INFORMATION PURSUANT TO ART. 13 OF THE EU REGULATION N. 679/2016 (“GDPR”)
This Policy explains which of your personal data are collected by Navionics s.r.l. a socio unico (hereinafter “we” or "Navionics"), for which purposes and how they are processed. You can also find below the necessary information to enforce your rights provided for by GDPR.
Generally, we collect your personal data if you create an account, when you use our services and products, when you email or call us or send us a message, when you use our websites, apps and social media. We inform you that the personal data collected during such processes will be used in order to reply to your queries, to allow you to use the services and products provided by Navionics, to carry out marketing activities, to provide customer support and to carry out analyses in order to ensure you have a customized user experience on the website and the app, as specified below.
Navionics s.r.l. a socio unico, with registered office in Milan, Corso Magenta, 43 – 20123 – Italy and offices in Via Fondacci, 269, Z.I. Montramito - 55054 Massarosa Italy, is the Data Controller of the processing of your personal data, necessary to provide you with the services and products of Navionics and, upon your consent, for marketing purposes, consistently with the purposes and modalities indicated below.
For the purpose of creating your Navionics account and providing you the Navionics services you have requested, as well as giving you customer assistance, we process your personal data such as name (or nickname), email address, telephone number and, when you wish to purchase our products or services, your credit card and billing information.
Also to allow you to use Navionics’ services and products, we process information on your location and that of your device.
To allow you to share the information you decide to disclose to the users of Navionics’ services, we will use data relating to your location and the personal information that you will decide to post using certain features which will be activated exclusively upon your request.
In order to send you commercial information about our products and services and to submit proposals tailored to your tastes, we may use your email address, your name and some browsing data, provided you have previously authorized such processing.
Directly from you. For example, if you download the app, if you create an account, or if you send us a query via email or through other communication means. If you do not communicate your data we may not activate your account or we may provide you with a very limited service. In all cases under section 4 where it is stated that the processing of your data is optional, revocable or that it can be activated upon your request, the failure to communicate your data does not affect your use of Navionics’ services.
From third parties. Your activities on our websites and apps may be posted on the social media platforms you have an account on (and of which you have accepted the terms and conditions, including those relating to the use of your data).
To provide you with Navionics’ services and products, through our apps and our websites, to give you information and assistance for the activation of your account and on Navionics’ services. The processing of your data is necessary to give you access to the apps and the websites of Navionics and their functionalities, to respond to your requests and to assist you when you use our products and services.
During your use of our products we may collect information about your location, such as IP address, GPS location or other information sent from your plotter or your mobile device on which one of our Apps is installed. This information is mandatory so that we can provide you with our services, such as the indication of the shortest route, the reporting of obstacles, the synchronization of your data with other devices. Failure to provide such information may entail the impossibility to access our services. The information on your location will be collected only upon your authorization, which you will provide to us by authorizing the use of the GPS location at the moment of the activation request. If instead you will not authorize the use of the GPS location, our App will not have access to information related to your location and will not be able to operate with all its functionalities. At any time you can choose to enable or disable the collection of this information through the settings provided by your device and in the settings of the app.
The legal basis of this processing is the performance of the services you have requested, in accordance with the terms and conditions of Navionics’ service that you have accepted, and the fulfilment of pre-contractual measures that you may have requested. The retention period of your data is equal to the period of activity of your account for the use of Navionics’ services according to the terms and conditions of use that you accepted. The deletion of your account can occur either by your express request or after 24 months (i) from your last activity on the app or (ii) from the expiration of the service you had previously purchased (usually you use our services in a specific season and we believe that you do not intend to use these services anymore if for two seasons we do not detect any activity on your account).
To allow you to interact with other users. Through the "Community Edits" function, which is activated only upon your request, you can leave comments or other information on your experiences which can be viewed by other users. The legal basis of this processing is the user's consent. The retention period of your data is equal to the period of activity of your account for the use of Navionics’ services, according to the terms and conditions of use that you have accepted. The retention period of your data is equal to the period of activity of your account for the use of Navionics’ services according to the terms and conditions of use that you accepted.
