Account Registration Information

To create an account, you provide data including:

• Full name and surname
• Email address
• Mobile phone number
• Date of birth and age
• Postal address
• Profile picture (optional)
• Username and password

Identity Verification

We may collect additional information to verify your identity, including:

• Identity document: ID card, passport, driver's license
• Boating licenses: PER, PNB, Yacht Master, or other certifications
• Driving history: To verify rental eligibility
• Biometric verification: Photographs for identity confirmation
• Background checks: As permitted by applicable law

YOU EXPRESSLY AUTHORIZE NAVEGA to access government databases, maritime traffic records, and other sources to verify the information provided.

Payment and Billing Information

When you make transactions, we collect:

• Credit/debit card number (processed by Stripe)
• Expiration date and CVV code
• Billing address
• Bank information for payments to Owners
• Tax ID for billing

Listing Information

Owners may provide information about their Vessels, including:

• Description, features, and photographs of the Vessel
• Location of the port or mooring
• Documentation of the Vessel (registration, inspections)
• Insurance information
• Prices and cancellation policies

Usage and Registration Information

• Pages visited and content viewed
• Searches performed and listings consulted
• Dates and times of access
• Time spent on each page
• Interactions with other users
• Messages sent through the platform

Device and Connection Information

• IP Address and approximate geographical location
• Unique device identifiers
• Hardware model and operating system
• Browser type and version
• Mobile network information and carrier
• Language and time zone settings

Location Information

We may collect location information in various ways:

• Approximate location: Based on your IP address
• Precise location: With your explicit consent, via the GPS of your mobile device
• Location history: To improve service recommendations

You can disable location services in your device settings, although this may limit certain functionalities.

Transaction Information

• History of bookings and payments
• Receipts and transaction confirmations
• Disputes and resolutions
• Processed refunds

Types of Cookies We Use

Type	Purpose
Essential	Necessary for basic functioning (authentication, security)
Functional	Remember preferences (language, preferred location)
Analytical	Understand how our Services are used
Advertising	Display relevant ads and measure their effectiveness

Other Tracking Technologies

• Tracking pixels: To analyze browsing behavior
• HTML5 local storage: To store data in your browser
• Application SDKs: To analyze mobile application usage
• Advertising identifiers: To personalize ads

Third-Party Cookies

Third parties, including advertisers and analytics providers, may use their own cookies to collect information about your activity on our Services and other websites. These third parties include, but are not limited to:

• Google Analytics and Google Ads
• Facebook Pixel
• Stripe (payment processing)
• Email marketing providers

Navega does not control these third-party cookies. To disable them, please refer to the privacy policies of each provider.

Service Provision

• Create and manage your account
• Process bookings and transactions
• Facilitate communication between Owners and Tenants
• Provide customer support
• Verify your identity and eligibility

Service Improvement

• Analyze usage patterns to enhance the experience
• Develop new features
• Conduct research and analysis
• Personalize listing recommendations

Communications

• Send notifications about your account and transactions
• Security alerts and important updates
• Promotional and marketing materials (with your consent)
• Satisfaction surveys

You can opt out of receiving promotional communications at any time through your account settings or by clicking "unsubscribe" in our emails.

Security and Legal Compliance

• Detect, investigate, and prevent fraud
• Protect the safety of users and vessels
• Comply with legal and regulatory obligations
• Respond to requests from authorities
• Enforce our Terms of Service

With Other Users

When you make or receive a booking, we share relevant information:

• With Owners: Name, profile picture, booking history, reviews
• With Renters: Owner's name, location of the vessel, contact information after confirming the booking
• Public profiles: Your public profile information is visible to other users

With Service Providers

We work with third parties who help us operate our Services:

• Stripe: Payment processing
• Identity verification providers: Cognito, Onfido
• Hosting and cloud services: AWS, Google Cloud
• Analytics: Google Analytics, Mixpanel
• Communications: SendGrid, Twilio
• Customer support: Zendesk, Intercom

These providers are contractually obligated to protect your information and use it solely to provide services to Navega.

With Insurance Companies

We may share information with insurers to:

• Process damage claims
• Verify insurance coverage
• Investigate incidents
• Assess underwriting risks

For Legal Reasons

Navega will disclose personal information when required by law or when we believe in good faith that it is necessary to:

• Comply with legal processes (subpoenas, court orders)
• Respond to governmental requests
• Protect the rights, property, or safety of Navega
• Prevent illegal activities, fraud, or threats
• Protect the safety of any person

Corporate Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or other corporate transaction, your information may be transferred as part of the company's assets. We will notify you of any changes in the ownership or use of your personal information.

