Privacy Statement for JN Money Services Ltd

    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 attend,

    and

    • if you use any of our products, services or applications (collectively the “services”) in any manner.

    JN Money Services Limited, (“JN Money”) takes its data protection and information security responsibilities very seriously. JN Money is a subsidiary of the JN Financial Group, which is in turn a subsidiary of The Jamaica National Group Limited (the ultimate parent company).

    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 firm with a global presence, we are subject to the varying requirements of data protection legislation in the jurisdictions where we operate. Our aim is to be as consistent as possible and obey all applicable laws and apply the highest standard of privacy laws to our approach.

    What information do we collect?

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

    From Websites or Events: We may collect any personal information that you choose to send to us or provide to us. For example, our online forms for our eMoney system collect personal information or if you register for a JN Money event, we may also collect personal information from you. If you contact us through the website, we will keep a record of correspondence.

    From the Services we provide: We receive and store information you provide directly to us. For example, when transacting through our locations, such as name and e-mail address, to provide you with services. The types of information we may collect directly from our customers and their users include: names, usernames, email addresses, postal addresses, phone numbers, job titles, proof of identification, transactional information (including services purchased), beneficiary information, proof of funds, as well as any other contact or information the customer chooses to provide us. If information is uploaded to our systems in connection with the services, we retain this information in line with our retention policy.

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

    • Provide, operate and maintain the services;
    • Process and complete transactions, and send related information, including transaction confirmations and invoices;
    • 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;
    • Investigate and prevent fraudulent activities, unauthorised 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 the Websites, we may collect certain information related to your device, such as your device’s IP address, what pages your device visited, and the time that your device visited our Website. These include:

    • Usage information– we keep track of user activity in relation to the types of services our customers and their users use, and the performance metrics related to their use of the Services.
    • Log information– we log information about our customers and their users when you use one of the Services including Internet Protocol (“IP”) address.
    • 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.

    How do we use the information?

    We will use the information we collect via our websites:

    • To administer our website, our events and 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;
    • For purposes made clear to you at the time you submit your information – for example, to fulfil your request for an information note requested about our services;
    • As part of our efforts to keep our website secure.

    Lawful basis

    Our lawful basis for processing is the Performance of a Contract for money transfers, foreign exchange transactions, parcel delivery and the procurement of airline tickets.

    Our use of your personal information may also be based on our legitimate interest to ensure network and information security, and for our direct marketing purposes.

    If you apply to become a JN Money agent to transact on our behalf, our application process will check your background, and your staff for compliance reasons, to investigate if you are a “fit and proper” person as described by Her Majesty’s Excise and Customs (HMRC) rules. To perform this task, we will share your details with Equifax and Lexus Nexis. They will check compliance watch lists to see if you are a fit and proper individual to perform the agency duties. This will include Credit checks, Caution list checks, Financial checks and Anti-Money Laundering and Criminal activity check. We will also check your criminal history via the UK governments DBS service. Our lawful basis for this processing is Legal Obligation. We may also share your information with law enforcement agencies if requested to do so.

    If you use our money transfer services, a compliance check is also performed at the transaction level as we are obligated by law to perform due diligence on the customer and the beneficiary. We may ask for proof of funds and purpose of funds information. We may also co-ordinate with our compliance team in Jamaica for this activity and law enforcement agencies in the UK and abroad for the purpose. Our Lawful basis for this processing is Legal Obligation.

    Retention policy

    Our retention policy for JN Money Services personal data is six years, then the information is securely destroyed.

    We have CCTV in various location 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 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 then it is destroyed if the applicant is unsuccessful.

    Agents of JN Money data is kept for six years after the termination of the agreement.

    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 may share your information in the United Kingdom with the Police National Crime Agency or HMRC if requested to do so;
    • We may share your information for compliance purposes to 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 who we employ to perform tasks on our behalf;
    • If you contract with us to perform a foreign exchange transaction, we share your information with FEXCO for the purpose of completing the transaction. JN Money services uses FEXCO Ltd for foreign exchange processing and is an agent of FEXCO Ltd. JN Money Services is the data processor and FEXCO is the data controller.
    • If you contract with us to perform a foreign exchange transaction, we share your information with alternative supplier, Moneygram International Ltd, for money transfer transactions. JN Money services uses Moneygram International Ltd for money-transfer processing and is an agent of Moneygram International Ltd. JN Money Services is the data processor and Moneygram is the data controller.
    • If you contract with us to deliver a parcel, we may share your information with DHL for parcel delivery. JN Money Services uses DHL for parcel delivery services. JN Money is the data processor and DHL is the data controller.
    • If you contract with us to procure an airline ticket, JN Money uses Diamond Travel Limited to procure the ticket. JN Money is an agent of Diamond Travel Ltd and we share personal information to complete the transaction. JN Money is the data processor and Diamond Travel ltd is the data controller.

