JAVAD Privacy Policy
Last modified: February 27, 2022
Introduction
JAVAD GNSS, Inc. and JAVAD EMS, Inc. (“JAVAD” or “we” or “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:
The types of information we may collect or that you may provide when you browse, download, register with, access, use, or transact with the JAVAD website or any associated content, material, or functionality contained on the JAVAD website or application, whether accessed via computer, mobile device or other technology or any associated content, material, or functionality contained on the JAVAD application (collectively, the “Website”). The Website is owned and managed by JAVAD.
- Our practices for collecting, using, maintaining, processing, accessing, storing, protecting and disclosing that information.
- Your rights under applicable law.
Information We Collect and How We Collect It
The below chart summarizes our collection, use, and disclosure of personal information:
| Types of Personal Information Collected | Source of the Personal Information | Purpose for Collection and Use | Information Disclosed for a Business or Commercial Purpose? (Yes/No) | Categories of Third Parties (Which Do Not Include Service Providers) with whom the Personal Information may be Shared under certain circumstances. |
| Identifiers (e.g., name, e-mail, postal address, persistent identifiers that we assign, and phone number) | Information that you provide directly to us through the Website; from business partners; and from our service providers that support the Website’s operations. | Operate the Website and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights.
|
Yes | Business partners who deliver product and service offerings and financial institutions. |
| Demographic information | Information that you provide directly to us through the Website; from business partners; and from our service providers that support the Website’s operations. | Operate the Website and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights.
|
Yes | Business partners who deliver product and service offerings and financial institutions. |
| Financial information and account details
|
Information that you provide directly to us through the Website and from our service providers that support the Website’s operations. | Operate the Website and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights.
|
Yes | Business partners who deliver product and service offerings and financial institutions. |
| Geolocation information | Information that you provide directly to us through the Website; from business partners; and from our service providers that support the Website’s operations. | Operate the Website and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights.
|
Yes | Business partners who deliver product and service offerings and financial institutions. |
| Commercial information (e.g., purchase, review, or comment history) | Information that you provide directly to us through the Website; from business partners; and from our service providers that support the Website’s operations. | Operate the Website and associated services such as making certain products and services available; Prevent fraud; Conduct surveys; Manage our business operations including legal compliance; Market products and services; Resolve complaints; Establish and defend legal rights.
|
Yes | Business partners who deliver product and service offerings and financial institutions. |
| Browsing activity, device information, and Usage Details | Web tracking technology such as browser cookies, flash cookies, and web beacons and information about your collection on the Website. | Website functionality, customization, and security.
Advertising and marketing. |
Yes | Third party web tracking providers. |
Location Data
When you subscribe to or use JAVAD’s location-based Services, you are enabling us, and certain of our third-party service providers, to record, store, view and process geolocation information from your device or equipment. This may include capturing and sending you portions of this data through our services or analyzing the data to identify patterns or performing other functions. We may also process location information from your device or equipment so that we can send you alerts.
Data protection and privacy laws in your jurisdiction may impose certain responsibilities on you and your collection and use of location data. You (not JAVAD) are responsible for ensuring that you comply with any applicable laws. For example, you may need to display a notice that alerts employees, customers, subcontractors, and other third parties that their geolocation may be recorded or tracked, and that the information may be shared with other parties as applicable. JAVAD takes absolutely no responsibility for your compliance with these laws.
Other Information Collection Technologies.
The technologies we use for automatic information collection may include:
Cookies. A cookie is a small file placed on your smartphone or browser. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting you may be unable to In addition to the disclosures described above, we may disclose personal information that we collect or you provide:
To our affiliates, group companies, holding companies, located within and outside the US.
To a buyer or other successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of JAVAD Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
To comply with any court order, investigation, law or legal process, including, without limitation, to respond to any government or regulatory request.
The Website will also allow you to intentionally interact with third parties, such as those whose businesses, products, or services are reviewed, advertised, or made available through the Website.
We do not necessarily control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Sweepstakes, Promotions, Contests & Surveys
On the Website, you may wish to participate in certain online polls, surveys, contests, sweepstakes, and other promotions that may be offered from time to time by us, a partner, or other entity through which you are using the Website. Participation in these polls, surveys, contests, sweepstakes, and promotions is completely voluntary; you have a choice about whether or not to disclose information required to enter. Information requested may include information such as your name, address, date of birth, phone number, mobile phone number, e-mail address, username, and/or similar information. Through these online polls, surveys and promotions, you may choose to participate in activities such as sharing information with others and sending email invitations. In connection with any online polls, surveys, contests, sweepstakes, and other promotions that may be offered from time to time via the Website by us, we use the information you provide to administer the polls, surveys, contests, sweepstakes and other promotions. Subject to applicable contractual or legal restrictions, we also may use the information to communicate with you, or the other people you select, about our services or products. Any information that you submit to one of our partners or another entity through which you are using the Website in the course of any poll, survey, contest, sweepstakes, or promotion offered by any third party shall be fully at your own risk, and JAVAD hereby disclaims all responsibility for any losses, liability, damages, or expenses that may arise from your submission of such information.
