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PRIVACY POLICY
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1. Responsibility for Data Processing

The Site is owned and operated by Navigant. You can contact the operator of the Site if you have any questions.

2. Data Protection Officer

The Global Chief Privacy Officer of Navigant is Dawn Cassie. For Europe, Middle East and Asia, the Data Protection Officer is Sandra Nguema. You can contact them at privacy@navigant.com if you have any questions.

When do we ask for your consent?

When you use the Site, you acknowledge that we are processing your Personal Data in accordance with this Privacy Policy. If you do not wish that we process your Personal Data in this way, please do not use our Site or otherwise provide our Site with your Personal Data. For prospective clients we only collect name and contact information, from clients we collect personal data, which may include sensitive in-formation only when this is necessary to provide the service. For website and social media users, we collect the domain name, IP address, browser type and version, operating system and platform, average time spent on our website, pages viewed, information searched for, access times and other relevant statistics.

We process your data to provide you the Site services. In certain instances, we only process your data if you have consented, for example in certain cases where we process your Personal Data for marketing purposes or where we use cookies. Where we process your data on the basis of your consent, we will ask for your consent in a transparent manner. We may also ask you to provide additional consent if we need to use your Personal Data for purposes not covered by this Global Online Privacy Policy or before sharing your Personal Data with third parties.

3. Purpose and Type of Data

(a)  Browsing, Registration and Account Information: You can browse the Site without telling us who you are or inputting any personal information (i.e., name, email address, phone number, fax number, mobile telephone number and physical contact information) about yourself. If you register for an account with us, you choose to give us your above listed personal information and are not anonymous to us. When you register an account, create a profile, purchase products or services, or otherwise engage with our Site, you may provide personal information. Personal information is only associated with your account/profile when you sign in as a registered user. You may also provide non-personal information such as your company name or business address.

We will process the Personal Data we obtain from you in context of your registration only for the purpose of administering your registration and offering you the related services.

The legal basis for such processing is performance of the agreement with you.

(b)  Career Information: The “Careers” sections of the Site give you the opportunity to register to apply for jobs. To apply for a position, you will need to establish a “Profile.” In order to do so, you will provide us with your email address, username, password, first and last name, physical address, phone number, career data (e.g., desired pay). You may also provide other information about you (such as your gender, ethnicity, Veteran, or disability status). Navigant is an equal opportunity employer. Your username and password will allow you to access your account later. Also, when you apply for a job or authorize us – through a separate consent – to obtain a consumer report (e.g., background check), we will collect personal and non-personal information (e.g., name, address, telephone number, resume, employment history, reference information, salary expectations, education, social security number and so on). When you apply for a position you may also provide the names, email addresses and phone numbers of third party references. You represent that you have obtained permission from your references to provide us with their personal information.

Visit our Career Submission Terms for more information regarding the types of career information we collect and how we treat it.

We will process the Personal Data we obtain from you in context of your application only for the purpose of administering your application.

The legal basis for such processing is performance of the agreement/steps prior to entering into an agreement (i.e. process your application) with you.

(c)  Information to respond to your requests: You may give us your personal information so we can send you information as requested – e.g., newsletters, publications, market research reports, surveys to understand your interests and other communications you request. Details of how you can opt-out of receiving any communications from us are detailed in the section headed “Your Choices” below.

We will process the Personal Data we obtain from you in context of your request only for the purpose of administering and providing the information you request.

The legal basis for such processing is – depending on your request – either your consent or performance of the agreement (i.e. process your request) with you.

(d)  Information from Other Sources: The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, additional contact in-formation) that we have acquired in accordance with the law. These sources include social media sites, company websites and subscription-based third party databases. For example, if you work at a law firm but we don’t know your title, we may go to the firm’s website or a social media site to confirm your title.

We will process the Personal Data we collected only for the main purpose that serves us to process the data we obtained earlier directly from you.

The legal basis for such processing is – depending on the situation – either consent, performance of the agreement (i.e. process your request) with you or balancing of interest. Where we base our processing on balancing of interests, our main interests pursued are to provide you a better and more tailored service by adding information that is publicly available anyway.

(e)  Mobile Information: We may collect additional basic information from you if you access our Site through a mobile device (e.g. your device’s operating system, unique device identifier, and country or state of location) to better serve your needs and optimize the services for you. Please also see the section on Tracking Technologies (Section 7 below) for further details.

