Version 2.0 – 01 January 2022
Who
we are
-
Navico
Holding AS
-
Navico
Inc.
- Navico Auckland Ltd
- Navico UK Limited
Information
we have about you
We have personal information about you
that you have given us; personal information that we collect from the following
sources:
-
Directly
from you when:
§ You create or use an account,
§ You subscribe to our newsletter,
§ You use our website (See our Website
Privacy Notice[i] and Cookie Policy)[ii]
§ You use our Apps (SIMRAD, LOWRANCE,
B&G and CMAP Apps)
§ You use our connected products.
§ You submit a support or warranty request
to us
-
From
Third Parties, upon obtaining your consent when:
·
You
choose or chose to create an account or to login through the third-party login/account
creation options (Facebook/Apple login)
Personal information you
give us on our websites: See Navico Websites Privacy Notice and Cookie
Policy
Personal information you
give us on our connected products: See the Navico Policy of your SIMRAD,
B&G or LOWRANCE connected product(s), if any.
Please note that your basic personal information,
Navico Account Number and login data, contact information,
order details, and product details, as well as some analytics information are collected
and processed by Navico if they are provided through our websites or Apps or
our connected products. Personal data and consents given through our websites,
Apps and connected products for marketing purpose will be treated as per Navico’s Website Privacy Notice (i).
- When creating your account or connecting to your account:
o Basic personal
information: Name, last Name, age
o Navico account number
and login data
o Facebook Unique / Apple Unique ID if you elected to create/connect to
your accounts via your Facebook/Apple account.
o Contact information:
Email address, phone number, address
o Country of use
o Smartphone
model and brand
- When you select the services you wish
to use/purchase from Navico:
o
Subscription type
o
Transaction records (Order detail, purchase ID, App
Store/Google Play transaction ID)
- When you use our Apps functionalities and services:
o
Last IP Address,
o
Settings and user preference parameters
o
Saved Locations (like your “Home Harbor”), waypoints,
routes and historic GPS tracks
o
Boat Name/Registration information (if you elect to
provide it)
o
Map areas you viewed and downloaded while using our
Apps
o
Limited in-App events and usage analytics to allow
us to provide you with our connected services
-
When you connect your App to a Navico
connected product:
o
Connected product Information (Serial number, brand,
software version and registration status)
o
Connected product setup language
o
Connected product IP address and embedded Wi-Fi
connection credentials
- When you give us your express consent:
o
Product use data* (In-App events and behavior) for
analytics purpose
* Except for in-App
events and use behavior collected to help you use our connected services, in-App
events and use behavior data will be collected on an anonymous basis unless you
consent to provide us such data to improve our Apps and services. We will
anonymize those data collected from your App in case you do not provide your
consent.
o
Temporary live location (Only if you elect to
enable the Navico Mobile Community “Traffic” Function*, upon providing Navico
with your express consent by activating this option on the App)
*Please note
that Live location data are retained by Navico for a very short period to
maintain your privacy. When user enabled, the Navico Mobile Community Traffic
will only maintain your live location data for 30 minutes in cache. Such
information will be automatically purged from our system after that period.
Why
we need your personal information
We need certain types of personal
information from you so that you can buy our goods and/or use our services and
we can make sure we process your orders correctly.
We also need to process some information
to offer you connected service
We notably need to process the following
type of information:
-
Your
basic personal information: Name, last name,
date of birth, as well as Navico account number and Login Data to administer
your account with Navico and ensure proper synchronization of our different
services
-
Your
transaction data and product details to comply with our legal obligation and
process support/warranty requests.
-
Your
subscription type to make sure we provide you with the relevant type of
services and software updates on our Apps
-
Your
boat Information, settings, user preference, waypoint, routes, historic GPS
tracks and connected products information to ensure proper interaction between
our different systems through our cloud solution, enable seamless
synchronization between our Apps and our connected devices and allow you to
access the information about your previous activities and planned routes from
your connected devices and Apps
-
Your
country location to make sure you are located in a country
we can provide service to when setting up your App
-
Your
Email Address to make sure we can communicate with you
-
Some
In-App events to make sure we provide you with the relevant support and
services where needed
-
Your
Live location when you consented to it, to provide you with the Community
Traffic services
How we use your personal information
We use personal information only to the
extent that is necessary to operate our business. The law allows us to use personal information
as long as we tell you what we are using it for and we
have a valid legal basis for doing so.
