Log Data – This data may be processed for the purposes of operating our website, providing our services,  ensuring the security of our website and services, maintaining back-ups of our databases and  communicating with you. 

Cookies – We may also use cookies and URL information to gather information regarding the date and time  of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces  of information that a website sends to your computer’s hard drive while you are viewing a web site. Upon  your initial visit to the website, you will have the option of accepting or refusing cookies and you will  be able to choose the type of cookie you accept or reject. You may also configure your browser to  ensure no cookies are stored on your hard drive.

We may use both session Cookies (which expire once you close your web browser) and persistent Cookies  (which stay on your computer until you delete them) to provide you with a more personal and interactive  experience on our Site. Persistent Cookies can be removed by following Internet browser help file  directions. Cookies may enable automatic logins when you visit in the future and may enable content  customization. 

4. Legal Basis for Collecting Personal Data: 

o Contractual Obligation – We may process your Personal Data in contemplation of  entering into a contract with you or to fulfill our existing contractual obligations to you.  o Legal Obligation- There may be instances when we will have to process your Personal  Data in order to comply with the law. This may 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  also legally obliged to assess affordability and suitability of credit for loan and other credit  applications and throughout the duration of the relationship.  

o Legitimate Interest – We process your Personal Data in order to efficiently provide and  market our services to you. However, we will not process your personal data where doing  so poses a risk to your rights and freedoms and vital interests. 

o User Consent – We will always obtain your clear, informed and freely given consent before  processing your Personal Data, except in circumstances where it is not possible to obtain  your consent, but your Personal Data still needs to be processed (for example due to legal  obligations we may have or to protect your vital interests, the public interest or to aid in  the administration of justice). You may withdraw your consent at any time by the same  method it was provided to us or by contacting our Data Protection Officer identified below. 

5. How We Use Your Personal Data 

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

• provide our products and services; 
• process and complete transactions, and send related information, including transaction  confirmations and records; 
• manage our members’ use of the services, respond to enquiries and comments and provide customer  service and support; 
• send alerts, updates, security notifications, and administrative communications; ● verify your identity, creditworthiness and the accuracy of the information provided; ● ensure compliance with laws and regulations, for example filing reports relating to FATCA and  the Common Reporting Standard; 
• trace debtors and recover debts; 
• investigate and prevent fraud and money laundering activities, unauthorized access to our services,  and other illegal activities; and 
• to record CCTV footage to ensure the safety and security of our employees, customers and any  other person visiting the Company’s premises. 

6. Third Parties and Transfers 

We may disclose your Personal Data to third parties to whom you expressly ask us to send your Personal  Data or to third parties for whom you consent to us sending your personal information. Third parties include  our partners, affiliates, service providers and professional advisors. Personal Data may also be shared with  regulators in order to demonstrate compliance with legal obligations. Personal Data will only be shared  with third parties to provide our services to you and/or to comply with legal obligations. These third parties  do not retain, share, use or process personal data beyond the defined purpose of providing our services to  you. 

7. How We Protect Your Personal Data 

Trelawny Co-Operative Credit Union is committed to protecting the security of your Personal Data. We  (and our third-party service providers) use a variety of industry-standard security technologies and 

procedures, as well as organizational measures to help protect your Personal Data from unauthorized access,  use, or disclosure, such as:  

o We use vulnerability scanning and/or scanning to PCI standards. 

o We use regular Malware Scanning. 

o Your Personal Data is contained behind secured networks and is only accessible by a limited  number of persons who have special access rights to such systems and are required to keep the  information confidential. In addition, all sensitive information you supply is encrypted via Secure  Socket Layer (SSL) technology. 

o We implement a variety of security measures when a user enters, submits, or accesses their  information to maintain the safety of your personal information. 

o All transactions are processed through a gateway provider and are not stored or processed on our  servers. 

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, while Trelawny Co-Operative Credit Union Ltd. makes reasonable efforts to protect your  Personal Data, we cannot guarantee its absolute security. 

8. Your Rights 

Under Jamaica’s Data Protection Act data subject enjoy the following rights: 

• Right to access your personal data – You are entitled to make a written request to us to be  informed whether your Personal Data is being processed by us. You are also entitled to request a  copy of your data. You may also request that your Personal Data be transferred to a third party; 
• Right to be informed about automated decision making – You may request in writing that  decisions regarding your Personal Data that have been made solely on the basis of automated  processing be reconsidered with human involvement; 
• Right to prevent processing in certain circumstances – You are entitled to make a written  request to us to cease or not to begin processing your Personal Data in a specific manner or for a  specific purpose; and 
• Right to request rectification of inaccuracies – You may request that inaccuracies in your  Personal Data be rectified. “Rectification” means amend, block, erase or destroy, as may be 

required to correct the inaccuracy. You may request that your personal data be erased on the  expiration of any applicable retention period. 

9. Retention Policy 

We only retain your Personal Data for as long as it is needed to provide our services to you. We also retain  Personal Data in line with legal requirements which may stipulate retention periods for different categories  of Personal Data. We typically therefore retain members’ Personal Data for a minimum of seven years  following the date of transaction or termination of customer relationship. 

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

10. Notifiable Data Breaches 

We take data breaches very seriously. We will endeavour to meet the 72-hour deadline as imposed by the  JDPA to report any data breach to the Information Commissioner. Further, where there is likely to be a high  risk to your rights, we will endeavour to contact you without undue delay.  

Our report will inform you of: 

• the nature of the security breach; 
• the measures taken or proposed to be taken to mitigate or address the possible adverse effects of  the breach; and 
• the name, address and other relevant contact information of our Data Protection Officer or other  designated representative. 

We will review every incident and/or breach and take action to prevent future incidents or breaches. 

11. Children’s Privacy 

Our services are not offered to persons under the age of 18 without parental or guardian consent. Any  information that is in breach of this provision will be deleted. 

If you become aware that a child has provided us with information, please contact our Data Protection Officer.  

12. Changes to This Privacy Policy

Trelawny Co-Operative Credit Union Limited 

Data privacy and protection is an ongoing responsibility and so this Privacy Notice is subject to occasional  revision to ensure that it remains in line with the ever-evolving regulatory and security landscape. Trelawny  Co-Operative Credit Union therefore reserves the right, at its sole discretion, to modify or replace any  part of this Privacy Notice. It is your responsibility to check this Privacy Notice periodically for changes.  The last date of modification will be noted at the bottom. Continued use of our Site or Services indicates  your acknowledgement that it is your responsibility to review this Privacy Notice periodically and become  aware of any modifications. Changes to this notice are effective once they have been uploaded to our  website. 

13. Contact Information 

Trelawny Co-Operative Credit Union Ltd welcomes your comments or questions regarding this  Privacy Notice. If you have any question or comment regarding this Privacy Notice or you would like to  make a complaint, please submit a written request to our Data Protection Officer as follows:  

In person – at any TCCU branch, addressed to the Data Protection Officer 

Mail: Trelawny Co-Operative Credit Union Ltd, Water Square, Falmouth, Trelawny and addressed to the  Data Protection Officer 

Email: dpo@jtccu.com.