Privacy Notice - JN Fund Managers

This privacy notice is to let you know how we manage your personal information at JN Fund Managers Limited. This includes information we collect when you establish and maintain a relationship with us. This notice also tells you about your privacy rights and how the law protects you.

OUR AGREEMENT WITH YOU
As a customer, you agree to us collecting, using and to appropriate disclosure of your personal information in accordance with our contract with you.

We may change our products and services at any time without notice, and consequently, our Privacy Notice may be updated at any time in the future. Continued use of our products and services implies ongoing consent.

WHO WE ARE
JN Fund Managers is a member company of The Jamaica National Group Limited (the parent company). Our Head Office is in Kingston, Jamaica and we take data protection and information security responsibilities very seriously. 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.

Your personal information will be processed by JN Fund Managers Limited and member companies of The Jamaica National Group. These companies are set up as separate legal entities which provide services, including insurance, banking, money remittance, information technology and fleet management.

Please read our Privacy Notice very carefully. In this Notice “we”, “us” and “our” means the JN Fund Managers, and “you” means the individual conducting business with us.

OUR PRIVACY PROMISE TO YOU

We will:

Secure and protect your personal information,
Not disclose your personal information outside the JN Group without your consent, and
Enable you to express your preferences so that you can manage how we use your personal information.

HOW WE PROTECT YOUR PERSONAL INFORMATION
In accordance with the law, our internal procedures for collecting, storing and securing your personal information are governed by controls which ensure the protection and security of your personal information. The law allows us to use personal information for lawful and legitimate purposes. These purposes include:

Fulfilment and performance of a contract to which you are a party;
When we have to comply with a legal obligation or duty;
When it is in our or another person’s legitimate interests to do so. A ‘Legitimate interest” includes when we have a business or commercial reason of our own to use your personal information. If we are going to rely on it as the reason for using your data, you will be told what it is. Even then, processing for that reason must not unfairly go against your privacy rights;
When you give us your consent to do so.

Some types of sensitive personal information are regarded by the law as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us so to do. If we do, it will only be when it is necessary:

for reasons of substantial public interest, or
to establish, exercise or defend legal claims.

TAKING CONTROL OF YOUR PERSONAL INFORMATION

Your Privacy Rights
JN Fund Managers respects your privacy and your rights. As the person who is the subject of your personal information, you have the right to ask us to:

request (1) a copy of the personal information we have collected about you and (2) how we process it,
correct that personal information if it is inaccurate,
stop using that personal information if we have done so unlawfully. This is known as the “right to object”;
restrict our use of your personal information if it is inaccurate, no longer relevant or it has been used unlawfully
remove or delete your personal information. This is known as the “right to erasure” or “right to be forgotten” and
Comply with the right of access provisions of the General Data Protection Regulation, as set out in article 15.

These rights may not be exercised by you if they adversely affect the privacy of others.

How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us by visiting any of our locations where you will be assisted to lodge a formal complaint.

JN Fund Managers Limited Locations

JN Financial Centre
2 Belmont Road
Kingston 5, Jamaica, WI

JN Financial Services – Catherine Hall
Lot 2-5 Megamart Complex
Montego Bay, St. James

Mandeville Plaza
Mandeville. Manchester

You can also use our online contact form on our website at info@jnfunds.com

How to withdraw your consent

If you no longer want us to hold or use your personal information, you can withdraw your consent at any time.
This will only affect the way we use information when our reason for doing so is that we have your consent. See the section, ‘Your Privacy Rights’, about more generally restricting use of your information.
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is incorrect. We will take reasonable steps to check and correct it.
If you want to request a correction you can visit any of our locations, or call us on: 876-929-7102

How We Use Your Personal Information
Below we outline the ways in which JN Fund Managers may use your personal information and the reasons for processing your information. We have also outlined our legitimate interests for collecting and processing your information.

What we collect your data for	How We Use your data that we collect	Other Reasons for collecting your data	Legitimate Interest for collecting your data
Establishing a relationship	To provide our Products and or Services	1. Fulfilling contracts 2. Our legitimate interests 3. Our legal duty 4. Marketing or analysis	1. Keeping our records up to date, working out which of our products and services may interest you and telling you about them 2. Seeking your consent when we need it to contact you 3. Defining types of customers for new products or services 4. Developing products and services, and what we charge for them 5. Seeking your consent when we need it to contact you 6. Being efficient about how we fulfil our legal and contractual duties
Maintaining a relationship	Update customer personal data
	Update contractual agreement terms and conditions.
	Offers related to our existing contract with you
Marketing and Product Development	To test new products.
	To manage how we work with other companies that provide services to us and our customers.
	To develop new ways to meet our customers’ needs.
	To communicate to you, information related to our products and services.
Transaction Processing/ Business Operations	To execute business in accordance with industry best practice.	1. Fulfilling contracts 2. Our legitimate interests 3. Our legal duty 4. Marketing or analysis	1. Being efficient about how we fulfil our legal and contractual duties 2. Complying with rules and guidance from regulators
	To deliver our products and services
	To facilitate and manage customer transactions.
	To manage fees, charges and interest due on customer accounts.
	To manage accounts receivables / payables.
	To manage and provide treasury and investment products and services.
Regulatory Requirements and Governance	To adhere to laws and regulations that apply to us.	1. Fulfilling contracts 2. Our legitimate interests 3. Our legal duty	1. To ensure adherence to internal controls and external regulatory requirements 2. Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect
	To detect, investigate, report, and seek to prevent financial crime.
	To manage risk for us and our customers.
	To respond to complaints and seek to resolve them
Legal	Customer Complaints		3. Manage and advise on customers legal queries or issues 4. Execute legal actions or query on behalf of client 5. Execute transfers on behalf of client (property, etc.) 6. Use any special categories of data as needed to establish, exercise or defend legal claims
	Transaction Processes
	Conveyancing
	Other Legal Proceedings

