PRIVACY POLICY

NAVIGATE AFFORDABLE HOUSING PARTNERS PRIVACY POLICY

Last updated October 1, 2024

INTRODUCTION

Navigate Affordable Housing Partners, Inc. (“We,” “Our,” “Us” or “Navigate”) strives to honor and protect your data protection rights. By using our website, https://www.navigatehousing.com/privacy-policy (the “Website”), you agree to the uses of your Personal Information disclosed in this Privacy Policy (or “Policy”). This Privacy Policy explains what Personal Information we collect, process and share, as well as your rights in regard to your Personal Information. 

By using our Website, you agree to this Privacy Policy and the uses of your Personal Information set out in it. 

The Website is intended for U.S. adult residents only. It is not intended for non-U.S. residents nor minors.

When you submit information to us via our Website, both directly and indirectly, that information is managed and processed in accordance with this Privacy Policy. We do not sell your Personal Information. We do not share it except for business purposes. We do not use your Personal Information for targeted advertisements to you through profiling. 

TABLE OF CONTENTS

DEFINITIONS

BINDING AGREEMENT

PERSONAL INFORMATION WE COLLECT

HOW WE MAY COLLECT PERSONAL INFORMATION

HOW WE USE INFORMATION

SHARING OR SELLING YOUR INFORMATION

YOUR INFORMATION / YOUR CHOICES

EXERCISING YOUR RIGHTS

VERIFICATION OF REQUESTS

RESPONDING TO YOUR REQUEST

APPEAL PROCESS

NON-DISCRIMINATION FOR EXERCISING YOUR RIGHTS

NOTICE OF FINANCIAL INCENTIVES

SURVEYS OR CONTESTS

USER CONTRIBUTIONS

CHILDREN’S PRIVACY POLICY AND PRACTICES

DATA SECURITY, RETENTION POLICIES AND PRACTICES

GLOBAL DATA TRANSFER

COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES)

JURISDICTIONAL PRIVACY RIGHTS

UPDATES TO THIS PRIVACY POLICY

CONTACT INFORMATION

DEFINITIONS

“Aggregated Information” is information about groups or categories of individuals, which does not identify and cannot reasonably be used to identify an individual.

“Individual” or “consumer” means a living natural person.

“Non-Identifying Information” is any Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual, household, or device.

“Personal Information” is any information that can identify, relate to, describe, or be linked with a consumer or their household. 

“Policy” means this Privacy Policy.

“Process,” “Processing,” or “Processed” means any operation or set of operations performed on Personal Information, including through automated means.

“Resident Portal” can be accessed through the Website, and it allows you to upload documents and transmit them to us through secured links. You will only have access to your Personal Information, not the personal information of unaffiliated third-party individuals.

“Sensitive Personal Information” is Personal Information that reveals a consumer’s (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email and text messages, unless the business is the intended recipient of the communication; (f) genetic data; (g) the processing of biometric information for the purpose of uniquely identifying a consumer; (h) Personal Information collected and analyzed concerning a consumer’s health; or (i) Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation.

As used in this Policy, references to “Personal Information” includes Sensitive Personal Information, except where Sensitive Personal Information is specifically referenced or used.

“Services” discussed in this Policy are the information, services and methods of communication we provide through the Website, including the Resident Portal. 

“User Contributions” means information that you may provide to be published, displayed, or transmitted to other Website users or third parties.

BINDING AGREEMENT

Please read this Policy carefully. By accessing or using the Website or the Services, you agree to us Processing your Personal Information as described in this Policy. This Policy may change from time to time. You should review <<UPDATES TO THIS PRIVACY POLICY>> to understand when and how it might change. Your continued use of the Website or the Services after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

If you do not agree to us Processing your Personal Information as stated in this Policy, do not use the Website or the Services, and do not submit any Personal Information to us. 

PERSONAL INFORMATION WE COLLECT

We may collect Personal Information and Sensitive Personal Information about individuals, such as payment information that you may provide to us through the Resident Portal.

Our Website may contain links to other websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects Personal Information.

HOW WE MAY COLLECT PERSONAL INFORMATION 

We collect Personal Information:  

• Directly from you when you provide it to us.
• Automatically as you navigate the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Personal Information Directly Collected from You. You may provide us Personal Information in the following ways: 

• When you request Services through the Website. 
• When you use the Website to communicate with us. 
• When you report a problem with our Website.
• When you respond to a survey on our Website. 
• When you run searches on our Website.
• Through User Contributions. Your User Contributions are posted and transmitted to others at your own risk.

Personal Information Collected Automatically. We may also collect Personal Information automatically as you navigate through and interact with our Website. This may be done through automatic data collection technologies to collect information about your equipment, browsing actions, and usage patterns. This information may include:

• Details of how you use the Website, such as how you access the Website, which pages of the Website you access, how long you access specific pages, the information you download from the Website; and the resources you use on the Website.
• Whether we have previously connected with you for business development purposes (i.e. do we have a sales lead for you, are you a current customer, or are you in our database for other reasons).
• Information about your computer, such as your operating system, device ID, browsing history, search history.
• Information about your mobile device information, such the type of your device, your operating system type and version, screen resolution, device language setting, model, and manufacturer, mobile carrier, operating system and other device attributes. 
• The different devices you use to access the Website; 
• Information about your internet connection or the equipment you use to access the internet, such as your IP address;
• The general geographic location of your device (city and state).
• Information about whether you’ve engaged with Navigate’s brand on social media platforms such as Facebook and Instagram.
• Derived information reflecting your employer’s name. 
• Information about the categories of other websites you have browsed. 
• Recordings of your calls to our customer service team. We use these recordings for quality and training purposes.

We may also collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please see << COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES)>> for information on how we use these technologies. Please see <<YOUR INFORMATION / YOUR CHOICES>> for information on your rights with respect to the information we Process, and <<EXERCISING YOUR RIGHTS>> for information on how to exercise those rights. 

The information we collect automatically may be associated with Personal Information we collect in other ways or receive from third parties. This can help us improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

Analytics tools are a specific type of automatic data collection tools. For more information on the analytic tools we use and how we use them, please see <<COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES )>>. 

Information We Collect from Third Parties.  We use information from third parties to supplement or update the information you provide to us or that we collect from you automatically. Examples of other information we may receive from third parties are: 

• Your name, personal and professional email addresses, and personal and professional phone numbers; 
• Profile information, comments, and similar information provided to or on social networks and other forums that connect to us; 
• Interests, demographic data and purchasing behavior; and
• Information collected from you offline or through other channels, such as information you provide when attending an in-person event or function or information you provide to us over the phone. 

Information We Do Not Collect.

We do not collect biometric information or sensory data on the Website. We do not collect non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).

Information We Collected in the Past 12 Months.

Collection of Non-Identifiable Information. We may also collect Non-Identifiable Information, such as are your preferred language, zip code, area code, referrer URL, and the time zone where the Website is accessed. We use this information to better understand user behavior and improve our Services. We also may collect information regarding user activities on our Website and aggregate that information to help us provide more useful information and Services to our users. This Non-Identifiable Information also helps us understand which parts of our Website and Services are of most interest. Aggregated data is considered Non-Identifiable Information and not Personal Information in this Policy.

Your Responsibilities With Regard to Information We Collect. If you provide us any Personal Information about another individual, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Policy.

You are responsible for ensuring the accuracy of Personal Information you provide to us. Inaccurate information may affect your use of the Services as well as our ability to contact you. You are not required to provide Personal Information to us, but if you chose not to do so, we may not be able to provide you with our Services or respond to questions you may have.

HOW WE USE INFORMATION 

Consistent with applicable law and the choices and controls that you select <<EXERCISING YOUR RIGHTS>>, we may use your information as described in this Policy. Some examples of how we may use your information, including Personal Information, are: 

• Fulfilling your requests; 
• Presenting our Website to you; 
• Providing you with the Services you request, view, or engage with;
• Allowing you participate in interactive features on our Website;
• Providing you with updates about Navigate’s latest happenings and upcoming events; 
• Communicating about your account or transactions with us, including, providing you notices about your account; 
• Providing you with information about Navigate, our Services and our business activities; 
• To comply with any applicable health care tracing efforts, such as COVID-19; 
• For customer service and customer support purposes;
• Sending you information or requesting feedback about features on our Website or about changes to our policies or Website;
• Sending you offers and promotions for our products and services or third-party products and services;
• Personalizing content and experiences presented to you;
• Providing you with information on our own or third party products or services based on your activity on our Website or on third-party sites and applications;
• Operating, understanding, optimizing, developing, or improving our Website, products, services and operations, including by using guest survey research and analytics tools; 
• Displaying advertisements from third parties where it appears that your information matches the target criteria specified by the third party (for this purpose, your information is not shared with or provided to the third party); 
• Detecting, investigating and preventing activities that may violate our policies, pose safety issues, or be fraudulent or illegal; 
• Testing, research, analysis, and product development, including development and improvement of our Website, and products, and services;
• Fulfilling our obligations or enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;
• To prevent transactional fraud;
• Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations; 
• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Navigate, if Personal Information about our users is one of the assets being transferred; 
• Speeding up your searches; 
• Providing, personalizing, measuring, and improving your experience with our Website and Services, and delivering content and Services; 
• Estimating our audience size and usage patterns;
• Maintaining and improving the safety, security, and integrity of our Website and Services;
• Recognizing you when you return to our Website so that we can return you to where you were on the Website;
• Supporting our general business operations;
• For any other purpose with your consent; and 
• For any other lawful purpose that is our legitimate interest and not overridden by your data privacy rights.

To learn more about how we use your information for personalization and tracking, please see <<COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES )>>.

Our Legal Basis for Processing Your Personal Information. We have determined that our legal basis for the different types of data process are as follows:  

SHARING OR SELLING YOUR INFORMATION 

Navigate strives to collect, process and share only the Personal Information that we need for our business operations.  We do not sell or share your Personal Information in exchange for money. 

Some privacy laws define the sale of data to include sharing Personal Information for a business purpose. Where this may be the case, we enter into contracts requiring those third parties to keep your Personal Information confidential and to use your Personal Information only for the permitted purpose. 

Sharing Personal Information. We may share your Personal Information in the following situations:   

• To fulfill the purpose for which you provided it; 
• To our affiliates (such as other companies that own us, that we own, or that share common ownership with us); 
• When you allow us to share your Personal Information with another company, by electing to share your Personal Information with carefully selected companies so that they can send you offers and promotions about their products and services;
• When you direct us to share your Personal Information with another company to fulfill your request; 
• When you direct us to share your Personal Information with third-party sites or platforms, such as social networking sites.
• When we cooperate with other businesses to offer co-branded products or services to you; however, we will do so only if permitted by applicable law, and, in these cases, the other business will be prohibited from using your Personal Information for purposes other than those related to the co-branded products or services;
• When companies perform services on our behalf, like marketing and advertising, and  customer service; however, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law; 
• When requested by law enforcement agencies, regulators, and courts in response to a court order, subpoena, regulatory requirement or similar legal process, to report any activities we reasonably believe to be unlawful or as otherwise required by law; 
• To combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of a legal proceeding affecting Navigate; 
• When we share your Personal Information with third parties as part of selling the business, to enforce our Terms of Use or rules, to ensure the safety and security of our users and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law;
• When it is necessary to respond to a public health emergency, or in an emergency, to protect the safety of your health and property; 
• For any other purpose we disclosed when collecting the information; and 
• With your consent. 

Aggregated or Non-Identifying Information. We may disclose Aggregated Information or Non-Identifying Information, for any reason without restriction.

Personal Information Shared in the Past 12 Months. We disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

YOUR INFORMATION / YOUR CHOICES 

You have the ability to exercise certain controls and choices regarding our collection, use and sharing of your Personal Information. In accordance with the laws that may apply to you, your controls and choices may include:

The Right to Know/Right To Access

You have the right to know what Personal Information we collect about you. Upon receipt of your request, and confirmation of your identity, we will disclose to you: 

• the categories and specific pieces of Personal Information that we have collected about you in the past 12 months, 
• the sources from which we have collected that information, 
• our business or commercial purpose for collecting such information,
• the categories and specific pieces of Personal Information that we have disclosed to third parties for a business purpose during the past twelve months, 
• the categories and specific pieces of Personal Information that we have sold to third parties during the past twelve months, and 
• the third parties to whom we have disclosed or sold such Personal Information. 

