, you agree to be responsible for and to protect Panini from and against any dispute, claim, request for compensation for damage from data treatment etc. that could reach Panini from people whose Personal Data have been forwarded by you without their consent or otherwise in violation of the applicable rules on the protection of Personal Data.

As, in such cases, Panini does not collect this information directly from the data subjects (but indirectly from you), you guarantee that this specific treatment can be based on the consent of these data subjects or on another suitable lawful basis that legitimises the processing of the information in question. You agree to indemnify and keep Panini indemnified against any claims from third parties whose Personal Data you may have provided without their consent.

IP address spatial coordinates

When you create a profile on the Website, we will collect the approximate spatial coordinates (state, city) of your IP address associated, only, with your last log-in. We will keep this information only to the extent strictly necessary and proportionate to ensure the Security of the Website and to identify anomalies, fraudulent activities and/or abuse in the use and access to the Website.

Browsing Data and Cookies

As you interact with our Website, we will automatically collect system and technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. This information is not collected by Panini to be associated with you, but by its very nature could, through processing and association with data held by third parties, allow you to be identified. This category of data includes the IP addresses or domain names of the devices used by you in connecting to the Website, the addresses in URI (Uniform Resource Identifier), notation of the requested services, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (good result, error, etc.) and other parameters related to the browser, operating system and your device.
The information on the use of cookies is available in our Cookie Policy, which we kindly ask you to read by clicking on the following symbol  and/or (Manage Cookies) in the Website footer.


Our Website is intended for use by those individuals aged 18 and over. People under the age of 18 are not permitted to purchase goods, subscribe to products or access any of the Services through the Website.

Children are not eligible to use the Services we offer. You are not permitted to use this Website or send your personal information to us if you are under the age of 18. Panini does not knowingly collect, use or disclose personal information from children under 18.


We will process your Personal Data for the following purposes:

  • allowing the execution of operations strictly connected and instrumental to the management of relationships with you, such as managing the response to queries received from you; executing contracts for the sale of goods and/or services, managing and fulfilling orders via E-Commerce platforms; allowing you to participate in games, initiatives, competitions and prize events; allowing the correct execution of the contractual obligations we have assumed towards you and vice-versa (Services Provision & Contractual Obligations);
  • complying with the laws and regulations of UK or EU Legislation (as applicable) and with any provisions issued by authorities empowered by law and provisions issued by Supervisory and Control Bodies, as well as allowing tax and accounting compliance (Legal Compliance);
  • to get the information required to identify anomalies, illegal activity and/or abuse of the use of the Website towards Panini UK or third parties (Security);
  • as part of certain Services, Panini carries out a series of automatic checks aimed at identifying and blocking any fraudulent procedures including purchases in violation of the contractual conditions of the Service, as well as checks for security purposes during the purchase and payment phases. These checks can also take place after receipt of the order and consist, for example, of automatic checks based on the similarity of the words with reference to the data of the account from which the order was sent, the total number of orders and their amount, even with respect to a certain period of time; or verification of transactions carried out by international payment circuits. The payment providers make an "anti-fraud dashboard" available to Panini which, through a scoring system, allows us to assess the risk associated with a transaction on the basis of which, for example, the use of a credit card is prevented if the issuing country is different from the country of dispatch of the goods. For each transaction Panini only becomes aware of the circumstance of a blocked order, without further information. In addition, through a special anti-fraud system (referred to in this Privacy Policy as the "Anti-fraud system") and before receiving the order, Panini carries out an automated analysis to determine whether or not a specific transaction should be accepted, based on configuration rules that attribute a certain risk score to each transaction, taking into account its characteristics. The Anti-fraud system also allows us to create blacklists when the data used by the user has already been previously involved in some blocked order ("Anti-fraud controls"); carrying out information activities about our products and/or services as well as promotional, commercial, marketing campaigns and market research through the use of automated systems (for example, e-mail), through the official pages managed by Panini on social networks; and through traditional methods of contact, such as the postal service; performing customer satisfaction surveys (by sending questionnaires, conducting surveys or telephone surveys). Other than Existing Customer Marketing as described below, we will only send you direct marketing via email, post or telephone if you have consented to receiving marketing via that method (Marketing);
  • if you are using or have used a service on our Website or if you are purchasing or you have purchased a product or a service through the Website, we may send you direct marketing and promotional communication via e-mail about similar products or services unless you have elected to not receive such communications (Existing Customer Marketing);
  • setting up groups of users by processing the data provided by our users so that we don’t send generalised commercial and promotional communications to all users in an indistinct way. This enables us to segment users, creating groups based upon common features for example, on the country of origin, language, gender, previous purchases, etc. This allows us to send commercial communications - through the use of automated systems (for example, e-mail), but also through traditional methods of contact, such as the postal service - that are the most relevant and least invasive possible, limiting as far as possible the circumstance that you receive messages not of your interest. If you have simultaneously provided consent for the purpose of "Marketing", this then allows us to send you commercial and promotional communications that are not generalised and indistinct and, therefore means that you receive the most relevant and least invasive communications for you, limiting as far as possible the circumstance that you receive messages that are not of your interest. Communications may be sent via automated systems without operator intervention (e.g. email); traditional methods of contact (e.g. post, telephone; Panini's official social pages (such as Facebook, Instagram and other social platforms - reach them through the social icons on our Websites) with the related online publication of personalised and specific ads / posts / advertisements relating to the Panini world (with custom activities audience or custom audience) (Customising our communications).
  • to provide contact data for specific initiatives to create an account or profile on the Website to third parties - individually and specifically indicated each time in the relevant consent form, when present at the time the Data is provided - with which Panini has commercial relationships in order to allow the latter to send you promotional, marketing communications and commercial information or to carry out market research for the products and services of those third parties (Communication to third parties).


