PRIVACY NOTICE

Version 2.0 – 01 January 2022

 

Who we are

We are the Navico Group, a Group of Company owned by Navico Holding AS. The Navico Group is part of the Advanced Systems Group, a branch of Brunswick Corporation. The Navico Group, as the manufacturer, provider and marketer of Lowrance, Simrad, B&G and C-MAP recreational products, believes that putting trust, transparency and control at the heart of our customer and consumer experiences is key to being a leading player in our industry.  

 

Navico Marine Electronics S.L (“Navico, we, us, our”) is the data controller responsible for protecting the personal information we hold about you. It may, from time-to-time, act as co-controller with other Navico Legal Entities listed below.

-       Navico Holding AS

-       Navico Inc.

-       Navico Auckland Ltd

-       Navico UK Limited

We will keep your personal information safe and secure, and we will not misuse it.  We appreciate that your personal information belongs to you even if it has been shared with others.  This privacy notice explains what we do with your personal information, so you understand how we use it.  It also tells you what your legal rights are in relation to it and how you can exercise them so that you are always in control of your personal information.

 

Information we have about you

We have personal information about you that you have given us; personal information that we collect from the following sources:

-       Directly from you when:

§     You create or use an account,

§     You subscribe to our newsletter,

§     You use our website (See our Website Privacy Notice[i] and Cookie Policy)[ii]

§     You use our Apps (SIMRAD, LOWRANCE, B&G and CMAP Apps)

§     You use our connected products.

§     You submit a support or warranty request to us

 

 

-       From Third Parties, upon obtaining your consent when:

·       You choose or chose to create an account or to login through the third-party login/account creation options (Facebook/Apple login)

 

Personal information you give us on our websites: See Navico Websites Privacy Notice and Cookie Policy

 

Personal information you give us on our connected products: See the Navico Policy of your SIMRAD, B&G or LOWRANCE connected product(s), if any.

 

Please note that your basic personal information, Navico Account Number and login data, contact information, order details, and product details, as well as some analytics information are collected and processed by Navico if they are provided through our websites or Apps or our connected products. Personal data and consents given through our websites, Apps and connected products for marketing purpose will be treated as per Navico’s Website Privacy Notice (i).

 

Personal Information you give us through the Navico Apps:

-       When creating your account or connecting to your account:

o   Basic personal information: Name, last Name, age

o   Navico account number and login data

o   Facebook Unique / Apple Unique ID if you elected to create/connect to your accounts via your Facebook/Apple account.

o   Contact information: Email address, phone number, address

o   Country of use

o   Smartphone model and brand

 

-       When you select the services you wish to use/purchase from Navico:

o   Subscription type

o   Transaction records (Order detail, purchase ID, App Store/Google Play transaction ID)

 

-       When you use our Apps functionalities and services:

o   Last IP Address,

o   Settings and user preference parameters

o   Saved Locations (like your “Home Harbor”), waypoints, routes and historic GPS tracks

o   Boat Name/Registration information (if you elect to provide it)

o   Map areas you viewed and downloaded while using our Apps

o   Limited in-App events and usage analytics to allow us to provide you with our connected services

 

-       When you connect your App to a Navico connected product:

o   Connected product Information (Serial number, brand, software version and registration status)

o   Connected product setup language

o   Connected product IP address and embedded Wi-Fi connection credentials

 

-       When you give us your express consent:

o   Product use data* (In-App events and behavior) for analytics purpose

*  Except for in-App events and use behavior collected to help you use our connected services, in-App events and use behavior data will be collected on an anonymous basis unless you consent to provide us such data to improve our Apps and services. We will anonymize those data collected from your App in case you do not provide your consent.

o   Temporary live location (Only if you elect to enable the Navico Mobile Community “Traffic” Function*, upon providing Navico with your express consent by activating this option on the App)

*Please note that Live location data are retained by Navico for a very short period to maintain your privacy. When user enabled, the Navico Mobile Community Traffic will only maintain your live location data for 30 minutes in cache. Such information will be automatically purged from our system after that period.

 

Why we need your personal information

We need certain types of personal information from you so that you can buy our goods and/or use our services and we can make sure we process your orders correctly.

We also need to process some information to offer you connected service

 

We notably need to process the following type of information:

-       Your basic personal information: Name, last name, date of birth, as well as Navico account number and Login Data to administer your account with Navico and ensure proper synchronization of our different services

-       Your transaction data and product details to comply with our legal obligation and process support/warranty requests.

-       Your subscription type to make sure we provide you with the relevant type of services and software updates on our Apps

-       Your boat Information, settings, user preference, waypoint, routes, historic GPS tracks and connected products information to ensure proper interaction between our different systems through our cloud solution, enable seamless synchronization between our Apps and our connected devices and allow you to access the information about your previous activities and planned routes from your connected devices and Apps

-       Your country location to make sure you are located in a country we can provide service to when setting up your App

-       Your Email Address to make sure we can communicate with you

-       Some In-App events to make sure we provide you with the relevant support and services where needed

-       Your Live location when you consented to it, to provide you with the Community Traffic services

 

How we use your personal information

We use personal information only to the extent that is necessary to operate our business.  The law allows us to use personal information as long as we tell you what we are using it for and we have a valid legal basis for doing so.

 

You will find the relevant legal basis for the processing of each piece personal information you provide to us below:

 

When we need to fulfil our Contractual Obligations to you:

 

      To maintain your account with us

      To provide you with the services your purchased from us

      To process, administer and deliver your order and to provide you with updates about your order status/ and software subscription

 

When it is in our legitimate interests (i.e. we have a business or commercial reason which we do not prioritize above your rights)

 

      To verify and process your warranty registration and claims. We have a legitimate interest in verifying that warranty claims submitted to us are legitimate

      To verify your location and identity, and ensure we are not selling to persons listed on trade sanction lists or located in embargoed countries

      To sufficiently verify your identity and treat potential subject access requests

      To communicate about how we process your personal data and how such processing evolve

      To provide you with information regarding the products you purchased, such as availability of new features, software and updates

      To understand when you face issues with our services and our apps and be able to assist you

 

Where we have your consent

      To provide you with targeted advertising and special offers, based on the products you purchased or showed interest to when browsing our website and Apps

      To analyze how you use our website, Apps, products and services

      To provide you with services that imply that we process your live location

      To provide you with marketing information about our products and services*

 

 

You have the right to withdraw your consent at any time. If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link placed at the bottom of the email. You can also notify us to change your marketing communication preferences using the Contact Us form on the website or reaching out to unsubscribe@navico.com. If you withdraw your consent, this will not affect the lawfulness of any processing carried out by us using your consent before such withdrawal.

 

When we are under a legal duty

      To allow us to comply with our legal, accounting, regulatory and tax obligations

      To establish, defend or exercise our legal rights

      To be able to notify you of important changes that may impact the processing of your data and management of your account

 

Who we share your personal information with
We will only share your personal information with other organizations after careful consideration and only when we have a legitimate reason. 

 

We may share your personal information with:

      The Navico co-controlling entity based on your geographical location:

      Navico UK and Navico Marine Electronic S.L for EMEA

      Navico Inc. for America

      Navico Auckland Inc. for Asia

      Other Navico entities for the purpose of providing local marketing content and offers from time to time

      Our service providers, suppliers, partners and subcontractors where this is necessary to provide our services to you

      Any prospective buyer of all or part of our business or assets (and associated advisors and agents)

      Our legal and other professional advisors and any other organization necessary to enforce our terms of use and other agreements and/or to protect the rights, property and safety of us, our users, or others

 

Transfers of personal information outside the European Economic Area

All EEA countries (the EU, Norway, Iceland, and Liechtenstein) provide an adequate level of data protection allowing free transfer of personal information to any of those countries.  We only transfer your personal information to countries outside of the EEA when it is necessary (for example where it is stored on servers based in a non-EEA country) and only if your personal information will benefit from the same protection as in the UK or EEA.

 

We protect your personal information that we transfer out of the EEA to other countries by ensuring that the organization to which personal information is transferred:

      Is in a country which the European Commission deems to provide an ‘adequate’ level of data protection

      Has entered into a contract with us which incorporates the European Commission’s Model Clauses

      Is one of our group companies and we have signed an Intercompany Data Protection Agreement that integrates the European Commission’s Model Clauses. We only transfer your personal data to our company responsible for customers in your region:

      Navico Marine Electronics SL (Spain) and Navico UK Ltd. (UK) acting as co-controllers for personal data of data subjects based in Europe, Middle East, and Africa (including the EEA)

      Navico Marine Electronics SL (Spain) and Navico Inc. (USA – Oklahoma) acting as co-controllers for personal data of data subjects based in South and North America

      Navico Marine Electronics SL (Spain) and Navico Auckland Limited acting a co-controllers for personal data of data subjects based in Asia and Oceania

 

How long we keep your Personal Information
We only keep your personal information for as long as we need it to carry out the different activities set out above. These periods are different depending on the nature of the activity. We also keep your personal information for as long as is necessary to comply with our legal obligations and to defend or exercise any legal claims.

