Privacy Policy

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Advanced Navigation Pty Ltd (ABN 49 156 101 549) and our related bodies corporate. 

When you share information with us, for example by purchasing a product, downloading an app, or creating an account with us, we want you to be clear how we’re using information and the ways in which you can protect your privacy.

Where our processing of your information is covered by the General Data Protection Regulation 2016/679 (“GDPR”), or the California Consumer Privacy Act (“CCPA”) the sections of this Privacy Policy in Appendix 1 – Additional DIsclosures  – apply to you. We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (“Privacy Act”).

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Our Privacy Policy explains:

  • What information we collect and store and why we collect and store it.
  • How we use that information.
  • How we disclose information we collect.
  • The choices we offer, including how to access and update information.

If you’re not familiar with terms like cookies, IP addresses and browsers, then we ask that you read about these key terms first. Your privacy matters to us; whether you are new to Advanced Navigation or a long-time customer, please do take the time to get to know our practices – and if you have any questions, contact us on the details set out below. 

You may set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our services may not function properly if your cookies are disabled. For example, you may not be able to utilise our services or access all Advanced Navigation content. 

What information do we collect?

We may collect the following types of personal information:

  •  name;
  •  mailing or street address;
  •  email address;
  •  telephone number and other contact details;
  •  age or date of birth;
  •  credit card information;
  •  your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
  • details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
  • any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
  •  information you provide to us through customer surveys; or
  • any other personal information that may be required in order to facilitate your dealings with us.

How do we collect your information?

Generally, we may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

  • register on our website or app;
  • communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites; and
  • interact with our sites, services, content and advertising. 

We collect information in the following ways:

  • Information you give us. We collect information about you and your company as you register for an account with us, create or modify your profile, use, access, or interact with our services or our websites. Such content includes any personal information or other sensitive information that you choose to include. For example, our services may require you to sign up for an account with us. When you do, we’ll ask for personal information, like your name, email address, telephone number or credit card. We may present your name, email address or image to other users in your organisation, or otherwise associated with your account in order to assist in sharing or recommendations.
  • Information we get from your use of our services. We may collect information about the services that you use and how you use them, like when you visit a website that uses our services or you view and interact with our content. This information includes:
    • Device information – We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your account.
    • Log information – When you use our services or view content provided by us, we may automatically collect and store certain information in server logs. This may include:
      • details of how you used our service, such as your search queries;
      • telephony log information like your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls;
      • Internet Protocol address;
      • device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL; and
      • cookies that may uniquely identify your browser or your account.
    • Location information – When you use a location-enabled Advanced Navigation service, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.
    • Unique application numbers – Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to us when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
    • Local storage– We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
    • Cookies and anonymous identifiers – We use various technologies to collect and store information when you visit our services, and this may include sending one or more cookies or anonymous identifiers to your device. We also use cookies and anonymous identifiers when you interact with services we offer to our partners, such as advertising services or Advanced Navigation features that may appear on other sites.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

How do we use information we collect?

We may use the information we collect, including your personal information and transaction information, from all of our services in any one or more of the locations that Advanced Navigation  has operations or otherwise conducts business (these locations currently being Australia, the United States, the United Kingdom, Poland, Abu Dhabi, Singapore and  France) for the following purposes:

  • to enable you to access and use our website and services;
  •  to operate, protect, improve and optimise our website and  services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; 
  •  to consider your employment application; 
  • for internal and service-related purposes, such as to provide, maintain, protect, improve, and personalise our services, to develop new ones and to protect the rights, property, or safety of Advanced Navigation and our users;
  • to communicate with you in order to provide you with information we think may be useful or relevant to you;
  • to promote our services and related services;
  • to analyse information in order to offer aggregated anonymised data products to third parties;
  • to facilitate the sharing of aggregated and anonymised information with third parties, including transaction data;
  • to enforce the Privacy Policy and our terms and conditions for use of our services and websites;
  • to monitor and analyse trends, usage, and activities in connection with our services and for marketing or advertising purposes or to offer you tailored content;
  • to investigate and prevent fraudulent transactions, unauthorised access to or use of our services, and other illegal or unusual activities;
  • when you contact us, to keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements;
  • from cookies and other technologies, to improve your user experience and the overall quality of our services; and
  • as otherwise stated in this Privacy Policy.

To use the information we collect, we may require our systems to access, screen capture, store, video and/or scan your information. Where appropriate or required by data protection laws, we will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Do we use your personal information for direct marketing?

We will always give you the opportunity to opt-out however, we and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with applicable legislation.  You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

Who do we disclose information to?

