1. BACKGROUND

1.1.

Navital Global FZ-LLC, with its registered office at In5 Tech, Premises No. HD32C, Dubai Internet City, United Arab Emirates and with commercial license number 99032, and other companies in the Navital Global FZ-LLC group, collect and use certain Personal Data.

1.2.

At Navital Global FZ-LLC, we respect the privacy of Users of the Navital Platform and we are committed to keeping all of your Personal Data secure. This Privacy Policy governs our handling of your Personal Data in the course of carrying on our business activities.

1.3.

We use the following definitions in this Privacy Policy:

Client

means Users of the Navital Platform seeking Members for employment or projects.

Cookie

means a small text file that includes a small quantity of information sent to the browser of website Users, by a web server, and stored on the hard disk drive of a computer for purposes of archiving, collecting navigation data for statistical analysis purposes, and offering Users services related to their interests or location.

Members

means Users of the Navital Platform seeking Members for employment or projects.

Navital, we, us or our

means Navital Global FZ-LLC and other companies in our group.

Navital Platform

means the platform and website accessed at www.navitalglobal.com, through which we provide the Navital Services.

Navital Services

means the various features, functionalities, services and other benefits made available to you through the Navital Platform.

Personal Data

means any data which relates to a living individual who can be identified from that data and other information which is in our possession of, or is likely to come into our possession (or the possession of our representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Navital Global or any other person in respect of an individual.

Privacy Policy

means this website privacy policy.

User(s) or you

means the users of the Navital Platform who may be either a Member or a Client.

2. THE SERVICES WE PROVIDE

2.1.

This Privacy Policy concerns information that we collect about you when providing the Navital Services as part of the Navital Platform.

3. THE TYPES OF PERSONAL DATA WE COLLECT

3.1.

Many of the Navital Services we offer through the Navital Platform require us to obtain Personal Data about you in order to provide those services. You may be unable to access specific parts of, or services made available on, the Navital Platform if such Personal Data are not provided.

3.2.

The type of information that we will obtain and process about you will be determined by whether you are using the Navital Platform as a Client or a Member. In relation to each, we will collect and process the following Personal Data about you:

3.3.

Clients

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Information that you provide to us. Such information may include (by way of a non-exhaustive list):

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basic Personal Data of the Client and the Client’s User who has access to the Navital Services (such as first name; family name; position in the company; company name; company email address; business phone number; company registration documents; business address; city; postcode; country);

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any information that you or the User choose to share on the Navital Platform which may be considered Personal Data; and

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if you are an individual and a Client, we may request copies of your passport and your passport details to verify your identity.

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Information that we collect or generate about you. This includes (by way of a non-exhaustive list):

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any information regarding the Navital Services purchased and/or used on the Navital Platform and our interactions with you or the User;

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a file with your or the Users’ contact and message history to be used for enquiry purposes so that we may ensure that you are satisfied with the Navital Services which we have provided to you;

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usage data when you visit the Navital Platform or otherwise use Navital Services; and

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activity data relating to your usage of the Navital Platform, publication of content, the use of documents on the Navital Platform, and information regarding the User that performed the activity.

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Information we obtain from other sources. This includes the Personal Data provided to us by third-parties, service providers, agencies or other publicly available sources where applicable.

3.4.

Members

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Information that you provide to us. This includes information about you that you provide to us. Such information may include (by way of a non-exhaustive list):

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basic Personal Data (such as first name; family name; employment status; email address; phone number; address; city; postcode; country);

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any information that you choose to share on the Navital Platform which may be considered Personal Data, including your education and career history, as well as any other information that you upload containing details about your CV or the CV itself; and

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your job preferences

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Information that we collect or generate about you. This includes (by way of non-exhaustive list):

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any information regarding the Navital Services purchased and/or used on the Navital Platform and our interactions with you;

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a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the Navital Services which we have provided to you;

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usage data when you visit the Navital Platform or otherwise use Navital Services; and

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activity data relating to your usage of the Navital Platform, publication of content and the use of documents on the Navital Platform.

