Navion — The Intelligent Platform for Digital Out-of-Home

1. Introduction

Navion Digital Ltd. ("Navion," "we," "us," or "our") is committed to protecting the privacy of individuals who interact with our website, platform, and services. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website at naviondigital.com (the "Site"), use our programmatic Digital Out-of-Home (pDOOH) platform, or engage with us in connection with our retail media network services.

By accessing or using our Site and services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue use of our services.

This Policy applies to Navion Digital Ltd., a company incorporated in Hong Kong (Business Registration No. [BRNO]), with its registered address at 404B, Block B, Sea View Estate, 4–6 Watson Road, North Point, Hong Kong.

2. Information We Collect

We collect information in the following categories:

2.1 Information You Provide Directly

Contact information (name, email address, phone number, job title, company name) when you complete enquiry forms, request a consultation, or correspond with us.

Business information provided in the course of establishing a commercial relationship, including company registration details, bank account information for revenue-sharing arrangements, and operational data about your retail locations.

Communications: records of correspondence, meeting notes, and support requests.

2.2 Information Collected Automatically

Log data: IP address, browser type and version, pages visited, time and date of visit, referring URL, and session duration.

Device information: hardware model, operating system, unique device identifiers.

Cookie and tracking data: as described in our Cookie Policy.

Analytics data: aggregated usage statistics collected via our analytics provider.

2.3 Platform and Network Data

For clients using the Navion platform: campaign data, impression logs, screen performance metrics, content scheduling data, and programmatic transaction records.

Aggregated and anonymised audience measurement data derived from DOOH screen networks, which does not identify individual persons.

Network health and device telemetry from managed media players and display hardware.

2.4 Third-Party Data

Data received from demand-side platforms (DSPs), data management platforms (DMPs), and other programmatic ecosystem partners in connection with campaign execution.

Publicly available business information used for commercial due diligence.

3. How We Use Your Information

We process personal data for the following purposes and on the following legal bases:

3.1 Service Delivery (Contractual Necessity)

To provide, operate, and maintain the Navion platform and managed services.

To execute profit-sharing and project-based commercial arrangements.

To manage hardware installation, network operations, and technical support.

To process programmatic advertising transactions on behalf of clients.

3.2 Business Operations (Legitimate Interests)

To respond to enquiries and communicate with prospective and existing clients.

To conduct network performance monitoring and quality assurance.

To generate revenue reports and financial reconciliation for profit-sharing partners.

To improve our platform, services, and operational processes.

To detect, prevent, and investigate fraud, security incidents, and misuse.

3.3 Marketing (Consent or Legitimate Interests)

To send marketing communications about our services, industry insights, and events, where you have provided consent or where we have a legitimate interest in doing so.

You may opt out of marketing communications at any time by clicking "unsubscribe" in any email or contacting us at [email protected].

3.4 Legal Compliance

To comply with applicable laws, regulations, and legal processes, including Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and applicable data protection laws in other jurisdictions where we operate.

4. Disclosure of Your Information

We do not sell personal data. We may share your information with:

4.1 Service Providers

Third-party vendors who assist in operating our platform and business, including cloud infrastructure providers, analytics services, email delivery services, and payment processors. These providers are contractually bound to process data only on our instructions and to maintain appropriate security measures.

4.2 Programmatic Ecosystem Partners

In connection with programmatic advertising transactions, certain campaign and inventory data is shared with DSPs, SSPs, and ad exchanges as required to execute campaigns. This data is processed in accordance with OpenRTB standards and applicable industry guidelines.

4.3 Retail and Property Partners

Where you are a retail partner, operational and revenue data relating to your network is shared with you as part of our managed services and profit-sharing reporting obligations.

4.4 Professional Advisors

Legal counsel, accountants, and other professional advisors, subject to confidentiality obligations.

4.5 Legal and Regulatory Authorities

Where required by law, court order, or regulatory authority, or where necessary to protect the rights, property, or safety of Navion, our clients, or the public.

4.6 Business Transfers

In connection with a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of the transaction, subject to appropriate confidentiality protections.

5. International Data Transfers

Navion operates primarily in the Asia-Pacific region. Your data may be processed or stored in jurisdictions outside your country of residence, including Hong Kong, Singapore, and other countries where our service providers operate. We take appropriate steps to ensure that international transfers of personal data are protected by adequate safeguards, including contractual protections consistent with applicable data protection law.

6. Data Retention

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by law. Specifically:

Client account and commercial records: retained for the duration of the commercial relationship and for 7 years thereafter, in accordance with Hong Kong company law requirements.

Marketing contact data: retained until you opt out or withdraw consent.

Platform usage logs: retained for up to 24 months for operational and security purposes.

Programmatic transaction records: retained for up to 36 months for audit and reconciliation purposes.

When data is no longer required, we securely delete or anonymise it.

7. Your Rights

Under the Hong Kong Personal Data (Privacy) Ordinance and, where applicable, other data protection laws, you have the following rights:

**Right of Access**: To request a copy of the personal data we hold about you.

**Right of Correction**: To request correction of inaccurate or incomplete personal data.

**Right to Opt Out of Direct Marketing**: To instruct us not to use your personal data for direct marketing purposes.

**Right to Erasure** (where applicable under relevant law): To request deletion of your personal data in certain circumstances.

**Right to Restriction**: To request that we restrict processing of your data in certain circumstances.

**Right to Data Portability** (where applicable): To receive your data in a structured, machine-readable format.

To exercise any of these rights, please contact our Privacy Officer at [email protected] or by post to our registered address. We will respond within 40 days as required by the PDPO.

8. Cookies

We use cookies and similar tracking technologies on our Site. Please refer to our Cookie Policy for detailed information about the types of cookies we use, their purposes, and how to manage your cookie preferences.

9. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include encryption in transit and at rest, access controls, regular security assessments, and staff training. For more information, please refer to our Security page.

No method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security.

10. Children's Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at [email protected].

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated Policy on our Site with a revised "Last Updated" date. We encourage you to review this Policy periodically.

12. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Privacy Officer:

Privacy Officer

Navion Digital Ltd.

404B, Block B, Sea View Estate

4–6 Watson Road, North Point

Hong Kong

Email: [email protected]

Phone: +852 3422 5505

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong if you believe your data protection rights have been violated.