Adaptive

Privacy & Security

The Privacy Policy describes how Adaptive Business Solutions, (“Adaptive,” “we” and “us”) collects, uses, protects, and discloses information when you visit or use our  websites, (www.justjewelerysoftware.com, adaptivenav.com)  mobile or web  applications, support portals, or our Business Central Application Suite including add-ons and integrations (each a “Site” and collectively “Sites”), contact our client service team, engage with us on social media or otherwise interact with us, or purchase our products or services.  It also covers data our clients ask us to process in any related connectors, AI Agents, or Integration Apps. A “client” is defined as a business using any Adaptive site or related consulting services. A “customer”  or “vendor” is defined a person or entity transacting with the “client”.  This Privacy Policy applies to all users of the Sites as well as all employees and applicants for employment.  By using the Sites, you are consenting to this Privacy Policy.

Information We Collect

We collect different categories of personal information depending on your interaction with us. The key categories and types of personal information that we may collect, and process are set out below.

Contact Information: When you create an account on our Sites, sign up for our mailing list, rsvp for an event, enquire about our products or services, or otherwise communicate or interact with us, we may collect your name, title, email address, mailing address, or telephone number.

Identifiers: When you visit our Sites, we may collect your IP address, username, account number, password or other security information for authentication and access.

Geolocation Data: When you visit our Sites, we may collect the general region or area from which you access our site.

Usage Data: When you visit our Sites, we may collect data concerning your Internet or other electronic activity including browsing and click history, device types, operating system, browser settings, IP address, language settings, or Site use data including information about how you navigate the Site, other websites, and the Internet.

Social Media Profiles: When you interact with us or our Sites through various social media networks, such as when you like us on Linkedin or when you follow us or share our content on LinkedIn or other sites, we may receive information from those social networks including your profile information, user ID associated with your social media account, or any other information you allow the social

network to share with third parties.

User Generated Content: When you contact us directly, e.g., by email, phone, mail or by completing an online form or by participating in an online chat or post on our Sites or by interacting with us at tradeshows, conferences, or events we may record  or transcribe your comments and opinions or any information that you choose to provide.

Audio/Visual Data: When you visit one of our offices or event booths or submit photos or videos to us, we may collect audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings.

Commercial Information: When individuals or companies inquire about our products or services or provide us information regarding products or services you considered or purchased, Adaptive may collect records of products or services purchased, obtained or considered, or other purchasing or consuming histories.

Applicant Data:  When you apply for a position with us, we may collect your contact information, resume information, education history, work history, certifications, qualifications, compensation history, or references.

Employment Information:  When you accept a position for employment with us, we may collect your contact information, benefit information, social security number, date of birth, immigration information, dependent information, Health insurance information, health information, and driver’s license information, or other government identification information.

Financial Information: If you accept a position for employment, we may collect your tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, card or account security details, or billing address

Inferences: Adaptive may combine information obtained from different sources with publicly available information, which may be used to draw inferences about you. For example, we may combine information we have with information that we have collected: (i) offline and online, (ii) across other third-party sites, (iii) across devices, such as computers and mobile devices, and (iv) from a third party. We may also use information from the categories described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitudes.

Sensitive Information: Adaptive may also collect certain Personal Identification Information as known as “PII” that is deemed “sensitive” under local law, such as information about health, medical information, disability status, financial information, religious beliefs, ethnicity, gender identity, political opinions or trade union membership, sexual life and orientation, biometric information, passwords or information about criminal records or civil litigation history. We will only process Sensitive Personal Information with your consent, pursuant to our contractual relationship with you, and/or where permitted by applicable governing law.

Customer, Vendor, and Third-Party Data In the process of providing analytical assessment or ongoing system support for potential or existing clients, upon written consent of the client we may access, and view Customer, Vendor, or Third-Party Data managed by potential or existing clients. This access may be granular, term, or indefinite depending on the arrangement made between Adaptive and the potential or existing client. We will not use the information for our own marketing purposes. Adaptive will make best effort through industry standard practices to ensure the integrity and security of this data at time of access. Adaptive will not alter the data unless specifically requested in written consent, will only alter based on the operations request.

