Navv Systems, Inc. Privacy Policy

At Navv Systems, Inc. (Navv), privacy and security are part of our core values and are built into our service. We respect the privacy and confidentiality of individuals who visit Navv’s websites ("Visitors"), Organizations and their registered users who use our services and apps ("Corporate Subscribers"), Corporate Partners who develop applications using Navv's APIs ("API Partners"), Corporate Partners engaged in selling Navv's products ("Sales Partners") and individuals or companies seeking a business relationship with Navv ("Applicants").

This Privacy Statement describes Navv's privacy practices in relation to general business practices, the use of the Company's websites and the use of applications and services offered by Navv ("Services"). By visiting our websites or providing us with your personal information, you consent to the collection, processing, and storage of your personal information as described in this Privacy Policy.

This Privacy and Security Policy covers the information practices of websites that link to this policy, collectively referred to as Navv's websites. https://navvtrack.com is our public website. Navv's websites may contain links to other websites. The privacy statements of those websites govern the information practices and the content of those websites. Navv encourages you to review the privacy statements of other websites to better understand their information practices.

1. GENERAL

We know that your privacy is important to you, and we work hard to earn and keep your trust.  Navv Systems, Inc. (“Navv,” “Company”, “we,”“us,” and “our”), respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”). The words “you” and “your” refer to you as a user of the Website (defined below),either as a visitor, registered user, customer, or employee of a Navv customer.

This Policy describes:

•     The types of information we collect from you or that you may provide when you visit our website(s) available at: https://www.navvtrack.com/ as well       as any websites and blogs directly owned by the Company where this Policy is linked (collectively, our “Website”).
•     Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on the Website or in emails and other electronic messages between you and the Website, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Navv or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. THE INFORMATION WE COLLECT

Personal Information. To ensure that we provide you with the best possible experience, we will store, use, and disclose personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). The Personal Information that we may receive and collect depends on what you do when you visit our Website.

Information of Other Individuals. You may have the opportunity to provide information of other individuals. When providing such information, you are solely responsible for obtaining the necessary consents and authorizations from any individuals in accordance with applicable data security laws and regulations, and Navv shall not be responsible or held liable for your failure to obtain the necessary consents.

Aggregated and De-Identified Data.We may also collect, use and disclose aggregated and de-identified data such as statistical or demographic data for any purpose. Aggregated and de-Identified data could be derived from your Personal Information but is not considered Personal Information under applicable law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated or de-identified data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting Navv to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Username and Password; Other Sources.We may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Additionally, we may receive information about you from other sources and add it to the information you have provided to us.

(a) Information We May Collect on the Website

You may have the opportunity to provide Personal Information on our Website, including but not limited to:

•     Personal identifiers: first and last name; postal address; telephone number; email address.
•     Internet activity: browsing history; search history; information in relation to our Website.
•     Professional or employment related information: Current or past job history in relation to a resume.

We may obtain the Personal Information listed above from the following categories of sources:

•     Directly from you. For example, when you:
        - Schedule a consultation;
        - subscribe to one of our e-newsletters;
        - review or comment on one of our products;
        - submit a job application; or
        - otherwise communicate with us, such as contacting us for more information.
•     Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
•     Directly and indirectly from activity on our Website. For example, from Website usage details that are collected automatically. For more information       on automatic information collection, please review the “Automated Information Collection” section below.  

3. AUTOMATED INFORMATION COLLECTION

Website. In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

(a) Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and       we may use either (or both) of them:

    (1) session cookies, which do not stay on your device after you close your browser, and

    (2) persistent cookies, which remain on your device until you delete them or they expire.

We may use the following categories of cookies on our Website.

          i. Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without           these cookies, services you have requested cannot be provided.

          ii. Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at           our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never           shows personal details from which your individual identity can be established.

          iii. Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred           language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections           and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies           cannot track your browsing activity on other websites.

          iv. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more           relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the           effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the           websites you visit and that information is shared with other parties, such as advertisers.


Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

(b) Google Analytics. The Website sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to       conduct technical and statistical analysis on the Website’s performance. For more information on how Google Analytics supports the Website and       uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

(c) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a       web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your       reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party       marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only       collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web       Beacon.

(d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the       link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email       recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal       Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing       campaigns.

(e) Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers       may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The       information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example,       we may collect data where our banner advertisements are displayed on third-party websites. For example, when you visit our Website, cookies and       similar technologies may be used by our online data partners or vendors, such as GetEmails, LLC d/b/a R! B2B, to associate these activities with       other Personal Information they or others have about you, including by association with your email or home address. We (or service providers on       our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by       visiting https://app.retention.com/optout.

4. HOW WE USE YOUR INFORMATION

The information we gather and that you provideis collected to provide you information and the services you request, inaddition to various other purposes, including, but not limited to:

•     security, credit or fraud prevention purposes;
•     providing you with effective customer service;
•     providing you with a personalized experience when you use the Website;
•     developing new products and services;
•     contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have           expressed to us);
•     contacting you with information and notices related to your use of the Website;
•     inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
•     better understanding your needs and interests;
•     improving the content, functionality and usability of the Website;
•     improving our products and services;
•     improving our marketing and promotional efforts; and
•     any other purpose identified at the point of data collection, in an applicable privacy notice, in a click-through agreement or in any other agreement        between you and us.

Duration. The length of time Navv intends to retain PersonalInformation, including sensitive personal information, if any, is for as longas reasonably necessary to carry out Navv’s intended business purpose for such information.  

