Privacy Notice

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We endeavour to maintain the highest standards of confidentiality and to respect the privacy of our customers and associated persons who deal with us. Our commitment to privacy includes being transparent about the nature and extent of the personal data processing we undertake. This privacy statement aims to inform you about how we collect, store, use and disclose information about you when you:

  • interact or use our websites;
  • register and/or attend any of our events, webinars, or the conferences we host;
    and,
  • if you use any of our products, services or applications (collectively the “services”) in any manner.

Who we are

JN Cayman (formerly the National Building Society of Cayman) is the only building society in the Cayman Islands and has operated in the jurisdiction since 1992. Our offices are currently located at 29, Elgin Avenue, George Town, Grand Cayman.

JN Cayman, is a member company of The Jamaica National Group Limited (JN Group – our parent company). JN Group has its Head Office in Jamaica and has subsidiary operations in the United Kingdom, USA and Canada.  JN Cayman takes its data protection and information security responsibilities very seriously. We obey the Data Protection Law of Cayman.  Accordingly, the effective management of all personal data, including its security and confidentiality, lies at the very heart of our business and underpins our practices and processes.

As a Group with a global presence, JN Group is subject to the varying requirements of data protection legislation in the jurisdictions where it operates. JN Group aims to be as consistent as possible, to obey all applicable laws and to apply the highest standards of data protection to the processing of personal data.

What information do we collect?

We gather from the following sources various types of information that may identify you as an individual ( i.e. “personal data”):

Websites or Events: We may collect any personal information that you choose to send or provide to us. If you use the online forms in our JN Cayman Live system or if you register for a JN Cayman account we collect personal information from you. We may also collect personal information from you if you participate in a JN Cayman event. If you contact us through our website we keep a record of the correspondence.

The Services we provide: We receive and store information you provide directly to us. For example, when opening an account or transacting business through our offices, we may collect your personal information.

The types of information we may collect directly from our customers includes:

  • Valid Photo Identification (ID), for example a Passport, Drivers Licence or ID card;
  • Proof of Employment;
  • Proof of address (for example a utility or credit card bill);
  • Email address;
  • A character reference;
  • Birth certificate;
  • Declaration of US citizenship, Tax residency, if appropriate;
  • Tax reference number;
  • Employment status;
  • Politically Exposed Person declaration, if applicable; and
  • Public Office Exposure, if applicable, as well as any other information the customer chooses to provide us.

If information is uploaded to our systems in connection with our services, we retain this information in line with our retention policy.

How do we use the information?

We may use the information collected from our customers in connection with the services we provide for a range of reasons, including to:

  • provide, operate and maintain the agreed services;
  • process and complete transactions, and communicate related information, including transaction confirmations, invoices, statements and information updates;
  • manage our customers’ use of the services, respond to enquiries and comments and provide customer service and support;
  • send customers technical alerts, updates, security notifications, and administrative communications;
  • verify customers’ identities and check credit with other financial institutions and credit reference agencies;
  • investigate and prevent fraudulent activities, unauthorized access to the services, and other illegal activities; and,
  • for any other purposes about which we notify customers and users.

When you use the Websites: When you visit our Websites, we may collect certain information related to your device, including, but not limited to your device’s IP address, the web pages your device visited, and the time that your device visited our Website. The information collected also includes:

  • Usage information – we keep track of user activity in relation to the types of services our customers and their users utilize, as well as the performance metrics related to their use of the Services;
  • Log information – we log information about our customers and their users when they use one of the services including Internet Protocol (“IP”) address; and,
  • Information collected by cookies and other similar technologies – we use various technologies to collect information which may include saving cookies to users’ computers.

For further information, please read the section headed “Cookies” in the “Your Privacy Rights” section of this statement.

We collect customer information via our websites:

  • to administer our website and our events as well as for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
  • to improve our website to ensure that content is presented in the most effective manner for you and for your computer;
  • for trend monitoring, marketing and advertising;
  • for compliance purposes, for example, to comply with Know Your Client, (‘KYC’), and Anti Money Laundering, (‘AML’) laws and regulations;
  • for purposes made clear to you at the time you submit your information – for example, to fulfil your request for an information note about our services; and,
  • as part of our efforts to keep our website secure.