In most cases, you may request this information up to two times each year. 

The Right to Data Portability 

You have the right to request a copy of the Personal Information we have about you. We will provide it in a format that we select, that you can reasonably transfer to a third-party. 

The Right to Correct/Right to Rectification

You have the right to request that we correct inaccurate Personal Information that we may maintain about you, subject to applicable legal exceptions. 

The Right to Delete/Right to Erasure 

You have the right to request that we delete your Personal Information, subject to applicable legal exceptions. If you submit this request, we will review it and attempt to confirm your identity. Once we confirm your identity, and assuming no exception applies that requires or allows us to retain your Personal Information, we will delete it and direct our service providers to do the same. 

We may deny your deletion request, for example, if retaining the Personal Information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with any international, national, federal, state, or local laws, rules or regulations, applicable to us or to your Personal Information.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation or other lawful uses.

Right to Opt-Out of Promotional Offers

If you do not wish to have your email address or other contact information used by Navigate to promote our products or services, you can opt-out of non-essential email or text communication by contacting us as provided in <<CONTACT INFORMATION>>. If we have sent you a promotional email or text, you may send us a return email or text asking to be omitted from future email distributions. 

Your election not to receive promotional and marketing correspondence from Navigate will not (a) preclude us from corresponding with you, by email, text or otherwise regarding your existing or past relationship with us, nor (b) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your Personal Information while maintaining and improving the Website. 

Right to Opt Out of Targeted Advertising and Profiling

Navigate does not use targeted advertising using your Personal Information nor engage in profiling.

Right to Opt Out of Sale or Sharing of Personal Information

You have the right to “opt out” of the “sale” or “sharing” of your Personal Information to or with “third parties” (as those terms are defined by applicable law). There may be situations where we cannot fulfill your requests if you opt-out of such sharing, and we will notify you if this applies. 

You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so.

To opt-out of the sale or sharing of your Personal Information, you or your authorized representative should: 

Click on the link “DO NOT SELL OR SHARE MY PERSONAL INFORMATION” on the footer of our Website.

Enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.  

Submit a request to us by contacting us <<CONTACT US>>. 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales by contacting us <<CONTACT US>>.

You do not need to create an account with us to exercise your opt-out rights. We will use Personal Information provided in an opt-out request only to review and comply with the request.

EXERCISING YOUR RIGHTS 

To exercise any of your rights, submit a request by: 

Navigate Housing

Attn: Data Privacy Rights Request

2701 1st Avenue South

Suite 200

Birmingham, AL 35233

Phone: 1-888-466-5572

Email: Privacy@navigatehousing.com

When submitting a request, you must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such individual.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

VERIFICATION OF REQUESTS

Only you, or someone legally authorized to act on your behalf, may make a request regarding your Personal Information. A parent or guardian with legal custody may make a request on behalf of a minor child. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you have given your permission and/or to verify your identity.

We cannot, and will not, respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm the Personal Information relates to you.

You are not required to submit a request through your account with us, but we do consider request through your password protected account to be verified, without further requirements, as long as the request is for information associated with that account. 

We will not use Personal Information provided in the request for any purpose other than to verify the requestor’s identity or authority to make the request.

Verifying an Authorized Agent

In certain circumstances, you are permitted to use an authorized agent, as that term is defined by applicable U.S. state privacy law (“Authorized Agent”) to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us. An Authorized Agent can make a request on your behalf by:

For requests to know and delete: (1) providing a valid power of attorney under the laws of the subject individual’s state of residence; or (2) providing sufficient evidence to show that the subject individual has (i) provided the Authorized Agent signed permission to act on their behalf, (ii) verified their own identity directly with us, and (iii) directly confirmed with us that they have provided the Authorized Agent permission to submit the request on their behalf; and

For requests to opt-out: submitting a signed permission demonstrating that the Authorized Agent has been authorized by the subject consumer to act on their behalf.

