Privacy is part of the service.

Who we are and the scope of this policy

Naples Lifestyle Management, referred to in this policy as “NLM,” “we,” “us” or “our,” is a private client services company based in Naples, Florida. We provide personal and executive support, household and property coordination, family and lifestyle management, advisor and vendor coordination, project and transition support, selected business support and Safekept™ private continuity services.

Depending on the circumstances and applicable law, NLM may act as a business, controller or organization responsible for deciding why and how personal information is processed. In some situations, we may process information on a client’s instructions or coordinate information held by another professional or service provider.

This policy applies to information collected through this website, enquiries, communications, consultations, client onboarding, service delivery and ordinary business administration. A written engagement, confidentiality agreement, data processing agreement or Safekept™ agreement may provide additional terms for a particular relationship. Where those terms provide stronger protections, they will apply to that engagement.

Information we collect

The categories below describe information we may collect. We do not necessarily collect every category from every person.

Information we do not seek through the public website

• Passwords, PINs, security answers, alarm codes or access credentials.
• Full bank, investment, credit card or financial account numbers.
• Passport, driver’s licence, Social Security or other identity documents.
• Detailed medical records, diagnoses or treatment information.
• Tax returns, estate documents or complete financial statements.

If such information becomes genuinely necessary after an engagement begins, the purpose, access, storage and appropriate transfer method will be considered separately.

Sources of personal information

We may obtain information from the following sources:

• Directly from you through forms, email, telephone calls, meetings and other communications.
• From a client who asks us to coordinate with or on behalf of a family member, employee, advisor, vendor or other authorized person.
• From authorized representatives, family offices, attorneys, accountants, financial advisors, property managers, household staff and other professionals.
• From vendors, contractors and service providers involved in an agreed responsibility or project.
• From public records, professional directories, websites and other publicly available sources where appropriate.
• Automatically from website hosting, security, analytics and similar technologies.

If you provide personal information about another person, you should have appropriate authority to do so and should tell them that their information may be shared with NLM for the relevant purpose.

How we use personal information

We may use personal information for the following purposes:

Marketing communications

We may send service-related communications that are necessary to respond to an enquiry or manage a client relationship. Promotional communications will be sent only where requested, consented to or otherwise permitted by applicable law. You may ask us to stop promotional communications at any time. We may retain a minimal suppression record so that the preference can be respected.

Automated decision-making

We do not use personal information to make solely automated decisions that produce legal or similarly significant effects. Decisions about prospective and existing client relationships are made by people.

Legal bases where data protection law requires them

Some privacy laws require an organization to identify a lawful basis for processing. Where those laws apply, we may rely on one or more of the following:

• Steps before a contract: responding to an enquiry, discussing a possible engagement and preparing a proposal.
• Performance of a contract: providing agreed private client services and administering the relationship.
• Legitimate interests: operating and protecting the business, communicating with relevant people, improving services, keeping appropriate records and establishing or defending legal rights, provided those interests are not overridden by individual rights.
• Consent: where you have made a clear voluntary choice, including certain optional communications or uses of sensitive information.
• Legal obligation: meeting tax, accounting, court, regulatory, reporting or other requirements.
• Vital interests: in limited circumstances where processing is necessary to protect a person’s life or physical safety and another basis is unavailable.

Where consent is the basis, it may be withdrawn at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Sensitive information and Safekept™

Certain services may involve information that is confidential, sensitive or capable of causing harm if misused. Examples may include family circumstances, health-related logistics, household access arrangements, asset or insurance information, trusted contacts, emergency instructions and the location of important records.

Safekept™ is designed to help individuals and families organize critical information, trusted relationships and practical instructions for emergencies, incapacity or significant life transitions. A Safekept™ engagement may therefore require additional decisions about what information should be included, who may access it, how it should be stored and when it should be reviewed, returned or deleted.

How sensitive information may be handled

• Collection is limited to information reasonably needed for the agreed purpose.
• Access is restricted to authorized people with a legitimate role.
• Transfer methods are considered according to the sensitivity of the information.
• Instructions and permissions are documented where appropriate.
• Information may be separated, redacted or referenced rather than duplicated where that reduces risk.
• Retention, return and deletion requirements may be agreed specifically for the engagement.

How and why information may be disclosed

We do not sell personal information. We do not share personal information for cross-context behavioural advertising. We may disclose information in the circumstances described below, using only what is reasonably appropriate to the purpose.

Authorized people involved in the service

Information may be shared with family members, representatives, household staff, property managers, attorneys, accountants, financial advisors, insurance professionals, medical offices, contractors, vendors and other people when the client has authorized the coordination or the disclosure is reasonably necessary for the agreed responsibility.

Business and technology service providers

We may use providers for website hosting, content delivery and security, email delivery, communications, document storage, accounting, invoicing, scheduling, analytics, administration and other essential business functions. Providers receive only the information reasonably needed for their role and are expected to protect it under contract, law or professional obligations.

