This Privacy Policy (“Policy”) briefly describes how Adlinc Business Services Limited, its directors, respective officers, employees, shareholders, affiliates, associated entities, agents and partners (collectively referred to herein as “Adlinc”, “us”, “we” or “our”) collect, use, store, disclose, retain, dispose and destroy your Personal Data (as defined below). It also summarizes the rights which you may have in relation to the Personal Data which is collected, used, stored, transferred and/or processed by Adlinc.
By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Adlinc collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to Adlinc’s authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
1. DEFINITIONS
- ‘Personal Data’ means any information (however stored) relating to a living individual or an individual who has been deceased for less than thirty (30) years who can be identified-
- from the information alone; or
- from the information and other information in the possession of, or likely to come into the possession of Adlinc.
2. COLLECTION OF PERSONAL DATA
2.1 Generally, we collect Personal Data in the following ways:
- when you submit any form, including but not limited to application forms or other forms relating to any of our products or services;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
- when you interact with our staff, including business relationship managers, example via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
- when you use some of our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;
- when you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
- when you are contacted by, and respond to, our marketing representatives, agents and other service providers;
- when we seek information about you and receive your Personal Data from third parties in connection with your relationship with us, for example, from referrers, credit agencies, public entities or the relevant authorities;
- when you submit your Personal Data to us for any other reason.
2.2 If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children or parents), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his/her Personal Data for the respective purposes.
2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested. You agree to inform Adlinc immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as Adlinc may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.
3. TYPES OF PERSONAL DATA WHICH MAY BE COLLECTED
3.1. Adlinc may collect the following types of Personal Data:
- Information which is needed for properly identifying you, which may include but is not limited to your name, D.O.B., postal address, home address, business address, telephone number, mobile number, facsimile number, email address, nationality, social security number and Taxpayer Registration Number.
- Other personal information, such as curriculum vitae, job title, source of income, tax information or employment details.
- Information on any assets whatsoever which you may hold or any investments you have made or are planning to make.
- Information on payment transactions and data which is necessary for us to make or process payments which may also include the implementation of fraud prevention measures, including credit / debit card numbers, security code numbers and other such relevant billing details.
- Any data or information which we are legally bound to collect to comply with Know Your Client (“KYC”) and anti-money laundering regulations as well as to comply with our client intake procedures.
- Information collected from publicly available resources or forums, including but not limited to information collected from databases we use to carry out compliance checks.
- Where necessary, we may collect information which may include sensitive information such as in relation to your health or criminal history. The processing of such data shall be based entirely on you providing your consent.
- Other information relevant to the provision of our services to you.
3.2 This is a non-exhaustive list which is reflective of the varied nature of the Personal Data processed by financial service providers.
4. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
4.1 Generally, Adlinc may collect, use and disclose your Personal Data for the following purposes:
- to provide our services and/or products as may be requested by you;
- verifying your identity and customer due diligence;
- managing the administrative and business operation of Adlinc and complying with internal policies, standards and procedures;
- to protect Adlinc’s own business interests including collecting outstanding balances owed to Adlinc or allowing the performance of a transaction;
- audit purposes;
- responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
- resolving complaints and handling requests and enquiries;
- processing payments, invoicing, or providing any ancillary services to you;
- for the purposes of compliance with our legal obligations such as record keeping obligations;
- for the purposes of preventing, detecting and investigating crime, including fraud, anti-money laundering or terrorist financing;
- requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
- to provide updates, reminders and requests in compliance with local laws;
- to protect the security of communication systems, websites and other systems, and to detect security threats, fraud or other criminal or malicious activities against our office or against you;
- for insurance purposes;
- upon receipt of instruction or request from you or any third-party authorized by you;
- for the purposes of communication with you through approved channels of communications and where necessary to keep you up to date on the latest developments, announcements, and other information;
- to comply with court orders or orders of other agencies with competent jurisdiction and to exercise and/or defend our legal rights;
- to comply with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to Adlinc or that it is expected to comply;
- to assist in law enforcement and investigations by relevant authorities;
- archival management; and/or
- any other purpose related and/or ancillary to any of the above or any other purpose for which your Personal Data is required by our office.
These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).
4.2 In addition, Adlinc collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
- If you are a prospective customer:
- evaluating your eligibility to conduct business with us and providing recommendations to you as to the type of products and services suited to your needs;
- assessing and processing any applications or requests made by you for products and services offered by Adlinc; and/or
- any other purpose relating to any of the above.