Methods of Collecting Information

We collect and process information in a variety of ways:

Directly from you: We collect contact information, demographic information, identifiers, commercial information, or health information, that you provide directly to us.

From our clients:  We collect contact information, demographic information, identifiers, commercial information, audio/ visual data, or health information from our clientsthrough the use of our products and services.

Audio/ visual data: When you access our Sites, we collect identifiers, geolocation data, or usage data using tools like browser cookies.

From third parties: We may collect contact information, identifiers, commercial information, audio/ visual data, or inferences from third parties, including investor relations companies, research institutions, service providers, and public authorities.

From social media platforms and networks: We may collect contact information, identifiers, geolocation data, usage data, commercial information, or audio/visual data from social media platforms and networks that you use in connection with our websites or mobile applications, or that share or allow you to share information with us, such as Facebook, Twitter, and Instagram.

Inquiries, Requests and Notifications : We use your contact information, identifiers, and commercial information to respond to your inquiries, complaints and suggestions and to notify you about any changes to our Sites, products or services. Legal Basis for Processing : To meet our contractual obligations to you or our customers, your consent, and, where appropriate, our legitimate interests .

Provision of Products and Services: We use your contact information, identifiers, user generated content, audio/visual data, commercial information and inferences to provide you or our clients with requested products or services. Legal Basis for Processing : To meet our contractual obligations to you or our clients your consent, and, where appropriate, our legitimate interests .

Employment:  Adaptive may use your contact information, identifiers, employment information, applicant information, audio/visual data, applicant data, employment information, financial information, and inferences to evaluate your suitability for a position and to manage and facilitate our employment relationship with you, including for human resources management. Legal Basis for Processing: To meet our contractual obligations to you or our clients, your consent, and, where appropriate, our legitimate interests.

Analytical Purposes: Adaptive may use your identifiers, usage data, geolocation data, commercial information, social media profiles, user generated content, and inferences to analyze preferences, trends and statistics. Legal Basis for Processing : To meet our contractual obligations to you or our clients, your consent, and, where appropriate, our legitimate interests .

Marketing Purposes : Adaptive may use your contact information, identifiers, commercial information, usage data, geolocation data, social media profile, user generated content, audio/visual data, and inferences to send you our marketing communications, register you for an event, improve our marketing efforts, create social media posts or advertisements, and provide you with information about us and our products and services, including personalized marketing communications. Legal Basis for Processing : To meet our contractual obligations to you or our clients, your consent, and, where appropriate, our legitimate interests .

Maintenance and Improvement of the Sites, Products, and Services : Adaptive may use your contact information, commercial information, identifiers, user generated publicly available content, social media profiles, geolocation data, audio/visual data, and usage data to improve our products, services and Sites, provide and maintain functionality on our Sites, and help us diagnose technical and service problems and administer our Sites. Legal Basis for Processing : To meet our contractual obligations to you or our clients, your consent, and, where appropriate, our legitimate interests .

Security and Fraud Prevention : We use your contact information, identifiers, commercial information, social media profiles, user generated content, geolocation data, usage data, audio/visual data, and inferences to protect our Sites and Services; protect us, our affiliated companies, our employees, and others; and to prevent fraud, theft and misconduct. Legal Basis for Processing : Our legitimate interests to protect our organization and to prevent fraud, theft and misconduct.

Legal : We use your contact information, identifiers, social media profiles, commercial information, user generated content, geolocation data, usage data, audio/visual data, and inferences to comply with our legal obligations, including reporting requirements, and defend us in legal proceedings, and protect us and our property, employees, and others through legal proceedings. Legal Basis for Processing: Our legitimate interests to protect our organization and to comply with our legal obligations.

Cookies and Similar Technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign in, providing interest-based advertising, combating fraud, analyzing how our products perform, and fulfilling other legitimate purposes.

Services we use may use or create operate  “web beacons” on our behalf to help deliver cookies and gather usage and performance data. Our websites and certain applications may include web beacons, cookies, or similar technologies from Microsoft affiliates and partners as well as third parties, such as service providers acting on our behalf.

