Privacy Policy Statement

I.　Statement of Policy

Your personal information is protected under the Personal Data (Privacy) Ordinance of Hong Kong ('PDPO'). To protect the confidentiality of your personal information provided to us (Navigator Asset Management Limited and its subsidiary, holding companies, associated companies or affiliates companies) (“Navigator”) (if any), we maintain the following privacy principles:

1. The personal information we collect is limited to that which we believe to be relevant and necessary in conducting our business and servicing the needs of customers.

2. We aim to use your personal information for providing financial services and products.

3. We shall not disclose your personal information to any third parties unless we have your consent or are required by law, or the transfer is required for the collection purposes stipulated in the Personal Information Collection Statement at the time of personal data collection.

4. We may be required by law or under proper authority to disclose your personal information to governmental bodies, judicial agencies or regulators.

5. We aim to keep your personal information on our records accurate and up-to-date.

6. We aim to maintain security measures to safeguard your personal information against unauthorized access or disclosure.

II.　Statement of Practices

1.　Personal Data Collected and/or Held by Navigator The personal data that we collect and/or hold includes a customer’s personal details, contact information, policy details, transaction records, education and training details, employment details, financial details, medical and health records and information on his/her family, lifestyle and social circumstances.

2.　Purposes of Personal Data Collection and Usage A customer’s personal data held by Navigator may be used for the following purposes:

i. administration of insurance or insurance related business, asset management, corporate advisory and health management business, which includes underwriting, processing and evaluation of applications, identity and credit checking, suitability checking, policy servicing, asset management service, investment management service, health management service, health checkup service, company secretary service, banking support service, accounting support service, claims processing, investigation, account/debt collection, litigation, communications, preparing statistics, data analysis and research, internal and external audit, maintaining quality services, sales and marketing, corporate brand building and customer loyalty building;

ii. direct marketing, which includes promoting, marketing or selling of Navigator insurance or insurance related products or services and/or any financial related products or services provided and/or marketed by third party financial institutions or health management institutions by electronic or other means; and

iii. complying with the obligations, requirements or arrangements for disclosing and using data that apply to Navigator or with which it is expected to comply according to:

a. any law binding or applying to it within or outside Hong Kong existing currently and in the future;

b. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future;

c. any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on Navigator by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations.

3.　Direct Marketing

Navigator may use a customer’s name, telephone number, email address and correspondence address for direct marketing only with his/her consent.

4.　Disclosure

The personal data a customer provides to Navigator will be kept confidential, except that it may be shared with the following parties:

i. any insurance broker, financial advisor, investment consultant, independent advisor acting on his/her behalf for any of the purposes set out in section 2;

ii. any subsidiary, holding company, associated company or affiliates of Navigator for any of the purposes set out in section 2;

iii. any TR, contractor or third party service provider, including but not limited to providers of risk intelligence, loss adjustors, private investigators, letter shopping service providers and debt collectors who provides administrative, telecommunications, computer, Internet, payment or other services to Navigator for any of the purposes set out in section 2;

iv. any actual or proposed insurers or health management institutors or financial institutors of Navigator for any of the purposes set out in section 2; and

v. any person to whom Navigator is under an obligation or otherwise required to make disclosure under the requirement of any law binding on or applying to Navigator or any of its group companies, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which Navigator is expected to comply or any disclosure pursuant to any contractual or other commitment of Navigator with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside Hong Kong and may be existing currently and in the future.

5. Transfer of Personal Data Outside Hong Kong

Navigator may from time to time transfer a customer’s personal data outside Hong Kong for any of the purposes set out in section 2 including data processing or storage.

III. Collection of Information Using Cookies

We may also use cookies to track your movements through the web site for research purposes. Personal information is not included in the tracking analysis and all individuals are treated anonymously for the purposes of data collection and research.

IV. Retention of Personal Data

Navigator shall keep your personal data for as long as necessary to achieve the purposes for which it is collected; and to comply with legal requirements. Practical steps will be taken to erase or anonymize the personal data when it is no longer necessary to be retained for the purpose.

V. Protective Measures

We have a range of security measures to guard against unauthorized access and disclosure. The security measure(s) which we choose to employ will commensurate with the level of sensitivity of the piece of personal data in question. Navigator will not by email ask you to provide your passwords or verify your account online. If you have any concern that you may have disclosed any confidential information on fraudulent websites, please contact us immediately.

VI. Access and Correction

Users of this website have the right under the PDPO to request access to and correction of all of their personal information. If any such personal information is given to and retained by Navigator, in accordance with the PDPO, Navigator has the right to charge a reasonable fee for processing data access requests. If any users of this web site want to access or correct their personal information held by Navigator, please contact us. Requests may be addressed to the Data Protection Officer, Suite 1006, 10/F., Ocean Centre, Harbour City, 5 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong. Users of this website can at any time request Navigator to cease using their personal information (given to and retained by Navigator) for direct marketing purposes. If you have any queries concerning information in this Privacy Policy Statement, please feel free to contact us.