We may access and use information from credit reference and fraud prevention agencies when you open your account and periodically to:

  • manage your accounts, including assessing your credit worthiness and carrying out the necessary checks to avoid customers becoming over-indebted;
  • to prevent criminal activity, fraud and money laundering;
  • to check your identity and verify the accuracy of the information you provide to us; and,
  • to trace debtors and recover debts.

Lawful basis

The Lawful basis for processing your personal data includes:

  • Consent: Your personal information may be processed for certain purposes based on your specific permission or consent.
  • Performance of a contract: We process your personal data as necessary based on the products and services that we agree to provide to you or in taking steps to provide products and services that you have requested.  “Performance of a Contract” is our lawful basis for processing your personal data for opening an account, maintaining your account details, providing services connected with an account and for our notary service for the arrangement of Mortgages and Loans.
  • Legal Obligation: We are required by law to collect and use certain personal data about you as we provide you with products and services. Please note that if you object to such legally required processing of your personal data then it may not be possible for us to continue to provide products and services to you.  These legal obligations may include processing to confirm your identity, to perform checks and monitor transactions, and location data for preventing and detecting crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions.  These legal obligations may also require us to process information about criminal convictions to investigate and gather intelligence on suspected financial crimes, fraud and threats and to share data with law enforcement and regulatory bodies.

We are legally obliged to assess affordability and suitability of credit for initial credit applications and throughout the duration of the relationship, including analyzing customer credit data for regulatory reporting.  We have a legal obligation to report suspicious activity and comply with court orders.

  • Legitimate Interest: JN Cayman LiveWe may also need to process your personal data to satisfy our legitimate interests to operate JN Cayman as appropriately as possible.  In doing so we are careful not to prejudice your rights and freedoms nor your legitimate interests.  We have a legitimate interest to ensure network and information security if you use any of our systems such as JN Cayman Live, and for Credit Checking your details and for the purposes of direct marketing, to provide you with the most appropriate products and services. JN Cayman will not share your information with third parties for the marketing purposes of those third parties without your permission.  We also have a legitimate interest to process your personal data for risk and general financial, accounting and management reporting to internal management and supervisory bodies.

Retention policy            

Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant company is located and the applicable local legal or regulatory requirements. We normally keep customer account records for up to seven years after your relationship with the Society ends, then the information is securely destroyed.

We have Closed Circuit Television (CCTV) in various locations on our premises. CCTV is kept until the storage is full and then it is overwritten. We have some cameras that take constant images and some that are activated by motion and consequently our retention policy varies by premises. Our retention policy for CCTV footage varies between 14-90 days depending on the location and nature of recording. We will supply footage for lawful purposes, if we have it, but do not commit to supplying any footage over 14 days.

Job applicant’s data is kept only for the duration of the application process and is subsequently destroyed if the applicant is unsuccessful.

We may also keep your data for longer than seven years if we cannot delete it for legal, regulatory or technical reasons.

How do we share and disclose information to third parties?

We do not rent or sell your personal information to anyone. We may share and disclose information (including personal information) about our customers in the following limited circumstances:

  • We share your personal data where required for the provision, administration and support of your products or services. If you ask us to, we will share your personal data with any third party that provides you with account information or payment services. If you ask a third-party provider to provide you with account information or payment services, you’re allowing that third party to access information relating to your account.  We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you;
  • we may share your information with the Royal Cayman Islands Police Service if requested to do so;
  • we may share your information for compliance purposes with national law enforcement agencies in other countries if requested to do so for compliance purposes;
  • we may share your information with third party vendors, consultants and other service providers whom we employ to perform tasks on our behalf;
  • we may share your information with credit reference agencies, and they will give us information about you for the purpose of credit and identity checks;
  • we may share information with other banks and third parties where required by law to help recover funds that have entered your account as a result of a misdirected payment by such a third party;
  • we may share information with other banks to help trace funds where you are a victim of suspected financial crime and you have agreed for us to do so, or where we suspect funds have entered your account because of a financial crime;
  • we may share information with third parties providing services to us, such as correspondent banking, and agents and sub-contractors acting on our behalf;
  • If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to fraud prevention agencies.  Law enforcement agencies and other organisations may access and use this information;
  • In the event that any additional authorised users are added to your account, we may share information about the use of the account by any authorised user with all other authorised users.

If JN Cayman receives your personal information and subsequently transfers that information to a third-party agent or service provider for processing, JN Cayman remains committed to ensuring that such third-party agents or service providers process your personal information to the standard required to meet the requirements of the Data Protection Law as amended from time to time.

