Privacy Policy

Thank you for your interest in our website www.thenavia.com (the “Website”) owned and operated by Navia, a Wyoming Corporation, hereafter referred to in this Privacy Policy as “Navia”, “us”, “our” or “we”. Unless otherwise specified, all references to our services (the “Service”) include the content, services and products available through the Navia Website, as well as any software that Navia provides to you that allows you to access the Services though the Website. The term “user”, “you” or “your” refers to the user of our Website and our Service.

Navia respects the privacy of your personal information and, as such, we use commercially reasonable measures to ensure your information is protected and remains private. We have provided this Privacy Policy to explain how we collect, use, share and protect information about the users of our Website. We will not use or share your personal information with anyone except as described in this Privacy Policy.

Navia collects information about you when you use our Website to access our Services, software, content, information, applications, recommendations, email notifications, direct messages and other mediums, or portions of such mediums, that Navia provides to you, collectively the Services.

This Privacy Policy will inform you about the types of personal information we collect, the purposes for which we use the data, the ways in which the data is handled and your rights with regard to your personal information.

By using, accessing, or interacting with our Website and our Services, you consent to the collection, use, storage, transfer and sharing of personal information that we receive from you through such use, access, and interactions with us as described in this Privacy Policy.

For purposes of this Privacy Policy, “Your Information” or “Personal Information” means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information (“PII”). PII means individually identifiable information that would allow us to determine the actual identity of a specific living person, while sensitive data may include other information, comments, content and other information that you voluntarily provide.

We may change this Privacy Policy at any time, with or without notice to you. If we make a change, we will post the updated policy on our website and update the "Last updated" date. We may also notify you by email or in the Service, but we are not required to. Your continued use of the Service after a change means the updated policy applies to you, to the extent the law allows. Please check this page from time to time.

BY YOUR USE, AND CONTINUING USE, OF THE WEBSITE OR APP AND OUR SERVICES, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND YOU CONSENT TO THE COLLECTION, TRANSFER, MANIPULATION, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION (COLLECTIVELY, “USE OF YOUR INFORMATION”) AS DESCRIBED IN THIS PRIVACY POLICY AND OUR TERMS OF USE WHICH MAY BE ACCESSED HERE. IF YOU DO NOT, OR NO LONGER, AGREE WITH OR CONSENT TO THIS PRIVACY POLICY AND OUR TERMS OF USE YOU MAY NOT ACCESS OR USE OUR SERVICES.

1. Information Provided Directly By You

We collect information you provide directly to us, such as when you request information about our Services, create or modify your account, enroll in an available Subscription Plan or newsletter, make a purchase, request Services, complete a Navia form, survey, questionnaire or application, contact customer support, join or enroll for an event or otherwise communicate with us in any manner. This information may include, but is not limited to, your name, date of birth, e-mail address, business name and physical address, business details, conversations with platform and content created, plan and billing details (full card numbers are handled by our payment processor and never reach us), information about your connected accounts, if you choose to connect them, information about your device and browser, and anything you need when you contact us.

Please do not enter sensitive information into Navia, such as health information, government ID numbers, financial account numbers, or information about children. Navia is not designed to protect it, and you are responsible for what you enter and the information that is associated with your account.

2. Information Collected Through Your Use of Our Services

We may collect certain information about you automatically when you visit or use our Services, or when you interact with emails, advertisements, or other electronic messages we send to you. This information may include your IP address, device characteristics (including device identifiers), web browser characteristics, unique identifiers and other data stored in cookies, operating system details, language preference, referring URLs, length of visits, pages viewed, and other information that may be automatically accessible to us from your browser or device. The following are situations in which you may provide Your Information to us:

a. When you fill out forms or fields, and connect your channels through our Services;

b. When you register for an account with our Service;

c. When you enroll in an available Subscription Plan;

d. When you order products or services from us, or through our Service from our affiliates or advertisers;

e. When you provide responses to a survey or questionnaire;

f. When you join or enroll in an event through our Services;

g. When you register for any newsletters, forum or other materials through our Services;

h. When you provide information to us through a third-party application, service or website;

i. When you communicate with us or request information about us or our products or Services, whether via email or other means;

j. When you participate in any of our marketing initiatives, including, contests, events, or promotions; and

k. When you participate in forums, reviews or provide or post user generated content as defined in our Terms of Use, or other submissions.