Security Policy

The Security Policy below is applicable to the users of Navigator Business Oriented Support System:

1. General To protect your personal information and policy records, valid Login ID and Password are required to gain access to your personal information in this web site. Therefore, you undertake to keep the Login ID and password confidential and secure at all times and agree not to disclose them to any unauthorised person or to use them to provide access to the Password Protected Areas to any unauthorised person. When changing your Password, you shall ensure that the Password is unlikely to be known by others. Navigator will not be liable for any loss you may incur as a result of someone else using your Login ID or Password, whether with or without your knowledge. You may change your Password at any time. We recommend that you log out from our web site each time after browsing your personal information and regularly change your Password. If you suspect that your Login ID, Password or personal information have been disclosed to unauthorised person, you are obligated to inform us immediately.

2. Online Transaction Navigator adopts SSL Certificate to enhance the security of your online transactions in respect of submission of request of change of contact information, request of fund switching, request of future investment redirection and request to apply lump sum top-up through our web site. Navigator accepts no responsibility for the operation of SSL Certificate Services. Through the use of SSL Certificate:

i. You can authenticate or verify this web site so that you can be assured that this website belongs to Navigator; and

ii. You can communicate with Navigator via Transport Layer Security (TLS) encryption technology so that your privacy will be protected. Our website's password-protected areas protect data over the Internet by using 256-bit encryption, one of the highest levels of protection possible for all Internet communications. While you are surfing our password-protected areas, the Internet browser will show a padlock icon in its address bar, near the top left-hand corner of the window. This icon indicates that your online transactions are protected by this encryption technology.

Note: In the event of any ambiguity or inconsistency between the English and Chinese Traditional version of the terms herein, the Chinese version will prevail.

This web site and the information contained in or any services provided under it are provided on the following terms and conditions. By using or visiting this web site you are deemed to have accepted these terms and conditions. Please read these terms and conditions carefully before using this web site. Navigator Asset Management Limited and its subsidiary, holding companies, associated companies or affiliates companies (“Navigator”) reserve the right to amend the terms and conditions herein at any time. You are bound by any such revisions and shall therefore periodically visit this page to review the current terms and conditions. This web site and the information contained in it shall not be regarded as an offer or solicitation of business in any jurisdiction to any person to whom it is unlawful to offer or solicit business in such jurisdictions.

1.　Company Details Navigator is a group of companies holding valid licenses issued by the Hong Kong Special Administrative Region ("Hong Kong") regulators on providing insurance brokerage, corporate advisory and health management services to individuals or corporate customers in Hong Kong. Due to the types of licenses, Navigator can engage in some general and long term including linked long term businesses in the provision of a range of whole life, endowment, general insurance, MPF and investment-linked insurance products. We can also provide a range of other related products, including term life, accident, medical, critical illness and disability insurance to individuals or corporate customers in Hong Kong. We also provide corporate advisory service, including company formation, company secretary service, group structural setup, IPO advisory, bank-servicing support, accounts servicing support etc. Its principal place of business is situated at Suite 1006, 10th Floor, Ocean Centre, Harbour City, 5 Canton Road, Kowloon, Hong Kong. Telephone +852 9545 4951, fax +852 2110 3189 and email address enquiries marketing@namintl.com.hk.

2.　Residence This web site is not directed to any person in any jurisdiction where (by reason of that person's nationality, residence or otherwise) the publication or availability of this web site is prohibited. The pages of this web site are issued in Hong Kong and are for the information of Hong Kong residents in relation to Hong Kong insurance products or corporate advisory services only. Those who choose to access this web site do so on their own initiatives and shall be aware that, other than in Hong Kong, accessing this web site may not be in compliance with local law.

3.　Conditions of Use Information provided on this site is believed to be reliable when posted. However, we cannot guarantee that information will be accurate, complete and current at all times. All information published on the website shall be used for reference purposes only. It is subject to modification from time to time without notice and shall not be taken as advice of any kind by Navigator. All materials contained in this website do not in any way constitute an offer. To the extent permitted by law, it is an invitation to you to make an offer to buy our products or services subject to our final acceptance.

4.　General Disclaimers and Terms Whilst Navigator has taken all reasonable care to ensure that the information contained within the pages of this web site is accurate and current as at the date of issue, no liability shall be accepted by Navigator or its affiliated companies for any errors or omissions in relation to this information, or for this information becoming out of date or for any direct or indirect loss arising as a result thereof. Neither Navigator nor its affiliated companies accepts any responsibility for information contained in any other web sites which can be accessed by hypertext link from these pages or for these web sites not being available at all times. Please note that when you click on any external web site hypertext link you will leave the Navigator web site. Navigator reserves the right to suspend or withdraw access to the pages of these web sites without notice at any time. Navigator reserves the right in its sole and absolute discretion to change without prior warning or notice any information or material contained in this web site. Navigator and its affiliated companies accept no liability and will not be liable for any loss or damage arising directly or indirectly (including special, incidental or consequential loss or damage) from your use of this web site, howsoever arising, including any loss, damage or expense arising from, but not limited to any defect, error, imperfection, fault, mistake or inaccuracy with this web site, its contents or associated services, or due to any unavailability of this web site or any part hereof. Navigator, its subsidiaries and affiliated companies and representatives are committed to respecting the privacy of your personal information. However, it must be understood that the Internet is not a secure mode of communication. Therefore, we cannot guarantee the privacy of any information you input on this site or send to us through the Internet. We will not be responsible for any damage you or others may suffer as a result of the loss of confidentiality of any such information.