Third party cookies may include: Social Media cookies designed to show you ads and content based on your social media profiles and activities on our websites; Analytics cookies to better understand how you and others use our websites so that we can make them better, and so the third parties can improve their own products and services; Advertising cookies to show you ads that are relevant to you; and Required cookies used to perform essential website functions. Where required, we obtain your consent prior to placing or using optional cookies that are not (i) strictly necessary to provide the website; or (ii) for the purpose of facilitating communication.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Site after the date such revised Cookie Policy is posted.

Combination of Data

We combine information we obtain from different sources with publicly available information, including to create inferences about you.  For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

Data Privacy Framework (DPF) Notice and Policy ;Data Privacy Framework and protecting EU, UK, and Swiss personal data transfers

Adaptive DPF:

Adaptive makes best effort to comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) and to the rights of EU, UK, and Swiss individuals, as set forth by the U.S. Department of Commerce. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the U.S. Principles shall govern.

Adaptive operates in the United States, and therefore makes best attempt to adheres to U.S. governing laws by state and local municipality.  Adaptive is considered a Cloud Services Provider (Microsoft licensed reseller) and Independent Software Vendor.

Adaptive  may be required to disclose personal information of our clients or information about our client’s customers, vendors, and third-party services in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Adaptive is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Inquiring About Your Data:

If you have a question or complaint about our compliance with the DPF Principles, please contact us at: support@adaptivenav.com

Individuals are informed that, under certain conditions, they may invoke binding arbitration to resolve disputes relating to the handling of their personal data.

Choice and Opt out:You have the option to choose (opt out) whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you, unless that third party is providing required services to you at Adaptive’s or your request. If you chose to opt out of any of the above uses of your data, submit the request via email to support@adaptivenav.com

With third party service providers, agents, or contractors. We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods. Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide client support service, to collect debts, and to analyze and enhance data (including data about users’ interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third-party providers on our behalf. We do not authorize them to use or disclose your personal information except in connection with providing their services or services with Adaptive.

Marketing/Analytics/Advertising Partners: We may share personal information with third-party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails and advertisements.

To comply with legal process or to protect Adaptive If we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to enforce applicable terms of use, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or Adaptive  as required by law; or to detect, prevent, or otherwise address, security or technical issues or illegal or suspected illegal activities (including fraud).

Business Transfers. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy. In such transitions, customer information is typically one of the business assets that is transferred or acquired by a third party. In the unlikely event that we or substantially all of our assets are acquired or enter a court proceeding, you acknowledge that such transfers may occur and that your personal information can continue to be used as set forth in this privacy policy.

Third Party Links We may have links on our site to other sites that we do not operate. If you click on a third-party link, you will be taken directly to that site which is governed by its own privacy notice. We strongly encourage you to read that privacy notice. We do not control that site and assume no responsibility for the content, policies or its practices.

Choices and Individual Rights We aim to take reasonable steps, so you can correct, amend, delete or limit the use of your Personal Data. We outline your choices below:

E-mail. If you do not wish to receive promotional e-mails from us, you may opt out at any time by contacting us at the contact information below or clicking on the link included in the email. If you opt out of a promotional e-mail, we may still send you transactional and administrative emails about this privacy policy or about the products or services you have purchased.

Digital Advertising. You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, the Digital Advertising Alliance of Canada in Canada or the European Interactive Digital Advertising Alliance in Europe. You can also opt out of the Digital Advertising Alliance using your mobile device settings. We work with Google AdSense & DoubleClick Cookie Google, who, as a third party vendor, uses cookies to serve ads on our site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.

Google AdWords/Analytics : Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at http://www.google.com/intl/en/policies/privacy/ Google also recommends installing the Google Analytics Opt-out Browser Add-on—https://tools.google.com/dlpage/gaoptout—for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

Linkedin: You can learn more about LinkedIn Ads and https://business.linkedin.com/marketing-solutions/ads. Preferences on Linkedin are managed through Account> Settings & Privacy.

We use regional job posting websites to advertising and disseminate information about open positions at Adaptive.  Accessing  and replying to a job posting on these third party websites, subjects you to the terms of that website.

Our Policy on Children’s Information Our site is not directed to children under 16. If you learn that your minor child has provided us with personal information without your consent, please contact us.

