Privacy Policy

Navarino Data Protection Policy

Introduction

Last modified: April 2025 

This privacy policy describes how we will collect, use, share and otherwise process your personal data in connection with your use of our website Navarino Capital (the Website) and any of our services that are accessible through the Website (the Services).

The Website is not intended for those under 18 and we do not knowingly collect data relating to children.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Navarino Capital Limited and Navarino Associates Limited (together, with their affiliates, Navarino) (we, us or our in this Policy).

Contact details

Our full details are: Navarino Associates Limited, 42 Berkeley Square, W1J 5AW, Company number: 05568977.

Telephone: 07771895265

E-mail: jmarler@navarinoltd.com

Name of Privacy Manager:  James Marler

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on the date at the beginning of it. It may change and, if it does, those changes will be posted on the Website. You may be required to read and acknowledge the changes to continue your use of the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links and sites

Our Website will contain links to and from the websites of third parties.

Please note that these websites (and any services accessible through them) are controlled by those third parties and are not covered by this privacy notice. You should review their own privacy notices to understand how they use your personal data before you submit any personal data to these websites or use these services.

The data we collect about you

We collect, use, store and transfer different kinds of personal data about you.  To make it easier for you to use this privacy notice, we group these into the following categories. Each of these categories is described in more detail

• Contact Data: e-mail address and telephone number.

• Cookies Data: the information collected through the cookies and similar technologies listed in our Cookies Policy (set out in this Policy).

• Device Data: the type of device you use (Device), a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), network information, your mobile operating system, screen type and resolution, the type of web browser you use, the time zone setting.

• Direct Marketing Data: information which we collect and store as a result of you being added to our mailing databases.

• Identity Data:  name, surname, gender, country of residence, date of birth.

• Location:  details of your use of our Services including, but not limited to, traffic data, statistics of content uploaded, downloaded and viewed. We may make use of location data sent from Devices.  You can turn off this functionality at any time by turning off the location services settings for the mobile application on the Device.

• Personalisation Data:  data about your preferences while using the Website.

• Technical Data:  protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Services.

We do not intentionally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

We will collect data relating to criminal offences through the measures we take to secure and protect our users. Further details can be found at Criminal offence data and special category data.

How is your personal data collected?

We collect your personal data in the following way:

• Registration. We collect your Identity Data and Contact Data when you register with us.

• Communications. When you communicate with us via email, telephone, one of our online forms or chat we collect your Contact Data. 

• Information you generate when using our Services. Each time you access and use our Services we collect Device, Cookies and Personalisation Data. Please see our cookie notice for further details.

• Information we collect through monitoring the use of our Website and Services. Each time you access and use our Services we collect information about that access and use, being Cookies, Device and Personalisation Data.

• Direct Marketing. We collect and record Direct Marketing Data when we add you to our marketing database, you request to change your direct marketing preferences, or you interact with our direct marketing communications.

• Cookies

We use cookies (small files placed on your device) and other tracking technologies on the Website and in our direct marketing emails to improve your experience and our development of our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:

• Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by by sending us a message at jmarler@navarinoltd.com or using our cookie banner (see Your legal rights below).

• Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.

• Legitimate interests. 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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

1) Delivery and improvement of our Services

2) Account management and profiling

3) Direct marketing

4) Troubleshooting, improvement and security

5) Rights and obligations

6) Cookies and personalisation

7) Other communications

8) Personal data sharing

9) Business contacts

Automated decision making and profiling

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

Criminal offence data and special category data

We do not intentionally collect criminal offence data about you. However, we may process data relating to criminal offences in monitoring the use of our Website and Services for security purposes, where we suspect you may have committed a crime, such as attempting to make a fraudulent purchase or claim or circumvent the security of the Website or Services. In such circumstances we will provide that information to law enforcement and/or use it to establish, exercise or defend a legal claim. In those circumstances, according to the type of activity and purpose, we will rely on legitimate interests (protecting our business, employees and other users) and legal obligation (where required by legal, judicial or law enforcement to disclose or process that information.

Disclosures of your personal data

We may share your personal data with the following third parties:

• Internal third parties. Other companies who provide IT and system administration services and undertake leadership reporting.

• External third parties.

  • Service providers who provide IT and system administration services, hosting services for our Website, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.

  • Our professional advisors including lawyers, auditors, insurers, and consultants who provide legal, accounting, insurance and other advisory services.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

  • Tax authorities, regulators, law enforcement, public authorities or other third parties based in any jurisdiction where necessary to exercise our rights or comply with a legal obligation.

International transfers

Where we transfer your personal data between the UK and the EEA those transfers are made pursuant to the UK government's adequacy decision in favour of countries in the EEA and the European Commission's adequacy decision in favour of the UK.

Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers located outside the UK or EEA. we use specific contracts which give personal data the same protection it has in the UK and EEA. 

Please contact the data privacy manager using the contact details above if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.

Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you do not use the Services for a period of 18 months, then we will delete your personal data.

Your legal rights

You have the following rights under data protection laws in relation to your personal data.

• Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it. 

• Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.) 

• Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. (In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.) 

• Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.

• Restriction. Request that we restrict or suspend our processing of your personal data:

  • if you want us to establish the data's accuracy;

  • where our use of the data is unlawful, but you do not want us to erase it;

  • where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or

  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Data portability. Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract. 

• Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

• Complain to the data protection regulator. If you are unhappy with how we process your personal data, we ask that you contact us first using the details below so that we have the chance to put it right. However, you also have the right to make a complaint to the at any time to the Information Commissioners Office (ICO): Make a complaint about data protection and personal information | ICO

You can exercise any of these rights at any time by contacting us at: jmarler@navarinoltd.com