Information Collected by Onboard Devices

If a Vessel has tracking devices installed, we may collect:

• Real-time location of the Vessel
• Route history and trajectories
• Sailing speed
• Usage time and operating hours
• Engine data and fuel consumption (if applicable)
• Environmental conditions (wind, wave height, temperature)

Use of Tracking Data

This information may be used for:

• Safety and location in case of emergency
• Verification of compliance with the agreed navigation area
• Investigation of claims and disputes
• Compliance with insurance requirements
• Cooperation with maritime and rescue authorities

Contract Execution

We process your data when it is necessary to fulfill our contractual obligations, such as:

• Creating and managing your account
• Processing bookings and transactions
• Providing the requested Services
• Communicating with you about your account

Compliance with Legal Obligations

We process data when it is necessary to comply with legal requirements:

• Tax and accounting obligations
• Prevention of money laundering
• Response to judicial requests
• Consumer protection regulations

Legitimate Interests

We process data based on our legitimate interests when these are not overridden by your fundamental rights:

• Fraud prevention and security
• Improvement of our Services
• Direct marketing (with the right to object)
• Business administration and management
• Defense of legal claims

Consent

In certain cases, we ask for your explicit consent for:

• Promotional marketing communications
• Collection of precise location
• Non-essential cookies
• Processing of sensitive data

You can withdraw your consent at any time, without affecting the lawfulness of the prior processing.

Server Location

Navega uses infrastructure services located in:

• United States
• European Union
• Other countries where our providers operate

Safeguards for Transfers

When we transfer data outside the EEA, we implement appropriate protective measures:

• Standard Contractual Clauses from the European Commission
• Adequacy Decisions from the European Commission
• Binding Corporate Rules (where applicable)
• Certifications such as the EU-US Data Privacy Framework

Retention Periods

Type of Data	Retention Period
Active account data	While the account is active
Transaction history	10 years (tax obligations)
Identity verification data	5 years after account closure
Support communications	3 years after resolution
Access logs	2 years
Marketing data	Until consent is withdrawn

Extended Retention

We may retain data for longer periods when necessary to:

• Comply with legal obligations
• Resolve pending disputes
• Prevent fraud and abuse
• Enforce our agreements
• Protect the rights of Navega or third parties

Account Closure

When you close your account:

• Your profile will no longer be publicly visible within 24-72 hours
• We will attempt to delete your data within 30 days
• Certain data may be retained as described above
• Published reviews will remain visible (they will show "user deleted")

ARCO Plus Rights

• Access: Request confirmation of whether we process your data and obtain a copy
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request the deletion of your data ("right to be forgotten")
• Objection: Object to processing based on legitimate interests
• Restriction: Restrict processing under certain circumstances
• Portability: Receive your data in a structured format and transfer it to another controller
• Withdrawal of consent: Withdraw previously granted consent

How to Exercise Your Rights

You can exercise your rights in the following ways:

• Account settings: Update information directly in your profile
• Email: Send a request to support@navegaapp.com
• Postal mail: Write to our address indicated in the Contact section

We will respond to your request within a maximum of 30 days. We may request additional information to verify your identity.

Limitations

Certain rights may be subject to legal limitations. For example, we may not be able to delete data that:

• Is necessary to comply with legal obligations
• Is required to exercise or defend legal claims
• Is necessary for reasons of public interest

Complaints

If you believe we have violated your data protection rights, you can file a complaint with the Spanish Data Protection Agency (AEPD) or another competent supervisory authority.

Security Measures

• Encryption: Data transmission via HTTPS/TLS
• Data at rest encryption: For stored sensitive information
• Authentication: Secure passwords and optionally two-factor authentication
• Access controls: Restricted access based on necessity
• Monitoring: Detection of suspicious activities
• Backups: Regular data backups
• Training: Employee training on data protection

Your Responsibility

You are responsible for:

• Maintaining the confidentiality of your password
• Not sharing access credentials
• Immediately notifying any unauthorized use of your account
• Using secure devices and networks to access the Services

Data Controller

BLACK GROUP APPS LLC

• Address: [Tax Address of Navega]
• Tax ID: [Tax ID of Navega]
• Email: support@navegaapp.com
• Phone: [Contact Number]

Data Protection Officer (DPO)

For inquiries related to data protection:

• Email: support@navegaapp.com

Supervisory Authority

You can file complaints with the competent supervisory authority:

Spanish Agency for Data Protection (AEPD)
C/ Jorge Juan, 6
28001 Madrid
www.aepd.es

Data Used for Advertising

• Advertising technologies: Web beacons, pixels, ad tags, cookies and device identifiers
• Information provided: Contact data, address, preferences
• Use of the Services: Search history, listings visited, bookings made
• Third-party information: Advertising partners, publishers, and data aggregators

Opt-Out Options (Ad Choices)

You can choose not to receive interest-based advertising. This does not mean you will stop seeing ads, but the ads shown will not be personalized based on your browsing history.

