Last Updated: November 11, 2019
Welcome to the NaviSavi ("NaviSavi") Privacy Notice.
We respect your privacy and are committed to protecting your personal data. This Privacy Notice explains how we collect, use, disclose, retain and protect your personal data when you visit or use our website, and provides information regarding your privacy rights.
This policy applies to all information we collect on our website and through emails or other electronic communications between you and us.
2. Important Information and Who We Are
2.1. Purpose of this Privacy Notice.
This notice (the "Privacy Notice") aims to give you information on how we collect and process your personal data through your use of our website.
Our website is not intended for persons under 18 years of age. No one under age 18 may provide any personal information to or on our website. We do not knowingly collect personal information from persons under 18. If you are under 18, do not use or provide any information on this website or on or through any of its features, make any purchases through the website, or provide any information about yourself to us. California residents may have additional rights regarding the collection and disclosure of their personal information. Please see the Privacy Notice for California Residents for more information.
It is important that you read this Privacy Notice together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.
NaviSavi, a Nebraska limited liability company, (collectively referred to as "NaviSavi", "we", "us" or "our" in this Privacy Notice) is the controller for your personal data collected through its website.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Where we have a legal obligation to do so, we will appoint a data protection officer (DPO) to be responsible for this Privacy Notice. You can contact our DPO, if one has been appointed, using the details set forth below.
2.3. Changes to the Privacy Notice.
We regularly update our Privacy Notice to account for changes in privacy law or our operations. Your continued use of our Website or your acknowledgement that you have received the update within the Platform will be deemed your acknowledgment of those changes, so please check this Privacy Notice regularly for updates.
2.4. Third-party links.
This Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their Privacy Notices. When you leave our Platform, we encourage you to read the Privacy Notice of every website you visit.
3. The Data We Collect About You
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data that cannot be used to identify an individual (anonymous data).
3.1. Types of Personal Data.
We may collect, use, store and transfer the following kinds of personal data about you:
3.1.1. Identity Data includes first name, last name or similar identifier, date of birth and gender.
3.1.2. Contact Data includes address, email address and telephone numbers.
3.1.3. Financial Data includes bank account and payment card details.
3.1.4. Transaction Data includes details relating to a transaction, such as payments to or from you.
3.1.5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Platform. If you access the Platform through different devices (e.g., your mobile phone or personal computer), the information that we collect and store through those different uses may be cross-referenced and combined, and your contributions from any of those devices or platforms will become part of the Platform.
3.1.6. Profile Data, with respect to a Member or a pseudonymous user, includes all of your personal data which is attributable to that Member or pseudonymous user. If you write reviews about Listed Businesses which you transact through the Platform, we may publicly display the fact that you transacted with those Listed Businesses along with the contents of your review.
3.1.7. Usage Data includes information about how you use our Platform.
3.1.8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your other communication preferences, and our own records of marketing or other communications of which you are the subject, and any other information you provide to us through your submission of a form within the Platform.
4. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
4.1. Direct interactions.
You may give us your Identity, Contact and Financial Data by using our Platform, filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes the personal data you provide when you use our services, give us feedback, or contact us, whether in person, by phone, by email, through social media platforms, or through any other medium.
4.2. Automated technologies or interactions.
As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, web beacons and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies.
4.3. Third parties or publicly available sources.
We may receive personal data about you from various third parties as set out below:
4.3.1 Technical Data from analytics providers; advertising networks; and search information providers.
4.3.2 Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
A cookie is a text file of letters and numbers that we store in your browser or on the hard drive of your computer or mobile device. Cookies contain information that is transferred to your computer's or mobile device's hard drive. Some of these cookies may originate from companies other than NaviSavi, such as Google Analytics.
A web beacon (also referred to as a clear gif, pixel tag, or single-pixel gif) is a electronic file that permits us, for example, to count users who have visited our website or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We use the following types of cookies:
4.4.1 Strictly necessary cookies.
These cookies are required for the operation of our Platform. Our users cannot opt into or out of these cookies.
4.4.2 Analytical/performance cookies.
These cookies allow us to recognize and count the number of visitors and to see how visitors move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily. We will place these cookies unless our users have opted out.
4.4.3 Functionality cookies.
These cookies are used to recognize you when you return to our Platform. This enables us to personalize our content for you and remember your preferences. We will place these cookies unless our users have opted out.
