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NAVAN PRIVACY POLICY

Last Updated August 24, 2023

Navan, Inc. and its affiliates (collectively, “Navan,” “we,” “us,” and "our")
respect your privacy. We are a travel management platform that helps companies
manage all of their corporate travel and expense management in one place as
described in our Terms of Service. “You” may be a visitor to one of our
Websites, a corporate customer of one or more of our Services (“Corporate
Customer”), or an employee, traveler, or guest of a Corporate Customer
(“Corporate Users”), or an independent business traveler ("Independent User").

This Privacy Policy describes the types of Personal Information we collect
through our main website at navan.com (“Website”) and through our travel
products and services that we provide to Corporate Customers, Corporate Users,
and Independent Users (“Services”). This Privacy Policy also describes how we
use Personal Information, with whom we share it, your rights and choices, and
how you can contact us about our privacy practices.

* • Overview
* • Personal Information
* • How We Collect Personal Information
* • How We Use Personal Information
* • How We Disclose Personal Information
* • Your Rights and Choices
* • United States Privacy Practices
* • Security and Retention
* • Links to Other Websites
* • Use of Services and Website by Minors
* • Sensitive Information
* • Jurisdiction and Cross-Border Transfer
* • International Privacy Practices
* • Updates to This Privacy Policy
* • Contact Us

OVERVIEW

Navan obtains Personal Information about you from various sources to manage our
Website and provide our Services. There are two primary ways you may interact
with Navan online.

WEBSITE VISITORS

Our Website at navan.com is publicly available and allows visitors to learn more
about Navan, request a demo, submit questions, join a discussion thread on our
community pages, and contact us. Personal Information may be collected through
webforms where you type in your information, comments you choose to post on our
community discussion boards, or automatically using tracking technologies, like
cookies.

NAVAN SERVICES

Our Services include our web application at app.navan.com and Navan mobile
applications made available by us. The web application and our mobile
applications (collectively, our “Apps”) provide the ability to search for and
book travel, access traveler support, trip consolidation, as well as corporate
administrative functionality including real-time reporting, traveler tracking,
spend reconciliation, travel continuity, and traveler customer support. Navan
Expense, a payments and expense application, provides the ability to make travel
payments, track and submit business expenses, reconcile expense reports, link to
personal accounts for expense submittals and reimbursements, import
transactions, manage business expenses, and access customer support. These
Services are offered through a corporate subscription.

When you use our Services because one of our Corporate Customers (e.g., your
employer) has purchased the Services, and you use our Services to book business
travel or manage expenses, we collect, use, and disclose Personal Information
about Corporate Users acting in our capacity as a “processor” or “service
provider” to our Corporate Customers. Navan’s Corporate Customers are the
controllers of this Personal Information and responsible for making sure that
the Traveler’s privacy rights are respected, including ensuring appropriate
disclosures about third-party data collection and use are made. When we act as a
“processor” or “service provider” to our Corporate Customers, we process
Personal Information in accordance with our Corporate Customer’s lawful
instructions, the terms of the agreement we have with the Navan Corporate
Customer, and consistent with this Privacy Policy.

By contrast, when you use our Services to book personal travel (as opposed to
Navan Business Travel) or when you respond to one of our surveys, we collect,
use, and disclose Personal Information about Corporate Users acting in our
capacity as a “controller” or “data owner.” Our Corporate Customers do not have
access to the Personal Information you provide when you book personal travel,
unless you choose to share that information with your employer. Similarly, when
you use our Services as an Independent User, including booking independent
business travel unrelated to our Corporate Customers, we collect, use, and
disclose your Personal Information in our capacity as a “controller.” When we
act as a “controller,” we process Personal Information consistent with this
Privacy Policy.

As a travel management platform, our Services may share your booking information
with other parties to fulfill your travel reservations, including third-party
websites, services or applications. This Privacy Policy does not apply to
third-party websites, services, or applications, even if they are accessible
through our Services, and you should consider the privacy practices of those
third parties carefully.

