Privacy Notice

This Privacy Notice explains how Cornerstone Trust & Merchant Bank Limited (“CTMB”) may collect, retain, process, share and transfer your Personal Data when you use our mobile wallet Services (including mobile applications, touch technologies, interactive features and electronic services) and Prepaid Card (collectively the “Service”) or when you join CTMB’s Waiting List.

Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Notice.

By using the Service, you acknowledge that you have read the terms of this Privacy Notice. If you do not want your personal data processed as described in this Privacy Notice, please exit the application and cancel your interaction with the Service.

We have defined the key terms within this Privacy Notice below:

Definitions

• Account/Mobile Wallet Account means the electronic JMD account linked to your CTMB Mobile Wallet.
• Device Information means data that can be automatically collected from any device used to access Services Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity).
• Geolocation Information means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation
• CTMB means Cornerstone Trust & Merchant Bank Limited and affiliates In this Privacy Policy, CTMB is sometimes referred to as “we,” “us,” or “our,” depending on the context.
• Personal Data means personal information that can be associated with an identified or identifiable person . “Personal Data” can include name, address, telephone number, email address, prepaid card number, other financial account information, account number, date of birth, driver’s license, national ID, passport, and TRN. Personal Data does not include information that does not identify a specific User.
• Process means any method or way that we handle Personal Data , whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.
• Services means any products, services, content, features, technologies, or functions and all related applications and services offered to you by CTMB in relation to CTMB’s Mobile Wallet and Prepaid Card.
• Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Services. Technical Usage Data tells us how you use the Services, including your IP address, statistics regarding how pages are loaded or viewed and other usage and browsing information collected through Cookies.
• User means an individual who uses the Services and/or who are placed on the Waiting List.
• Waiting List by providing personal information through the waitlist registration process.

What Personal Data Do We Collect?

We may collect information about you when you use the Services and/or is placed on the Waiting List, including the following:

• Waiting List Registration - When you register to join the waitlist, we will collect Personal Data as required to determine your eligibility for subsequent registration to our services. We may require your full name, email address, telephone number, country of residence, and date of birth.
• Services Registration and use information - When you register to use the Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfill the Services you request. We may require you to provide us with your name, address, telephone number, email address, and identification information to establish an Account. We may require you to provide us with additional Personal Data.
• Transaction and experience information- When you use our Services, for example, to receive money, to process payments, or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information
• Participant information - When you use our Services, we collect Personal Data you provide us about the other participants associated with the transaction.
• Send or request money - When you send or request money through the Services, we collect Personal Data such as name, address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money.
• Add value to your accounts - If you use our Services to add value to your Account, or if you ask a User to add value to your Account, we may collect Personal Data from you about the other party, or from the other party about you to facilitate the request. For example, if you use our Services to reload a mobile phone, or to request value be added to your mobile account, we may collect Personal Data and other information including mobile account number from the other participant.
• Location information: such as information related to your city or parish. Our app collects location data to provide personalized and localized content experiences enhance by nearby places. We only collect your location data in the following situations:
• Foreground location access: When the app is open and actively being used, we collect your location data to share localized content on demand with various different Cards you have in your Wallet.
• Background location access: We also collect your location data when the app is not actively in use to provide location-based notifications from within the Cards you have in your Wallet.
• Why We Need Background Location Access: Mobile Wallet requires background location access to share relevant push notification in your area. It is essential to share critical Card information that is localized even when you’re not using the app.
• Behavior information: such as engagement and usage.
• Internet and network activity information: : such as information about your browsing behavior, search history, and interactions with websites and advertisements, including data from cookies, and web beacons.
• Inferences regarding preferences and other characteristics: : such as our assessment of the types of products or services you may have an interest in.
• Information about your public profile and your friends and contacts- – It may be easier for us to help you transact with your friends and contacts if you choose to connect your contact list information with your Account or if your Account profile is publicly available. If you establish an account connection between your device or a social media platform and your Account, we will use your contact list information (such as name, address, email address) to improve your experience when you use the Services. When your Account profile is public, other users can find your profile to send you money by searching for you by name, username, email, or mobile number on the Mobile Wallet Account and confirm it’s you by viewing your photo. You can make your Account profile private anytime in your Mobile Wallet Account settings.
• Information that you choose to provide us to obtain additional Services or specific online Services – If you request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that information differs from the uses disclosed in this Privacy Policy
• Other information we collect related to your use of our Services- – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
• Non-Account holders

If you use our Services without creating or logging into an account, we will still collect your personal data, which may include your payment information, device information, and location. When you use our Services without creating or logging into an account, we will use this information to process transactions, prevent fraud and comply with the law. We may connect this information with your account, if you have one or if you create an account at a later date.

Why Do We Retain Personal Data?

We retain Personal Data to fulfill our legal or regulatory obligations and for our business purposes If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Notice

How Do We Process Personal Data?

We may process your information for the following reasons:

• To provide the Services, including to:
• initiate a payment, send or request money or add value to an account;
• authenticate your access to an Account;
• communicate with you about your Account, the Services, or CTMB; and
• keep your Account and financial information up to date
• To manage our business needs such as monitoring, analyzing, and improving the Services. For example, we analyze User behavior and perform research about the way you use our Services.
• To manage risk and protect the Services and you from fraud by verifying your identity. CTMB’s risk and fraud tools use Personal Data, Device Information, Technical Usage Data and Geolocation Information to help detect and prevent fraud and abuse of the Services.
• To market to you about CTMB products and Services. We may also Process your Personal Data to uniquely tailor the marketing content and certain Services to better match your interests.
• To provide you with location-specific options , functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the and Services and provide you with location-based Services, such as advertising, search results, and other personalized content.
• To comply with our obligations and to enforce the terms of our Services , including to comply with all applicable laws and regulations
• To respond to your requests, for example to contact you about a question you submitted to our customer service team.

Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Notice.

We may share your Personal Data or other information for the following reasons:

• With Cornerstone Affiliates : : We may share your Personal Data with affiliates of CTMB to, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of our products, Services, and communications.
• With other companies that provide services to us : We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and Services, or provide customer support.
• With other third parties as permitted or required by law We may share information about you with other parties as permitted or required by law, including:
• if we need to do so to comply with a law, legal process or regulations;
• law enforcement, regulators, government officials, or other third parties in relation to a subpoena, court order, or other legal process or requirement; when we need to do so to comply with such law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a user agreement;
• to protect our property, Services and legal rights;
• to help assess and manage risk and prevent fraud against us, our Users and fraud involving our our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants
• to banking partners as required by card association rules for inclusion on their list of terminated merchants;
• to credit reporting and collection agencies; and
• to support our audit, compliance, and corporate governance functions
• With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.

In addition, CTMB may provide aggregated statistical data to third parties, including its supervisory regulatory body (“the Bank of Jamaica”), other businesses and members of the public, about how, when, and why Users visit our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent

How Do We Use Cookies and Tracking Technologies?

When you use our Services, we and our vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety. Certain aspects and features of our Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Services may be limited or not possible

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

What Privacy Choices Are Available To You?

You have choices when it comes to the privacy practices and communications described in this Privacy Notice. Many of your choices may be explained at the time you sign up for or use a Service. You may be provided with instructions and prompts within the experiences as you navigate the Services.

• Choices Relating to the Personal Data We Collect
• Personal Data. You may decline to provide Personal Data when it is requested by CTMB, but certain Services or all of the Services may be unavailable to you
• Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that CTMB may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
• Choices Relating to Cookies

You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or Site.

You may have an option regarding the use of cookies and other tracking technologies when you use a Service. For example, you may be asked if you want the Service to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them

• Choices Relating to Your Registration and Account Information

If you have an Account, you generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. You may also contact us if you do not have an Account or if you have questions about your Account information or other Personal Data

• Choices Relating to Communication

Notices, Alerts and Updates from us:

• Marketing: We may send you marketing content about our Services, products, products we jointly offer with financial institutions, as well as the products and services of CTMB’s affiliates through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications by following the instructions in the communications you receive. If you have an Account with us, you may also adjust your communication preferences in your Account settings. For messages sent via push notifications, you may manage your preferences in your device.
• Informational and Other: We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.

How we may use your information?

We may use information collected as described in this Privacy Notice to:

• Operate, maintain, and improve the Service and other programs, features, and functionality related to the Service;
• Provide you with interest-based advertisements, push notifications, communications, and offers for products and services from us and our business partners, including based on your precise geolocation;
• Perform analytics and conduct customer research
• Communicate and provide additional information that may be of interest to you about our Mobile Wallet Cards and our business partners, sometimes by combining your information with information we obtain from other sources;
• Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requesting information from you;
• Administer rewards, surveys, contests, or other promotional activities or events sponsored by our business partners
• Verify your requests made pursuant to this Privacy Notice
• Enhance other information we have about you to help us better understand you and determine your interests;

We also may use information collected as described in this Privacy Notice with your consent or as otherwise required or permitted by law.

What are your Rights?

Subject to limitations set out in the Data Protection Act, you have certain rights in relation to your personal data. You have the right to request access to your data and rectification. Please contact us if you want to exercise these rights.

• You may have the right to review automated decision making. You may also revoke consent
• You have the right to revoke your consent, however, this may affect our ability to provide the Service to you
• You have the right to know and request personal information that we have collected about
• Right to know and request personal information collected
• Right to know the categories of third parties with whom we may share your Personal Data
• You have the right to update your personal information

If you want to exercise any of your rights, contact us. If you wish to complete a request for access to all personal data CTMB holds about you, remember that you may be required to prove your identity.

If you have an Account with us, you will generally be able to review and edit Personal Data in the Account by accessing the account and updating the information directly.

You can also contact us if you do not have an Account or if you have questions about Account information or other Personal Data.

How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

Can Children Use Our Services?

The Services are not directed to persons under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Services. If we obtain actual knowledge that we have collected Personal Data from a person under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

What Else Should You Know?

Changes to This Privacy Policy

We may revise this Privacy Notice from time to time to reflect changes to our business, the Services, or applicable laws. The revised Privacy Notice will be effective as of the published effective date. If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Notice Update” page of our website. We also may notify Users of the change using email or other means. .

Transfers of Your Personal Data to Other Countries

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and Process your Personal Data in the United States of America and elsewhere in the world. We will protect your information as described in this Privacy Notice if your Personal Data is transferred to other countries. By using our Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Services are appropriate or available in any particular jurisdiction.

Contact Us

You may contact us if you have general questions about our Privacy Notice and practices or questions about your Account information or Personal Data. To contact us about your mobile wallet account and prepaid cards please email us at support@bricapp.zendesk.com