Children under the Age of 16
The Website is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16, we will delete that information to the best of our ability. Please be aware that we may not be able to fully delete certain user information if a user’s account remains open. If you believe we might have any information from or about a child under 16, please contact us at the e-mail address provided to you below.
Do Not Track
We treat the information of everyone who comes to our Website in accordance with this Privacy Policy. We do not monitor or respond to any “Do Not Track” setting that may be available through certain browsers.
Information Security
We have implemented measures designed to secure your personal information against accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
If you receive a suspicious email on our behalf, we suggest you do not reply to it and do not open any attachments, click on links contained in the e-mail or provide any information in response to it. You can report suspected fraud involving us by sending an e-mail to ________. Please include the word “phishing” in the subject line of your e-mail and provide as much information as possible about the fraudulent activity or message. We do not send e-mails requesting a user for payment information, username, or passwords.
If you identify a security vulnerability, please contact us to make a responsible disclosure at the following address: __________.
Online Account Management
If you elected to subscribe to any online services provided via the Website, including, without limitation, the ability to access any password-protected areas of the Website, you will be required to submit personal information for the purpose of verifying your identity and your authority to manage the account (“Access Credential Information”). This Access Credential Information will be used exclusively by JAVAD, our agents, suppliers, and third-party service providers for internal use and to respond to your service requests.
Changes to Our Privacy Policy
We may update our Privacy Policy from time to time and may amend it at any time to incorporate additional terms specific to additional features, applications, opportunities, or services that we may make available on or through the Website. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy.
You should review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the Website signifies your continuing consent to this Privacy Policy.
The most recent version of the Privacy Policy is reflected by the effective date specified in this Privacy Policy. The version of this Privacy Policy posted at _______________ on each respective date you use the Website shall be the Privacy Policy applicable to your access and use of the Website on that date. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you used the Website.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: _________ or at _________.
You may request to receive details about how we collect, use, and share your personal information. Specifically, you may request to receive the specific pieces of personal information that we have collected about you.
You may also request to receive:
the categories of personal information that we have collected about you,
the categories of personal information that we have disclosed for a business purpose,
the categories of sources from which we collected the personal information,
our purposes for collecting that personal information, and
the categories of parties with whom we share your personal information.
We do allow third parties to collect personal information through our Services and share personal information with third parties for the business purposes described in this Privacy Policy.
You can exercise your applicable CCPA rights by contacting us _________ or at _________.
Please note that the CCPA requires us to verify the requests we receive from you when you exercise certain of the rights listed above. We may need more information when we receive your request before taking further action to verify your identity. You may also authorize an agent to make a request on your behalf, who will need to provide similar information for verification.
Special Notice to Residents of the European Union and United Kingdom
If you are a natural person who is a resident of the European Union or the United Kingdom, then the following Special Notice to Residents of the European Union and United Kingdom applies to you. Similarly, if you are a natural person who is a resident of the following jurisdictions, then the following Special Notice to Residents of the European Union applies to you:
Liechtenstein;
Norway;
Iceland; or
Switzerland.
Scope
This Privacy Policy applies to our privacy practices for your use of (i) this website and any mobile sites or applications operated by JAVAD (the “User Interfaces”) and (ii) any combination of JAVAD’s products and services purchased or accessed via any User Interface (the “Services”), and all personal data we directly receive or collect from you in the course of doing business.
Data Collection and Use
Data You Provide to Us – If you are an individual user of JAVAD or an owner, agent, or employee of a corporate user, you may provide us with personal data when you register with JAVAD, engage with customer support or marketing, and transact business with JAVAD.
Further, you may provide us with personal data when you set up your account with JAVAD and use JAVAD User Interfaces or Services.
We may use this information for our business operations, to communicate with you or your employer (as applicable), to comply with the law, and to protect the security and integrity of the User Interfaces and Services.
When using the User Interfaces, you may provide us with personal data including, but not limited to, your name, home or business address, phone number, email address, location, or zip code.
