Last Updated 01 December 2019
External Privacy Notice
We respect the privacy of every person who visits with www.navienuk.com (the “Site”) and we are further committed to ensuring a safe online experience. We also respect the privacy of every person who uses the products and services that we make available from the Site or who engages with us to use the products or services that Navien Ltd (“Navien”) provides (be it through the Site or not) (our “Services”) or whose personal information we may process as a result of providing the Services to others or who applies to work at Navien.
1 PURPOSE OF THIS POLICY
This privacy notice (“Privacy Notice”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.
2 WHO ARE WE AND WHAT DO WE DO?
The Site and our Services are operated by Navien (“we”, “us” or “our”). F
3 HOW TO CONTACT US?
If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by:
• sending an e-mail to firstname.lastname@example.org; or
• calling us on: +44(0)20 3598 2020
4 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
Our primary goal in collecting personal information from you may be to: (i) verify your identity; (ii) help us deliver our Services; (iii) improve, develop and market new Services; (iv) carry out requests made by you on the Site or in relation to our Services; (v) invite you to industry events specifically related to your business (the “Event”); (vi) investigate or settle inquiries or disputes; (vii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (viii) enforce our agreements with you; (ix) protect the rights, property or safety of us or third parties, including our other customers and users of the Site or our Services; (x) provide support for the provision of our Services; (xi) recruitment purposes; and (xii) use as otherwise required or permitted by law.
To undertake these goals we may process the following personal information:
If you are a visitor to the Site or a visitor to the Event:
• Name and job title.
• Contact information including email address.
• Demographic information such as postcode, preferences and interests.
• Other information relevant to provision of Services.
However as part of such instructions personal information about other persons may be provided to us (e.g. personal information relating, without limitation, to any of our corporate customers’ or prospective customers’ workers.)
If you are an individual whose personal information may be processed by us as a result of providing the Services to others (including individual clients and corporate clients) we will process a variety of different personal information depending on the Services provided in question.
If you are a potential recruit to the Navien office:
• Name and job title.
• Contact information including email address.
• Curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us.
• Other information relevant to potential recruitment to Navien.
In particular, we may use your personal information for the following purposes:
Fulfilment of Services.
Your feedback about our Services.
Business administration and legal compliance.
Client insight and analysis.
We carry out the following marketing activities using your personal information:
o Postal marketing.
o Email marketing.
o Online personalised advertising.
o Social media remarketing.
o Social media insight.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.
5 HOW DO WE OBTAIN YOUR CONSENT?
Where our use of your personal information requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
• by informing us by e-mail, post or phone using the contact details set out in this Privacy Notice.
7 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
Regarding visitors to the Site, will retain relevant personal information for at least [three] years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations).
Regarding personal information we have processed as part of providing the Services to any client, we will retain relevant personal information for at least [six] years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations). We may then destroy such files without further notice or liability. If you request your files and documents we may charge you for the costs of copying a duplicate.
If personal information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
8 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration.
9 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
You have the following rights in relation to the personal information we hold about you:
- Your right of access.
- Your right to rectification.
- Your right to erasure.
- Your right to restrict processing.
- Your right to data portability.
- Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing.
Your rights in relation to automated decision-making and profiling.
Your right to withdraw consent.
Your right to lodge a complaint with the supervisory authority.
10 COLLECTION OF INFORMATION BY THIRD-PARTY SITES AND SPONSORS
The Site contains links to other sites whose information practices may be different than ours. Visitors should consult the other sites’ privacy notices as Navien has no control over information that is submitted to, or collected by, these third parties.
11 CHANGES TO THIS PRIVACY NOTICE
We may make changes to this Privacy Notice from time to time.