RESPONDING TO YOUR REQUEST

We endeavor to confirm receipt of all requests within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email Privacy@navigatehousing.com to ensure we received your request.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

The information in our response will cover the 12-month period preceding our receipt of your request. If we cannot comply with your request or any portion of your request, our response will explain the reasons we cannot comply. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

APPEAL PROCESS

If we refuse to take action upon your request to exercise any of your data privacy rights, you may appeal our decision within a reasonable period after you receive notice of our decision. To initiate an appeal, please contact us using the information in the <<CONTACT INFORMATION>> section and inform us that you would like to appeal our decision. Within forty-five (45) days after we receive your appeal, we will inform you of any action taken or not taken in response to your appeal, and we will provide you with a written explanation of the reasons in support of our response. 

If your appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general to submit a complaint, should you wish to do so.

NON-DISCRIMINATION FOR EXERCISING YOUR RIGHTS

We will not discriminate against you for exercising any of your data protection rights, and specifically we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer certain financial incentives permitted by applicable data protection laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. 

Please be aware that if you do not allow us to collect Personal Information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of Personal Information is mandatory for successful provision of our services, we will make that clear at the point of collection so that you can make an informed decision whether to participate. 

NOTICE OF FINANCIAL INCENTIVES

From the time to time, we may run sweepstakes, contests, or other offers and promotions (collectively, “Programs”) that may be deemed “financial incentives” in relation to our collection of Personal Information under applicable data privacy laws. A business may offer financial incentives for the collection, sale or deletion of Personal Information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. We may run sweepstakes or contests from time to time. Please refer to the terms and conditions of each Program for additional information about the Program, including how eligible consumers can opt-in or opt-out of the Program at any time.  In order to enter a Program, you may be required to provide us or a service provider acting on our behalf with certain Personal Information, such as identifiers including your name and contact information (“Rewards Data”). If you submit your entry in accordance with the applicable Program’s rules, you may be entered into the Program and will get a chance to win a prize or receive another benefit from us. The value of Rewards Data is related to the value of your information and the costs associated with offering the Program.

SURVEYS OR CONTESTS

From time-to-time our Website may request information via surveys or contests. Participation in these surveys or contests is completely voluntary, and you may choose whether to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this Website.

USER CONTRIBUTIONS 

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our <<TERMS OF USE>>.

Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other Website users. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

CHILDREN’S PRIVACY POLICY AND PRACTICES 

Our Website is not intended for individuals under 18 years of age. No one under age 18 may provide any Personal Information to or on the Website. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Website, or through any of its features, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from an individual under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about an individual under 16, please contact us at Privacy@navigatehousing.com. 

DATA SECURITY, RETENTION POLICIES AND PRACTICES 

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. 

The safety and security of your information also depends on you. You are responsible for keeping your username and password confidential. We ask you not to share your password with anyone.

Wherever we collect Sensitive Personal Information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.

While we use encryption to protect Sensitive Personal Information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access as needed. The computers/servers in which we store your information are kept in a secure environment.

We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.  

GLOBAL DATA TRANSFER

The information you provide due to your use of the Website may be transferred or accessed by entities outside of the U.S.

COOKIE POLICY (ONLINE TRACKING TECHNOLOGIES)

We may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Website. These technologies allow us to understand who has interacted with us and also help us to operate our Website and Services more efficiently. 

Types of Cookies.