    If JN Money Services receives your personal information and subsequently transfers that information to a third-party agent or service provider for processing, JN Money Services remains committed to ensuring that such third-party agent or service provider processes your personal information to the standard required to meet GDPR and other local privacy laws.

    International Data Transfers

    Personal Information you submit on the websites or through our services may be sent to the country of destination for the money transfer or parcel service which may be outside of the EU. We do this when you contract with us for the service.

    Information for this purpose is processed on our money transfer system where the servers are located in Jamaica and the United States and Canada.

    These countries may not have similar data protection laws to those in your country of residence. However, we will always protect your information in accordance with this Privacy Notice wherever it is processed.

    Linked Websites

    For your convenience, hyperlinks may be posted on the website that link to other websites. 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 this 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 group company for the purposes consistent with this Privacy Notice. When we send your data to our group companies outside of the EU, 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 senior level.

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

    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:

    1. track your Internet usage after leaving the website or
    2. store personal information others may read and understand.

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

    Our cookies are listed below.

    Cookie NameDefault Expiration timeDescription
    _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.

     

    You can deactivate the non-technical cookies by not consenting to cookies when your first visit the site. When you first visit the site, it give you an opportunity to opt-in or opt-out of 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.

    Marketing Communications

    You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the unsubscribe link in the email communications we send. You can also contact us from the details provided in the “Contact Us” section.

    We may still send you non-promotional communications, for instance, administration related emails.

    How Can I Exercise My Data Subject Rights?

    If you would like to access, review, update, rectify, and delete any personal information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR), you can email us at jnmtonline@jngroup.com. Our privacy team will examine your request and respond to you as quickly as possible.

    Please note that we may still 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.

    Your rights subject to the application of GDPR

    Your rightsMeaning
    The right to object to the processingYou have the right to object to the processing of your personal data in certain situations.
    The right to informationYou have the right to be informed whether and to what extent we process your data.
    The right of accessSubject to certain exceptions you have the right to obtain a confirmation as to whether or not we process your personal data, and if we do, request access to your data.
    The right to rectificationIf the personal data that we process is incomplete or incorrect, you have the right to request their completion or correction at any time.
    The right to deletion

     

    Subject to certain exceptions, if you consider that we should stop processing some or all of your personal data, you have the right to request its deletion. However, there may well be reasons why an immediate deletion may not be possible (for example where retention is required to meet legal or regulatory obligations).
    The right to restrict the processing

     

    You have the right to request that we restrict the processing of your personal data in certain situations:

    ·         If you contest the accuracy of your personal data, you may request that its processing is restricted while we verify its accuracy.

    ·         If the processing of your personal data is considered unlawful, but you do not require the deletion of your personal data.

    ·         If we no longer need the data for the purposes of its processing, but you need it for the establishment, exercise or defence of legal claims.

    ·         If you object to our processing of your data based on our legitimate interests

    The right to data portability

     

    Where the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that we provide your personal data to you in a machine-readable format.
    Rights in relation to automated decision making and profiling

     

    You have the right to object to decisions based exclusively on the automated processing of your personal data.
    The right to withdraw your consentIf your personal data is processed on basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
    ·         If you wish to exercise your rights, you can get in touch with us by contacting the Data Protection Officers or call or email us from the information on the “Contact Us” section.

     

    Automated decision making

    For compliance reasons, we monitor transactions and we follow our legal obligation set by HMRC rules. Automated decision making occurs stopping the money transfer transaction if it breaches guidelines set by HMRC. We liaise with our compliance colleagues in Jamaica for the same compliance purposes for the protection and detection of fraud and money laundering. Your rights to object to this processing are restricted as we follow a Legal Obligation set by HMRC.

    Contact Us

    For any GDPR enquiry, you can email us at  jnmtonline@jngroup.com.

    You can contact us

    By calling our customer service agents on the following numbers

    UK            0800-328-1622

    Jamaica     888-991-4065

    Or write to us at 17 Ruthven Rd, Kingston 10, Jamaica

    We also have additional contact points on our website, www.jnmoneyonline.com

    You can also contact our Data Protection Officers:

    Anthony Robinson

    AnthonyR@JNGroup.com

    JN Group

    2 – 4 Constant Spring Road, Kingston 10

    Barry McCormack

    DPO@jnmsuk.com

    JN Money Service (UK) Limited

    Unit 220 Elephant and Castle Shopping Centre

    Elephant & Castle

    London, SE16TE

    You also have the right to make a complaint to an EU regulator if you are resident in the EU. If you are unhappy at the way, we have dealt with your privacy, you can contact our Data Protection Officer or make a complaint to the Information Commissioners Office. The details are;

    Information Commissioner’s Office
    Wycliffe House
    Water Lane
    Wilmslow, Cheshire
    SK9 5AF

    Helpline number: 0044 (0)303 123 1113

    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

    We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for our services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Information, please contact us a soon as possible. You can find the information in the “Contact us” section of this privacy statement.