PRIVACY POLICY

[Last Modified: Oct.7, 2026]

 

This Privacy Policy (“Policy”) explains how Navigage AI, Inc., together with its subsidiaries and affiliated companies (“Navigage”, “we”, “us”, or “our”), collects, uses, discloses, retains, and otherwise processes Personal Information in connection with: (i) our public-facing promotional website available here (the “Website”); (ii) our web application and related technological interfaces through which customers or users access and manage the Services (collectively, the “Platform”); and (iii) our AI-based web application designed to help users review and manage topics related to their health status, medical expenses, and their Medicare plan. (collectively, the “Services”). Any capitalized terms not defined herein shall have the meanings ascribed to them in the applicable terms between us (“Terms”), or under the applicable privacy laws.

 

This Policy applies when you visit the Website, create or use an account, access the Platform or Services, communicate with us, or otherwise interact with Navigage (“you” or “your”). The Policy does not pertain to Personal Information relating to our employees, directors, contractors and other staff as part of their employment or engagement with us.

 

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: info@navigage.ai.

 

POLICY AMENDMENTS:

 

We reserve the right to amend this Policy from time to time. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. Subject to applicable law, any amendments to the Policy will become effective immediately, unless we notify you otherwise. If we materially change the way in which we process your previously collected Personal Data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to review this Policy periodically to ensure that you understand our most updated privacy practices.

 

1. CONTACT INFORMATION:

 

Navigage acts as an independent Controller (or Business, as applicable) responsible for the processing of your Personal Information collected from you as a user of our Services.

 

You may contact us as follows:

 

• By email: info@navigage.ai.

• By Mail: Navigage AI, Inc., 251 Little Falls Dr., Wilmington, DE 19808.

 

2. DATA SETS WE COLLECT AND FOR WHAT PURPOSE:

 

Below you can find information regarding the purposes for which we process your personal data and the definition of “personal” and “non-personal” data or information, and how it is technically processed.

 

Non-Personal Data

 

Non-Personal Data means data that does not identify an individual and cannot reasonably be used to identify an individual, including aggregated or irreversibly anonymized data. Non-Personal Data may include, for example: Aggregated usage statistics (e.g., number of users accessing certain features, average session duration, feature adoption rates), provided that such data does not enable identification of any individual; Technical and device-related information (e.g., device type, operating system, browser type, general system configurations), where such data is not linked to an identifiable individual; De-identified or anonymized analytics data (e.g., traffic patterns, performance metrics, latency and system logs), processed in a manner that prevents re-identification and subject to applicable law; High-level geographic or demographic insights (e.g., country-level usage distribution), where no individual can be identified; Aggregated business or performance data derived from user activity (e.g., trends, benchmarks, or statistical models), provided such data does not relate to an identifiable person.

 

Where we process Personal Data to create anonymized or aggregated datasets, we will implement measures designed to prevent re-identification. To the extent such data does not constitute Personal Data under applicable law, we may use it for legitimate business purposes, subject to applicable law.

 

Personal Data

 

We may also collect from you, directly or indirectly, during your access or interaction with the services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below. If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

 

The table below describes the categories of Personal Information we may collect and the purposes for which we collect and use it.

 

CATEGORIES OF PERSONAL INFORMATION

PURPOSES OF COLLECTION AND USE

 

Contact, Inquiry and Customer Support Information

 

When you contact us through the Website, Platform, email, telephone, text message, or other communication channels, we may collect your name, email address, telephone number, the contents of your communication, and any other information you choose to provide. We use this information to respond to inquiries, provide customer support, communicate with you, maintain records of our interactions, improve our operations, and establish, exercise, or defend legal claims.

 

Account and Profile Information

 

When you create or use an Account, we may collect information such as your name, email address, telephone number, address, username and password, date of birth, gender, Medicare plan type and number, picture and other profile information. We use this information to create and administer your Account, authenticate you, personalize the Services, manage your preferences, communicate with you, provide support, and operate and secure the Platform.

