Privacy Policy

Last updated: September 17th, 2020

This Privacy Policy describes how we collect and use your personal information in relation to Navalapp websites, applications, products, services, events, and experiences that references this Privacy Policy (together, “Navalapp Offerings”).

This Privacy Policy does not apply to the “content” processed, stored, or hosted by our customers using Navalapp Offerings in connection with a Navalapp account. See the agreement governing your access to your Navalapp account for more information about how we handle content and how our customers can control their content through Navalapp Offerings. This Privacy Policy also does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy.

Where we provide the Services under contract with an organization (for example, your employer) that organization controls the information processed by the Services. This policy does not apply to the extent we process personal information in the role of a processor on behalf of such organizations.

If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

Personal information we collect

We collect your personal information in the course of providing Navalapp Offerings to you.

Here are the types of information we gather:

• Information you give us: We collect any information you provide in relation to Navalapp Offerings. Click here to see examples of information you give us.
• Automatic information: We automatically collect certain types of information when you interact with Navalapp Offerings. Click here to see examples of information we collect automatically.
• Information from other sources: We might collect information about you from other sources, including service providers, partners, and publicly available sources. Click here to see examples of information we collect from other sources.

How we use personal information

We use your personal information to operate, provide, and improve Navalapp Offerings. Our purposes for using personal information include:

• Provide Navalapp Offerings: we use your personal information to provide and deliver Navalapp Offerings and process transactions related to Navalapp Offerings, including registrations, subscriptions, purchases, and payments.
• Measure, support, and improve Navalapp Offerings: we use your personal information to measure use of, analyze performance of, fix errors in, provide support for, improve, and develop Navalapp Offerings.
• Recommendations and personalization: we use your personal information to recommend Navalapp Offerings that might be of interest to you, identify your preferences, and personalize your experience with Navalapp Offerings.
• Comply with legal obligations: in certain cases, we may have a legal obligation to collect, use, or retain your personal information.
• Communicate with you: we use your personal information to communicate with you in relation to Navalapp Offerings via different channels and to respond to your requests.
• Marketing: we use your personal information to market and promote Navalapp Offerings.
• Fraud and abuse prevention: we use your personal information to prevent and detect fraud and abuse in order to protect the security of our customers, Navalapp, and others.
• Purposes for which we seek your consent: we may also ask for your consent to use your personal information for a specific purpose that we communicate to you.

Cookies

We use cookies, pixels, and other similar technologies (collectively, “cookies”) to recognize your browser or device, learn more about your interests, provide you with essential features and services, and for additional purposes, including:

• Recognizing you when you sign in use our offerings. This allows us to provide you with recommendations, display personalized content, and provide other customized features and services.
• Keeping track of your specified preferences. This allows us to honor your likes and dislikes, such as your language and configuration preferences.
• Conducting research and diagnostics to improve our offerings.
• Preventing fraudulent activity.
• Improving security.
• Delivering content, including ads, relevant to your interests.
• Reporting. This allows us to measure and analyze the performance of our offerings.

Navalapp cookies allow you to take advantage of some of essential Navalapp features. For instance, if you block or otherwise reject our cookies, you might not be able to use certain offerings that require you to sign in, or you might have to manually adjust some preferences every time you visit Navalapp sites.

Approved third parties may also set cookies when you interact with our offerings. Third parties include cloud providers, search engines, providers of measurement and analytics services, social media networks, and advertising companies. Cookies set by these third parties do not enable them to automatically collect through Navalapp any personally identifiable information such as name or email address. Third parties use cookies in the process of delivering content, including ads relevant to your interests, to measure the effectiveness of their ads, process payments, and to perform services on behalf of Navalapp. Some of the third parties that may set cookies when you use Navalapp Offerings are:

• Amazon Web Services: https://aws.amazon.com/
• Google: http://www.google.com/
• Stripe: https://stripe.com/

Click here for specific information about cookies related to our site at https://navalapp.com.

How we share personal information

Information about our customers is an important part of our business and we are not in the business of selling our customers’ personal information to others. We share personal information only as described below and with other companies of the group that are either subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy.

• Third-party service providers: we employ other companies and individuals to perform functions on our behalf. Examples include: sending communications, processing payments, analyzing data, providing marketing and sales assistance (including advertising and event management), conducting customer relationship management, and providing training. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process that information in accordance with this Privacy Policy and as permitted by applicable data protection law.
• Business transfers: as we continue to develop our business, we might sell or buy businesses or services. In such transactions, personal information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the individual consents otherwise). Also, in the unlikely event that Navalapp or substantially all of its assets are acquired, your information will of course be one of the transferred assets.
• Protection of us and others: we release account and other personal information when we believe release is appropriate to comply with the law, enforce or apply our terms and other agreements, or protect the rights, property, or security of Navalapp, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and detection and credit risk reduction.
• At your option: other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.

Location of personal information

Navalapp is located in Finland. Depending on the scope of your interactions with Navalapp Offerings, your personal information may be stored in or accessed from Finland, Ireland, or/and the United States. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection laws.

How we secure information

At Navalapp, security is our highest priority. We design our systems and offerings with security and privacy in mind.

• We protect the security of your information during transmission to or from Navalapp websites, applications, products, or services by using encryption protocols and software.
• We and our third-party suppliers maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

Internet advertising and third parties

Navalapp Offerings may include third-party advertising and links to other websites and applications. Third party advertising partners may collect information about you when you interact with their content, advertising, or services.

Access and choice

You can view, update, and delete certain information about your account and your interactions with Navalapp Offerings. If you cannot access or update your information yourself, you can always contact us for assistance.

