Privacy Policy

In this Privacy Policy, 'us' 'we', 'our' or ‘Hdao’ means Navigation Joy Limited and our related bodies corporate. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information. By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We will change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your bank or credit card information.

Using our website and cookies

If you are browsing our website, we may collect personal information about when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that puts the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, we will consider this personal information. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

What personal information do we collect?

If you create an account, we may collect the following types of personal information:


mailing or street address;

email address;

telephone number and other contact details;

age or date of birth;

bank account and credit card information;

drivers’ licence, passport or other types of identification;

government issued cards, concession card, senior card;

your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;

details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;

any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information;

any information relating to you and/or your account collected from the use of ‘cookies’;

information you provide to us through customer surveys; or

any other personal information that may be required in order to facilitate your dealings with us.

We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

register on our website;

communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;

interact with our sites, services, content and advertising; or

invest in our business or enquire as to a potential purchase in our business.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees.

Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

to enable you to access and use our website and services;

to enable you to subscribe for Digital Assets;

to process payments;

to operate, protect, improve and optimise our website, services, business and our users experience, such as to perform analytics, conduct research and for advertising and marketing;

to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;

to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

to comply with our legal and compliance obligations and other financial compliance, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and

to consider your employment application.

We may also use your personal information for related purposes which would reasonably be expected without your permission.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the services that you receive.

Do we use your personal information for direct marketing?

We and our carefully selected business partners may occasionally send you direct marketing communications and information about our services, products, special deals and promotions. This may take the form of emails, SMS, mail, chats or other forms of communication. At any time, you may opt-out of receiving marketing materials from us by contacting us using the information provided below or by using the unsubscribe link at the bottom of each of our emails.

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this privacy policy to:

our employees and related bodies corporate;

third party suppliers and service providers (including providers assisting us with the verification of user identities, providers for the operation of our websites and/or our business or in connection with providing our services to you, such as outsourced helpdesk service providers);

issuers of Digital Assets to meet their KYC (know your client/Digital Asset holder) requirements;

professional advisers, dealers and agents;

payment systems operators (e.g. merchants receiving card payments);

our existing or potential agents, business partners or partners;

our sponsors or promoters of any competition that we conduct via our services;

anyone to whom our assets or businesses (or any part of them) are transferred;

cloud storage providers;

specific third parties authorised by you to receive information held by us; and/or

other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

If you believe your personal information has been compromised by a data breach, please advise us using the contact details set out below. Unless otherwise required by law or where reasonably expected to, we will not disclose your personal information when addressing the data breach concern unless you have consented.

Disclosure of personal information

We may disclose personal information to related parties and third parties who may provide some of the Services we offer, or secure information storage solutions located in Singapore.

When you provide your personal information to us, you consent to the disclosure of your information to other jurisdictions.


We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modifications or disclosure by routinely assessing such risks. We use a number of physical, administrative, personnel and technical measures to address such risks including implementation of an audit trail of additions, deletions and alterations of personal information and monitoring staff access to protect your personal information. However, we cannot guarantee the security of your personal information.


Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the email noted below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will advise you of the reason why. We will need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, please contact us with details and we will take reasonable steps to ensure that it is corrected.

Deactivating your account

If you deactivate your Hdao account, we will mark your account in our database as “deactivated”, but will keep your account information in our database for a minimum of 7 years period of time. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. If you do deactivate your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcements, as required by law, or in accordance with this Privacy Policy.

Making a complaint

If you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:



17 APRIL 2019