 

Health, Medicare, and other Provided Information and Sensitive Personal Information

 

When you use the Services, we may collect information you provide through chat or voice interactions and transcripts, including medical and health-related information, insurance information, Medicare plan details, and any other information you voluntarily provide. Such information may be considered sensitive under applicable law. To the extent that any information you provide constitutes “consumer health data” under applicable state consumer health data laws, we will obtain any consent required by those laws through the Platform interface before collecting or processing such data. You provide this information voluntarily in order to receive a personalized service. The Services may also generate outputs based on the information you provide, including summaries, risk or urgency indications, action lists, topics for discussion with your healthcare provider, and general information about coverage and rights (“AI-Generated Outputs”). We use this information, together with AI-Generated Outputs, to provide, personalize, and improve the Services, maintain continuity between sessions, facilitate a handoff to a licensed agent or FMO at your request or with your consent, and keep appropriate records. We use Sensitive Personal Information only as reasonably necessary to provide the Services you request, maintain security, prevent fraud, comply with law, or for other purposes permitted under applicable law.

 

Information Received from Third Parties

 

We may receive Personal Information from service providers, advertising and analytics partners, social media platforms, integrated applications, vendors, third-party authentication providers (such as Google and Clerk), Field Marketing Organizations (“FMOs”), licensed insurance agents, and other third parties with which you or Navigage interact. For example, if an FMO transfers information about you to our system, we will process it in accordance with this Policy. We may combine this information with information collected directly from you or through your use of the Website, Platform, or Services. We use such information for the purposes described in this Policy, including to provide, personalize, secure, analyze, and improve the Services.

 

If you choose to register and sign in to the Platform using a third-party authentication provider, such as Google or Clerk, we will collect the Personal Information made available to us by such third party, including your name, email address, profile picture, and account identifiers, subject to such third party’s privacy policy. We use this information to create and authenticate your Account, enable single sign-on, and maintain the security of your login credentials.

 

Artificial Intelligence and Generated Content Data

 

The Services use generative artificial intelligence or machine learning tools, such as Anthropic (Claude) or OpenAI, to process the information you provide and generate responses, summaries, risk or urgency indications, action lists, other outputs and to perform the requested Services, provide personalized assistance, monitor quality and security, and develop, improve, and enhance our Services and AI-supported features. We always make sure, by contractual means, that our external AI and LLM providers are forbidden from using your Personal Data for training their products. Separately, Navigage may use aggregated, de-identified, or otherwise minimized information derived from your use of the Services for its own analytics, research, development, and improvement purposes. We may also engage other third-party AI service providers to process such information on our behalf, subject to appropriate contractual and security safeguards. We do not use AI to make automated medical decisions, coverage determinations, or enrollment decisions; any such output is an automated indication only and requires independent verification by a qualified professional or an official authorized source.

 

Information About Other Individuals

 

You may provide Personal Information about or on behalf of other individuals in connection with the Services. This may include names, contact details, dates of birth, health-related information and any other information relevant to your inquiry. We use this information only as reasonably necessary to provide the Services you request.

 

If you provide us with Personal Information relating to another individual, you represent that you are authorized to provide such information and that such individual has been informed, to the extent required under applicable law, that their information may be collected and processed by us.

 

Voice and Audio Information

 

If you use voice-based interaction features of the Services, we may collect and process audio recordings and/or transcripts of your voice interactions, subject to the permissions you grant through your device or browser settings. We use this information to process your requests, provide the Services, and, where applicable, improve speech recognition and the quality of our AI-supported features.

 

Payment and Billing Information

 

The Services are currently offered free of charge, and we do not collect payment information. If we introduce paid features in the future, we may collect billing information, payment method details, including credit card, debit card, or bank account information and transaction history as necessary to process payments, maintain financial records, and prevent fraud. Such processing may involve third-party payment processors.

 

Platform Activity and Service Records

 

We may collect information about your use of the Platform and Services, including chat sessions, queries submitted, AI-Generated Outputs, session history, account settings, preferences, support inquiries, and records of Services provided. We use this information to provide, operate, manage, and personalize the Services, respond to inquiries, send service-related communications, reminders, and notifications, maintain continuity, support and secure the Services, conduct analytics, research, development to improve the Services, resolve disputes, maintain records of our relationship with you, and comply with applicable law.