When using our Services, you or your employer may provide us with certain additional information (e.g., business description, business size, business location, account information, and device settings) in order to help us personalize your Services. JAVAD may also receive personal data that you have provided to our partners to enable JAVAD to provide our Services.
On behalf of you or your employer, JAVAD may process information regarding your use of the JAVAD Services. We receive this type of information from your devices that are monitored by JAVAD and your computer or other electronic device through which you may access, browse, download, receive, or otherwise use the JAVAD User Interfaces or Services (each a “Personal Device”), and we may also receive and collect such information from third parties.
JAVAD will process all personal data received by employers via contractual arrangements and may use compiled aggregate statistics about the User Interfaces and Services to improve our Services.
Location-based Information – Some features of our Services (“GeoServices”), use location information. This location information may include your current location or places you have recently visited. We also may aggregate this information, but this information will only be used for JAVAD’s internal purposes (including providing the Services to you and other users) and to provide information requested by you. If you do not wish for us to collect and store this information, please do not register for or use the Services.
Data We Collect Automatically – When you use the User Interfaces or access JAVAD Services using your Personal Device, certain information may be collected by automated means, such as cookies. Information about JAVAD’s use of cookies can be found in this Privacy Policy above.
Legal Basis for Processing Personal Data
We will only collect and process personal data about you where we have a legal basis. Legal bases include consent (where you have given consent), contract (where processing is necessary for entering into or the performance of a contract with you), compliance with a legal obligation, and “legitimate interests.”
Where we process personal data based on consent, we will ask for your unambiguous consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.
We may process your personal data for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms. Where we rely on legitimate interests, you have the right to object. Please keep in mind that if you object this may affect our ability to perform certain services for your benefit. We process your personal data based on legitimate interests in order to:
Protect you, us, or others from security threats by enhancing the security of our network and information systems;
Identify and prevent fraud;
Comply with applicable laws and industry regulations;
Enable or administer our business, such as for invoicing Employers and maintenance of User Interfaces; and
Improve our User Interfaces and Services by enabling us to enhance, modify, or personalize them for your benefit.
Data Sharing
JAVAD will not disclose your personal data to any other entity except:
as is necessary to provide the JAVAD User Interfaces and Services to you;
to your employer or the company through which you subscribed to our Services;
when you have opted in to share the information;
to third party suppliers, subcontractors or business partners who work or perform services on our behalf and are only permitted to use the minimum amount of information necessary to assist in providing the Services;
as necessary in connection with other lawful business purposes; and
as otherwise necessary when required or permitted by law.
In addition, we may disclose your personal data when the personal data has been converted to a form that cannot be used to identify you. It may also be necessary for us to disclose your personal data in case of a merger or combination with, or acquisition of a portion of our business by, another company or entity, in which case personal data collected by JAVAD would be expected to be one of the transferred business assets.
International Data Transfers
Our servers are located in the United States and offices are located around the world, so your personal data will be transferred to, stored, or processed in many international jurisdictions. We rely on legally provided mechanisms to lawfully transfer personal data across borders, as approved by the relevant supervisory authorities.
Exercising Your Rights
You may view, update, or delete certain personal data at any time by contacting us at the contact details set forth below. If you access this site on behalf of your employer, you should also contact your employer directly to make changes to its records.
You may be able to exercise the following rights:
Deletion. You may be able to ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Object to, or Limit or Restrict, Use of Data. You may be able to ask us to stop using all or some of your personal data (e.g., if there is no legal right to keep using it) or to limit use of it (e.g., if your personal data is inaccurate or unlawfully held).
Take Your Data. You may be able to ask for a copy of your personal data provided in a machine-readable form.
If we have collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
We do not make use of automated decision-making. As defined under current data protection laws, automated decisions are defined as decisions about individuals that are based solely on the automated (i.e., no human involvement) processing of data and that produce legal effects or that significantly affect the individuals involved.
You have the right to register a complaint with a data protection or supervisory authority about our collection and use of your personal information. For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA, the UK and Switzerland are available at https://edpb.europa.eu/about-edpb/board/members_en).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity to help us respond efficiently to your request.
Retention Period
We retain the personal data that we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the Services you requested or to comply with an applicable legal requirement).
Third Party Websites
For your convenience, some hyperlinks may be posted on the JAVAD website that link to other websites not under JAVAD’s control. JAVAD is not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that JAVAD does not own or control. JAVAD does not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. JAVAD encourages you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website linked to the JAVAD website, even if you reached that site through the JAVAD User Interfaces, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how personal data that is collected about you is used and protected.
Contact Information
You can contact our data protection officer (DPO) at ______________
