For purposes of this Policy, “Personal Information”  is information that identifies you as an individual or relates to you, including name, title, job function, postal address, telephone number, or email address, where applicable law treats it as such, your IP Address. If you submit any Personal Information relating to other people to us or to our service providers regarding the Sites or Services, you represent that you have the authority to do so (e.g.  have obtained any necessary consent where required by applicable law) and to permit us to use the information in accordance with this Policy.

For purposes of this Policy, “Other Information” means any information that does not identify, and cannot reasonably be linked to, an identifiable individual, including aggregated, anonymized, or de-identified information where permitted by applicable law. This might include, for instance, browser type and device information, app usage data, demographic information and aggregated information. We use this information to operate, improve, analyze, secure, and optimize our Sites and Services and for the purposes described in this Policy.

Naviga may disclose Personal Information to certain types of third parties for the purposes detailed below:

We may use and disclose Other Information to facilitate our operation and for other purposes described above. 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.

8. How Can I Access, Correct, Amend or Remove my Personal Information and Exercise my Privacy Rights?

Individuals have the right to access, correct, amend, remove, transfer (including data portability), object or limit their personal data as well as the right not to be subject to automated decision making. If you would like to exercise your rights please notify us at info@navigaglobal.com so that we evaluate and respond to your request in accordance with applicable law.

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 as soon as possible and in general within thirty days.

Please note that we may need to retain certain Personal Information, for example for record-keeping purposes, to comply with applicable law (including laws outside your country of residence), and/or to complete any transactions that you began prior to your request.

When applicable, you have the right to withdraw your consent. This will not affect the lawfulness of the processing completed before the consent withdrawal.

Residents of certain U.S. states may have additional rights regarding their Personal Information. Residents wishing to exercise these rights may contact Company using the contact information provided below.

You may also have the right to complain to a data protection authority in your country (e.g., the ICO in the UK, the CNIL in France, the Garante in Italy) if you think we have processed your Personal Information unlawfully. If you have such concerns, we invite you to contact us in the first instance at: privacy@navigaglobal.com so that we can investigate, and hopefully resolve, your concerns.

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. For example, contract-related information and financial information may be retained for up to ten years following the termination or expiration of the applicable contract, where required to comply with legal, tax, accounting, or record-keeping obligations. If appropriate, usage data collected automatically by Naviga may be anonymized and stored indefinitely.

For more information about Naviga’s retention periods, please contact us at: privacy@navigaglobal.com.

10. Right to Opt Out

You may opt out of receiving marketing messages from Naviga or our Affiliates by sending an email to: info@navigaglobal.com or by unsubscribing through the unsubscribe or opt-out link in an email. We will try to comply with your request as soon as reasonably practicable. If you elect to opt out, you will not receive product updates and other marketing related emails but may still receive important administrative messages.

11. Can Children Use Naviga’s Sites?

The Sites and Services are not intended for use by children under the age required by applicable law. Naviga does not knowingly or specifically collect information about children under the age required by applicable law. Naviga is not responsible for embedded content. If you believe that we have mistakenly or unintentionally collected such information, please notify us at info@navigaglobal.com so that we may delete the information from our servers.

12. 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 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 of other organizations, such as Meta, 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.

13. Sensitive Information

Please do not send or otherwise provide Naviga or disclose to Naviga any Sensitive Personal Information (including, but not limited to, 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 Sites, Services or via any other means.

14. Changes to this Policy

Naviga may amend this Policy from time to time. The Global Privacy Policy statement 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 the Site. Material changes will be communicated where required by law.

15. International Transfer of Data

Your Personal Information may be processed in any country where we have facilities or in which we engage service providers including the United States and the United Kingdom. Where required under applicable law, we seek to ensure that Personal Information transferred outside of the EEA is subject to adequate protection, such as adequacy decisions of the European Commission (e.g., UK adequacy decision), Standard Contractual clauses or other applicable guarantees.

Naviga has responsibility for the processing of Personal Information it receives under the Data Privacy Framework and subsequently transfers to a third party acting as an agent on its behalf. It commits to cooperate with EU data protection authorities and the Swiss Federal Data Protection and Information Commissioner and seek to comply with the advice given by such authorities, including about human resources data transferred from the EU and Switzerland in the context of the employment relationship.

EU-U.S., UK Extension to the EU-U.S., and Swiss-U.S. Data Privacy Framework

Naviga complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Naviga has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. DPF Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Naviga has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit: https://www.dataprivacyframework.gov/.

For the purposes of enforcing compliance with the Data Privacy Framework, we are subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.

The U.S. affiliates of Naviga also adhere to Naviga’s Data Privacy Framework Principles, including, but not necessarily limited to, Naviga Mobile, Inc.; Mediasota, LLC; Marketing G2, LLC; MG2 ConneXt LLC; Miles 33 LLC; Miles 33 USA Inc.; Zinio Corporation, Inc.; Zinio, LLC; and ZinioPro, LLC.

16. Questions, Concerns and Complaints

Naviga takes any privacy related questions or concerns 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 EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Naviga commits to resolve DPF Principles-related complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Naviga at: info@navigaglobal.com.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Naviga commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.