Introduction

Navigator Ltd. (“Navigator” or “we”) is committed to keeping our clients’ information confidential, consistent with our obligations as professionals. This commitment extends to personal information of our clients and other individuals (“you”). This Privacy Commitment has been designed to assist you in understanding the type of information we collect, how we use that information and the safeguards we have in place to protect that information and your privacy.

Collection, Use and Disclosure of Personal Information

Canadian privacy legislation defines “Personal Information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, Personal Information means information about an identifiable individual as defined from time to time in applicable privacy legislation. Generally, Personal Information does not include your name, business address or business contact information, such as your business title, email address or phone numbers, which you provide to us for business purposes.

Navigator generally collects Personal Information that you voluntarily provide, but we may collect information from third parties and as agents on behalf of our clients where we or they have obtained the requisite consent, or as otherwise permitted or required by law. Examples of types of Personal Information that Navigator may collect about you includes your name, home address, telephone number, personal e-mail address, billing and account information, information about a client issue and other information incidental to providing our advice and services (including Personal Information about individuals involved in your issue, including directors, officers, employees, decision-makers, experts, other professional advisors and our clients’ business partners, investors, shareholders, competitors and customers whom are individuals).We may also collect information through our website, although that information is typically restricted to your name, home address, and/or email address .

We will obtain your consent prior to collecting, using or disclosing Personal Information for any purpose, except where otherwise permitted or required by law. Consent may be provided orally or in writing or may be implied, such as where you continue to provide Personal Information to us in the context of our ongoing relationship, or where you provide members of Navigator with non-business contact information in connection with our service offerings. By providing Personal Information to Navigator, you consent to our collection, use and disclosure of such Personal Information in accordance with this Privacy Commitment and as permitted or required by law. To the extent that you provide Personal Information of another individual to Navigator, you represent that you have the necessary consent or authority to permit us to collect, use and disclose such Personal Information for the purposes set out in this Commitment.

Navigator collects, uses and discloses Personal Information primarily to provide advice and other services to clients and prospective clients, for administrative and relationship management purposes (including to develop and manage our knowledge management systems, and to market and deliver Navigator services) and as otherwise permitted or required by law.

Navigator only keeps Personal Information as long as it is required for the reasons it was collected or to comply with law or professional standards.

Security

Your Personal Information is treated as private, confidential information by Navigator and we strive to ensure that your Personal Information, regardless of format, is protected and kept secure at all times. Most methods of communication are not fully secure and security measures may create challenges to the efficient exchange of information. Email is often our preferred method of communication and unless you object we usually use unencrypted plain text emails when communicating with you.

Our Website

The only information we collect through our website is the information voluntarily supplied by you if you contact Navigator through the website. This information is typically restricted to your name and e-mail address. We do not employ any electronic means to automatically collect Personal Information from any visitor or user of our site or from their computers.

Our website contains links to other websites which may collect your Personal Information. Navigator does not assume any responsibility for the privacy practices, policies or actions of the third parties operating these websites. You should read the privacy policies of these websites and make an informed decision whether or not to provide your Personal Information to the websites’ operators.

Cookie Policy

This cookie policy (“Cookie Policy”) is intended to inform you of how we use “cookies” and similar technologies on our website at www.navltd.com (“Website”) and to assist you in making informed decisions when using our Website. Please take a moment to read and understand this Cookie Policy.

What are cookies?

Cookies and similar technologies are very small text documents or pieces of code, which often include an anonymous unique identifier. When you visit a website or use a mobile application, a computer asks your computer or mobile device for permission to store this file on your computer or mobile device and access information from it. Information gathered through cookies and similar technologies may include the date and time of visits and how you are using the particular website or mobile application. Cookies are used by us as part of our Website and they are also used by some of our third party partners.

For more details on cookies and similar technologies please visit All About Cookies. For the purposes of the remaining sections of this Cookie Policy we will refer to all technologies using the above features as “cookies”.

Consent to our use of cookies

By using the Website, you acknowledge that we may store and access essential cookies on your computer or other devices. Essential cookies are cookies which are essential for the operation of our Website. Please note that we do not need your consent to store and access essential cookies as we have a legitimate interest (i.e. the functionality of the Website) for doing so.

Further, by using the Website, you consent to us storing and accessing certain non-essential cookies on your computer or other devices. These cookies are not essential to the operation of our Website but allow us to provide additional functionality or to gather additional information about your use of our Website.

If you wish to block or delete cookies, or if you would like to withdraw consent to our use of non-essential cookies, you can find out how to do so below.

What do we do with cookies?

Essential cookies

We use essential cookies where they are essential for the operation of the Website.

Session cookies

We use session cookies to allow the Website to uniquely identify your browsing session on our Website, which allows us to coordinate this information with data from our Website server.

Analytics cookies

We use “analytics” cookies. These, along with other information, allow us to calculate the aggregate number of people using the Website and see which features of our Website are most popular.

We use this information to improve the Website, such as to understand what content is most popular so we can produce similar content. We do not generally store any information that you provide to us in a cookie.

Can you block cookies?

You can block the use of cookies altogether by activating the relevant settings in your browser. You can find out how to do this for a variety of browsers at All About Cookies. For more information on cookie management and blocking or deleting cookies for a wide variety of browsers, visit All About Cookies.

Accessing Your Personal Information

In providing any Personal Information to Navigator, whether through the website or otherwise, you consent to the collection, use and disclosure of that information in accordance with this Privacy Commitment. You have the right to verify and amend your Personal Information collected by us. You are also free at all times to withdraw your consent to the collection, use and disclosure of your Personal Information. You have rights to access your Personal Information. These rights are not absolute; however if we deny your request for access, we will provide reasons for doing so. If you wish to access, verify and/or amend your Personal Information or make a complaint under this Commitment, please send us a written notice, at the address below.

General Counsel
Navigator Ltd.
121 King Street West
Suite 1810
Box 100, Toronto, ON
M5H 3T9

– or –

info@navltd.com, subject line: “Personal Information”

Navigator reserves the right to modify or amend this Privacy Commitment from time to time and we encourage you to refer back to this Commitment regularly.