Privacy Policy

Last updated: 2023.01.09


This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use our Services and communicates to You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve our Services. By using our Services, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.

Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

CCPA means the California Consumer Privacy Act.

Company (referred to as either the “Company", "We", "Us" or "Our" in this Agreement) refers to Navigatr CS (Canada) Inc. and Navigatr CS (USA) Inc. For the purpose of the GDPR, the Company is the Data Controller.

Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Country refers to Canada and the United States of America.

Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access our Services such as a computer, a cellphone or a digital tablet.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

GDPR means the European General Data Protection Regulation.

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.

Service refers to our Website, and any of the services or goods sold on our Website or through other appropriate means.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate our Services, to provide our Services on behalf of the Company, to perform services related to our Services or to assist the Company in analyzing how our Services is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Usage Data refers to data collected automatically, either generated by the use of our Services or from our Services infrastructure itself (for example, the duration of a page visit).

Website refers to the Company website, accessible from https://www.navigatr.com/

Youor Your means the individual accessing or using our Services, or the company, or other legal entity on behalf of which such individual is accessing or using our Services, as applicable.

Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using our Services.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Transactional and inquiry history
  • Personal preferences for improving the quality of our Service
  • Usage Data

Usage Data

Usage Data may be collected automatically when using our Services.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access our Services by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Website or when You access our Services by or through a mobile device.

Tracking Technologies and Cookies

We may use Cookies and similar tracking technologies to track the activity on Our Website and store certain information. Tracking technologies used may include cookies, beacons, tags, and scripts to collect and track information and to improve and analyze Our Website performance. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Website. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies. We do not currently respond to browser Do Not Track signals.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We may use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

Targeting and Advertising Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest to You. These Cookies use information about your browsing history to group You with other users who have similar interests. Based on that information, and with Our permission, third party advertisers can place Cookies to enable them to show adverts which We think will be relevant to your interests while You are on third party websites.

Social Media Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: In addition to Our own Cookies, We may also use various third parties Cookies to report usage statistics of various social media platforms, deliver advertisements on and through Social Media platforms, including behavioural remarketing and similar audience ads. These Cookies may be used when You share information using a social media networking website such as Facebook, Instagram, Twitter, Pinterest, Snapchat, WeChat, TikTok, YouTube, WhatsApp, Vimeo, or any other social media networking website or mobile application.

Pixel Tags

A pixel tag (also known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages or email messages. When you access these web pages or open an email, pixel tags generate a generic notice of the visit, including the type of device being used, and permit us to set or read our cookies. Pixel tags are used in combination with cookies to track the activity on a site by a particular device. When you turn off cookies, pixel tags simply detect a given website visit or opening of an email message. For email messages, turning off the display of images will disable pixel tags.

For more information about the cookies we use and your choices regarding cookies, please see the Cookies section of our Privacy Policy below.

Your Choices Regarding Cookies

If You prefer to avoid the use of Cookies on the Website, first You must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website. You may use this option for preventing the use of Cookies at any time.

If You do not accept Our Cookies, You may experience some inconvenience in your use of the Website and some features may not function properly.

If You'd like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the help pages of your web browser.

For the Chrome web browser, please visit this page from Google: Clear cache & cookies - Android - Google Account Help

For the Internet Explorer web browser, please visit this page from Microsoft: How to delete cookie files in Internet Explorer

For the Firefox web browser, please visit this page from Mozilla: Clear cookies and site data in Firefox

For the Safari web browser, please visit this page from Apple: Clear cookies in Safari on Mac - Apple Support

For any other web browser, please visit your web browser's official web pages.

More Information about Cookies

A cookie is a small text file that is created by a website and stored on your computer through your browser. The idea is that the website can access the cookie at a later time and retrieve information about you. The website then customizes pages based on this information.

Many uses of cookies are uncontroversial and help the users. Examples include:

  • Storing your username (but not your password) to save you having to remember it or type it in when you return to a site
  • Keeping items in a virtual "shopping basket" for an online retailer website
  • A site such as a weather forecast service or movie theater listings 'remembering' your location and automatically displaying relevant details when you next visit

Cookies fall into two main categories: session cookies only last until you leave the website in question, while persistent cookies will last until a set expiration date, 13 months from when the cookies were first placed on your device.