The lawful basis for processing the Personal Data, in accordance with the purposes set in the earlier Section of this Privacy Policy ("Purposes of the Data Processing"), is as follows.

The provision of Personal Data and the related processing for the purposes related to Services Provision and Contractual Obligations, is necessary for the performance of the requested service and the correct execution of the contractual relationship with you. Consequently, failure to provide the Personal Data requested for this purpose, or the inaccuracy of the data provided, will make it impossible for Panini to carry out the service and the contractual relationship and would legitimise Panini to refuse to carry it out.

The provision of personal Data, and the related processing for purposes related to Legal Compliance, is necessary for Panini in order to comply with the related legal obligations deriving from the laws of the EU / UK (as applicable). When you provide your Personal Data to Panini, we must process them in accordance with applicable laws which may include the storage and communication to the competent authorities for compliance with tax, customs or other obligations.

The provision of Personal Data and its processing for purposes related to Security are based on

  1. the legitimate interests of Panini to identify and prevent any illegal behaviour and to determine the responsibilities in the event of computer crimes to the detriment of the Website such as to compromise the availability, authenticity, integrity and confidentiality of the Personal Data stored or transmitted, and
  2. in your interest in order to detect and follow up the appropriate checks in case of fraudulent access or acts illegal through the profile you created on the Website.

The provision of Personal Data and the corresponding processing in order to perform the Anti-fraud controls is based on the legitimate interest of Panini to identify and block any fraudulent purchase procedures and / or in violation of contractual conditions, within the context of certain Services, as well as seeking to ensure security during the purchase and payment phases. These security measures also protect the customer by identifying in advance and therefore blocking fraud and / or purchase attempts made in violation of the limits set by the contractual conditions governing the orders. In general, purchases made in excess of Panini's limits are aimed at creating supply and demand in the resale market, usually at much higher prices than the recommended retail price as set by Panini.

The provision of Personal Data, and the related processing of such data for the purposes related to the Marketing activity, is based on your consent collected through a specific checkbox. You are not forced to provide such consent to Panini and, if you do so, you are free to withdraw it at any time without suffering any consequence (other than not receiving marketing communications from Panini). You can withdraw your consent for this purpose by following the instructions contained in the “Data Subjects Rights” section of this Privacy Policy or, where the communications are sent by email, by using the link at the bottom of each of the emails received for that purpose.