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or
relates to an identifiable individual. The types of Personal Information we
collect vary according to your interactions with us, for example, depending on
whether you are a visitor to our website, a Corporate Customer of Navan, or an
employee of Customer using our Services. The Personal Information we collect
from our Corporate Customers or Corporate Users booking business travel or using
our payment services is “Corporate Customer Data,” and the Personal Information
we collect from our Website visitors, Corporate Users booking personal travel,
Independent Users, or otherwise apart from providing Services is “Other
Information.”

HOW WE COLLECT PERSONAL INFORMATION YOU PROVIDE TO US

Website Visitors. If you visit or use our Website, you can fill out web forms to
ask for a demo, sign-up for a newsletter, register for a Navan event or account,
or take a survey. The specific Personal Information you provide on these forms,
as well as any Personal Information you choose to provide on our community
discussion boards, will be treated as Other Information. For example, when you
respond to Navan emails or surveys, or create a user account to participate in
our community discussion boards, we collect your name, contact details, profile
photo, and any other information you choose to include in your email, survey
response, or account profile.

Navan Services. When you use our Services, the Personal Information that you
provide directly to us through our Services will be apparent from the context in
which you provide the data. You may provide Personal Information to us when you
book travel or use our expense management services. Personal Information may be
provided to us directly by you or others, such as our Corporate Customer (e.g.,
your employer), a designated travel admin, or a traveling companion, on your
behalf.

When you use Navan to register an account (“Account”) on our Services, we
collect Personal Information, such as name, email, postal address, telephone
number, financial data (payment card information and billing address), date of
birth, gender, and emergency contact information (optional). When you use our
Services for personal travel, we collect Personal Information such as your
personal payment card information, billing address, and your personal email
address. You may customize your travel profile by providing additional Personal
Information, such as passport data, marital status, travel preferences, Known
Traveler Number, TSA-Pre number, special meal preference, travel loyalty
programs, and COVID-19-related health data.

When you contact us for travel support through our chat feature on our Apps or
by telephone, we collect Personal Information to verify your identification and
help with your travel issue. In addition, we may record telephone calls between
you and our representatives for training and quality assurance purposes. To the
extent you may choose to provide us with feedback, suggestions, or
recommendations about your experience, we collect that information and treat it
as Other Information.

Other Methods. You may also choose to submit Other Information to us via other
methods, including in response to marketing or a survey, through social media or
online forums, through participation in an offer or promotion, or by giving us
your business card or contact details at trade shows or other events.

Information Automatically Collected

In addition to the information you provide when you visit our Website and use
our Services, we automatically collect Other Information about how you access
and interact with our Website and Services. This information is a key part of
how we improve your experience on Navan and provide you with personalized
insights, recommendations, and travel notices. These may include things like
cookies, browser web storage, web beacons, and similar technologies. These
technologies record information about your use of our Website and Services.

• Browser and Device Information. Certain information is collected by most
browsers or automatically through your device, such as your Media Access Control
(MAC) address, IP address for purposes of connecting, computer type (Windows or
Mac), screen resolution, operating system name and version, device manufacturer
and model, language, Internet browser type, add-ons, and version and the name of
the website or app you are using. We use this information to ensure that our
Website and Services function properly.

• Log Information. When you use our Website, certain information is
automatically collected in system logs about how you interact with our Website,
such as your online activity, search terms, pages you visit, date and time of
access, and cookie information, such as mouse clicks and keystrokes. This
information is used to improve your experience on our Website and keep the
Website free of bugs or errors. When you use our Services, we also may collect
information about your online activity, such as trips viewed, travel
reservations made, and other actions within our App. When you download and use
one of our Apps, we and our service providers may track and collect App usage
data, such as the date and time the App on your device accesses our servers and
what information and files have been downloaded to the App based on your mobile
device's identifier.

• Cookies. Navan uses a variety of cookies and similar technologies on our
Websites and Services to help us collect Other Information. For more details
about how we use these technologies, and your opt-out opportunities and other
options, please see our Cookies Policy.

• Geolocation. When you use certain features of the Services, we may collect
certain information like IP address, device information, or log information to
estimate your location (e.g., city or state) and to offer you an improved user
experience and provide you with personalized location-based services, such as
identifying nearby hotels, airports, or merchants. For Navan Expense, you have
the option to share location information when uploading receipts. Most mobile
devices allow you to control or disable the use of location services for
applications in device settings menu.