You can choose not to provide certain information, but then you might not be able to take advantage of certain Navalapp Offerings.

Children’s personal information

We don’t provide Navalapp Offerings for purchase by children. If you’re under 18, you may use Navalapp Offerings only with the involvement of a parent or guardian.

Retention of personal information

We keep your personal information to enable your continued use of Navalapp Offerings, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by law (including for tax and accounting purposes), or as otherwise communicated to you. How long we retain specific personal information varies depending on the purpose for its use, and we will delete your personal information in accordance with applicable law.

Additional information for certain jurisdictions

We provide additional information about the privacy, collection, and use of personal information of prospective and current customers of Navalapp Offerings located in certain jurisdictions.

For any prospective or current customers of Navalapp Offerings in Canada:

Your Rights. Subject to applicable law, you have the right to:

• ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;
• request that inaccurate personal information is corrected;
• request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements; and
• lodge a complaint with us regarding our practices related to your personal information.

You can exercise your rights of access, rectification, erasure, restriction, or complaint by contacting us at privacy@navalapp.com.

For any prospective or current customers of Navalapp Offerings in the European Economic Area (EEA):

Controller of Personal Information. Navalapp, part of Elakoon, Svinhufvudintie 2 D 30, 00570, Helsinki, Finland.

Processing. We process your personal information on one or more of the following legal bases:

• as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide Navalapp Offerings, to respond to requests from you, or to provide customer support;
• where we have a legitimate interest, as described in this Privacy Notice (see How we use personal information above);
  as necessary to comply with relevant law and legal obligations, including to
• respond to lawful requests and orders; or
• with your consent.

Your rights. Subject to applicable law, you have the right to:

• ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;
• request that inaccurate personal information is corrected;
• request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;
• request us to restrict the processing of personal information where the processing is inappropriate;
• object to the processing of personal data;
• request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means; and
• lodge a complaint with our principal supervisory authority, the Finnish Data Protection Authorities Office of the Data Protection Ombudsman, P.O. Box 800, FIN-00521, Helsinki, Finland. Telephone: +358 29 56 16670. Email: tietosuoja[at]om.fi. Website: http://www.tietosuoja.fi

You can exercise your rights of access, rectification, erasure, restriction, objection, and data portability by contacting us at privacy[at]navalapp.com

When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

Transfers outside of the EEA. When we transfer your personal information outside the EEA, we do so in accordance with the terms of this Privacy Notice and applicable data protection law.

Contacts, Notices, and Revisions

If you have any concern about privacy at Navalapp or want to contact us, please contact us at privacy@navalapp.com with a thorough description, and we will try to resolve it. You may also contact us at the following address: Navalapp, Svinhufvudintie 2 D 30, 00570, Helsinki, Finland.

If you interact with Navalapp Offerings on behalf of or through your organization, then your personal information may also be subject to your organization’s privacy practices, and you should direct privacy inquiries to your organization.

Our business changes constantly, and our Privacy Policy may also change. You should check our website frequently to see recent changes. You can see the date on which the latest version of this Privacy Policy was posted. Unless stated otherwise, our current Privacy Policy applies to all personal information we have about you and your account. We stand behind the promises we make, however, and will never materially change our policies and practices to make them less protective of personal information collected in the past without informing affected customers and giving them a choice.

Examples of information collected

Information you give us

You provide information to us when you:

• subscribe to, or purchase Navalapp Offerings;
• create or administer your Navalapp account (and you might have more than one account if you have used more than one email address when using Navalapp Offerings);
• configure your settings for, provide data access permissions for, or otherwise interact with Navalapp Offerings;
• register for or attend a Navalapp event;
• purchase or use content, products, or services from third-party providers through Navalapp;
• communicate with us by phone, email, or otherwise;
• complete a questionnaire, a support ticket, or other information request forms; and
• post on Navalapp websites or participate in community features.

Depending on your use of Navalapp Offerings, you might supply us with such information as:

• your name, email address, physical address, phone number, and other similar contact information;
• payment information;
• information about your location;
• information about your organization;
• usernames, aliases, roles, and other authentication and security credential information;
• content of feedback, testimonials, inquiries, support tickets, and any phone conversations, chat sessions and emails with or to us;
• your image (still, video, and in some cases 3-D), voice, and other identifiers that are personal to you when you attend a Navalapp event or use certain Navalapp Offerings;
• information regarding identity, including government-issued identification information; and
• VAT numbers and other tax identifiers.

Automatic information

We collect information automatically when you:

• visit, interact with, or use Navalapp Offerings (including when you use your computer or other device to interact with Navalapp Offerings);
• download content from us;
• open emails or click on links in emails from us; and
• interact or communicate with us.

Examples of the information we automatically collect include:

• network and connection information, such as the Internet protocol (IP) address used to connect your computer or other device to the Internet and information about your Internet service provider;
• computer and device information, such as device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting;
• the location of your device or computer;
• authentication and security credential information;
• content interaction information;
• Navalapp Offerings metrics, such as offering usage, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs;
• the full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and Navalapp Offerings, content you viewed or searched for, page response times, download errors, and page interaction information (such as scrolling, clicks, and mouse-overs);
• identifiers and information contained in cookies.

Information from other sources

Examples of information we receive from other sources include:

• marketing, sales generation, and recruitment information, including your name, email address, physical address, phone number, and other similar contact information;
• subscription, purchase, support, or other information about your interactions with products and services offered by us, our affiliates, or third parties in relation to Navalapp Offerings;

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