 

Device, Online Identifier and Tracking Information

 

When you access or use the Website, Platform, or Services, we and our service providers may automatically collect information such as your IP address, IDFA, Google Advertising ID, IMEI or other device identifiers, browser type and language, operating system, device characteristics, network information, referring and exit pages, pages or features viewed, session activity, clickstream data, timestamps, approximate location, ETags, browser fingerprinting information, and information generated through recognition technologies designed to recognize or associate browsers, devices, or users. We use this information to operate, authenticate, secure, troubleshoot, analyze, and improve the Website, Platform, and Services; prevent fraud and misuse; remember preferences; measure performance and marketing effectiveness; and, where applicable, support targeted or interest-based advertising.

 

Cookies and Similar Technologies

 

We and our analytics, advertising, and technology partners (to the extent operated by us) may collect information through cookies, pixels, web beacons, embedded scripts, local storage, and similar technologies. This may include online identifiers, device information, browsing activity, interactions with the Website, and information about advertisements or content viewed. We use this information for Website functionality, security, analytics, personalization, advertising, retargeting, and measuring campaign performance, as further described in the Cookies section below.

 

Location Information

 

We may collect approximate location derived from an IP address and, if you enable location services or request location-based Services, precise geolocation information from your device. We use this information to provide location-based Services, personalize recommendations, support requested tasks, prevent fraud, and improve the Services. You may disable precise location access through your device settings, although doing so may affect certain Services.

 

Marketing and Communications Information

 

We may use your name, email address, communication preferences, account information, and information about your relationship with us to send operational, transactional, and service-related communications and, subject to applicable law, marketing and promotional communications. These may include service updates, reminders, newsletters, event invitations, offers, and information about new features or services. You may opt out of marketing emails through the unsubscribe link and of marketing text messages by replying “STOP.” You may continue to receive communications necessary to administer your Account or provide the Services.

 

Recruitment Information

 

If you apply for a position with Navigage, we may collect your name, contact details, residential address, CV, references, and other information you choose to provide or that is reasonably necessary for the recruitment process. We use this information to evaluate your application, communicate with you, verify qualifications, conduct the recruitment process, comply with legal obligations, and maintain appropriate recruitment records.

 

Please note that the actual processing operation for each purpose of use detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction.

 

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the services and to enforce the Terms, as well as to protect the security or integrity of our databases, services, and the website, and to take precautions against legal liability.

 

Please note that the Services perform automated analysis and generate inferences and recommendations, but do not make automated medical decisions, coverage determinations, or enrollment decisions. Platform’s outputs may include automated indication, and are not a substitute for independent professional judgment.

 

3. HOW WE COLLECT YOUR INFORMATION:

 

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

 

• Provided by you or about you voluntarily – we will collect information if and when you choose to provide us with the information, such as through the contact form, chat interface, voice interaction or other input methods.

• Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies (such as pixels, tags, agent, etc.) to gather some information automatically through the use of our services.

• Provided from third parties – from service providers, analytics and advertising partners, social media platforms, integrated applications and accounts, vendors, third-party authentication providers (such as Google and Clerk), Field Marketing Organizations (FMOs), licensed insurance agents, analytics providers, relevant caregivers and family members, and other third parties with which you or Navigage interact. Where permitted by applicable law, we may combine information received from third parties with information collected directly from you or through your use of the Website, Platform, or Services.

 

4. COOKIES

 

When you access or use our services, we may use “cookies” or similar tracking technologies, which store certain information on your device (i.e., locally stored). The use of cookies is standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies are used by us for various purposes, including allowing you to navigate between pages efficiently, and for statistical and analytic purposes. You can find general information about cookies here: www.allaboutcookies.org.