If you are using an old version of the app we recommend you download and use our new app. If you don’t want – or simply can’t – download the new version of the app, to disable “Community Edits” send an email to firstname.lastname@example.org
To send you communications in connection with your purchase order. We may send you emails (or other types of messages, such as in-app messages) regarding your account or your purchase of Navionics products and services. The legal basis of this processing is the performance of the agreement you become a party of when you accept the terms and conditions of Navionics’ service and the fulfilment of pre-contractual measures that you may have requested. The retention period of your data is equal to the period required to process the purchase order and, if you have also an account, to the period of activity of your account for the use of Navionics services, according to the terms and conditions of use that you have accepted.
To properly manage your customer account. We process your data for accounting, administrative and tax purposes, directly related to the business of Navionics as required by the applicable legislation. The legal basis of this processing is the compliance with legal, statutory, obligations and the retention period is equal to that required by law (in particular by tax, anti-money laundering, banking and public security law). For internal administrative purposes, we may also share your data within the Navionics companies group, located abroad, in compliance with the principles set by the GDPR for the transfer of personal data to companies located in a third country (in particular, we could communicate your data to mother companies or Navionics affiliated operating in the United States and which have entered into with Navionics standard data protection clauses approved by the European Commission). The legal basis of such processing is the legitimate interest of Navionics in pursuing its corporate organizational purposes recognised by law. The retention period, where it is not required by law for a longer period (see the previous paragraph), is equal to the duration of your contractual relationship with Navionics (therefore to the activity of your account (see above on the deletion of the account), to the processing of the purchase order or to the provision of assistance and statutory warranty).
(of which you find the details above).
To let you interact with customer care operators. We may use your e-mail address or telephone number, as well as the name and/or postal address, to assist you in case you need help using the app or in general for the use of Navionics’ products and services. Also to provide you customer assistance, we may communicate your data to Navionics’ parent companies or affiliated companies operating in the United States and which have entered into with Navionics standard data protection clauses approved by the European Commission. The legal basis of this processing is the performance of the agreement which you have entered into with Navionics when you have accepted the terms and conditions of use of Navionics’ services and the compliance with the legal obligations regarding statutory due warranties and assistance to the consumer.
We might also collect information regarding customer assistance or issues occurred to our service. To improve quality of customer care services, subject to applicable legislations, Navionics may also record and listen conversations with customer care operators. The legal basis of this processing is the legitimate interest of Navionics to improve the quality of the services provided to its customers. In addition, Navionics might analyze any feedbacks provided voluntarily through surveys submitted to the client. The legal basis of this processing is the consent of the data subject.
In all the above-mentioned cases, the retention period of the data is equal to the period of activity of your account.
To improve the quality of our cartography and services. The data of users concerning the navigation, after being anonymized, can also be used to process information, including statistics, necessary to improve or correct our maps and services, thus contributing to the safety of navigation and quality of our products. The legal basis of the processing necessary to anonymize the data is the legitimate interest of Navionics in the quality and safety of its products and services provided to users.
To monitor and improve our products, services and websites. With your consent, we analyse your data to improve our approach towards you and our customers in general, through automated processings, including profiling. We do this so that we can make better decisions related to services, advertising, products and content based on greater awareness of how our customers use our services and to ensure you a customized user experience. For such purpose we may also collect the advertising identifier of your mobile device (IDFA - Identifier for Advertising - for iOS devices and ADID - Google Advertising ID - for Android devices) to enable us to always provide you with targeted and accurate ads based on your preferences and your interests. The legal basis for this processing is your consent. This consent can be revoked at any time by sending a request to email@example.com. This data will be retained as long as your account is active.
To prevent or assess unlawful conduct, to protect and enforce our rights. For example, we may use your data to prevent or prosecute torts and infringements, including of our - and third parties’ - intellectual/industrial property rights, or to prevent or prosecute cybercrimes or crimes committed through the internet. The legal basis of such processing is the legitimate interest of Navionics to protect its rights and to prevent criminal offences. The retention period of your data is equal to the time reasonably necessary to enforce our rights from the moment we become aware of the offence or of its potential commission.
To obtain information on the use of the website. When you browse our website, even when you do so without being registered or having logged in, the software procedures and the computer system controlling the functioning of the web applications acquire, during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects, but due to their very nature they could, through processing and associations with data held by the Data Controller or by third parties, allow users to be identified.
