Commercial Privacy Policy

Nave Bank is committed to treating, protecting, and using personal and financial information about you and your business responsibly. Nave Bank's Privacy Policy explains and sets out what information we collect, why we collect it, how we protect it, and how and why in certain cases we may share it among affiliates or with other parties. We also tell you how to exercise your information sharing and use choices.

For the purposes of this Privacy Policy, “We”, “our”, “us”, “Nave” and “Bank” means Nave Bank, its successors and assigns. “You” and “your” refers to the Commercial Customers, as defined below.

I. Scope

This Privacy Policy applies to Company Information (as defined below) about individuals and businesses or other entities that seek or obtain financial products and services from Nave for business or commercial purposes and in whose name the Account is held (“Commercial Customers”).

This policy applies to all personal and company data we collect and use when you interact with us in a business context, and/or any information about a Commercial Customer from which the Commercial Customer could be identified, whether obtained directly from the Commercial Customer or from another source. For the purpose of this policy, “Company Information” may include, but is not limited to:

1. company name;
2. date of incorporation;
3. physical and postal addresses, including street name and name of city or town;
4. email address or other electronic contact information;
5. telephone number;
6. tax identification number;
7. merchant registration number provided by the PR Treasury Department;
8. credit history;
9. account balance, transaction history or any information related to the Account(s);
10. bank or credit card account number, payment card details, and/or purchase order numbers
11. financial statements;
12. information about officers, directors, and other control persons.

II. How we collect Company Information

We may gather and retain Company Information about Commercial Customers from the following sources:

1. Directly from you; information you provide when opening an account with us.
2. From other sources, like information from financial institutions and credit agencies.
3. Automatically from your use of our products and services, like data associated with using our network (such as cookies, usage and transaction history, and other technical data that we use for security purposes and to enhance the online experience).
4. Information from your interaction with our social media pages, information provided from entering a promotion or survey organized by us, or otherwise providing us with feedback, and/or information provided from subscribing to our services or publications, or otherwise requesting marketing material to be sent to you.
5. Information we receive from third parties such as data providers or independent researchers.

III. How we use Company Information

We collect Company Information for the following purposes:

1. To provide the products and services you have requested and perform our contractual obligations.
2. To process orders, payments, and account adjustments.
3. To administer the owner's account (such as the employer).
4. To verify your identity.
5. To contact you.
6. To conduct research and create reports from analysis of usage patterns and trendsM
7. To create market reports
8. To detect and help protect against security incidents and illegal, fraudulent, or unauthorized activities; investigate suspicious traffic, cybersecurity threats or vulnerabilities, complaints, and claims; authenticate your credentials for account access and information and provide other security protections.
9. To protect you and others from fraudulent, malicious, deceptive, abusive, or unlawful activities.
10. To facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to local, state, or federal government requirements.
11. To cooperate with law enforcement and protect the rights, interests, safety, or property of Nave and others.
12. To verify that there does not exist any conflict of interest, prohibition, or government regulation which restricts us from doing business with you.
13. To enforce our policies, terms and conditions, or other agreements.
14. To allow us to analyze, develop, improve, and optimize the use, functionality, and performance of our sites or products, services, and/or the responsiveness of our staff to potential customer inquiries.
15. For marketing and analytics purposes.
16. To provide technical support and customer service.
17. To comply with, defend, pursue and enforce applicable legal and regulatory obligations and respond to governmental requests.

We do not collect any Company Information for the purpose of selling it to third parties. However, please note that Nave could sell loans and other obligations to third parties for a variety of reasons. Consent of Commercial Customers, guarantors, or borrowers is not required, and notice will not be provided in the event of a sale of any loan or other obligation to a third party.

IV. Who we share Company Information with

Company Information covered by this Privacy Policy is exclusively processed for the purposes referred to above and will be shared within the following categories of recipients:

1. Among and between all of our affiliates;
2. Authorized third party agents, service providers, external auditors and/or subcontractors of Nave;
3. A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation or as permitted by applicable local law;
4. Analytics providers;
5. Advertising networks; or
6. As necessary or appropriate to enforce our terms and conditions, and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

V. How we protect Company Information

We maintain administrative, physical, procedural, and technical safeguards, as required by law, designed to protect Company Information against loss, misuse, damage and unauthorized access or disclosure while in our possession.

You are entirely responsible for maintaining the confidentiality of your account information, including your password, and for all activity that occurs under your account. You should also use multi-factor authentication where possible. We cannot guarantee that information transmitted through the Internet is secure, or that such transmissions will be free from transmission, computer viruses, malware, system failure, delay, interruption, interception or error.

VI. Changes to Privacy Policy

We keep this privacy policy up to date. When we make changes, we'll let you know by updating this notice and including the date of the update at the top of this page.

VII. Application

This privacy policy will apply to all affiliates of Nave Holdings Inc., now existing or hereafter arising.

VIII. Contact Us

If you have any questions regarding this Privacy Policy, please contact us at 787-802-8282 or via email at help@navebank.com