Advertising

We may partner with third-party advertising companies that serve advertisements regarding goods and services that may be of interest to You when you access and use other websites or online services. You may receive advertisements based on information relating to Your access to and use of Our Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.

Contact Us

If you have any questions about this Cookies Policy, You can contact us:

Limiting Collection

We limit the collection of Personal Data to that which is necessary for the purposes identified by Us in this Privacy Policy.

Children under 18: We do not knowingly collect Personal Data online from individuals under the age of 18 without parental consent. Should We inadvertently acquire personal information from individuals under the age of 18, a parent or guardian of such child may contact Us and upon notification, we will delete from our records any information collected as required by law. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Use of Your Personal Data

By contacting Us and requesting travel services information, or otherwise providing us with Personal Data, You consent to the collection, use or disclosure of Your Personal Data in accordance with the purposes identified below. We may seek additional consent to use and disclose Personal Data after it has been collected but before it is used or disclosed for a new purpose.

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service: including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of our Services. The Personal Data You provide can give You access to different functionalities of our Services that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through our Services.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You: with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • To deliver targeted advertising to You: We may use Your information to develop and display content and advertising (and work with third-party vendors who do so) tailored to Your interests and/or location and to measure its effectiveness.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to advertise on third party websites to You after You visited our Service, to contact You.
  • Travel-Related Service Partners: We may share your personal information with select third parties for marketing purposes. For example, We may work with tour companies to provide You with the opportunity to purchase travel-related services suitable to Your needs.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

This Privacy Policy does not address, and We are not responsible for, the privacy, information or other practices of the above third parties, including any third party operating any website or service to which our Website links. The inclusion of a link on Our website does not imply endorsement of the linked site or service by Us or by Our affiliates.

You may choose not to have your Personal Data disclosed or transferred to third parties in accordance with the terms of this Privacy Policy. However, if You choose not to submit your Personal Data, or allow Us to provide such Personal Data to third parties, then We might not be able to provide the service requested.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Data Retention Timelines

The Company, its affiliates and business partners store data collected to provide the Services to You. Reporting data (which does not contain any personal data), is stored for the duration of the contract we have with you. Reporting data may be deleted at your request. If our contract terminates with you, we do not further collect or use any information received from you for any purposes.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your local jurisdiction, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

You may update, amend, or delete Your information at any time by contacting Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with our Services
  • Protect the personal safety of Users of our Services or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Data Breach Notification

The Company does not guarantee that its security measures will be effective under all conditions. If the Company, it’s affiliates or business partners discover a data breach, we will notify you without undue delay. In the event of any unauthorized access or theft of your data, We will promptly notify you and perform all actions considered reasonably necessary to remedy or mitigate the effects of the data breach.

Nevada Privacy Rights

If You are a Nevada resident, please refer to the “For Nevada Residents” section at the end of this Privacy Policy for more information about your rights under Nevada law.

California Privacy Rights

If You are a California resident, please refer to the “For California Residents” section at the end of this Privacy Policy for information about the information requests You may make under the CCPA.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors may collect, store, use, process and transfer information about Your activity on Our Service in accordance with their privacy policies.

Analytics

We use third-party Service providers to monitor and analyze the use of our Services as well as for the purpose of categorization and analysis of behavioural characteristics using data collected to improve the performance of our advertising and Services provided.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on our Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: Google Privacy Policy

Data Cohorting

Merkle is an analytics consulting service that provides data analysis and consulting services to improve the relevancy, placement, and performance of our Services and offers. Personal data collected is shared with Merkle for the purpose of cohorting and normalization, and is not sold or shared with any third parties by Merkle at any time.

WNS Triange is an analytics consulting service that provides data analysis and consulting services to improve the relevancy, placement, and performance of our Services and offers. Personal data collected is shared with Merkle for the purpose of cohorting and normalization, and is not sold or shared with any third party vendors by Merkle at any time.

