NAVÉGALO PRIVACY POLICY

Updated May 5, 2020

Navégalo com S.A. is an information technology service provider. Headquartered in San Jose, Costa Rica, we provide Internet, Cloud Computing, Data Center, Web Hosting, VoIP, Cybersecurity, Connectivity, IXP, Software Licensing, IoT and Marketing to our customers (“Services”). Navégalo has Data Center presence in Costa Rica, Panama, Nicaragua, El Salvador, Guatemala, Honduras and in Miami, FL (USA).

Navégalo respects the privacy of every individual who visits www.navegalo.com ( “Website”) and/or purchases its Services. 

This Privacy Policy is our commitment to transparency in communicating how Navégalo collects, uses, and discloses the information that is collected from you, the visitor of its website and/or customer as well as the choices you have with respect to the information.

SCOPE OF POLICY

This Privacy Policy applies to how we collect, use, and disclose information from the following individuals:

  • Customers – individuals who register, on their own or on behalf of an entity, to use Navégalo Services with the creation or administration of a Navégalo account.
  • Event/Marketing Participants – individuals who provide their information to Navégalo when they register for Navégalo webinars, subscribe to marketing material, participate in surveys or contests, or attend other Navégalo events.
  • Website Visitors – individuals who visit Navégalo’s Website and opt to provide contact information including an email address to receive communications from Navégalo. 

This Privacy Policy does not apply to a Navégalo Customer’s website that is hosted by Navégalo. Our Customers are responsible for the information they or their end users store in our hosting environment as well as compliance with applicable laws and regulations, and Navégalo’s terms related to the collection and storage or personal information.

INFORMATION WE COLLECT

Customers

Navégalo asks for your account information which includes your full name, email address, physical address, phone number, mobile number, credit card information, and website domain. By voluntarily providing Navégalo with your account information, you represent that you own and consent to our use of such personal data.

Event/Marketing Participants

Navégalo may ask for your full name, email address, physical address, and phone number. Participation in events, surveys, contents, or subscribing to marketing material is voluntary and you may choose whether or not to participate and therefore disclose this personal data.

Website Visitors

At your option, Navégalo asks and may collect your name, email address, physical address, and phone number. In addition, we also collect information such as web server logs, internet protocol (IP) addresses, browser type, or other information as part of aggregated data.

Navégalo uses cookies, beacons, tags, and other tracking technologies to gather demographic information about you, identify your visits to our Website, other interactions with our Website, and personalize your search experience on our Website. We gather information such as internet protocol (IP) addresses, internet service provider (ISP), operating system, browser type, date/time stamp, and store it in log files. To collect this information, a cookie, a standard feature of a website that allows us to store a small amount of data on your computer to allow our web servers to recognize you, may be set on your computer or device when you visit our Website. We may track your use across different websites and services. In some countries, including those in the European Economic Area (“EEA”), the information in this paragraph may be considered personal information under applicable data protection laws.

You can control how websites use cookies by changing your cookie settings (www.aboutcookies.org), but your modification may limit your use and functionality of some of the features on our Website. We may also use cookies and other tracking technologies to provide you advertising based on your browsing activities. You may opt out of targeted advertisements by visiting NAI’s opt-out page, or if located in the EEA, you may opt out by visiting Your Online Choices.

HOW WE USE YOUR INFORMATION

Navégalo uses the information it collects about you in the following ways:

  • To respond to any requests from you regarding sales and support.
  • To contact you regarding any agreements or accepted terms that you may have with Navégalo for the Services.
  • To provide you with marketing emails, special offers, advertising campaigns, or newsletters.
  • To provide you with information logs associated with the use of Navégalo’s Services.
  • To contact you regarding functionality changes to our Services or Website.
  • To develop new features and functionality to our Services and Website.
  • To collect payment and bill for our Services.
  • To help personalize searches.
  • To diagnose problems.
  • To find and prevent fraud.
  • To register your domain and IP address through LACNIC (Latin American Registry for Internet Numbers) and ARIN (American Registry for Internet Numbers).
  • To carry out other purposes as disclosed to you through the Website, or found in terms or an agreement between you and Navégalo.
  • Process for other purposes for which we obtain your consent.

