Privacy Policy

Please refer to the end of the document for Privacy Policies for other countries and links to Navgar’s Sub-Processors.

Effective as of June 5, 2023

This Privacy Policy describes how Navgar, Inc. (“Navgar,” “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, online portals and other activities described in this Privacy Policy (collectively, the “Service”)). Navgar may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

Index

• Personal information we collect
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfers
• Children
• Changes to this Privacy Policy
• How to contact us
• Information for EU Users
• Information for California Residents

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Profile data, such as the username and password that you may set to establish an online account on the Service, the profile photo you upload and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Transactional data, such as information relating to or needed to complete your orders or requests on or through the Service, including order numbers and transaction history, and the tasks, projects and users flows you input into our system.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Session-replay technologies, such as those provided by LogRocket that employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those sessions. The replays include users’ clicks, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Log Rocket at https://logrocket.com/privacy.
• Chatbots, chat services and conversational services, such as those provided by Intercom, that collect any information users upload to the chat services, for the purpose of providing support services and helpful articles in response to user inquiries. You can learn more about Intercom’s privacy practices at: https://intercom.com/legal/privacy.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide, operate and improve the Service and our business;
• personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• establish and maintain your user profile on the Service;
• enable security features of the Service, such as by sending you security codes via Google Authenticator, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Marketing. We and our service providers may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates for uses consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Third parties designated by you. We may share the information you upload with third parties where you have instructed us or provided your consent to do so. Any personal information you share will be accessible to the third party/parties you designate for the period of time that you specifically designate when granting access or until you revoke such access.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Navgar, financing of Navgar, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Navgar as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

• Email: Legal@navgar.app

Information for EU users (EU Disclosures)

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 2016 on the protection of natural persons with regard to the processing of personal data, Navgar informs you that this document contains information about how we collect, process, and protect your data, and how we guarantee your rights regarding its use and access.

This section applies only to Users located in the European Union, as Navgar is committed to helping our users understand the rights and obligations under the General Data Protection Regulation (GDPR), which took effect on May 25, 2018.

Contact Information for the Data Controller and Data Protection Officer

Navgar
1919, 14th Street
Boulder, CO 80304
legal@navgar.app

Data Protection Officer (DPO)
Seifti Software SL
Plaza Juan Zorrilla, 1, Madrid, ES, 28003
privacy@seifti.io

Legal Bases for Processing EU Users´ Personal Information

In accordance with the General Data Protection Regulation (EU) 2016/679, as data controllers, we are required to have an appropriate legal basis for processing your data in each case. Every data processing activity must be supported by a valid legal ground.

There are different legal bases for processing your personal data, depending on the specific purpose. These legal bases will mainly be the performance of a contract, our legitimate interest, your consent, or compliance with our legal obligations.

• We will rely on the performance of a contract when processing your personal data is essential to formalize the provision of the services you request. For example, to enter into a contract with us and allow its subsequent execution, to respond to your related requests, or to provide you with the services you have requested, maintain them, and manage our business relationship.
• We will rely on our legitimate interest when it prevails for processing your data and when we ensure that it does not override your rights. For example, for fraud prevention, to prevent the commission of crimes and protect our economic interests, to prepare aggregated and anonymized reports on the use of our services, or to investigate uses or behaviors not permitted according to the terms established for such services.
• We will rely on your consent when our processing requires a clear, free, informed, affirmative, and specific action from you. For example, to provide you with commercial information about products and services when it is not based on our legitimate interest. In this regard, Navgar informs you that you may, at any time, grant or withdraw your consent, as well as communicate your preferences regarding these purposes.
• We will rely on compliance with our legal obligations when we must share your data to fulfill a legal provision or requirement. For example, to comply with legal obligations regarding the retention of tax and accounting documentation.

Transfer of EU Users’ Personal Information Outside the EU

In order to comply with the principle of transparency, we inform you, pursuant to Articles 45 and 46 of the GDPR, that when Navgar carries out transfers of personal data that are or will be subject to processing after their transfer to a third country or international organization (for example, United States), Navgar will comply with and implement the safeguards set out in current legislation to ensure that such transfers are adequate to protect the rights of data subjects, whenever such transfers take place.

Nevertheless, any such transfers will always be carried out in accordance with the appropriate safeguards established in data protection regulations (either through Standard Contractual Clauses approved by the European Commission or based on the existence of an adequacy decision by the Commission).

Our headquarters are located in the United States and we may use service providers that operate in other countries, and Navgar will ensure that there is an appropriate legal basis and that suitable transfer mechanisms are in place to safeguard the transfer as defined.

Additionally, you can find an up-to-date list of data processors at the end of this policy.

You can obtain more information on countries with an adequacy decision, and regarding data transfer mechanisms here.