5.　Nature of Information Provided The pages on this web site are for general information only and do not constitute financial, professional, investment or any other kind of advice in any way. If you wish to receive advice on investment and / or insurance products and / or corporate advisory services, please feel free to contact us.

6.　Copyright and Trademark Navigator and other parties own the trademarks, logos and service marks displayed on this web site. These may not be used without the written permission of Navigator or the relevant owners. Materials on this web site are protected by copyright. No part of these materials may be modified, reproduced, stored in a retrieval system, transmitted, copied, distributed or used in any other way for commercial or public purposes without Navigator's prior written consent.

7.　E-mail, Internet-based Communications and Internet Transaction Please note that, due to the inherently insecure nature of Internet communications, there is no guarantee that any e-mail or message sent using the facilities of this web site will be received, or that the contents of any such e-mail will remain private and will not be corrupted during transmission. Since internet transactions may be vulnerable to interruption, blackout, delay and corruption of data during transmission, Navigator is not liable for malfunctions in communication facilities not under its control that may affect the accuracy or timeliness of messages and transactions. Navigator shall not accept any liability for direct, indirect, special or consequential damages arising out of the use of this website. Apart from using the internet, you may contact us by phone or post.

8.　Downloads Please note that any software is downloaded at your own risk. Navigator does not warrant the suitability of any such software which is downloaded and accepts no liability for any problems with your computer that may arise as a result. If you are in doubt as to the suitability of software to be downloaded for your computer, it is recommended that you obtain specialist advice before downloading. Furthermore, it is a condition of your use of this web site that you agree that Navigator shall not be liable for any computer viruses, trojans, worms or other harmful computer code or data which may infect or otherwise damage your computer software or equipment as a result of your access to or use of this web site or any of its contents.

9.　Responsibility of Users Upon registering to use our web site services, all users warrant that their information provided relating the services is true, complete and up-to-date and all users agree to notify Navigator regarding all changes to the information previously declared (including but not limited to changes in address, contact details, etc.).

10.　Linked Web Sites This website contains hyperlinks to other websites operated by parties other than Navigator. Such hyperlinks are provided for user's reference and service convenience only. We are not responsible for the availability of these external sites, nor are we responsible for any of the contents, advertisements, products, or other materials in external sites. Under no circumstances shall Navigator, its subsidiaries or its affiliated companies or their representatives be held responsible or liable, directly or indirectly, for any loss or damage caused or alleged to have been caused in connection with the use of or reliance on any content, goods, or services available in an external site. Concerns regarding any external link shall be directed to the relevant site administrator or webmaster.

11.　Governing Law and Jurisdiction This website is not intended for use by persons located or resident in any jurisdictions where the availability of information in this website is prohibited (by reason of the person’s nationality, place of residence or otherwise). Subject to the above, the products and services posted on this website are intended for citizens of Hong Kong, Hong Kong permanent residents and foreign nationals residing in Hong Kong. Nothing in this website shall be construed as an offer to sell or solicitation to buy or provision of any product or service outside of Hong Kong. Navigator, its subsidiaries and affiliates do not offer or sell any insurance product or other product or service (collectively "Product") in any other jurisdiction in which such offering or sale of the Product is illegal under the laws of such jurisdiction. If any Product is offered / sold by Navigator, its subsidiaries or affiliates in any jurisdiction in which such offering or sale is illegal (under the laws of such jurisdiction), such offering or sale shall neither be effective nor valid. Unless otherwise expressly set forth herein, Navigator, its subsidiaries or affiliates has not made any representation that: (i) materials on this website are appropriate for use in any location outside Hong Kong; or (ii) the Products available through this website comply with the laws of any country outside Hong Kong. In the event that the jurisdiction you are in imposes restrictions on our Products or do not permit access to the contents of this website, you shall comply with such restrictions or forthwith discontinue access (as the case may be) hereto. Navigator, its subsidiaries or affiliates shall not be liable to any person in any way for visiting this website. These terms and conditions shall be governed by and construed in accordance with the laws of Hong Kong. You agree that the courts of Hong Kong shall have jurisdiction over any disputes arising from the use of this web site.

Note: In the event of any ambiguity or inconsistency between the English and Chinese (Traditional or Simplified) version of the terms herein, the Chinese version will prevail.