Privacy Policy

1. Scope of This Policy

This Policy applies to personal information collected through the Website, through consultation requests, and in the course of delivering Services to clients. It does not apply to information provided by clients about third parties (such as travel companions or family members) that clients are separately responsible for handling in accordance with applicable law, nor to the practices of independent third-party vendors, which are governed by their own privacy policies.

Given the discretion required by our clientele, Nobilis applies elevated confidentiality standards to client information beyond what is legally required, as described throughout this Policy.

2. Information We Collect

Information You Provide Directly

• Contact details: name, email address, phone number, mailing address;
• Consultation and engagement information: area of interest, lifestyle preferences, family and household details, travel and itinerary information, dietary and health-related preferences relevant to service delivery;
• Payment and billing information, processed via secure third-party payment processors;
• Identity verification information as required for compliance with anti-money-laundering, know-your-customer, or similar obligations applicable to high-value transactions; and
• Any other information you choose to share with your Lifestyle Director in connection with your engagement.

Information Collected Automatically

• Device and usage data such as IP address, browser type, operating system, referring URLs, and pages visited;
• Approximate location derived from IP address; and
• Cookie and similar tracking data as described in Section 10.

Information From Third Parties

• Information from referral sources when a prospective client is introduced to Nobilis;
• Information from vendors and partners necessary to complete a specific booking or request you have authorized; and
• Publicly available information used for identity verification or due diligence consistent with our confidentiality and security obligations to existing clients.

Sensitive Information

In limited circumstances, and only with your consent or as necessary to deliver a specific requested service (for example, arranging medical travel or dietary accommodations), we may process sensitive categories of information such as health-related details. We limit the collection of such information to what is reasonably necessary and apply heightened safeguards to it.

3. How We Use Your Information

• Responding to consultation requests and evaluating prospective client engagements;
• Delivering, personalizing, and coordinating requested concierge and advisory services;
• Communicating with you regarding your engagement, bookings, and service updates;
• Processing payments and maintaining business and financial records;
• Verifying identity and conducting due diligence as required by law or sound business practice;
• Maintaining, securing, and improving the Website;
• Complying with applicable legal, tax, and regulatory obligations; and
• Protecting the rights, safety, and property of Nobilis, our clients, and third parties.

4. Legal Bases for Processing

For clients and website visitors located in the European Economic Area, the United Kingdom, or other jurisdictions with similar requirements, we process personal information on the following legal bases: performance of a contract with you, our legitimate interests in operating and improving our business (provided those interests are not overridden by your rights), compliance with a legal obligation, and, where applicable, your consent.

5. How We Share Your Information

Nobilis does not sell personal information for monetary consideration. We may share information in the following circumstances:

• Vetted vendors and partners (e.g., aviation operators, hospitality providers, event organizers, real estate brokers, medical and wellness providers) engaged solely to fulfill a specific request you have authorized, limited to what is necessary for that purpose;
• Service providers who support our operations, such as payment processors, IT and data hosting providers, and professional advisors, under confidentiality obligations;
• Legal and safety purposes, where disclosure is required by law, court order, or governmental request, or necessary to protect the rights, property, or safety of Nobilis, our clients, or others; and
• Business transfers, in connection with a merger, acquisition, financing, or sale of business assets, subject to confidentiality protections.

6. International Data Transfers

Given our operations across multiple countries, information may be transferred to, stored, and processed in jurisdictions other than your country of residence, including the United States. Where required, we implement appropriate safeguards for such transfers, such as standard contractual clauses or equivalent mechanisms recognized under applicable data protection law.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including for the duration of a client engagement and thereafter as needed to comply with legal, accounting, tax, or record-keeping obligations, resolve disputes, and enforce our agreements. Website inquiry data from prospective clients who do not proceed with an engagement is retained for a limited period and then securely deleted or anonymized.

8. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction, including encryption in transit, access controls limiting information to personnel on a need-to-know basis, and confidentiality agreements with staff and vendors. No method of transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

9. Your Privacy Rights

General Rights

Depending on your jurisdiction, you may have the right to request access to, correction of, deletion of, or a copy of your personal information, and to object to or restrict certain processing. To exercise these rights, contact us using the details in Section 16. We will respond within the timeframe required by applicable law.

California Residents (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect, use, and disclose; to request deletion or correction of your personal information; to opt out of the "sale" or "sharing" of personal information (Nobilis does not sell or share personal information as those terms are defined under California law); to limit the use of sensitive personal information; and to not receive discriminatory treatment for exercising these rights.

European, UK & Other International Residents

If you are located in the EEA, UK, or a jurisdiction with similar data protection laws, you have the right to access, rectify, or erase your personal information, restrict or object to processing, request data portability, and lodge a complaint with your local data protection supervisory authority.

10. Cookies & Tracking Technologies

The Website may use cookies and similar technologies to enable core functionality, remember preferences, and understand aggregate usage patterns. You can manage or disable cookies through your browser settings; disabling certain cookies may affect Website functionality.

11. Marketing Communications

With your consent where required, we may send you communications about Nobilis services, curated experiences, or events. You may opt out of marketing communications at any time by using the unsubscribe mechanism provided or by contacting us directly; this will not affect transactional communications related to an active engagement.

12. Children's Privacy

Our Website and Services are intended for adults and are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will take steps to delete it.

13. Third-Party Links

The Website may contain links to third-party websites or services. This Policy does not apply to those third parties, and we encourage you to review their respective privacy policies before providing any information to them.

14. Data Breach Notification

In the event of a security incident affecting your personal information, we will notify affected individuals and relevant authorities as required by applicable law, without undue delay.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be indicated by updating the "Last updated" date above, and, where appropriate, through additional notice to clients.

16. Contact Us

Questions, requests, or concerns regarding this Privacy Policy or our handling of your personal information may be directed to:

Nobilis LLC
Attn: Privacy Officer
Moncks Corner, SC, USA
Email: support@nobilisusa.com
Phone: (843) 270-6883