This Privacy Policy is designed to help you understand how Naviguer LLC (collectively with any subsidiaries, called “Naviguer,” “we,” “us,” and “our”) collects, uses, and shares your personal information and to help you understand and exercise your privacy rights.
SCOPE
CHANGES TO OUR PRIVACY POLICY
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR PERSONAL INFORMATION
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
INTERNATIONAL DATA TRANSFERS
RETENTION OF PERSONAL INFORMATION
SECURITY OF PERSONAL INFORMATION
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
CHILDREN’S INFORMATION
THIRD-PARTY’S WEBSITES/APPLICATIONS
SUPERVISORY AUTHORITY
CONTACT US
1. SCOPE
This Privacy Policy applies to personal information processed by us, through our websites and any other services or interfaces owned or controlled by Naviguer that link to this Privacy Policy (each a “Service” and together, the “Services”).
2. CHANGES TO OUR PRIVACY POLICY
We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. We encourage you to periodically review this privacy statement to learn how Naviguer is protecting your information. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
3. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect personal information that you provide to us, personal information we obtain automatically when you use our Services, and personal information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services such as:
Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your browser or device information, location information (including approximate location derived from IP address), and metadata about the content you provide. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications.
C. Information Collected from Other Sources
4. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and services, as described below.
If your personal information is subject to the General Data Protection Regulation or UK General Data Protection Regulation, our processing of your personal information will be under one of the following lawful bases:
A. Processing Necessary for Us to Provide Our Services
We process your personal information to perform our contract with you and provide you with our Services including by:
B. Administrative Purposes
We use your personal information for our legitimate interests, such as:
C. Marketing our Products and Services
We may use personal information to tailor and provide you with content. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information and for which you provide your consent.
E. Other Purposes
We also use your information for other purposes as permitted by applicable law.
De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, information about how you use the Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.
5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, to the extent permitted by law.
6. YOUR PRIVACY CHOICES AND RIGHTS
The privacy choices you may have about your personal information are determined by applicable law and are described below.
Email Communications. If you receive a direct marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transfer-related emails regarding services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Policy).
Your Privacy Rights. In accordance with applicable law, you may have the right (subject to certain limitations) to:
Confirm Whether We Are Processing Your Personal Information (the right to know);
Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; or (ii) receiving an electronic copy of personal information that you have provided to us, or, in certain circumstances, asking us to send that information to another company (aka the right of data portability);
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information;
Request to Opt-Out of Certain Processing Activities including, as applicable, if we were to process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we were to engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws). For clarity, as described in the “Supplemental Notice to California Residents” Section below, we do not currently “sell” or “share” your personal information
Request Restriction of or Object to our processing of your personal information, including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes;
Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal; and
Appeal our Decision to decline to process your request.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
7. INTERNATIONAL DATA TRANSFERS
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, we will use a valid data transfer mechanism to ensure that your personal information is transferred in accordance with this Privacy Policy and applicable data protection laws.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
8. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy only for as long as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
9. SECURITY OF PERSONAL INFORMATION
We employ appropriate technical and organizational measures designed to protect the security of all personal information we collect. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We will continue to evaluate these measures to ensure the security of the processing.
10. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time, including by the California Privacy Rights Act of 2020) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Naviguer has collected about them and whether Naviguer disclosed that personal information for a business purpose (e.g., to a service provider), whether Naviguer “sold” that personal information, and whether Naviguer “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information we Collect” and “How We Use Your Personal Information” above, respectively.
Additional Privacy Notices and Rights for California Residents
“Sales” of Personal Information under the CCPA. In the preceding twelve months, Naviguer has not “sold” any personal information (as defined by the CCPA), nor does Naviguer have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Cross-Context Behavioral Advertising under the CCPA. In the preceding twelve months, Naviguer has not “shared” any personal information for “cross-context behavioral advertising” (as such terms are defined in the CCPA), nor does Naviguer have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising**”.
Disclosure Regarding Sensitive Personal Information. Naviguer uses and discloses sensitive personal information (as defined in the CCPA) for the following purposes:
Limit the Use and Disclosure of Sensitive Personal Information: You have the right to ask that we limit our use and disclosure of your sensitive personal information to certain purposes permitted by law and can do so by contacting us using the information in the “Contact Us” section below.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below.
Verification. When you make a request under the CCPA, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us as set forth in “Contact Us” below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
12. CHILDREN’S INFORMATION
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information without your consent, you may contact us as set forth in “Contact Us” below. If we learn that a child has provided us with personal information in violation of applicable law, we will promptly take steps to delete such information, unless we have a legal obligation to keep it.
13. THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
14. COMPLAINTS
If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as set forth in “Contact Us” below.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
EEA Data Protection Authorities (DPAs)
Swiss Federal Data Protection and Information Commissioner (FDPIC)
UK Information Commissioner’s Office (ICO)
15. CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at support@naviguerconsulting.com
SCOPE
CHANGES TO OUR PRIVACY POLICY
PERSONAL INFORMATION WE COLLECT
HOW WE USE YOUR PERSONAL INFORMATION
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
YOUR PRIVACY CHOICES AND RIGHTS
INTERNATIONAL DATA TRANSFERS
RETENTION OF PERSONAL INFORMATION
SECURITY OF PERSONAL INFORMATION
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
CHILDREN’S INFORMATION
THIRD-PARTY’S WEBSITES/APPLICATIONS
SUPERVISORY AUTHORITY
CONTACT US
1. SCOPE
This Privacy Policy applies to personal information processed by us, through our websites and any other services or interfaces owned or controlled by Naviguer that link to this Privacy Policy (each a “Service” and together, the “Services”).
2. CHANGES TO OUR PRIVACY POLICY
We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. We encourage you to periodically review this privacy statement to learn how Naviguer is protecting your information. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
3. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect personal information that you provide to us, personal information we obtain automatically when you use our Services, and personal information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
- Account Creation. We may collect personal information when you sign up for a newsletter or create an account with us or our service providers (e.g., Shopify), such as name, phone number, time zone, and email address. We may also collect additional personal information, such as your shipping address if you purchase merchandise from us.
- Purchases. In order to engage in certain transactions or purchases on the Services, you may need to provide us or our third-party payment processors with your payment information. We do not directly collect or store any payment card information entered through our Services, but we may receive from our third-party payment processing providers information associated with your payment card information (e.g., your billing details). We may also collect your name, the name of the recipient, email address, the currency and the date as part of the transactions taking place on the Services.
- Other Transactions. We may collect personal information and details associated with your activities on our Services.
- Your Communications with Us. We may collect personal information, such as email address, phone number or mailing address when you request information about our Services, register for our newsletter, apply for a job or otherwise communicate with us.
- Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., via social media pages). Such personal information may include photos, avatars, or other images that you upload and usernames that include personal or biographic information. Any personal information you provide on the public sections of these features will be considered “public,” (the “User Content”) unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
- Sweepstakes, Giveaways or Contests. We may collect personal information you provide for any sweepstakes, giveaways or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
- Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services such as:
Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your browser or device information, location information (including approximate location derived from IP address), and metadata about the content you provide. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
- Cookies and Other Technologies. We, as well as third parties that provide content or other functionality on our Services, may use cookies, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Analytics. We may use tools to process analytics information on our Services. These technologies allow us to process usage data to better understand how our Services are used, and to continually improve our Services.
- Social Media Platforms. Our Services may contain social media buttons, such as Discord, Instagram, and Twitter, which might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications.
C. Information Collected from Other Sources
- Third-Party Sources. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. Your access through a third-party application may also subject you to the privacy policies of such third parties, so we encourage you to read and understand their privacy policies
- Sharing Features. Our Services may offer various tools and functionalities that allow you to provide information about your friends; third parties may also use these services to upload information about you. Our Services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people if you have their express consent.
4. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and services, as described below.
If your personal information is subject to the General Data Protection Regulation or UK General Data Protection Regulation, our processing of your personal information will be under one of the following lawful bases:
- Performance of a Contract. We may process your personal information to carry out our contract with you or to take steps at your request prior to entering into a contract. For further details, see Section 4(A).
- Legitimate Interest. We may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms. For a detailed list of our legitimate interests, see Sections 4(B).
- Compliance with Legal Obligations. We may process your personal information to comply with our legal obligations as detailed in Section 4(B).
- Consent. In some cases, we may also rely on your consent to process your personal information for a specific purpose as detailed in Section 4(C).
A. Processing Necessary for Us to Provide Our Services
We process your personal information to perform our contract with you and provide you with our Services including by:
- Managing your information;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods to facilitate purchases and transfers via the Services; and
- Allowing you to register for events.
B. Administrative Purposes
We use your personal information for our legitimate interests, such as:
- Conducting marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services; improving, upgrading or enhancing our Services; developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transfers and other compliance activities;
- Sharing information with third parties as needed to provide the Services;
- Sending you news and/or marketing communications (by email, phone, or text), subject to your marketing preferences and choices, including information about us or third party offerings that we think may be of interest to you;
- Enforcing our agreements and policies;
- Administer contests, surveys, and sweepstakes you enter, notify contest winners, and award prizes; and
- Other uses as required to comply with our legal obligations, applicable laws, regulations, regulators and authorities.
C. Marketing our Products and Services
We may use personal information to tailor and provide you with content. We may provide you with these materials as permitted by applicable law. Some of the ways we may market to you include email campaigns.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information and for which you provide your consent.
E. Other Purposes
We also use your information for other purposes as permitted by applicable law.
De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, information about how you use the Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.
5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
- Other Users of the Services and Parties You Transact With. Some of your personal information may be visible to other users of the Services (e.g., information featured on generally accessible parts of the contracts or on a user profile). In addition, to complete transfers via the Services, we will need to share some of your personal information with the party that you are transacting with.