In case of unregistered users, geographical location data will only be used in an anonymous form that does not in any way allow, even in combination with the Unique Device Identifier (UDID), the MAC address, the IMEI or IMSI codes or other customer codes, to trace, directly or indirectly to your identity. In any case, unregistered users who do not intend or cannot download the new app and who in any case do not read this Policy and do not express preferences on the processing of their data, will no longer be subject to the processing of personal data.
This category of data includes IP addresses or domain names of the devices used by users connecting to the application or to the websites, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code given by the server indicating the status of the response (successful, error, etc.), the visited sections of the website, the type of device used, the country from which you connect and other parameters related to the operating system and the user's computer environment. Navionics uses this information solely to allow navigation on its websites and to process the operations normally related to the use of the website and of the apps in connection to customer care activities. The legal basis of this processing is the legitimate interest of Navionics to communicate with the public through telematic networks and to assist its own customers in order to improve products and services. The retention period of the information that could potentially allow the identification is 30 days from access to the website.
To obtain information on the use of the app. We may collect data relating the type of device that you are using, or the operating System version of your computer or device. We may also analyse how often you use the app and from where you downloaded it.
You can express your preferences on the methods through which we use data on mobile devices through the privacy settings page of your Navionics apps.
For these purposes we use third parties’ tools
Third party’s tool
Crashlytics - Firebase
Data collection for the analysis of abnormal events (e.g. crash) in order to improve the quality of the product and solve any problems.
Identification data of the mobile device on which the abnormal event occurred.
You can disable this feature via the privacy settings page of your Navionics apps.
Among these tools there are some that we use to handle technical problems in the app, whose resolution requires the use and sharing of the identification data of the mobile device with our service providers. This function will only use your data if you have spontaneously activated and authorized it.
The legal basis of the processing is the legitimate interest of Navionics to improve the quality of the services offered to its users and the security of its application. The retention period of the information used for this purpose is 3 months from the moment of collection.
In relation to the aforementioned purposes, the processing of personal data takes place using manual, IT and telematic tools with logics strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the same data in compliance with the law.
We collect data from users about their usage of our apps. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions.
Navionics uses this data to improve the quality and functionality of our apps; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.
Google Analytics for Firebase is used on our mobile apps to better understand usage of our apps, to improve user experience, and to track migration of users to new versions of the apps. You can find out more information about how this analytics information may be used, how to control the use of your information, and how to opt-out of having your data used by Google Analytics by clicking here.
The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our apps so we can enhance the user experience and functionality of our apps.
What are cookies. Cookies are small text files that the websites visited by users send to their terminals, where they are stored before being re-transmitted to the same websites during subsequent visits.
Cookies used by Navionics’ website and their purpose.
The first time you will visit the website, you will be asked to accept cookies through a banner. You can also access all the information useful to accept or not accept all or some functional, analytical and profiling cookies.
You can change, even later, the settings of your computer so as to know when you receive cookies or to disable the automatic acceptance of cookies function.
The website uses the following cookies categories:
• Technical cookies (or browsing cookies), which contribute to the functioning of the website, for example to allow to browse through the pages and access the reserved area of the website; the legal basis of the processing underlying the use of these cookies is Navionics’ legitimate interest in providing efficient and well-functioning services to its customers; the retention period of these cookies starts from the date of the first access to the website until they are disabled.
• Functional cookies, which allow to activate specific functionalities of the website and store your preferences (such as the language), in order to improve your browsing experience; the legal basis of the processing underlying the use of these cookies is Navionics legitimate interest in providing efficient and well-functioning services to its customers; the retention period of these cookies starts from the date they are enabled to the website until they are disabled. The user can accept and disable these cookies at any time by using www.navionics.com/legal/cookie-policy.
• Analytical cookies, which allow the acquisition of statistical information in aggregate and anonymous form, in relation to the navigation modalities; the legal basis of the processing underlying these cookies is Navionics’ legitimate interest in providing efficient and well-functioning services to its customers; the retention period of these cookies starts from the date they are enabled to the website until they are disabled. The user can accept and disable these cookies at any time by using www.navionics.com/legal/cookie-policy.
