Effective Date:  March 25, 2024

If you are a visitor to the website or a data subject in receipt of our services from the EEA and/or the UK, the following Privacy Notice applies to you: English.

If you are a California resident visiting our website or in receipt of our services the following supplemental privacy provisions apply to you: Privacy Notice for California Residents

PRIVACY POLICY

Your privacy is important to us.  This Privacy Policy describes the types of information NAVIS Invest, NAVIS group and their affiliates (“NAVIS”) collect from you when you visit www.navisinvest.com or www.navisgroup.com or any other of our websites where this policy is posted (each a “Site”) or otherwise interact with us online.

This Privacy Policy also explains how Navis Invest may use and disclose your information, as well as your ability to control certain uses of your personal information.  This Privacy Policy is in addition to any separate annual Privacy Notice that Navis Invest may send you under applicable privacy law.

INFORMATION COLLECTION

Information Collected About Clients and Visitors To Our Website
We collect information from you when you choose to share it with us.  This may include when you visit our Sites, request information from us, or contact us.

The information we collect from you may include:

• Contact information, including your name, address, email address, telephone, or mobile number;
• Employer-related information, such as your title and the company’s name, address, and phone number;
• Navis Invest account number;
• Location Information (IP address, IP address locations, information about your location);
• Owned Website Activity (how you use our sites, pages viewed, time of service, date of service, duration of service, time since last visit, links clicked, information about pages viewed on sites);
• Off-Website Activity (referring website addresses, information about the site you came from); and
• Information About Your Device (device type, computer type, internet connection type, linking multiple devices to the same user) and Browser (type, language, version, font settings).

Information Collected about Participants in One of Our Trading Programs:
We may collect information about you that you either provide to us directly, that we receive from third parties, or that we collect automatically as you access any of our Navis Invest sites in connection with your participation in one of our trading programs, which may include:

• Contact information, including your name, address, email address, telephone, or mobile number;
• Geolocation of any computer, mobile device, or other electronic device used to access the Site; and
• Information you provide during the on-boarding process (e.g., information provided on your tax forms, authorization agreement for direct deposits) including information provided on a personal information collection form (name, SSN, DOB, mobile phone number, email address, EEO designation, gender, military status, marital status, emergency contact information) and supplemental disclosures regarding your disciplinary history, employee conflicts, and political contribution disclosures.

Information Collected about Prospective Employees and Job Applicants
We may collect the following information about you that you either provide to us directly, that we receive from third parties, or that we collect automatically as you access any of our Navis Invest sites:

• Prospective Employees:
  • Career-related information (job title, job role, profession, education, industry, years of experience, skills);
  • Location Information (IP address, IP address locations, information about your location);
  • Owned Website Activity (how you use our site, pages viewed, time of service, date of service, duration of service, time since last visit, links clicked, information about pages viewed on sites);
  • Off-Website Activity (referring website addresses, information about the site you came from);
  • Information About Your Device (device type, computer type, internet connection type, linking multiple devices to the same user) and Browser (type, language, version, font settings); and
  • Advertising Information (interests, activities, social network activities and data, purchases, media, advertising network categories, technology usage, ads received and clicked).
• Job Applicants:
  • Information About Your Identity (e.g., name, personal email address, cell phone number, mailing address, password, username);
  • Career Demographics (job title, job role, profession, education, industry, years of experience, skills);
  • Location Information (IP address, IP address locations, information about your location);
  • Career Interests (career topics, current student, expected date of graduation for current students, majors, locations interested in working, profession category (e.g., financial, tech), work area of interest (e.g., trading, legal), interests in upcoming events);
  • Information You Provided In-Person (e.g., events attended);
  • Topics you have expressed interest in;
  • Owned Website Activity (how you use our site, pages viewed, time of service, date of service, duration of service, time since last visit, links clicked, searches conducted, registration for event, clicks on event registration links, language choice, comments, ratings, preferences and settings, information about pages viewed on sites);
  • Email Activity (emails opened, email program used, IP address of email open, clicks in email);
  • Off-Website Activity (referring website addresses, information about the site you came from, profile information from social media sites);
  • Information About Your Device (device type, computer type, internet connection type, linking multiple devices to the same user) and Browser (type, language, version, font settings);
  • Information You Submit to Us (e.g., submitted images, photos, videos; other items you submit; details about your requests made to us);
  • Advertising Information (interests, activities, social network activities and information purchases, media, advertising network categories, technology usage, ads clicked); and
  • Job applied for or interested in (including the job opening’s education and experience description).

