Privacy Policy

NAVIG8 Services Group LLC, trading as NAVIG8 (‘we,’ ‘our,’ or ‘us’), facilitates a range of offshore services. These include the formation of offshore trusts, companies, and other legal entities, second citizenships, international banking services, advisory services, and any related or ancillary services that may arise across multiple jurisdictions (‘Services’).

Our registered office is Hunkins Plaza, Main Street, Charlestown, Nevis. Our Services are also available via our website (our “Website”) at navig8.global.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how this policy applies, our relationship with you and how and why we collect, store, use and share any information that can directly or indirectly identify you (personal information). It also explains your rights in relation to your personal information and how to contact us, or the relevant regulator in the event you have a complaint. 

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).

If you are aged under 18, we recommend that you speak to an adult that you trust if you have any difficulties reaching an informed decision regarding the activation of any use of your information or our treatment of your information.

To find out more, click on any of the sections below:

What this policy applies to

This privacy policy applies to the use of our Website and Services and to all individuals who provide personal information to us in relation to our Services (“you”). 

We collect, use and are responsible for certain personal information about you to provide our Services to you. 

Our Website may link to other apps, websites or services owned and operated by certain trusted third parties, for example to make additional products, information and services available to you

These other apps, websites or services may also gather information about you in accordance with their own separate privacy policies for their own purposes, including for example, to develop and improve their identity verification services designed to prevent and detect fraud. 

For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate.

Our relationship with you

We collect, use and are responsible for certain personal information about you to provide the Services to you. 

In respect of your personal information that we process if we market to you, we are the controller of that personal information. 

Information we collect about you when you use our Services

We may collect, use, store and transfer different kinds of personal data about you, including the following:

  • Identity Data: information to check and verify your identity, including first name, last name, title, date of birth.

  • Contact Data: includes your current residential address, previous addresses, email address and telephone numbers.

  • Financial Data: includes bank account details and to conduct source of funds checks using open banking data technology to access and analyse your financial and banking information.

  • Transaction Data: includes details about payments to and from you including dates, amounts and beneficiary details.

  • Technical Data: includes internet protocol (IP) address, 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 our Services.

  • Details of any information, feedback or other matters you give to us by phone, email, post or via social media.

  • Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

  • Usage Data: includes anonymous analytical data about how you use our services.

  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Location Data: if you choose to give this to us.

  • Biometric Data: photograph or liveness video (see section below)

How your information is collected

We collect personal data from you when you:

  • enter or send us information, such as when you register with us, 
  • contact us (including via email), 
  • send us feedback, 
  • purchase products or services via our Website, 
  • post material to our Website or
  • complete customer surveys.

How and why we use your information

We will use the information that you provide during the setup process to:

  • To create and maintain your account 
  • To provide our Services
  • To respond to your enquiries and provide assistance
  • To ensure compliance with applicable Anti-Money Laundering (“AML”) / Combating the Financing of Terrorism (CFT) regulations and/or other laws and regulations.
  • Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us.
  • Enforcing legal rights or defending or undertaking legal proceedings.
  • Customising our Website and its content to your preferences based on a record of your selected preferences or on your use of our Website.
  • Retaining and evaluating information on your recent visits to our Website and how you move around different sections of our Website for analytics purposes to understand how people use our Website so that we can make it more intuitive or to check our Website is working as intended.
  • Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or services or other important notices.
  • Protecting the security of systems and data used to provide the Services.
  • Statistical analysis to help us understand our customer base.
  • Updating and enhancing customer records.
  • Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant.
  • Marketing our services to existing and former customers (See ‘Marketing’ below for further information).
  • To share your personal information with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.

Under data protection law, we can only use your information if we have a proper reason, e.g:

  • where you have given consent
  • to comply with our legal and regulatory obligations
  • for the performance of a contract, or to take steps at your request before entering into a contract, or 
  • for our legitimate interests or those of a third party


A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Biometric Data

The personal information we collect may include data that may be considered biometric data in some jurisdictions. 

We may process biometrics to verify whether provided facial images are likely to match depending on the Service you have chosen. The processing of biometrics means extracting facial features from uploaded or recorded facial images on government-issued identity documents submitted by the user and comparing them. 

