PRIVACY POLICY

Last revised April 2022

National Commercial Bank Jamaica Limited and its subsidiaries (“NCB”) are committed to ensuring and protecting the privacy and confidentiality of its clients' personal information. NCB has therefore adopted this policy to comply with its obligations under current data protection and privacy legislation. This policy briefly describes how we collect, hold, use and whenever necessary, disclose your personal information. It also summarizes your right to have access to update the information as necessary. If you have any questions about our privacy policy or your personal information, please contact NCB Customer Care Centre at 888-622-3477 or e-mail your privacy concerns to ncbinfo@jncb.com.



Use of the Internet

Privacy issues, including security and confidentiality of personal information disclosed on or through this web site or any other electronic channels maintained by NCB, are viewed very seriously by us. Policies governing the protection of privacy are strictly observed and enforced to ensure the highest standards of protection of privacy and personal information.

When you access our services through any of our electronic channels including our website and our Mobile App, and move from page to page, read pages, download content onto your electronic device from these channels, or, in the case of our Mobile App, download the App to your device, the following information may be recorded:


– The address you are connecting from
– Which pages are visited
– What content is downloaded
– The address of the web sites that you visited immediately before coming to our web site.
– The amount of time you spend logged in to the particular electronic channel
– Details of the types and number of transactions completed

NCB uses this information to find out how many people use our electronic channels and which aspects of our channels are used most frequently.

NCB may use this information to determine what type of information is most useful in order to, improve its electronic channels, address your specific needs, provide you with a better customer experience, for marketing purposes and for general operation of our business. The information may also be used to provide records of communication between NCB and you, and to comply with any legal and/or regulatory requirements.

Client Record and Personal Information

In the course of our business relationship with you, the personal information collected about you is held in a "client record." This information likely includes, at a minimum, your name, address and telephone number(s), birth date, account holdings and if applicable, the name address of your spouse or beneficiary. Depending on the type of service you request, additional personal information may be held in your client record. This information was provided to NCB by you at the time the account was opened or as the information became necessary throughout the service process.

Collecting, Holding, Using and Disclosing Personal Information

NCB may collect, hold and use the personal information in your client record as well as collect personal information from and disclose personal information to the third parties identified below, for the following purposes:
– IIdentifying you and ensuring the accuracy of information contained in your client record;
– Establishing and administering your account, determining, maintaining, recording and storing account holdings and transaction information in your client record;
– executing transactions with or through NCB including transferring funds by electronic or other means;
– providing you with investment account statements, tax receipts, financial statements for your investments, proxy mailings, transaction confirmations and other information that you may request to service your account;
– complying with a request for such disclosure by another bank, financial institution, credit agency, or credit bureau;
– facilitating an investigation of or prosecution for fraud, money laundering or offences associated with terrorism or terrorist financing in accordance with law;
– protecting its own business interests including collecting a debt owed to NCB or allowing the performance of a transaction;
– disclosing to and among the offices, affiliates and subsidiaries of NCB to process your transactions or provide you with other services which may be of interest to you;
– meeting legal and regulatory requirements;
– verifying information previously given by you with any other organization when necessary;
– advising you of other NCB products, services or initiatives that may be of interest to you; and for any other purpose you and NCB may agree upon from time to time.

Sharing With Companies That Work With Us

In order to conduct our business, execute your transactions and to offer products or services that may be of interest to you, we may share some or all of the information we collect, as described above, with the following third parties (including our affiliates):
– Companies that perform services for us or on our behalf, such as vendors we hire to provide support for one or more of our products and services; and
– Companies that perform marketing services on our behalf or other financial institutions with which we have joint marketing agreements, such as credit card issuers.

The contractual arrangements between us and these third parties require them to keep the information we provide them confidential and to use the information only for the purposes authorized by us.

Consent

Your knowledge and consent to NCB's collection, use and disclosure of your personal information is important. We rely on your actions as indications of your consent to our existing and future personal information practices:
– Your voluntary provision of personal information in person to NCB or through any of our electronic channels;
– Your express consent or acknowledgement contained within a written, verbal or electronic application process;
– Your consent solicited by NCB (or our agent) for a specified purpose;
– Your receipt of this Privacy Policy, until you notify NCB of a withdrawal of your consent; or
– Your consent given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.

Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent at any time. If you wish to withdraw consent or discuss the implications of such withdrawal, please contact us through one of the means described in the preface. In some circumstances, legal requirements may prevent you from withholding consent. Your decision to withhold consent may also limit the products and services that NCB is able to provide to you.

Location of Your Client Record

Your client record, whether electronic or paper, is kept at the offices of NCB. Paper records forming part of your client record may also be kept in offsite storage. Your client record may be transferred to other locations for disaster recovery purposes which may be overseas.

Right to Access and Correct Your Personal Information

Except in limited circumstances described in the applicable legislation, you are entitled to access, through a written request, the personal information contained in your client record. You may verify this personal information and request that any inaccurate information be corrected. For information on this process, please contact our Customer Care Centre at 888-NCB-FIRST (888-622-3477).

Limits on How Long personal information is kept

NCB will only retain your personal information as long as it is necessary, including updating the product or service or as required by law. When we destroy the information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.

Safeguards for your personal information

NCB maintains appropriate technical and organization safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. If you believe that our Privacy Policy does not adequately address your privacy concerns, you may contact our Customer Care Centre at 888-NCB-First (888-622-3477).