Information Collected from Third Parties or Other Sources
We may obtain personal or other information about you from third parties or other sources, and combine this information with the information we collect from you.  This might include any other information obtained through companies that have business relationships with us, such as our licensees, affiliates, and business partners.

We may also obtain information about you from other online sources, including when you connect with Navis Invest through its official corporate pages on third party social networks (such as LinkedIn or Facebook) or the “apps” on those pages.  This information may include your name, user name, demographic information, updated address or contact information, interests, and publicly-observed data.  We may combine this information with the information we collect from you through the Sites.

Information Automatically Collected
We may use cookies, web beacons, pixel tags, JavaScript, or other technologies to collect certain information about visitors to our Site and interactions with our emails and online or mobile advertisements, and to allow Navis Invest to keep track of analytics and certain statistical information which enables us to improve our Site and provide you with more relevant content and advertising on our Site, or other websites and marketing channels.

For example, we may automatically collect certain information from you, including your device type, operating system, software version, Internet Protocol (“IP”) address, geolocation, phone model, phone operating system, screen resolution, browser information (e.g., type, language, version, font settings), and the domain name from which you accessed the Services.  We also may collect information about your use of the Site, including the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing or using the Site, other click-stream or site usage data, emails that you open, forward or click-through to our Site, comments and ratings you submit, website preferences and settings, and other sites that you may be referred from, including referring website addresses and information about the site you came from.

We may also use third party cookies and other technologies to support our Sites, provide services on our behalf, complete business transactions, or provide relevant advertising to you.  Some of these third parties may use technology such as cookies, web beacons, pixel tags, log files, or Flash cookies on our Site or Apps, which may send them some of the above-referenced information.  The use of this information by those third parties will be governed by their own privacy policies including, for example, Google’s Analytics Privacy Policy or the Salesforce Privacy Policy.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).  We may use this information collected about you in order to recruit potential job candidates and communicate with employees and employee alumni.  For example, we may use the information we have collected from you to enable us to in order to recruit potential job candidates (e.g., display advertisements about relevant positions to our target audiences).  Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, we may assume that you meet the target criteria.

Deletion of Cookies, Tracking Options and California Do Not Track Disclosures
You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site.  Please refer to your Web browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences.

Our system responds to most Do Not Track requests or headers from some or all browsers.  To learn more about the use of cookies or other technologies to deliver more relevant advertising and to know your choices about not having this information used by certain service providers, please click http://www.aboutads.info/choices/ and https://policies.google.com/technologies.

On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

INFORMATION USE

Navis Invest may use the information we collect from and about you for any of the following purposes:

• To deliver’s Navis Invest´s services you;
• For recruiting, position advertising, talent management and employment purposes (recording, examination, assessment, selection, conclusion of an employment offer, and with your consent the storage in our recruitment database for a possible future offer of employment, etc.);
• For your participation in certain of our Trading Programs;
• To enhance your online experience, including as a way to recognize you and welcome you to the Site or App;
• To develop new products or services and to conduct analysis to enhance current products and services;
• To review the usage and operations of our Site, and improve our content, products, and services;
• To recognize your online activities over time and across different websites and devices;
• To provide you with customized Site content, or with your consent where applicable via email, telephone, text message, by mail and other marketing channels;
• As applicable and with your consent where applicable, to contact you with information, newsletters and promotional materials from Navis Invest or on behalf of our business partners, licensees, and affiliates;
• With your consent where applicable, to serve ads or send direct messages through third party services (including social media platforms) that are targeted to reach people on those services who are identified in our data bases.  This may be done by matching common factors between our data bases and the data bases of third party operators.  For example, we use Facebook’s “Custom Audience” services, which allows us to provide such information on Facebook to people whose information and email addresses we already have when they expressed an interest in hearing from us;
• To contact you when necessary, including for employment purposes, by email, telephone text message, or by mail;
• To use your data in an aggregated non-specific format for analytical purposes;
• To address problems with the Services, or our business;
• To protect the security or integrity of the Site, and our business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users; and
• As otherwise described to you at the point of data collection.

