Effective Date: 31 March 2025

Galanthus Group Holdings Limited (collectively, with its affiliates, “Galanthus,” “we,” “our,” and “us”) is committed to protecting your personal privacy. This Galanthus Privacy Policy (this “Privacy Policy”) applies to our websites located at https://naviam.io/ and https://moremaximo.com/ and related URLs (the “Websites”), and all websites, applications, platforms, software, tools, data, products and services that are owned and operated by Galanthus and made available by us through the Websites or that otherwise link to this Privacy Policy (collectively, with the Websites, the “Services”).

This Privacy Policy explains: (i) what information we collect and how we process the information provided to us through the Services; and (ii) options you have with respect to our use of your information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE PROCESS INFORMATION COLLECTED THROUGH THE SERVICES. BY ACCESSING OR USING THE SERVICES, YOU AGREE TO OUR USE OF YOUR INFORMATION AS DESCRIBED HEREIN. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE SERVICES.

1. Information We May Collect From You.

Information We May Collect Directly From You. If you choose to use the Services, including, without limitation, by creating an account, contacting us or otherwise interacting with the Services, we may collect information from you. In order to receive or obtain access to our Services, you may be required to provide us with certain information, including, for example, your name, e-mail address, and information about your organization. Failure to provide such data may make it impossible for us to provide you with our Services. The types of personal information collected and shared depend on the services provided to you. Information collected by us, our affiliates, partners, and suppliers may include, but is not necessarily limited to:
‍
• contact information, such as your name, email address, phone number, and mailing address;
• log-in information, such as the username and password you use to access the Services or any of our products or services or to create an account, and the associated data;
• information we receive in the course of establishing a customer relationship or that you otherwise provide to us while engaging with the Services including, but not limited to, information and data provided in applications, forms, questionnaires and through our Services; and
• user-generated content and messages, such as messages you send us when requesting customer support.

Information We May Collect From Your Computer or Device. We and our affiliates, partners, and suppliers may collect information about you automatically as you access the Services, including, but not limited to, the following:

• analytics data and logs used to monitor traffic and fix bugs, such as Google Analytics for traffic analysis and event metrics, internal logs and the collection of obfuscated error tracking data. For example, we may collect information on web requests, the data sent in response to such requests, the IP address, the browser type, the browser language and a timestamp for the request;
• data related to access and security of customer accounts, including information required for authentication logic such as login status, Internet Protocol address, request timestamps, and success/failure rates;
• analytics monitoring your actions taken while interacting with the Services, such as the use of features and modifications to data. You may choose to opt out of automated tracking for user metrics by enabling the “Do Not Track” setting in your browser; and
• cookies used to store session information. Galanthus may use cookies to track usage of the Services and to address security issues. We may also use cookies to store your preferences relating to use of our Services. If you do not want to allow our Services to place a cookie on your computer, you can change your browser’s settings to deny third-party cookies; however, denying first-party cookies may prevent you from using the Services.

Information We May Collect About You From Third Parties. We may receive information about you from other sources, including third parties that help us update, expand, and analyze our records or prevent or detect fraud.

2. How We May Use Your Information.

Galanthus may use your information for various purposes to the extent permitted by applicable law, including, but not limited to, the following (collectively, “Our Purposes”):
• to provide you with the Services, including, if applicable, to identify you when you sign into your account, to respond to your inquiries, to communicate with you about the Services and for billing and collection purposes;
• for planning and strategy development and other business purposes related to our Services, including to enhance and improve our Services or our other products and services and to analyze the use of the Services;
• to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
• to send you marketing e-mails about new proposals, opportunities, upcoming events, and other news, including, without limitation, information about products and services offered by us and our affiliates. You may opt out of receiving such information at any time. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you; and
• for any other related legitimate business purposes and as otherwise described herein.