(f)  Technical Usage Information: When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site such as the browser type, IP address, user language, the operating system, the presence/absence of “flash” plug-ins, screen resolution, connection type, and information that identifies the cookie, the pages you view and the length of your visit to the Site (“usage information”). We use tracking technologies (including cookies, flash cookies, web beacons/GIFs, embedded scripts, e-tags/cache browsers) to collect usage information.

We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.

Our goal is to collect and use only that information that we think is required, in order to better understand your interests and improve your experience of using the Site. To learn more about how we use tracking technologies and cookies, and your ability to consent to such usage, see Section 7 of this Privacy Policy and click here.

4. Retention of Data

We will delete or block your Personal Data, once we do not need it any longer for any of the above purposes for which we have collected or received the information, unless we are required by law to retain your personal information, or unless we need to retain your personal information in order to continue providing a service. You consent to our retention of your video viewing tracking data for as long as permissible under applicable law – up to twenty-six months after your last visit to the Site. For browsing we keep data for twenty-six months, for career information up to five years, mobile information will be kept for maximum twenty-six months – unless you request that we delete your information sooner. These storage terms apply unless agreed otherwise in a contract with Client or in locally applicable legislation.

5. Who Receives Your Data

Information collected on the Site may be shared with:

(a)  The Navigant Corporate Family as Controllers. We may share the information we collect about you with the Navigant corporate family and their and our affiliates and subsidiaries, as well as with third-party suppliers. The information may be disclosed (i) to provide joint content and our services (e.g., registration, transactions, analytics and customer support); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our Navigant products, Site, applications, services, tools, and communications. Members of our corporate family will use this information to send you marketing communications and you will have the opportunity to opt-out in email communications. We will only transfer your Personal Data to any third-party suppliers if and to the extent we are permitted to do so by law or if you have provided your prior consent.

(b)  Service Providers and Other Third Parties. We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, software development, email delivery, marketing communications, bill collection, payment processing, and site analytics and operations).

(c) Other Entities with your Consent. Other third parties to whom you explicitly ask us to send your Personal Data (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Site, you may have opportunities to express interest in or register for other services. If you do, we will provide your Personal Data to those third parties, or parties working on their behalf, to implement your request. When you interact with our Site through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.

(d) Legal. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to comply with such legal process, or to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We will inform you separately of any such transfer either before the transfer or at the latest after there is no risk of impairment of the purpose of the planned transfer.

(e) Change of Control: New Owners. We may share your information with other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this policy, we will request that the new owner provide you with prior notice. We will in-form you separately of any such transfer and ask your for your consent (if required) either before the transfer or at the latest after there is no risk of impairment of the purpose of the planned transfer.

6. Your Choices

You can control how and when you want to receive notifications regarding electronic newsletters and marketing-related emails for services described on the Site by contacting us at yourchoices@navigant.com or by following the “unsubscribe” instructions within the notices.

For navigantresearch.com, go to https://www.navigantresearch.com/contact-us to update or change your preferences regarding notifications or electronics newsletter, or follow the “unsubscribe” instructions within the notices.

7. Tracking Technologies (Cookies)

When you visit the Site, we and our business partners may use tracking technologies to enhance your online experience or customize our offerings.

A few additional important things you should know about our use of tracking technologies (cookies):

  • We offer certain features that are available only through the use of tracking technologies.
  • We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
  • We use tracking technologies with your prior consent as obtained through your continued use of this Site.
  • You may encounter tracking technologies/cookies from our third party service providers, that we have allowed on our site that assist us with various aspects of our web site operations and services, such as Google Analytics.
  • You also may encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page posted as a link from our Site, there may be a cookie placed by that web page).
  • We may target and track the videos you view on the Site. You consent to our tracking of your video viewing through the Site or third party social media for up to two years or as permitted by applicable law, unless you notify us through the channels in Section 5 (Your Choices) or Section 16 (Contact Us).

For more information about the use of cookies and similar technology on our Site please review this Privacy Policy and our Cookies and Tracking Technologies Policy.

8. European Residents

Notice to EEA Residents.

