Navin Systems Ltd. (“Navin”, “we”, “our” or “us”) offer community-based indoor positioning and navigation services. We put great efforts in making sure that the personal information processed by us is safe and used properly, and that our data practices are properly communicated to users and visitors (“Users”).

This Privacy Policy describes how we collect, store, use and disclose personal information relating to any Users who visit or otherwise interact with our mobile app and related websites (collectively the “Site”), and any online ads and content, or emails or communications in relation to the Site. This Privacy Policy apply to all services offered by us as more described in our Terms of Use https://nav-in.com/wtac/.

Specifically, this Privacy Policy covers:

1. Information We Collect
2. How Do We Use The Information Collected
3. Where We Store Personal Information
4. Retaining Your Information
5. Sharing Your Information
6. Cookies and Tracking Technologies
7. Communications
8. Information Security
9. Your Rights
10. Additional Notices

Please read this Privacy Policy (this “Policy”) carefully and make sure that you fully understand it.

Please note that you are not legally required to provide us with any personal information. If you do not wish to provide us with your personal information, or to have it processed by us or any of our Service Providers (defined below), please avoid of using our services or submit a request to exercise your rights as further explained in Section ‎9 below.

1. Information We Collect

We collect and generate the following types of personal information concerning our Users:

• • Website usage information (connectivity, technical and aggregated usage data), user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on their device.
  • Geographic location and route information history. This information is retained by us for unlimited period of time and in accordance with this Policy.
  • User information that you provide us, such as information you provide when submitting an online form on the Site, including the “Get In Touch” form, such as, your first and last name, e-mail address, or information we collect by contacting us or interacting with us through any other means. In this respect, please do not provide us with any personal information which is not required by us to process your request or inquiry. We collect such data either automatically, through your interaction with us or with our Site, or through third party services such as, social media and analytics tools.

2. How We Use the Information Collected

We use Users’ personal information as necessary for the operation and provision of the Site; to comply with our legal and contractual obligations; to support our legitimate interests in maintaining and improving our Site, e.g. in understanding how our Site is used, and gaining insights which help us dedicate our resources and efforts more efficiently; to help us effectively provide you services; in marketing, advertising and selling our services; providing customer service and technical support; and protecting and securing our customers, Users, ourselves and our services.
If you reside or are using the Site or our services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal information as described herein (in general, or specifically with respect to the types of personal information you expect or elect to process or have processed by us), your acceptance of our Policy will be deemed as your consent to the processing of your personal information for all purposes detailed in the Policy. If you wish to revoke such consent, please contact us via info@nav-in.com.
Specifically, we use our Users’ personal information for the following purposes:

• • To facilitate, operate, and provide the Site.
  • To monitor, study and analyze use of the Site.
  • To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you.
  • To enforce our Terms of Use, Terms of Service, this Policy and other contractual arrangements, to comply with court orders and warrants, and prevent misuse of the Site and to take any action in any legal dispute and proceeding.
  • To gain a better understanding on how individuals use and interact with our Site and services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Site and services.
  • To facilitate and optimize our sales operations.
  • To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.
  • To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
  • To comply with applicable laws and regulations.

3. Where we store personal information

We and our authorized Service Providers (defined below) maintain, store and process personal data in the U.S and other locations, as reasonably necessary for the proper performance and delivery of our Site and its services, or as may be required by law. While privacy laws may vary between jurisdictions, we committed to protecting personal information in accordance with this Policy and customary industry standards, regardless of any lesser legal requirements that may apply in other jurisdictions.

4. Retaining your Information

We retain your personal information only for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Site and offerings; in order to comply with our legal and contractual obligations; to pursue our legitimate business purposes; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal information for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice. If you have any questions about our data retention policy, please contact us via e-mail at info@nav-in.com.

5. Sharing your information

Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal information, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Site, products, and services.
Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers may include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session, call or activity recording and analysis services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal information, depending on each of their specific roles and purposes in facilitating and enhancing the Site, and may only use the information for such limited purposes as determined in our agreements with them.
Third Party Websites and Services: Our Site may include links to third party websites, and integrations with third party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third party’s terms and privacy practices and policies, and not by this Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services. This Policy applies only to the Site and to our services.
Protecting Rights and Safety: We may share personal information with others if we believe in good faith that this will help protect the rights, property or personal safety of the Site, our services, any of our Users or any members of the general public.

6. Cookies and Tracking Technologies

We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable or aggregated extracts of such information with our partners for our legitimate business purposes.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Site.
We also use analytics tools such as Google Analytics. These tools help us understand users’ behavior on the Site, including by tracking page content, and click/touch, movements, scrolls and keystroke activities.
Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/;
Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout;

7. Communications

We may engage you in service and promotional communications through e-mail, phone, SMS and notifications. We may also notify you about new features, additional offerings or any other information we think you may find valuable. We may provide such notices through any of the contact means available to us (e.g., e-mail) or through the Site or the services.
If you do not wish to receive such promotional communications, you may notify us at any time by via an e-mail to: info@nav-in.com, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

8. Information Security

We implement systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, although we make efforts to protect your privacy, we cannot guarantee that our Site will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

9. Your Rights

Individuals have rights concerning their personal information. Please contact us by e-mail via info@nav-in.com.
Please note that when you ask us to exercise any of your rights under this Policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of information or data that you request to access. Such additional information will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).
We may redact from the data which we will make available to you, any personal information related to others.

10. Additional Notices

Updates and Amendments: We may update and amend this Policy from time to time by posting an amended version on the Site. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Site. After such notice period, all amendments shall be deemed accepted by you.
Children: Our Site is not designed to attract children under the age of 16. We do not knowingly collect personal information from children and do not wish to do so. If we learn that a person under the age of 16 is using the Site, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal information stored with us with regard to such child. If you believe that we might have any such data, please contact us via info@nav-in.com.
Questions, Concerns or Complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal information held with us, please contact us via: info@nav-in.com. If you are a GDPR or UK-GDPR protected individual, you also have the right to lodge a complaint with an EU supervisory authority, or the UK Information Commissioner’s Office, as appropriate.