Effective July 25, 2018
Naavi ID is an online identity platform for Naavi products (the “Services”) operated by Naavi Pty Ltd, a company headquartered in Melbourne, Victoria, Australia (“we,” “us,” “our,” and “Naavi”).
The Services enable our Users to, among other things, sign up and login to Naavi products.
“User” means any person or entity that is registered with us to use the Services.
“Personal Information” means any information that identifies or can be used to identify a User or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
“Visitor” means any person who visits any of our Websites.
“you” and “your” means, depending on the context, either a User or a Visitor.
This section applies to the Personal Information we collect and process from a User or potential User through the provision of the Services. If you are not a User, the Visitors section of this policy may be more applicable to you and your data. In this section, “you” and “your” refer to Users and potential Users.
The Personal Information that we may collect broadly falls into the following categories:
Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to login with your Google account), or communicate with us in any other way.
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:
We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.
You may have the following data protection rights:
To access, correct, update or request deletion of Personal Information. Naavi takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a User, you can manage many of your individual account and profile settings within the dashboard provided through the Naavi ID platform, or you may contact us directly by emailing us at email@example.com.
In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us using the contact details provided in the “Questions and Concerns” section below.
Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.
This section applies to Personal Information that we collect and process through our Websites and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities. In this section “you” and “your” refers to Visitors.
Information you provide to us on the Websites or otherwise: Certain parts of our Websites may ask you to provide Personal Information voluntarily. For example, we may ask you to provide certain Personal Information (such as your name, contact details, company name, profile information) in order to sign up for a Naavi ID account, apply for a role with Naavi, or otherwise submit inquiries to us. We may also collect Personal Information, such as your contact and job details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information. We will also let you know prior to collection whether the provision of the Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information.
Information we collect automatically through the Websites: When you visit our Websites, we may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.
We may use the information we collect through our Websites for a range of reasons, including:
Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us at firstname.lastname@example.org. If we are unable to remove your information, we will tell you why.
Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly.
Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively, “Promotions”).
You have the following data protection rights:
To access, correct, update, or request deletion of your Personal Information. Naavi takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at email@example.com. We will consider your request in accordance with applicable laws.
In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at firstname.lastname@example.org.
Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If you are a User, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the “Questions and Concerns” section below.
Users and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the “Questions and Concerns” section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Users cannot opt out of these messages unless you cancel your Naavi ID account.
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at email@example.com.
Naavi ID accounts require an email address and password to log in. Users must keep their email address and password secure, and never disclose it to a third party. Because the information in a User’s Naavi ID account is so sensitive, account passwords are hashed, which means we cannot see a User’s password. We cannot resend forgotten passwords either. We will only provide Users with instructions on how to reset them.
We operate in the Australia
Our servers are located in the United States and our offices are located in Australia, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States and Australia might not be as comprehensive as those in your country, we take many steps to protect your privacy.
Users located in Australia
If you are a User who lives in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 (“Australian Privacy Act”). Here are the specific points you should be aware of:
Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us through our contact form or email us at firstname.lastname@example.org.
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by postal mail or email at:
For EEA Residents:
For the purposes of EU data protection legislation, Naavi Pty Ltd is the controller of your Personal Information. Our Data Protection Officer can be contacted at email@example.com.
For Non-EEA Residents:
Naavi Pty Ltd
Attn. Privacy Officer
PO Box 222
Chadstone Centre, 3148