Additionally, if you use the Site to connect with third party services you authorize us to use information from you, on your behalf, to interact with these third party services based on your requests.

INFORMATION SHARING

Navis Invest may disclose the personal information we collect from you with the following categories of third parties and in the following ways:

• With our affiliated companies;
• With our third party service providers that provide business, professional or technical support functions for us;
• As necessary if we believe that there has been a violation of our Terms of Use or of our rights or the rights of any third party;
• To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and
• As otherwise described to you at the point of collection.

Navis Invest may also share aggregate or anonymous non-personal information with third parties for marketing or analytics uses on behalf of Navis Invest.

We may share your personally identifiable information (“PII”) in connection with a merger, financing, acquisition, dissolution transaction, bankruptcy or proceeding involving sale, transfer, divestiture of all or a portion of our business or assets.  If another entity acquires our business or assets, that entity will have your PII collected by us and will assume the rights and obligations regarding your information as allowed by this privacy policy.

LINKS TO OTHER WEBSITES

The Site, and email messages from us, may contain links to third-party websites, which may have privacy policies that differ from our own.  You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy.  We are not responsible for the practices of such websites.

PUBLIC FORUMS

Any information you may disclose on our Site, in blogs, on message boards, in chat rooms, or on other public areas on the Site, or other third-party websites that the Site may link to, becomes public information.  Please exercise caution when disclosing personal information in these public areas.  We reserve the right to remove any posting or content in a posting at our sole discretion.

CHILDREN’S PRIVACY

Protecting children’s privacy is important to us.  We do not direct the Site to, nor do we knowingly collect any personal information from, children under the age of thirteen.  If we learn that a child under the age of thirteen has provided personally identifiable information to the Site, we will use reasonable efforts to remove such information from its files.

DATA SECURITY

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site visitors.  While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

DATA STORAGE

Your personal information may be stored on servers in the United States and is subject to the laws of the United States, where the data protection and other laws may differ from those of other countries.  Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

YOUR OPTIONS AND ACCESS TO YOUR PERSONAL INFORMATION

To access, review, or update your information stored by Navis Invest, you may contact your respective Navis Invest office or account representative to have them update your information in our system.  If you have any additional questions concerning access to or updating your personal information, please contact us at the information provided in the “Contact Us” section below.

CONTACT US

We hope this Privacy Policy answers your questions about our collection, use and disclosure of your personal data.  If you have additional questions about this Privacy Policy or the practices described herein, you may contact us at PrivacyInquiries@navisinvest.com or write to us at the following address:

NAVIS Invest LLC
Legal Department
100 East Pine Street,
Suite 110,
Orlando, FL
32801

NON-EEA USER’S ACCEPTANCE OF THIS PRIVACY POLICY

By using the Services, you confirm that you have read and understood this Privacy Policy.  If you do not agree with the terms of this Privacy Policy, please do not use our Services at all.  You may opt out of marketing communications at any time by contacting Navis Invest using the information above.

REVISIONS TO THIS PRIVACY POLICY

Navis Invest reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time.  If we do, we will provide access to the immediately prior version of the Privacy Policy on the Site.  Your continued use of the Site following the posting of changes to these terms means you accept these changes.

Non-affiliated third parties are independent from Navis Invest and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.

