Effective as of March 18, 2024

Nav.it, Inc. ("Nav.it," "we", “us” or "our") provides a financial health platform and application that helps people manage their cash flow and build better spending habits (the “Nav.it Platform”). Our business customers (“Employers”) may invite their employees to sign up for the Nav.it Platform as a benefit offered by the Employer. This Privacy Policy describes how Nav.it processes personal information that we collect through the Nav.it Platform as well as through our digital or online properties that link to this Privacy Policy (including as applicable, our websites at www.navitmoney.com and www.nav.it and our social media pages) as well as our marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”). Nav.it may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

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Index

• Personal information we collect
• Tracking Technologies
• How we use your personal information
• Retention and account changes
• How we share your personal information
• Your choices
• Other sites and services 
• Security
• International data transfers
• Children
• Changes to this Privacy Policy
• How to contact us

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Personal Information We Collect

Nav.it Platform. If you sign up for or use the Nav.it Platform, personal information we may collect from you through the Services includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, and age.
• Account data, such as the username and password that you may set to establish an online account on the Service, date of birth, redemption code, preferences, spending habits, financial goals, or information about familial relationships when you choose to connect a joint account with your partner or spouse.  
• Communications data based on our exchanges with you, including when you contact us through the Service or otherwise communicate with us. 
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Survey data, such as your responses to our surveys.   
• Financial account data, when you choose to directly link your financial account(s) to the Nav.it Platform, such as your transaction history, balances or debts for such financial account(s). 
• Payment data, including payment card information, when you make a purchase on the Service (e.g., to purchase one-on-one coaching). Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, as described in more detail in the “Payment processors” subsection below.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Employers. If you are an Employer, personal information we may collect from you includes:

• Contact data, such as your first and last name, salutation, business email address, billing and mailing addresses, professional title and company name, and phone number.
• Communications data based on our exchanges with you, including when you contact us through the Service or otherwise communicate with us. 
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Payment data, needed to complete transactions, such as your company’s bank account number.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Other Users. If you visit our websites or social media pages or otherwise engage with us, personal information we may collect from you includes:

• Contact data, such as your first and last name, salutation, business email address, mailing address, professional title and company name, and phone number.
• Communications data based on our exchanges with you, including when you contact us through the Service or otherwise communicate with us. 
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• ‍Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Partners, such marketing partners. 
• Your Employer and other Nav.it Platform users, including your Employer when they invite you to use the Services and other Nav.it Platform users who may submit information about you in connection with their use of the Nav.it Platform (e.g., a Nav.it Platform user providing information about their partner or spouse). 

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

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Tracking Technologies

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites may include “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place. 
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 
• Session-replay technologies, such as those provided by Smartlook, that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, and scrolls during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Smartlook at https://help.smartlook.com/docs/privacy-policy and you can opt-out of session recording by Smartlook at https://www.smartlook.com/opt-out/.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section, below.

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How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

‍Service delivery and operations. We may use your personal information to:

• provide the Service, including to connect to your financial accounts that you have chosen to link to the Service;
• enable security features of the Service;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; 
• provide support for the Service, and respond to your requests, questions and feedback; and
• establish and maintain your user profile on the Service.

Service personalization, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. 

Marketing. We, our service providers and our third-party marketing partners may collect and use your personal information for marketing purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.  

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
• audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
• enforce the terms and conditions that govern the Service; and 
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. If you connect your financial account(s), you also authorize us to create such data from your financial account data. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data for our lawful business purposes, including to analyze and improve the Service and promote our business and to share such data, such as in reports, with third parties such as Employers and research institutions. 

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics, Metabase, and Firebase for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en. You can learn more about Metabase by reading its privacy policy here: https://www.metabase.com/privacy. You can learn more about Firebase by reading its privacy policy here: https://firebase.google.com/support/privacy. 

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

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Retention and account changes

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.   

When we no longer require the personal information we have collected about you, we may either delete it, anonymize, deidentify or aggregate it, or isolate it from further processing. 

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How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics). 

Payment processors. Any payment card information you use to make a purchase on the Service, such as to purchase one-on-one financial coaching, is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy. 

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so, such as your financial institution in connection with your use of the Nav.it Platform.  

‍Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Nav.it, financing of Nav.it, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Nav.it as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

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Your choices 

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning. 

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can request that we delete your information by submitting a request to privacypolicy@nav.it. Upon request, and except where otherwise required by law, we will permanently disable your account and delete all identifiable personal information associated with your account as described above or otherwise de-identify or anonymize such information so that it is no longer identifiable to you.

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Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

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Security 

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. You can report potential security issues to security@nav.it.

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International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

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Children  

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

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Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

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How to contact us

• Email: privacypolicy@nav.it
• Mail: 511 Greenwood Ave N #311 Seattle, WA 98103
• Phone: (804) 876-2848

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