Your browser does not support HTML5 video.
  • Contact Us

Privacy Notice

Introduction

Naviger Capital Limited ("NCL"), a company registered in the Abu Dhabi Global Market ("ADGM") with commercial license number 24191 and registered address at B06, Floor 11, Al Sarab Tower, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates, along with its affiliates and subsidiaries (collectively referred to as "we," "us," or "our"), is committed to safeguarding your personal data and ensuring compliance with the ADGM Data Protection Regulations 2021, as amended or supplemented from time to time ("DPR"). This Privacy Notice explains how we collect, use, share, and retain personal data.

By accessing our website, using our services, or engaging with us in any manner, you agree to this Privacy Notice and consent to the collection, processing, and retention of your personal data as described herein.

Unless defined below, terms not defined here shall retain their meanings as provided in the DPR.

Purpose 

To safeguard the privacy of your data, DPR restricts our handling of your Data for specific lawful purposes. The requirements are set to ensure the Processing of your Data is done fairly and without adversely affecting you or your rights as a Data Subject.

The DPR allows Processing for specific purposes, including the following purposes:

  • You have given us your consent for specific purposes which we have requested from you, including special categories of Personal Data.
  • The Processing is necessary for the performance of a contract we have entered into with you.
  • To meet our legal, regulatory, and compliance obligations.
  • To protect your vital interests.

We acknowledge that the Processing of your Data shall only be done on a lawful basis, and only where necessary and for the purpose of providing you with the services agreed in the contract we have entered into with you. We shall determine and document the lawful basis before beginning Processing your Data.  If there is a change in circumstances or a new purpose for Processing your Data arises, then we will review that lawful basis and make the required changes while ensuring you are informed and the changes are documented.

Privacy Principles 

In the Processing of your Data, we adhere to the privacy principles as required by the DPR, under section 4, personal Data must be:

  • processed lawfully, fairly and in a transparent manner (lawfulness, fairness and transparency);
  • collected only for specified, explicit and legitimate purposes (purpose limitation);
  • adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (data minimisation);
  • accurate and where necessary kept up to date (accuracy);
  • kept in a form which permits identification of you, as Data Subject for longer than is necessary for the purposes for which the Data is Processed (storage limitation); and
  • processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (security, integrity and confidentiality).

Management Responsibilities 

Naviger Capital Limited's management has the ultimate responsibility to ensure compliance with DPR. This is achieved through ensuring sound, prudent and ethical collection, use, process and sharing of your Data in accordance with all applicable relevant laws and regulations.

In addition to the appointment of a Data Protection Officer that reports directly to the management body, is an expert in Data protection, and is independent and adequately resourced. As well as ensuring adequate resources and controls are in place to ensure and document compliance with DPR including:

  1. Providing senior management and staff with regular training on obligations under DPR, this privacy policy and other related matters;
  2. Keep a record of the training session attendees and the frequency of training;
  3. Ensure Data protection is incorporated into internal documents and contract with clients; and
  4. Regularly test the privacy measures implemented and conduct periodic reviews and audits to assess compliance.

Why Do We Collect Personal Data

To ensure we provide you with the best level of services, through our operations, we collect, hold process and share your personal data for a number of purposes include:

  • Delivering financial and investment services.
  • Managing business relationships and accounts.
  • Complying with regulatory requirements.
  • Conducting risk assessments and AML screening.
  • Processing recruitment and employment applications.
  • Managing communications, marketing, and events.
  • Enhancing customer experience and service offerings.

Data controller

The collection, processing and use of your personal data is conducted by:

Naviger Capital Limited having its registered address at:

B06, Floor 11

Al Sarab Tower

Al Maryah Island

Abu Dhabi, United Arab Emirates

NCL has appointed a Data Protection Officer, who is accessible via privacy@naviger.capital

Types of Personal Data Collected

We collect personal data relevant to our interactions with individuals and businesses, including, but not limited to:

  • Identification Data: Name, passport, Emirates ID (if you are a UAE resident), visa details, date of birth, and signature specimen.
  • Contact Information: Email address, phone number, and office address.
  • Financial Data: Bank account details, credit history, and transaction data.
  • Regulatory Compliance Data: KYC (Know Your Customer) details, due diligence checks, AML screening.
  • Employment Data: CVs, job applications, references, and background checks.
  • Website and Technical Data: IP addresses, cookies, browser details, and usage analytics.

How We Collect Personal Data

We collect personal data through:

  • Direct interactions (e.g., forms, applications, contracts, emails, phone calls, or meetings).
  • Website usage (cookies, analytics, online forms, and surveys).
  • Third-party sources (financial institutions, regulators, credit bureaus, and publicly available records). 