      We keep your personal data collected for marketing purpose upon receipt of your consent for 3 years from the date of providing your consent

      We keep your personal data collected from any ecommerce transaction for 7 years

      We keep your personal data collected for legitimate interest, accounting and auditing for 7 years

      We keep the data related to your account at Navico and the connected services for as long as you maintain you account with Navico

      We only maintain live location data for thirty minutes from the time of their collection

 

As soon as there is no longer any need for us to hold your personal information, we will delete it or, in some cases, anonymize it so you can no longer be identified from it.

 

Sale of Personal Data

 

We do not sell, rent or trade your Personal Information with any third parties for commercial purpose. Your Personal Information is only shared with third parties as described in this notice and for the purposes mentioned above.

 

Your Rights
You can exercise your rights at any time by emailing us at DPO@navico.com. We will verify your identity before we deal with your request so your personal information is protected against unauthorized access.

 

You may also request that we provide you with a list of our third-party partners, with whom we share your data for the purposes mentioned in this Privacy Notice, if you submit a legitimate request for information.

 

To opt-out of marketing communications

You have the right to withdraw your consent at any time. If you would like to unsubscribe, follow the ‘unsubscribe’ link placed at the bottom of the email. You can also notify us to change your marketing communication preferences using the Contact Us  form in the app  or by emailing us at unsubscribe@navico.com.

 

To know what personal information we have collected and request a copy of the personal information we hold about you

 

To ask us to correct any inaccurate information we hold about you

 

To ask us to delete any personal information we hold about you

You have this right in certain circumstances only.  For example, it does not apply if we need to use your personal information to comply with our legal obligations or to establish, exercise or defend a legal claim.

 

To ask us to restrict our use of your personal information

You have this right in certain circumstances, for example where you have objected to our use of your personal information, and we are considering whether our legitimate interests override yours.  This is often a temporary measure, and we are still allowed to store your information while we are restricted from using it.

 

To ask us to transfer your personal information to you or another organization

This right is also known as the right to data portability.  It is your right to have your personal information ported to you or a nominated third party in a structured, commonly used and machine-readable format. 

 

This right applies only to information which we have collected from you and which we process using automated means.  You have this right only where we are using your personal information with your consent or to fulfil our contractual obligations to you (see: How we use your personal information)). 

 

To object to our use of your personal information

You have this right only in relation to our use of your personal information on the ground of legitimate interests (see How we use your personal information).

 

Not to be subject to discriminatory treatment.

You have the right not to receive discriminatory treatment for the exercise of your rights under the relevant privacy regulations, including, notably, the CCPA, subject to certain limitations.

 

Changes to our privacy notice
Our Privacy Notice will be revised regularly to ensure that we provide you with the most updated information with regards to the way your data are collected and processed. In any case, we shall review this Privacy Notice at least every twelve (12) months and amend it where necessary.

 

Any changes we make to this policy will be posted on this page.  Where the changes are significant, we will let you know by email or in another appropriate manner such as when you next interact with our website.

 

If we believe that the changes materially affect the way we process data that we collect based on your consent, we may elect to either inform you and offer you a way to withdraw your consent by email or ask you to give your consent again.

 

Contact us

 

You have the right to withdraw your consent at any time. If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link placed at the bottom of the email. You can also notify us to change your marketing communication preferences using the Contact Us form on the app or reaching out to unsubscribe@navico.com.

 

We really do welcome any questions, comments or requests you may have regarding this privacy notice.  You can email us at DPO@Navico.com or write to us at:

 

Data Protection Officer

Navico Marine Electronics S.L.,

Muelle Levante, 6 Módulo 14, Local 1, 03001 Alicante,

Spain

 

Please also use these contact details if you have any complaints about the way we have used your personal information.

 

If we do not deal with your complaint satisfactorily and within a reasonable timeframe, you have the right to complain to the Spanish Data Protection Authority.

 

 



[i] Website Privacy Policies: C-Map, Simrad, B&G, Lowrance

[ii] Website Cookies Policies: C-Map, Simrad, B&G, Lowrance