Information From Third Parties

We may obtain and rely on Personal Information about you from third parties and
other sources, such as our business partners, Corporate Customers, and other
Corprate and Independent Users of our Services. For example, Navan Corporate
Customers may provide Personal Information about Corporate Users when they
create new Accounts for their employees or guests. Organizers of meetings and
events may share Personal Information when they are organizing Navan Group
Travel for attendees. Corporate and Independent Users may provide Personal
Information about their travel companions when booking personal travel. We may
also work with different third-party partners to supplement information we
collect directly from you.

As a travel management platform, when we conduct fraud monitoring, prevention,
and detection activities, we may also receive Other Information about you from
our business partners, financial service providers, identity verification
services, and publicly available sources as necessary to confirm your identity
and prevent fraud.

If you disclose any Personal Information relating to other people to us or to
our service providers in connection with our Services, you represent and warrant
that you have the authority to do so and to permit us to use the information in
accordance with this Privacy Policy and/or any other agreements we may have with
you.

HOW WE USE PERSONAL INFORMATION

We use the information we collect from you and third parties to operate our
Website and Services, communicate with you, conduct research and development to
improve our Website and Services, and promote our Services.

Navan Services for Corporate Customers. Navan uses Corporate Customer Data for
the purpose of providing our Services to Corporate Customers to enable their
employees to book business travel and manage expenses. Corporate Customer Data
will be used by Navan in accordance with Corporate Customer’s instructions,
including any applicable terms in our agreements with our Corporate Customers,
and as required by law. Navan is a processor of Personal Information and
Corporate Customer is the controller. Some examples of how we use Corporate
Customer Data:

• Account Information. To create, maintain, and secure accounts, including
customizing your travel profile.

• Reservations. To complete travel bookings, process your payments, provide
travel confirmations, provide notifications and updates, and verify your
information.

• Services Communications. To communicate with you regarding travel
interruptions, flight changes, delays, travel alerts and restrictions, and
cancellations; respond to inquiries and questions; and notify you of updates to
our Services, product updates, and service announcements. Communications may be
sent via email, push notifications, browser notifications, SMS, and postal mail.

• Payments and Expenses. To track and submit travel or other business expenses,
reconcile expense reports, link to personal accounts for expense submittal and
reimbursement, and manage expenses.

• Corporate Customer Support. To provide customer support when you contact us
via chat, telephone, or email. We use this Corporate Customer Data to verify
your identity and retrieve travel records related to your inquiries.

• Providing Personalized Services. To personalize your experience on our
Services, such as to curate booking recommendations, identify nearby hotels and
airports, record travel meal and seating preferences, and optimize search
results. We provide these personalized services in accordance with the terms of
our agreement with our Corporate Customer.

• Navan Digital Health Passport. To enable access to health documents required
to meet airline and state/country requirements for travel.

Navan Services for Corporate Users Booking Personal Travel and Independent
Users. Navan uses Other Information for the purpose of providing our Services to
Corporate Users booking personal travel and Independent Users booking their own
travel. Navan is the controller of Other Information and uses it, for example,
as follows:

• Account Information. To create, maintain, and secure accounts, in order to
manage our contractual relationship with you and/or to comply with a legal
obligation.

• Reservations. To complete travel bookings, process your payments, provide
travel confirmations, provide notifications and updates, and verify your
information, in order to manage our contractual relationship with you or to
comply with a legal obligation.

• Payments and Expenses. To track and submit travel or other business expenses,
reconcile expense reports, link to personal accounts for expense submittal and
reimbursement, and manage expenses, in order to manage our contractual
relationship with you, where we have a legitimate interest, or to comply with a
legal obligation.

• Traveler Support. To provide traveler support when you contact us via chat,
telephone, or email. We use Other Information to verify your identity and
retrieve travel records related to your inquiries. We engage in travel support
in order to manage our contractual relationship with you or where we have a
legitimate interest.

