Effective Date: 2/23/2024
Navu, Inc. (“Navu”) is committed to protecting the privacy and security of the information we collect and to being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for handling the information we collect from or about you. It applies to the websites and online service that we operate and that link to this Privacy Policy, and also to the information we collect and use in connection with the services we provide to our partners and clients on their websites and other online services (“Publishers”) (collectively, the “Services”).
Publishers who use Navu’s Services use the information they collect in accordance with their own privacy policies. Accordingly, please refer to the privacy policies and notices of such parties, who are responsible for the collection and processing of information on their sites.
We also may aggregate or de-identify the information collected under this Privacy Policy. Aggregated or de-identified data is not subject to this Privacy Policy, and where we process such data, we maintain and use it in deidentified form and do not to attempt to reidentify individuals from it.
I. COLLECTION OF INFORMATION
We collect the following categories of information when you use our Services:
Information you provide directly to us.
- Contact Information, including name, alias, maiden name, email address, telephone or mobile phone number, and general location information (city, region, country);
- Sign-In Information, including username and password and account name;
- Transaction and Billing Data, including bank account and payment card details, (credit card number, expiration date, and credit card security code, where needed to complete a transaction), and billing address; and
- Correspondence you send to us.
Information we collect automatically. We collect Internet Use, Electronic Activity, and Other Related Information automatically from the devices and browsers that you use, including your device type; Internet protocol (IP) address; device and advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers; time zone setting and location; browser type and version; browser plug in types and versions; operating system and platform; Internet service provider; pages that you visit before and after using the Services, browsing history, and search history; the date and time of your visit; information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use the Services; the technology on the devices you use to access these Services; inferences used to create a profile about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; and standard server log information. If you or your device experiences an error, we collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
We also receive the categories of information described above from other sources, including from users of our Services, our Publishers, and other third-party services and organizations. For example, if you access a Publisher’s website or other online service, we may collect information about your use and engagement with that website or other online service.
Without this information, we are not able to provide you with all the requested Services, and any differences in services are related to your information.
We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.
II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING
We use and otherwise process each of the categories of information identified above for the following business purposes:
| Purpose/Activity | Type(s) of Information Used | EEA lawful basis for processing, including basis of legitimate interest |
| To provide you with the information, products and services that you request from us | * All categories of data described above, as applicable | * Performance of a contract with you * Necessary to comply with a legal obligation (for instance, tax and record-keeping requirements) * Necessary for our legitimate interests (for instance, to provide our Services and operate our business) |
| To manage accounts and manage our relationship with you, including processing payment, providing you with the information you request from us, and notifying you about changes to our terms or privacy policy | * Contact Information * Sign-In Information * Transaction and Billing Data * Correspondence | * Necessary to comply with a legal obligation (for instance, where we are required to notify you about changes in our terms) * Necessary for our legitimate interests (for instance, to manage our customer accounts and provide you with information you request from us) |
| To allow you to participate in interactive features of our Services, when you choose to do so | * Internet Use, Electronic Activity, and Other Related Information * Sign-In Information | * Necessary for our legitimate interests (for instance, to enable you to access interactive features) * Consent (where required by applicable law) |
| To make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you, or to send promotional materials from us or by our affiliates and trusted business partners. | * Correspondence * Internet Use, Electronic Activity, and Other Related Information | * Necessity for our legitimate interests (for instance, to grow our business by informing you of ) * Consent (where required by applicable law) |
To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device | * Contact Information * Sign-In Information * Internet Use, Electronic Activity, and Other Related Information * Correspondence | (a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent cybercrime and fraud; in the context of a business reorganisation or group restructuring exercise; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)(b) Necessity to comply with a legal obligation |
| To administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes | * Contact Information * Sign-In Information * Transaction and Billing Data * Internet Use, Electronic Activity, and Other Related Information * Correspondence | Necessary for our legitimate interests (for instance, to conduct troubleshooting and debugging, analytics, testing, and surveys) |
| To keep our Services, business and users safe and secure | * Sign-In Information * Internet Use, Electronic Activity, and Other Related Information | * Performance of a contract with you (for instance, our Terms of Service) * Necessary to comply with a legal obligation (for instance, applicable data protection laws) * Necessary for our legitimate interests (for instance, to ensure the ongoing integrity, confidentiality, and availability of our Services) |
| To comply with applicable laws and regulations | All categories of data described above, as applicable | Necessary to comply with a legal obligation |
| To protect or exercise our legal rights and privileges and/or to defend against legal claims | All categories of data described above, as applicable | Necessary for our legitimate interests (for instance, to exercise, establish, and defend against legal claims) |
Where legally required and we have no other valid legal basis to process your information, we will obtain consent (for example, to provide you with marketing information or share information with third parties), which may subsequently be withdrawn at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.
Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may cancel a product or service you have requested from us.
III. DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Authorized third-party vendors and service providers. We share your information with third-party vendors and service providers that provide services to us for a variety of business purposes, such as billing, payment processing, customer service, email deployment, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing.
- Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy.
- Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Navu, our affiliates, users, or the public.
- With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services — such as third-party single-sign on tools — through the Services, these third-party services may be able to collect information about you, including information about your activity on the Services, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.
Navu does not sell your personal information to [or share it for targeted advertising purposes with] third parties. Navu does permit third parties to collect the information described above through our Service and discloses such information with third parties for business purposes as described in this Privacy Policy. The information practices of these third parties are not covered by this Privacy Policy.
IV. COOKIES AND SIMILAR TECHNOLOGIES
When you use our Services, we use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”) to collect information from your browser or device. By using the Services, you consent to our use of cookies and similar technologies.
The following types of cookies are used on our Services:
- Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these cookies, certain services cannot be provided. These cookies also help keep our Services safe and secure.
- Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
- Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
- Content cookies – These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content on our Services and elsewhere online and across your devices. They are also used to gather feedback on customer satisfaction through surveys. They remember that you’ve visited our Services and help us understand usage of our Services.
Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals
V. YOUR RIGHTS AND CHOICES
You may be entitled, in accordance with applicable law, to request access to, rectification, erasure, and portability of your information or more information about our information practices, as well as object to or request restriction of processing of your information. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. If you would like to use an agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
You may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable Local Shared Objects and similar technologies. For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt out selection in your browser.
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you. Any difference in the Services are related to the value provided.
You may lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful.
VI. INTERNATIONAL TRANSFERS
By using the Services and providing us with information, you understand and agree that we may transfer and store your information on servers located outside your resident jurisdiction. To the extent you are a resident of a country other than the United States, we will ensure that we process your information in accordance with applicable law.
VII. CHILDREN
We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.
VIII. DATA RETENTION, SECURITY, AND INTEGRITY
Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.
We maintain reasonable security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
IX. CHANGES TO THE PRIVACY POLICY
We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.
X. CONTACT INFORMATION
If you have any questions about this Privacy Policy or our practices, please email [email protected]