Data Enrichment & Customer Intelligence

Neustar is a data enrichment and customer intelligence service that provides competitive insights and customer intelligence to improve the relevancy, placement, and performance of our Services and offers to you. Personal data collected is shared with Neustar for the purpose of customer profile enrichment. Data collected, managed, and provided by Neustar is considered protected data under GDPR and CCPA regulations. If you would like to opt-out of Neustar’s use of information about you in connection with Cookie-based marketing and analytics services, click here for a simple, easy to use link. Alternatively, you can also opt out of the use of Neustar services Cookies by using the Network Advertising Initiative (NAI) Consumer Opt-Out tool, the Digital Advertising Alliance (DAA) tool, or the European Digital Advertising Alliance (EDAA) Opt-Out tool.

Advertising

We may use some or all of the following Service Providers to show advertisements to You and to help support and maintain Our Service.

Google Ads

Google Ads (AdWords) marketing service is provided by Google Inc. Google, as a third party vendor, uses cookies to serve ads about our Services. Google's use of cookies enables it and its partners to serve ads to our users based on their visits and interactions with our Service or other websites on the Internet.

You may opt out of the use of Google Ads Cookies for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: Google Privacy Policy

Google AdSense & DoubleClick

Google, as a third party vendor, uses cookies to serve ads on our Services. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookies for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Bing Ads

Bing Ads is an advertising service provided by Microsoft Inc.

You can opt-out from Bing Ads by following the instructions on Bing Ads Opt-out page: Personalized ads - Microsoft Advertising

For more information about Bing Ads, please visit their Privacy Policy: Microsoft Privacy Statement

Sojern

Sojern as a third party vendor, uses cookies to serve ads on our Services. Sojern’s use of advertising cookies enables it and it’s partners to serve ads to our users based on their visit to our Services or other websites on the Internet. You may opt out of the use of Sojern Cookies for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Criteo

Criteo as a third party vendor, uses cookies to serve ads on our Services. Criteo’s use of advertising cookies enables it and it’s partners to serve ads to our users based based on their visit to our Services or other websites on the Internet. You may opt out of the use of Criteo Cookies and Services for interest-based advertising by visiting the Criteo disable web browsing tracking web page: https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/

MNTN Performance TV

MNTN Performance TV (MNTN) as a third party vendor, uses cookies to serve ads on our Services. MNTN’s use of advertising cookies enables it and it’s partners to serve ads to our users based based on their visit to our Services or other websites on the Internet. You may opt out of the use of MNTN’s Cookies and Services for interest-based advertising by visiting http://optout.aboutads.info/.

Twitter

Twitter marketing services are provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: Your privacy options for personalized ads | Twitter Help

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: Twitter Privacy Policy

Facebook

Facebook advertising services are provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: How Ads Work on Facebook | Facebook Help Center

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: Adjust how ads on Facebook are shown to you | Facebook Help Center. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: Meta Privacy Policy - How Meta collects and uses user data | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy

Pinterest

Pinterest marketing services are provided by Pinterest Inc.

You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: Personalization and data | Pinterest help. You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: Privacy policy

LinkedIn

LinkedIn marketing service is provided by LinkedIn Corp. You can opt-out from LinkedIn’s interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following LinkedIn instructions: Manage Advertising Preferences | LinkedIn help. You can learn more about the privacy practices and policies of LinkedIn by visiting their Privacy Policy page: Privacy policy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Zoho Campaigns

Zoho Campaigns is an email marketing module within the Zoho suite of products. Zoho, as a third party vendor, uses cookies and web beacons to improve the effectiveness of their digital marketing and sales solutions as well as the services they provide to us as a client. You may opt out of email marketing communications by clicking “unsubscribe” within the email body content and confirming your decision. Their Privacy Policy can be viewed at Zoho - Privacy Policy.

