Navitas Safety External Privacy Policy

Navitas Safety respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our sites (regardless of where you visit them from) and tell you about your privacy rights and how the law protects you.

The key laws protecting your privacy are the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018. In practice, these require that all personal data which we hold about you will be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

First and foremost, we know how irritating it can be to get spam emails from companies which you have never heard of. Navitas Safety will never sell your personal data to such companies for marketing purposes.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how Navitas Safety collects and processes your personal data.

This policy applies to two main areas of our business:

• data which we collect through our website; and
• data which we collect through the services and platforms which we provide to our clients.

Please note our services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Navitas Safety

Navitas Safety is made up of the following legal entities:

• Navitas Digital Safety Limited (which sometimes trades as “Navitas Safety Compliance”) which is registered in England and Wales with Company Number 08861678 and whose registered office is at C/O Charnwood Accountants The Point, Granite Way, Mountsorrel, Loughborough, Leicestershire, England, LE12 7TZ
• Gardner James LLP (which sometimes trades as “Navitas Safety Academy” and “ESB Academy”) which is registered in England and Wales with Company Number OC378359 and whose registered office is at C/O Charnwood Accountants The Point, Granite Way, Mountsorrel, Loughborough, Leicestershire, England, LE12 7TZ
• The European Safety Bureau Limited (which sometimes trades as “Navitas / ESB” and “Inviso”) which is registered in England and Wales with Company Number 02367034 and whose registered office is at Unit 7 Grove Court, Grove Park, Leicester, LE19 1SA

This privacy policy is issued on behalf of Navitas Safety so when we mention “Navitas Safety”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in Navitas Safety responsible for processing your data.

Navitas Safety Contact details

If you have any questions about this privacy policy, or wish to exercise any of the rights it describes, please contact us using the details set out below.

• Email address: [email protected]
• Postal address: Navitas Safety, Unit 7 Grove Court, Grove Park, Leicester, LE19 1SA
  
  

If you can mark your e-mail or letter with a suitable title or subject line it will help us to classify and deal with your request.

Information Commissioner’s Office

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Client Contact details

If you are the nominated contact point for your business we will require your name, job title, email address and phone number. Any updates or amendments to these details should be sent to [email protected] within 48 hours of them being made.

Changes to the privacy policy

We keep our privacy policy under regular review. Any changes we make will be displayed on this site. This version was last updated on 22^nd June 2018.

Third-party links

Our sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our sites, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (which is called “anonymous data”).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes your name, username or similar identifier, marital status, title, job title, service length, date of birth and gender.
• Contact Data includes residential address, work address, billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our sites.
• Platform / Service Data includes your username and password, incident / injury details, witness statements, treatment / medical details, personal training records and other details provided through our platforms or services. Please note the Platform Data we collect may be “Special Category” Data for the purposes of the GDPR and Data Protection Act 2018.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our sites, platforms, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our platforms. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods, services or access to one of our platforms).

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your data when you:
  • apply for our products or services;
  • create an account on our sites;
  • subscribe to our service or publications;
  • submit information through our service platforms (whether on your own behalf or on behalf of your employer);
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • give us feedback or contact us; or
  • correspond with us through our sites, by post, phone, email or otherwise.
• Organisation data. Your data may be inputted onto Navitas Safety platforms for or otherwise on your behalf, whether by Navitas Safety, your employer, or a third party engaged for the purpose.
• Automated technologies or interactions. As you interact with our sites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy in section 5 below for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties including:
  • analytics providers, advertising networks and search information providers;
  • providers of technical, payment and delivery services; or
  • publicly available sources such as Companies House.

Such third parties may be based outside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• where we need to comply with a legal obligation.