• Providing Personalized Services. To personalize your experience on our
Services, such as to curate booking recommendations, identify nearby hotels and
airports, record travel meal and seating preferences, customize your travel
profile, and optimize search results. We provide these personalized services
based on our legitimate interests, and with your consent to the extent required
by applicable law.

• Navan Digital Health Passport. To enable access to health documents required
to meet airline and state/country requirements for travel, in order to manage
our contractual relationship with you or to comply with a legal obligation.

Accomplishing Our Business Purposes. Navan uses Other Information in furtherance
of our legitimate interest in operating our Services, Websites, and business, as
well as to comply with our legal obligations. Our business purposes include:

• Data analysis to improve our Services, develop new products and services,
enhance, modify, and maintain our current products and Services, as well as
undertaking quality and safety assurance measures;

• Security of our Website and Services. To protect the safety, integrity of our
Corporate Customers and our Corporate and Independent Users, including
monitoring, detecting, and preventing fraud, cyberattacks, attempts to commit
identity theft, and unauthorized or illegal use of our Website or Services;

• Identification of usage trends. To better understanding which parts of our
Services are of most interest to users and focus our energies on meeting our
users’ interests;

• Determine the effectiveness of our promotional campaigns, so that we can adapt
our campaigns to the needs and interests of our users;

• Audits. To verify that our internal processes function as intended and to
address legal, regulatory, or contractual requirements;

• Aggregated reports. To analyze and/or predict preferences in order to prepare
aggregated trend reports on how our Website and Services are used, so we can
improve our Website and Services.

Legal compliance. We use Other Information to verify the identity of our
Corporate and Independent Users and Corporate Customers in order to comply with
fraud monitoring, prevention and detection obligations, laws associated with the
identification and reporting of illegal and illicit activity, such as AML
(Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial
reporting obligations. For example, we may be required to record and verify user
identity for the purpose of compliance with legislation intended to prevent
money laundering and financial crimes. These obligations are imposed on us by
the operation of law, industry standards, and by our financial partners, and may
require us to report our compliance to third parties, and to submit to third
party verification audits.

Marketing and Events-Related Communications. When you use our Website or
Services, we may use Other Information to send you marketing communications
about our Services, products and features, and other news about Navan. Marketing
communications may invite you to participate in our events, product demos, beta
program, or surveys. We will engage in marketing activities with your consent or
where we have a legitimate interest.

Emails from Navan with updates and offers when you opt-in to marketing. You can
choose to receive emails containing updates and offers tailored to your
interests, such as our newsletter. These emails contain offers for our own
services and services offered by our travel partners. With your consent, we will
also send you emails on specific occasions, such as a special offer on your
birthday or personalized offers for your next trip within a few months after
your return.

Navan Events. When you participate in trade shows or other events, we may
collect Other Information, such as your business contact details, to follow-up
with you regarding an event, offer a demo of our Services, send you information
that you requested, and, with your permission, include you on our marketing
campaigns.

Consent. We may use Personal Information for other purposes that are clearly
disclosed to you at the time you provide Personal Information or with your
consent.

Aggregated and De-Identified Personal Information. We may aggregate and/or
de-identify Personal Information such that it is no longer considered Personal
Information. We do so to generate other data for our use, which we may use and
disclose for any purpose, as it no longer identifies you or any other
individual. We engage in these activities based on our legitimate interest.

HOW WE DISCLOSE PERSONAL INFORMATION

We disclose your Personal Information in connection with providing our Services
and the operation of our business.

Navan. We share Personal Information with other Navan entities in order to
provide our Services and for internal administration purposes. These entities
are Navan Labs BV (Netherlands), Navan BV (Netherlands), Reed & Mackay Travel
Limited (UK), Navan Limited (UK), Comtravo GmbH, and Navan Pty Limited
(Australia).

Navan Corporate Customers. As a corporate travel management platform, we share
Corporate Customer Data, such as Traveler Personal Information related to
business travel, with the Corporate Customer who has made our Services available
to the user. Information may include business travel bookings and details,
business travel status, business expenses, profiles, current locations (based on
business travel itinerary), travel preferences, business payments and
transactions history. Only travel bookings designated as business are accessible
by the Traveler’s employer. If your employer has elected to establish Navan
Rewards, information related to your business travel will be shared with your
employer, such as traveler, booking, destination, travel dates, and pricing
information. Please note that the information we provide will be subject to the
receiving Corporate Customer’s privacy policy. We are not responsible for the
privacy and security practices of our Corporate Customers.

