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Privacy Policy
Last updated: March 2026
This Privacy Policy describes how Nexara Digital Ventures Ltd (“we,” “us,” or “our”), trading as Real Passione, collects, uses, and protects your personal data when you visit realpassione.com or make a purchase from us. By using our website, you agree to this Privacy Policy.
1. Data Controller Information
| Trading Name | Real Passione |
| Legal Entity | Nexara Digital Ventures Ltd |
| Company Number | 16899230 |
| Jurisdiction | England and Wales (incorporated 9 December 2025) |
| Registered Address | 4 Raven Road, Unit 1C3-987, London, E18 1HB, United Kingdom |
| Director | Ugur Saygı |
| privacy@realpassione.com | |
| Website | realpassione.com |
2. Information We Collect
Information you provide directly:
- Name, email address, billing address, shipping address
- Phone number (optional, for delivery notifications)
- Payment reference information (for bank transfer orders)
- Account username and password (if you register an account)
- Communications: contact form submissions, review content, support emails
Information collected automatically:
- IP address and approximate location (country/city level only)
- Browser type, device type, operating system
- Pages visited, time spent on site, referring URL
- Cookies and similar tracking technologies (see Section 5)
3. How We Use Your Information
- Order processing: To process, fulfill, ship, and manage your orders
- Customer service: To respond to inquiries, process returns, and resolve complaints
- Account management: To maintain your customer account and order history
- Marketing: To send promotional emails — only with your explicit consent, which you may withdraw at any time
- Analytics: To understand how our website is used and improve your experience
- Legal compliance: To meet our obligations under UK and EU law
- Fraud prevention: To detect and prevent fraudulent transactions
4. Legal Basis for Processing (UK GDPR / EU GDPR)
- Contract performance (Article 6(1)(b)): Processing your order, managing your account
- Legitimate interests (Article 6(1)(f)): Fraud prevention, site security, analytics
- Consent (Article 6(1)(a)): Marketing emails, analytics/marketing cookies — withdraw anytime
- Legal obligation (Article 6(1)(c)): Tax records, Companies House compliance
5. Cookies
We use the following categories of cookies. You can manage your preferences via the Cookie Preferences panel at the bottom of this page.
| Category | Purpose | Consent Required |
|---|---|---|
| Necessary | Shopping cart, session management, login, security | No (essential) |
| Analytics | Google Analytics — measures traffic and usage patterns | Yes |
| Marketing | Meta Pixel, Pinterest Tag — advertising and retargeting | Yes |
| Preferences | Currency, language, wishlist preferences | Yes |
6. Third-Party Data Processors
We share your data only with trusted processors necessary to run our business:
| Processor | Purpose | Location |
|---|---|---|
| Hostinger | Web hosting | EU (Lithuania) |
| Automattic (WooCommerce) | E-commerce platform | USA (SCCs) |
| Google Analytics 4 | Website analytics | USA (SCCs) |
| Meta Platforms | Advertising analytics | USA (SCCs) |
| Klaviyo / Mailchimp | Email marketing | USA (SCCs) |
| Shipping carrier | Order delivery | Varies |
We never sell your personal data to third parties.
7. International Data Transfers
Nexara Digital Ventures Ltd is registered in England and Wales. Some of our processors are located outside the UK/EEA. All such transfers are governed by Standard Contractual Clauses (SCCs) approved by the Information Commissioner’s Office (ICO) and the European Commission, or other equivalent transfer safeguards.
8. Data Retention
- Order data: 7 years (UK tax law requirements)
- Account data: Until account deletion is requested
- Email marketing lists: Until you unsubscribe
- Analytics data: 26 months (Google Analytics default)
- Cookie consent records: 1 year
9. Your Rights
Under the UK GDPR and EU GDPR, you have the following rights:
- Access: Request a copy of your personal data we hold
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data (“right to be forgotten”)
- Restriction: Request that we limit processing of your data
- Portability: Receive your data in a machine-readable format
- Objection: Object to processing based on legitimate interests or direct marketing
- Withdraw consent: For any consent-based processing, at any time
To exercise any right, email privacy@realpassione.com. We respond within 30 days. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO): ico.org.uk
10. Security
We implement appropriate technical and organisational measures including SSL/TLS encryption, access controls, and regular security monitoring. No transmission over the internet is 100% secure; while we use commercially reasonable means to protect your data, we cannot guarantee absolute security.
11. Children’s Privacy
Our website is not directed to persons under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data to us, please contact us immediately for deletion.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by email or via a prominent notice on the website at least 7 days before the changes take effect. The “Last updated” date at the top of this page indicates when this policy was last revised.
13. Contact
Nexara Digital Ventures Ltd (trading as Real Passione)
Company No: 16899230 | Registered in England and Wales
4 Raven Road, Unit 1C3-987, London, E18 1HB, United Kingdom
Email: privacy@realpassione.com
Website: realpassione.com