Privacy Policy


NAT Securities Inc. (NAT),
Authorized and regulated by VFSC
Company Number 700646


This Privacy Policy (“Policy”) explains the privacy practices employed by NAT Securities Inc (the “Company” and/
or “We”, and/or “Us”) in providing services to its clients (“Client” and/or “You”).

This privacy notice aims to give you information on how the Company collects and processes your personal
data through your use of this website, including any data you may provide through this website when you sign up to any of the services offered by the Company. This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specifc occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices
and is not intended to override them.


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 your relationship with us.


This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


Personal data, or personal information, means any information about an individual from which that person can be identifed. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped
together follows:
a) Application information

Personal information Client provides to the Company in its application form, such as name, address, date of birth, email address, income and income source etc. in order to facilitate the evaluation of Client’s application. The information provided is also used for the purposes of communicating with the Clients.

b) Transaction information

Information about the anticipated volume and value of Client’s transactions with us and income information provided in order to enable the construction of Client’s economic profle.

c) Verifcation information

Information necessary to verify Client’s identity, such as an identifcation card, passport or driver’s license. This also includes background information the Company receives about the Client from public records or from other entities not afliated with the Company.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specifc website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

We do not 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). Nor do we collect any information about
criminal convictions and offences.


Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contractual relationship you have with us but we will notify you if this is the case at the time.


We use different methods to collect data from and about you including through:
a) Direct interactions
You may give us your personal data by flling in forms or by corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

b) Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
c) Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources such as Technical Data from analytics providers such as Google based outside Vanuatu;


a) Circumstances in which we may use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract that we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us at the following ttttemail: [email protected]

b) Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identifed what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specifc purpose for which we are using your data.


Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new client• identity details
• contact details
• address details
• fnancial profle
• economic profle
• Performance of a contract with you
To process and deliver your order including:
Manage payments, fees and charges
Collect and recover money owed to us
• identity details
• contact details
• address details
• fnancial profle
• economic profle
• transaction
• marketing and
• Performance of a contract with you
• Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
• Notifying you about changes to our terms or privacy policy
• Asking you to leave a review or take a survey
• identity details
• contact details
• address details
• fnancial profle
• economic profle
• transaction
• marketing and
• Performance of a contract with you
• Necessary to comply with a legal obligation
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
• identity details
• contact details
• technical
• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
• Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you• identity details
• contact details
• profle
• usage
• marketing and communications
• technical
Necessary for our legitimate interests (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and ttttexperiences• technical
• usage
Necessary for our legitimate interests (to defne types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you• identity details
• contact details
• technical
• usage
• profle
Necessary for our legitimate interests (to develop our products/services and grow our business)


\c) Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and
d) Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profle Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered our website for the purpose of receiving information and, in each case, you have not opted out of receiving that marketing.
e) Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Company’s group of companies for marketing purposes.
f) Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time at the following email address: [email protected]
g) Cookies
The Company’s Technology provider may use “cookies” and other tracking technologies to collect Anonymous Information. A “cookie” is a small text fle stored by a web browser when users access a website. Cookies enable the website browsed to save and identify the user’s browsing activity and individual preferences, for example, to collect information about the User’s activity in relation to the Services and it may serve to recall Personal Data previously indicated by a User, such as his/her user ID and password for access to the Service(s).


In particular, the Company’s technology providers might be using “Flash Cookies” and/or local storage technologies to help users access the Client’s accounts seamlessly and save their account settings to their browsers. Do note that most browsers allow controlling cookies, including whether or not to accept them and how to remove them.


Reasons why the Company is using Cookies
Cookies are used on the Company’s website to:

• Identify the web browser and the settings;
• Verify our client’s identity to ensure his/her personal data protection;
• Remember the client’s individual preferences.

How are Cookies used by the Company?
Cookies are downloaded by your browser whenever you access our websites. The stored data is used to track your browsing path and the pages you visit most frequently.

Your privacy is important to us, so the gathered information will be stored for a period not less than the one we are required to observe in order to comply with the applicable rules and regulations.

Cookies are commonly introduced to improve the efciency of websites. By tracking our user’s behavior, we seek to make our website more user-friendly and tailored to your preferences.

You can, if you wish, set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Cookies do not contain any executable code or software viruses. Instead, it is more like your personal ID that is updated whenever you access our website.


We may have to share your personal data with third parties for the purpose of carrying out our services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specifed purposes and in accordance with our instructions.


We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confdentiality.

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




a. How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfl the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal