NAVIO

• Terms of Use
  • Copyright
  • Privacy Policy
  • AV Account - User Policy
  • AV Account - Merchant Policy
  • Spam Policy

Privacy Policy – Updated May 23, 2006

Navio Systems, Inc. is a licensee of the TRUSTe Privacy Program.  TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices.  This privacy statement covers the following web site: www.navio.com

Because Navio wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.

If you have questions or concerns regarding this statement, you should first contact the Navio Privacy Officer at privacy@navio.com.  If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily address, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.

At Navio Systems, Inc ("Navio"), your privacy is our priority.

• We do not sell your personal information to anyone
• You are already opted out from sharing personal information with third parties as we explain in Information Sharing and Disclosure.
• We protect the security and confidentiality of your personal information.

Our most important asset is our relationship with you. We understand that you entrust us with your personal information. We will do everything we can to maintain that trust.

Details of our approach to privacy and how your personal information is collected and used are set forth in the Navio Privacy Policy sections below.

Navio and Navio-owned brands are the sole owners of the information we collect except as outlined in the Privacy Policy below under Co-branded Sites.

Information We Collect

Overview: Navio provides various elements that enable you to collect, share, and trade digital assets. Navio manages your digital portfolio of your digital assets, the rights you have to those assets, and any payment mechanisms you have chosen to enable the purchase of digital assets.

Navio works with merchants that make offers for digital goods and services to you. These offers may appear to you in both electronic and physical forms. You may encounter these offers from time-to-time as a consequence of Internet searches, retail shopping, event attendance, merchant advertising, or other means.

Navio provides to these merchants a redemption site where you can get or purchase digital goods and services, including those presented in the merchants' offers.

Navio also operates a store where digital goods and services are sold. These digital goods and services are either owned outright by Navio or Navio is an authorized reseller of the digital good or service.

Navio's information collection and use is designed to protect your personal information in the context of this network of stores, merchants, redemption channels, and offers.

Registration: Navio supports both registered and non-registered users. In some cases, users are able to download or redeem content from Navio or Navio partners without requiring registration. However, when registration is required, you are required to provide a valid email address or working mobile phone number, and a password. Your AV Home can also be created using a mobile phone, in which case your password will be generated and sent to your phone. Additionally, if required by a content owner with an age policy, you will need to provide an attestation that you are 13 years or older at the time of registration.

You will receive an email confirming your registration and requesting that you confirm that email address so that Navio can activate your account for subsequent access by you.

If you wish to subscribe to our newsletter, you will be given the opportunity to opt-in to receiving that newsletter. By default, you are automatically opted-out.

Orders: In the course of using the AV Home to purchase or redeem items, Navio may request additional personal information in order to complete the transaction. You may be asked to provide payment information such as credit card details and billing address. You may be asked to provide details about your mobile phone for items to be delivered to your mobile phone handset. Along with transaction data, Navio collects the purchased / redeemed item's description.

Your email address serves as our point of contact to you for order confirmations or any problems in processing your order. You will receive an email from Navio for each order confirmation. The order confirmation will identify the order number, item(s) purchased, the amount paid, and any other details necessary to help you obtain the item(s).

Information About You From Third Parties: In order to protect all our customers and ourselves against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you provide a credit card with Navio, we will use card authorization and fraud screening services to verify that your card information and address matches what you provided to Navio, and that the card has not been lost or stolen.

Web Site Traffic Information (Log files): As part of the inherent nature of the Internet and specifically the World Wide Web, we capture the web address of the site you came from or are going to. We also collect information on which pages of our site that you visit, when you visit, and which Internet browser you use. We use this information only to better understand how our customers use our site and to improve the response time of our services. We do not track which sites you originate from or which sites you depart to.

The log files are not associated with individual users.

Cookies: A cookie is a small text file that is stored on your computer for record keeping. We use "session" cookies to aid in navigation through the site, specifically so you only need to login once. Once you logout of the AV Home, these session cookies expire. In addition, there is an automatic timeout where if you do not perform any activity on the site you are automatically logged off and the session cookie expires.

We also use longer-lasting, persistent cookies to retain your login email and password so that if you revisit any Navio-enabled site you do not need to reenter your login details, you merely confirm them to login.

Our cookie files are encoded so only Navio software can read them.

If your Internet Browser is set up to reject cookies, you may still use our site but your ability to use some areas of our site may be inhibited.

Web Beacons / Web Bugs: We use Web Beacons to anonymously track sales activity on our hosted websites and each stage of the buying process in the shopping cart. This data is not associated with any personally identifiable information and is used to better understand our sales and checkout process.

Contests and Surveys: From time to time, Navio may conduct surveys or contests. In such cases, you may be asked to provide additional personal information to be used as part of the contest or survey. You will always have the opportunity to opt-out of the contest or survey without penalty.

Third Party Advertisers: We do not deliver any ads to you from third parties and as such, no additional personal information about you is collected for third party benefit via cookies.

Links to Other Sites: Our Web sites may from time to time contain links to other sites that are not owned or controlled by Navio. We encourage you to be aware when you leave our sites and to read the privacy statements of each and every Web Site that you visit.

Customer service correspondence: If you send us correspondence such as email, we retain such information as part of your Navio Account records. We also retain any correspondence sent by Navio to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our Terms of Use. We may, over time, delete these records if permitted by law.

