1. Introduction
1.1 In this policy, ‘we’, ‘us’ and ‘our’ refer to ‘Nardo Capital Holding Limited’ that is the owner of the website. The term ‘you’ and ‘your’ refers to the user or viewer of our website (see Section 18).
1.2 We are highly committed to safeguarding the privacy of our website visitors and users.
1.3 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and users.
1.4 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.5 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing information and any other communication which we may decide to send to you from time to time, and limit the publication and/or of your details.
2. How we use your personal data
2.1 In this Section we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website (‘usage data’). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, language used, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source(s) of the usage data is third party providers Google Analytics and Hotjar. This usage data may be processed for the purposes of improving the pages of the website and/or analysing the use of the website. The legal basis for this processing is consent or our legitimate interests, namely monitoring and continuously enhancing our website and business services.
(a) Read the Hotjar Privacy Policy: https://www.hotjar.com/legal/policies/privacy(b) Read the Google Analytics Privacy Policy: https://support.google.com/analytics/answer/6004245?hl=en
2.3 We may process information contained in any enquiry form you submit to us regarding goods and/or services (‘enquiry data’). Enquiry data may include full name, date of birth, language, country of origin and/or employment, work position, qualifications, company name, phone numbers, email address and postal address. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you at any time. Enquiry data is encrypted upon submission, delivered to us by email. The legal basis for this processing is consent.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications for ongoing communication purposes and/or newsletters (‘notification data’). The notification data may be processed for the purposes of sending you the relevant notifications, replies and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5 We may process information contained in or relating to any communication that you send to us (‘correspondence data’). The correspondence data may include the communication content and metadata associated with any type of communication. Our website will generate the metadata associated with communication made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and timely communication with users.
2.6 We may process information including your preferences in receiving marketing from us and your communication preferences (‘marketing and communications data’).
2.7 Marketing – We may use your enquiry, notification, usage, marketing and communication data to form a view on what we think you may want, requiry or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. We only use the data you provide to us directly for this purpose along with the Aggregated Data provided to us by our analytics partners (such as Google Analytics) and we do not track what other websites you may visit after visiting our site, though in common with most websites, we may register the site which referred you to our site (known as a search engine).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We only send electronic marketing – such as email marketing (automated or bespoke) – to people who have requested to receive email marketing and other company communication updates. We use MailChimp to manage our newsletter and other email lists. There is no third-party tracking in messages we send through MailChimp besides MailChimp’s own analytics, which may aggregate how many subscribers open a message or click the links inside. MailChimp’s privacy policy is available for you to read at http://mailchimp.com/legal/. You can unsubscribe (ie, opt-out) from our newsletter by clicking on the unsubscribe link provided at the end of our newsletters. You can also email info@luciano-nardo.com to update or unsubscribe your email address, or to request that we delete your email from our database.
What we will do with your email address: It will be shared with “MailChimp”, since we use their email service, we will send you emails about updates for our offers and event updates.
We will not share your personal information with or sell it to any other third-party unless we have your permission or the law requires us to do so.
We may share certain data with third-party social media platforms in order to show you targeted ads when you visit them. We do this by the use of cookies which capture your visits to our website. Please refer to our Cookies Policy for more information.
We may provide third-party social media platforms with your email address to create ‘audiences’ of users fitting within a certain demographic/category so that we can target our marketing.
This is in our legitimate interests of sending you direct marketing.
2.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others at any time.
2.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject to, or in order to protect your vital interests or the vital interests of another natural person.
2.11 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Automated decision-making
3.1 Not applicable.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 We will not disclose your personal data to any other third party unless we have received your permission.
4.3 In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 We may transfer your personal data outside the European Economic Area (EEA) for purposes strictly related to our business or any of its services and/or scopes.
5.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data where appropriate.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Usage data will be retained indefinitely for the purpose of monitoring the historical performance of our website, however personal data beyond the ISP will not be linked to this data.
(b) Enquiry data will be deleted at any time on request, after which it will be deleted unless required for monitoring, auditing or legal reasons.
(c) Marketing and communication data will be deleted at any time on request or retained indefinitely.
