Effective Date: January 1, 2017.
Information we collect
Nava collects personal data in the course of its business activities, including in connection with some client services. We also collect personal data on certain areas of the Sites when you register for or apply for jobs, create a user profile, register for Nava newsletters and alerts, sign up for conferences and events, and/or participate in public user posting areas (such as bulletin boards, discussion forums and surveys). The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number, and background information required to apply for a job.
We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected will be associated with any personal data you have provided.
Nava may also collect personal data about you from third parties, such as data brokers or aggregators, in the course of its business activities including in connection with some client services. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions, foot traffic in retail environments). We will always seek to confirm that the third party has informed you in advance about its, and Nava’s, use of this data.
Cookies used by Nava, do not give us access to anything on your hard drive and cannot do anything to your computer. Cookies are encrypted for security purposes to make any information in the cookie unreadable to anyone except the organization with which you are dealing.
Use of information
Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to “do not track” signals transmitted from web browsers.
Use of information collected via mobile devices
In connection with our mobile applications, Nava may use third party service providers to analyze user activity to fix errors, monitor usage, and improve the performance of the mobile applications. For example, Nava receives reports on some of our mobile applications’ aggregate usage and browsing patterns, including information about the type of device used, articles accessed, and other events occurring within our apps. Nava also receives reports on certain errors occurring within mobile applications.
In addition, our Nava Insights app offers a personalized list of recommendations (called “Insights for you”) directing you to Nava content that we think you will find interesting. Recommendations are based solely on what you have viewed in the Insights app. A unique user identifier that is generated by the app helps personalize your app experience and tracks the articles that you read in the app. We do not share your viewing history or trends with other users or any external third parties (i.e., persons or entities that are not affiliates or third party service providers of Nava).
The legal basis by which we process your personal data
Our processing of your personal data for the purposes mentioned above is based:
in part, on our legitimate interests in promoting and protecting Nava, building and maintaining relationships, recruitment, and providing our services;
in part, on your consent, for example if you create a user profile, or register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our web-sites;
in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.
Data recipients and international data transfers
Personal data collected in the course of Nava business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to Nava subsidiaries and affiliates and their personnel, as well as to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by Nava and our third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Nava subsidiaries, affiliates and third party service providers, including the transfer of your personal data to countries other than the one in which you reside.
We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you.
In addition, we may disclose information about you:
If we are required to do so by law or legal process;
To law enforcement authorities or other government officials;
When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
If disclosure is necessary to protect the vital interests of a person;
To protect our property, services and legal rights;
To prevent fraud against Nava, our subsidiaries, affiliates and/or business partners;
To support auditing, compliance, and corporate governance functions; or
To comply with any and all applicable laws.
In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. Nava is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.
Link to third party sites
The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Nava. The Sites also may allow you to log in to a Nava account using certain social network account credentials.
If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.
Nava has implemented generally accepted standards of technology and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized Nava personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. Despite these precautions however, Nava cannot guarantee that unauthorized persons will not obtain access to your personal data.
Nava retains personal data, as necessary, for the duration of the relevant business relationship.
The Sites are not designed for or directed at children 13 years of age or younger, and Nava does not intentionally collect or maintain personal data about anyone under this age.
Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, where applicable, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.
In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.
If you have registered for Nava newsletter or alerts, or you receive invitations to survey or events from Nava and you prefer not to receive future email communications from us, please review the communications settings in your profile, follow the instructions on the page of the Site where you have provided such information, subscribed or registered or write to unsubscribe from all Nava communications.
Your Ontario privacy rights
Nava only collects personal information that is necessary for the administration of a lawfully authorized purpose, in accordance with section 38(2) of the Freedom of Information and Protection of Privacy Act (FIPPA). At the time of collection, you will be informed of the specific purpose for which it is being collected.
To make a removal request, please send an email with a detailed description of the specific content or information. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.