PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with our Services.
Information You Provide to Us
- Account Creation. If you create an account with Narvar (e.g., as an authorized user of our Customer), we will collect your name, email address, job title, company name, phone number, and address.
Your Communications with Us. We collect personal information from you such as email address, phone number, or mailing address when you use our products or Services, request information about our Services (including a demo), ask to download content (such as a whitepaper or an e-book), subscribe to our newsletter, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features. We may offer interactive features such as review forums, blogs, chat and messaging services, and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.
Customer Service and Support. If you call or otherwise interact with Narvar’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.
Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Narvar and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on the Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and process the information contained therein to assess your suitability, aptitude, skills, and qualifications for employment with Narvar.
Information Collected Automatically
- Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, mobile carrier, pages that you visit before, during and after using the Services, actions that you take while using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
Information from Other Sources
- Third Party Services and Organizations. We may supplement the information that we collect from you (such as your email address) with additional information about you and your company obtained from publicly available and third-party databases or services that provide information about business people and companies (including an individual’s name, job title, business contact information, and company information). This helps us update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
Information We Process via the Narvar SaaS Services
SMS Alerts. The Narvar SaaS Services also allow Customers to ensure that their consumers can obtain information about their orders via SMS. In this case, we will use phone number and other information submitted to us to provide the text messages associated with the SMS service. You may opt out of receiving text messages by replying "STOP" to a text message you have received from us or by otherwise contacting us.
HOW WE USE YOUR INFORMATION
We use your personal information for a variety of business purposes, including:
To Provide the Services or Information Requested, such as:
- Fulfilling our contract with you or the organization on whose behalf you use the Services;
- Responding to questions, comments, and other requests;
- Providing access to certain areas, functionalities, and features of our Services;
- and Answering requests for customer or technical support.
Administrative Purposes, such as:
- Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Measuring interest and engagement in our Services;
- Improving the Services;
- Developing new products and services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Carrying out audits;
- Preventing and prosecuting potentially prohibited or illegal activities;
- Enforcing our agreements; and
- Complying with our legal obligations.
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
DISCLOSING YOUR INFORMATION TO THIRD PARTIES
We may share your personal information with the following categories of third parties:
- Customer. In cases where you use our Services on behalf of our Customer (e.g., your employer), our Customer may access information associated with your use of the Services including usage and other data.
Service Providers. We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.
Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide personal information to business partners with whom we jointly offer products or services.
Affiliates. Narvar may share personal information with our affiliated entities, including members of our corporate family in Australia, France, India, Japan and the United Kingdom.
APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your personal information in order to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Disclosures to Protect Us or Others We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, India, or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
EU – U.S. PRIVACY SHIELD AND SWISS – U.S. PRIVACY SHIELD
Narvar complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States.
Narvar has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield List
Narvar is responsible for onward transfers to our agents under the Privacy Shield Framework. With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Narvar is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (“FTC
If you have any questions or concerns related to our Privacy Shield certification or to resolve any complaints about our collection or use of your personal information, you should first contact us using the information provided below.
Narvar has further committed to refer unresolved Privacy Shield Complaints to our U.S.-based third-party dispute resolution provider (free of charge) that you may contact by visiting the JAMS’ website
Under certain conditions, more fully described on the Privacy Shield website
, you may be entitled to invoke binding arbitration when other dispute resolution options do not satisfactorily resolve your concerns.
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails or you can contact us at firstname.lastname@example.org
. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g.,
. Do Not Track (“DNT
”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
YOUR PRIVACY RIGHTS
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict or object to our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, outdated or improperly processed personal information; (vi) withdraw your consent (Note: if you withdraw your consent to processing, some features of the service may not be available); (vii) request erasure, anonymization, or blocking of personal information held about you by us; (viii) be informed about third parties with which your personal information has been shared; and (ix) request the review of decisions taken exclusively based on automated processing if that could affect data subject rights, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. We may choose to delete personal information by de-identifying and/or aggregating it.
Please note that Narvar is not able to fulfill requests it receives from individuals about personal information that is processed via the Narvar SaaS Services. If you have a request related to personal information processed via the Narvar SaaS Services, please contact our Customer.
SECURITY OF YOUR INFORMATION
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Narvar, in its capacity as a business, has collected about them and whether Narvar disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Personal Information Collected by Narvar
Category of Third Parties
Personal information categories listed in Cal. Civ. Code § 1798.80(e)
Internet or other electronic network activity
Professional or employment-related information
Inferences drawn from other personal information to create a profile about a consumer
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.
Additional Privacy Rights for California Residents
“Sales” of Personal Information under the CCPA. For purposes of the CCPA, Narvar does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.
Verification. When you make a request under the CCPA, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include verifying your email address or other information you have provided to us. If you are a California resident and would like to exercise any of your rights under the CCPA where Narvar is acting as a “business”, please contact us as set forth below. We will process such requests in accordance with applicable laws.
OUR LAWFUL BASIS FOR PROCESSING
For purposes of the EU General Data Protection Regulation, Narvar’s processing of your personal information is supported by the following lawful bases:
- Performance of a Contract: Narvar needs to process your personal information to perform our contract with you or our Customer.
Legitimate Interest: Narvar processes your personal information to further our legitimate interests but only where our interests are not overridden by your interests or fundamental rights and freedoms.
Consent: In some cases, Narvar also relies on your consent to process your personal information.
Compliance with Legal Obligations: Narvar may process your personal information to comply with our legal obligations.
If you are located in the European Economic Area, the United Kingdom, or Brazil you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
THIRD PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
Office of the General Counsel
3 East Third Avenue, Suite 211
San Mateo, CA 94401