1. INTRODUCTION
Protecting the privacy of personal data is of paramount importance to Eppley Limited, its subsidiaries and affiliated companies (“Eppley”, “we”, “us”, “our”). We respect the privacy rights of our customers, team members, contractors and other third-parties (“you”, “your”) and use appropriate safeguards to keep your data confidential and secure.This Privacy Notice sets out personal data that we collect and process about you. For the purposes of this Privacy Notice, “personal data” means any data relating to an identified or identifiable individual, in accordance with the Jamaican Data Protection Act, 2020.

2.WHAT PERSONAL DATA DO WE PROCESS?
We collect, process and use your personal data depending on how you interact with us and our services, including:

• When you request data about our services;
• When you apply for our services;
• When you enter into an employment or service relationship with us;
• When you correspond with us via telephone, mail, electronic mail, in office or via any other means;
• When you submit documents to us;
• When you view or use our website.

The personal data we collect may include your name, email address, residential or business address, telephone number, nationality, date of birth, government issued identification (including relevant government and/or tax identification number), credit information, banking information and other information required to fulfil your requests/ queries or to meet our regulatory obligations. We may also obtain your personal data through automated technologies or interactions or from third-parties or publicly available sources.
It is important that the personal data we hold about you is accurate and current. It is your duty to inform us of any changes in your personal data during the period of your relationship with us.

3. HOW DO WE PROCESS YOUR PERSONAL DATA?
We may process your personal data for a range of purposes, including to:

• carry out your instructions;
• provide, operate, maintain and otherwise deliver our services to you;
• communicate with you, including to provide customer service and support;
• process and complete transactions and send related payment information (including transaction confirmations and invoices);
• verify your identity, to comply with our Know-Your-Customer processes;
• prevent or detect crime including fraud and financial crime, for example money laundering and terrorist financing;
• correspond with our professional advisors, consultants and financial institutions including attorneys-at-law, surveyors/ valuers, banks and third-party intermediaries;
• fulfil requests for reports, including requests of auditors;
• maintain and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
• improve our services, including through analysing how you use them;
• provide you with other services which may be of interest to you;
• manage risk, ensure security and business continuity and protect our business interests;
• fulfil contractual, regulatory and legal obligations.

4. LEGAL BASIS FOR COLLECTING PERSONAL DATA
We will process your personal data if we are of the view that we have a legal basis upon which to do so. We will normally collect personal data in circumstances such as where we need it to enter into or perform a contract with you, where we have your freely given consent to do so, where the processing is necessary to fulfil legal/regulatory obligations or where the processing is in our legitimate interests.

5. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain your personal data for as long as reasonably necessary to fulfil the purpose(s) for which we collect the personal data, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. When we dispose of your personal data, we will use appropriate safeguards to prevent unauthorized parties from gaining access to your personal data during the disposal process.

6. DATA SHARING/TRANSFER
We take care to allow access to personal data to those team members who require such access to perform their tasks and duties, and third-parties who we believe have a legitimate purpose for accessing it and who have notified us that they have appropriate security measures in place to protect your personal data. In the process of doing business with us, your personal data may be shared with:

• persons with whom we have been asked to share your personal data, by either you or a third-party who contractually provides instructions or confirms that they are authorised to operate accounts on your behalf;
• our agents and third-party service providers who provide services relevant to your business;
• our affiliates, to process your transactions or provide you with other services which may be of interest to you;
• correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties;
• financial institutions, lenders, and holders of security over any property you charge to us, tax authorities, trade associations, credit reference agencies, payment service providers and debt recovery agents;
• companies in connection with any assignment, sale or transfer of our portfolio;
• law enforcement, government, courts, dispute resolution bodies, our regulators, auditors and any party appointed or asked for by our regulators to carry out investigations or audits of our activities;
• financial crime prevention agencies.

We may need to transfer personal data to countries outside of Jamaica in order to conduct business on your behalf. When we send personal data to a different country, we seek to ensure adequate safeguards for the transfer of data in accordance with applicable law.

7. YOUR RIGHTS
You have a number of rights in relation to the personal data that we process about you. These rights include the right to access, restrict processing in certain circumstances, rectification of inaccuracies, and rights in relation to automated decision making.
Any questions or requests can be sent to our Data Protection Officer at the e-mail address: questions@eppleylimited.com.

8. LINKS TO OTHER SITES
This website may contain links to other sites that are not operated by us. If you click on a third-party link, you may be directed to a third-party’s site that collects cookies.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

9. UPDATES
This Privacy Notice may be updated from time to time. Updates are effective once posted on our website. We encourage you to check this Privacy Notice periodically to be aware of the most recent version.