Beam Privacy Policy

We at Nava PBC ("Nava", “we”, “us” or “our”) have created this Privacy Policy to describe our practices regarding information we collect through our web sites, including website, mobile features, applications, software, and any other interactive features or services owned or controlled by Nava that post a link to this Privacy Policy (each, a "Service" and collectively, the "Services"), as well as any information we collect offline and combine in our databases. Certain features discussed in this Privacy Policy may not be offered on each Service at any particular time. Note that we combine the information we collect from you through all of our websites, mobile applications, software, and other Services.

Nava provides Services on behalf of educational institutions (colleges, universities, and K-12 institutions), governments (federal, state, and local), and partner organizations. If you are utilizing Nava Services in conjunction with an educational institution, government,or a partner organization providing funding, Nava may share disclosed data with your affiliated institution or district for the purposes of program improvement, assessment and additional student support.

Note about Children: Our Services are not intended for, marketed to or available to individuals younger than the age of 13, and individuals younger than the age of 13 should not submit personal information to us or use any Service.

Summary

WE FULLY DESCRIBE OUR PRIVACY PRACTICES BELOW IN THIS PRIVACY POLICY. THIS SUMMARY PROVIDES AN OVERVIEW OF SOME IMPORTANT INFORMATION REGARDING OUR USE AND SHARING OF YOUR INFORMATION, AND THIRD PARTIES WHO MAY SERVE ADVERTISEMENTS AND WHO MAY SET COOKIES OR WEB BEACONS OR SIMILAR TRACKING TECHNOLOGIES WHEN YOU USE THE SERVICES; PLEASE READ THE ENTIRE PRIVACY POLICY VERY CAREFULLY. BY USING THE NAVA BEAM SERVICE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY.

We primarily use the information we collect when you use the Services in connection with your relationship with Nava, your use of the Services, and for sending you information from us or on behalf of certain third parties. This includes linking you to other members of the Nava community. It also includes providing offers to you based on information you provide or we collect, or your use of the Services. Please review the "INFORMATION COLLECTION" and "HOW WE USE YOUR INFORMATION" sections of this Privacy Policy for a full description of the information we collect, including Personal Information (as defined below), and how we use that information. Note that we do not share your Personal Information with third parties for their marketing purposes without your consent; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below entitled "Information Sharing.”

We work with analytics service providers to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services, and to provide us with information regarding the use of the Services. Our analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your visits to and activity on the Services, as well as on other web sites or online services. Some of these parties may collect Personal Information when you visit the Services or other websites and services.

Information collection

1. Registration and Other Information

The Services may collect "Personal Information" (which is information that can reasonably be used, alone or in combination with other reasonably available information, to identify or contact a specific individual). Personal Information includes, but is not limited to your name, email address, phone number, physical address or zip code, account information (such as a password or other information that helps us confirm that it is you accessing your account) and demographic or other information (such as your school, gender, age or birthdate) and information about your interests and preferences. Nava may integrate with a third party programming interface (API) for financial and credit agencies utilized by a user (such as bank or credit accounts). This API integration is essential for certain Nava Services that use financial management tools and may be made available to a user’s institution for financial aid advice (as discussed in more detail below). Any information combined with Personal Information will be treated as Personal Information.

2. Your Account, Community Forums and User Content

You may have the opportunity to create an account and corresponding application, which consists of information about you, which may include Personal Information, documents including photo IDs, information about your academic and work history, your interests and activities, your use of the Services and other information ("Account"). Some of the information in your Account may be visible to third parties or to the institution your account is associated with, depending on the nature of the information and the privacy settings. We do not control how frequently third-party search engines update their indexes; consequently, their information may be outdated and still available for a period of time even if you discontinue use of the Service.

Note that in order to provide services and opportunities to you, governments, educational institutions, partner organizations, grant providers and other third parties may (to the extent permissible by law) be able to review certain information in your Account for some of the Services, whether or not you have limited public access to that information. You may have the opportunity to control whether this information is shared, but some information may be shared automatically to the extent permissible by law -- all as disclosed on the website or other service where you created your Account. Nava does not share your contact information (email, full postal address or phone number) with those third parties unless you request or agree to that sharing. However, Nava may send you information and offers from third parties and information about the services, and you may not be able to opt-out from these messages without closing your account.