4.4.4 Targeting cookies.
These cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform, and the material displayed on it, more relevant to your interests. We may also share this information with third parties for this purpose. We will only place these cookies with your consent.
California law requires us to disclose how we respond to web browser Do Not Track (DNT) signals. Because there is no industry or legal standard for recognizing or honoring DNT signals, the Platform does not treat users that transmit a DNT signal differently than those users that do not.
5. Purposes for which We Use Your Personal Data
5.1. Fulfillment of Contract.
We use your personal data to fulfill the services that you use through our website, which is our performance of a contract with you.
5.2. Legitimate Interests.
We may use your personal data for any reason that is necessary for our pursuit of our own legitimate interests (or those of a third party) so long as any prospective harms to your rights and freedoms under applicable law does not override those interests. Those legitimate interests include the provision and improvement of the Platform for Users and Listed Businesses.
5.3. Compliance with Legal Obligations.
We may use your personal data to comply with a legal obligation.
Where we collect your consent, we may use your personal information in any manner consistent with that consent.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
5.5.1 Promotional offers from us. We may use your Profile Data to form a view on what we think you may want or need, or what may be of interest to you. Where this information is collected pseudonymously, we may use pseudonymous information to advertise or share with others so they may advertise tailored products and services to a user. If we collect your consent, we may use and share your Profile Data (except payment information) in order to advertise or enable others to advertise tailored goods or services to you. You may opt out of either form of tailored advertising (or withdraw your consent, where applicable) as described in this Privacy Notice.
5.5.2 Third-party marketing. We will collect your express opt-in consent before we share your personal data with any third party for marketing purposes where such consent is required under applicable law.
5.5.3 Opting out. You can opt out of (i) our disclosure of your Personal Information to third parties that are not agents of, or providers of service to, us, or (ii) our use of your Personal Information for direct marketing purposes by contacting us as provided below.
5.5.4 "Do Not Sell My Personal Information", or by using any opt-out mechanism we make available within the Platform. Please note that, even if you have opted out of sharing with third parties, your Personal Information may still be disclosed to third parties to the extent that you provide it to the general public.
5.6. Change of purpose.
We will use your personal data only for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of Your Personal Data
We may share your personal data with the parties set out below:
Service providers who provide video processing, payment processing, IT and system administration services, professional advice (including lawyers, bankers, auditors and insurers, who provide consultancy, banking, legal, insurance and accounting services), and other related services.
Joint Marketing Partners.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
Law enforcement, judicial or similar officers, to comply with legal requirements, court orders, or investigations.
We may also receive personal data from these parties. We require all third parties with whom we contract to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes except as described in this Privacy Notice and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
We will retain your personal data only for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Data Access
9.1. Your Rights.
Under certain circumstances, you have rights under the data protection laws in relation to your personal data. Such rights may include the right to:
Request access to your personal data.
Request deletion of your personal data.
Correct your personal data.
Object to the processing of your personal data.
Request that your personal data be transferred to another person.
Request restriction of processing your personal data.
Withdraw your consent to the processing of your personal data.
If you wish to exercise any of those rights, please contact us as provided below. You may also have the right to lodge a complaint with your applicable supervisory authority in the event we violate applicable data protection laws.
9.2. No fee normally required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may (a) charge a reasonable fee, or (b) refuse to comply with your request, if your request is clearly unfounded, repetitive or excessive, to the extent permitted by law.
9.3. What we may need from you.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.4. Time limit to respond.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9.5. Your California or Nevada Privacy Rights.
If you are a California or Nevada resident, California or Nevada law may provide you with additional rights regarding our use of your personal information. To learn more about your California or Nevada privacy rights, visit our Privacy Notice for California and Nevada Residents.
10. International Transfers
If you are located in the European Economic Area, your personal data may be stored in or transferred to countries outside the European Economic Area for the purposes described in this Privacy Notice when you use the Platform. Whenever we store or transfer your personal data outside the European Economic Area, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. We may transfer data from the European Economic Area:
to a country recognized by the European Commission as providing an adequate level of protection;
to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses promulgated by the European Commission; or
to any country provided that we have implemented other appropriate cross-border transfer solutions to provide adequate protection under applicable law.
11. Contact Information
To ask questions about Privacy Notice or our privacy practices, or to exercise your rights under applicable data protection laws, please send an email to email@example.com, or a letter to:
Attn: Data & Privacy
807 Central Street
12.1. "Content" means all content available on the Platform, including but not limited to any of Your Content and all LB Content.