We also automatically collect non-personal information through the use of various technologies, including, but not limited to, cookies, web server logs, tags, SDKs, tracking pixels, local storage, Scripts, APIs, session replay, screen capture, and other similar technologies. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.

3. Information Collected From Other Sources Including Third Party Social Networking Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your Navia account with a social media and networking service included in the platform, or if you engage with a separate application or website that uses our API, or whose API we use, we may receive information about you or your connections from that website or application. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social network or media account, age range, language, country, friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other information you permit the social media and networking service to share with third parties. The data we receive is solely dependent upon the privacy settings you have selected with the social media and networking service. You agree that you have read the third party social media or networking service Terms of Service and Privacy Policy, authorize Navia to access certain information about you that is made available through that third party social networking site, and further authorize us to collect, store, retain and use, Your Information in accordance with our Privacy Policy.

4. Aggregated Data

We may collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Information as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy. When we de-identify information, we commit not to try to re-identify it, except as the law allows.

5. Cookie Policy, Log Files and Anonymous Identifiers

a. When you visit or use our Services, we may send one or more Cookies small data files to your device to uniquely identify your browser and let us help you log in faster and enhance your navigation through the platforms. “Cookies” are text-only pieces of information that we may transfer to an individual’s device for record keeping purposes. A Cookie may convey anonymous information to us about how you browse the Services so we can provide you with a more personalized experience, but does not collect Personal Information about you. Cookies allow our Service to remember important information that will make your use of the Service more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.

b. Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Website.

c. Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).

d. When we use session Cookies to track the total number of visitors to our Website, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any Personal Information).

e. We may also employ Cookies so that we remember your device when it is used to return to the Website to help customize your web experience. We may associate Personal Information with a Cookie file in those instances.

f. We use Cookies to help us know that you are logged on, provide you with features based on your preferences, understand when you are interacting with our Services, and compile other information regarding use of our Services.

g. Third parties with whom we partner to provide certain features on our Website or to display advertising based upon your Web browsing activity (including Affiliates and Sponsors) use Cookies to collect and store information.

h. Our Website may use remarketing services, to serve ads on our behalf across the internet on third party websites to previous visitors to our Website. It could mean that we advertise to previous visitors who haven’t completed a task on our Website. This could be in the form of an advertisement on the Google search results page or a website in the Google Display Network. Third-party vendors, including, but not limited to, Google, use Cookies to serve ads based on your past visits to our Website. Any data collected will be used in accordance with our own privacy policy, as well as Google’s privacy policies. To learn more, or to opt-out of receiving advertisements tailored to your interests by our third parties, visit the Network Advertising Initiative at www.networkadvertising.org/choices.

i. We may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including Cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager here https://adssettings.google.com/authenticated?hl=en. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout. For additional information on how Google uses data when you use Google partners’ sites or apps, go here: https://policies.google.com/technologies/partner-sites.

j. You can control the use of Cookies at the individual browser level. Use the options in your web browser if you do not wish to receive a Cookie or if you wish to set your browser to notify you when you receive a Cookie. You can easily delete and manage any Cookies that have been installed in the Cookie folder of your browser by following the instructions provided by your particular browser manufacturer. Consult the documentation that your particular browser manufacturer provides. You may also consult your mobile device documentation for information on how to disable Cookies on your mobile device. If you reject Cookies, you may still use our Website, but your ability to use some features or areas of our Service may be limited. We cannot control the use of Cookies by third parties (or the resulting information), and use of third party Cookies is not covered by this policy.

k. We cannot control the use of Cookies by third parties (or the resulting information), and use of third party Cookies is not covered by this policy.

l. We automatically collect information about how you interact with our Services, preferences expressed, and settings chosen and store it in Log Files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or Website functionality, and to document your consent to receiving products, services or communications from us or our partners. If we link such information with personally identifiable information in a manner that identifies a particular individual, then we will treat all such information as PII for purposes of this Privacy Policy.

m. When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns to enforce our Terms, protect our rights, and comply with the law. No Personally Identifiable Information from your account is collected using these Web Beacons.

6. Table of Possible Cookies

The following is a list of the possible Cookies we may use in our Services. Please note that the Cookies and other technologies may change over time. We run a cookie scan from time to time, and the list below may not include every cookie.

7. Device Information

When you use our Services through your mobile phone or other digital devices, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.

8. Call and SMS Data

In connection with providing Service, we may receive call data, including the date and time of the call or SMS message, the parties phone numbers, and the content of the SMS message. You consent to the receipt, collection and storage of this information unless you opt out.

9. Children’s Privacy

Navia is for adults only. You must be 18 or the age of legal adulthood where you live. We do not knowingly collect information from anyone under that age. If you believe a child has given us information, contact us and we will delete it. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, without receiving the consent of a parent or legal guardian, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.

10. Protective Measures We Use

We protect Your Information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure Your Information, we do not promise, and you should not expect, that your Personal Information, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

11. Payment Information

Payments are processed by Stripe, through our sign-in and billing provider Clerk. We do not receive or store your full card number. We receive limited billing details such as your plan, payment status, and the brand and last four digits of your card. Stripe’s privacy policy applies to the payment information it handles.

12. How We Use Information We Collect

We do not sell your personal information for money. Some laws treat certain advertising and analytics activities, such as the Meta and Google tags on our website, as "sharing" or "selling" for advertising. You can opt out as described in Section E. We do not use your content to train AI models that are available to others.Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will use this information in order to:

a. Operate and provide our Services;

b. Improve our internal operations, systems, products, and Services;

c. Provide users with customer support including, sending you related information, including confirmations, technical notices, updates, security alerts, and administrative messages;

d. Understand you and your preferences to enhance your experience and enjoyment using our Services;

e. Analyze, improve and manage our Services and operations;

f. Contact you for administrative, account maintenance purposes;

g. Resolve problems and disputes, and engage in other legal and security matters;

h. Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;

i. Enforce our Terms of Use and any terms and conditions of any agreements for our Services;

j. Send you communications we think will be of interest to you and marketing emails, including information about our services, products, promotions, events and news about Navia;

k. Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.

l. Create content, plans, and suggestions for you with AI (see section A).

m. Measure and run our own advertising on our website (see Section E).

13. How We Share Information We Collect

a. We share the information we collect about you as described in our Terms of Use and this Privacy Policy, or as described at the time of collection or sharing, as follows:

i. With third party Service Providers to enable them to provide the Services you request. Access to your Personal Information by these Service Providers is limited to the information reasonably necessary in order for them to perform their limited function for us. We also require that these Service Providers (a) protect the privacy of your Personal Information consistent with this Privacy Policy, and (b) not use or disclose your Personal Information for any purpose other than providing us with products or services for which we contracted;

ii. With Clerk.com (https://clerk.com) a Service Provider we use to authenticate, manage and store data for our users and the subscribers of our Services. Clerk also handles our billing, and passes payments to Stripe. We also require that Clerk.com (a) protect the privacy of your Personal Information consistent with this Privacy Policy, and (b) not use or disclose your Personal Information for any purpose other than providing us with products or services for which we contracted;

iii. With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate;

iv. With Navia subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes. Any information relating to you that we provide to our subsidiaries and affiliated entities will be treated by those parties in accordance with the terms of this Privacy Policy;

v. With Service Providers that may now or in the future provide payment processing services on our behalf. Access to your Personal Information by these Service Providers is limited to the information reasonably necessary in order for them to perform their limited function for us. We also require that these Service Providers (a) protect the privacy of your Personal Information consistent with this Privacy Policy, and (b) not use or disclose your Personal Information for any purpose other than providing us with products or services for which we contracted;

vi. With vendors, consultants, marketing partners, and other Service Providers who need access to such information to carry out work on our behalf. Access to your Personal Information by these Service Providers is limited to the information reasonably necessary in order for them to perform their limited function for us. We also require that these Service Providers (a) protect the privacy of your Personal Information consistent with this Privacy Policy, and (b) not use or disclose your Personal Information for any purpose other than providing us with products or services for which we contracted;

vii. In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, court or legal process;

viii. With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our Terms of Use or policies, or to protect the rights, property, or safety of Navia or others;

ix. In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company. We require that these parties (a) protect the privacy of your Personal Information consistent with this Privacy Policy, and (b) not use or disclose your Personal Information for any purpose;

x. If we otherwise notify you and you consent to the sharing; and,

xi. In an aggregated and/or de-identified form which cannot reasonably be used to identify you.

xii. With the social media platforms and other services you connect, and with our posting provider, when you ask us to post or connect an account (see Section B)

xiii. With advertising and analytics providers, as described in Section E.

b. We may disclose Your Information as follows:

i. To any person who, in our reasonable judgment, is authorized to receive Your Information, including as a result of your business dealings with that person (for example, your attorney);

ii. As required by law or ordered by a court, regulatory, or administrative agency;

iii. As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;

iv. To enforce our Terms of Use, this Privacy Policy, and any other applicable agreements and policies.

14. Sharing Information With Law Enforcement

a. Navia is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If Navia receives a request for user account information from a government agency investigating criminal activity, we may review the request to check that it satisfies legal requirements before releasing information.

b. Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer Communications or Records), Navia may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. Navia will not release more information than it prudently believes is necessary to prevent harm in an emergency situation.

15. Social Network or Media Sharing

a. Our Services may now, or in the future, integrate with other services providing social network sharing features, and other related tools, that allow you to share actions you take on our Services with other applications, websites, or media, and vice versa. When you connect a social media account and approve a post, we send the content you approved, and the related account details, to our posting provider and the platform. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social network sharing service. Please refer to the privacy policies of those social network sharing services for more information about how they handle the data you provide to, or share through them. Once content is published, it is public (or visible to whoever the platform allows) and is governed by the platform's privacy policy. We cannot remove it from the platform for you.

b. Any information or content that you voluntarily disclose for posting publicly to a social network sharing service becomes available to the public, as controlled by any applicable privacy settings that you set with the social network sharing service. Once you have shared User Content or made it public, that User Content may be re-shared by others. If you remove information that you posted to the social network sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using the social network sharing service, have re-shared, copied or saved that User Content.

16. User Content and Public Sharing

a. If we permit you to share User Content as defined in our Terms of Use or to post a comment or message that contains personally identifiable information to a page, or area of our Services that is accessible to the public, or accessible to other users of our Service, third parties may use that information, or share it with other parties. As a result, you may receive unsolicited messages from other parties. Such User Content, comments or messages are not subject to this Privacy Policy and you share this information at your own risk. a. The Service does not currently have public forums, comment areas or public profile pages. If we add them, anything you post there may be visible to others, who may use it or share it, and you may receive unsolicited messages. That content is not private and you share it at your own risk. Content you choose to publish on social media through Navia becomes public (or visible to the audience the platform allows) as soon as it is posted, and is governed by that platform's privacy policy.

b. You will need to contact Navia in the event that you wish to have this personally identifiable information removed from our Service. Please note that responding to your request may not ensure complete or comprehensive removal from the internet if the content or information has been reposted by another party. To request removal of content or information, please contact us at hello@thenavia.com.  We cannot remove a post from a social platform for you, which is already covered in Section 15.

17. Analytic Services Provided By Others

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use Cookies, Web Beacons, software development kits (SDKs), and other technologies to identify your device when you visit our Website and use our Services, as well as when you visit other online sites and services. On our marketing website we use the following tools (but are not limited to): Google Analytics and Google Tag Manager, the Meta Pixel and Meta's Conversions API (Facebook and Instagram), and Vercel Web Analytics. This is to understand how people use our website and Service and to measure and run our own advertising. These providers may collect your IP address, device and browser information, and your activity, and may use it under their own privacy policies. See Section E for how to opt out.

18. Links to Third-Party Websites, Affiliates and Advertisers

a. Our Services, as well as the email messages sent with respect to our Services, may contain links or access to websites operated by third parties that are beyond our control. These third parties may include paid Advertisers or Affiliates that may provide us with compensation when you click on their links. Access or links to third parties from our Services are not an endorsement by us of such third parties, or their websites, applications, merchandise, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties. These third-parties may send their own Cookies to you and independently collect data.

b. If you visit or access a third-party Website, application or other property that is linked or accessed from our Services, we encourage you to read any privacy policies and terms and conditions of that third party before providing any personally identifiable information. If you have a question about the terms and conditions, privacy policy, practices or contents of a third party, please contact the third party directly.

19. Do Not Track Settings

Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting Cookies, as browsers with a “do not track” feature enabled may still accept Cookies. There is no common standard for how to respond to "do not track" signals, and we do not respond to them. We do treat a Global Privacy Control signal from your browser as a request to opt out of the sharing of your information for advertising on that browser.

20. International Privacy Practices; Users Outside of the United States

Navia is based in the United States, and our providers store and process information in the United States and possibly other countries. If you live or are located outside the United States, your personal information will be transferred to and processed in the United States and other countries, where privacy laws may be different from, and less protective than, those where you live. Where the law requires it, we use safeguards for these transfers, such as standard contractual clauses or similar arrangements with our providers. By using the Service you acknowledge these transfers and the risk that protection may be different.

21. Account Information

You can correct your account information at any time in your account settings, or by emailing us at hello@thenavia.com. You can cancel your subscription in the security section of your account settings. Cancelling stops future charges but does not delete your account or Your Content. You can delete your account in the app in the security section, or by emailing us at hello@thenavia.com . After deletion we delete or de-identify your information within a reasonable time. We may keep some information afterward where the law requires, to resolve disputes, to enforce our Terms, or in backups for a limited period, and our email list provider may keep a record until you ask us to remove it. Content already published to social media is controlled by the platform.Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law.

22. Promotional Information Opt Out

You may opt out of receiving promotional messages from us at any time by following the instructions in those messages sent to you or by contacting us at any time using the Contact Us information at the end of this Privacy Policy. In doing so, you elect not to receive correspondence from us or have Your Information shared with other entities for their marketing purposes. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations. We will act on your opt-out within 10 business days. You can also ask us to remove you from our email list by emailing hello@thenavia.com.

23. The Legal Basis and Reasons For Collection and Processing Your Personal Information

The legal basis upon which we rely for the collection and processing of your Personal Information are the following:

a. When registering to use our Services, you have given us explicit consent allowing Navia to provide you with our Services and generally to process Your Information in accordance with this Privacy Policy;

b. It is necessary for entering into, or performing, the obligations of a contract between you and Navia, including, without limitation, the Terms of Use agreement which may be accessed by you here and any available paid plan for our Services that you agree to;

c. It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in.

d. It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you;

e. To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support.

f. To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative, billing and account management related messages.

g. To send promotional communications and marketing emails that you have consented to receive;

h. It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you;

i. It is necessary for our compliance with certain legal provisions which may require us to process your Personal Information. By way of example, and without limitation, we may be required by law to disclose your Personal Information to law enforcement or a regulatory agency;

j. It is necessary to carry out your requests, such as connecting a social media account and posting for you when you agree to;

k. Where you have given us your consent, such as for non-essential cookies and advertising tags or for marketing emails. You can withdraw your consent at any time.

24. General Data Protection Regulation (GDPR); Your Access and Rights to Your Personal Information

You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

a. Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and in certain cases updating or deleting such information. Furthermore, if you prefer that we do not share certain information as described in this Privacy Policy, you can direct us not to share that information. We will comply with an individual’s requests regarding access, correction, sharing and/or deletion of the personal data we store in accordance with applicable law. To make changes to your account affecting your personal information contact us at the email address in our Contact section below. For any deletion, non-sharing or update request, we will make the changes as soon as practicable; however this information may stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.

b. Right of Correction or Completion of Your Personal Data. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.

c. Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request deletion of information please contact us at the email address in our Contact section below.

d. Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.

e. Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.

f. Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please, contact us at the email address in our Contact section below.

g. Right to Complain. You have the right to file a complaint regarding our data protection practices with a supervisory authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en.

h. Navia uses AI to generate content and suggestions. We do not make decisions about you that have legal or similarly significant effects based only on automated processing.

25. Your Nevada Consumer Privacy Rights

We do not sell consumers’ covered Personal Information for monetary consideration (as defined in Chapter 603A of the Nevada Revised Statutes). However, if you are a Nevada resident, you have the right to submit a request directing us not to sell your Personal Information. To submit such a request, please contact us using the information in the “Contact Us” section at the end of this document.

26. Your Canadian Privacy Rights

If you live in Canada, you may ask for access to, correction of, or deletion of your personal information, and may withdraw consent, subject to legal limits. To submit such a request, please contact us using the information in the “Contact Us” section at the end of this document. We send marketing emails only with the consent Canadian anti-spam law requires, and you can unsubscribe at any time. Information may be stored outside Canada, including in the United States.

27. Your Colorado, Connecticut, Virginia, and Utah Privacy Rights

Depending on where you live (for example Colorado, Connecticut, Virginia, Texas, Oregon and others), you may have the right to know, access, correct, delete and receive a copy of your personal information, and to opt out of targeted advertising, sale and certain profiling. To use these rights, contact us at the address in Section 30. We will respond within the time the law allows. If we decline your request, you may appeal by replying to our decision, and we will respond to the appeal within the time the law allows. If you are still not satisfied, you may contact your state attorney general.

28. California Consumer Privacy Rights

This section has been provided to comply with the California Consumer Privacy Act (the “CCPA”), the California Privacy Rights Act (the “CPRA”) and the California Shine the Light Act, collectively the “California Privacy Laws”, and applies solely to residents of the State of California; it is designed to supplement the information provided elsewhere in this Privacy Policy. Please read the entire Privacy Policy in conjunction with the following terms.

Information We Collect. We collect information that identifies directly or indirectly, with a particular person or a device (“personal information”). Below, if indicated “YES” in the 3^rd column, are the categories of personal information collected about California residents in the past 12 months:

b. Direct Collection. We collect information directly from you when you fill out forms or fields through our Service; register for an account; subscribe to a service plan; order products or services from, or through our Service; provide responses to a survey or questionnaire; join or enroll in an event through our Service; sign up for any newsletters or other materials; provide information to us through a third-party application, service or website; communicate with us or request information about us, or our products or Service, whether via email or other means; and participate in any of our marketing initiatives.

c. Indirect Collection. We may Collect Information Indirectly from you through the use of various technologies, including, but not limited to Cookies, Pixel Tags and Web Beacons.

d. Our Use of Personal Information. Please refer to Section 12 of this Privacy Policy.

e. How We Share Personal Information. Please refer to Section 13 a. of this Privacy Policy.

f. Disclosures of Personal Information. Please refer to Section 13 b. of this Privacy Policy.

g. Children. We do not knowingly collect personal information from anyone under 18, and we do not sell or share the personal information of anyone under 16.

INDIVIDUAL RIGHTS AND CHOICES FOR CALIFORNIA RESIDENTS

h. Right to Access Specific Information and to Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

i. The categories of personal information we collected about you.

ii. The categories of sources for the personal information we collected about you.

iii. Our business or commercial purpose for collecting that personal information.

iv. The categories of third parties with whom we share that personal information.

v. The categories of personal information that each recipient received.

vi. The specific pieces of personal information we collected about you.

i. Right to Request Deletion. You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete your personal information from our records.

j. Exercising Your Rights to Access, Data Portability, and Deletion. To exercise the access, data portability, and deletion rights discussed herein, you must submit a verifiable consumer request to us using the How to Contact Us information at the end of this Privacy Policy. Only you, or a person you have designated in writing as your authorized agent (“Authorized Agent”), may make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must (a) describe your request in adequate detail, and (b) include sufficient information that allows us to verify that you are the person associated with the personal information we collected. We will respond within 45 days. If we need more time, we may extend that once by up to 45 more days, and we will tell you why.

k. Non-Discrimination. We will not discriminate against you because you exercise any of the rights provided by the California Consumer Privacy Act.

l. Do Not Sell My Personal Information; Opt Out. We do not sell your personal information for money. Our marketing website uses some pixels and tags, including, but not limited to, the Meta Pixel and Google tags, which some laws treat as "sharing" your information for advertising. You can opt out using the "How to Contact Us information at the end of this Privacy Policy, or by sending a Global Privacy Control signal from your browser. You can opt out of marketing emails by using the unsubscribe link in any message, or by contacting us using the How to Contact Us information at the end of this Privacy Policy. If you opt out of marketing emails, we may still send you non-promotional communications, such as those about your account, services you have requested, or our ongoing business relations.

m. Other California Privacy Rights

i. Shine The Light Act. California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the information in the How to Contact Us section at the end of this Privacy Policy.

ii. Do Not Track. Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. We do not take any action in response to this signal.

iii. Right to Correct. You have the right to ask us to correct inaccurate personal information we hold about you. Send your request using the How to Contact Us information at the end of this Privacy Policy.

iv. Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit.

v. Retention. For how long we keep personal information, see Section 29.

29. Our Information Retention Policy

We keep your information while your account exists and for as long as we need it for the purposes in this policy. After you delete your account, we delete or de-identify your information within a reasonable time, except where we must keep it to follow the law, resolve disputes, or enforce our agreements, or where it remains in backups for a limited period. Billing records are kept as long as tax and accounting laws require. Our email list provider may keep a record until you ask us to remove it.

a. How Navia uses AI
Navia uses artificial intelligence services provided by third-party AI providers to generate content and suggestions. We send the information needed for the task (for example your business details, writing samples, chat messages and website content you ask us to read) to those providers for processing. AI output can be wrong. Do not enter sensitive information. We do not use your content to train AI models available to others. The AI providers' privacy terms apply to their processing.

B. Publishing, connected accounts and post results
If you connect a social media account, we use a third-party posting provider to connect to it. We store access tokens that allow posting on your behalf until you disconnect. When you click "Post it now" or schedule a post, we send the approved content to our posting provider and the platform. We also receive post performance information (such as likes, comments and reach) and show it to you and use it to improve suggestions for your business. You can disconnect an account at any time. We keep a record of what you approved and when. Published content is controlled by the platform.

C. Reading your website and Instagram
If you ask Navia to read a website or a public social media page, we use third-party tools to collect publicly available content from the page you provide. We use it only to understand your brand and create content for you. You promise that you have the right to ask us to read the page (see our Terms).

D. Our service providers
We use the following types of service providers to run Navia. Each receives only the information it needs to do its job:
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Sign-in, billing and payment providers: sign-in, subscriptions and payments. They receive your name, email, sign-in details, plan and billing details.
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Database and hosting providers: store and run the Service, store files, and measure website visits. They receive your account data, Your Content, files and visit data.
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AI providers: generate content and suggestions. They receive the content you send for AI tasks.Website and public-page reading providers: read pages you point us to. They receive the address of the page and read its public content.

Social media posting provider: posting, scheduling and post performance. It receives your approved post content, your connected social account tokens and post performance information.
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Email and event providers: email list, marketing email and event sign-ups. They receive your name, email and event attendance.
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Design and image providers: design tools and stock images. They receive the design content you choose and search terms.
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Publishing platforms you connect: publish to your blog if you connect one. They receive your approved post content.

Advertising and analytics providers (see Section E): measure website visits and advertising. They receive site activity, identifiers and, in some cases, a hashed email.You can ask us for the names of our service providers at any time by emailing hello@thenavia.com, and we will tell you.

E. Advertising, analytics and your choices
Our marketing website (www.thenavia.com) uses tracking technologies such as pixels, tags, cookies and similar tools, including the Meta Pixel and Google tags and tools from other advertising and analytics providers that we may add or change over time. We use them to measure visits and to run and measure our own advertising. They are not used inside the Navia app. They may collect your IP address, device and browser information, and actions you take, such as signing up or buying. Some of these tools, including Meta's advanced matching and server-side tools, may also receive a scrambled (hashed) version of your email address or other contact details, from your browser and from our servers, so the provider can match your actions to your accounts with them. Depending on where you live, this may count as "sharing" or "selling" your information for advertising. You can opt out in these ways: (a) use the cookie banner or the "Do Not Sell or Share My Personal Information" link; (b) send a Global Privacy Control signal; (c) change your settings in the ad preferences of the platforms you use, such as Facebook, Instagram or Google; or (d) install Google's browser opt-out add-on. We do not send names or email addresses to Google Analytics.

F. Marketing emails
When you opt in to our marketing emails, for example by joining our email list through a sign-up form, downloading a resource, or registering for an event, you agree to receive marketing emails from Navia, such as tips, product updates, promotions and news. If you sign up for a subscription plan, we may also send you marketing emails about Navia while your plan is active and for up to two years afterwards, or for as long as the law allows. You can withdraw your consent and unsubscribe at any time using the link in any message, or by emailing hello@thenavia.com. We will act on your request within 10 business days. Creating a free Navia account does not, by itself, sign you up for marketing emails. We will still send you account and service messages, such as receipts, security alerts and product notices. Our email list provider stores your name and email address. By creating an account you also join our email list. Unsubscribe anytime.

G. Personal information about other people
You may enter personal information about other people into Navia, such as your customers or contacts. You are responsible for having the right to do so and for giving any notices and obtaining any consents the law requires. We process that information only to provide the Service to you, and we do not use it for our own advertising. If you are one of our customers' customers and want to exercise privacy rights, please contact the business that gave us your information.

H. Relationship to the Terms
This Privacy Policy is part of the Navia Terms of Use. Anything in the Terms about disputes, limits on liability and governing law applies to this policy.

30. How to Contact Us

If you have any questions or if you would like to contact us about our processing of your Personal Information, including exercising your rights as outlined above, please contact us by using the information below. When you contact us, we will ask you to verify your identity.

Contact name: Data Protection Officer
Email: hello@thenavia.com

Navia
30 N Gould St.
Sheridan, 82801, Wyoming

Last updated: November 3, 2026