AtData

AtData as a third party vendor, uses cookies to serve ads on our Services. AtData’s use of advertising cookies and web beacons enables it to provide services, capture user data, and provide a better service to our users based based on their interactions with our content, emails, or visits to our Services or other websites on the Internet. You may opt out of the use of AtData Cookies and Services for interest-based advertising by visiting the AtData disable web browsing tracking web page: https://instantdata.atdata.com/optout/

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Us to:

  • Measure and analyze traffic and browsing activity on Our Service
  • Show advertisements for our products and/or services to You on third-party websites or apps
  • Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

We may use some or all of these third-party vendors for remarketing services:

Google Ads (Previously AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: Google Ad Settings. Google also recommends installing the Google Analytics Opt-out Browser Add-on - Google Analytics Opt-out Browser Add-on Download Page - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: Google Privacy Policy

Bing Ads Remarketing

Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads interest-based ads by following their instructions: Personalized ads - Microsoft Advertising. You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: Microsoft Privacy Statement

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: Your privacy options for personalized ads | Twitter Help

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: Twitter Privacy Policy

Facebook

Facebook advertising and remarketing services are provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: How Ads Work on Facebook | Facebook Help Center

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: Adjust how ads on Facebook are shown to you | Facebook Help Center. Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: Meta Privacy Policy - How Meta collects and uses user data | Privacy Center | Manage your privacy on Facebook, Instagram and Messenger | Facebook Privacy

Pinterest

Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions: Personalization and data | Pinterest help

You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: Privacy policy

LinkedIn

LinkedIn remarketing service is provided by LinkedIn Corp. You can opt-out from LinkedIn’s interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following LinkedIn instructions: Manage Advertising Preferences | LinkedIn help

You can learn more about the privacy practices and policies of LinkedIn by visiting their Privacy Policy page: Privacy policy

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

Invisible reCAPTCHA

We may use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google. The reCAPTCHA service may collect information from You and from Your Device for security purposes. The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: Google Privacy Policy

For Residents in the European Economic Area

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. To complete these actions, you will need to contact us by email at privacy@navigatr.com to assist you. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of our Services.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You may have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

For Nevada Residents

If you would like to request that the Company refrain from selling your Covered Information, as defined under Nevada law, please contact privacy@navigatr.com.

For California Residents

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: Yes.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Services or advertisements.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: Yes.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: Yes.

Under CCPA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service.
  • Indirectly from You. For example, from observing Your activity on our Service.
  • Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Services or Website.
  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to provide advertising on our Service, third-party vendors to deliver targeted advertising to You, or other third-party vendors that We use to provide our Services to You.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

  • To operate our Service and provide You with our Services.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category C: Protected classification characteristics under California or federal law

Category D: Commercial information

Category F: Internet or other similar network activity

Category G: Geolocation data

Category I: Professional or employment-related information

Category K: Inferences drawn from other personal information

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

Service Providers

Our affiliates

Our business partners

Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
  • The categories of personal information We collected about You
  • The categories of sources for the personal information We collected about You
  • Our business or commercial purpose for collecting or selling that personal information
  • The categories of third parties with whom We share that personal information
  • The specific pieces of personal information We collected about You
  • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
  • The categories of personal information categories sold
  • The categories of personal information categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
  • Denying goods or services to You
  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or services to You
  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

By email: privacy@navigatr.com or by visiting this page on our website: https://ensembletravel.com/privacy

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on our Services that sells personal information as defined by the CCPA. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under the CCPA, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on our Services:

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time, and any changes become effective when we post the revised Privacy Policy on the Website. For material changes that apply to personal information that you provided already, We may notify You and We may ask for your consent to the change.

You are advised to review this Privacy Policy periodically for any changes as well as the “Last updated” date at the top of this Privacy Policy. Your continued use of Our Website after we have updated or changed our Privacy Policy will be considered Your consent to those updates or changes.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: privacy@navigatr.com or by visiting this page on our website: https://ensembletravel.com/marketing/questions/

Ensemble

New York

261 Madison Avenue, 9th Floor #945
New York, NY 10016
United States
(212) 545-7460

Toronto

2 Queen Street East, 20th Floor
Toronto, ON M5C 3G7
Canada
(416) 367-3660

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  • CST: 2141530-70