International Data Transfers

We may transfer data when we process an international transaction as part of our contract of service with you. If you send payment information or engage in a funds transfer, you allow the end destination bank to access your data.

These countries may not have similar data protection laws to those in the Cayman Islands. However, we will always protect your information on the basis that anyone to whom we pass the information protects it in the same way we would and in accordance with this privacy notice and applicable laws. International data transfers outside the Cayman Islands are protected by model contract clauses.

Personal Information that you submit on the websites or through our JN Cayman Live system is processed on our servers located in Jamaica and the United States of America. We also have a presence in the United Kingdom and Canada. Importantly, information sent from the client to the server is encrypted and our servers are securely protected.

Linked Websites

For your convenience, hyperlinks that link to other websites may be posted on JN Cayman’s website. We are not responsible for these sites, and this privacy notice does not apply to the privacy practices of any linked sites or of any companies that we do not own or control. Linked sites may collect information in addition to that which we collect on our website. We encourage you to seek out and read the privacy notice of each linked site that you visit to understand how the information that is collected about you is used and protected.

Business Transfers:

We may choose to buy or sell assets and may share or transfer customer information in connection with the evaluation of such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.

Jamaica National Group Companies:

We may also share your personal data with our parent company or another group company for the purposes consistent with this Privacy Notice. When we send your data to our group companies outside of the Cayman Islands, you are protected by model contract clauses.

Security

We use appropriate technical, organisational and administrative security measures to protect any information we hold in our records from loss, misuse, and unauthorised access, disclosure, alteration and destruction. We have written procedures and policies which are regularly audited, and the audits are reviewed at a senior level.

We use CCTV as a deterrent to protect our staff, customers, equipment and your personal data.

Exercising your Privacy Rights

What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to transact with us or to take advantage of some of our offers and discounts.

Cookies

We use cookies and other internet tracking software to collect data while you are using our websites or mobile apps. Cookies allow us to store information about the computer device you use to access our website so that you can conduct business with us easily. They allow us to recognise when you revisit our websites and to evaluate our websites’ advertising and promotional effectiveness. We use both our own (first party) and partner companies’ (third party) cookies to support this activity.

We do not use Cookies to:

  • track your Internet usage after leaving the website; or,
  • store personal information others may read and understand.

Processing of personal data associated with the use of these cookies occurs based on our legitimate Interests to administer the website.

 Our cookies are listed below.

Cookie NameDefault Expiration timeDescription
_ga2 yearsThis is a Google Analytics cookie used to distinguish users.
_ga2 yearsThis is a Google Analytics cookie used to distinguish users.
_gid24 hoursThis is a Google Analytics cookie used to distinguish users and its main purpose is for performance of the site.
_gat1 minuteThis is a Google Analytics cookie used to throttle the request rate limiting the collection of data on high traffic sites.
PHPSESSIDExpire when browser is closedIn-house cookie generated by applications based on the PHP language. This is a general-purpose identifier used to maintain user session variables. It is normally a random-generated number, how it is used can be specific to the site, but a good example is maintaining a logged-in status for a user between pages. This is technically required for the functioning of the website.

When you first visit the site, it gives you an opportunity to opt-in or opt-out of cookies.

You can deactivate the non-technical cookies by not consenting to non-essential cookies.

You may also set your browser’s setting to deactivate cookies. If you use that option, some functions of this website (e.g. login, memory of preferences etc.) may not be available. Detailed guidance on how to control cookies preferences for the most common browsers can be found at:

You also have the option to install the Google Analytics opt-out browser add-on and thereby deactivate the use of Google analytics cookies and the associated data processing. You can find the Opt-out browser add-on here:

https://tools.google.com/dlpage/gaoptout

You can find the Google privacy notice here:

Google Analytics privacy notice

Your rights under the Data Protection Law as amended from time to time include:

Your rightsMeaning
The right to be informedYou have the right to be informed about The identity of the organization processing your personal data, and The purposes for processing the personal data.  
The right to access your dataYou have a right to a copy of your personal data that we process.
The right to correct your dataYou have the right to correct data – and where it is wrong you have a right to have it corrected.
Rights regarding automated decision makingYou have the right to not be subject to an automated decision without human involvement where it significantly affects you. It also gives you the right to have the data controller reconsider the decision or take a new decision.  This right is subject to limitations.
The right to stop processingWhere the processing of your personal data is not necessary because of a contract with you or because the organization is legally obliged to process your personal data, you have the right to have the processing stopped.
The right to stop direct marketingYou have the right to stop direct marketing, whatever the medium.
The right to compensation for damageYou have a right to be compensated for any damage that occurred because of a breach of data protection.
The right to make a complaint to the Ombudsman  Rights are only as good as their enforcement – and where you feel that your rights are not being respected, you should submit a complaint to the Office of the Ombudsman.