5. HOW WE DISCLOSE YOUR INFORMATION

We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose, including the following categories of third parties:

•     Our Affiliates. We may disclose the information collected through the Website with our affiliates, subsidiaries, or other related entities in order to        provide our products, services and effective customer support.
•     Third-party ServiceProviders. We disclose Personal Information collected through the Website with third-party Service Providers who act for or on       behalf of Navv. These third parties may need information about you to perform their functions. “Service Providers” may include suppliers, dealers,       distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order       fulfillment, information technology and related infrastructure support, customer service, email delivery, and auditing.
•     With Other Carefully Selected Business Partners. From time to time, we may disclose your Personal Information with selected third parties(other       than our service providers). For example, we partner with third parties to sponsor promotions, and we may disclose with these third parties       thePersonal Information you submit to us to take advantage of the promotion. Before doing so, however, we may offer you the opportunity to “opt       out” or “opt in” as required by applicable law.”
•     Businesses. We may disclose your information with your applicable Business, such as, but not limited to, when managing all active accounts under       the Business’ subscription with us. Navv is not responsible or liable for any uses of your information or your content by your applicable Business.
•     In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing       and other business interests of Navv. Such use shall not include PersonalInformation or information that can identify you as an individual or       reasonably be used to identify you.

Except as described in this Policy, we will not disclose your information with third parties without your notice and consent, unless it is under one of the following circumstances:

•     LegalReasons.
          o  We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
          o  To respond to duly authorized information requests from law enforcement or other governmental authorities;
          o  To enforce our agreements or policies;
          o  To investigate and prevent security threats, fraud, or other malicious activity; or
          o  To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious                bodily injury of any person or Navv employee.

•    Sale of Business or Merger. There are circumstances where Navv may decide to buy, sell, or reorganize its business. Under these circumstances, it       may be necessary to disclose or receive Personal Information with prospective or actual purchasers, acquisition targets, partners or affiliates. In       such circumstances, Navv will ensure your information is used in accordance with this Policy.

6. YOUR CHOICES AND SELECTING YOUR
PRIVACY PREFERENCES

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to whatinformation we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails. You may opt out of them at any time by selecting the“unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Even if you opt-out of receiving marketing material, we may still need to contact you with important information about your account or responding to your requests or questions.   

7. ACCURACY AND ACCESS TO YOUR PERSONAL INFORMATION

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing. Where we can provide you access to your Personal Information in our possession, we will always ask you for a user name and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.  To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

8. INFORMATION OF MINORS

We do not knowingly collect or use information from individuals under the age of eighteen (18) without parental or guardian consent. We do not target the Website to minors and would not expect them to be engaging with the Website or our services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors under the age of eighteen (18), we will take steps to securely remove it from our systems.  

9. THIRD-PARTY WEBSITES

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services. For example, if you click on an advertisement on the Website, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.  

10. YOUR RIGHTS UNDER STATE LAWS

California.

•    Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for       the purposes of third-party marketing to you without your prior consent.
•    Do Not Track Signals. Other than as disclosed in this Policy, thePlatform does not operate any differently when it receives Do Not Track signals from       your internet web browser.
•    WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or“share” Personal Information, as those terms are       defined under the CaliforniaConsumer Privacy Act of 2018, as amended by the California Privacy Rights Actof 2020 (“CCPA”), we will update you       via this Policy and include a linkentitled “Do Not Sell or Share My Personal Information,” to provide you with anopportunity to opt out of the selling or       sharing of your Personal Information.

Nevada.

Nevada law permits customers in Nevada to opt-out of the sale of certain kinds ofPersonal Information. We do not sell your Personal Information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your Personal Information, should we change our practices in the future, you can contact us at: privacy@navv-systems.com or any other methods listed in this Policy.

Your Consumer Rights.

Some state laws in the United States provide consumers with additional rights with respect to their Personal Information(also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, theCCPA, the Colorado Privacy Act and its implementing regulations (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Montana Consumer Data Privacy Act(“MTCDPA”), the Oregon Consumer Data Protection Act (“OCPA”), the Texas DataPrivacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”) (collectively “U.S. PrivacyLaws”). Any Personal Information we collect is for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about the Platform, Navv’s products or services. If you are a consumer in a state that provides consumer rights, please be advised that Navv Systems, Inc. is NOT a“business” or “controller” as that term is defined under U.S. Privacy Laws and therefore does not afford consumers these rights with respect to their PersonalInformation. Regardless, all Personal Information will be processed in accordance with this Policy.

11. LOCATION OF OUR WEBSITE AND SERVICES

We do not warrantor represent that this Policy or the Website’s use of your Personal Information complies with the laws of every jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the UnitedStates and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.  

12. SAFEGUARDING THE INFORMATION WE COLLECT

We use reasonabletechnical, administrative, and physical safeguards in order to protect yourPersonal Information against accidental loss and from unauthorized access, use,alteration, and disclosure. However, we can never promise 100% security. Youhave a responsibility, as well, to safeguard your information through theproper use and security of any online credentials used to access your PersonalInformation, such as a username and password. If you believe your credentialshave been compromised, please change your password. Please also notify us immediatelyof any actual or suspected unauthorized use of the Website or your information.  

13. CHANGES TO THIS POLICY

This Policy describes our current policies and practices with regard to the information we collect through the Website. We are continually improving and adding to the features and functionality of the Website along with the products and services we offer through the Website. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

14. HOW TO CONTACT US

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at privacy@navv-systems.com or by mail/phone at:

Data Protection Officer
Navv Systems, Inc.
330 E. Liberty Street, Suite 3B
Ann Arbor, MI  48104
+1 313-566-4845