Effective Date: October 31, 2019
Naviga Inc., a company with a registered office in the United States and domiciled at 7900 International Drive, Suite 800, Bloomington, Minnesota 55425, informs you that the personal data you have or may in the future provide shall be processed in accordance with this Policy.
1. What Types of Information Does Naviga Collect About its Users?
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including: name, title, company name, job function, expertise, postal address, telephone number, or email address. If you submit any Personal Information relating to other people to us or to our service providers regarding the Sites, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation and for other purposes described below.
Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Sites, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. Naviga uses IP Addresses to calculate usage levels of the Sites, help diagnose problems with its servers, administer the Sites, and monitoring the regions from which you navigate to Naviga’s Sites.
2. How Does Naviga Collect Information?
We and our service providers may collect Personal Information in a variety of ways, including:
- Through our Web Sites: We may collect Personal Information e.g., when you request a free trial or demo, register for a webinar, contact us, subscribe to our email newsletter, download content (e.g. whitepapers), etc.
- Offline: We may collect Personal Information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact customer service.
- Through You: Naviga may collect information such as your location or your preferred means of communication when you voluntarily provide it. Unless combined with Personal Information, this information does not personally identify you or any other user of our web site. Note that there is no legal obligation for you to provide us with Personal Information and any information collected by us will be provided by you at your own will and with your consent.
- Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers, and Services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
We and our service providers may collect Other Information in a variety of ways, including:
- Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the application you are using.
- Through Your Use of the Apps: When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Through Cookies and Other Similar Technologies: Cookies and other similar technologies may be used to collect Other Information. We may use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Sites and other websites. To do so, these companies may place or recognize a unique cookie on your browser (including using pixel tags and web beacons). Please review our Cookies Policy for more information. Naviga does not recognize automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions.
Naviga also uses web analytics services, which currently include Google Analytics and Crazy Egg Analysis Service.
- By Aggregating Information: Aggregated Personal Information does not personally identify you or any other user of the Sites (for example, we may aggregate Personal Information to calculate the percentage of our users who have a telephone area code).
3. How Does Naviga Use Personal Information?
We may use Personal Information:
- To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our Services;
- To send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies;
- To communicate with you and provide you with related customer service;
- To send you marketing communications, including via email and SMS in compliance with applicable laws, that we believe may be of interest to you;
- To personalize your experience on the Sites by presenting products and offers tailored to you;
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Sites and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities; and
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations (f) to protect our rights, privacy, safety or property and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
The legal basis for the processing of Personal Information is the performance of the contractual relationship between you and Naviga when using the Sites and/or the Services, as well as user’s consent provided in conjunction with the provision of the Services.
4. How Will Naviga Share Personal Information It Receives?
Naviga may disclose Personal Information to certain types of third parties for the purposes detailed below.
Subsidiaries and Affiliates
We may disclose Personal Information to our subsidiaries and affiliates (collectively, “Affiliates”) for the purposes described in this Policy. Naviga is the party responsible for the management of the jointly-used Personal Information.
Third-Party Business Partners
Naviga partners with a variety of businesses and works closely with them to market or sell products or services. In certain situations, these businesses operate within the Sites. We may disclose Personal Information to our partners for the purposes described above. Some of our third-party business partners may co-sponsor events and other offerings with Naviga. We may share Personal Information with these co-sponsors when you sign up for events or offerings to allow our partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law.
Agents and Service Providers
We contract with other companies and people to perform tasks on our behalf and may share your Personal Information with them to provide products or services to you, or to otherwise communicate with you, such as to provide marketing or offers on our behalf. Examples may include removing repetitive information from customer lists, analyzing data, providing marketing assistance, conducting billing, processing credit card payments, engaging technical support for our services, providing customer service, and performing analysis related to our Services. We may also provide your Personal Information to agents and service providers to verify or compile aggregate usage data that we provide to our partners. When we share this information in this way, we seek to require the agent or service provider to maintain the privacy, confidentiality and security of the Personal Information.
Naviga Blog and Social Media Pages:
Personal Information may also be disclosed by you through the Sites, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Naviga Blog, at http://navigaglobal.com/blog and Social Media Pages). This information may appear in public ways, such as through search engines or other publicly available platforms, and may be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large.
In some cases, we may buy or sell assets or businesses. In these types of transactions, user information is typically one of the business assets that is transferred. Naviga may disclose Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Protection of Naviga and Others
Naviga is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, i.e., we may release Personal Information when we believe that release is necessary or appropriate (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce or apply our conditions of use and other agreements; (e) to protect our operations or those of any of our Affiliates; (f) to allow us to pursue available remedies or limit the damages that we may sustain; and (g) to protect the rights, privacy, property, or safety of Naviga, our employees, our Affiliates, our users, or any other person or entity. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
5. How Does Naviga Use and Disclose Other Information?
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.
In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we do, we will treat the combined information as Personal Information for as long as it is combined.
