Last Updated August 24, 2023
The following chart details which categories of Personal Information we collect and process, as well as which categories of Personal Information we disclose to third parties for our operational business purposes, including within the preceding 12 months. The chart also details the categories of Personal Information that we “sell” to third parties or “share” for purposes of cross-context behavioral or targeted advertising, including within the preceding 12 months.
Categories of Personal Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes | Sold to Which Categories of Third Parties | Shared with Which Categories of Third Parties for Cross-Context Behavioral or Targeted Advertising |
|---|---|---|---|
Identifiers, such as name, contact information, unique personal identifiers, IP address, and government-issued identifiers | Other Navan entities; our service providers; our business partners and providers of travel services | Website Analytics Providers to improve Navan’s website | Website Analytics Providers to improve Navan’s website |
Personal information as defined in the California customer records law, such as name and contact information | Other Navan entities; our service providers; our business partners and providers of travel services | None | None |
Commercial Information, such as transaction information and purchase history | Other Navan entities; our service providers; our business partners | None | None |
Internet or network activity information, such as browsing history, search history and interactions with our online properties | Other Navan entities; our service providers; our business partners | Website Analytics Providers to improve Navan’s website; interest-based advertising | Website Analytics Providers to improve Navan’s website; interest-based advertising |
Geolocation Data, such as approximate location derived from IP address | Other Navan entities; our service providers; our business partners | None | None |
Audio/Video Data. Audio, electronic, visual, and similar information, such as call recordings | Other Navan entities; our service providers | None | None |
For a more detailed explanation of the Personal Information we have collected about you, including the sources of Personal Information, please refer to “Information You Provide to Us,” “Information Automatically Collected,” and “Information From Third Parties” sections in Navan Privacy Policy. For information on our retention of Personal Information, please refer to the “Security and Retention.”
For a detailed explanation of the purposes for which we use and disclose Personal Information, please refer to “How We Use Personal Information” and the “How We Disclose Personal Information” section(s) above. Subject to applicable law and your residency, you may make the following individual requests:
If you are a California resident, you may request that we disclose to you the following information: (i) the categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information; (ii) the categories of Personal Information about you that we sold or “shared” (as defined under California law) and the categories of third parties to whom we sold or “shared” such Personal Information; (iii) the business or commercial purpose for collecting, “sharing,” or selling Personal Information about you; and (iv) the categories of Personal Information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Information.
Navan may collect personal information that may be considered “sensitive” such as passport numbers and covid health data, which are optional fields. Navan does not use passport number and covid health data for the purpose of inferring characteristics about a consumer. You may opt-out of providing these fields at any time by deleting these fields in the Navan app.
Certain U.S. state privacy laws define a “sale” as disclosing Personal Information in exchange for “monetary or other valuable consideration.” Although some of the ways in which we share Personal Information may technically be considered a “sale” under these laws, we do not sell your Personal Information for money. Additionally, you may opt-out of targeted advertising, including the “sharing” of your Personal Information for purposes of cross-context behavioral advertising. We use third-party technologies such as cookies to display personalized content, which may be considered a “sale” or “sharing” under these laws. You may opt-out of these third-party technologies by clicking on the “Your Privacy Choices'' in the footer of our website.
In addition, you may also opt-out of any “sales” or “sharing” for purposes of cross-context behavioral or targeted advertising by broadcasting the Global Privacy Control signal on a browser/extension that supports it. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/. We do not knowingly “sell” the Personal Information of minors under 16 years of age.
Residents of California, Colorado, Connecticut, Utah, and Virginia or their authorized agents may make a data subject request by contacting us at privacy@navan.com. We will verify and respond consistent with applicable law, taking into account the information associated with your account, including email address. As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.
If you are a Colorado, Virginia, or Connecticut consumer, and we refuse to act on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at privacy@navan.com.
If you are a resident of California, under 18, and have an Account on our Services, you may ask us to remove content or information that you have posted to our Services by writing to privacy@navan.com. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.
The California Consumer Privacy Act (the “CCPA”) defines a “financial incentive” as a program, benefit, or other offering “for the collection, retention, or sharing of personal information.” Navan may offer our customers opportunities to participate in surveys or promotions. In exchange for participation you may be offered a financial incentive, such as a discount or a monetary prize.
As part of these promotions or surveys we may collect Personal Information, such as your name, email, job role, preferences, experiences, opinions, and other responses to survey questions. You may opt-in to these programs by participating in the survey or promotion. The applicable terms and conditions for the program will describe any financial incentives and how to participate. You can terminate participation at any time by emailing rewards-feedback@navan.com. Our good-faith estimate of the value of your Personal Information is the value of the improvements we are able to make to our services as a result of the information. We have calculated this value by using the expense related to the benefit.
Navan also offers rewards programs related to personal travel (Rewards Program). For rewards members, the types of personal information that we collect from Rewards Program members are generally similar to the types of personal information that we collect from individuals who are not members. Navan uses the Personal Information of members, including their travel details, to both award and redeem points.
Solely for the purposes of the CCPA, we estimate the value of a member’s personal information to Navan to be reasonably related to the value of the benefits members obtain through participating in the Rewards Program. We have based this good faith estimate by calculating the amount of travel bookings likely to be made through the Navan application as a result of rewards incentives, less the expenses associated with the program.
For individual travelers, you can opt-in to this program when you create an account or by navigating to the “Rewards” section in your profile. For travelers associated with a company account, you can opt-in by booking personal travel using Reward Points as payment. You may withdraw from this program at any time by navigating to the Loyalty Program page and click “leave loyalty club.”
We reserve the right to change this Privacy Policy at any time to reflect new services, changes in our Personal Information practices or relevant laws. If we make material changes, we will notify you as required by applicable law. The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy.
Navan, Inc., located at 3045 Park Blvd, Palo Alto, CA 94306, USA, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact us at privacy@navan.com, or write to us at Navan, Inc., 3045 Park Blvd, Palo Alto, CA 94306.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.