Service Providers. We share Corporate Customer Data and Other Information with a
limited number of our service providers. We have service providers that provide
services on our behalf, such as website hosting, data analysis, credit card
payment processors, billing services, business analytics, distribution of
surveys or sweepstakes programs, information technology and related
infrastructure, customer service, email delivery, identity verification,
auditing, and fraud protection.

Business Partners and Providers of Travel Services. We may share Corporate
Customer Data and Other Information with third-party business partners when this
is necessary to provide our Services. Third parties to whom we may disclose
Personal Information include airlines, hotels, rail, rental car companies,
travel networks and agencies in order to make the travel bookings you requested.
Please note that the business partners are typically third-party controllers and
that information we provide may be subject to and processed according to the
receiving third party’s privacy policy. If your booking is made via a
reservation system provider ("GDS"), it will be processed according to its
privacy policy available at http://www.iatatravelcenter.com/privacy. Where a
booking is made via the Amadeus GDS, to provide the services, your Personal
Information may be processed by Amadeus IT Group, S.A. You should read this
documentation, which applies to your booking and specifies, for example, how
your personal data is collected, stored, used, disclosed and transferred. We are
not responsible for the privacy and security practices of these third parties.

Your Choice to Disclose Personal Information. By participating in any community
discussion boards, blogs, or other services to which you are able to post
information and content, you may choose to disclose Personal Information. Please
note that any information you post or disclose through these services will
become public and may be available to other users and the general public.

Legal Compliance and Obligations. We share Personal Information as necessary or
appropriate (i) to comply with applicable laws and regulation which may include
laws outside your country of residence; (ii) to protect the rights, privacy,
safety, and property of our Corporate Customers, you, others, or Navan and to
enforce our Terms of Service; (iii) to collect amounts owed to us, and (iv) 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.

Corporate Transactions. We may disclose or transfer Personal Information to a
third party 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).

Underwriting/Risk management. We share Personal Information of our Corporate
Customers who are purchasing Navan services with third parties for the purposes
of setting credit limits and managing financial risk.

YOUR RIGHTS AND CHOICES

You have choices regarding our use and disclosure of your Personal Information.
You may opt out from:

• Receiving marketing-related emails from us. If you no longer want to receive
marketing-related emails from us, you may opt-out via the “unsubscribe” link
included in such emails. Please note that if you opt-out of receiving
marketing-related emails from us, we may still send you important administrative
messages that are required to provide you with our Services, from which you
cannot opt-out. We will try to comply with your request(s) as soon as reasonably
practicable.

• Receiving Travel Alerts from Us. You can manage your communication preferences
by visiting your Account Profile and then Settings. You can choose which types
of travel alerts to receive and the method for receiving the alerts. You may
also opt-out of SMS alerts in your Account Settings.

• Our Use of Certain Cookies. You can manage some of the cookies we use on our
Website and Services by visiting our Cookie Policy.

Accessing and Changing Your Personal Information. You may access, update,
correct, or delete your profile information and preferences at any time by
logging in to your Account through our Apps.

Your Data Protection Rights. In accordance with applicable law and depending on
where you reside, 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 information to
another company (the “right of data portability”); (iv) object to or restrict
our uses of your Personal Information; (v) seek correction or amendment of
inaccurate, untrue, incomplete, or improperly processed Personal Information;
(vi) withdraw your consent at any time, without affecting the lawfulness of
processing based on consent before its withdrawal; and (vii) request erasure of
Personal Information held about you by us, subject to certain exceptions
prescribed by law.

If you would like to exercise any of these rights, please email us at
privacy@navan.com or contact us as specified in the Contact Us section below. We
will respond to your request consistent with applicable law and as soon as
reasonably practicable. To protect your privacy, we will verify your request
using the information associated with your account, including email address.

Please note that if you use our Services on behalf of an organization that is
our Customer (e.g., your employer), that Customer may be responsible for
fulfilling the rights listed above.

