Privacy Policy

Only in Naples 239 (“Only in Naples 239,” “we,” “us,” or “our”) is a local marketing agency and social media platform based in Naples, Florida, serving businesses throughout Southwest Florida. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit our website at only239.com, submit one of our forms, subscribe to our newsletter, or engage our services.

This policy covers information we handle as the party that decides how and why it is used (a “controller”). When we handle information on behalf of a client as part of our services, different rules apply — see Section 3. By using our website or services, you agree to the practices described in this policy.

We collect information in the following ways:

Information you provide directly

• Free Growth Audit form: your name, business name, email address, phone number, website URL (optional), and service area.
• Strategy Call form:your name, business name, email address, phone number, and the service you’re interested in.
• Contact requests: the details you include when you reach out to us through any form on our site.
• Newsletter sign-up: your email address, so we can send you the Naples Morning Briefing and related updates.
• Client onboarding:if you become a client, the information needed to deliver your services — which may include billing details and authorized access to your social media, advertising, and analytics accounts.
• Direct communications: any information you include when you call, email, message us on social media, or work with us as a client.

Information collected automatically

• Usage and device data: pages visited, referring pages, browser and device type, IP address, approximate location, and similar analytics data, collected through cookies and similar technologies (see Section 6).
• Video playback data: when videos hosted through our provider load or play, limited technical data may be processed to deliver that content.

Information from third parties

• Social media and advertising platforms (such as Meta/Instagram and Google), analytics providers, and publicly available sources, where permitted by their terms and applicable law.

We do not intentionally collect sensitive categories of personal information (such as health, precise geolocation, or government IDs) through our website.

We provide a short notice of what we collect and why at the point you provide it (for example, on our forms), and this policy gives the fuller picture.

When we deliver marketing services, we may process personal information that relates to our clients’ own customers, audiences, followers, or leads — for example, audience and engagement data inside advertising and social platforms, or contacts inside an email tool (“Client Data”).

For Client Data, our client is the party responsible for the information (the “controller” or “business”), and we act as a service provider that processes it only on the client’s instructions and to provide the agreed services. Our handling of Client Data is governed by our Service Agreement with that client (and a data processing addendum where one applies), not by this Privacy Policy. If your personal information was given to a business that uses us, please direct privacy requests to that business; we will support them in responding.

We use the information we collect to:

• Respond to audit requests, strategy-call requests, and other inquiries.
• Deliver, manage, personalize, and improve our marketing services for clients.
• Add you to our business newsletter and email list when you submit one of our forms (such as the Free Growth Audit, Strategy Call, or contact forms) or otherwise sign up, and send you the Naples Morning Briefing and related marketing communications. You can unsubscribe at any time.
• Understand how our website is used and improve its content and performance.
• Process payments and manage our client relationships and records.
• Maintain the security of our website and prevent fraud or abuse.
• Comply with legal obligations and enforce our Terms of Service.

If you are in the European Economic Area or the United Kingdom, we process your personal information only when we have a legal basis to do so, including:

• Consent— for example, when you subscribe to our newsletter or accept non-essential cookies.
• Contract— to take steps you request and to provide services you’ve engaged us for.
• Legitimate interests— to operate, secure, and improve our website and business, where not overridden by your rights.
• Legal obligation— to meet accounting, tax, and other legal requirements.

We use cookies and similar technologies to operate our website, understand how it is used, and (where enabled) support marketing. Cookies generally fall into these categories:

You can control cookies through your browser settings, including blocking or deleting them, and we honor recognized opt-out preference signals such as Global Privacy Control (GPC) where required. Because there is no common industry standard for browser “Do Not Track” (DNT) signals, our website does not currently respond to them, but we treat GPC as a valid opt-out where required. Disabling some cookies may affect how parts of the site work. If you are in a region that requires opt-in consent for non-essential cookies (such as the EU or UK) and would like us to add a consent management tool for your traffic, please contact us.

We rely on a small number of trusted providers to run our website and services. Each processes data under its own privacy terms:

• Netlify hosts our website and processes form submissions through Netlify Forms.
• Google Analytics (Google LLC) provides website traffic and usage analytics.
• Cloudinary hosts and delivers the video content featured on our site.
• Meta / Instagram (Meta Platforms, Inc.) powers our social presence and, for clients, advertising and content delivery.

We work only with providers that we believe offer appropriate protections, and we require them to use your information only to provide services to us.

We may share your information:

• With the service providers listed above, so they can perform services on our behalf.
• With advertising and social platforms (such as Google or Meta) when we run campaigns on behalf of a client, using data as needed to deliver those services.
• When required by law, subpoena, or to protect our rights, safety, or property.
• In connection with a business transfer, such as a merger or acquisition, subject to this policy.

We do not sell your personal informationfor money, and we do not “share” it for cross-context behavioral advertising as those terms are defined under California law.

We are based in the United States, and our providers may process information in the U.S. and other countries. If you access our website or services from outside the U.S., your information may be transferred to and processed in the U.S., where data-protection laws may differ from those in your location. Where required, we rely on appropriate safeguards (such as standard contractual clauses) for these transfers.