We may disclose personal information for the purposes described in this privacy policy to:

  • our employees and related bodies corporate;
  • third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
  • professional advisers, dealers and agents;
  • payment systems operators (eg merchants receiving card payments);
  • our existing or potential agents, business partners or partners;
  • our sponsors or promoters of any competition that we conduct via our services;
  • anyone to whom our assets or businesses (or any part of them) are transferred;
  • specific third parties authorised by you to receive information held by us; and/or
  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Retention of Personal Data

We will retain your personal information for the time necessary to provide the services we perform for you, or to achieve other purposes outlined in this Privacy Policy, and you can always request that we stop processing or delete your personal information.

We’re required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping.

Disclosure of personal information outside Australia

Advanced Navigation processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live.

We may disclose personal information outside of Australia to third parties for the purposes outlined in this Privacy Policy.

By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia. Where we disclose your personal information to third parties, we will take reasonable steps to ensure that any overseas recipient will deal with such information in a way that is consistent with the Australian Privacy Principles.

Information you share

Some  of our services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our services provide you with different options on sharing and removing your content.

Information we share

We do not share personal information with third parties unless one of the following circumstances apply:

  • With your consent
    We will share personal information with companies, organisations or individuals outside of Advanced Navigation when we have your consent to do so.
  • With account administrators
    If your account is managed for you by an organisation administrator then your organisation’s administrator and resellers who provide user support to your organisation will have access to your information (including your email and other data).
    Your account administrator may be able to:

    • view statistics regarding your account;
    • change your account password;
    • suspend or terminate your account access;
    • access or retain information stored as part of your account;
    • receive your account information in order to satisfy applicable law, regulation, legal process or enforceable governmental request;
    • restrict your ability to delete or edit information.

Please refer to your account administrator’s and reseller’s privacy policy for more information.

  • With Third Party Service Providers
    We may disclose personal information to:

    • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage or management, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, customer lifecycle management providers, data analytics or reporting providers, finance systems, cyber security providers, project management or collaboration providers, testing, research and alert tools, email service providers and payment systems operators;
    • our existing or potential agents or business partners;
    • third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you.
  • To address fraud, security or technical issues
    We will share your personal information with trusted third parties where necessary to detect, prevent or otherwise address fraud, security or technical issues.
  • For legal reasons
    We may disclose your information if required by applicable law, regulation or as part of any actual or prospective legal process (including if reasonably necessary to enforce applicable Terms of Service or in order to establish, exercise or defend our legal rights). If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR, the CCPA and other laws, we may disclose certain information to such bodies or agencies.
  • Merger or acquisition
    If we merge with or are acquired by another business, we may share your personal information with the new owners of the business and their advisors. We will continue to ensure the confidentiality of any personal information and give affected users notice (for example, via a message to the email address associated with your account) before personal information is transferred or becomes subject to a different privacy policy.

We may share aggregated, non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services. This could also include government bodies, industry groups, insurers and educational/training facilities.

Information security

We have put in place robust measures regarding the security of the information we collect and store about you (including through the use of network and database security measures) and will use our reasonable endeavours to protect your personal data from unauthorised access to or unauthorised alteration, disclosure or destruction. In particular:

  • We encrypt many of our services using Secure Sockets Layer (SSL) or Transport Layer Security (TLS).
  • We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
  • We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
  • We have multiple authentication and access control measures to ensure data is only accessed by authorised personnel.
  • We enforce strong encryption of all data at rest through the use of the Advanced Encryption Standard (AES-256).

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our servers via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Application

Our Privacy Policy applies to all of the services offered by Advanced Navigation and its affiliates, including services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include Advanced Navigation services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organisations who advertise our services.

Enforcement

We regularly review our compliance with our Privacy Policy. We also adhere to several self regulatory frameworks. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Restrict

You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access

You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

Correction

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints

If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

Other Websites

Please note that clicking on links and banner advertisements on our websites can result in your browser accessing a third party website, where data privacy practices are different to that of Advanced Navigation.

We are not responsible for, and have no control over, information that is submitted to or collected by these third parties and you should consult their privacy policies.

Changes

We may revise this Privacy Policy from time to time and will post the most current version on our website. If a revision meaningfully reduces your rights or involves a material change to our processing of your personal information, we will notify you.

Contact

If you have any enquiries or if you would like to contact us about our processing of your personal information, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.

Contact name:  Head of Legal

Email: [email protected] 

Telephone: +61 02 9099 3800

Post: 
Level 12, 255 George Street
Sydney  NSW  2000, AUSTRALIA

Appendix 1 – Additional Disclosures

(a) GDPR

For the purpose of this Privacy Policy the controller of personal data is Advanced Navigation and our contact details are set out in the Contact section above.