 

Advertising, retargeting, cross-context behavioral advertising, and related advertising or tracking technologies, if used, are limited to Navigage’s public-facing Website and are not deployed within the Platform or Services. Navigage does not disclose to Advertising Partners, or use for advertising, retargeting, marketing profiling, or the creation of advertising audiences, any information submitted or generated through the Platform or Services, including chat or voice content, Consumer Health Data, Sensitive Personal Information, Medicare or insurance information, and AI-Generated Outputs.

 

Analytics technologies used within the Platform or Services are limited to operational, security, performance, and service-improvement purposes and are configured to avoid the collection or disclosure of identifiable medical or health-related content. Such content will be processed through analytics technologies only where strictly necessary to provide, secure, or troubleshoot a Service requested by the user, subject to appropriate safeguards and as otherwise permitted by applicable law. Navigage does not permit Advertising Partners to collect Consumer Health Data over time or across websites or online services.

 

We use a third-party analytics provider, acting as our service provider, to understand how the Platform is used. This provider sets a first-party cookie when you access the Platform, which collects information such as pages viewed, interactions, device and browser information, and IP address. It does not collect identifiable medical or health-related content. This cookie remains on your device for a limited period, unless you delete it sooner. You can block or delete cookies through your browser settings. Blocking cookies will not affect your ability to use the Services.

 

There are several types of cookies, including without limitation:

 

• Essential, Functionality, Operation & Security Cookies. These cookies are essential for enabling visitor movement around the website, for the website to function properly, and for security purposes (i.e., used to authenticate visitors, prevent fraudulent use, and protect visitor data from unauthorized parties). This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work.

• Analytic, Measurement & Performance Cookies. These cookies are used to collect information about how visitors use our website, in order to improve our website, content, and the way we offer them, as well as assess the performance of the content and marketing campaigns. These cookies enable us, for example, to assess the number of visitors who have viewed a certain page as well as their country of origin. It enables our website to remember information that changes the way it behaves or looks, such as your preferred language.

• Preference, Targeting & Advertising Cookies. These cookies are used to advertise across the internet and to display relevant ads tailored to visitors based on the parts of the website they have visited (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).

 

You may find more information about the cookies we use as well as opt-out from cookies or change your preferences at any time by using the cookies setting tool available on the footer of our website.

 

Where we use third-party advertising cookies on the Website, those third parties may collect information through cookies and similar technologies and combine it with information collected across other websites or services in order to provide targeted or interest-based advertising and measure campaign performance. Their processing of Personal Information may also be governed by their own privacy policies.

 

Our use of certain advertising and tracking technologies on the Website may constitute a “sale,” “sharing,” or processing for targeted advertising under applicable U.S. privacy laws. If we choose to do so, we will always do hat after verifying it conforms with applicable law. You may opt out through the cookie settings tool available on the Website and through any other methods described in this Policy or our applicable state privacy notices. Opting out will not necessarily prevent you from seeing advertisements, but they may be less personalized.

 

For IBA opt out options on desktop and mobile websites, please visit:

 

• Digital Advertising Alliance (US) https://www.aboutads.info/choices/

• Network Advertising Initiative https://optout.networkadvertising.org/?c=1

 

Where required by applicable law, we recognize and process supported browser-based opt-out preference signals, including the Global Privacy Control (“GPC”) and other legally recognized Universal Opt-Out Mechanisms, as requests to opt out of the sale or sharing of Personal Information or its use for targeted advertising.

 

Do Not Track Disclosures: Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity. As of the effective date of this Policy, there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to DNT browser signals. However, as noted above, where required by applicable law, we will honor GPC signals as requests to opt out of the sale or sharing of Personal Information. You can learn more about Do Not Track at https://allaboutdnt.com.

 

5. DATA SHARING:

 

We may share your data with third parties, including our partners or service providers that help us operate and provide our services. You can find here information about the categories of such third-party recipients.

 

Categories of Recipients

Additional Information

 

Our Affiliated Companies

 

We may share Personal Data with our affiliated companies and subsidiaries in order to provide joint services, for example, marketing, improving our services, etc. Some of our affiliated companies or subsidiaries and their employees may not be located in the US.

 

Our Service Providers

 

We share your Personal Data with our trusted service providers and business partners that perform business operations for us on our behalf (as service providers) and pursuant to our instructions.

