Privacy Policy

Effective Date: July 31, 2023

Last Updated: July 31, 2023

Navengage Education Technologies Inc. (“Navengage,” “our”, “us” or “we”) is committed to protecting your privacy.

This privacy policy (this “Privacy Policy”) describes the types of personal information that we collect from you through or in connection with (i) our website located at https://www.navengage.com/ and any subdomains thereof (collectively, the “Site”), (ii) the Navengage mobile application and website application (collectively, the “App”), and (iii) any content, products, or services made available from or through the Site or the App (together with the Site and the App, the “Services”). The Privacy Policy further describes how we use your personal information and the circumstances under which we may disclose it to others.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. BY USING THE SERVICES, YOU CONSENT TO THE PRIVACY PRACTICES SET FORTH HEREIN. IF YOU DO NOT AGREE WITH THESE PRIVACY PRACTICES, YOU MUST CEASE USING THE SERVICES IMMEDIATELY.

Collection of Personal Information and Sensitive Information – What Do We Collect and How do We Collect it?

Personal Information, including Sensitive Personal Information, You Provide to Us

We collect the personal information that you choose to provide to us through the Services, including when you sign up for an account with us. This personal information may include, but is not limited to, your name, address, e-mail address, phone number, educational history, a photo of you, payment information, and other data that by itself, or in combination with other data, reveals your identity.

• Interactive Features. We and others who use our Services may collect personal information, including sensitive personal information, that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services is optional and will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. If you provide us with sensitive personal information, we do not use it to infer characteristics about you.

Usage Data We Automatically Collect 
We may collect personal information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
• Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services. 
  

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality.
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below).
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services, such as Google Analytics, DataDog, and Amplitude. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
• Social Media Platforms. Our Services may contain social media buttons, such as Facebook, Instagram, and Twitter, which might include widgets such as the “share this” button or other interactive mini programs. These features may collect personal information such as your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
  

For more information about these Technologies, please see the section of this Privacy Policy titled “Cookies and Other Technology.”

Personal Information Collected From Other Sources.
We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application, such as a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

What Do We Do with Your Personal Information?

Navengage’s Use of Your Personal Information 
We may use your personal information, including sensitive personal information, as described at the point of collection and in this Privacy Policy for the following purposes: 

• To operate and improve the Services;
• To detect, prevent and address technical issues;
• To monitor the usage of the Services;
• To deliver the services that you have requested;
• To contact you about events, publications and services that we provide;
• To better understand how you interact with the Services;
• To tailor the content and information that we provide to you through the Services;
  For security purposes;
• To comply with applicable laws;
• To enforce and protect our rights and the rights of others, including to assist law enforcement, campus police, or other authorities;
• To consider you for certain opportunities;
• For research and analytics purposes;
• To fulfill any other purpose for which you provide it; and
• For other purposes with your consent.

Disclosure of Personal Information to Third Parties
We may disclose your personal information for business purposes with the third parties described below. We do not sell or share (as that term is defined under the California Consumer Privacy Act) your personal information or sensitive personal information.

• Service Providers.  We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, suppliers, agents, attorneys, and representatives (collectively, “Service Providers”).  Service Providers assist us with a variety of functions including, but not limited to, sending marketing communications, assisting with advertising and related analytics, providing management services, conducting research or surveys, sending regular mail and e-mail, maintaining databases, or processing credit card payments.
  
• Business Partners.  We may share your personal information with third-party business partners product suppliers, partners who we conduct joint-marketing activities with, partners who we offer a co-branded service with or provide advertising and related-analytics services to us.
  
• Other Users or Third Parties You share or Interact With. As described above in “Data Collection - What Do We Collect and How do We Collect it?” our Services may allow you to share personal information, including sensitive personal information, or interact with other users and third parties including individuals and third parties who do not use our Services and the general public. The information you share in such contexts is up to you.
  
• Disclosures Under Special Circumstances.  We may disclose your personal information to third parties: (i) where we have a good faith belief that such disclosure is necessary to meet any applicable law, regulation, legal process or other legal obligation; (ii) when we believe disclosure is necessary to protect or prevent harm, illegal activity, or financial loss; (iii) to detect, investigate and help prevent security, fraud or technical issues; and (iv) to cooperate with law enforcement, government, quasi-governmental and public agency requests or reporting requirement.  
  
• Corporate Transactions.  We may transfer your personal information in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations.
  
• At Your Direction.  We may disclose or transfer your information to any third party that you direct or ask us to provide that information to.
  
  

How do We Protect Your Personal Information?

We use commercially reasonable security measures, including technical, physical and administrative practices and procedures, to protect your personal information against unauthorized access, loss, misuse and alteration. Nevertheless, no system is perfect. Therefore, we cannot guarantee the absolute security of your personal information, and we make no representations or warranties with respect to the sufficiency of those security measures, nor will we be responsible for any direct or indirect damages that you may incur as a result of a security breach or technical malfunction.     

How Long do We Retain Your Personal Information?

We retain your personal information, including sensitive personal information, only for as long as is reasonably necessary for the purposes listed above in the section entitled “What Do We Do with Your Personal Information.” This includes retaining your personal information for the purposes of satisfying any legal, accounting, or reporting obligations. 

