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Privacy Policy

Introduction and Our Commitment

  1. Navigo Partners Limited (Navigo, we, us, or our) is incorporated in the Abu Dhabi Global Market (ADGM) under license number 27834. Our registered office is at D45, 11th Floor, Al Sarab Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates.
  2. We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal Data (as defined in the Regulations) when you visit our website www.navigo-partners.com, use our services, or otherwise interact with us.
  3. This policy is designed to comply with our obligations under the ADGM Data Protection Regulations 2021 (the Regulations).
  4. For the purpose of the Regulations, Navigo is the Controller of your Personal Data. We have appointed a Data Protection Officer (DPO) who can be contacted at thetherington@navigo-partners.com or via post at our registered address.

The Personal Data We Collect

  1. We may collect and process various types of Personal Data about you, which we have grouped together as follows:
    • Identity Data: Includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, and official identification documents (e.g., Passport, Emirates ID);
    • Contact Data: Includes billing address, delivery address, email address, and telephone numbers;
    • Financial Data: Includes bank account, payment card details, and other financial information required for “Know Your Customer” (KYC) and Anti-Money Laundering (AML) checks;
    • Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us;
    • Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
    • Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses;
    • Usage Data: Includes information about how you use our website, products, and services; or
    • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  2. We may also collect Special Categories of Personal Data (such as biometric data for identity verification or information about political exposure) only where strictly necessary for our services and with a clear lawful basis under the Regulations.
  3. Where we are required by law or regulation, or under a contract with you, to collect certain Personal Data (for example, for KYC and AML purposes) and you do not provide that data when requested, we may be unable to provide our services to you, or to enter into or perform our contract with you. We will inform you if this is the case at the relevant time.

How We Collect Your Personal Data

  1. We may collect and process various types of Personal Data about you, which we have grouped together as follows:
    • Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, when we provide services to you, or otherwise;
    • Automated Technologies or Interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this Personal Data by using cookies and other similar technologies.; or
    • Third Parties or Publicly Available Sources: We will receive Personal Data from various third parties and public sources such as web searches, AI tools, due diligence providers, analytics providers, and public registers.

The Lawful Basis for Processing Your Personal Data

  1. Under the Regulations, we will only process your Personal Data when there is a lawful basis to do so. Most commonly, we will use your Personal Data in the following circumstances:
    • Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you;
    • Legitimate Interest: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
    • Legal or Regulatory Obligation: Where we need to comply with a legal or regulatory obligation, such as our duties to any competent regulatory authority, court, government authority, or under AML/CFT regulations; or
    • Consent: Where you have given us explicit consent to do so. You have the right to withdraw consent at any time by contacting us.

How We Use Your Personal Data

  1. We use the information held about you for the following purposes:
    • To register you as a new client;
    • To provide and manage our products and services to you;
    • To manage our relationship with you, including notifying you of changes to our terms or privacy policy;
    • To comply with our legal obligations, including KYC, AML, and other regulatory requirements;
    • To administer and protect our business and this website (including troubleshooting, data analysis, testing, and system maintenance);
    • To invite you to events;
    • To send you intelligence or other similar information that we have produced for publication;
    • To deliver relevant website content and advertisements to you and measure the effectiveness of the advertising we serve; or
    • To make suggestions and recommendations to you about services that may be of interest to you.

Data Sharing and Disclosures

  1. We may share your Personal Data with the parties set out below for the purposes described in Section 5:
    • External Third Parties: such as other service providers that we may work with when providing you with services;
    • Service providers acting as Processors who provide IT, system administration, and other operational services;
    • Professional advisers including lawyers, bankers, auditors, and insurers;
    • Regulators and other authorities, including the ADGM Commissioner of Data Protection and the ADGM Authority, who require reporting of processing activities in certain circumstances; or
    • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
  2. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process it for specified purposes and in accordance with our instructions.

International Data Transfers

  1. As a business operating in an international financial centre, we may need to transfer your Personal Data outside of the ADGM.
  2. We will only transfer your Personal Data where:
    • The transfer is to a jurisdiction that the ADGM Commissioner of Data Protection has deemed to have an adequate level of protection for Personal Data; or
    • We have put in place appropriate safeguards to protect your Personal Data, such as by using ADGM-approved Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs). You may request further information about the safeguards we have applied to a particular transfer, or a copy of them, by contacting our DPO.

Data Security

  1. We have implemented appropriate technical and organisational security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know.
  2. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and the ADGM Commissioner of Data Protection of a breach where we are legally required to do so. Where we are required to notify the Commissioner, we will do so without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, in accordance with the Regulations.

Automated Decision-Making and Profiling

  1. We do not currently make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or that similarly significantly affect you. If we introduce such processing in the future, we will update this Privacy Policy and tell you about the logic involved, as well as the significance and likely consequences of that processing, in accordance with the Regulations.

Data Retention

  1. We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. As a general rule, client data is retained for a minimum of six (6) years after the end of our client relationship.

Your Legal Rights

  1. Under the Regulations, you have the following rights in relation to your Personal Data:
    • Right of Access: To request a copy of the Personal Data we hold about you;
    • Right to Rectification: To request correction of inaccurate Personal Data;
    • Right to Erasure (‘Right to be Forgotten’): To request the deletion of your Personal Data where there is no compelling reason for its continued processing;
    • Right to Restrict Processing: To request the suspension of the processing of your Personal Data;
    • Right to Data Portability: To request the transfer of your Personal Data to you or to a third party in a structured, commonly used, machine-readable format;
    • Right to Object: To object to the processing of your Personal Data where we are relying on a legitimate interest; and
    • Rights related to automated decision-making and profiling.
  2. To exercise any of these rights, please contact our DPO at thetherington@navigo-partners.com.

Complaints

  1. You have the right to make a complaint at any time to the ADGM Office of Data Protection, which is the supervisory authority for data protection issues in the ADGM. We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner, so please contact us in the first instance.
  2. The ADGM Office of Data Protection can be contacted at:

    Abu Dhabi Global Market Authorities Building
    ADGM Square, Al Maryah Island
    PO Box 111999, Abu Dhabi, UAE

    Email: data.protection@adgm.com

Changes to This Privacy Policy

  1. We keep our privacy policy under regular review. Any changes will be posted on this page, and where
    appropriate, notified to you by email.

    Last Updated: 24th June 2026