Effective Date: March 11, 2021
Naviant, Inc. is responsible for processing your personal data as described in this Policy. The term Personal Data as used in this Policy means information related to an individually identifiable natural person.
This policy contains the following sections:
Information We Collect
Information You Provide to Us. We collect information you provided directly to us. For example, we collect information when you complete our online contact form. This information may include Personal Data. The Personal Data you might choose to submit through the Site or at Naviant Events may include your:
- Name, physical address, and contact information, including e-mail and telephone numbers;
- Job title;
- Account profile, including your interests and photograph;
- Dietary preferences and restrictions;
- Order information for trainings courses;
- Questions, feedback, comments and other postings; and
- Other information you choose to provide.
Data Analytics. The Site uses third-party web analytics services, such as Google Analytics, to help us analyze how visitors use the Site. These services track information about visitors, including IP addresses, browser types, referring pages, pages visits and time spent on particular pages. We use this information to improve our products and services, to market our products and services to you, and to customize your experience when using the Site. To learn more about how Google Analytics may use information collected through the Site, click here.
We may link individually identifiable information that you provide voluntarily (e.g., your name and contact information) to the information that the Site collects automatically (e.g., data analytics).
Do Not Track Setting. We track your online activities over time and across third-party websites or online services. We also track your activities on the Site. Additionally, we use web beacons to track your visits so that third-party service providers can display Naviant advertisements to you on other websites based on your activities while visiting the Site. We may allow third-party service providers to use tracking devices to collect the same types of information for the same purposes as we collect your information. You may implement restrictions on tracking, such as plug-ins or browser settings. In that case, some features of the Site, for example, personalization or authentication, may not work as designed.
Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, the Site is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, click here.
Information Third Parties Provide About You. If you attend a Naviant Event sponsored by a third-party, that third-party may provide Naviant with your information, including Personal Data, such as your name, e-mail address, and phone number. Additionally, at times, Naviant posts advertisements on third-party websites. These third parties typically inform Naviant if a user clicks on our advertisements.
How We Use Your Information
We may use the information, including Personal Data, we obtain through the Site or Naviant Events, as applicable, for a number of purposes, including:
- To improve and customize the online user experience;
- To respond to e-mails or other requests, comments or questions;
- To provide customer support;
- To provide you with information that we believe may be useful to you, such as information about products or services we offer;
- To maintain records of our transactions and communications;
- To monitor and analyze trends, usage, and activities of the Site users;
- To measure and improve our online ad performance and retarget website visitors;
- To report suspected criminal acts;
- To comply with applicable laws, regulations, or legal process as well as industry standards and our company policies; or
- To prevent fraud or other misuse, including by protecting our rights and the rights of related third parties.
In addition, we may use the Personal Data we obtain about you in other ways for which we provide notice at the time of collection.
How We Share Your Information
We may share your Personal Data with:
- Third Party Service Providers under Contract with Naviant. For example, data analytics providers, event management companies, credit card processors, website management, law firms, auditors, marketing and advertisement companies, and other similar providers. We share your Personal Data with these Service Providers so that they can perform certain business functions on behalf of Naviant.
- Other Unaffiliated Third Parties. We may share your Personal Data with other unaffiliated third parties for the following purposes:
- Required Disclosures. To comply with a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
- Government Agency Requests. To respond to a request by a government agency.
- Legal Compliance and Protection. To comply with the law or to protect the rights, property, or safety of Naviant, our users, or others. This may include sharing information, including Personal Data, with other companies and organizations for fraud protection and credit risk reduction.
- Corporate Transactions: In the event of a corporate merger, consolidation, sale, assignment, bankruptcy (or similar proceeding), or other disposition of a portion or of all our business, assets, or stock.
We may share aggregated information about our users and information that does not identify any individual user without restriction.
We do not rent, lease, or sell your Personal Data to third parties.
How We Secure Your Information
We maintain appropriate physical, electronic, and administrative safeguards designed to protect the Personal Data that we obtain in accordance with this Policy. Although we use reasonable efforts to secure such information, transmission via the internet is not completely secure, and we cannot guarantee the confidentiality of information transmitted to us over the internet.
Your Choices Regarding Your Personal Data
You may request that we update, correct, or delete your Personal Data collected through the Site or at Naviant Events by emailing firstname.lastname@example.org. To help protect your privacy and security, we may take reasonable steps to verify your identity prior to honoring any such requests.