(d) Notification data will be deleted at any time on request or retained indefinitely following your subscription to this service.
(3) Correspondence data will be deleted at any time on request, after which it will be deleted from our systems unless required for monitoring, auditing or legal reasons.
6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the period we need to access the data for the provision of services, receiving payment, resolving insurance or other issues or any other monitoring, auditing or legal reasons.
6.5 Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store all your personal data on secure and cloud-based servers, and will be accessible to our staff via computers and/or mobile devices.
7.4 Data relating to your enquiries and/or financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using available encryption technology.
7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 It is your responsibility to check this page to ensure you are happy with any changes to this policy.
8.3 We may at times notify you of changes to this policy by email.
9. Your rights
9.1 In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data whenever requested by you. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can ask for your personal data by email to info@luciano-nardo.com
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party related or not to us. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.13 You may exercise any of your rights in relation to your personal data by written notice to us or by email to info@luciano-nardo.com
10. Third party websites
10.1 Our website may include hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 16.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. Acting as a data processor
13.1 In respect of certain client data, we do not act as a data controller; instead, we act as a data processor.
13.2 It is the requirement of the performance of our services to our clients to access client data stored within their website or marketing databases. None of this data is downloaded or stored and it does not leave the secure platform on which it is stored.
13.2 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the agreement between us and the relevant data controller, if applicable.
14. About cookies
14.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
14.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session, when the web browser is closed.
14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
15. Cookies used by us and our service providers
15.1 We use cookies for the following purposes:
| Cookie | Type | Duration | Description |
|---|---|---|---|
| _ga | 2 years | The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. | |
| _ga_MP7BECKKFK | 2 years | This cookie is installed by Google Analytics. | |
| _gat_gtag_UA_211817551_1 | 1 minute | Set by Google to distinguish users. | |
| _gid | 1 day | Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously. | |
| cookielawinfo-checkbox-advertisement | 1 year | Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the "Advertisement" category . | |
| cookielawinfo-checkbox-analytics | 1 year | Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the "Analytics" category . | |
| cookielawinfo-checkbox-functional | 1 year | The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". | |
| cookielawinfo-checkbox-necessary | 1 year | Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the "Necessary" category . | |
| cookielawinfo-checkbox-others | 1 year | Set by the GDPR Cookie Consent plugin, this cookie is used to store the user consent for cookies in the category "Others". | |
| cookielawinfo-checkbox-performance | 1 year | Set by the GDPR Cookie Consent plugin, this cookie is used to store the user consent for cookies in the category "Performance". | |
| wp-wpml_current_language | session | No description available. |
16. Managing cookies
16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via the following links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
16.2 Blocking all cookies will have a negative impact upon the usability of some or many websites.
16.3 If you block cookies, you will not be able to use all the features on our website.
17. Cookie preferences
17.1 You can manage your preferences relating to the use of cookies on our website by visiting: Cookie Settings
18. Our details
18.1 This website is owned and operated by Nardo Capital Holding Limited.
18.2 We are registered in England and Wales under registration number 07396764, and our registered office is at Riverside House, Kings Reach Business Park, Yew Street, Stockport, SK4 2HD, United Kingdom.
18.2 Our principal place of business is online.
18.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using info@luciano-nardo.com
19. Glossary
19.1 Legal Basis
(a) Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
(b) Performance of Agreement means processing your data where it is necessary for the performance of an agreement to which you are a party or to take steps at your request before entering into such an agreement.
19.2 Third Parties
(a) External Third Parties
IT Service Providers – we may disclose your data to service providers acting as processors who provide IT and system administration services.
Email service providers – in order to send you marketing content we share your details with our email service providers.
Social Media Platforms – we may share certain data with social media platforms in order to advertise and market our services to you through other platforms on the internet (e.g. Facebook, Instagram, Twitter, LinkedIn).
Analytics tools – we use analytics tools to track the way that users interact with our website.
Marketing and insights providers – marketing and insights tools allow us to understand our customers better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our customers to facilitate this process.
Customer service platforms – when you interact with our customer service team, your details are shared with our customer service platform providers.
