NAVEX Global Privacy Statement

Effective November 26, 2013

This privacy statement applies to navexglobal.com and NAVEX websites, services and products that collect data and display these terms. It does not apply to any NAVEX Global site, service or product that does not display or link to this statement or that contains its own privacy statement.

NAVEX Global, Inc. (“NAVEX Global”, formerly Global Compliance Services, Inc., EthicsPoint, Inc., ELT, Inc. and Policy Technologies International, Inc.) is committed to protecting your privacy in a variety of ways including using industry accepted security measures to protect against loss, misuse and alteration of data contained in our systems. This Privacy Policy is designed to describe how we secure and maintain our customers' and visitors' personal information when collected on sites which link to this Privacy Policy. Any information given to us will never be sold, rented, traded, shared or leased other than as outlined in this Policy.

NAVEX Global does not publish text, images, or multimedia content that portray nudity, foul language, violence or other information not suitable for children. Web sites maintained by NAVEX Global are not directed to children under the age of 13. NAVEX Global will not knowingly collect or maintain personally identifiable information from or about anyone under 13. NAVEX Global is committed to complying with privacy laws to which it is subject and adhering to the highest industry standards for privacy.

NAVEX Global is not responsible for content saved to any NAVEX Global system by Hotline/Ethicsline reporters or client company representatives.

Collection and Use of Information

NAVEX Global collects different kinds of information in order to provide you with the best products and services and to operate effectively. Some of this information is provided directly by you, while other information may be provided by your employer in connection with use of our products and services. We may also gather information by observing how you interact with our website, products and services.

What information we collect:

  • Registration: When you, or your organization, sign up to use our sites or services, or you sign up to attend a webinar or get additional information about our products and services, we may receive certain necessary information such as your name, job title and contact information such as email address, phone number and address.
  • Account/Report Access: To access some of our products and services you may be required to provide us specific information (such as your login credentials) that allows us to verify your identity before accessing certain data we host. This identity verification information is kept secure on our private servers and is only used to assist you in accessing your account or report; this information is not released outside of the relevant NAVEX Global system unless specifically authorized.
  • Hotline/EthicsLine Reporters: No personally identifying information is automatically collected from reporters using NAVEX Global applications. Personally identifying information, such as name and e-mail address, is stored only when a reporter voluntarily gives this information for use by a client company.

How we collect information:

NAVEX Global gathers information about how you use our sites and services in a number of ways, including:

  • Web forms, such as when you type information into a registration form
  • Technologies like cookies (please see Cookies for more information about this technology)
  • Web logging, which enables us to collect the standard information your browser sends to every web site you visit such as your IP address, browser type and language, and the site you came from as well as pages you visit and links you click on within our site

How we use Personal Information:

NAVEX Global uses the information we collect to operate and improve our products and services and to respond to requests about promotions or products and services offered.

Visitors:

When NAVEX Global collects personally identifiable information from visitors to our sites, the information collected from opt-in users is used only to respond to visitors' requests. In instances where opt-in participants' requests relate to NAVEX Global partners, we will provide personally identifiable information only to respond to that request. NAVEX Global does not sell, rent, lease, trade or share visitors' personally identifiable information other than as outlined in this Policy. When you provide us with your personally identifiable information or otherwise choose to sign up to receive email communications from us, we will use that information to send those communications to you. Individuals may "opt-in" and "opt-out" of receiving e-mail communications through selections available on e-mails received. For participants of our web seminars, the only personally identifiable information we share is web seminar registration information and it is only shared with our web seminar presenters to provide this service. They are not permitted to use this information for their own marketing purposes.

Licensed Users of Products and Services:

Personally identifiable information such as name, contact information, username and password is stored in our database for access to and use of certain software applications. This information is kept secure on our private servers and is only used to assist you in accessing your account. No information is released outside of the NAVEX Global system unless specifically authorized.

Hotline/EthicsLine Reporters:

No personally identifiable information is automatically collected from reporters submitting a case. Personally identifying information, such as name and e-mail address, is collected and stored only when a reporter voluntarily gives this information.

Use of Cookie, Clear Gif and Log File Technology:

A “cookie” is a small text file that is stored on a user’s computer.

NAVEX Global utilizes Cookie technology on our sites for purposes of Website traffic analysis such as the time/date of the visit, the time/date of last visit, the page viewed, the referring site, and other data. NAVEX Global also tracks click behavior in the e-mails it sends out. This data is used to update specific user-profile information, ascertain the areas of most interest to opt-in e-mail recipients, and to personalize e-mail messages to them.

We also use session ID cookies for access to products and services by our licensed users and reporters. These session Cookies are used to make it easier to navigate our site, products and services. A session ID Cookie expires when your browser is closed.

If you reject Cookies, you may still use portions of our site, but your ability to use some areas of our site, products or services, may be limited.