3. How We May Disclose Your Information.

We may disclose your information in the following ways:
• to our affiliates and subsidiaries for Our Purposes in connection with the management or servicing of your accounts, providing you with our Services, or as permitted or required by law;
• to institutions with which we have joint business arrangements for Our Purposes in connection with the management or servicing of your account;
• to persons we reasonably believe to be your authorized agent or representative or regulators in order to satisfy our regulatory obligations and as otherwise required or permitted by law;
• to vendors, service providers and agents that we engage to help us provide the Services or our other products and services and administer our business, provided that such companies may use your information only in the performance of the specific services we have requested, may not use your information for their own purposes and are contractually obligated to maintain strict confidentiality;
• when required by law, court order, or other government or law enforcement authority or regulatory agency;
• when it may be necessary for Our Purposes as reasonably determined by us and in accordance with applicable law, including, without limitation, our interests in conducting our business, fulfilling contractual obligations, and managing and delivering the best Services; and
• for other reasons when you provide us with consent to do so.

If we, or all or a portion of our assets, are acquired, or if we go out of business or enter bankruptcy, information would be one of the assets that may be transferred to or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or any of our assets may continue to use your information as set forth in this Privacy Policy.

4. Aggregated Data.

We may aggregate and/or de-identify any information collected through our Services so that such information can no longer be linked to you or your device (“Aggregated Data”). We may use such Aggregated Data for any lawful purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, partners, and sponsors.

5. Children.

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or through the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through the Services or any of their features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If a child has provided us with personally identifying information without parental or guardian consent, the parent or guardian should contact us to remove the information and opt out of further electronic communication with us. Residents of certain states or countries may have additional rights regarding the collection and sale of their personal information.

6. Third-Party Practices.

This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. When you access our Services, you could be directed to other websites or services not operated by Galanthus that are beyond our control. There may be links to other sites that take you outside our service, such as links to business partners and industry associations. If you choose to use these links and features, please note that we are not responsible for their content or privacy practices, and that the use of such links and features may result in information such as your IP address and information collected through cookies being shared with the third parties that control these links and features. The collection, use, and disclosure of your information will be subject to the privacy policies of such third parties, and not this Privacy Policy. We urge you to read the privacy policies of these third parties if you choose to interact with these links and features.

Some content or applications, including advertisements, on the Websites may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our websites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

7. Security.

We follow generally accepted industry standards to help protect your information. We have put in place physical, electronic, and managerial procedures designed to safeguard the information we collect. We strive to ensure all of our employees are aware of their responsibility to protect the security and confidentiality of your information. We seek assurances from our vendors and suppliers that they will adhere to privacy management practices equivalent to ours when handling personally identifiable information on our behalf. However, no data transmission over the Internet or any wireless network can be guaranteed to be secure. As a result, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at info@naviam.io.

8. Your Rights and Choices

Marketing Communications. Subject to applicable law and any preferences you have expressed to us, we may send you marketing communications regarding our Services or third-party services that we believe will be of interest to you. You can opt out of receiving future communications using the opt-out instructions provided in such communications or by contacting us as set forth in the “Contact Us” section below. Please note that even if you opt out of marketing communications, we may still send you non-marketing communications, such as emails about updates to this Privacy Policy, confirming your requests, or notifying you of security issues with your account. We may also use and disclose certain information as required by applicable law.

Rights Regarding Your Information. Depending on your jurisdiction, you may have certain rights under applicable data protection laws regarding your “personal information” or “personal data” (as such terms are defined under applicable law; collectively referred to in this section as “personal information”). If you are a resident of the European Economic Area; the United Kingdom; the U.S. states of California, Colorado, Connecticut, Oregon, Texas, Utah, Virginia, or U.S. states with similar privacy laws; or another jurisdiction providing such rights, you have the right to ask us to:
• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such personal information; the business or commercial purpose for collecting such personal information; and the categories of third parties to which we disclose such personal information;
• Provide you access to and/or a copy of certain personal information we hold about you;
• Correct or update personal information we hold about you;
• Delete certain personal information we have about you;
• Restrict or object to certain uses of your information; or
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects (note that we do not engage in such processing).

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information to provide the Services to you, fulfill your requests, or comply with applicable law, and if you ask us to delete such information, we may deny your request. We may take reasonable steps to verify your identity before responding to a request, which may include, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address (at a minimum). If we cannot verify your identity, we may be unable to respond to your requests.  

