Confidentiality

SAS NAVAWAY is the owner and administrator of the website and mobile application, which are registered with the Lyon Trade and Companies Registry under number 902055904. The company’s registered office is located at 23, rue Paupière – 69270 Couzon-aux-Mont-d’Or (France).

Any request for information concerning NAVAWAY should be sent to the e-mail address hello@navaway.io or to the postal address of the registered office indicated above.

Description and nature of personal data

We may ask you to provide us with personal data when using the mobile application “NAVAWAY” (hereinafter: “the Application”) to allow us to use the services provided by NAVAWAY (hereinafter: “the services”).

Personal data is any information that makes it possible to identify a person, such as your first and last name, your job title, your date of birth, your city of residence, your e-mail address and your telephone number. It also includes any other information you wish to share with us about yourself.

Aim of this policy

The purpose of this privacy policy is to inform you about the ways in which we obtain your personal information, in full compliance with all your rights.

Accordingly, we inform you that we comply with Law No. 78-17 of 6 January 1978 on data processing, data files and individual liberties in its current version known as “Informatique et Libertés” and Regulation (EU) 2016/679 of 27 April 2016 (hereinafter “RGPD”).

Identity of the data collector

We are the ones who obtain and process your personal information. SAS NAVAWAY, registered in the Lyon Trade and Companies Register under number 902055904, has its registered office at 23, rue Paupière – 69270 Couzon-aux-Monts-d’Or (France) (“We”).

Our legal bases

We collect, hold, share and process the information we hold about you on a number of legal bases, including those described in this privacy policy:

• We will strive to protect your privacy and comply with all applicable laws. We need access to your location data in order to provide the Services and to fulfil our obligations under the Terms of Use. For example, we cannot provide you with the Services you would expect if we do not have access to your location data.
• Once you have given your consent ;
• Where necessary to comply with a court order, fulfil a legal obligation, or defend and pursue legal claims;
• By protecting your vital interests or those of others, for example, in the event of an emergency;
• In the case of activities that take place on our platforms and, where applicable, for the purposes of our legitimate interests or those of a third party, such as protecting our users, working with them and maintaining the services.

Collection of personal data

The profile section of our application asks for personal information. We collect data about you, including information that is clearly identifiable, through the profile section of the application.

We inform you whether specific data is required or optional when collecting your personal information. The use of our services requires essential data. You have the option of refusing to provide optional data. We also explain the potential consequences of not doing so.

We collect the following data with your consent:

• First name and surname
• E-mail address
• Civility
• Your home town
• Date of birth
• Phone number

We will be the sole owners of your information and will only use it as described in this agreement.

Third-party services such as Google, Facebook, Apple and Mapbox are used by the application.

Declaration of Place

When you create an account and use the services, we collect and process geographical information.

When you are not using the application, we do not track the movements of your device, but in order to offer the main functions of the application, we need to monitor your position while you are using it.

You can stop your device being tracked at any time by adjusting the settings on your device.

How the application uses the data

As you can see, the application is quite simple. It uses the data we collect and acquire as described below:

• We use the data we collect and receive to provide the services, for example by enabling you to record your activities and evaluate your actions.
• Help you choose the most appropriate routes to reach your goal.
• To personalise your visit: we use the data we collect about you and your past interactions with us to personalise your visit, for example by suggesting new places nearby.
• We use the data we collect to improve our services, in particular by using third-party analysis companies to obtain information on how people use our services, in order to help us improve them.
• To communicate with you: we will use the information we collect to respond to your requests and comments. We may also use the data we collect for marketing and promotional purposes, such as promoting and advertising the App, activities, events and other commercial goods or services. This includes marketing and push communications to which you have not responded in the negative.
• To comply with our legal and regulatory requirements.
• We use the data we collect and receive to provide the services, for example by enabling you to record your activities and evaluate your actions.
• Help you choose the most appropriate routes to reach your goal.
• To personalise your visit: we use the data we collect about you and your past interactions with us to personalise your visit, for example by suggesting new places nearby.
• We use the data we collect to improve our services, in particular by using third-party analysis companies to obtain information on how people use our services, in order to help us improve them.
• To communicate with you: we will use the information we collect to respond to your requests and comments. We may also use the data we collect for marketing and promotional purposes, such as promoting and advertising the App, activities, events and other commercial goods or services. This includes marketing and push communications to which you have not responded in the negative.
• To comply with our legal and regulatory requirements.

Log data

We would like to inform you that in the event of an application fault when you use our service, we will collect data and information (via third party products) from your phone, known as log data. This data may contain details such as the IP address of your hardware, the name of your device, the version of your operating system, the configuration of the application when using our application, the time and date of use and other information.

Links to other sites

Please note that some of the links on this page may direct you to third-party sites. If you click on a third-party link, you will be directed to the site in question. Please note that these external web pages are not managed by us. Consequently, we cannot guarantee the content, policies or practices of these third-party sites. We strongly recommend that you read their privacy policy.