• Profiling cookies, which allow us to customise advertising messages according to your interests and your preferences, in order to only send you advertisements that you may consider relevant or interesting. The legal basis of the processing underlying the use of these cookies is the consent of the data subject; the retention period of these cookies starts from the date they are enabled to the website until they are disabled, and in any case no more than 12 months. The user can accept and disable these cookies at any time by using www.navionics.com/legal/cookie-policy.
The data will be processed and stored at our offices in Via Fondacci, 269, Z.I. Montramito - 55054 Massarosa (LU) Italy.
As anticipated, for internal administrative and organizational purposes and to provide you with customer assistance, we may communicate your data to companies belonging to the Navionics’ group, operating in the United States and which have entered into with Navionics standard data protection clauses approved by the European Commission.
Your data may also be stored in the USA by Navionics’ suppliers to whom the data are transmitted on the basis of standard data protection clauses in accordance with the decision of the European Commission concerning the standard contractual clauses for the transfer of personal data and/or in accordance with an adequacy decision of the European Commission on the level of data protection (Privacy Shield). The updated list of third party suppliers, operating as data processors pursuant to art. 28 GDPR, is available by sending a request to firstname.lastname@example.org.
With other Navionics’ users. If you activate the "Community Edits" function you can interact with other users, to whom the objects (POI) which you will insert or modify, your comments, your nickname, and the other information that you want to share will be visible. By default this feature does not reveal your nickname to other users, until you decide to make your nickname visible. After you have done so, you can always change your mind and restore the "private" mode, which will make the shared POIs from that moment onwards no longer connectable to your identity.
With service providers. Navionics uses third-party services (cloud, analysis, profiling, messaging, app and website browsing functionalities and components of Navionics’ products and services) that operate as data processors pursuant to agreements in compliance with art. 28 GDPR and in accordance with the provisions relating to the transfer of data to third countries, where such data are actually transferred. These subjects acquire only the personal data necessary to fulfil their functions and may use them only for the purpose of performing these services on our behalf or to comply with the law. The updated list of third-party suppliers, operating as data processors pursuant to art. 28 GDPR, is available by sending a request to email@example.com.
With other companies belonging to the Navionics’ or Garmin Group. Your data may be shared with other companies belonging to Navionics’ or Garmin group either for internal administrative and organizational purposes or to provide you with the services you have requested or with customer assistance. Up-to-date data on Navionics companies recipients of your data are available by sending a request to firstname.lastname@example.org.
With judicial or administrative authorities. Where we believe we have to do so to comply with an order from the judge or from an authority, or to comply with legal obligations or in order to protect us or third parties judicially, we may disclose your data to the Judicial Authority or to a Governmental Agency in Italy or the European Union.
The websites, the app and Navionics’ services and products in general are not intended for minors under the age of 16, who shall not therefore provide personal data to Navionics. In the event that Navionics becomes aware that it has collected personal data from users under the age of 16, it will take the necessary steps to delete such information as soon as possible.
In addition to managing your preferences on processing of your personal data in accordance with the previous paragraphs, you can contact Navionics to request access to your personal data, rectification, erasure of the same or restriction of the processing, to object to the processing and ask for the portability or the copy of your data; you can also revoke the consent at any time (this will not affect the lawfulness of the processing based on the consent given before the revocation).
When you exercise the right of access, you have the right to know if the processing of your data is underway, what the purpose of the processing is, what are the categories of processed data, who are the recipients or categories of recipients to whom your data are communicated (and, if they reside in a third country, what are the conditions and safeguards for transfers), the retention period of your data (or the criteria for determining the retention period), if an automated processing is underway (e.g. by profiling) and what is the logic of such processing, the origin of the data (if not collected initially by us).
You have the right to lodge a complaint with the Authority for the Protection of Personal Data and to ask to the data controllers, at any time, information about the data processors and the persons authorized by the data controllers to process your data.
You can exercise your rights by contacting Navionics via email at email@example.com or by writing to the address indicated above.
You can contact Navionics’ Data Protection Officer (“DPO”) by sending an email to firstname.lastname@example.org or by writing at the above Navionic postal address.
Updated on May 30, 2019