If you are located in the European Economic Area and you interact with our Site or provide Navigant Personal Data over the Site then your Personal Data may be transferred to the United States. If you create an account/profile, you consent to the collection and/or processing in the United States of your personal information and tracking technologies/cookies as described in this Policy. Be informed that the US is not in the list of countries that the European Commission considers adequate to the protection of Personal Data. However, we provide appropriate safeguards for your data in the US as we elected to self-certify under the EU-US Privacy Shield and the Swiss-US Privacy Shield. If data is processed in the European Economic Area, you may be entitled to request information from us regarding your Personal Data stored by us and to have your Personal Data corrected, deleted or blocked by us in accordance with applicable laws. Please contact us by using the contact information as set out in Section 14 of this Privacy Policy below.

If you reside or otherwise find yourself in the territory of Europe, Navigant is committed to facilitate the exercise of your rights granted by the European data protection laws. Otherwise you can contact us at any time to discuss your privacy concerns.

Privacy rights under European data protection laws:

Transparency and the right to information: we provide notice to our employees, customers, suppliers, vendors and others of how we use Personal Data in our day-to-day operations at the time of collecting Personal Data, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.

Right to access, rectification, restriction of processing, and erasure: we provide data subjects with access to their own personal data where required by applicable law. In addition, we will rectify their Personal Data when we are notified that it is inaccurate, and we will ensure the right to erasure and to restriction of processing when these rights are not compatible with local regulations.

Right to object and withdraw consent at any time: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities will be balanced in order to ensure that it is not incompatible with local regulations or the legitimate interests of Navigant.

Right to data portability: based on your specific situation, we provide data subjects with the right to obtain and reuse your data across different services and includes transferring of your data to you, another controller or a trusted third party.

Right to lodge a complaint with a supervisory authority

These requests should be submitted as follows:

  • Opt-out of marketing communications: you can opt-out anytime by following the opt-out instructions in our commercial e-mails
  • To exercise the rest of your rights: you should send a communication in writing to privacy@navigant.com. Navigant will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.
  • Right to lodge a complaint with a supervisory authority: you can have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of the alleged infringement.

9. Californian and Canadian Residents

(a) How Do We Respond to Do Not Track Signals for California Residents

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Navigant responds to “Do Not Track” browser settings. Navigant does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

(b) Notice to Canadian residents

This policy considers the principles of accountability, identifying purposes, consent, limiting use and disclosures, openness and safeguards established by the Canadian Privacy regulation (PIPEDA). However, there are other principles that we also guarantee for the Canadian residents such as the principle of limiting collection, retention, accuracy, and individual access and rectification.

  • Limiting collection: we limit the amount and type of the information gathered to what is necessary for the identified purposes.
  • Retention: we keep personal data only as long as necessary to satisfy the purposes for which it was collected. When information is no longer required for an identified purpose or a legal requirement we destroy, erase or render anonymous the information.
  • Accuracy and right to correct: we keep your personal data as accurate, complete and up to date as necessary, taking into account its use and your interests. We also provide you to request correction to your personal data if its inaccurate or incomplete.
  • Right of access: we will make available to you any personal information of yours that we have collected, used or disclosed upon request, to the extent permitted by law. To exercise your request please write us at privacy@navigant.com and provide sufficient data for your identification. The access request does not usually have any cost, in cases it has it we will provide you an estimate beforehand.

If you have questions or concerns about this policy, please contact us at privacy@navigant.com. We will respond to any request as soon as possible, or in any case not later than 30 days after receipt of the request. If you are not satisfied with our response, you have the right to make a complaint to the Federal Privacy Commissioner.

10. Third Parties

Our Site may contain links to other third party websites. We are not responsible for the privacy practices or the content of these third party sites.

11. Security

Navigant is committed to the security, confidentiality and integrity principle. We take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access and use and we periodically review our security measures. We are committed to processing your data in a secure manner and have put in place specific technical and organizational measures to prevent the personal data we hold from being accidentally or deliberately compromised. We store and process your information on our servers located in the United States and around the world. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal in-formation is accurate.

12. Children's Privacy

Our services are not directed to children. We do not knowingly collect personal data from children. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, please contact us. If we become aware that a child has registered for a service and has provided us with personal data, we will delete such information from our files.

13. Notification Regarding Updates

From time to time, we may update this Global Online Privacy Policy. If we make any material changes to how we treat personal data we will notify you by placing a notice on the Site, prior to the change becoming effective. You should check the Site frequently for updates.

14. Contact Us

If your questions are not answered online, you may email us at privacy@navigant.com or write to us at Navigant: 150 N. Riverside Plaza, Suite 2100 Chicago, IL 60606, U.S., or by using the contact of the operator of the Site.

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