You will find the relevant legal basis
for the processing of each piece personal information you provide to us below:
When we need to fulfil our Contractual
Obligations to you:
●
To
maintain your account with us
●
To
provide you with the services your purchased from us
●
To
process, administer and deliver your order and to provide you with updates
about your order status/ and software subscription
When it is in our
legitimate interests (i.e. we have a business or
commercial reason which we do not prioritize above your rights)
●
To
verify and process your warranty registration and claims. We have a legitimate
interest in verifying that warranty claims submitted to us are legitimate
●
To
verify your location and identity, and ensure we are not selling to persons
listed on trade sanction lists or located in embargoed countries
●
To
sufficiently verify your identity and treat potential subject access requests
●
To
communicate about how we process your personal data and how such processing
evolve
●
To
provide you with information regarding the products you purchased, such as
availability of new features, software and updates
●
To
understand when you face issues with our services and our apps and be able to
assist you
Where we have your
consent
●
To
provide you with targeted advertising and special offers, based on the products
you purchased or showed interest to when browsing our website and Apps
●
To
analyze how you use our website, Apps, products and
services
●
To
provide you with services that imply that we process your live location
●
To
provide you with marketing information about our products and services*
You have the right to withdraw your
consent at any time. If you would like to unsubscribe from an email sent to
you, follow the ‘unsubscribe’ link placed at the bottom of the email. You can
also notify us to change your marketing communication preferences using the
Contact Us form on the website or reaching out to unsubscribe@navico.com. If you withdraw your consent, this will
not affect the lawfulness of any processing carried out by us using your
consent before such withdrawal.
When we are under a legal
duty
●
To
allow us to comply with our legal, accounting, regulatory and tax obligations
●
To
establish, defend or exercise our legal rights
●
To
be able to notify you of important changes that may impact the processing of
your data and management of your account
Who
we share your personal information with
We will only share your
personal information with other organizations after careful consideration and
only when we have a legitimate reason.
We may share your personal information
with:
●
The
Navico co-controlling entity based on your geographical location:
○
Navico
UK and Navico Marine Electronic S.L for EMEA
○
Navico
Inc. for America
○
Navico
Auckland Inc. for Asia
○
Other
Navico entities for the purpose of providing local marketing content and offers
from time to time
●
Our
service providers, suppliers, partners and
subcontractors where this is necessary to provide our services to you
●
Any
prospective buyer of all or part of our business or assets (and associated
advisors and agents)
●
Our
legal and other professional advisors and any other organization necessary to
enforce our terms of use and other agreements and/or to protect the rights,
property and safety of us, our users, or others
Transfers of personal
information outside the European Economic Area
● Is in a country which the European
Commission deems to provide an ‘adequate’ level of data protection
● Has entered into a contract with us which
incorporates the European Commission’s Model Clauses
● Is one of our group companies and we have
signed an Intercompany Data Protection Agreement that integrates the European Commission’s
Model Clauses. We only transfer your personal data to our
company responsible for customers in your region:
○
Navico
Marine Electronics SL (Spain) and Navico UK Ltd. (UK) acting as co-controllers for
personal data of data subjects based in Europe, Middle East, and Africa
(including the EEA)
○
Navico Marine Electronics SL (Spain) and Navico Inc.
(USA – Oklahoma) acting as co-controllers for personal data of data subjects
based in South and North America
○
Navico Marine Electronics SL (Spain) and Navico
Auckland Limited acting a co-controllers for personal
data of data subjects based in Asia and Oceania
How long we keep your Personal Information
We only keep your
personal information for as long as we need it to carry out the different
activities set out above. These periods are different depending on the nature
of the activity. We also keep your personal information for as long as is
necessary to comply with our legal obligations and to defend or exercise any
legal claims.