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Information we obtain from other sources. This includes the Personal Data provided to us by third-parties, service providers, agencies or other publicly available sources where applicable. This includes (by way of non-exhaustive list):

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where agreed with you and approved by you, any Personal Data we collect from screening, background and/or reference checks we may perform on you, which may include your address history, your credit history, your qualifications (both academic and professional) and/or your previously held directorships (if any);

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where agreed with you and approved by you, a criminal records check; and

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where agreed with you and approved by you, any Personal Data we collect from obtaining feedback, references and testimonials from your previous employers on your behalf.

3.5.

Cookies

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When Users visit the Navital Platform, Cookies are used to collect technical information about the services that you use, and how you use them. For more information on the Cookies we use, please see Section 10 of this Privacy Policy.

4. HOW WE USE YOUR INFORMATION

4.1.

Clients

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

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to help you connect with Members;

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to allow the use of our online messaging services;

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for ongoing review and improvement of the information provided on the Navital Platform to ensure it is user friendly and to prevent any potential disruptions or cyber attacks;

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to allow you to use and access the functionality provided by the Navital Platform;

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to set up you and your individual Users up to use the Navital Platform;

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to understand feedback on the Navital Platform and Navital Services and to help provide more information on the use of those services quickly and easily;

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to communicate with you in order to provide you with Navital Services or information about us and the Navital Services;

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to understand your needs and interests;

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for the management and administration of our business;

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in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or

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for the administration and maintenance of our databases storing Personal Data.

4.2.

Members

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

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to help you connect with Clients and allow you to find and be found for work and business opportunities;

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to allow us to tailor the information you see about jobs or opportunities that are most relevant to you;

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where you give us permission, to proactively recommend and share your profile with Clients, or to directly connect or introduce you to Clients;

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where you give us your permission, to provide a link that makes your Member profile accessible to the public;

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to allow the use of our online messaging services;

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for ongoing review and improvement of the information provided on the Navital Platform to ensure that it is user friendly and to prevent any potential disruptions or cyber attacks;

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to allow you to use and access the functionality provided by the Navital Platform;

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to set you up to use the Navital Platform;

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to understand feedback on the Navital Platform and Navital Services and to help provide more information on the use of those services quickly and easily;

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to communicate with you in order to provide you with Navital Services or information about us and the Navital Services;

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to understand your needs and interests;

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for the management and administration of our business;

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in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or

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for the administration and maintenance of our databases storing Personal Data.

However we use your Personal Data, we make sure that our usage complies with applicable data protection laws. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:

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we need to do so in order to perform our contractual obligations with our customers and third-party providers;

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we have obtained your consent;

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we have legal and regulatory obligations that we have to discharge;

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we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or

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the use of your Personal Data as described is necessary for our legitimate business interests, such as:

o

allowing us to effectively and efficiently manage and administer the operation of our business and the Navital Platform;

o

maintaining compliance with internal policies and procedures;

o

monitoring the use of our copyrighted materials; and

o

enabling quick and easy access to information on the Navital Platform and the Navital Services.

5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

5.1.

We may share your Personal Data within our group of companies for the purposes described above. We will take steps to ensure that your Personal Data is accessed only by our employees that have a need to do so for the purposes described in this Privacy Policy.

5.2.

We may also share your Personal Data outside of our group of companies as further described below:

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with our business partners where they are contractually obliged to comply with data protection obligations and relevant privacy and confidentiality legislation;

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with third party agents, contractors and service providers for the purposes of providing services to us (for example, our accountants, professional advisors and IT and communications providers). These third parties will be subject to data protection obligations and they will only use your Personal Data as described in this Privacy Policy;

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to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;

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if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and

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if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

6.1.

We are a global business with customers and operations around the world. As a result, we collect and transfer Personal Data on a global basis. This means that we may transfer your Personal Data to locations outside of your country.