We use third-party service providers for the purposes of processing Biometric Data, including collecting, exporting, storing and otherwise processing biometric data, including your personal information. 

Marketing

We may use your information to send you updates (by email, text message, telephone or post) about our Services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your information for marketing purposes (see above ‘How and why we use your information’). 

You have the right to object/opt out of receiving marketing communications at any time by:

  • contacting us at legal@navig8.global     
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts, or
  • clicking the “unsubscribe” link on any marketing email received.     

 

We will always treat your information with the utmost respect and never sell OR share it with other organisations outside the Volentio Limited group for marketing purposes.

For more information on your right to object at any time to your information being used for marketing purposes, see ‘Your rights’ below.

Who we share your information with​

We routinely share your information with:

Service providers we use to help us run our business or provide the services or functionalities in the app, (e.g. marketing agencies, hosting service providers of the systems that deliver the service or app’s functionalities and services, IT software and service providers, administrative service providers, and analytics and search engine providers). 

We only allow the service providers to handle your information if we are satisfied, they take appropriate measures to protect your information. We also impose contractual obligations on service providers to ensure they can only use your information to provide services to us and to you. 

We or the third parties mentioned above occasionally also need to share your information with:

  • our or their external auditors, e.g. in relation to the audit of our or their accounts — the recipient of the information will be bound by confidentiality obligations
  • our or their professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
  • law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
  • other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your information will be bound by confidentiality obligations
  • Identity verification providers, to comply with legal or regulatory requirements;
  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our website;
  • credit reference agencies;
  • IT and software providers who supply us with our IT infrastructure for the provision of our services and administering our business (including our internal and external communications) and who also help us manage our customer and contact databases, customer relationships and marketing.

 

How long your information will be kept

Different retention periods apply for different types of your information, but we keep your information for as long as we have a contract with you or as we reasonably need it to fulfil the purposes for which the data was collected.

Transferring your information out of the UK or the EEA

 It is sometimes necessary for us to transfer your information to countries outside the UK or EEA. In those cases, we will comply with applicable UK and EEA laws designed to ensure the protection of your information.

We take measures to help protect your personal information when it is transferred from the EEA, Switzerland, or the United Kingdom (“UK”) to other countries. We may rely on European Commission adequacy decisions or UK adequacy regulations for certain countries or include standard contract clauses issued by the European Commission or by the UK Information Commissioner’s Office in our contracts. 

In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your information outside the UK or EEA unless we can do so on the basis of an alternative mechanism or exception provided by UK and/or EEA data protection laws. 

If you would like further information about data transferred outside the UK, or the EEA please contact us our Data Protection Manager (see ‘How to contact us’ below).

Cookies and other tracking technologies

We use cookies to help you navigate efficiently and perform certain functions. You will find detailed information about all cookies in our Cookie Policy which you can find here

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data: The right to be provided with a copy of your personal data.

Correction (also known as rectification): The right to require us to correct any mistakes in your personal data.

Erasure (also known as the right to be forgotten): The right to require us to delete your personal data in certain situations.

Restriction of use: The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability: The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

The right to object:

—at any time to your personal data being used for direct marketing (including profiling); or

—in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.

Not to be subject to decisions without human involvement: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.

The right to withdraw consents: If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by using our contact details in the ‘How to contact us’ below. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). 

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and
  • let us know which right(s) you want to exercise and the information to which your request relates.

Further information

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

  • provide enough information to identify yourself (eg your full name, address and matter reference number) and any additional identity information we may reasonably request from you, and

  • let us know which right(s) you want to exercise and the information to which your request relates

 

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

If you are unhappy with our processing of your personal information you also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Keeping your information secure

We have appropriate security measures to prevent your information from being accidentally lost or used or accessed unlawfully. We limit access to your information to those who have a genuine business need to access it. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example via the app or by other means, such as email.

How to contact us

You can contact us and/or our Data Protection Manger by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Data Protection Manager
NAVIG8 Services Group LLC
Suite 2, Hunkins Plaza,
Main Street, Charlestown, Nevis, WI
legal@navig8.global