Information Use, Sharing and Disclosure

Internal Uses:
In general, we collect, store, and process your personal information on servers located in the United States. We use this information about you in several ways:

Email and password: Navio uses your email address and password to allow you return visit access. You, upon return, may do any of the functions permitted by the AV Home including acquiring more digital content through shopping or redemption, redelivering already-acquired content, adding new payment mechanisms, purchasing digital cash or digital cash equivalents, and sharing your items with friends.

Email: We use your email to send you order confirmations or service-related communications. We do not use your email to send you promotions, advertisements, or other marketing items that you have not explicitly opted to receive.

Credit Card Details: Navio uses your credit card details to allow purchase of items where a credit card is an accepted payment mechanism or to allow you to purchase digital cash or digital cash equivalents. The credit card details are remembered so they do not have to be re-entered. The credit card details are those necessary to process such a purchase through the international credit card networks such as Visa or MasterCard. Navio uses your credit card details to ensure against a fraudulent transaction.

Stored value: You may use a credit card or other method to buy credits which in turn may be used to purchase digital goods or services. We will not disclose the balances of such credits, and use this information solely to determine if you have a sufficient amount available to make such purchases.

Attestations: Navio uses your attestation that you are at least 13 years of age (or older in certain cases where jurisdictions or content owners require a specific minimum age for purchase, sharing or trading of content deemed mature or adult or activities of similar nature) as protection for Navio.

Navio uses your attestation of Terms of Use reading as protection for Navio in the event of disputes.

Digital items you collect or purchase: Anything you add to your AV Home digital portfolio is private to you. We maintain this so you can see it whenever you want. We do not analyze this information for purposes of creating promotions. We do not disclose this portfolio to third parties.

Contest / survey information: Navio may use this information to improve its site for the benefit of all users. In some cases, and only if you opt-in, this information will be shared with the contest or survey sponsor if that is a third party.

Communications from Navio:
Special Offers and Updates: You are automatically opted-out of any communications regarding special offers, advertising, and the like.

Newsletters: You are automatically opted-out of any Navio newsletter.

Service-related announcements: We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily unavailable due to maintenance, we might send you an email.

Customer service: Upon registration, we will send you a welcoming email. This email will contain instructions on activating your Navio Account for return visits. It is important that at registration that you provide a valid email address.

External uses
Disclosure to other Third Parties: Navio will not share any of your personally identifiable information with third parties except in the limited circumstances below, or with your express permission (and to other end users you choose to share with as described above). These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.

• Credit Card Details: Navio uses your credit card details to process any purchase through the international credit card networks such as Visa or MasterCard. Navio uses your credit card details to ensure against a fraudulent transaction.
• Investigations - Fraud: Navio will disclose information that we in good faith believe is appropriate to cooperate in investigations of fraudulent activity or activity in violation of our Terms of Use. Specifically, if we conduct a fraud investigation or conclude one has engaged in deceptive practices, and then we can share your contact information (but not your financial instruments) to victims who request it.
• Investigations - Legal: We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
• Agents/Legal Representatives: We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
• Contest / survey information: In some cases, and only if you opt-in, your email address and the survey/contest information will be shared with the third party contest or survey sponsor.
• Co-branded sites. Please see the section on Co-branded sites.

Co-Branded sites: Navio assists third parties ("Co-brand Partner") to offer their goods and services to end-users. This assistance may take the form of:

• A single co-branded web page containing an offer. The AV Home is used to enable the end-user's acquisition of the item(s) in the offer.
• A co-branded web-based redemption site or online store. The AV Home is used to enable the end-user's acquisition of any item(s) in the site's catalog.

Navio will not share any details about you or your digital items portfolio to the Co-brand Partner unless you opt-in.

If you opt-in, Navio will share at most to that Co-brand Partner your email address and whatever items you acquired from that Co-brand Partner's site. Items you have acquired from other sites will not be shared. Information about your payment mechanisms or digital cash/ cash equivalent balances will not be shared. The Co-brand Partner's Privacy Policy Statement should be read to understand how the Co-brand Partner uses the information Navio shares.

Information Security

The security of your personal information is important to us. When you enter sensitive information such as a credit card number or a password on any of our pages, that information is encrypted using Secure Socket Layer (SSL) technology.

Your credit card and bank account information are stored ONLY IN encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to our employees who need to know that information in order to provide the Navio service. Your credit card and bank account information cannot be displayed to our other employees.

We maintain physical, electronic, and procedural safeguards to guard your non-public information.

The security of your Navio Account also relies on you protecting your Navio password. You may not share this password with anyone. You should change it periodically. Navio will never ask to see your password in an email. You use your password only to access your Navio Account.

When you are finished using your Navio Account, be sure to log off. This is especially important when your computer is in a shared environment.

Business Transitions

In the event Navio goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified by email of any such change in ownership or control of your personal information.

Accessing and Changing Your Information

You can review your personal information in your Navio Account by logging into your AV Home and going to the Home Page.

You can change your email and password on the Settings page. You can change your payment mechanisms on the Wallet page.

You cannot close your account nor can you transfer unused monetary balances out of the system.

Wherever you have opted-in to some information or service, you always have the opportunity to opt-out.

Changes in This Privacy Statement

If we decide to change our privacy policy, we will post changes to this privacy statement on our websites and in such other places as we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, within the AV Home, or by means of a notice on our home page.

Contact Us

If you have any questions about this privacy statement or our privacy policy, please contact us by:

• Email at support@navio.com
• Write to Navio Systems, Inc / 20400 Stevens Creek Blvd. Suite 750 / Cupertino CA 95014 / Attention Privacy Officer