If you are accessing the Site, please see the “Users Located Outside the United States” section below for additional information on accessing your Personal Data and other legal rights available to you under applicable law.
Your Choices Regarding Promotional Emails. You may unsubscribe from receiving promotional emails from us by following the instructions provided in those email communications. Please note that even if you opt out of receiving promotional communications from us, we may continue to send you non-promotional emails, such as emails concerning our ongoing business relationship with you.
- To prevent your information from being used by Google Analytics, you can install Google’s opt-out browser add-on: https://tools.google.com/dlpage/gaoptout.
- To opt out of interest-based advertising, you can visit http://optout.networkadvertising.org/#!/and follow NAI’s on-screen instructions. Note that if you opt out through the NAI, you will still receive advertising, but the advertising will not be tailored to your interests. In addition, if you opt out through NAI and later delete your cookies, use a different browser, or buy a new device, you will need you opt out of interest-based advertising again.
- Check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.
Users Located Outside the United States
If you are visiting the Site, please be aware that information we collect from the Site will be transferred to, and processed in, the United States. By using the Site or attending a Naviant Event, you acknowledge and consent to the transfer and processing of your Personal Data in the United States as described in this Policy.
Users Located in the European Economic Areas, United Kingdom, or Switzerland (Collectively the “EEA”)
Obligation to Provide Personal Information and Automated Decision-Making. Individuals in the EEA (“EEA Individuals”) are not required by statute or by contract to provide any Personal Data. We will not use an EEA Individual’s Personal Data submitted through the Site or at a Naviant Event for automated decision-making, including for profiling, that produces legal effects or similarly significantly affects an EEA Individual.
Data Retention. We retain the Personal Data collected through the Site or a Naviant Event for as long as we have a business purpose or longer if required by applicable law. You may request that we delete your Personal Data as described below.
Legal Bases For Processing: Naviant processes your Personal Data with your consent and as required by law. Naviant also processes Personal Data as necessary for its legitimate interests as follows:
Business Operations: We use your Personal Data for our legitimate business purposes, including to develop new products and services, to improve existing products and services, and to personalize communications.
Marketing and Advertising: We use your personal data to provide you information about the products and services that we think might interest you in accordance with applicable law. We also use this data to conduct market research and to improve our marketing strategies.
Investigations: In the event of fraud, a security incident, or a suspected criminal act, we would examine Personal Data that appeared to be linked to the incident as necessary to investigate and remediate the incident as well as to report the incident to authorities, and prevent a recurrence.
Right to Object to Processing for Legitimate Interests: EEA Individuals have the right to object to the processing of their Personal Data for purposes of Naviant’s direct marketing or other legitimate interests by contacting email@example.com.
EEA Individuals have the right to access their Personal Data collected by the Site or at Naviant Events. EEA Individuals’ right to access their Personal Data includes their right to receive a copy of all, or a portion, of their Personal Data in Naviant’s possession as long as Naviant’s providing the Personal Data would not adversely affect the rights and freedoms of others. EEA Individuals also have the right to request that Naviant update, correct or delete their Personal Data and to restrict Naviant’s processing of their Personal Data, as provided by applicable law.
EEA Individuals also have the right to data portability concerning their Personal Data. Subject to certain limitations, the right to data portability allows EEA Individuals to obtain from Naviant, or to ask Naviant to send to a third party, a digital copy of the Personal Data that they provided via the Site or to Naviant at a Naviant Event.
EEA Individuals can exercise these rights by contacting firstname.lastname@example.org. We may request identifying information from you to confirm your identity and ensure your right to exercise any of these rights. Naviant will respond to such requests in accordance with applicable data protection law. If EEA Individuals believe that their Personal Data has been processed in violation of applicable data protection law, they have the right to lodge a complaint with the relevant data protection authority in the country where they reside, where they work, or where the alleged violation occurred.
EEA Individuals may use the contact information above, at any time, to withdraw their consent for the processing of their Personal Data where Naviant requires their consent as a legal basis for processing their Personal Information. Any withdrawal will apply only prospectively, and Naviant will continue to retain the Personal Data that EEA Individuals provided before they withdrew their consent for as long as allowed or required by applicable law.
The Site includes features that are designed to permit interactions that you initiate between the Site and third-party websites or services, including third-party social networks (“Social Features”). Examples of Social Features include enabling you to “like” or “share” our content on other websites or services or to transmit content to our Platform from your account on a third-party website or service.