3. Referral Features

The Services may offer referral features whereby users may use an email tool to invite friends to use the Services using a one-time email. Nava stores this information for the purpose of verification, as well as tracking the success of our referral program. Nava will not use those referred email addresses for any other purpose (unless, of course, the referred user comes to a Service and registers as a user, in which case we may use the email address provided by the referred user in accordance with this Privacy Policy). The referred person may contact us via email to request that we remove this information from our active database.

We will automatically send your referral a one-time email including an invitation to visit the Services. Nava does not sell or disclose any of this information to any outside sources or parties and collects this information only to maintain records.

4. Information Nava Collects

When you access other web sites and online services, we and our analytics providers, vendors and other third party service providers may automatically collect certain "Usage Information" whenever you access and use the Services.

Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit (including information about any ads you may view), and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes and to enhance or otherwise improve the Services and our products.

In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device (any, a "Device") you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.

Usage Information is collected via tracking technologies, including:

Cookies: Our Services utilize Cookies to improve your current and future experience by allowing us to understand your usage of our Services. For example, cookies help our systems recognize you if you return to our Services shortly after exiting them. Cookies are small text files stored on your computer that allow us to personalize the content of our Services. Cookies can be turned off via your browser settings if you so choose. However, if you turn your cookies off, some features of our Services may not function properly. In our Products, we use local storage to help remember your settings and account configuration.

Web Beacons: We, as well as our affiliate program partners, service providers, and other third parties, may employ a software technology called clear gifs (a.k.a. web beacons/web bugs), that help us better manage content on our Services by informing us of what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users for our affiliate program. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. This information is used to help improve the overall quality and experience of our Services. We tie the information gathered by clear gifs to our customers' Personal Information.

An Embedded Script: Programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third party service provider and is deactivated or deleted when you disconnect from the Services.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

Flash & HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features in our Services or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 & Flash to collect and store information.

Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here: Macromedia

How We Respond To “Do Not Track” Signals:

Please note that your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online services you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about "Do Not Track", please visit http://www.allaboutdnt.com.

How we user your information

We may use information about you, including Personal Information, to: (1) allow you to participate in features we offer or to provide related customer service, including, without limitation, to respond to your questions, complaints or comments; (2) tailor content, recommendations and offers we display to you, both on the Services and elsewhere online; (3) process your registration with our Services, including verifying your e-mail address is active and valid; (4) improve the Services and our products, and for internal business purposes, including the measurement of ad effectiveness; (5) contact you with regard to your use of the Services and, in our discretion, changes to our policies; (6) to provide you with location features and services; and (7) as described in the Privacy Policy and for purposes disclosed at the time you provide your information or otherwise with your consent.

Note that we may create, facilitate or display social advertisements, whereby your name and profile photo may be used to advertise products and services to your network based on your use of the Services and your interactions with Nava Services, and third parties through the Services. If we are utilizing Social Ads on one of our Services, you will be able to opt-out through your account settings for that Service.

Please note that information submitted on the Services via a "Contact Us" or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.

Information sharing

Nava does not share your Personal Information with third parties for their marketing purposes without your explicit consent and in compliance with all applicable laws (including California Business & Professions Code section 22584 ("SOPIPA"), and California Education Code section 49073.1). Nava may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services. We also may share your Personal Information with third parties with your consent (if permissible under applicable law), as disclosed at the time you provide us with information, and as described below or otherwise in this Privacy Policy. For Educational Institutions: We work with colleges, universities, scholarship providers and educational institutions ("Educational Institutions") to help improve retention and ensure students have the financial means to graduate. We do not share your contact information (email address, full postal address or phone number) with these Educational Institutions without your consent, but we may send you information on their behalf. We are not responsible for the privacy policies and practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

When You Request That We Share Your Information: In compliance with all applicable laws, we may offer opportunities and features through the Services that are brought to you by a third party or that otherwise involve sharing your information with a third party. If you request or agree at that time to have your information shared, your information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. This includes, without limitation, instances in which you use our Services to purchase products or services provided, in whole or part, by third parties, such as when you use our Service to order food from a local restaurant. You also may request, sometimes through your use of an interactive feature, a widget or third party application, that we share information about you with a third party and we will typically do so under those circumstances.

Service Providers. We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, such as shipping your prepaid card, sending our emails, or offering customer service.