(Source of information about your rights: Website of The Cayman Islands Ombudsman)

How May I Exercise My Data Subject Rights?

If you would like to access, review, update or rectify any any personal information we hold about you, or exercise any other data subject right available to you under the Data Protection Law as amended from time to time, you can obtain contact information from the “Contact Us” section of this privacy notice.  Our privacy team will examine your request and respond to you as quickly as possible.

Please note that we may use any aggregated and de-identified personal information that does not identify any individual. We may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Automated Decision Making

You may be subject to automated decision making in the following circumstances.

Pricing


We may decide what to charge for some products and services based on what we know. This will help us decide whether to offer you the product and what price to charge you.

Tailoring Products, Services, Offers and Marketing

We may place your personal data in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs and behaviours, and to make decisions based on what we learn. This helps us to design products, services and offers for different customer segments, and to manage our relationships with them. It also helps us tailor the information that individuals receive or see on ours and other websites and mobile apps, including social media.

Detecting Fraud


We use your personal information to help decide if your personal or business accounts are likely being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Additionally, we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the account or refuse access to it.

Opening Accounts or Establishing Customer Relationships

When you open an account with us, we check that the product or service is relevant to you, based on what we know. We also check that you or your business meets the conditions needed to open the account.

Loans and Mortgages and Credit provision

If you request or take a loan, mortgage or other form of credit we will use your personal information to assess the outcome of the decision to grant you a loan, mortgage or credit.

To help us make decisions on when to give you credit, we use a credit score to assess your application. To work out your credit score, we look at information you give us when you apply – information from credit reference agencies that will show us whether you’ve kept up to date with payments on any credit accounts (that could be any mortgages, loans, credit cards or overdrafts), or if you’ve had any court action such as judgments or bankruptcy; your history with us such as maximum level of borrowing; and affordability, by looking at your available net income and existing debts.

You have rights in relation to automated decision making, including the right to request a review if your application is refused.

Marketing

Unless you have told us that you do not want to receive direct marketing, we will send you relevant marketing information (including details of other products or services provided by us or other Group companies which we believe may be of interest to you), by mail, phone, email, text and other forms of electronic communication. If you change your mind about how you would like us to contact you, or you no longer wish to receive this information, you can have your information removed by clicking the unsubscribe link at the bottom of each email communication or by contacting us. For the contact information, please look at the “Contact Us” section of this notice.

We may still send you non-promotional communication such as administrative related emails concerning your account.

Contact Us

For any Data Protection enquiry, you may email us at ccrooks@jncayman.com.ky

Or Call us:

Cayman Islands           345.946.3030

You may write to us at:         P.O. Box 504, 29 Elgin Avenue, George Town, Grand Cayman, KY1-1106, Cayman Island

You may also contact our Data Protection Officer at;

JNGroupDPOOffice@JNGroup.com
L. Anthony Robinson

Data Protection Officer

JN Group

2-4 Half Way Tree Road,

Kingston 10,

Jamaica

For further information you may find us at www.jncayman.com.ky

You also have the right to make a complaint to the Information Commissioner appointed pursuant to the Freedom of Information Law as amended from time to time if you are unhappy about the way we have dealt with your privacy, or you may contact our Data Protection Officer.

The details are:

Information Commissioner’s Office

3rd Floor, Anderson Square

George Town, Grand Cayman

P.O. Box 1375, Grand Cayman KY11108

Cayman Islands

Tel:                  (345) 747-5402

Fax:                 (345) 949-2026

Email:              appeals@ico.gov.ky

Website:         www.INFOCOMM.ky


Changes to this privacy statement occur from time to time as the business develops and grows and adds more processing. You are encouraged to check back regularly to see any changes that may have occurred.

Information Pertaining to Children

For children under the age of 13, all data held for children is with the consent of their parents or guardians and is held for the purpose of administering an account. Our practice is to hold accounts jointly in the name of the child and the adult parent or guardian. Identification details are held for both the child and the parent or guardian.