4. INFORMATION WE COLLECT ABOUT YOU AUTOMATICALLY

4.1 We also automatically collect personal data indirectly about how you access and use the Native Website and/or Application, and information about the device you use to access the Native Website and/or Application, read our emails, or otherwise engage with us. We use this information to provide to you the features and functionality of the Native Website and/or Application, to monitor and improve the Native Website and/or Application and to develop new products and services. We typically collect this information through a variety of tracking technologies, including cookies and similar tracking technologies.

4.2 The table below at this section 4 sets out in detail the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data. For more information on cookies and other tracking technologies we use, please see Section 8 below.

4.3 We may anonymize and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Native Website and/or Application and our services or developing new services and features. We may also share such anonymized and aggregated information with others.

Category of personal data	How we may use it	Legal basis for the processing
Location information or your IP address, including longitude, latitude, date and time if you use location features on the Website and/or Application (the precision of this data varies greatly and is determined by factors controlled by your device or mobile service provider).	We use this information to enable you to use location features of the Website and/or Application.	The processing is necessary for the performance of a contract with you, if you choose to use Native’s location features on the Website and/or Application.
Device and connection information, including hardware model, operating system information, browser information, IP address, mobile network information including phone number and device identifiers.	Where relevant and where permitted under applicable law, we use this information to identify potential risk or unlawful behavior including fraud detection, theft prevention, emergency response purposes and legal compliance.	Legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Website and/or Application, Native and users
	We use this information to improve and monitor the Website and/or Application.	We will only process your personal data in this way to the extent that you have given us your consent to do so.
	We use this information to analyze preferences, trends and statistics to better improve the Website and/or Application.	We will only process your personal data in this way to the extent that you have given us your consent to do so.
Status information, including about your online and status message changes on the Website and/or Application (including “online status” and “last seen status”).	We use this information to enable you to show those you communicate with on the Website and/or Application what you “online status” and “last seen status” is.	The processing is necessary for the performance of a contract with you.
Usage and log information, including information about your activity (such as how you use the Website and/or Application, how you interact with others using the Website and/or Application), log files and diagnostic, crash, website and performance logs and reports.	Where relevant and where permitted under applicable law, we use this information to identify potential risk or unlawful behavior including fraud detection, theft prevention, emergency response purposes and legal compliance.	Legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Website and/or Application, Native and users
	We use this information to improve and monitor the Website and/or Application.	We will only process your personal data in this way to the extent that you have given us your consent to do so.
	We use this information to analyze preferences, trends and statistics to better improve the Website and/or Application.	We will only process your personal data in this way to the extent that you have given us your consent to do so.
Name, mailing address, email address, and payment information, including payment information receiving payment receipts from app stores and other third parties if you make a payment in connection with your use of the Website and/or Application.	We use this data to process subscription fees and data overage charges, and to send you receipts for all payments.	We will only process your personal data in this way to the extent that you have given us your consent to do so.

5. HOW LONG WE KEEP YOUR PERSONAL DATA

5.1 We will store the personal data we collect for as long as you have an active account with us and for a period of 30 days following termination of your account. 

5.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

6. RECIPIENTS

6.1 As required in accordance with how we use your personal data, we may share your personal data with the following: 

6.1 (a) Service providers and advisors. We may share your personal data with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email or chat services, fraud prevention, web hosting, providing analytics services or payment processing. For specific details of the sub-processors that we use to provide our services, please see trust.native.tech. 

6.1 (b) Purchasers and third parties in connection with a business transaction. Your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.

6.1 (c) Law enforcement, regulators and other parties for legal reasons. We may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Native, its users or others.

6.1 (d) Affiliates. We may share your personal data with affiliated legal entities within our family of companies for purposes and uses that are consistent with this Privacy Notice, such as for the provision of our services and Website and/or Application.

7. MARKETING

7.1 From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

7.2 Our marketing messages will be sent by email, text, post. For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.

7.3 We will only send you marketing messages if you have given us your consent to do so to the extent required by applicable law. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails, by opting out via the link in the text message, by contacting us on the contact details provided at the end of this Privacy Notice. We do our best to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).

8. COOKIES AND SIMILAR TECHNOLOGIES

8.1 The Native Website and/or Application uses cookies and similar tracking technologies to distinguish you from other users of the Native Website and/or Application. Cookies are pieces of code that we transfer to your device for record-keeping purposes. This helps us to provide certain functionalities of the Native Website and/or Application, to monitor and improve the Native Website and/or Application, as well as to allow our partners determine products and services that may be of interest to you and to display relevant advertising to you as you browse the Internet.

8.2 We use the following types of cookies:

8.2 (a) Strictly necessary cookies. These are cookies that are required for the operation of our Website and/or Application. They include, for example, cookies that enable you to log into secure areas of our Website and/or Application, use a shopping cart or make use of e-billing services.

8.2 (b) Analytical/performance cookies. They allow us to recognize and count the number of visitors, to see how visitors move around the Native Website and/or Application when they are using it and to monitor the performance of certain features on the Native Website and/or Application. This helps us to improve the way the Native Website and/or Application works, for example, by ensuring that users are finding what they are looking for easily and to test the rollout of new features.

8.2 (c) Functionality cookies. These are used to recognize you as you move around the Native Website and/or Application and to remember information that you enter when you use the Native Website and/or Application, such as when you fill in a form.

