Privacy Policy – Navis Capital Partners

Privacy Policy

Effective date: 11 April 2018

Thank you for visiting the website of Navis Capital Partners (“Navis Capital”, “we” or “us”). Your privacy is very important to us. This Privacy Policy (“Policy”) seeks to help you understand how we collect, use, communicate and disclose information about you when you visit our website (“Site”) or when you provide us with your information in your dealings / communications with us.

Consent

Your visit to this Site is subject to this Policy and our Terms & Conditions. Please review this Policy and the Terms & Conditions carefully, as by visiting this Site and / or by providing us with your Personal Information (as hereinafter defined) whether via e-mail communications or otherwise, you are deemed to have consented to the terms of this Policy, including the practices described below.

If we do not receive any notification from you in relation to the processing of your Personal Information, we shall continue to process the same in accordance with the terms of this Policy, on the basis that you continue to consent and do not have any objections with respect to our processing of your Personal Information in accordance with this Policy.

Please note that if you do not consent, or if you later seek to revoke your consent to the processing of your Personal Information, this may result in us not being able to provide you with our services.

Information Collection

“Personal Information” means any information that is directly or indirectly associated with a specific person, or that reasonably can be used to identify a specific person, including without limitation, a person’s name, e-mail address, phone number and/or mailing address. If we collect your Personal Information, we will do so by lawful means and, where appropriate, with the knowledge or consent of the individual concerned. We will collect and use Personal Information solely for fulfilling those purposes specified by us and / or as set out in this Policy and for ancillary purposes, unless we obtain the consent of the individual concerned or as required by law.

We may automatically collect information about your computer or other applicable electronic device when you visit our Site. This information may include your Internet Protocol (IP) address, domain name, browser type, Internet Service Provider (ISP), date and time of your request and information provided by tracking technologies, such as JavaScript, cookies and other similar technologies (“Automatically Collected Information”). Tracking technologies help to collect session information, including page interaction information, page response times, download errors, length of visits to certain pages, and methods used to browse away from the page. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use this Site, but your ability to use some features of this Site may be limited. We may use Automatically Collected Information to better understand how visitors use this Site, analyse their behaviour, interests and demographics to improve the content of this Site and further develop our businesses and services.

We do not consider Automatically Collected Information to be Personal Information. However, if we connect any Automatically Collected Information to any Personal Information collected about you, we will treat such Automatically Collected Information in accordance with the terms of this Policy.

Please note that to the extent that you voluntarily disclose to us any Personal Information of another individual, if at all, in the course of your dealings with us, we shall assume, without independent verification, that you have obtained such individual’s consent for the disclosure of such Personal Information as well as the processing of the same in accordance with the terms of this Policy.

Sources of Information

Your Personal Information will not be collected via the Site. However, when you reach out to us with any enquiries and / or during the course of our dealings with you, we may collect and process your Personal Information provided by you directly to us whether via e-mail communications and / or otherwise.

Purposes of Collection

Any Personal Information which we collect from you are processed for the following purposes:

    1. To communicate with you via telephone, mail, e-mail, facsimile and/or any other forms of communication in order to respond to any enquiries you may forward to us via the ‘Contact Us’ form and/or otherwise;
    2. For the facilitation of transactions / contractual dealings you have or may have with us;
    3. In order for us to provide you with our services; and
    4. In order to fulfil any purpose directly related to the purposes above.

Information Disclosure

We may provide your Personal Information to our third party service providers that provide services to help us with our business activities such as analytics providers, the provider of our investor portals and/or technology service providers, amongst others. These service providers may be located outside Malaysia. We recommend that you review the privacy policy of any service provider you interact with.

We may disclose Personal Information as required by law or applicable court order. Additionally, we may disclose Personal Information when we believe that disclosure is necessary to protect our property, including tangible or intangible property. We may also disclose Personal Information in order to protect our interests and/or rights, such as to investigate fraud or in response to a request from any governmental or regulatory authority.

In addition, you will appreciate that we are part of the Navis Capital group of companies which operates in multiple jurisdictions. Accordingly, access to your Personal Information may in certain instances be granted to other entities within the Navis Capital group of companies whether within and / or outside of Malaysia.

Links to Other Websites

The Policy applies only to any Site owned by Navis Capital that links to this Policy. It does not apply to any third-party website or application to which the Site may link, such as the websites of our portfolio companies or investor portals. We cannot be held responsible or liable for any loss or damage incurred by a user as a result of visiting such websites. We recommend that you review the privacy policies of any such sites before you submit information there.

Information Protection

We have in place, administrative, operational and technical, processes and methods designed to maintain the integrity and security of our databases, including firewalls. Please be aware that while all reasonable measures have been taken to ensure the accuracy of information provided on this Site, the accuracy and reliability of any such information on this Site cannot be guaranteed because the internet is not a fully secure medium. We will not be responsible or liable for any damage, loss or cause of action arising out of or relating to the disclosure of your Personal Information.

Amendments to this Privacy Policy

Navis Capital reserves the right, in its sole and absolute discretion, to modify or amend this Policy in any way and at any time, without prior notice. If we update our Policy, we will post the updated Privacy Policy here. Any such changes will be effective immediately upon posting.

International Use

Please note that this Site is hosted in Malaysia and only complies with the applicable laws of Malaysia. This Site does not comply with the laws of any jurisdiction other than Malaysia. The laws of Malaysia may not afford your Personal Information the same privacy rights as your home country or jurisdiction. By using this site, you are consenting to the processing of your Personal Information consistent with the terms of this Policy and the transfer of your Personal Information to Malaysia.

Contact Us

If you wish to access, correct, and / or limit the processing of your Personal Information which you have submitted to us, to make any inquiries or complaints about the processing of such Personal Information or if you have any questions or comments about this Policy, please contact us using the Contact Us Page. Otherwise, you may also choose to direct any questions to our Data Protection Officer, at Level 17, Axiata Tower, 9 Jalan Stesen Sentral 5, Kuala Lumpur Sentral, 50470 Kuala Lumpur, Malaysia or email privacy@naviscapital.com