The Legal Basis for Processing your Information

Under GDPR, the main grounds that we rely upon in order to process personal data collected via our websites and services are the following:

  • Necessary for entering into, or performing, a contract– in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
  • Necessary for compliance with a legal obligation– we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
  • Necessary for the purposes of legitimate interests– either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website, applications and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
  • Consent– in some circumstances, we may ask for your consent to process your personal data in a particular way.
Third Party Service Providers

As mentioned above, we will share your personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, and to perform maintenance or respond to technical incidents affecting our services. A list of sub-processors currently engaged by Advanced Navigation is published here.

Where we disclose personal information to third parties, we require minimum standards of confidentiality and data protection from such third parties.

Processing Outside of the European Economic Area (“EEA”)

To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will ensure that approved safeguards are in place to ensure that we comply with GDPR, such as the standard contractual clauses approved by the European Commission.

Advanced Navigation processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live, including outside the EEA. We use data centres operated by our third-party cloud hosting provider, Amazon Web Services (“AWS”) to store user data and data uploaded to our products.

Retention of Personal Data

We will retain your personal information for the time necessary to provide the services we perform for you, or to achieve other purposes outlined in this Privacy Policy, and you can always request that we stop processing or delete your personal information (see the section below regarding your rights).

Your rights in respect of information we hold about you

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

Right of Access

You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

Right of Correction or Completion

If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us at [email protected]

Right of Erasure

In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

Right to object to or restrict processing

In certain circumstances, you have the right to object to our processing of your personal information by contacting us at [email protected] . For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.

You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability

In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.  You can ask us to transmit that information to you or directly to a third party organisation.

The above right exists only in respect of personal information that:

  • you have provided to us previously; and
  • is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.

You can exercise any of the above rights by contacting us using any of the methods in the Contact section above.

Most of the above rights are subject to limitations and exceptions.  We will provide reasons if we are unable to comply with any request for the exercise of your rights.

To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section above.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. It is specifically regulated under GDPR where such decisions are taken which have legal or other significant effects on individuals. It is permitted in the following circumstances:

  • Where it is necessary to enter into or perform our contract with you and appropriate measures are in place to safeguard your rights.
  • In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated processing, unless we have a lawful basis for doing so, we have notified you and given you a right to challenge the decision or to require that the decision be taken by a person.

Complaints

If you are unhappy about our use of your personal information, you can contact us using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:

Telephone: 0303 123 11113

Website: https://ico.org.uk/concerns/

Post: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority.  A list of relevant authorities in the EEA and the European Free Trade Area can be accessed here.

(b) California Consumer Privacy Act (“CCPA”)

The CCPA grants California residents certain additional rights regarding the personal information that Advanced Navigation may collect, disclose or sell. For purposes of this section, “Personal Information” means anything that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular California consumer or household. We do not collect, use or sell Personal Information of children age 16 or under.

Individuals with disabilities may access this policy in an alternative format by sending an email to: [email protected]

Your Disclosure Rights

As provided in this Privacy Policy:

  • Over the past 12 months, Advanced Navigation has collected personal information from you as provided in the “Information we collect” section above.
  • Advanced Navigation may share your information with third parties as provided in the “Information we share” section above.
  • Advanced Navigation does not sell (as such term is defined in the CCPA) the personal information that we may collect from you.
Requests

The CCPA also provides California residents with the right to request additional details about the personal information we collect (including how we use and disclose this information and whether it is sold) and, if necessary, the right to delete your personal information.

California residents may make a request pursuant to your rights under the CCPA by contacting us at [email protected]. To ensure that the request is coming from you and to protect the security of your Personal Information, we will verify your request using 2 out of the following 4 data points to verify your identify: (1) email address; (2) telephone number; (3) description of the product or service you purchased or inquired about, and (4) the security code from your credit card. If you are requesting to delete sensitive information, you must provide us with 3 out of the following 4 data points described above to verify your identity. Government identification may be required.

We also commit to not discriminate against any California consumers because you exercise any of your rights. To read more about the CCPA please visit California Legislative Information.

Non-discrimination

You have the right to receive our products and services on equal terms regardless of whether or not you exercise your rights under the CCPA.

To read more about the CCPA please visit California Legislative Information 

Third Party sub-processors

Advanced Navigation uses sub-processors to process personal data on behalf of its customers. 

Advanced Navigation routinely evaluates each sub-processor initially and on a regular basis. We also adopt supplementary measures to protect such personal data. 

When we engage a new sub-processor, or remove a sub-processor, we will update this page. If you have questions or concerns about a new sub-processor, we are happy to help. Please contact us at [email protected]