Third-Party Websites

We may include links on the Services to third-party websites that we do not operate or control (“Third-Party Websites”). We are not responsible for the collection, use or disclosure of personal information collected through the Third-Party Websites, and we expressly disclaim any and all liability related to such collection, use and disclosure. Therefore, before interacting with the Third-Party Websites, you should consult the privacy policies of those websites to learn more about their privacy practices.

Children’s Privacy

We do not knowingly collect, store, or sell personal information of minors under 16 years of age and no parts of the Services are directed towards or designed to attract anyone under that age. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to dan@navengage.com. 

Cookies and Other Technologies

What is a cookie? 
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website again, the cookie allows that website or online service to recognize your browser. Cookies may store unique identifiers, user preferences and other data. 

What are Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Why do we use them? 
Cookies help us improve the Services by providing us with data about which parts of the Services are most popular, enabling us to analyze technical and navigational data about the Services and helping us to detect and prevent fraud. We also use cookies and other Technologies to help improve your experience with the Services. 

How do I control cookies? 
Web browsers allow some control of most cookies through the browser settings. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although you are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some parts of the pp. To find out more about cookies, including how to manage and delete them, visit www.allaboutcookies.org.

Do Not Track
The Services do not support Do Not Track (DNT). DNT is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your online activities collected. For more information about DNT, please visit www.donottrack.us. 

Additional Information for EU Visitors

With respect to “personal data” as defined by Regulation (EU) 2016/679 that you may provide to us through the Services, we serve as the “controller”. 

We provide the Services from servers located in the United States. If you are accessing the Services from the European Union, we will only transfer your personal data to the United States through the use of appropriate safeguards. We process your personal data to pursue our legitimate business interest to operate the Services and as described in the section of this Privacy Policy titled “Navengage’s Use of Your Personal Information”. To learn more about with whom we may share your personal data, please refer to the section of this Privacy Policy titled “Disclosure of Personal Information to Third Parties”. 

We retain your personal data for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations. Copies of information that you have updated, modified or deleted will remain in our systems if applicable law requires us to retain it.

You have the right to access your personal data, rectify inaccuracies in it, request the erasure of it and request that we restrict the processing of it in certain circumstances. If you wish to access your personal data, please contact us at dan@navengage.com, and allow reasonable time for your personal data to be collected. 

You also have the right to lodge a complaint with a supervisory authority.

Your Privacy Rights – Residents of California, Colorado, Connecticut, Utah, and Virginia

1)    Your Privacy Rights

This section explains your privacy rights under applicable law. Please note that some of the rights may vary depending on your state of residence and when your state’s laws become effective.

a) Right to Know.
You have a right to request that Navengage disclose what personal information it collects, uses, discloses, and sells. It includes a request for any or all of the following: 

1. Specific pieces of personal information that Navengage has about you;
2. Categories of personal information Navengage has collected about you;
3. Categories of sources from which your personal information is collected;
4. Categories of personal information that Navengage has sold or disclosed for a business purpose about you; 
5. Categories of third parties to whom your personal information was sold or disclosed for a business purpose; and
6. The business or commercial purpose for collecting or selling personal information.

b) Request to Delete.
You have a right to request that Navengage delete your personal information that we have collected from you, with certain exceptions. 

c) Request to Correct.
Residents of California, Colorado, Connecticut, and Virginia have the right to request that Navengage correct inaccurate personal information that it maintains about you.

d) No Discrimination.
You have a right not to receive discriminatory treatment by Navengage for the exercise of your privacy rights. 

2)    How to Exercise Your Privacy Rights

a) Submitting a Request to Know, Correct, or Delete.
You may submit a Request to Know, Request to Delete, or Request to Correct through our web portal, available here, or contact us at dan@navengage.com. 

b) Verification Methods. 
Once you submit a request, we will verify that you are the consumer to which the request pertains by matching your name, email address, physical address, telephone number, email address, a security code, or similar information we maintain.  Depending on the type of request you submit, we will attempt to match either two or three of these data points you provided.  If we are unable to verify your request with the data points you provided, we may reach out to you for additional information to verify your request.

Residents of California, Colorado, and Connecticut may designate an authorized agent to submit a request on your behalf or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

If you are a Colorado, Connecticut, or Virginia resident, you may appeal our decision to your request regarding your personal information. To do so, please send an email to dan@navengage.com. We respond to all appeal requests as soon as we reasonably can, and no later than legally required. If you have concerns about the result of your appeal, you may contact the attorney general of your state.

3)    Alternate Format of Privacy Notice.  

If you have a disability that prevents or limits your ability to access this Privacy Policy, please email us via email at dan@navengage.com. We will work with you to provide it in an alternative format.

Contact

We welcome questions and comments about this Privacy Policy. Please send your questions and comments to us at dan@navengage.com.

Modifications to this Privacy Policy

We reserve the right, in our sole discretion, to modify this Privacy Policy at any time without notice to you. We will post all modifications to this Privacy Policy on the Site and they will become effective immediately upon being posted to the Site. Your continued use of the Services following the posting of modifications to this Privacy Policy constitutes your acceptance of those modifications. Therefore, you should check the Effective Date of this Privacy Policy each time that you visit the Site and review the table below to learn what has changed since the last time you visited. Notwithstanding the foregoing, to the extent required by law, we will notify you of any material changes to this Privacy Policy.

The table below identifies material modifications to this Privacy Policy since the Effective Date.