NAV limited

Online Privacy And Client Confidentiality Statement

Who we are
nav Limted provides data management and information technology services to the wealth management industry.  You can find out more about us at www.navglobal.com.

Your financial advisor is using the nav system to provide valuations and services to you and to manage their business.  nav Limited is based in Hong Kong so its activities are governed by the Personal Data (Privacy) Ordinance.  It also complies with the requirements of the EU General Data Protection Regulation (GDPR)

What do we do
nav Limited aggregates data from the providers of the different financial products that you obtain from your advisor to fulfil your financial planning goals.  This data is collected in a single data base and made available through software and online applications both to you and to your advisor in the form of reports and analysis

In addition we provide customer relationship management (CRM) functionality, fact find and compliance support, and document storage

How do we collect your data and what does it include?
nav gathers data electronically from insurance companies, fund managers, trading platforms and price providers.  Except  for account numbers, we do not not include personal details in the information that is imported into the system from financial institutions.

We only collect data that is required to provide you with financial advice.

Your adviser may use the CRM functionality to store basic information that you provide about you and your family.

You may be asked to complete and periodically review an online fact find  which includes questions relating to your personal and financial data.  This is a regulatory requirement and is needed to ensure that you are getting the best possible advice appropriate for your situation.

When you visit our website, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about visitors to our websites..

When you visit our website we automatically log  where you navigated within it and what features and settings you used. We use this information to improve our websites and services and to plan new product development.

How will we use your data?
nav Limited is a data processor, its role is to provide data from different sources aggregated in a standard format  to your advisors  for use in their business.  We don’t use individual investors information.

We provide tools to analyse your data so that you and your advisor can monitor your financial situation including the value of your assets and to alert you should your insurance protection require renewal.

Your data will  not be shared by us with third parties or used by us for marketing or any other purposes except in aggregate form (ie as anonymous statistics such as “55% of our visitors are male”).

What is the legal basis for the transfer of your data to us under GDPR?
Despite having strong data protection laws, Hong Kong has not been deemed ”adequate” for the transfer of personal data from inside the EU.  As a result, nav has signed a Data Processor Agreement with your advisor which strictly limits the processing activities that we can carry out with your information.

The agreement is based on the fundamental principles for the processing of personal data around which GDPR is written.

The transfer of the data of an individual is allowed under GDPR once this is in place for any of  the following reasons:

  • Contractual necessity, you have appointed your adviser to look after some or all of your financial affairs.  To do so he needs complete, accurate and timely information about your investments.
  • The legitimate legitimate interests of  your advisor who depends on the data of all of his customers to manage his business provided that his needs are not overridden by the requirement to protect your data.
  • Your consent, you have approved the transfer by signing an agreement, most likely when you became a customer of the advisory company or at the time of purchasing a financial product, or when accepting the nav site usage agreement to access your valuation.
  • There may be a legal requirement to collect your information, or your personal data might be needed to protect your vital interests or those of another person.


What rights do I have under GDPR

You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you.

  • You have the right to update the information we hold about you or to rectify any inaccuracies.
  • You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
  • You may also have the right to request to restrict the use of your information in certain circumstances but we may need to verify whether we have overriding legitimate grounds to use it.
  • You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
  • You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
  • You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information.


What if I am not covered by GDPR
nav will honour the  the rights that you would have under GDPR wherever you live.  However if you are not an EU citizen either in the EU or living abroad or living in the EU and if your data is not being transferred from the EU or a centre such as the Isle of Man which follows the GDPR, you are still protected by the Hong Kong  Personal data (Privacy) Ordinance which strictly controls our activities as a data processor.

You may also be protected by the Data Privacy code of the country in which you live.

How long will you keep my data
Once you have ceased to be a client of the advisor that provided you with access to our website  we will no longer receive data about your investments.

Your advisor may keep sufficient information on the system to meet legal, regulatory and business requirements but for no longer than to fulfil this purpose . Reasons to retain data can include:

  • To respond to complaints
  • To maintain records according to rules that apply in their jurisdiction.
  • To ensure that you are not contacted again should you have asked not to be.

If the agreement between your advisor and nav is terminated, your data will be transferred or deleted depending on what they decide.

Cookies
Cookies are text files placed on your computer to collect standard Internet log in and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology
For further information, visit allaboutcookies.org.
How do we use cookies?
Our Company uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in
  • Understanding how you use our website

What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:

  • Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
  • Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Data Protection Officer
If you have any questions or concerns about our privacy practices with respect to your personal information please contact our Data Protection Officer by emailing dataprotection@navglobal.com

Last Updated: 20th Jan 2020

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