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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.
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