6.2.

Where we transfer your Personal Data to another country, we will ensure that it is protected and transferred in a manner consistent with applicable legal requirements.

7. HOW WE SAFEGUARD YOUR INFORMATION

7.1.

We have extensive controls in place to maintain the security of our information and information systems. User files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

7.2.

Where we transfer your Personal Data to another country, we will ensure that it is protected and transferred in a manner consistent with applicable legal requirements.

7.3.

When you contact one of our employees about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

8. HOW LONG WE KEEP YOUR PERSONAL DATA

8.1.

How long we will hold your Personal Data for will vary and will be determined by the following cumulative criteria:

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the purpose for which we are using it – we will need to keep your Personal Data for as long as is necessary for that purpose; and

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legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

9. YOUR RIGHTS

9.1.

In all the above cases in which we collect, use or store your Personal Data, you may have the following rights which you can exercise free of charge. These rights include:

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the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

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the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;

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in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to us;

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the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

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the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are legally entitled to retain it;

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the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and

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the right to lodge a complaint with the relevant data protection regulator (if any) if you think that any of your rights have been infringed by us.

9.2.

Where applicable, you can exercise your rights by contacting us using the details listed in Section ‎11 below.

9.3.

Where applicable, further information about the rights available to you may be obtained by contacting the relevant supervisory data protection authority (if any) located in your jurisdiction.

10. COOKIES

10.1.

To the extent that we collect Personal Data with the help of Cookies, we will process it in accordance with this Privacy Policy.

10.2.

Types of Cookies and purposes

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Cookies used on the Navital Platform are used to record information necessary for the proper functioning of the Navital Platform and the Navital Services offered to you, audience measurement, use monitoring and security.

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Cookies are placed by us and, if applicable, our business partners, third party agents and contractors (without us being held responsible for the placement of Cookies by our partners, third party agents and contractors).

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Each time a User is identified on the Navital Platform, a Cookie is placed allowing us to identify the computer or hardware used and the User navigating the Navital Platform. This Cookie allows the Navital Services to be provided seamlessly and therefore without re-identification. This Cookie is invalidated when the browser is closed or after a period of inactivity on the Navital Platform.

10.3.

Cookies on the Navital Platform are generally divided into the following categories:

(A)

Strictly necessary Cookies. These are Cookies that are required for the operation of the Navital Platform or provide necessary functions relating to the Navital Services you request or receive. They include, for example, Cookies that enable you to log into secure areas of the Navital Platform.

(B)

Analytical or performance Cookies. These allow us to recognise and count the number of Users and to see how Users move around the Navital Platform when they are using it. This helps us to improve the way the Navital Platform works, for example, by ensuring that Users are finding what they are looking for easily. These Cookies also allow us to collect statistical information about how you use the Navital Platform (including how long you spend on the Navital Platform) and where you have come to the Navital Platform from, so that we can improve the Navital Platform and learn which parts and functions of the Navital Platform are most popular with our Users.

(C)

Functionality Cookies. These Cookies enable helpful but non-essential functions that improve your experience on the Navital Platform. By recognising you when you return to the Navital Platform, they may, for example, allow us to personalise our content for you, greet you by name, or remember your preferences (for example, your choice of language or region). This also enables us to customise elements of the layout and/or content of the pages of the Navital Platform

(D)

Targeting Cookies. These Cookies enable different advertising related functions. They may allow us to record information about your visit to the Navital Platform, such as pages visited, links followed, and videos viewed so we can make the Navital Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

11. QUESTIONS AND CONCERNS

11.1.

For further information regarding our processing of your Personal Data or this Privacy Policy, please contact us using the following contact details:

Address: In5 Tech, Premises No. HD32C, Dubai Internet City, United Arab Emirates

Email Address: [email protected]

11.1.

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may, in some cases, be able to escalate concerns to the applicable privacy regulator in your jurisdiction where there is one. Upon request, we will provide you with the contact information for that regulator, where applicable.