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Privacy Policy

We take the privacy of our users very seriously. We ask that you review this Privacy Policy carefully, as it contains important information about how we use your personal data. 

1 Who are we?

We are Nero Escorts Ltd, aka “Nero Escorts”. We operate the Nero Escorts website. Nero Escorts is a Limited Company registered in England and Wales under the name “Nero Escorts Ltd” with company number XXXXXXXX and with its registered office at 143 Burneside Road, Kendal, LA9 6EB. 

2 Our commitment to privacy

At Nero Escorts, we truly appreciate the trust you place in us when subscribing to our website, or arranging to spend time with any of our models. We take your privacy seriously and aim to always store and process your personal information securely, and for limited purposes. At Nero Escorts, we will never disclose your personal information except with your consent, or where we are required to by law. We will never sell your personal information. 

3 What data do we collect?

In order to provide our services to you and to allow you to browse our site and arrange to meet our models, it may be necessary for us to collect some of your personal information. 

If you browse our website as a guest, we may collect some or all of the following information about you: 

  • Information about your device and how you use our website 
  • Your IP address 

If you choose to subscribe to our site and become a member, we may collect the information described above, plus some or all of the following information: 

  • Your full name 
  • Your email address 
  • Your password (only in encrypted form) 
  • Your payment information 
  • Your payment and subscription history 

In addition to the above, if you are a model who wishes to advertise using our platform, we may collect some additional information including: 

  • Your phone number 
  • Your date of birth 
  • Copies of official Proof of Identity documents 
  • Media you upload to our website 

4 How do we use your data?

4.1 Information about your device and how you use our website

We collect information about your device and how you use our website. This may take the form of our own server logs, or information collected by Google Analytics when you load our website. This allows us to continue to develop our business strategy, and to predict and protect against potential attacks which may cause disruption to our website or services. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – this –information forms part of our business strategy planning and helps us maintain a secure site for our visitors and subscribers. 

4.2 Your IP address

If you access our site, we will collect the IP address of the device you are using. We need to do this to predict and protect against potential attacks which may cause disruption to our service. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – this information forms part of our business strategy planning and helps us maintain a secure site for our visitors and subscribers. 

4.3 Your full name

We will use your full name internally to process payments you make when becoming a member of our website. For models, we will use your full name as part of our process to verify your age and identity. 

We will never display your full name publicly on the Nero Escorts site. 

Legal Basis: GDPR Art. 6(1)(b) – “Performance of contract” – We collect your name as part of the payment process when you become a member of our website. 

Legal Basis: GDPR Art. 6(1)(c) – “Legal obligation” – We have an obligation to ensure that models advertising their services using our website are of legal age. 

4.4 Your email address

We will use your email address to communicate with you about your account, to send you optional updates about our services, and to update you with information about bookings and paid memberships associated with your account. 

We also require your email address to be able to send you updates about this Privacy Policy. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – Being able to communicate with you about your bookings and your account is vital to our business function. 

4.5 Your password

We will store your password on our servers in an encrypted format. We use passwords to make sure visitors are only able to access their own personal account. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – It is critical to our commitment to protect our customers to ensure that accounts and account information is accessible only to the customers themselves. 

4.6 Your payment information

We may store some information related to payments and to your prior transactions on our site. This is important to fulfil your payments, and to help combat fraud. 

Legal Basis: GDPR Art. 6(1)(b) – “Performance of contract” – It is necessary for us to keep records of the payments our third-party processor has processed on your behalf, so that we can ensure that subscriptions to our site are processed properly and attached to the right user accounts. 

Legal Basis: GDPR Art. 6(1)(c) – “Legal obligation” – For the purposes of taxation and appropriate records management, it is important that we retain information of any transactions made through our website. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – In order to perform our business functions and to ensure proper reporting and auditing, it is important for us to maintain records of payment transactions. 

4.7 Your payment and subscription history

In order to assist with customer services, and to monitor for potential fraud, we maintain records of the transactions and type of transaction each member account makes when using our website. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – In order to assist with customer service and protect against fraud, we must retain a history of payments and subscriptions for each account. 