HOW WE SHARE INFORMATION

Navégalo shares the information it collects about you in the following ways:

  • Third Party Providers – Navégalo may share your information with third party providers that provide services on our behalf. These companies may assist with marketing support, processing credit card payments, providing sales leads, and customer support. Third party providers may only process personal information pursuant to Navégalo’s instructions, and in compliance with Privacy Policy and other applicable regulations.
  • Advertising – Based on the cookies and other tracking devices, we may work with advertising companies to display ads that may be of interest to you.
  • Business Transactions – To provide information to a third party in the event of any disposition of all or any portion of our business (e.g. reorganization, sale, assignment, bankruptcy).
  • Aggregated or De-identified Data – We may disclose or use aggregated or de-identified information with third party providers for research purposes relating to our Services.
  • As Required by Law or Similar Investigations – To comply with legal obligations (e.g. subpoena) or investigate potential legal violations. Navégalo may be required to share personal data in response to lawful requests from public authorities including to meet national security and/or law enforcement requirements.
  • Safety – We may disclose your information to protect and defend the safety of Navégalo in connection with investigating and preventing fraud or security issues.
  • Consent – Navégalo may share your information with your consent.

YOUR CHOICES

You may unsubscribe from receiving promotional or marketing emails from Navégalo at any time by using the “unsubscribe” link in the email received, or by emailing us at [email protected]. As outlined in the Section, Information We Collect, you can also control your cookie settings.

With respect to your account information, you may update, correct or delete information that you provided to us by logging into your Navégalo account or contacting us at [email protected].

DATA RETENTION AND SECURITY

When Navégalo no longer has a legitimate business need (e.g. termination of a Customer agreement) to process your personal information, we will delete it.

Navégalo takes all reasonable steps to protect information received from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We maintain technical, physical, and administrative safeguards to secure your information, and we use industry standard Secure Socket Layer (SSL) encryption for your data that is transferred over the internet. Despite its use of encryption, Navégalo cannot guarantee any method of transmission of information over the internet is 100% secure. If you have any questions about the security of your personal information, please contact us at [email protected].

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

For individuals in the European Economic Area (EEA), Navégalo’s legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. Navégalo will process personal information from you where, a) we have your consent to do so, b) where processing is necessary for Navégalo to perform Services pursuant to an agreement, or c) where processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information, or may otherwise need the personal information to protect your vital interests or those of another person. At any time, you have the right to withdraw or decline consent. If you do not provide the requested information, Navégalo will not be able to perform Services for you. Also, you have the right to object where we rely on our legitimate interests to process your personal information.

DATA PROTECTION AUTHORITY

If you are a resident of the European Economic Area (EEA) and believe we maintain your personal information subject to the General Data Protection Regulation (GDPR), you may direct questions or complaints to your local supervisory authority.

‘DO NOT TRACK’ NOTIFICATIONS

Some browsers allow you to automatically notify websites you visit not to track you using a “Do Not Track” signal. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

AGE RESTRICTIONS

Our Services are available for purchase only for those over the age of 18. Our Services are not targeted to, intended to be consumed by or designed to entice individuals under the age of 18. If you know of or have reason to believe anyone under the age of 18 has provided us with any personal information, please contact us.

CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and any other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our home page, at least thirty (30) days prior to the implementation of the changes.

CONTACT US

If you have any privacy-related questions, concerns or complaints about our Privacy Policy, our practices or our Services, you may contact our Office of the DPO (Data Protection Officer) by email at [email protected]. 

In the alternative, you may contact us by either of the following means:

  • By Mail: Attn: Office of the Data Protection Officer, Second Floor Centro Colon Building, Suite 2-17, San Jose, Costa Rica. 
  • By Phone: +506-4020-4000 

We will respond to all requests, inquiries or concerns within thirty (30) days.