Recipients of the data collected

Personal information is shared with third parties, in accordance with your preferences, and where necessary to operate our business, provide services, and where required by law.

As a result, we may share information about you with third parties who work on our behalf to support, improve, advertise and secure our services. These service providers only have access to the data necessary to carry out these essential tasks on our behalf and are obliged to keep it safe and secure.

Bailiffs, agents and debt collection agencies may all have access to your personal information for reasons that fall strictly within our legal obligations.

We allow you to connect the Services to third party applications, plugins and websites that integrate with the Services, as well as to third parties that work with the application to provide integrated features such as a challenge sponsor or tracking device. You have the option of sharing your profile data and activity data (including private activities). The data these third parties collect is governed by their rules and policies, so you should read them carefully. We are not responsible for the conditions or practices of these third parties.

Transfer of personal data

We do not sell, rent or share your personal data.

You may provide information to the application, which it may combine with other data provided by you and others in connection with the services and publish it publicly or share it with others.

Storage time

We retain data for as long as we need it to provide the Services to you, subject to any legal obligation to retain such data further. Most of your account information will be retained until you stop using the Services or your account is terminated. You may delete several items of information (such as personal information) without closing your account.

Protecting your information

We take seriously the trust you place in us by sharing your personal information, which is why we strive to employ commercially acceptable security measures. However, please bear in mind that no method of transmission over the Internet, nor any form of electronic storage, is ever 100% secure and reliable; we cannot promise total security.

We take a number of precautions to secure the data we collect. We use appropriate security measures for your information, which are proportionate to its sensitivity. Personal information is encrypted using industry standard Secure Sockets Layer (SSL) technology when transmitted via the Services. We work with industry leaders in online security and service verification to enhance the security of our services. Your browser can confirm our identity before sending any personal information, as the Services are certified by site identification organisations. Our servers are also equipped with advanced firewall technology, which guarantees the security of your sensitive data.

Access to your personal data

You have the right to obtain notification of data breaches and, if necessary, their modification or deletion under Law No. 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties and the RGPD. You can contact us at the following address

E-mail address: hello@navaway.io

Postal address: NAVAWAY – 23, rue Paupière – 69270 Couzon-aux-Monts-d’Or

Any person may, on legitimate grounds, legally object to the processing of information relating to them. However, we may continue to process your data if there are compelling reasons for the processing that outweigh your rights and freedoms, or if the processing is necessary to establish, enforce or defend our legal rights.

Establish instructions for processing data after your death

You have the right to establish instructions for the conservation, deletion and publication of your personal data after your death.

These instructions may be broad and cover all your personal data. In this case, they must be submitted to a reputable digital third party approved by the CNIL.

Detailed instructions may also be adapted to the data processed by our company. Please send them to us at the following address:

E-mail address: hello@navaway.io

Postal address: NAVAWAY – 23, rue Paupière – 69270 Couzon-aux-Monts-d’Or

By submitting such instructions, you agree to the storage, transmission and execution of such instructions in accordance with the terms of this agreement.

You can specify in your instructions who will be responsible for implementing them. This person will then have the power, on your death, to view the instructions and ask us to carry them out. If no specific name is given, your heirs will be able to consult your instructions after your death and ask us to carry them out.

You can change or cancel your instructions at any time by writing to us at the above address.

Portability of your personal data

You have the right to transfer your personal data to any other entity, provided that you have given your consent and that this is not prohibited by law. As a reminder, this right does not extend to data collected and legally processed on the basis of consent or the performance of a contract binding us.

This right applies at no additional cost, when you so wish, in particular when you close your account on the Application, in order to take back and keep your personal data.

In this case, we will send you your personal information, in any way we consider useful, in a commonly used open standard machine-readable format, according to the state of the art.

Making a complaint to a control body

We also inform you that you have the right to lodge a complaint with the competent supervisory authority of the Member State in which you reside (the Commission Nationale Informatique et Libertés for France), work or in which you believe your rights have been violated if you believe that your personal data is not being processed correctly.

A legal right of access allows you to challenge companies before the supervisory authorities if they refuse to meet their obligations under European data protection legislation. You may exercise this right without prejudice to any other remedy before a governmental or judicial body. You may seek administrative or judicial redress if you believe that your personal data has not been respected.

Limitation of treatment

You have the right to request that the use of your personal data be restricted in the following situations:

• During the verification stage carried out by our services, when you dispute the accuracy of your personal data.
• When your personal data is being processed unlawfully and you wish to restrict access rather than delete it,
• When your personal data is no longer required by our company, but you wish to retain it in order to exercise your rights,
• If you do not agree with the use of your personal data for legitimate reasons,

Changes

We may modify our privacy policy at any time. We therefore advise you to check this page regularly for any changes. We will notify you of any changes by updating the new privacy policy on this page.

Contact us

If you have any questions or suggestions about our privacy policy, please contact us at : hello@navaway.io