Thank you for visiting a Navigant offering. Navigant Consulting, Inc., with headquarters located at 150 N. River-side Plaza, Suite 2100, Chicago, IL 60606, USA, (“Navigant,” “we” or “us”) takes the protection of your Personal Data in connection with your use of our navigant.com website and our other related websites, as well as mobile websites and mobile Navigant applications (“Mobile Apps”), services, tools, and other applications (collectively, the “Site”) very seriously. The categories of the Personal Data collected from you depend on how you use the Site. “Personal Data” as used herein is all information that can directly or indirectly identify you or other individuals.
2. Who is responsible for data processing on the Site?
The Site is owned and operated by Navigant. You can contact the operator of the Site if you have any questions.
3. Who is the 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 email@example.com if you have any questions.
When do we ask for your consent?
4. Who is responsible for data processing on the Site?
(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.
5. How long do we process and keep your Personal 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.
6. Who is receiving our Personal 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).
(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.
7. Newsletters and Marketing: 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 firstname.lastname@example.org or by following the “unsubscribe” instructions within the notices.
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).
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 email@example.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.
Accountability and enforcement
Navigant is responsible for the processing of personal data it receives under the Privacy Shield Frame-works and subsequently transfers to a third party acting as an agent on its behalf. Navigant complies with the Privacy Shield Principles for all onward transfers of personal data from the EU or Switzerland, including the onward transfer liability provisions.
In compliance with the Privacy Shield Principles, Navigant commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Navigant (contact info can be found in clause 14). Navigant has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution - American Arbitration Association (ICDR-AAA), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Navigant is subject to the investigatory and enforcement powers of the Federal Trade Commission. We will comply with lawful requests by public authorities to disclose personal information, including to meet national security or law enforcement requirements.
10. 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 firstname.lastname@example.org 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 email@example.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.
11. 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.
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.
13. 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.
14. Notification Regarding Updates
15. Contact Us
If your questions are not answered online, you may email us at firstname.lastname@example.org 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.