- Third Party Websites and Applications. You may choose to share personal information or interact with third-party websites and/or third-party applications, including, but not limited to, third-party electronic wallet extensions. Once your personal information has been shared with a third-party website or a third-party application, it will also be subject to such third party’s privacy policy. We encourage you to closely read each third-party website or third-party application privacy policy before sharing your personal information or otherwise interacting with them. Please note that we do not control, and we are not responsible for the third-party websites’ or the third-party applications’ processing of your personal information.
- Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, Game Usage Information, customer service, and related services.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
- Affiliates. We may share your personal information with members of our corporate family.
- APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, to the extent permitted by law.
6. YOUR PRIVACY CHOICES AND RIGHTS
The privacy choices you may have about your personal information are determined by applicable law and are described below.
Email Communications. If you receive a direct marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transfer-related emails regarding services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Policy).
Your Privacy Rights. In accordance with applicable law, you may have the right (subject to certain limitations) to:
Confirm Whether We Are Processing Your Personal Information (the right to know);
Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; or (ii) receiving an electronic copy of personal information that you have provided to us, or, in certain circumstances, asking us to send that information to another company (aka the right of data portability);
Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information;
Request to Opt-Out of Certain Processing Activities including, as applicable, if we were to process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we were to engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws). For clarity, as described in the “Supplemental Notice to California Residents” Section below, we do not currently “sell” or “share” your personal information
Request Restriction of or Object to our processing of your personal information, including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes;
Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal; and
Appeal our Decision to decline to process your request.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
7. INTERNATIONAL DATA TRANSFERS
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, we will use a valid data transfer mechanism to ensure that your personal information is transferred in accordance with this Privacy Policy and applicable data protection laws.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
8. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy only for as long as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
9. SECURITY OF PERSONAL INFORMATION
We employ appropriate technical and organizational measures designed to protect the security of all personal information we collect. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We will continue to evaluate these measures to ensure the security of the processing.
10. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents supplements our Privacy Policy and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time, including by the California Privacy Rights Act of 2020) (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Naviguer has collected about them and whether Naviguer disclosed that personal information for a business purpose (e.g., to a service provider), whether Naviguer “sold” that personal information, and whether Naviguer “shared” that personal information for “cross-context behavioral advertising” in the preceding twelve months. California residents can find this information below:
- Category of Personal Information Collected by Naviguer
- Category of Third Parties To Whom Personal Information is Disclosed to for a Business Purpose
- Identifiers
- Other users of the Services and parties you transact with
- Third party websites and applications
- Service providers (e.g. third party identity verification providers)
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Other users of the Services and parties you transact with
- Third party websites and applications (e.g., wallet providers)
- Service providers (e.g. third party identity verification services)
- Protected classification characteristics under California or federal law
- Service providers (e.g. third party identity verification providers)
- Commercial information
- Other users of the Services and parties you transact with
- Service providers (e.g. customer service support vendors)
- Internet or other electronic network activity
- Service providers (e.g. data analytics providers and game operators)
- Geolocation data
- Service providers (e.g. third party identity verification services)
- Inferences drawn from other personal information to create a profile about a consumer
- Service providers (e.g. marketing consultants and game operators)
- Professional or employment-related information
- Service providers (e.g. applicant and recruiting software providers)
- Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number
- Service providers (e.g. third party identity verification services)
- Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
- Service providers (e.g. cryptocurrency and payment vendors)
- Personal information that reveals the contents of a consumer’s mail, email, and text messages unless Naviguer is the intended recipient of the communication
- Service providers (e.g. customer service support vendors)
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information we Collect” and “How We Use Your Personal Information” above, respectively.
Additional Privacy Notices and Rights for California Residents
“Sales” of Personal Information under the CCPA. In the preceding twelve months, Naviguer has not “sold” any personal information (as defined by the CCPA), nor does Naviguer have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Cross-Context Behavioral Advertising under the CCPA. In the preceding twelve months, Naviguer has not “shared” any personal information for “cross-context behavioral advertising” (as such terms are defined in the CCPA), nor does Naviguer have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising**”.
Disclosure Regarding Sensitive Personal Information. Naviguer uses and discloses sensitive personal information (as defined in the CCPA) for the following purposes:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, and or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at Naviguer and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by Naviguer, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by Naviguer.
- To make inferences about users, which we may use to promote certain products or services.
Limit the Use and Disclosure of Sensitive Personal Information: You have the right to ask that we limit our use and disclosure of your sensitive personal information to certain purposes permitted by law and can do so by contacting us using the information in the “Contact Us” section below.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in “Contact Us” below.
Verification. When you make a request under the CCPA, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us as set forth in “Contact Us” below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
12. CHILDREN’S INFORMATION
The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information without your consent, you may contact us as set forth in “Contact Us” below. If we learn that a child has provided us with personal information in violation of applicable law, we will promptly take steps to delete such information, unless we have a legal obligation to keep it.
13. THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
14. COMPLAINTS
If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as set forth in “Contact Us” below.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
EEA Data Protection Authorities (DPAs)
Swiss Federal Data Protection and Information Commissioner (FDPIC)
UK Information Commissioner’s Office (ICO)
15. CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at support@naviguerconsulting.com