• Network Advertising Initiative: optout.networkadvertising.org
• Digital Advertising Alliance (DAA): aboutads.info/choices
• European Digital Advertising Alliance: youronlinechoices.eu
• Mobile device settings: Enable "Limit Ad Tracking" on your device

Sharing for Marketing

• We may share information with marketing partners to offer you products or services that we believe may be of interest to you
• You can opt out of receiving such communications through your Navega account settings
• Data obtained through SMS programs WILL NOT be shared with third parties for their marketing purposes

Rewards Programs and Contests

Through our Services, you may choose to participate in rewards programs, contests, or other programs involving third parties. When you do so, you authorize us to share your personal information with those third parties. We will only share the information reasonably necessary to provide you with such programs.

Affiliated Companies

We may make information available to our affiliated companies (i.e., entities controlled by, that control, or are under common control with BLACK GROUP APPS LLC). These affiliates will be subject to this Privacy Policy or similar policies that provide equivalent protection.

Types of SMS Messages

• Account verification and two-factor authentication
• Booking confirmations and reminders
• Important security alerts
• Customer support communications
• Promotional notifications (only with your consent)

How to Manage SMS

• For help: Reply HELP to the short number
• To cancel: Reply STOP to cancel the SMS service
• Your phone must have text messaging capability
• Message and data rates may apply depending on your carrier
• The frequency of messages varies based on your account activity

Your Rights under CCPA

• Right to Know: Request that we disclose what personal information we have collected, used, disclosed, or sold about you in the past 12 months
• Right to Delete: Request the deletion of your personal information, subject to certain exceptions
• Right to Opt-Out: Opt-out of the "sale" of your personal information (if applicable)
• Right to Non-Discrimination: Not be discriminated against for exercising your CCPA rights

Categories of Collected Information

Category	Examples
Identifiers	Name, email, phone, IP address
Commercial Information	Booking history, transactions
Internet Activity	Browsing history, searches
Geolocation	Device location
Professional Information	Boating licenses, certifications

How to Exercise Your CCPA Rights

You can submit a verifiable consumer request:

• Email: support@navegaapp.com (indicating "CCPA Request" in the subject line)
• We will respond within 45 days of receiving your verifiable request
• We may request additional information to verify your identity

California "Shine the Light" Law

Section 1798.83 of the California Civil Code allows California residents to request, once a year and free of charge, information about the third parties to whom we have disclosed their personal information (if any) for direct marketing purposes in the previous calendar year, as well as the type of information disclosed to those parties.

To make such a request, send an email to support@navegaapp.com indicating "California Shine the Light Request" and your current address in California. We will respond within 30 days.

Specific GDPR Rights

In addition to the rights described in Section 11, EEA residents may:

• Request confirmation on whether we process your personal data
• Prevent processing for direct marketing (including profiling)
• Request the transfer of your data to another data controller
• Withdraw consent previously given at any time
• File a complaint with the data protection supervisory authority in the country where you reside

Supervisory Authorities by Country

Country	Authority
Spain	Spanish Data Protection Agency (AEPD)
France	National Commission on Informatics and Liberty (CNIL)
Italy	Garante per la protezione dei dati personali
Germany	Federal Commissioner for Data Protection
Portugal	National Data Protection Commission (CNPD)

Linked Sites

• We provide these links solely for your convenience
• We have no control over, do not review, and are not responsible for Third Party Sites
• This Privacy Policy DOES NOT apply to Third Party Sites
• Any data you provide to Third Party Sites is done at your own risk

Social Media Widgets

Our site may include social media widgets (such as "Share" or "Like" buttons) that may provide information to your associated social networks or third parties about your interactions with our web pages, even if you do not click or interact with the widget.

This information may include:

• Identifier assigned by the social network
• Type of browser and operating system
• Type of device and IP address
• URL of the page where the widget appears

No Sale of Personal Data

Navega DOES NOT SELL your personal information to third parties for their direct marketing purposes in the traditional sense. However, under certain legal interpretations (such as CCPA), certain data transfers for personalized advertising could be considered "sale." If you wish to opt-out of such transfers, please contact us at support@navegaapp.com.

Automated Decisions and Profiling

We may use automated systems to:

• Verify your identity and prevent fraud
• Assess your eligibility for certain services
• Personalize the content displayed
• Detect suspicious activities

You have the right not to be subject to decisions based solely on automated processing that produce legal effects concerning you or significantly affect you, except when necessary for the performance of a contract, authorized by law, or based on your explicit consent.

Aggregated and Anonymized Information

We may create anonymized or aggregated data by removing components that personally identify you (such as your name, email, or tracking identifiers). We use this data to:

• Generate statistics about the use of our Services
• Market trend analysis
• Reports to investors or partners (without identifying individuals)

This Privacy Policy DOES NOT APPLY to the use of anonymized or aggregated data.