Purposes for which we will use your personal data

1.	Purpose: To manage our relationship with our customers, which will include providing our services and platforms (as they vary from time to time). This may include both you as an individual and your employer. Types of Data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Technical; (f) Profile; (g) Platform / Service; (h) Usage and (i) Marketing and Communications. Basis for Processing: (a) Performance of a contract; (b) Necessary to comply with a legal obligation; and (c) Necessary for our legitimate interests (to develop our business, keep our records updated and to study how customers use our products/services)
2.	Purpose: To process and deliver your order including:(a) managing payments, fees and charges; and(b) collecting and recovering money owed to us Types of Data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Platform / Service and (f) Marketing and Communications Basis for Processing: (a) Performance of a contract with you; and (b) Necessary for our legitimate interests (to recover debts due to us)
3.	Purpose:To enable you to partake in a prize draw, competition or complete a survey Types of Data: (a) Identity; (b) Contact; (c) Profile; (d) Usage; and (e) Marketing and Communications Basis for Processing: (a) Performance of a contract with you; and (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
4.	Purpose:To administer and protect our business and our sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Types of Data: (a) Identity; (b) Contact; (c) Technical; and (d) Platform / Service Basis for Processing:(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and (b) Necessary to comply with a legal obligation
5.	Purpose:To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Types of Data: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; and (f) Technical Basis for Processing: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
6.	Purpose:To use data analytics to improve our sites, products/services, marketing, customer relationships and experiences Types of Data: (a) Technical; and (b) Usage Basis for Processing: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our sites updated and relevant, to develop our business and to inform our marketing strategy)
7.	Purpose:To make suggestions and recommendations to you about goods or services that may be of interest to you Types of Data: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; and (f) Marketing and Communications Basis for Processing: Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We may use your Identity, Contact, Technical, Usage, Platform / Service and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, platform use, warranty registration, product/service/platform experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. COOKIES

Background

Cookies are small files which are created by a website and held on your computer. These have been designed to hold a modest amount of information specific to your browsing history and are completely harmless to your computer. In essence, cookies are a handy store of the choices you have previously made whilst on our website and allow us to present you with more pertinent information on your next visit. By continuing to use our website, we shall interpret this as consent to continue using cookies.

Controlling Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our sites may become inaccessible or not function properly.

Please refer to the help section within your browser to find out what options you have to block, limit or otherwise manage cookies.

Cookies we set

Name	URL / Platform	Purpose	Duration
navitas_session	Navitas Safety Digital Food Safety	Tracking of user sessions	360 days
system_session	Navitas Safety Compliance	Tracking of user sessions	2 hours
ci_session	Navitas Safety Academy	Tracking of user sessions	2 hours
ci_session	ESB Academy	Tracking of user sessions	2 hours

Google Analytics

In addition to the cookies we set ourselves, we use Google Analytics to help collect information about how our users interact with and navigate our sites. This data is collected to ensure that we provide the best possible experience for our customers and meet the expectations and needs of our customers.

Google Analytics records information relating to:

• how you accessed the site;
• how long you stayed on each page;
• what parts of the site you accessed;
• what you clicked on or viewed; and
• what you searched for within our site.

Further details of the cookies which Google uses can be found at https://policies.google.com/technologies/cookies

6. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below:

• any third parties listed in the table in section 4 above;
• other companies in Navitas Safety;
• service providers who provide Navitas Safety with: IT and system administration services; client relationship management services; payment services; hosting services; delivery services; graphic design services; hardware, firmware, software, service and platform development services; and e-mail platforms;
• social media platforms such as Facebook, Twitter, Instagram, LinkedIn and Hootsuite;
• professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, accounting and other professional services;
• HM Revenue & Customs, regulators and other authorities;
• fraud prevention agencies; and
• third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. INTERNATIONAL TRANSFERS

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• the recipient operates in a country that has been deemed to provide an adequate level of protection for personal data by the European Commission;
• where we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
• where we use providers based in the US, where they are part of the “Privacy Shield” scheme, which requires them to provide similar protection to personal data shared between Europe and the US.
  
  
  

8. DATA SECURITY

Business Processes

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

System Hosting

Navitas Safety is hosted on the Google Cloud infrastructure within the ‘europe-west’ (London and Belgium) cluster. The system and data is securely segregated by Google’s platforms; specifically, the system runs in dedicated virtual machines that only Navitas Safety have access to. Further information is available at: https://support.google.com/cloud/answer/6262505?hl=en#gcp-fix-it.

All Navitas Safety systems run solely on Linux based Virtual Machines. These systems comprise of MySQL databases and either Nginx or Apache2 Web Servers.

Data stored in the Google Cloud is encrypted at the storage level using either AES256 or AES128 – further information is available at: https://cloud.google.com/security/encryption-at-rest/default-encryption/.

System Development

Navitas Safety uses GitFlow for managing code changes, feature development and hot fixes. Code changes are peer reviewed before being merged. Changes are deployed to a staging environment and tested for suitability prior to being deployed to the production environment.

Navitas Safety uses TLS encryption for data in transit, encrypted passwords at rest and implements CSRF protection.

Business Continuity and Disaster Recovery

A full nighty database backup is taken across all platforms, with a full restore performed to a dedicated testing database instance once a month.

In the event of a serious disruption or total system failure, we would re-deploy the whole platform from scratch using the latest backup. In addition, if the service provider was rendered unavailable, we can use an alternative hosting environment.

9. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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 may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

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