EU Users’ Rights to Control Personal Information

Navgar recognizes and guarantees the exercise of the following rights, free of charge in the cases established by current legislation, at any time and in an effective and accessible manner:

• Access. You have the right to access your data, as well as to know whether your personal data is being processed. In this regard, you may obtain a copy of your personal data, although exercising this right must not adversely affect the rights of others and their right to data protection.
• Rectification. As a data subject, you have the right to obtain, without undue delay, the rectification of inaccurate data or to have incomplete data completed.
• Restriction. As a data subject, you have the right to obtain restriction of the processing of your data, provided that one of the following circumstances applies:
  • You contest the accuracy of the data, for a period enabling us to verify its accuracy.
  • When you prefer restriction to erasure of the data.
  • When your data is not being processed and should be erased, but is needed to establish a claim or respond to a request.
  • When you have objected to processing, but the legitimate grounds for processing are being verified.
• Objection. You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on legitimate interest.
• Erasure. As a data subject, you have the right to have your data erased without undue delay, provided there is a justified reason for doing so.
• Portability. As a data subject, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, whenever technically possible. This right must not adversely affect the rights and freedoms of others.
• Not to be subject to automated decisions. As a data subject, you have the right not to be subject to decisions made solely as a result of automated processing, including profiling, which may have significant effects on you.

Additionally, Navgar informs you that, pursuant to Article 77 of the General Data Protection Regulation (GDPR), you have the right as a data subject to lodge a complaint with the relevant Supervisory Authority if you consider that the processing of your personal data by us infringes the Regulation.

How to exercise your rights: Any data subject wishing to exercise any of the aforementioned rights may do so by emailing Legal@navgar.app, clearly referencing the exercise of the corresponding right.

Information for California Residents (CCPA Disclosures)

These disclosures are provided by Navgar and apply solely to residents of the State of California (“consumers” or “you”) with respect to personal information Navgar processes as a business.

Any terms defined in the California Consumer Privacy Act of 2018, as amended from time to time, including by the California Privacy Rights Act of 2020 and its implementing regulations (“CCPA”) have the same meaning when used in these disclosures.

These disclosures do not reflect our collection, use, or disclosure of California residents’ personal information, or data subject rights, where an exception or exemption under the CCPA applies.

California Consumer Privacy Act Disclosures. Under the California Consumer Privacy Act, effective on January 1, 2020, California residents have the right to request:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose of collecting or selling personal information;
• The categories of third parties with whom we share or sell personal information;
• The categories of personal information about you that we have sold; and
• The specific pieces of personal information we have collected about you.

Additionally, you have the right to request deletion of your personal information, the right to opt out of the sale of your information and the right not to be discriminated against for exercising any of your CCPA rights.

We have set out below categories of personal information about California residents we have collected, and as applicable disclosed, for a business purpose in the preceding 12 months.

In the twelve (12) months preceding the Effective Date of this Privacy Policy, we may have collected or received from you, from public sources or from third parties in connection with providing our services, information about California consumers in each of the following categories and disclosed the information to our service providers.

• Identifiers such as a real name, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Profile data, such as the username and password that you may set to establish an online account on the Service, the profile photo you upload and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Transactional data, such as information relating to or needed to complete your orders or requests on or through the Service, including order numbers and transaction history, and the tasks, projects and users flows you input into our system.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

The information collected has been directly originated by direct consumer interactions and our website analytics, where applicable.

Navgar does not sell personal information of consumers for monetary consideration under CCPA. The use of cookies and other website collection tools described in this policy may fall under the definition of “sale” of information under CCPA. This “sale” of information is not part of service and product offerings to our customers, but rather applies only to our marketing websites and our own use of cookies for website visitors.

Also, all information processed by Navgar about its visitors is non-sensitive data, other than log-in information, password and location data.

Do Not Sell Opt-Out Rights

You have the right to opt-out of any sales, as defined by the CCPA, of Personal Information by Navgar. You must request that Navgar not sell any information you provide to Navgar as an individual, either upon the provision of personal information to Navgar or any time thereafter. Once Navgar receives and confirms your request, we will refrain from selling your Personal Information.

EXERCISING YOUR RIGHTS

As a California resident, you have the following rights under the CCPA:

• The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. You may only exercise your right to know twice within a 12-month period.
• The right to delete personal information that we have collected from you, subject to certain exceptions.
• The right to correct inaccurate personal information that we maintain about you.
• The right to opt-out of the sale or sharing of your personal information by us. We do not sell or share for cross-context behavioral advertising any of the categories of personal information that we collect about California residents.
• The right to limit our use and disclosure of sensitive personal information to purposes specified in subsection 7027(l) of the California Consumer Privacy Act Regulations. We do not use or disclose sensitive personal information.
• The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, in violation of California Civil Code § 1798.125.

To exercise your access, data portability, and deletion or do not sell opt-out rights described above, you may submit a verifiable consumer request by writing an email at legal@navgar.app

Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may designate an authorized agent. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected which will depend on your prior interactions with us and the sensitivity of the personal information being requested.

We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request.

We will only use the personal information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.

NON-DISCRIMINATION

We will not discriminate against you or any other individual for exercising any of your CCPA rights. Unless and only to the extent permitted by the CCPA, Navgar will not (i) deny you goods or services; (ii) charge you different prices or rates for goods or services; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Childrens’ Privacy

We do not have actual knowledge that we sell or share the personal information of California residents under 16 years of age.

Our Services are not designed for and are not marketed to people under the age of 16 (“minors”). We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our Services. Please contact our Privacy Office if you believe we might have information from or about a minor.

Privacy Policies in other countries

Mexico

Navgar’s Data Processing Agreements

DPA EU/UK

DPA CANADA