12.3. "Joint Marketing Partner" means any third party with whom we have a joint marketing agreement.
12.4. "Member" means a registered user of the Platform.
12.5. "Messaging" includes written communication within, and telephone calls initiated using the Platform.
12.6. "NaviSavi Affiliates" means any of our affiliates or subsidiaries, or any of their or our respective owners, managers, officers, employees, agents or representatives.
12.7. "Payment Management Vendor" means any third party contracted by NaviSavi to process payments on the Platform.
12.8. "Platform" means the Website, our iOS application, and our Android application.
12.9. "Privacy Notice" means our disclosure of our privacy practices, which is located at navisaviapp.com/privacy-policy.
12.10. "Promotion" means an offer from NaviSavi to discount or reimburse a user for the cost of certain Services.
12.11. "Promotion Terms" means any terms and conditions set forth in a Promotion pertaining to that Promotion.
12.12. "LB Content" means any offers, responses, writings, and other content that a Listed Business generates when it uses the Platform.
12.13. "LB Tools" means certain tools that we offer exclusively to Listed Businesses including, without limitation, the ability to review user Content pertaining to your Listed Business, the ability to submit responses to user Content, the ability to update and maintain profile information on your Listed Business, the ability to utilize the dispute resolution process offered through the Website and facilitated by NaviSavi, and any of the other services that we may offer to Listed Businesses from time to time.
12.14. "Listed Business Affiliates" means individuals affiliated with a Listed Business, including without limitation any current or former owners, current or former employees or officers, family members, or current or former partners, investors, managers or directors.
12.15. "Services" means services offered to a user by a Listed Business.
12.16. "Technical Issues" means limitations, delays and other problems inherent to the use of the internet and electronic communications.
12.19. "Transaction" means each time that a Listed Business collects payment from a user for its Services.
12.20. "User ID" means a unique account number issued to each Member.
12.21. "Website" means navisaviapp.com.
12.22. "Your Content" means content submissions, including discussion posts, profile information and links, pictures, reviews, and other such content that you submit via the Platform.
Last Updated: November 7, 2019
This Privacy Notice for California and Nevada Residents supplements the information contained in NaviSavi's Privacy Notice and applies solely to all visitors, users, and others who reside in the States of California and Nevada. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and NRS § 603A. Any terms defined in the CCPA have the same meaning when used in this notice. Any other terms defined in Navi Savi's Privacy Notice have the meanings ascribed to them in that Privacy Notice.
1. Information We Collect
Our Platform collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our Platform has collected, transferred to one of our service providers in connection with our provision of the (disclosed), and transferred for other reasons (sold) the following categories of personal information from its consumers within the last twelve (12) months:
Personal information does not include:
Publicly available information from government records.
Non-identifiable, de-identified, or aggregated consumer information.
Information excluded from the CCPA's scope, like certain health or medical information and other categories of information protected by different laws.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, we collect information that you provide in online forms or provide in order to fulfill a purchase.
Indirectly from you. For example, we collect data generated from your actions on our Platform.
2. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To advertise products or services in which we think you may be interested.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our or our affiliates' assets in which personal information held by us or our affiliates about our website users is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
3. Sharing Personal Information
We may disclose your personal information to service providers for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We sell your personal information with the following categories of third parties:
You may limit these sales as described below.
4. Your Rights and Choices
The CCPA and NRS § 603A provide California and Nevada residents with specific rights regarding their personal information. This section describes your CCPA and NRS § 603A rights and explains how to exercise those rights.
4.1. Opt-Out Rights.
You can opt out of our sales of your personal information by contacting us as provided below, or by using any opt-out mechanism we make available within the Platform. Please note that, even if you have opted out of sharing with third parties, your Personal Information may still be disclosed to third parties to the extent that you provide it to the general public.
4.2. Access to Specific Information and Data Portability Rights.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. If we receive and confirm your verifiable consumer request
(see Exercising Access, Data Portability, and Deletion Rights),
we will disclose to you:
The categories of personal information we've collected about you.
The categories of sources for the personal information we've collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we've collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
4.3. Deletion Request Rights.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
4.4. Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us using the contact information below.
Only you, or a person registered with the California or Nevada Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we've collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
4.5. Response Timing and Format.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as provided below.
7. Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update the notice's effective date.
Your continued use of our website following the posting of changes constitutes your acknowledgment of such changes.
8. Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: