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Privacy Policy

Introduction

Welcome to Navatar’s Privacy Policy.

Navatar respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA 
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR DATA ACCESS RIGHTS
  10. GLOSSARY

1. Important information and who we are

Purpose of this privacy policy

This Privacy Policy aims to give you information on how Navatar collects and processes your personal data through your use of the Navatar corporate website at https://www.navatargroup.com, the Navatar Investor-dedicated website at https://navatarinvestor.com, the Navatar “deal room” website at www.navatardealroom.com, and their respective subdomains (collectively, the “Website”), including any information you may provide through the Website when you request a demo of our services, sign up to be informed of webinars and ebooks, register for one of our events, complete our “Support Request”, or “Email Us” online forms, register as an investor or GP, or apply for one of our available positions at Navatar.

Please note that this Website is not intended for children. No one under age 18 may provide any information to or on this Website. We do not knowingly collect personal data from children. If you are under 18, do not use or provide any information on this Website or on or through any of its features, use any of the interactive features of this Website or provide any information about yourself to us, including your name, address, telephone number, or email address. If we learn we have collected or received personal data from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at privacy@navatargroup.com

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice 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 Policy supplements the other notices and is not intended to override them.

Controller

Navatar is made up of different legal entities, details of which can be found here. This Privacy Policy is issued on behalf of the Navatar Group so when we mention “Navatar”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the Navatar Group responsible for processing your data. Navatar Group, Inc. is the controller and responsible for this Website.

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your data access rights, please contact our Data Privacy Manager using the details set out below.

Contact details

Our full details are:

Navatar Group, Inc.

Title: Data Privacy Manager

Email address: privacy@navatargroup.com

Postal addresses and Telephone numbers:

US Residents: Navatar Group, Inc., 90 Broad Street, New York, NY 10004, U.S.A. Tel: 1-212-863-9655

UK Residents: Navatar Ltd, 2-6 Boundary Row, South Bank, London SE1 8HP, UK. Tel: 020 3868 3389

India Residents: Navatar Consulting Private Limited, Pinnacle Tower, A-42/6, 5th Floor, Sector-62, Noida-201301, India. Tel: +91-120-4516181

EU residents: you have the right to make a complaint at any time to the UK Information Commissioner’s Office (ICO) for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on May 25, 2018, and historic versions can be obtained by contacting us at privacy@navatargroup.com.

We reserve the right to change the terms of this Privacy Policy at any time. When we do, we will post the revised Privacy Policy to our Website and the last revision date of revision will be updated so that you will always be able to understand what data we collect, how we use your data, and under what circumstances we may share your data with others. We will notify you of any material changes by way of an email or other electronic communication announcing that the Privacy Policy has changed, and pointing the changes to your attention.

It is important that the personal data we hold about you is accurate and current. Please keep us informed by sending us an email at privacy@navatargroup.com if your personal data changes during your relationship with us.

Third-party links

This Website 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 statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

Please note that we also do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. If you are based in the United States you can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website at http://optout.networkadvertising.org. If you are based in the European Union you may visit the website of the European Interactive Digital Advertising Alliance (“EIDAA”) at https://www.edaa.eu as well as of the European Advertising Standards Alliance (“EASA”) at http://www.easa-alliance.org.

2. The personal 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 where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us.
    • 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 this Website.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you provide us with personal data about a third party, such as your spouse, a colleague or friend of yours, you represent and warrant to us that you have all necessary rights to provide the data to us for our processing in accordance with this Privacy Policy. You represent and warrant to us that you have obtained the third party’s consent to the processing by Navatar, including, if the personal data relates to a resident of the European Union, its transfer outside of the EEA in accordance with this Privacy Policy. Should such a consent be revoked by the third party please communicate the fact of such revocation to us immediately by sending us an email at privacy@navatargroup.com so we can make sure we don’t process the personal data any longer.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • create an account on our Website;
  • request a demo with us;
  • subscribe to our webinars and ebooks;
  •  register for one of our events;
  • apply for one of our available positions;
  • request marketing to be sent to you; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie notice for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the analytics providers such as Google based outside the EU;
  • Identity and Contact Data from data brokers or aggregators, such as Pitchbook based outside the EU.
  • Identity and Contact Data from publicly availably sources such as LinkedIn based outside the EU, or the Companies House based inside the EU.
  • Identity and Contact Data from customers of our products and services, in which case we only process your personal data on the customer’s behalf and following their instructions.

Should you wish to obtain additional information about any sources of personal information about you please contact us at privacy@navatargroup.com.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Please check the table below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us at privacy@navatargroup.com.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us at privacy@navatargroup.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Privacy Policy Table

Marketing

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:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Navatar group of companies for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at marketing@navatargroup.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Do Not Track “DNT” Signals

While we take all reasonable steps to protect the privacy of our Website visitors, we cannot promise that the current limitations of our online applications programming will address every browser setting or honor every personal browser preference. In particular, we have not implemented the necessary program changes to honor “Do Not Track” or “DNT” browser signals. As our online applications programming is refined, we will take all reasonable steps to honor such requests in the future. Please return to this Privacy Policy for further updates on this topic.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie notice.

Change of purpose

We will only use your personal data 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 at privacy@navatargroup.com.

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.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.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 Policy.

We require all third parties 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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

EU residents: We share your personal data within the Navatar Group. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us at privacy@navatargroup.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.

However, you should note that no transfer of data over the Internet is completely secure. While we use reasonable efforts to protect your personal data on our systems, when the data is transferred over the Internet, it may be accessed and used by unauthorized third parties. Navatar has no control over the performance, reliability, availability or security of the Internet and does not warrant that any information transfer via the Internet or any communication through the Internet is secure. Navatar shall not be liable for any disclosure, unauthorized use, loss, damage, expense, harm or inconvenience resulting from the loss, delay, interception, corruption, intervention, misuse or alteration of any personal data due to any reason beyond Navatar’s reasonable control.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request from us by contacting us at privacy@navatargroup.com.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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 data indefinitely without further notice to you.

9. EU residents: Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us at privacy@navatargroup.com.

No fee usually 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 charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific data 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 data in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may 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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@navatargroup.com.

Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Navatar Group acting as joint controllers or processors and who are based in the UK, the U.S. and India and provide IT, HR, Marketing, Operations, Finance, and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in the UK and the U.S. who provide Marketing, IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and the U.S., and who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities acting as processors or joint controllers based in the UK or the US, and who require reporting of processing activities in certain circumstances.

Should you wish to obtain additional information about any third parties with whom we may share your personal information please contact us at privacy@navatargroup.com.

 

EU RESIDENTS: YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the data to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.