5. Administrative, Legal Reasons & Academic Integrity Investigations

We may also disclose your information, including Personal Information, in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; upon request of an academic institution connected to an investigation into academic integrity; to protect and/or defend any applicable Terms of Use or other policies applicable to the Services; or to protect the personal safety, rights, property or security of any organization or individual. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies at our discretion. These disclosures may be carried out without your consent or without notice to you.

6. Business Transitions

Nava may share Personal Information with its affiliates and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable law with regard to such Personal Information. In the event that Nava goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, your information, including Personal Information, will likely be among the assets transferred. This Privacy Policy will become binding upon the new owner of the information until amended.

7. Mobile Use

Text Messages: You may be able to opt-in to receiving text messages from Nava and/or its Services. You may always opt-out by replying "STOP" to one of the text messages received. You also acknowledge and agree that use of the Services through a mobile device may cause data to be displayed on and through your mobile device which may be viewed by your mobile carrier or other access provider.

Push Notification: We may send you push notifications if you agree to receive them. You may opt-out of receiving these at any time by going to the phone settings and turning them off.

Updating your account information and control over emails

You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information. You also may be able to limit the information you receive from us by adjusting your settings here. All changes to your email settings and preferences must be made in your account preferences page on the applicable Service. However, we reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive information from us, you will need to close your account for that Service.

Closing your account

If you wish to close your account with one of our Services, please refer to the Terms of Service or the End User License Agreement for the relevant Nava Service for instructions on closing your account. Requests to change your email preferences or unsubscribe from all emails may be submitted through one of the channels set out in the previous section or the Terms of Service or End User License Agreement for the relevant Nava Service.

Even if your account is closed, information may remain in backup or archival records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, account recovery or if required by law. All retained data will continue to be subject to the applicable privacy policy for the Service. Also, if you have posted content on or through the Services, such as in any Community Forums, we may not be able to delete it and will not make an attempt to do so unless specifically requested.

Third party content, links to other sites, and Nava services content found outside of the Services

Certain content provided through the Services may be hosted and served by third parties, which may include third party widgets (such as those that allow you to "like" or "share" content with third party web sites and online services). In addition, the Services may link to third party web sites or content over which Nava has no control and which are governed by the privacy policies and business practices of those third parties. In addition, third-party partners of Nava, from whom you order through the Services, may have different privacy policies, which apply to such partners' use of your information.

Please also note that Nava content and widgets may be included on web pages and web sites that are not associated with us and over which we have no control. These third parties may independently collect data. Nava is not responsible or liable for the privacy practices or business practices of any third party.

Testimonials

We display personal testimonials of satisfied customers on our Services in addition to other endorsements. With your consent, and only if you are at least 18 years old, we may post your testimonial along with your first name. If you wish to update or delete your testimonial, you can contact us via email.

Security

Nava takes data security very seriously. Nava takes commercially reasonable technical, physical, and administrative security measures to protect the Personal Information submitted to us, both during transmission and once we receive it. Such measures vary depending on the sensitivity of the information at issue. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. In the event that Nava becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. If you have any questions about security on our Services, please see our related security certifications located at https://www.navapbc.com/contract-vehicles, or you can email us at it@navapbc.com.

Changes to this Privacy Policy

Nava may update this Privacy Policy at any time and any changes will be effective upon posting. Upon any update the “Last Updated” date at the top of this policy will be updated. In the event that there are material changes to the way we treat your Personal Information, You are responsible for regularly reviewing this Privacy Policy and your Service account for notice of such modifications. Your continued use of the Services following an update to this Privacy Policy will constitute your acceptance of the updated Privacy Policy. We will notify you of material changes to the Privacy Policy on our Website and/or by email, and make additional efforts to notify customers of material changes that impact the treatment of data collected through our Services.

Questions or comments about this Privacy Policy

If you have questions or comments about this Privacy Policy, please contact us at the address below or via email:

Nava PBC
601 13th St NW, Floor 12
Washington, DC 20005
Hello@navapbc.com

California Residents - Your CA Privacy Rights

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties' direct marketing purposes and the categories of personal information the company shares. Alternatively, the law provides that a company that has a privacy policy that provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties' direct marketing purposes may instead provide information on how to exercise that choice.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request via email to legalsupport@navapbc.com.

You must put the statement "Your California Privacy Rights" in the subject field of your e-mail. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.