If you contact us, please specify the right you want to exercise and the information with respect to which you want to exercise this right. You may be able to designate an authorized agent to make requests on your behalf. So we can verify an authorized agent, you must provide the authorized agent with a power of attorney or a signed, written permission to make such requests. We may follow up with you to verify your identity before responding to the authorized agent’s request, as permitted by applicable law.

If we deny your request, you may appeal this decision if you reside in Colorado, Connecticut, Oregon, Texas, Utah, Virginia, or certain other U.S. jurisdictions. We will provide information about how to make an appeal in our response denying the request. You also have the right to lodge a complaint with the supervisory authority in your jurisdiction. However, we encourage you to contact us first with any concerns or complaints so we can do our best to resolve them.

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes.

If you reside in California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia, you also have the right to opt out of “sales” of your personal information and “sharing” or processing of your personal information for “targeted advertising” purposes, as such terms are defined in applicable data protection laws. As explained in the “How We May Disclose Your Information” section above, we may provide personal information to third-party advertising and related analytics providers for targeted advertising and related analytics purposes. Under applicable law, these disclosures to these parties for these purposes may be considered a “sale” of personal information or “sharing” or processing personal information for “targeted advertising” purposes.

To opt out of the disclosure of your personal information to such third parties through cookies and similar tools for purposes that could be considered “sales” or “sharing” or processing for purposes of targeted advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out (NetworkAdvertising Initiative’s Consumer Opt-Out) or the Digital Advertising Alliance’s Consumer Opt-Out (http://optout.aboutads.info/#!/) or use our cookie consent tool. You must complete this opt-out on each browser or device you use to access the Services.

9. European Union GDPR Rights.

In this section, we have summarized certain rights that you may have under the European Union General Data Protection Regulation 2016/679 (“GDPR”) if you are a data subject covered by the GDPR. Some aspects of GDPR are complex and not all of the details have been provided below. Therefore, you should read the GDPR and relevant guidance from the applicable regulatory authorities for a full explanation of these rights.

Your primary rights under GDPR are: (a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the right to complain to a supervisory authority; and (h) the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purpose of the processing, to have any incomplete personal data about you completed.

In some circumstances, you have the right to erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of GDPR; the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the rights to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal crimes.

In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the right of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purpose of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us via any of the contact information described in the section entitled “Contact Us.”

10. Notice to California Residents—Your California Privacy Rights.

If you are a California resident, you have the right to request one Notice of Information-Sharing Disclosure per year which will identify the third parties, if any, with whom we or any of our affiliates has shared the personal information we have collected from you. You may request the Notice of Information-Sharing Disclosure by contacting us using the contact information below. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. We will respond to your request within 60 days.

To the extent the California Consumer Privacy Act of 2018 applies to our collection of information that identifies or relates to you or your household, you may have a number of important rights free of charge. In summary, those rights may include: (a) the right to know the categories of personal information to be collected and the purposes for which the information will be used (see above); (b) the right to know the categories of personal information that were actually collected in the preceding 12 months and sold or disclosed for business purposes in the preceding 12 months (see above); (c) the right to require us to respond to verifiable requests with disclosures about our collection, sale, or disclosure of your personal information (such requests may be made by contacting us as described in section entitled “Contact Us”); (d) the right to access a copy of the specific pieces of personal information that we have collected about you; (e) the right to request that we delete, and request any third-party service providers to delete, any personal information collected about you; and (f) the right to opt out of the sale of your personal information to third parties, if you have previously given us permission to do so, since we do not sell or rent personally identifying information collected during your use of the Websites without your permission (such requests may be made by contacting us as described in section entitled “Contact Us”).

11. Changes to this Privacy Policy.

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Websites home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Websites and this Privacy Policy to check for any changes.

12. Contact Us.

If you have any questions concerning this Privacy Policy, or to exercise your rights herein, such as to unsubscribe, update, correct, or delete your information, please contact us by email at info@naviam.io or by regular mail sent to 3815 Harrison Avenue, Cincinnati, OH 45233, United States.