UNITED STATES PRIVACY PRACTICES

US-Specific rules may apply to our processing of personal data of residents of
certain states in the United States. For information on United States Privacy
rules, please visit our United States’ Privacy policy.

SECURITY AND RETENTION

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.

We retain Personal Information for as long as needed or permitted in light of
the purpose(s) for which it was obtained and consistent with applicable law. If
you are a Corporate Customer or a Corporate or Independent User, we retain your
Personal Information as long as we are providing Services to you. We may retain
Personal Information and certain records of your transactions to the extent
necessary to comply with our legal and regulatory obligations. We may also
retain Personal Information in light of our legal position such as in regard to
applicable statute of limitations, litigation, or regulatory investigations.

LINKS TO OTHER WEBSITES

The Website and Services may provide the ability to connect to third-party
websites or other online services. These third-party websites and services
operate independently from us. This Privacy Policy 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
Website and Services link. The inclusion of a link does not imply endorsement of
the linked site or service by us or by our affiliates.

Our Apps use Google Maps/Earth services, including the Google Maps API(s). Use
of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and
the Google Privacy Policy.

In addition, we are not responsible for the information collection, use,
disclosure, or security policies or practices of other organizations, such as
Facebook, Apple, Google, Microsoft, or any other app developer, app provider,
social media platform provider, operating system provider, wireless service
provider, or device manufacturer, including with respect to any Personal
Information you disclose to other organizations through or in connection with
our Apps or social media pages.

INTEREST-BASED ADVERTISEMENT PRACTICES

When you visit our Website, we and certain third-party advertising companies
engaged by us, collect information about your online activities over time to
provide you with advertising about products and services tailored to your
individual interests. You may see Navan ads or promotions on other websites or
mobile apps based on information related to your visit to our Website, as well
as information received from third parties, because we participate in
advertising networks. These advertising networks may place or recognize a unique
cookie on your browser (including through the use of pixel tags). They also use
these technologies, along with information they collect about your online use,
to recognize you across the devices you use, such as a mobile phone and a
laptop. If you would like more information about this practice, and to learn how
to opt out of some personalized advertising in desktop and mobile browsers on
the particular device on which you are accessing this Privacy Policy, please
visit http://optout.aboutads.info/#, http://optout.networkadvertising.org/#, and
http://www.youronlinechoices.eu.

USE OF SERVICES AND WEBSITE BY MINORS

Our Website and Services are not directed to individuals under the age of
sixteen (16), and we do not knowingly collect Personal Information from
individuals under 16.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any
sensitive Personal Information (e.g., social security numbers, information
related to racial or ethnic origin, political opinions, religion or other
beliefs, health, biometrics or genetic characteristics, criminal background, or
trade union membership) on or through the Services or Website, or otherwise to
us.

In order to offer certain services, we may gather information that falls under
the category of sensitive data or special category of data as defined by
relevant data protection laws. However, it is important to note that the
collection of this data is completely optional. For instance, you have the
choice to specify your meal preference, which could indirectly reveal details
about your ethnic origin, religious beliefs, or health status as per Article 9
of the GDPR. This information is only collected with your consent in order to
provide the information to our travel partners. At any point, you can remove
this information from your profile.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we
have facilities or in which we engage service providers, and by using our
Website or Services you understand that your information may be transferred to
countries outside of your country of residence, including the United States,
which may have data protection laws that are different from those of your
country. In certain circumstances, courts, law enforcement agencies, regulatory
agencies or security authorities in those other countries may be entitled to
access your Personal Information.

INTERNATIONAL PRIVACY PRACTICES

European Economic Area. 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
endeavor to put in place adequate measures to ensure your Personal Information
is safeguarded consistent with the requirements of applicable laws. You may
obtain more information by contacting us in accordance with the “Contact Us”
section below.

You may contact our Data Protection Officer at dpo@navan.com. You may also lodge
a complaint with the EU/EEA 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.