The provision of Personal Data, and the related processing, for the purposes related to the activity of Existing Customer Marketing is based on the legitimate interest of Panini to send marketing communications via e-mail regarding products and services similar to those you have already used or purchased through the Website. You can stop the receipt of these communications without suffering any consequence (other than that of not being able to receive further communications of this kind by Panini) using the link at the bottom of each of the e-mails received for that purpose.

The provision of Personal Data, and the related processing, for the purposes related to Customising our communications is based on your consent collected through a specific checkbox and based on our legitimate interests. You are not obliged to provide such consent to Panini and, if you do so, you are free to revoke it at any time without suffering any consequence (other than not being able to benefit from the personalisation of Panini's commercial offers). You can withdraw your consent for this purpose by following the instructions provided in the "Data Subjects Rights " section of this Privacy Policy.

We will use a specific checkbox to collect your consent to provide and permit the relevant processing of your Personal Data for Communication purposes to third parties. You are under no obligation to provide Panini with this consent and, if you do so, you are free to withdraw it at any time. The only consequence will be to prevent communication of your personal data to any third parties, specifically named individually from time to time in the relevant consent form when you provide your Data, so they may subsequently send you marketing communications. We wish to specify that this particular consent form is provided and is present only when specific initiatives are running. You can withdraw your consent to the communication of your Data by following the instructions in “Data Subject Rights" in this Privacy Policy.


The Personal Data will be made known to the Panini staff in charge of the development and management of the Website that are authorised to process them for the purpose of achieving the aforementioned purposes and who are committed to confidentiality or otherwise have received an appropriate legal obligation to confidentiality.

Personal Data will be disclosed to subjects who hold the role of system administrators: these are our employees or our data processors who are entrusted with the management of our IT systems and who therefore have the power to access, modify, suspend and limit the processing of your Personal Data. These subjects have been previously selected and appropriately trained.

Personal Data may be shared, used and transferred within the companies belonging to the same group as Panini for accounting and administrative purposes.

Personal Data will be made known to third parties, appointed as Data Processors, as they process Data on behalf of Panini (for example, companies responsible for managing and processing sales orders, suppliers with whom it is necessary to interact for the Service Provision such as hosting providers, platform providers for sending e-mails or, again, suppliers who perform technical maintenance activities including the maintenance of network equipment and electronic communications networks, suppliers who develop interactive games and competitions, software developers for the payment systems, suppliers providing the technological platform and payment gateway for orders for products in the e-payments area, payment service providers for e-payments activities).

Personal Data may be shared with third parties with whom Panini has ongoing contractual relationships concerning services functional to the performance of the activity (such as couriers for the delivery of products, audit firms, persons, companies or professional firms that provide assistance and advice on the subject, administrative, legal, tax, financial and credit recovery firms relating to the provision of the Services).

Where you have given consent to Data being shared for Communication purposes to third parties, data will be shared with the applicable third parties for whom consent has been given.

Finally, Personal Data will be communicated when requested to the competent taxation offices, or to other public bodies, according to the provisions of the laws in force.

Personal Data is not intended for publication or dissemination.

More information is available by writing to Panini at the following address:


Given the international presence of Panini group, some of your Personal Data may be shared with recipients, referred to in the previous paragraph, which could be found in countries outside the UK and the EU or the European Economic Area. Panini ensures that the processing of your Personal Data by these parties will be in compliance with applicable law. Therefore, the transfers will be made with adequate guarantees, such as adequacy decisions, models of Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.

More information is available by writing to Panini at the following address:


The Personal Data processed for the purpose of Service Provision and Contractual Obligations will be retained by Panini for such time as is necessary for the execution of the requested service and for the correct execution of the contractual relationship with you. As this Personal Data is processed to provide you with the Services and allow the execution of the contractual relationship, Panini may keep them for a longer period, in particular for what may be necessary in order to protect the interests of Panini against possible claims arising from the provision of the Services.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means. Personal Data related to contacts who have had financial transactions are kept for 10 years from the last transaction date owing to regulatory and tax requirements by competent authorities and to assess, defend or bring legal claims. Personal Data related to contacts without financial transactions but with dispatch history are kept for 3 years from the last dispatch date. Personal Data related to contacts without financial transactions or dispatch history are kept for 2 years from the last contact interaction date. After the end of the retention period, your Personal Data will be deleted or will be made anonymous.