Professional advisors and insurers

We may disclose information to our attorneys, accountants, insurers, auditors and other professional advisors where needed for advice, risk management, claims, compliance or protection of legal rights.

Legal requirements, safety and protection

Information may be disclosed when we reasonably believe disclosure is required by law, court order or lawful government request, or is necessary to protect rights, property, systems, clients, service providers or the safety of a person.

Business reorganization

If NLM is involved in a merger, acquisition, financing, sale of assets, reorganization or similar transaction, information may be disclosed to appropriate parties subject to confidentiality and used consistently with this policy unless notice is provided otherwise.

Cookies, server logs and website technology

The website may use cookies and similar technology to function, maintain security, remember preferences and understand performance. The technologies actually used may change as the website and its providers are updated.

Strictly necessary technology

These technologies support functions such as page delivery, security, fraud and spam prevention, load balancing, session management and form submission. Disabling them may prevent parts of the website from working properly.

Analytics and performance technology

If analytics is enabled, it may collect information about pages viewed, approximate location derived from an IP address, device and browser characteristics, referral source and interactions with the site. Where consent is required, non-essential analytics should be used only after the appropriate choice has been made.

Embedded or third-party content

If the website later includes maps, videos, scheduling tools, social content or other embedded services, those providers may collect information under their own policies. We will update this policy or provide additional notice where appropriate.

Browser controls and privacy signals

Most browsers allow cookies to be blocked or deleted. Because we do not sell personal information or use it for cross-context behavioural advertising, recognized opt-out signals such as Global Privacy Control generally do not change those practices. Where applicable law requires a signal to be honored for another activity, we will process it as required.

How long information is retained

We retain personal information only for as long as reasonably needed for the purposes described in this policy, including service delivery, continuity, legal obligations, accounting, dispute resolution and protection of rights. The periods below are general guides rather than guarantees for every record.

Information may be retained longer where required by law, subject to a legal hold, needed for a dispute, necessary to protect a person or system, or contained in secure backups that are not immediately capable of selective deletion. When information is no longer required, it will be deleted, anonymized or securely disposed of as appropriate.

How we protect personal information

We use administrative, technical and physical safeguards intended to be proportionate to the nature of the information and the risks involved. No website, email system, storage provider or transmission method can be guaranteed completely secure.

• Limiting collection and avoiding unnecessary duplication of sensitive information.
• Restricting access according to role and legitimate need.
• Using authentication, access controls and secure configuration where available.
• Using reputable hosting, security, communication and storage providers.
• Maintaining website security, spam prevention, updates, backups and monitoring.
• Considering appropriate transfer methods before sensitive information is exchanged.
• Reviewing, returning, deleting or anonymizing information when it is no longer needed.
• Maintaining procedures for responding to suspected loss, misuse or unauthorized access.

Security incidents

If we become aware of an incident affecting personal information, we will assess the nature and likely consequences, take reasonable containment and remediation steps, and provide notifications where required by applicable law or contract.

Your privacy rights and choices

Privacy rights vary according to where you live, the nature of the relationship and whether a particular law applies to NLM or the processing. Subject to applicable law, you may have some or all of the following rights:

Complaints

Please contact us first so that we can try to resolve the concern. Depending on your location and applicable law, you may also have the right to complain to a state attorney general, data protection authority or other privacy regulator. UK or European visitors may have the right to complain to the supervisory authority in their country.

International visitors and cross-border processing

NLM is based in the United States. If you contact us or receive services from outside the United States, your information may be processed in the United States and other countries where our service providers operate. Privacy laws in those countries may differ from the laws where you live.

Where applicable law requires safeguards for an international transfer, we will use an appropriate legal mechanism or take other required steps. These may include contractual protections, transfer assessments, provider certifications or reliance on a permitted derogation for a particular transaction.

Children’s information

This website and our services are not directed to children under 13, and children should not submit personal information through the website. We do not knowingly collect personal information online directly from children under 13 without appropriate parental authorization.

A client engagement may involve information about children when it is reasonably necessary for family scheduling, travel, household coordination, emergency planning or another agreed service. In those situations, the information should be provided by or with the authority of a parent, guardian or other authorized adult and used only for the relevant purpose.

Third-party websites and services

The website may link to other websites, professional providers, social platforms, maps, scheduling services or other third-party resources. A link does not mean that NLM controls or endorses the third party’s privacy practices.

Information you provide directly to a third party is governed by that party’s privacy notice and terms. You should review those materials before providing personal or confidential information.

Changes to this privacy policy

We may update this policy when our services, technology, providers, legal obligations or privacy practices change. The current version will be published on this page with an updated date.

If a change materially affects how personal information already collected is used, we will provide additional notice or obtain consent where applicable law requires it. We encourage visitors and clients to review the policy periodically.

Contact us about privacy

Questions, concerns and privacy rights requests may be submitted to Naples Lifestyle Management through the contact page or by using the protected email link below.

Please write “Privacy Request” in the subject line and describe the request clearly. Do not include passwords, access credentials, complete account numbers or unnecessary identity documents.