In limited circumstances, and with appropriate notice to licensed users, we will use persistent Cookies (Cookies that do not expire when your browser is closed). In these situations, licensed users are required to consent to the placement of a Cookie prior to it being activated and consent may be withdrawn at any time by simply accessing the form and un-ticking the box giving NAVEX Global permission to store the information. Any persistent Cookie that is unused for 30 days will automatically expire.

As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link automatically-collected data through the use of Cookies and log files to personally identifiable information.

We and our third party tracking-utility partners employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

Secure Communications

NAVEX Global will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

For licensed users and reporters, communications between the NAVEX Global site and a user's web browser are accomplished using, at a minimum, 128 bit SSL encryption and various third party security certificates to protect confidential data. NAVEX Global does not allow users to transfer or receive confidential information unless they are using a validated 128 bit (or greater) encrypted session.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our Web site, you can send e-mail us at itsecurity@navexglobal.com with "Questions about Web site Security" in the subject line. We do not link this automatically-collected data to personally identifiable information.

Automatic Information Storage

Session Variables may be used temporarily in your system cache to create ease-of-use during your transaction. Examples of such information are automatically-produced alphanumeric numbers held during your session on our site to facilitate page-to-page transactions. We only store name, e-mail, phone, address, company name or any other identifying information for licensed users; no information is stored for others unless otherwise stated in this policy.

Use of Third Party Services

NAVEX Global contracts with select third parties for Web-based services that include e-mail delivery and content streaming, that may collect non-personally identifiable visitor data including IP address and pages visited. These third parties may only use personally identifiable information, for example, e-mail addresses, for the service requested and not for their own marketing purposes.

NAVEX Global also contracts with select third parties in connection with the delivery of services to our clients. These third parties may not use any personally identifiable information other than to provide the specific contracted services.

Public Forums

Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at policyshare@navexglobal.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Links to Other Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of NAVEX Global. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Social Media Features and Widgets

Our Web site includes Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Terms

No company other than NAVEX Global is allowed to access information stored on our servers, unless expressly authorized by NAVEX Global. Unauthorized access to this information is a violation of the law. NAVEX Global has placed security measures and firewalls on all network servers in an attempt to prevent outside parties from accessing private information. In the event of a breach of security, NAVEX Global will press charges to the fullest extent possible against those parties illegally accessing information on our servers.

Safe Harbor

NAVEX Global complies with the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. NAVEX Global has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the NAVEX Global certification, please visit http://www.export.gov/safeharbor.

Access to Personal Information

Upon request by mail or e-mail (to the addresses noted below in the Contact Information section), NAVEX Global will grant individuals reasonable access to personal information that it holds about them, unless otherwise legally unable to do so. In addition, NAVEX Global will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. NAVEX Global shall provide a response to an access request within 30 days of receiving such request.

We will retain your information for as long as your account is active or as needed to provide services to your organization. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Disclosure Pursuant to Judicial or Government Subpoenas, Warrants or Orders

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on us.

Business Transfer

In the event NAVEX Global 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 via prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information

Breach of Privacy Policy

If you have received unwanted, unsolicited e-mail sent by NAVEX Global or from any NAVEX Global system or purporting to be sent via NAVEX Global, please forward a copy of that e-mail with your comments to info@navexglobal.com for review.

NAVEX Global has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program covers only information that is collected through the web sites which link to this policy and does not cover information collected in instances where NAVEX Global is operating as a data processor.

TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy Trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@navexglobal.com with “Privacy Enquiry” in the subject line. If you are not satisfied with our response you can contact TRUSTe here.

If you have any complaints regarding our compliance with Safe Harbor you should first contact us at privacy@navexglobal.com with “Complaint regarding Safe Harbor Compliance” in the subject line. If contacting us does not resolve your complaint, you may raise your complaint with TRUSTe by Internet at http://www.truste.org/consumers/watchdog_complaint.php, fax at 415-520-3414, or mail at Watchdog Complaints, TRUSTe, 685 Market Street, Suite 270, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: our name, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint to be shared with us. For information about TRUSTe or the operation of TRUSTe's dispute resolution process, see http://www.truste.org/consumers/watchdog_complaint.php or request this information from TRUSTe at any of the addresses listed above. The TRUSTe dispute resolution process shall be conducted in English.

Contact Information

Questions or comments regarding this Policy should be submitted to NAVEX Global by mail or e-mail as follows:

NAVEX Global, Inc.
Attention: Privacy Officer
6000 Meadows Road
Suite 200
Lake Oswego, OR 97035
USA
privacy@navexglobal.com

Changes To This Privacy Policy

Any updates or changes to our privacy statement will be posted to this privacy statement, the home page, and other places 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 e-mail, or by means of a notice on our home page.