Your requests, and the data contained in them, collected through the Contacts/Customer Service area of ​​the Website will be maintained for one year from the closure of the request in order to allow Panini to handle any additional requests received after closure. At the end of this period the Data that permit the identification, even indirect, of a physical person (such as name, surname, e-mail) will be made anonymous and will only be retained in the form of aggregated data, for statistical purposes.

The Personal Data processed for the purposes of Legal Compliance will be retained by Panini for the period necessary to comply with specific legal obligations or applicable legislation.

Personal Data processed for the purposes of Security will be kept by Panini for such period Panini considers necessary for the said purposes.

Panini retains, as part of the anti-fraud system adopted, the Personal Data processed in order to carry out the "Anti-fraud checks" for one year from collection; the data of unsuccessful and / or unauthorised transactions, included in the blacklist, are kept for 24 months. In any case, Panini reserves the right to keep such data for a further period of time, as may be required by legal proceedings or to communicate such Data to the competent authorities.

The Personal Data processed for the purposes of Marketing and Customising our Communications will be retained by Panini until the revocation of the consent you have given and reviewed periodically. Once your consent is withdrawn, Panini will no longer process your Personal Data for such purposes, but may retain them, particularly as may be necessary in order to protect Panini from legal action or other risks based on such processing (i.e. some of your identification data may be stored as necessary for Panini to be able to demonstrate the correct acquisition and / or revocation of your consent at a given time). Panini, from time to time, for the execution of "Marketing" and "Customising our Communications" purposes, may use the details of any order and purchase you have made in the previous 24 months.

Storage times of Personal Data processed for Communication to third parties are the same as those indicated above for authentication credentials. The reason behind this is that the information provided, following consent, consists only of the contact data provided when you created an account or profile on the Website. Nevertheless, it remains understood that if you revoke your consent, Panini will stop communicating that Data to third parties individually and specifically indicated in the relevant consent form.

The Personal Data processed for the purpose of Existing Customer Marketing will be kept by Panini until you object to the process through the link found at the bottom of each of the Existing Customer Marketing e-mails sent or until we consider that such Personal Data is no longer accurate or necessary.


As a Data subject, you are entitled to at any time:

  • request access to your Personal Data, (and/or a copy of such Personal Data), as well as further information on the current treatment of them;
  • request the correction or updating of your Personal Data processed by Panini, where they are incomplete or out of date;
  • request the deletion of your Personal Data from the Panini databases, where you deem the processing unnecessary or illegitimate;
  • request the limitation of the processing of your Personal Data by Panini, where you believe that your Personal Information is not correct, necessary or is unlawfully processed, or if you had opposed its processing;
  • exercise the right to data portability, i.e. to obtain a copy of the Personal Data supplied to Panini that relates to you in a structured format, for common use and readable by an automatic device, or to request transmission to another Data Controller;
  • oppose the processing of your Personal Data, using a legal basis relating to your particular situation, which you believe should prevent Panini from processing your Personal Data; with reference to exercising the right of opposition with respect to the purpose of "Anti-fraud controls" the same may not be given if Panini believes that there are compelling legitimate reasons for proceeding with the processing in any case;
  • to revoke your consent to certain cookies when using the website by clicking on the Settings button in the appropriate banner, always accessible by clicking on the following symbol  and/or (Manage Cookies) located in the footer of the website;
  • revoke your consent for purposes of Marketing, Customising our Communications and Communication to third parties and to oppose processing for the purpose of Existing Customers Marketing. Please remember that consent expressed by sending promotional communications for the purposes of Marketing and Customising our Communications extends not only to communications sent using automated systems without an operator (e.g. email), but also via traditional contact methods, e.g. postal services and telephone. You can always revoke your consent to processing, even separately, e.g. by deciding to receive communications only by post and not via automated systems such as email, or also by blocking the use of third party profiling cookies on Panini websites to stop receiving such communications.