 

This includes the following categories of service providers:

 

• Advertising and marketing service providers, who help us with advertising measurements, email marketing, etc.;

• Data storage providers, with whom we entrust the hosting and storage of our data (e.g. AWS);

• General IT and SaaS providers – providing us with IT systems for the management of our daily conduct;

• Payment Processors – which may be used by us for processing of any Premium Services Fees;

• Data analytics and data management providers, who help us improve, personalize and enhance our operations;

• Data security partners, who help us detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches and ensure compliance with legal obligations.

• AI and machine learning service providers, who help us provide and improve our personal assistant features (e.g. Anthropic (Claude));

• Communications service providers, who help us deliver text messages and other communications to you (e.g. SendGrid);

• Third-party Authenticators, such as Google and Clerk, for identity management, authentication, and sign-in services.

 

Licensed Agents and Field Marketing Organizations (FMOs)

 

If you request or consent to be connected with a licensed insurance agent or FMO, we may disclose the information reasonably necessary to facilitate that contact (such as your name, contact details, and general plan inquiry). We will not share the medical information you provided us unless you separately consent to it. After the transfer, the agent or FMO may act as an independent controller of your information, and their continued use of your information will be governed by their own privacy policies. We do not sell databases of Personal Information or consumer health data. Any compensation Navigage receives from a third-party provider is a referral fee or similar commission in connection with a referral or transaction. Whether a referral or transaction constitutes a sale or sharing of Personal Information depends on applicable law and the arrangement. Where required, we will obtain separate consent or authorization before the disclosure and honor applicable opt-out rights.

 

Legal and Law Enforcement

 

We may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other visitor to legal liability, and solely to the extent necessary to comply with such purpose.

 

Corporate Transactions

 

In the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation, or asset sale) we will share the Personal Data we store with our acquiring company.

 

In any such case, we will oblige the acquiring company to assume the rights and obligations as described in our Privacy Policy.

 

When we share information with service providers, we ensure they only have access to such information that is strictly necessary for us to operate the services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations.

 

6. DATA RETENTION:

 

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you exercise your right for erasure, where applicable.

 

The circumstances in which we will retain your Personal Data include: (i) where we are required to do so in accordance with legal requirements, or (ii) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data, or (iv) for security purposes and backups, or (v) where the data has been anonymized. When you close your Account and request deletion, we will delete your Personal Data subject to these exceptions. Personal Information already transferred to an independent controller, such as a licensed agent or FMO, will remain subject to that party’s own privacy policy. Except as required by applicable law, we will not be obliged to retain your data for a particular period, and we may delete it for any reason and at any time, without providing you with prior notice of our intention to do so.

 

7. SECURITY MEASURES:

 

We take great care in implementing physical, technical, and administrative security measures for the website and services, that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

 

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email.

 

8. INTERNATIONAL DATA TRANSFER:

 

Due to our business operations, we may store or process your Personal Information in the United States and other countries. Your Personal Information may be transferred to and processed in countries other than the country from which you accessed our website or otherwise the country of your jurisdiction. We will take appropriate measures to ensure that your Personal Information receives an adequate level of data protection upon its transfer in accordance with applicable law.

 

In addition, some of the third parties used for cookies management on our website may store and process data globally, including in the US (e.g., Google Analytics servers). When granting consent for such cookies, you hereby acknowledge and approve such cross-border transfer, in accordance with such third party’s privacy practices.

 

9. YOUR RIGHTS

 

Applicable data protection and privacy laws may grant you certain rights with regards to your Personal Information. The rights may include one or all of the following: (i) request to correct inaccurate Personal Information we store; (ii) review and access your Personal Information that we hold; (iii) request to close you account and delete your Personal Information that we hold (subject to certain exceptions); (iv) opt-out of the sale or sharing of your Personal Information for cross-context behavioral advertising or its use for targeted advertising; (v) limit the use of your Sensitive Personal Information; (vi) withdraw any consent you have previously given, including consent to process consumer health data; (vii) receive information about the third parties with which your consumer health data has been shared; and (viii) the right to non-discrimination for exercising your privacy rights. We will not discriminate against you for exercising any of your privacy rights.