●
We
keep your personal data collected for marketing purpose upon receipt of your
consent for 3 years from the date of providing your consent
●
We
keep your personal data collected from any ecommerce transaction for 7 years
●
We
keep your personal data collected for legitimate interest, accounting
and auditing for 7 years
●
We
keep the data related to your account at Navico and the connected services for
as long as you maintain you account with Navico
●
We
only maintain live location data for thirty minutes from the time of their
collection
As soon as there is no longer any need
for us to hold your personal information, we will delete it or, in some cases, anonymize
it so you can no longer be identified from it.
Sale
of Personal Data
We do not sell, rent or trade your Personal Information with any third
parties for commercial purpose. Your Personal Information is only shared with
third parties as described in this notice and for the purposes mentioned above.
Your
Rights
You can exercise your
rights at any time by emailing us at DPO@navico.com. We will verify your identity before we
deal with your request so your personal information is
protected against unauthorized access.
You may also request that we provide you with
a list of our third-party partners, with whom we share your data for the
purposes mentioned in this Privacy Notice, if you submit a legitimate request
for information.
To opt-out of marketing
communications
You have the right to withdraw your consent
at any time. If you would like to unsubscribe, follow the ‘unsubscribe’ link
placed at the bottom of the email. You can also notify us to change your
marketing communication preferences using the Contact Us form in the app or by emailing us at unsubscribe@navico.com.
To know what personal
information we have collected and request a copy of the personal information we
hold about you
To ask us to correct any
inaccurate information we hold about you
To ask us to delete any
personal information we hold about you
You have this right in certain
circumstances only. For example, it does
not apply if we need to use your personal information to comply with our legal
obligations or to establish, exercise or defend a legal claim.
To ask us to restrict our
use of your personal information
You have this right in certain
circumstances, for example where you have objected to our use of your personal information,
and we are considering whether our legitimate interests override yours. This is often a temporary measure, and we are
still allowed to store your information while we are restricted from using it.
To ask us to transfer
your personal information to you or another organization
This right is also known as the right to
data portability. It is your right to
have your personal information ported to you or a nominated third party in a
structured, commonly used and machine-readable
format.
This right applies only to information
which we have collected from you and which we process using automated
means. You have this right only where we
are using your personal information with your consent or to fulfil our
contractual obligations to you (see: How
we use your personal information)).
To object to our use of
your personal information
You have this right only in relation to
our use of your personal information on the ground of legitimate interests (see
How we use your personal information).
Not to be subject to discriminatory
treatment.
You have the right not to receive
discriminatory treatment for the exercise of your rights under the relevant
privacy regulations, including, notably, the CCPA, subject to certain
limitations.
Changes
to our privacy notice
Our Privacy Notice will
be revised regularly to ensure that we provide you with the most updated
information with regards to the way your data are collected and processed. In
any case, we shall review this Privacy Notice at least every twelve (12) months
and amend it where necessary.
Any changes we make to this policy will
be posted on this page. Where the
changes are significant, we will let you know by email or in another
appropriate manner such as when you next interact with our website.
If we believe that the changes materially
affect the way we process data that we collect based on your consent, we may
elect to either inform you and offer you a way to withdraw your consent by email
or ask you to give your consent again.
Contact
us
You have the right to withdraw your
consent at any time. If you would like to unsubscribe from an email sent to
you, follow the ‘unsubscribe’ link placed at the bottom of the email. You can
also notify us to change your marketing communication preferences using the Contact
Us form on the app or reaching out to unsubscribe@navico.com.
We really do welcome any questions, comments or requests you may have regarding this privacy
notice. You can email us at DPO@Navico.com or write to us at:
Data Protection Officer
Navico Marine Electronics S.L.,
Muelle Levante, 6
Módulo 14, Local 1, 03001 Alicante,
Spain
Please also use these contact details if
you have any complaints about the way we have used your personal information.
If we do not deal with your complaint
satisfactorily and within a reasonable timeframe, you have the right to
complain to the Spanish Data Protection Authority.