• Cookies. Cookies are small data files created by web browsers and downloaded onto your computer or other device when you access a website. Cookies help make your browsing experience with our Website more personal. Different cookies serve different purposes, such as recognizing your devices, storing information about your preferences, identifying the geographic area of a user, tracking browsing habits and preferences, recalling information entered on forms, login pages, or other features of the Website. This helps us understand how the Website is being used and is used to generally improve your browsing experience on the Website. 
• Session Cookies expire once you close your web browser. Persistent Cookies stay on your computer or mobile device until you delete them. For information on cookies that Navigate uses, please see our <<COOKIE POLICY>>.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Website that collects information about users’ engagement on the site. The use of a pixel allows us to record, for example, that a user has visited a particular web page.
• Analytics/Performance Cookies. Google Analytics and Google Ads collect information regarding visitor behavior and visitor demographics for our Website. For more information on how Google uses your information, please see Google’s Privacy Policy, at https://policies.google.com/privacy?hl=en-US, and Google’s Advertising Policy, at https://policies.google.com/technologies/ads?hl=en-US.
• Functional Cookies. Functional cookies are small pieces of code that are stored on a device or browser to help websites remember user preferences and provide additional functionality. They can be first-party or third-party, persistent or session-based, and are generally considered “strictly necessary” cookies that don’t require consent.
• Marketing/Advertising Cookies. Tracking/Marketing/Advertising cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and usually originate with third-parties.You can opt-out of many of these cookies by updating your preferences on www.aboutads.info.
• Social Media Cookies. Social media cookies are stored on your computer browser to help you log into your social media accounts faster. Social media companies may recognize you and collect information about your visit to our Website, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

Categories of Cookies.

There are different ways to classify cookies, including based on when they expire or whether they are managed by us or a third party. 

What Cookies Do We Use?

Navigate uses Strictly Necessary, Functional, Analytics/Performance and Marketing/Advertising  cookies.

Why Do We Use Cookies? 

We use cookies to learn how you interact with our Website and to improve your experience and provide you additional functionality on the Website. We may also use pixels for the same purposes.

How Do Third Parties Use Cookies on Our Website?

We work with limited third parties to provide certain services on the Website. These third parties include Facebook and Instagram. They may use their own cookies to collect information about your actions on our Website. 

For more information on how these third-party service providers collect and use information, please refer to their privacy policies.

How Can You Control Cookies? 

You can set your browser to reject cookies, or you can manually delete individual or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, this may alter your access and use of some of the pages and features on our Website.

Users can visit Google Analytics Opt-out Browser Add-on Download Page, https://tools.google.com/dlpage/gaoptout, for information on how to opt-out of Google Analytics.

You may also reject or block all or specific types of cookies from our Website by setting your preferences. You can change those preferences at any time. You may also visit https://allaboutcookies.org/ or https://www.aboutcookies.org/ for details on how to delete, reject, or block cookies and for further information on cookies generally. 

Some web browsers may transmit “do-not-track” signals to Website with which the user communicates. These are different from Global Privacy Controls. The Website does not monitor or identify “do not track signals,” and such signals will not impact the operation of this Website.

We do not 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. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on NAI’s website.

You may have additional rights regarding your Personal Information based on the state in which you reside. Please see <<JURISDICTIONAL PRIVACY RIGHTS>> for more information. 

JURISDICTIONAL PRIVACY RIGHTS 

UNITED STATES

California

California residents have the following rights: 

Shine the Light Act. If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your Personal Information by Navigate to third parties for the third parties’ direct marketing purposes. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share your Personal Information with third parties for those parties’ direct marketing use, unless you elect that we do so.

Nevada

Nevada provides its residents with a limited right to opt-out of certain Personal Information sales. Residents who wish to exercise this sale opt-out rights may do so as provided for in <<EXERCISING YOUR RIGHTS>>. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Other U.S. States Data Privacy Laws

The rights set out in <<YOUR INFORMATION / YOUR CHOICES>> discusses the rights that residents of various U.S. states have regarding their Personal Information. The following states have passed and/or enacted data privacy laws that currently allow or will allow the rights in <<YOUR INFORMATION / YOUR CHOICES>>: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. This list does not purport to be all-inclusive, as the laws in the area of data privacy are constantly evolving.

UPDATES TO THIS PRIVACY POLICY 

From time to time, we may change this Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. Any changes to this Policy will be posted to this website page. The date the Policy was last revised is identified at the top of the page. 

CONTACT INFORMATION 

If you have a comment or question about this Policy, please contact us at:  

Navigate Housing

Attn: Data Privacy Rights Request

2701 1st Avenue South

Suite 200

Birmingham, AL 35233

Phone: 1-888-466-5572

Email: Privacy@navigatehousing.com