6. How Does Naviga Secure Personal Information About Me?
Naviga has implemented organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be one hundred percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Information online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with Section 15 below.
7. How Can I Access, Correct, Amend or Remove Information About Me?
Individuals have the right to access their personal data. If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Information about you that has been collected and stored by Naviga, please notify us at email@example.com so that we may evaluate and respond to your request in accordance with applicable law. Please note that Naviga holds an establishment within the European Union, as set forth in Section 15 below.
For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will use commercially reasonable efforts to respond to your request within thirty days.
Please note that we may need to retain certain information for recordkeeping purposes, to comply with applicable law (including laws outside your country of residence), and/or to complete any transactions that you began prior to requesting such access, change, or deletion.
8. For How Long Will Naviga Retain My Personal Information?
Naviga will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Usage data collected automatically by Naviga may be anonymized and stored indefinitely.
9. What Choices Do I Have?
You can always opt for Naviga to not to disclose information to you. However, if you elect to opt out, you may be limiting some Services we can provide to you. You will not receive product updates and other marketing related emails. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, since by opting out, you will still be able to request webinars and other information.
You may opt-out of receiving marketing messages from Naviga or our Affiliates by sending an email to firstname.lastname@example.org, by unsubscribing through the unsubscribe or opt-out link in an email, or by unsubscribing via the Naviga Subscription Center on www.navigaglobal.com. We will try to comply with your request(s) as soon as reasonably practicable.
You can also request that all Personal Data pertaining to you be erased. To exercise your right to be forgotten, please contact email@example.com. Please note that we may need to retain certain information for recordkeeping purposes, to comply with applicable law (including laws outside your country of residence), and/or to complete any transactions that you began prior to such request.
10. Can Children Use Naviga’s Sites?
The Naviga web site, Naviga social media pages, and Naviga Services are not intended for minors under the age of 18. Naviga does not knowingly or specifically collect information about minors under the age of 18 and believes that children of any age should get their parents’ or legal guardians’ consent before providing any Personal Information. If you believe that we have mistakenly or unintentionally collected such information, please notify us at firstname.lastname@example.org so that we may delete the information from our servers.
11. Third Party Sites
We may permit you to link to other websites on the Internet through direct links or through applications such as “share” or “Like” buttons, and other websites likewise may contain links to the Sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Policy. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information may be collected and used.
We are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or the Social Media Pages.
12. Sensitive Information
Please do not send Naviga or disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Naviga web site or via other means.
13. Changes to this Policy
Naviga may amend this Policy from time to time. The “Effective Date” legend at the top of this page indicates when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on our web site.
14. International Transfer of Data
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using this site or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including (but not limited to) the United States, Australia, Denmark, India, Spain, Sweden, and the UK, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. Where required, we put in place a solution to ensure that Personal Data transferred outside of the EEA is subject to adequate protection.
Naviga has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.
Naviga further commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities about human resources data transferred from the EU and Switzerland in the context of the employment relationship.
EU-U.S. and Swiss-US Privacy Shield
When transferring any Personal Data from the EEA and Switzerland to the U.S., Naviga adheres to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce.
Naviga adheres to the Privacy Shield Principles. Naviga complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and/or Switzerland to the United States. Naviga has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Naviga’s certification, please visit http://www.privacyshield.gov/.
For the purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.
If Naviga has received your Personal Data in the U.S. and subsequently transfers it to a third-party agent or service provider for processing, and such third-party agent or service provider processes your Personal Data in a manner inconsistent with the Privacy Shield Principles, Naviga remains responsible under the Privacy Shield Principles, unless Naviga can prove that it is not responsible for the event giving rise to the damage.
The U.S. subsidiaries of Naviga also adhering to Naviga’s Privacy Shield Principles are Naviga Inc.; Naviga Mobile, Inc.; Mediasota, LLC; Marketing G2, LLC; MG2 ConneXt, LLC; Zinio Corporation, Inc.; Zinio, LLC; and, ZinioPro, LLC.
15. Questions, Concerns or Complaints
Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at email@example.com. Since email communications are not always secure, please do not include sensitive information in your emails to us. You may also contact us by mail as follows:
Within the United States:
7900 International Drive, Suite 800
Bloomington, MN 55425
Within the European Union:
Avenida Diagonal 605, 8ª planta
08028 Barcelona, Spain
Naviga will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
In compliance with the Privacy Shield Principles, Naviga commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Naviga at: firstname.lastname@example.org.
Naviga has further committed to refer unresolved Privacy Shield complaints to Privacy Trust (see https://www.privacytrust.com/cert/296507.html), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.privacytrust.com/drs/Naviga for more information or to file a complaint. The services of Privacy Trust are provided at no cost to you.
Naviga provides the possibility, under certain conditions, for the individual to invoke binding arbitration.
For the purposes of enforcing compliance with Privacy Shield, we are subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.