When and Where We Collect Your Personal Information
We collect your information in the following circumstances:

When you request information about our products and services;
When you apply for our products and services;
When you talk to us on the phone, including recorded calls and notes we make;
When you use our websites, web chats and mobile device apps;
In emails and letters;
In insurance claims or other documents;
In customer surveys;
If you take part in our competitions or promotions.

We may also collect data when you use our services. This covers two areas:

details about how and where you access our services and
account activity that is shown on your statement as follows: –

Payments and Transactions
This includes the amount, frequency, type, location, origin and recipients. If you borrow money, it also includes details of repayment and whether they are made on time and in full.

Profile and Usage of Information
This includes any security details you create and use to connect to our services. It also includes your settings and marketing choices. Additionally, we gather data from the devices you use (such as computers and mobile phones) to connect to our internet, mobile and telephone banking services. We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This information is statistical data about your browsing actions and patterns.

Usage of 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.

Who We Share Your Personal Information With
We may share your information, including how we manage your account(s) or visits to our website, with other companies within the JN Group and/or with relevant third parties, and as permitted by law, including, but not limited to the following:

People who provide a service to us or are acting as our agents, on the understanding that they will keep your information strictly confidential ad otherwise process it in accordance with data protection rules.
Anyone, to whom we transfer or may transfer all or any part of our business or assets, from whom we acquire any business or assets, or who acquires substantially all of the assets of JN Fund Managers.
Credit reference and fraud prevention agencies.

We may also provide information about you if we have a duty to do so in order to comply with any legal obligation, or in order to enforce or apply our terms of use or if the law allows us so to do.

If we disclose your information to a service provider (a person, office or organisation) located in this or another country, we will take reasonable steps necessary to ensure that they apply the same levels of protection as we are required to apply to your information, and to use your information only for the purpose of providing the service to us. By submitting your personal information, you agree to this transfer.

Sending Data Outside of the European Economic Area or Jamaica

We will only send your data outside of the European Economic Area (‘EEA’) or outside of Jamaica in the following circumstances:

to follow your instructions,
to comply with a legal duty or
to work with our service providers who help us to manage your accounts and to provide you with services. If we do transfer your personal information outside the EEA or Jamaica to our suppliers, we will make sure that it is protected to the same extent as in the EEA and Jamaica.

How We Use Personal Information for Automated Decisions

We sometimes use systems to make automated decisions about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct based on what we know. Automated decisions can affect the products, services or features we may offer you now or in the future. They are based on personal information that we have or that we are allowed to collect from others.

Here are the types of automated decision we make:

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 you 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 our own 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 may be 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
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.

Information We May Receive from Outside Organisations
We may receive your personal information from organisations outside of JN Fund Managers. These include but are not limited to:

insurers
companies that introduce you to us (such as a store or car dealership offering finance deals through us)
financial advisers
credit card providers such as Visa
credit reference agencies such as Credit Info and CRIF
comparison websites
social networks (for instance, when you click on one of our Facebook or Google ads)
fraud prevention agencies
other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
employers (for instance, to get a reference if you apply for a mortgage)
payroll service providers
land agents (such as firms who do property valuations for mortgages)
public information sources such as the Registrar of Companies
market researchers (who combine data from many sources to produce market trend reports and advice)
medical professionals and
Government and law enforcement agencies.

How long is Your Personal Information Kept?
We keep your information for at least seven years based on our local laws.

Contacting Us About Data Privacy
We are committed to the protection of your privacy rights and of your personal information. If you have any questions or require more details about how we use your personal information please see below:

Contact our JN Group Member Ombudsman at 876-936-0262
Write us at 2-4 Constant Spring Road, Kingston 10, Jamaica or The JN Financial Centre, 2 Belmont Road, Kingston 5, Jamaica
Contact our JN Group Call Centre at 876-926-134-9
Email us at helpdesk@jngroup.com or info@jnfunds.com