We keep personal information only as long as needed for the purposes described in this policy, and then delete or anonymize it. In general:

• Audit, strategy-call, and contact form submissions are kept while we follow up and for a reasonable period afterward to maintain our records.
• Newsletter subscriber information is kept until you unsubscribe or ask us to remove it.
• Client records, contracts, and billing information are kept for the length of the engagement and as needed to meet tax, accounting, and other legal obligations.
• Website analytics and server logs are kept for a limited period in line with our providers’ settings.

You can ask us to delete your information at any time (see Section 11), subject to any records we are required to keep by law.

Depending on where you live, you may have some or all of the following rights over your personal information:

• Access or receive a copy of the personal information we hold about you.
• Request correction of inaccurate information or deletion of your information.
• Request portability of your information to another provider.
• Opt out of marketing emails and the newsletter at any time.
• Opt out of the “sale” or “sharing” of personal information (note: we do not sell or share your information).
• Withdraw consent where we rely on it, without affecting prior processing.

To exercise any of these rights, contact us using the details in Section 21. We will verify your request and respond within the timeframe required by applicable law. You may use an authorized agent to submit a request on your behalf where the law allows. We will not discriminate against you for exercising your privacy rights.

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you specific rights. In the past 12 months, we have collected the categories of personal information described in Section 2 (such as identifiers, contact and commercial information, and internet/usage activity) from the sources and for the purposes described in this policy.

You have the right to:

• Know what personal information we collect, use, and disclose.
• Request deletion or correction of your personal information.
• Opt out of the sale or sharing of personal information — we do not sell or share it.
• Limit the use of sensitive personal information — we do not use it for such purposes.
• Not be discriminated against for exercising your rights.

We disclose the categories of personal information described in Section 2 to the categories of third parties described in Sections 7 and 8 (such as our service providers and advertising and analytics platforms) for the business purposes described in this policy. We do not sell or share personal information as those terms are defined under California law.

We honor Global Privacy Control (GPC) signals as a valid opt-out request where required. To exercise these rights, contact us using Section 21.

If you are located in the EEA or UK, you have the rights described in Section 11, including the right to object to or restrict certain processing and the right to lodge a complaint with your local data-protection supervisory authority. We process your information on the legal bases described in Section 5. For any request or question, use the contact details in Section 21.

We do not make decisions that produce legal or similarly significant effects about you based solely on automated processing without human involvement. Where we use analytics, lead-scoring, or advertising tools that profile engagement (for example, to estimate which audiences are most relevant to a campaign), a person remains involved in meaningful decisions, and these tools support — not replace — human judgment.

If you are in a jurisdiction that grants rights regarding automated decision-making or profiling, you may ask us about the logic involved and request human review. Contact us using the details in Section 21.

Residents of certain other U.S. states — including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana — have privacy rights under their state laws that are similar to those described in Sections 11 and 12. Depending on your state, these may include the right to confirm whether we process your personal information; to access, correct, or delete it; to obtain a portable copy; and to opt out of targeted advertising, the sale of personal information, and certain profiling.

Right to appeal.If we decline to act on your request, you may appeal that decision by contacting us using the details in Section 21. We will respond to your appeal within the timeframe required by your state’s law and explain the reasons for our decision. Where your state provides one, you may also contact your state attorney general to raise a concern.

When you subscribe to our newsletter, submit one of our forms (such as the Free Growth Audit, Strategy Call, or contact forms), or request information, we may add you to our business newsletter and email list and send you marketing emails. Every marketing email includes an unsubscribe link, and you can opt out at any time or by contacting us directly, consistent with the CAN-SPAM Act. Opting out of marketing does not affect service-related messages we send to active clients.

If you provide a mobile number and opt in, we may send you text messages about your inquiry or our services. We send marketing texts only with your prior express consent as required by the Telephone Consumer Protection Act (TCPA); message and data rates may apply, and you can opt out at any time by replying STOP.

We take reasonable technical and organizational measures to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If we become aware of a security incident that affects your personal information, we will notify you and the appropriate authorities as required by applicable law, including Florida’s Information Protection Act (Fla. Stat. § 501.171), and without unreasonable delay.

Our website and content may link to third-party websites and platforms we do not control. This policy does not apply to those sites, and we encourage you to review their privacy policies before providing any information.

Our website and services are intended for businesses and adults. We do not knowingly collect personal information from children under 13. If you believe a child has provided us information, please contact us so we can remove it.

We may update this Privacy Policy from time to time. When we do, we’ll revise the “Last updated” date at the top of this page. Significant changes may be communicated through our website or by email.

Questions about this policy or your information? Reach out and we’ll be glad to help:

• Email: sales@onlyinnaples239.com
• Phone: (757) 275-4355
• Instagram: @only.in.naples.239
• Online: book a strategy call or request a free audit.
• Location: Naples, Florida (serving Southwest Florida).

See also our Terms of Service.