 

To exercise any privacy right available to you under applicable law, please contact us at info@navigage.ai and identify the right you wish to exercise. We may request additional information reasonably necessary to verify your identity and process your request.

 

We do not control third parties' method of collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website at https://optout.networkadvertising.org/?c=1.

 

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

 

In certain circumstances, and subject to applicable US Privacy Laws, you may permit an authorized agent to submit requests on your behalf.

 

You always have the right to make a data protection complaint directly to us if you believe that we have infringed applicable data protection law in connection with your Personal Data. You may submit such complaint by contacting us at info@navigage.ai or through our Data Subject Request form. We will always take appropriate steps to review and respond to your complaint without undue delay, including by making appropriate enquiries and keeping you informed of the progress and outcome of the complaint within the timeframes set by applicable law.

 

Responding to US Data Rights Requests:

 

For U.S. residents exercising data privacy rights, we endeavor to confirm receipt of all requests within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at: info@navigage.ai to ensure we received your request.

 

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt, or as otherwise required by U.S. Privacy Laws. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If we cannot comply with your request or any portion of your request, our response will explain the reasons we cannot comply.

 

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm that the Personal Information relates to you.

 

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. You do not need to create an account with us to exercise your privacy rights.

 

Appeals:

 

If we decline to take action on your request, we will notify you within the period required by applicable law, explain the basis for our decision, and, where applicable, provide instructions for submitting an appeal. Our response will include a justification for the decision and an explanation about your right to lodge an appeal. If you wish to do so, please send your appeal request with a summary of the request and decision you want to appeal to: info@navigage.ai.

 

If you are not happy with our response, depending on your jurisdiction, you may have the right to lodge a complaint against us with the relevant State’s Attorney General. If you do not have your Attorney General’s contact information, please contact us at info@navigage.ai, and we will endeavor to provide the relevant information to you.

 

10. VISITORS TO THE SITE OUTSIDE OF THE UNITED STATES:

 

Our services are offered and Provided in the US. If you are visiting the website from a location outside of the US, your connection will be through and to servers located in the US. All information you receive from the website will be created on servers located in the US, and all information you provide will be maintained on web servers and systems located within the US. The data protection laws in the US may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the US according to laws of the US.

 

11. USE OF AI TOOLS

 

Our Services use external generative artificial intelligence and machine learning tools, including services like Anthropic (Claude) or OpenAI (“AI”), in many ways. We use AI to help perform the Services requested, build new features, improve the website and Services, and provide new services to users. When you use our Services, AI may process your Personal Information to provide personalized assistance, generate responses to your queries, summaries, generate risk or urgency indications, action lists, and other AI-Generated Outputs. Anthropic processes your information on our behalf solely to generate the applicable response and is subject to contractual restrictions on its use of such data. Separately, Navigage may use aggregated technical usage and performance data, subject to the limits described above for Non-Personal Data, for its own analytics, research, development, and improvement purposes.

 

12. THIRD PARTY WEBSITES:

 

Our Privacy Policy only addresses the use and disclosure of Personal Data we collect from you. To the extent that you disclose your Personal Data to other parties via the website (e.g., by clicking on a link to any other website or location), different rules may apply to their use or disclosure of the Personal Data you disclose to them, and this Policy does not apply to any such third-party products and services.

 

We use Google Sign-In and Clerk for account authentication and sign-in. Use of these services is subject to the applicable third party’s own terms and privacy policy. If you are connected with a licensed insurance agent or FMO, that party’s use of your information after we connect you, is governed by its own privacy policy, not this Policy.

 

13. ELIGIBILITY AND CHILDREN PRIVACY:

 

Our Services are not directed nor intended for use by children. We do not knowingly collect Personal Information directly from children under the age of 18 and we do not solicit any information from any child directly. If we become aware that we have collected Personal Information from a child under 18 without appropriate parental or guardian consent, we will take steps to delete that information.