To facilitate the efficient management of services Navicom International Investment will at time collect, store and use information submitted by Clients and potential Clients. Navicom International Investment is obligated under law to collect the personal information of clients as part of 'Know Your Client' programs.

Data can collected from Clients under ordinary business conditions and data may be exchanged in the context of a business relationship between Client and Navicom International Investment .

Providing personal data to Navicom International Investment through electronic (e-mail, Internet or recording systems) cannot be guaranteed to be secure. Navicom International Investment is not responsible for damages suffered by Clients if they send information to Navicom International Investment using electronic devices, or if the Navicom International Investment sends information through electronic devices by request of the Client. Clients should be diligent of potential vulnerabilities and communicate personal data with caution.

Navicom International Investment will not collect any personal data identifying a visitor to this Website unless specifically requested by the Client. Your visit to this Website will record only the Domain Name Server, your email address and a log of pages visited. This information will only be used to prepare general statistics on usage patterns of the Website.

The purposes for which personal data relating to Clients may be used are as follows:

  • (i) daily operation of services and facilities provided to Clients;
  • (ii) conducting Know Your Client and credit checks;
  • (iii) assisting other financial institutions to conduct checks;
  • (iv) ensuring credit worthiness of clients;
  • (v) designing financial services products for clients' use;
  • (vi) marketing of financial services products;
  • (vii) determining level of indebtedness owed to or by clients;
  • (viii) meeting the disclosure requirements of any legal or regulatory requirement or court order.
  • (ix) any purposes relating to the above.


Navicom International Investment will not disclose or sell personal information to a third party. As an exception to this disclosure, Navicom International Investment may, under consent of the Client, disclose personal information to a business associate for the provision of financial management services. In connection with this, please note:

  • (a) name, contact details, products and services, portfolio information, transaction patterns, financial background, demographic data. May be held by Navicom International Investment and used for direct marketing;
  • (b) the following services, products or subjects may be marketed:
  • (i) securities, investments, commodities and related services or products;
  • (ii) reward, loyalty and privilege programmes referred to in clause b(i);
  • (iii) donations and contributions to charitable or non-profit purposes.
  • (c) Any Client who doesn't wish Navicom International Investment to use or transfer the Client's data for direct marketing may without charge exercise the right to opt-out.
  • Personal Data held by Navicom International Investment relating to a Client will remain confidential but Navicom International Investment may provide information to the following parties:

  • (i) an agent, contractor or 3rd party service provider providing administrative, computer, financial, cash, securities, telecommunications, trade execution or contracts, clearing, settlements or other services to Navicom International Investment in connection with business operations;
  • (ii) any person or group in a role of confidentiality to Navicom International Investment who has undertaken to keep information confidential;
  • iii) financial institutions or dealers with which the Client have dealings;
  • (iv) a credit reference agency in the event of default or debt collection;
  • (v) any actual or proposed assignees of Navicom International Investment or participant or transferee of the rights of Navicom International Investment in respect of the Client;
  • (vi) any exchange, agency, regulatory, entity or government body if required by law or pursuant to court orders or regulations to which Navicom International Investment is subject. Navicom International Investment is usually under duty of secrecy and won't be able to notify a Client or seek consent in relation to a release of information.
  • In accordance with the terms of the Personal Data Ordinance, an individual has the right to:

  • (i) check whether Navicom International Investment holds data about them and the right to access such data;
  • (ii) require Navicom International Investment to correct data relating to them which is inaccurate;
  • (iii) ascertain Navicom International Investment 's policies and practices relating to data and be informed of the type of personal data held by the Company.


Should you require further information on the Navicom International Investment policies to protecting personal information, please contact the Privacy Officer directly;

Navicom International Investment
8/F Harcourt House
39 Gloucester Road
Wan Chai
Hong Kong

In accordance the Personal Data Ordinance of the Laws of Hong Kong, Navicom International Investment has the right to charge a fee for processing any data request. In addition to Navicom International Investment 's duty of confidentiality to Clients, Navicom International Investment shall observe these privacy principles and Ordinance of Hong Kong SAR in collecting, using and maintaining the personal data of Clients.

This Policy may, without prior notice, occasionally be revised, supplemented or amended by Navicom International Investment .

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