Navan Candidate Privacy Notice
LAST UPDATED: FEBRUARY 7th, 2023
Introduction
Navan, Inc. (“Navan,” “we,” “us,” and “our”) values your trust and is committed to protecting your Personal Information. This Notice describes our practices in connection with the information that we collect through the jobs section of our website (located at https://navan.com/job-openings) (“Jobs Site”) and offline in connection with your application for a job or internship with Navan, Inc. or one of our affiliates. Personal Information submitted elsewhere on Navan’s and its affiliates’ web sites will be used in accordance with our general online Privacy Policy.
What Personal Information is Collected?
Personal Information is any information that relates to an identified or identifiable individual. In connection with your application, we collect, use, and store the following categories of Personal Information about you:
Contact information (such as name, address, email address, and telephone number);
Experience information (such as title, education, skills, work experience, curriculum vitae (CV), references, employee records and appraisals);
Demographic information (such as date of birth, gender, nationality);
Interview records;
Work authorization status;
Other information necessary for making a recruitment decision or otherwise voluntarily provided by you (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships).
Any information you submit must be true, complete and not misleading. Submitting inaccurate, incomplete, or misleading information may lead to a rejection of your application during the application process or disciplinary action including immediate termination of employment. In addition, it is your responsibility to ensure that information you submit does not violate any third party’s rights.
If you provide us with Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the Personal Information to us.
Diversity and Sensitive Personal Information
Navan is an equal opportunity employer, which means we offer equal treatment to all applicants. We do not discriminate, either directly or indirectly, on protected grounds: race, colour, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, or genetic information in any area of recruitment.
In certain cases, we will ask questions about race/ethnic origin, gender, and disability of our applicants, for monitoring equal opportunity. We may also inquire about criminal records. We will do so only where permitted by applicable law. Otherwise, we ask that you avoid submitting information that may qualify as sensitive Personal Information under applicable law, except where such information is legally required. Sensitive Personal Information includes race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, veteran status, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings.
How is your personal information collected?
For the purpose of background check reports in connection with your application, and as permitted by applicable law, we collect Personal Information about candidates from the following sources:
You, the candidate.
Your named references and prior employers, from whom we collect the following categories of data: full name, periods of previous employment, performance during previous employment.
Educational institutions you attended.
Publicly accessible sources, such as LinkedIn, etc., where we collect your name, email, work history, and other data included in your profile.
Third-party providers of background checks, as permitted by applicable law.
How Navan uses your Personal Information
We use Personal Information for reasons related to your application. Specifically, we collect and use Personal Information used for global personnel recruitment, management and planning purposes, as permitted by applicable law to:
Process your application.
Assess your skills, qualifications, aptitude, and suitability for the position.
Complete reference checks, where applicable.
Conduct background checks if we offer you a position.
Communicate with you about the application process and/or your application.
Keep records related our hiring process.
Comply with legal or regulatory requirements.
The Personal Information in the application process is required by Navan to assess your application for employment. We collect and use Personal Information to comply with our legal obligations and to serve Navan’s legitimate interest to hire qualified and appropriate people. Providing Personal Information to us through the Jobs Site is voluntary. If you do not provide some or all of this Personal Information, however, it may affect our ability to process your application and, therefore, to enter into an employment agreement with you. Where the collection or processing is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law.
The Personal Information about you will be added to our international candidate database and can be retained and used to consider you for opportunities at Navan, Inc. and its affiliates other than the one(s) for which you apply. If you do not wish us to do this, please contact us at the address in the “Contact Us” section below.
If we hire you, Personal Information we collect in connection with your application can be incorporated into our human resources system and used to manage the new-hire process; any such data can become part of your employee file and used for other employment-related purposes.
How we use sensitive Personal Information
We will use your sensitive Personal Information only insofar as we are permitted by law.
We use Personal Information about a disability status to consider whether we need to provide appropriate accommodations during the application process such as during an interview.
We use Personal Information about your nationality to assess whether a work permit and a visa will be necessary for the role.
How we disclose and transfer your personal information
Navan limits access to your Personal Information to personnel with a business need-to-know for the reasons listed above, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying. We share Personal Information with affiliates that are involved in evaluating candidates for a given position.
Navan also shares Personal Information with our third-party service providers to facilitate services they provide to us, including hosting and operating the Jobs Site, recruiting assistance, and background check processing.
Disclosing your Personal Information can include transferring Personal Information to other countries, including the United States or any other country in which we or our service providers have operations, which may include countries outside of the European Economic Area (“EEA”). Some non-EEA countries are recognized by the European Commission as providing adequate level of data protection according to EEA standards (the full list of these countries is available here.) For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us using the address in the ‘Contact Us’ section below.
Other uses and disclosures of personal information
We use and disclose Personal Information as necessary or appropriate: (i) to comply with applicable laws and regulations which may include laws outside your country of residence; (ii) to protect the rights, privacy, safety, and property of you, others, or Navan, and to enforce our Terms of Service; (iii) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities (including national security requests), which may include authorities outside your country of residence; and (iv) in the event we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, or disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Security of Your Personal Information
We maintain commercially reasonable technical and organizational measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately. To the fullest extent permitted by applicable law, we hereby disclaim any liability for Navan, Inc. and its affiliates and contractors for any Personal Information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not timely delivered to our Jobs Site.
Retention of Personal Information
We will retain Personal Information as long as necessary to satisfy the purposes outlined in this Notice, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods are: (i) the duration of the application process; (ii) as long as we have an ongoing relationship with you; (iii) as required by a legal obligation to which we are subject; and (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
We may remove Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we can delete Personal Information about you (including your CV/résumé) from our database at any time and without providing any reason. Therefore, please retain your own copy of the Personal Information provided to us.
Individual Choices, Access, and Rights
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that Personal Information to another company (the “right of data portability”); (iv) restrict or object to our uses of your Personal Information; (v) seek correction of inaccurate, untrue or incomplete Personal Information; (vi) withdraw your consent; and (vii) request erasure of Personal Information held about you by Navan, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable law. To protect your privacy, Navan may take steps to verify your identity before fulfilling your request. In your request, please make clear what Personal Information you would like to access or have changed, whether you would like to have Personal Information that you have provided to us suppressed from our database. Please note that certain Personal Information may be exempt from such requests pursuant to applicable data protection laws or other laws and regulations.
Additional Information for the EEA
You may contact our Data Protection Officer at dpo@navan.com. You may also lodge a complaint with a data protection authority for your country or region where you have your residence, place of work, or where an alleged infringement of applicable data protection law occurs.
Links to other websites
This Notice does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Jobs Site links. The inclusion of a link on the Jobs Site does not imply endorsement of the linked site or service by Navan, Inc. or our affiliates.
Law applicable to Job Application
The Jobs Site allows you to apply for jobs worldwide, as a benefit of Navan’s centralized global recruitment function. This Jobs Site is operated from the United States. Accordingly, any Personal Information you submit to the Jobs Site will be collected in the United States and will be subject to U.S. laws. However, if we share your Personal Information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your Personal Information in accordance with this Notice. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.
About Minors
The Jobs Site is not intended for minors under the age of 18.
Current Personnel of Navan
If you currently work for Navan, Inc. or one of our affiliates, you must be eligible to apply for a different position within Navan to use the Jobs Site. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.
The Jobs Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.
Changes to our Privacy Notice and Practices
We may revise this Privacy Notice at any time in order to address reflect company developments, the changes to the Jobs Site, or changes in industry or legal trends. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Notice.
Contact Us
If you have any questions about our privacy practices or this Privacy Notice, please contact Navan by email at privacy@navan.com.