Contacting Us We welcome any queries, comments or requests you may have regarding this policy please do not hesitate to contact us at support@adaptivenav.com.  If you would prefer to write to us then our contact address is on the footer of our website.

Changes to this Privacy Policy Adaptive  reserves the right to modify this Privacy Policy.  Adaptive will post the most current version of the Privacy Policy at its Sites with an effective date.  Your continued use of Services after Adaptive publishes or notifies you about Adaptive’s changes to the Privacy Policy means You consent to the updated Privacy Policy.

Country/Region/State Specific Provisions

California

For residents of California, the following additional provisions apply to you.

Shine The Light: If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please send an email to support@adaptivenav.com and include “CA Shine the Light” in the subject line of your email.

California Consumer Privacy Act (CCPA) Disclosures:

Categories and sources of personal information we collect: In the preceding 12 months, we have collected the following categories of personal information: contact information, identifiers, social media profiles, user generated content, commercial information, geolocation data, usage data, audio/visual data, health information, applicant data, employment information, sensitive information, and inferences. For details about the data points we collect and the categories of sources of such collection, please see the Information We Collect and Methods of Collecting Information sections above.

Purposes for which we use personal information: We collect personal information for the business and commercial purposes described in the Use of Your Data section of this Privacy Policy.

Your Rights Under the CCPA

Subject to certain exceptions, the CCPA affords California consumers the following rights:

The Right to Know About Personal Information Collected, Disclosed, or Sold You have a right to request what personal information we have collected, used, disclosed and sold about you in the preceding 12 months. You can also request the specific pieces of personal information we have collected about you. You can also request the following categories of information:
The categories of personal information we have collected about you.
The categories of sources from which the personal information was collected.
The business or commercial purpose for collecting or selling the personal information.
The categories of third parties with whom we shared personal information.

Right to Request Deletion of Personal Information You can also request that we delete your personal information. We may not delete all of your personal information if one of the exceptions to the CCPA applies. Please note that if we delete your personal information, the Services provided may not maintain the same functionality. For example, your previous opt-out requests will not be saved and saved preferences and information will no longer be available.

Right to Opt Out of Sale or Sharing of Information You have a right to opt out of the sale of your personal information. The CCPA defines a “sale” as disclosing or making available to a third party personal information in exchange for monetary or other valuable consideration. While we do not sell personal information for monetary value, we may disclose personal information to third parties, such as marketing/analytics/advertising partners, in such a way that may be considered a “sale” of personal information under the CCPA. We do not sell personal information of minors who we know are under 16 years of age. You also have the  right to opt out of the sale of your personal information.  The CCPA defines “sharing” as disclosure of personal information to a third party “for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.”

The Right to Limit the Use of Sensitive Personal Information You have the right to limit the use of “sensitive personal information” to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services” or for the performance of specific enumerated business purposes.

Right to Access Information About, and Opt-Out of, Automated Decision-Making Technology You have the right to request information concerning and to opt-out of the use of automated decision-making technology and profiling.

Right to Not Be Discriminated Against You have a right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.

Right to Correct Inaccurate Information You have the right to request that we update or correct your personal information when it is inaccurate or incomplete. Exercising Your Rights Under the CCPA To exercise any of your CCPA rights, please email support@adaptivenav.com. For all requests, you must provide us with your name, email address, phone number, and mailing address. Failure to provide all of the foregoing information will prevent us from processing your request.

Further, in order to verify your identity, we will provide a verification form to you at your email address. Please be aware that you must complete the verification form and submit it to us in order for us to match that information to the information we have in our systems and process your request. Additionally, some requests may be subject to additional identity verification procedure. In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at support@adaptivenav.com

Updated: Nov 10th 2025 Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

By using the Site, downloading our applications/extensions, or interacting with us through client portals, support@adaptivenav.com, or social media channels, you agree to be bound by this Cookie Policy and our Privacy Policy.

Security Adaptive uses industry standard best practices to keep all information collected about clients or business information accessed on behalf of or by request of existing and potential clients, secure. This includes the storage, sharing, and accessing of aforementioned information. For purposes of integrity and security, we do not publicly release our security measures.  For more details on our security policies and measures, please email support@adaptivenav.com