The information we collect in connection with Social Features is subject to this Policy. The information collected and stored by the third parties remains subject to those third parties’ privacy practices, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third-party websites or services.
The Site and Naviant Events are not intended for children, nor are they targeted to children under the age of 13. We do not knowingly collect personal data from children under the age of 13 through the Site or at Naviant Events, and if we learn that we have received information from a visitor under the age of 13, we will delete such information in accordance with applicable law.
California Privacy Rights
California law permits California residents to request certain details about how their Personal Data is shared with third parties and, in some cases, affiliates for direct marketing purposes. California customers may request information about our compliance with this law by contacting us at email@example.com. Any such inquiry must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per individual each year.
Any California residents under the age of eighteen (18) who have registered to use the Site, and who have posted content or information on the Online Community, can request that such information be removed from the Site by contacting us at firstname.lastname@example.org, stating that they personally posted such content or information and detailing where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal.
Cookies: A cookie is a unique identifier that is placed and stored on a computer when it is used to visit a website. Cookies may be used for various purposes, including to track user preferences or web pages visited while using a website, to identify the number of unique visitors to a website, and to verify whether or not a visitor is a repeat visitor.
Web Beacons (also known as tracking pixels): Web beacons are small graphic images, also known as “Internet tags” or “clear gifs” that may be embedded in web pages and email messages. Web beacons may be used to monitor the number of visitors to a website, to track how users navigate a website, or to count how many emails were actually opened or specific pages or links were actually viewed.
Embedded Scripts: An embedded script is programming code designed to collect information about a user’s interactions with a website. Typically, the script is temporarily downloaded onto a computer from the host website’s server (or the server of a third-party service provider), and is active only while the visitor is connected to the website, then deleted or deactivated thereafter.
Cookies We Use And Why We Use Them
We use four types of cookies on our website:
- Essential Cookies: These are cookies that are strictly necessary for the functioning of the website or for performing services that an individual user has requested. Some examples of functions performed by essential cookies are cookies that remember previous actions (e.g., entered text) when navigating back to a page in the same session.
- Analytical Cookies: These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information that analytical cookies collect is aggregated and therefore anonymous. These cookies are used only to improve how a website functions.
- Functional Cookies :These cookies allow the website to remember choices users make and to provide enhanced, personalized features.
Cookies can also be categorized by how long they remain on your device. There are two broad categories of duration:
- Persistent Cookies: Persistent cookies remain on your device until deleted manually or automatically.
- Session Cookies: Session cookies remain on your device until you close your browser when they are automatically deleted.
We use both persistent cookies and session cookies on the Site.
Cookies can be first-party cookies, which means that we place the cookies ourselves, or third-party cookies, which means that a third-party places them on your device. The Site uses first-party cookies and occasionally use third-party cookies.
Regarding third-party cookies, Naviant has relationships with third-party advertising companies to place advertisements on the Site and other websites, and to perform tracking and reporting functions. These third-party advertising companies may place cookies on your computer when you visit the Site so that they can display targeted advertisements to you. To opt out of third-party cookies, please see Section III below.
Information Collected by our Cookies, Web beacons, and Scripts:
Our cookies, web beacons, and scripts collect information including:
- Websites you visit immediately before and after visiting the Site;
- What web pages you visit on the Site and how long you visit them;
- Information about how you navigate, use, and interact with our Site;
- Your IP address, device identifiers and signatures, and browser type
Many web browsers provide options to allow you to stop accepting new cookies, or to disable existing cookies. You can go to the HELP function of your browser to learn how. You can also go to https://www.cookiesandyou.com for information about how to disable and control cookies on most browsers. Please be aware that if you disable the cookies on your computer you may not be able to use certain features of the Site or other websites, and disabling cookies may invalidate opt outs that rely on cookies to function. Also, these options may not be effective in all cases, or may be effective with respect to one type of browser or service, but not another.
To opt-out of targeting by many third-party advertising companies, please visit the Network Advertising Initiative (NAI) at http://www.networkadvertising.org.
Changes to this Policy
We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Policy. We encourage you to review this Policy whenever you visit the Site or attend a Naviant Event to stay informed about our information practices. This Policy was last modified on March 11, 2021. If we materially change this Policy in a way that affects how we use or disclose your Personal Information, we will provide a prominent notice and the effective date of the changes before making them.
To contact us regarding this Policy or with questions about our privacy practices, you may email us at email@example.com, call us at 1-866-686-4624, or reach us at:
201 Prairie Heights Drive
Verona, WI 53593