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Effective Date: January 1, 2023   

This California Consumer Privacy Statement (“Statement”) supplements the NAVEX Privacy Statement. This Statement applies to California consumers, including visitors of NAVEX’s Website and representatives of NAVEX’s business customers and business partners.  This Statement does not apply to NAVEX’s personnel or job applicants. 

This California Consumer Privacy Statement uses certain terms that have meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA/CPRA”).  

Notice of collection and use of personal information  

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:  

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as device identifiers; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; unique pseudonym; user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, login credentials, and other similar identifiers.  
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature information. 
  • Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies. 
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history and information regarding your interaction with websites, applications or advertisements. 
  • Sensory Information: audio, electronic, visual, and similar information.  
  • Employment Information: professional or employment-related information such as business contact information, occupation details, certifications and professional associations. 
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

We may use (and may have used during the 12-month period prior to the effective date of this Statement) the categories of personal information listed above for the purposes described in the NAVEX Privacy Statement and for the following Business Purposes as described in the CCPA/CPRA:  

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services; 
  • Providing advertising and marketing services to you, except for cross-context behavioral advertising (which is addressed in the Sale or Sharing of Personal Information Section below); 
  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance; 
  • Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us; 
  • Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes; 
  • Debugging to identify and repair errors that impair existing intended functionality; 
  • Undertaking internal research for technological development and demonstration; and 
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us. 

NAVEX does not collect or process sensitive personal information with the purpose of inferring characteristics about consumers.  

Retention of personal information 

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in our NAVEX Privacy Statement and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.  

Sources of personal information 

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:  

  • Directly from you, such as when you create an account with us, or contact us  
  • From your devices, such as when you interact with our Website, products, and other online services 
  • Our affiliates and subsidiaries  
  • Vendors who provide services on our behalf 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Data brokers 
  • Data analytics providers 

Sale or sharing of personal information 

We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information by allowing certain third parties (such as online advertising services, advertising networks and social networks) to collect personal information via automated technologies on our websites for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information. 

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you to online advertising services, advertising networks and social networks: 

  • Identifiers 
  • Online Activity 
  • Inferences   

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age. 

Disclosure of personal information 

During the 12-month period prior to the effective date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Categories of personal information Categories of third parties

Identifiers

  • Our affiliates and subsidiaries 
  • Vendors who provide services on our behalf 
  • Data analytics providers 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Professional services organizations, such as auditors and law firms 

Additional data subject to Cal. Civ. Code § 1798.80

  • Our affiliates and subsidiaries 
  • Vendors who provide services on our behalf 
  • Data analytics providers 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Professional services organizations, such as auditors and law firms   

Commercial information

  • Our affiliates and subsidiaries 
  • Vendors who provide services on our behalf 
  • Data analytics providers 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Professional services organizations, such as auditors and law firms   

Online activity

  • Our affiliates and subsidiaries 
  • Vendors who provide services on our behalf 
  • Data analytics providers 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Professional services organizations, such as auditors and law firms   

Sensory information

  • Our affiliates and subsidiaries 
  • Vendors who provide services on our behalf 
  • Data analytics providers 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Professional services organizations, such as auditors and law firms   

Employment information

  • Our affiliates and subsidiaries 
  • Vendors who provide services on our behalf 
  • Data analytics providers 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Professional services organizations, such as auditors and law firms   

Inferences

  • Our affiliates and subsidiaries 
  • Vendors who provide services on our behalf 
  • Data analytics providers 
  • Our business customers and partners 
  • Online advertising services and advertising networks 
  • Social networks 
  • Professional services organizations, such as auditors and law firms   

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have disclosed personal information about you to government entities (e.g., in response to law enforcement requests) and third parties in connection with corporate transactions (e.g., mergers, acquisitions, joint venture, reorganization, divestitures, dissolution or liquidation). 

California consumer privacy rights 

You have certain choices regarding your personal information, as described below. 

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold or shared about you during the past 12 months. 

Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate. 

Deletion: You have the right to request that we delete certain personal information we have collected from you.  

Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes. 

How to submit a request 

To submit a request to (a) access, correct, or delete your personal information, click here. You may also email us at privacy@navex.com, with “Personal Information Request” in the subject line and provide full details about your request, including your contact information, or call us toll-free at 1-844-842-0916.  To opt-out of the sale or sharing of your personal information, follow the instructions provided in this link, or email us at privacy@navex.com, with “Personal Information Request” in the subject line and provide full details about your request, including your contact information. You may also opt-out of the sale or sharing of your personal information by using the Global Privacy Control signal.  To submit a request as an authorized agent on behalf of a consumer, please email us at privacy@navex.com with the subject line Authorized Agent Request. 

Verifying requests  

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. For example, if you have an online account with us, we may verify your identity by requiring you to sign into your account. Alternatively, or if you do not have an online account with us, we may require you to provide us information to enable us to verify your identity, for example your corporate email address, phone number, or job title. In addition, if you do not have an online account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. 

If you designate an authorized agent to make a request on your behalf, depending on whether you have an online account with us, we may require that you verify your identity as set forth above. We also may require you to provide the authorized agent a written confirmation that you have authorized the agent to act on your behalf and the scope of such authorization. 

Additional information 

If you choose to exercise any of your rights under the CCPA/CPRA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. For questions or concerns about our privacy policies and practices, please contact us at privacy@navex.com. You may also call us at 1-(866)- 297-0224 or mail us at 5500 Meadows Road, Suite 500, Lake Oswego, OR 97035, Attn: Data Protection Officer.