4.8 Your phone number

If you use our website as a model, we will store your phone number. This will be used if we need to contact you, and will be used to notify you about client bookings. 

Legal Basis: GDPR Art. 6(1)(b) – “Performance of contract” – In order to provide our services to you as a model, your phone number is required to facilitate communication with you. 

4.9 Your date of birth

If you use our website as a model, we will store your date of birth as shown on your identity documents. This is to validate that you are above the age of eighteen, which is a requirement to advertise through our website. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – In order to ensure that we do not inadvertently facilitate the advertising of services for anyone under the age of eighteen, we must store and process your date of birth. 

4.10 Copies of official Proof of Identity documents

If you use our website as a model, we will store copies of the Proof of Identity documents you provide. This may include, but is not limited to, passports, driving licenses, or national identity cards. 

Legal Basis: GDPR Art. 6(1)(f) – “Legitimate interests” – In order to ensure that we do not inadvertently facilitate the advertising of services for anyone under the age of eighteen, we must store and keep records of your Proof of Identity documents. 

4.11 Media you upload to our website

As a model, you are given the ability to upload media, such as images and video to our website for advertising purposes. We are required to store and process this media in order to display it as part of your modeling profile on our website. In your account, you will be able to choose which media is displayed publicly, and which media is displayed only to logged-in members of our website. 

It is your responsibility to ensure that media you upload cannot be used to directly identify you if you do not wish to be identified by it. Media which may identify you is your own responsibility. If you wish for us to remove any media you have uploaded, please contact us using the contact details provided in this Privacy Policy. 

We update and reorganize the content on our website frequently, however we will never post any material or information you have submitted without your consent. 

Legal Basis: GDPR Art. 6(1)(a) – “Consent” – when you upload your media, you provide us with consent and a worldwide license to publish the media as part of our website. We need this because our website is accessible from anywhere in the world. 

5 Third parties we may share your data with

Operating a modern web platform like ours requires us to rely on a number of third parties to keep our website running safely, smoothly, and securely. We take your privacy seriously and only share your data with trusted third parties with the goal of providing our services to you. We will never sell your personal information. 

5.1 Google Analytics

We make use of Google Analytics on our site to collect metrics about our visitors for technical capacity and business strategy planning. 

You can opt out of data processing by Google Analytics by enabling Google’s “Google Analytics Opt-out Browser Add-on” on your device. 

The privacy policy for Google Analytics can be found here

 

6 How long will we keep your data?

We hold on to the information we collect about you, detailed above, for as long as you have your account with us, or for as long as is required for us to be able to provide the services to you, or (in the case of any contact you have with customer support) for as long as is necessary to provide internal support-related performance reporting or trend analysis. 

If you apply to be a model with Nero Escorts Ltd and your application is unsuccessful, we will permanently delete your submitted information. 

We will keep data for longer periods if reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or to enforce our Terms and Conditions. 

7 Your rights

You have a number of relevant rights in respect of our processing of your personal data. The relevant rights are: 

  • You may request access to your personal data, and information about how and why we process it. You can read more about this right here
  • You may request us to rectify information about you which you think is inaccurate. You can read more about this right here
  • In some circumstances, you may request that we delete your personal information. You can read more about this right here
  • You may have the right to object to our processing of your data if we are doing so as part of our legitimate interests. You can read more about this right here

For more general information about your rights as a data subject, please see the Information Commissioner’s Office’s “Your Data Matters” project. 

If you wish to exercise any of these rights, please contact us at info@neroescorts.com

You also have the right to lodge a complaint about our processing with a supervisory authority. In the United Kingdom, this authority is the Information Commissioner’s Office

8 Updates to this document

We regularly review and may, where necessary, update this Privacy Policy from time to time. 

If we plan to use your personal data for a new purpose, we will update this information and communicate any changes to you before starting any new processing. 

We will communicate any updates to this notice prominently on our website. 5

9 Questions about privacy?

If you have questions about privacy or any of the contents of this notice, please don’t hesitate to get in touch with us! 

You can email us at info@neroescorts.com, or write to us at: 143 Burneside Road, Kendal, LA9 6EB.