NAVIS COPYRIGHT POLICY

In conjunction with the provision and use of this website (the “Service”), Navis Invest LLC (“Navis”) has adopted the following general policy toward copyright infringement in accordance with the Digital Millennium Copyright Act (http://lcweb.loc.gov/copyright/legislation/dmca.pdf).  The address of Navis’s Designated Agent to Receive Notification of Claimed Infringement (“Designated Agent”) is listed at the end of this policy.  This DMCA Copyright Policy is part of the Terms of Service for the Service.

It is Navis’s policy to (i) block access to or remove material that it believes in good faith to be copyrighted material that has been illegally copied and distributed by users or downloaded through Navis’s networks; and (ii) remove and discontinue service to repeat offenders.

A. Procedure for Reporting Copyright Infringements:

If you believe that material or content residing on or accessible through the Service website or the Service, or downloaded using Navis’s networks, infringes a copyright, please send a notice of copyright infringement containing the following information to the Designated Agent listed below:

• A physical or electronic signature of a person authorized to act on behalf of the owner of the copyright that has been allegedly infringed;
• Identification of works or materials being infringed;
• Identification of the material that is claimed to be infringing, including information regarding the location of the infringing materials that the copyright owner seeks to have removed, or the date and time that the allegedly infringing material was downloaded using Navis’s networks with sufficient detail so that Navis Invest is capable of finding and verifying its existence;
• Contact information about the notifier, including address, telephone number, and, if available, e-mail address.  If you are not the owner of the copyright that has been allegedly infringed, please describe your relationship to the trademark owner;
• A statement that the notifier has a good faith belief that the material is not authorized by the copyright owner, its agent, or the law; and
• A statement made under penalty of perjury that the information provided is accurate and the notifying party is authorized to make the complaint on behalf of the copyright owner.

B. Once Proper Bona Fide Infringement Notification is Received by the Designated Agent:

Upon receipt of a fully completed and signed notification form, Navis Invest will disable access to the allegedly infringing materials and will promptly notify the individual who posted the materials that access has been disabled.  If your notification is unsigned or does not contain the authorization language described above, Navis Invest will work with you to obtain a properly executed notification.  If any of the other information is missing from your notification, however, Navis Invest will not be able to respond to your request.

C. Procedure to Supply a Counter-Notice to the Designated Agent:

If the content provider, member, or user believes that the material that was removed or to which access was disabled is either not infringing, or the content provider, member, or user believes that it has the right to post and use such material from the copyright owner, the copyright owner’s agent, or pursuant to the law, the content provider, member, or user must send a counter-notice containing the following information to the Designated Agent listed below:

• A physical or electronic signature of the content provider, member, or user;
• Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or disabled;
• A statement that the content provider, member, or user has a good faith belief that the material was removed or disabled as a result of mistake or a misidentification of the material; and
• Content provider’s, member’s, or user’s name, address, telephone number, and, if available, e-mail address and a statement that such person or entity consents to the jurisdiction of the United States District Court for the judicial district in which the content provider’s, member’s, or user’s address is located, or if the content provider’s, member’s, or user’s address is located outside the United States, for any judicial district in which Navis Invest is located, and that such person or entity will accept service of process from the person who provided notification of the alleged infringement.

If a counter-notice is received by the Designated Agent, Navis Invest may send a copy of the counter-notice to the original complaining party informing that person that it may replace the removed material or cease disabling it in 10 business days.  Unless the copyright owner files an action seeking a court order against the content provider, member, or user, the removed material may be replaced or access to it restored in 10 to 14 business days or more after receipt of the counter-notice, at Navis’s discretion.

Please contact Navis’s Designated Agent to Receive Notification of any claimed copyright infringement at the following address:

DMCA Agent

NAVIS Invest LLC
Legal Department
100 East Pine Street,
Suite 110,
Orlando, FL
32801
Email: info@navisinvest.com

Navis’s agent information is provided pursuant to the Digital Millennium Copyright Act, 17 U.S.C. § 512(c)(2).