Security Measures

We implement robust security controls to protect personal data, including:

  • Access control mechanisms ensuring only authorized personnel have access.
  • Secure storage solutions with encryption.
  • Regular security assessments and audits.
  • Cybersecurity defences against unauthorized access, data loss, or breaches.
  • Data minimization and retention of data only where necessary.
  • Implementation of incident response procedures in case of data breach or security incident.

Use of Cookies

We use cookies and tracking technologies to:

  • Enhance user experience and website functionality.
  • Analyse website traffic and engagement.
  • Improve marketing and advertising activities.

Users can manage or disable cookies via browser settings. Note that restricting cookies may impact website functionality.

Disclosures, Data Sharing and Transfers

We may share personal data with:

  • Affiliates and subsidiaries: For business and operational purposes.
  • Regulators and authorities: Where required by law or regulatory obligations.
  • Third-party service providers: IT support, compliance consultants, auditors, and marketing agencies.
  • Financial institutions: For credit checks, AML compliance, and fraud prevention.
  • Legal and professional advisors: Where necessary for legal or compliance purposes.

When conducting international data transfers, outside ADGM, we will ensure transfers are made into jurisdictions with adequate safeguards, such as:

  • Transfers to jurisdictions with ADGM-approved data protection standards.
  • Implementing Standard Contractual Clauses (SCCs) approved by ADGM.
  • Seeking approval from the ADGM Data Protection Office where required.

Data Retention

We retain personal data for:

  • Regulatory Compliance: A minimum of six years after business relationship termination, in line with ADGM Financial Services Regulatory Authority (FSRA) requirements.
  • Employment Records: Retained per UAE Labor laws and internal HR policies.
  • AML and Fraud Prevention: Data related to financial transactions, KYC, and compliance checks may be held longer in case of fraud investigations or regulatory needs.
  • Marketing Data: Retained until you opt out or withdraw consent.

Upon expiration of the retention period, personal data is securely deleted or anonymized unless legal obligations require further retention.

Whenever your consent is the legal ground to process your personal data, we will store that data for as long as you do not revoke your consent.

If you exercise your right to withdraw consent, we will cease processing your personal data for which you have withdrawn consent, unless there is another legal basis for processing that data. We will update our records to reflect your withdrawal of consent and ensure that your personal data is no longer used for the specified purposes.

Your Rights

Under ADGM Data Protection Regulations, you have the right to:

  • Access: Request copies of your personal data.
  • Rectification: Correct inaccurate or incomplete data.
  • Erasure: Request deletion of personal data, subject to legal obligations.
  • Restriction: Limit or suspend processing of certain data.
  • Data Portability: Transfer personal data to another service provider.
  • Objection: Object to processing, direct marketing or automated decision-making.
  • Withdraw Consent: Where applicable, withdraw previously given consent.
  • Automated Decision Making and Profiling: Challenge automated decision making or profiling and request human intervention.

Upon receiving an objection/ request to exercise any of these rights, we will:

  1. Assess the grounds of the objection/ request;
  2. Record your request;
  3. Comply, where possible;
  4. Inform relevant third party, if applicable; and
  5. Inform you of our decision and any actions taken.

Requests/ objections can be submitted via our contact details below. We may request verification to ensure data security.

Complaints and Contact Information

If you have concerns about our data processing or wish to exercise your rights, you can contact our Data Protection Officer (DPO):

  • Email: privacy@naviger.capital
  • Address: B06, Floor 11, Al Sarab Tower, ADGM Square, Al Maryah Island, Abu Dhabi, United Arab Emirates.

The following steps will be followed to address and manage your complaint:

  1. make a record of your complaint;
  2. within 10 UAE business days of receiving a complaint, we will provide you with an explanation of our complaints process, including the relevant timeframe in which we will provide a response ; and
  3. we will aim to investigate and resolve all complaints within 30 UAE calendar days of receipt of a compliant.

If you wish to make a complaint, please contact us at privacy@naviger.capital

Additionally, If you are not satisfied with how a complaint has been handled, you have the right to lodge a complaint with the ADGM Commissioner of Data Protection if you believe your data protection rights have been violated. To file a complaint, kindly complete the appropriate complaint forms and send them via email to data.protection@adgm.com.

Marketing

We do use some of your Data for marketing purposes including:

  • Promotional events;
  • News and offers; and
  • Conducting market research and surveys.

We will only send you marketing communications upon acquiring your consent. You may elect to opt-out of marketing communications by speaking to your relationship manager, visiting our website and changing your preferences or by unsubscribing to our mail.

Updates to This Privacy Notice

We may update this Privacy Notice periodically. The latest version will always be available on our website.

  • Test

© All rights reserved
Terms and Conditions | Privacy Notice | Cookies Policy