Navan complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK
Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.
Navan has certified to the U.S. Department of Commerce that it adheres to the
EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard
to the processing of personal data received from the European Union and the
United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the
EU-U.S. DPF. If there is any conflict between the terms in this privacy policy
and the Principles shall govern. To learn more about the Data Privacy Framework
(DPF) program, and to view our certification, please visit
https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF Principles, Navan commits to resolve
complaints about your privacy and our collection or use of your personal
information transferred to the United States pursuant to the EU-U.S. DPF
Principles. European Union individuals with DPF inquiries or complaints should
first contact Navan.

Navan has further committed to refer unresolved privacy complaints under the DPF
Principles to an independent dispute resolution mechanism, Data Privacy
Framework Services, operated by BBB National Programs. If you do not receive
timely acknowledgment of your complaint, or if your complaint is not
satisfactorily addressed, please visit
https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers
for more information and to file a complaint. This service is provided free of
charge to you.

If your DPF complaint cannot be resolved through the above channels, under
certain conditions, you may invoke binding arbitration for some residual claims
not resolved by other redress mechanisms. See
https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

In the event we transfer Personal Data covered by the EU-US DPF to a third party
acting as a “controller” (as defined by the EU-US DPF), we will do so consistent
with any notice provided to Data Subjects, any consent they have given, and only
if the third party has given us contractual assurances that it will (i) process
the Personal Data for limited and specified purposes consistent with any consent
provided by the Data Subjects, (ii) provide at least the same level of
protection as is required by the EU-US DPF Principles and notify us if it makes
a determination that it cannot do so; and (iii) cease processing of the Personal
Data or take other reasonable and appropriate steps to remediate if it makes
such a determination. If Navan has knowledge that a third party acting as a
controller is processing Personal Data covered by the EU-US DPF in a way that is
contrary to the EU-US DPF Principles, Navan will take reasonable steps to
prevent or stop such processing.

With respect to our “agents” (as defined by the EU-US DPF), including third
parties acting on our behalf, we will transfer only the Personal Data covered by
the EU-US DPF needed for an agent to deliver to Navan the requested product or
service. Furthermore, we will (i) permit the agent to process such Personal Data
only for limited and specified purposes; (ii) require the agent to provide at
least the same level of privacy protection as is required by the EU-US DPF
Principles; (iii) take reasonable and appropriate steps to ensure that the agent
effectively processes the Personal Data transferred in a manner consistent with
Navan’s obligations under the EU-US DPF Principles; and (iv) require the agent
to notify Navan if it makes a determination that it can no longer meet its
obligation to provide the same level of protection as is required by the EU-US
DPF Principles. Upon receiving notice from an agent that it can no longer meet
its obligation to provide the same level of protection as is required by the
EU-US DPF Principles, we will take reasonable and appropriate steps to stop and
remediate unauthorized processing.

Navan remains liable under the EU-US DPF Principles if an agent processes
Personal Data covered by the EU-US DPF in a manner inconsistent with the EU-US
DPF Principles, except where Navan is not responsible for the event giving rise
to the damage.

Russian Federation. The services hereunder are not intended for use by Russian
citizens who are resident in Russia. If you are a Russian citizen residing in
Russia, any Personal Information that you provide to us through our Website or
Services will be solely at your own risk and responsibility. You expressly agree
that we may gather your Personal Information and will process this data in the
United States and in other countries, and that you will not hold us accountable
for any potential non-observance of Russian law.

In the UK, Navan is an agent of Plaid Financial Ltd., an authorised payment
institution regulated by the Financial Conduct Authority under the Payment
Services Regulations 2017 (Firm Reference Number: 804718). Plaid provides you
with regulated account information services through Navan as its agent.

UPDATES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time to reflect new
services, changes in our Personal Information practices or relevant laws. If we
make material changes, 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 Policy.

Navan, Inc., located at 3045 Park Blvd, Palo Alto, CA 94306 USA is the company
responsible for collection, use, and disclosure of your Personal Information
under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at
privacy@navan.com, or write to us at Navan, Inc., 3045 Park Blvd, Palo Alto, CA
94306 USA.

Because email communications are not always secure, please do not include credit
card or other sensitive information in your emails to us.

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The Navan card is issued by Celtic Bank (Member FDIC), Stripe Technology Europe
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