Please note that the Personal Data you provided to Panini may be changed at any time by writing to: or through the "My Account" area of Here you may change some Personal Data including contact telephone number and delivery address, so long as it is within the same country. For changes to name, e-mail or destination country, customers are instructed to contact Customer Services.

We inform you that for the Marketing and Existing Customer Marketing purposes you can revoke and terminate at any time the sending of this commercial information, by writing to the e-mail address indicated above, in addition to using any unsubscribe options set out in the relevant e-mails.

In general, if the information provided by you is not sufficient to identify you with a sufficient degree of certainty, taking into account the specific type of right exercised (such as, in particular, your right to request access to your Personal Data, data portability and right to request the deletion of your Personal Data), Panini will request further information from you as required by specific regulatory provisions regarding the protection of personal data. In the event that Panini detects the absence or lack of suitable data to identify you and therefore there are reasonable doubts about your identity, Panini may then ask you to provide a copy of an identification document or any additional information deemed useful for your identification. In the event that you provide such a document, personal details such as your first and last name and your address should be clear in order to be able to identify you correctly, while any other information such as your photo or any other personal characteristics not necessary for identification should be removed or obscured before sending. We specify that our use of the information on your identity document is strictly limited to fully accounting for your request: in fact, such Data will be used only to verify your identity and will not be kept for longer than necessary for this purpose.

With reference to the treatments carried out by Panini for the purpose of Anti-fraud controls these can produce significant effects such as the possibility of allowing or denying the purchase of Panini products and / or services. These treatments, in particular those carried out through the anti-fraud system adopted, involve the use of technologies including artificial intelligence which determine the adoption of decisions based on automated processes. Therefore, Panini has adopted measures deemed appropriate to protect your rights, freedoms and legitimate interests, guaranteeing you the right to obtain human intervention at any time, to express your opinion and to obtain an explanation as timely as possible on the decision reached after the evaluation of the anti-fraud system. If the anti-fraud system prevents you from completing your order, you have the option to contact Panini by emailing report the problem and continue your purchase, where possible and with the help of a Panini operator. Further information on the logic used within the anti-fraud system can be requested via the contact details indicated at the beginning of the Privacy Policy.

You can also stop receiving Marketing to Existing Customers by using the appropriate link at the bottom of each email received (via the "Unsubscribe" button).

We inform you that for Marketing purposes you can revoke and terminate at any time the sending of this commercial information, by writing to the email address indicated above or, in the case of communications received through IT tools, following the procedure indicated at the bottom of the communication (via the "Unsubscribe" button).

Consent for the purpose of Customising our Communications can be revoked by changing, at any time, the preferences of the user profile that can be created on the Website or by writing to the email address to the email address

If, on the other hand, you are using the Website and intend to block the use of third party profiling cookies and therefore prevent, when for example using social networks, the display of communications (such as specific ads/posts/insertions regarding the Panini world) please refer "How to manage or delete cookies" section in the cookie policy.

You can revoke your consent for Communication to third parties– Panini at any time, by modifying your user profile preferences, which can be created on the Website or by writing to the email address: To stop receiving third-party marketing communications, to which you have already agreed, specified and identified individually each time, you must read the procedures in the specific Privacy Policy provided by the third party as that third party will be acting as a Data Controller in their own right.

Panini informs you that you always have the right to lodge a complaint with the competent Supervisory Authority (for example that of the country in which you have your habitual residence: in the UK, this is the Information Commissioner’s Office or “ICO”, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113, if you believe that the processing of your Personal Data is contrary to the legislation in the field of personal data protection currently applicable.


This Privacy Policy was last updated on 28 February 2024. Panini reserves the right to modify or update the content of this policy (in part or completely), for example where there are changes to the applicable legislation. Panini may not inform you of these changes as soon as they are introduced, but they will be applicable as soon as they are published on the Website. Panini invites you to visit this section regularly to review the most recent and updated version of the Privacy Policy in order to understand the Personal Data collected and the use that Panini makes of it.