8.2 (d) Third party cookies. Please be aware that advertisers and other third parties may use their own cookies or tracking technologies when you click on an advertisement or link on our Website and/or Application. These third parties are responsible for setting out their own cookie and privacy policies.

8.3 The table below at this section 8 contains more information about the cookies we use and how long they remain on your device. 

8.4 Other than cookies that are required to operate the Website and/or Application, we will only place cookies on your device with your consent where required by applicable law. You can also change your preferences in relation to the cookies you consent to receive by emailing us trust@native.tech.

8.5 You also have the ability to opt out by disabling cookies in your browser or mobile settings. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.

8.5 (a) Cookie settings in Internet Explorer

8.5 (b) Cookie settings in Firefox

8.5 (c) Cookie settings in Chrome

8.5 (d) Cookie settings in Safari web and iOS.

Cookie Name	Type of cookie	When is the cookie set?	How long does the cookie stay on my device?	Purposes / Additional information
Website Cookies and Tracking Technologies
Google Analytics	Analytics/ Performance	When the user first visits the Native Website and/or Application	[6420 days]	These cookies are used to collect information about how visitors use our Website and/or Application. We use the information to compile reports and to help us improve the Website and/or Application. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
Hubspot Forms	Analytics/ Performance	When the user first visits the Native Website and/or Application	[3650 days]	These cookies collect data to personalize the website and the user’s experience. Cookies keep track of a user’s identity to assist with pre-populating any Hubspot forms or embedded forms on a website. The data collected in doing so is not shared across websites and forms or embedded forms will work on a website without cookies (i.e., when cookies have been rejected).
Rebrandly	Analytics/ Performance	When the user first visits the Native Website and/or Application	[730 days]	These cookies collect data on links users click after seeing a promotion. The data collected in doing so is not shared across websites.
Sentry	Analytics/ Performance	When the user first visits the Native Website and/or Application	[6420 days]	Application utilizes Sentry, a third-party error tracking and monitoring service, to help us identify and diagnose technical issues that may arise while you are using our site. Sentry uses cookies to collect information about your device, browser, and the error encountered. This information enables us to better understand and resolve the issue, ultimately improving user experience. The collected data may include your IP address, browser type, operating system, and the specific error details

9. STORING AND TRANSFERRING YOUR PERSONAL DATA

9.1 Security. We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. All personal data we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

9.2 International Transfers of your personal data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are, to jurisdictions where we and our third party service providers have operations. If you are located in the UK or European Economic Area (“EEA“), your personal data may be processed outside of the UK or EEA. These international transfers of your personal data will be made pursuant to appropriate safeguards, including:

9.2 (a) ensuring that the personal data is transferred to countries recognized by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or

9.2 (b) ensuring that such transfer is to a third party who uses appropriate safeguards in respect of the processing in question, including but not limited to the UK or EU standard contractual clauses, which are recognized as offering adequate protection for the rights and freedoms of data subjects, as determined by the European Commission or the UK Secretary of State (as applicable).

9.3 We may transfer your personal data to, or store your personal data in, the following countries:

9.3 (a) West US 

9.4 We will take appropriate steps to ensure that your personal data is treated securely and in accordance with applicable law and this privacy notice regardless of where it is processed.

9.5 If you wish to enquire further about the safeguards we use, please contact us using the details set out at the end of this privacy notice.

10. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA

10.1 In accordance with applicable privacy laws, you may have the following rights in respect of your personal data that we hold:

10.1 (a) Right of access. You have the right to obtain:

10.1 (a) (i) confirmation of whether, and where, we are processing your personal data;

10.1 (a) (ii) information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;

10.1 (a) (iii) information about the categories of recipients with whom we may share your personal data; and

10.1 (a) (iv) a copy of the personal data we hold about you.

10.1 (b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

10.1 (c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay. 

10.1 (d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified. 

10.1 (e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

10. 2 You have a right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal data despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason. 

10.3 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy notice. 

10.4 We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs. 

10.5 You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK, information about how to contact your local data protection authority is available here.

11. LINKS TO THIRD PARTY SITES

The Native Website and/or Application may, from time to time, contain links to and from third party websites and/or applications, including those of our partners, advertisers, news publications, social media platforms and affiliates. If you follow a link to any of these websites and/or applications, please note that these websites and/or applications have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites and/or applications.

12. OUR POLICY TOWARDS CHILDREN

The Native Website and/or Application is not directed at individuals under 18 and we do not knowingly collect personal data from individuals under 18. If you become aware that your child has provided us with personal data without your consent, then please contact us using the details below so that we can take steps to remove such information as quickly as possible.

13. CHANGES TO THIS NOTICE

Our executive management meets on a quarterly basis to review compliance with privacy practices and privacy regulations. We review this privacy notice annually and may update this privacy notice from time to time and so you should review this page periodically. When we change this privacy notice in a material way, we will update the “last modified” date at the end of this privacy notice. Changes to this privacy notice are effective when they are posted on this page.

14. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Native Website and/or Application.  

15. CONTACTING US

15.1 Please contact trust@native.tech if you have any questions, comments and requests regarding this privacy notice. 

15.2 This privacy notice was last modified on 05/15/2023.