5. DISCLOSURE OF PERSONAL DATA
5.1 Adlinc will take reasonable steps to protect your Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable) to the following entities or parties whether they are located overseas or in Jamaica:
- an affiliate or associated entity of Adlinc on a confidential basis, who may only use your Personal Data for the purposes listed above and who will be bound by law or contract to protect your Personal Data and only use your Personal Data in accordance with our instructions;
- government agencies, as required by law, for the purposes of fraud and crime prevention purposes, including financial institutions and regulatory bodies;
- third- parties to whom we may assign or novate any of the rights or obligations of Adlinc;
- courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
- agents, contractors, vendors, installers, or third-party service providers who provide administrative or operational services to Adlinc, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to Adlinc;
- agents, contractors, vendors or other third-party service providers in connection with marketing, products and services offered by Adlinc;
- our professional advisers such as our auditors and attorneys;
- relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over Adlinc or over any transaction entered into by you;
- any liquidator, receiver, administrator, judicial manager, trustees-in-bankruptcy, custodian or other similar official who has been so appointed, pursuant to bankruptcy, winding-up or insolvency proceedings instituted in Jamaica or elsewhere, in respect of you or your assets;
- any person to whom Adlinc is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to Adlinc, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which Adlinc are expected to comply, or any disclosure pursuant to any contractual or other commitment of Adlinc with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside Jamaica and may be existing currently and in the future; and/or
- any other party to whom you authorize us to disclose your Personal Data to.
5.2 Please note this list is non-exhaustive and there may be other examples where we need to share
your Personal Data with other parties in order to provide our services and/or products as effectively as we can.
6. CONSENT
6.1 Your knowledge and consent to Adlinc’s collection, use and disclosure of your Personal Data is important. We rely on the following actions as indications of your consent to our existing and future personal data practices:
- Your voluntary provision of Personal Data in person to Adlinc 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 Adlinc (or our agent) for a specified purpose;
- Your receipt of this Policy, until you notify Adlinc 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.
6.2 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 the means as described below. In some circumstances, legal requirements may prevent you from withholding consent. Your decision to withhold consent may also limit the products and services that Adlinc is able to provide to you.
7. COOKIES
Adlinc utilizes cookies and similar technologies (“Cookies”) on this website to collect and store certain information. This section details the types of Cookies we use and how you can manage your Cookie preferences.
What are Cookies?
Cookies are small data files transferred to your electronic device (computer, phone, tablet) upon visiting a website. They enable the website to recall your actions and preferences (e.g., login credentials, language selection) over time, eliminating the need for repeated input during subsequent visits or page navigation.
Types of Cookies We Use:
We utilize various Cookies for specific purposes:
Essential Cookies: These Cookies are strictly necessary for website functionality. They allow you to navigate and utilize the website’s features.
Performance Cookies: These Cookies collect data regarding your website usage, such as visited pages and time spent on each. This information is used to enhance website functionality and user experience.
Functionality Cookies: These Cookies enable the website to remember your choices (e.g., language preference) and deliver a more personalized experience.
Targeting or Advertising Cookies: These Cookies may be used to deliver advertisements more relevant to your interests.
Your Cookie Preferences
You have control over the Cookies placed on your device. Most web browsers offer settings to manage Cookies. You may choose to:
Accept All Cookies: This is the default setting for many browsers.
Block All Cookies: This may restrict your ability to use certain website features.
Manage Cookies on a Per-Site Basis: This allows you to determine which websites can place Cookies on your device.
Please note that if you reject cookies, you will not be able to use some or all of Adlinc’s Site. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use the Adlinc Site.
8. SECURITY
8.1 Adlinc maintains appropriate technical and organizational safeguards to protect your Personal Data against loss, theft, unauthorized access, disclosure, copying, use or modification. Your Personal Data is kept in the electronic systems of our office, in back storage systems and on paper files.
8.2 All of our partners, employees, consultants, agents, independent contractors and data processors (i.e. those who process your Personal Data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of your Personal Data, are obliged to respect the confidentiality of such Personal Data.
8.3 We, however, do not warrant or make any representations that your Personal Data may not be accessed, used, disclosed, altered, or destroyed by breach of such safeguards. We will immediately notify you in the event that your Personal Data has been affected by a security breach and will maintain an incident response policy that includes notifications consistent with applicable law.
APPROACH TO DATA SECURITY
Adlinc’s security program is aligned with applicable industry regulatory requirements, including but not limited to Jamaica DPA, GDPR, HIPAA, ISO, and PCI. The program encompasses information security and cyber operations capabilities that protect Adlinc and our clients. It is continuously reviewed and strengthened as necessary to ensure responsiveness to and protection against emerging threats. Adlinc maintains a highly qualified workforce and utilizes external experts to support the program. We administer internal education, training, and communication programs to ensure ongoing awareness and vigilance. We maintain and communicate formal documented policies and standards. We monitor and assess the overall operating effectiveness of our program through risk assessments that include identification and remediation of vulnerabilities and threats. We maintain and test our cyber incident response plan, and undertake various independent reviews in conjunction with PCI DSS, external audits, internal audits, and client assurance efforts. Various additional operational protections, controls, and processes exist, including but not limited to malware protection, intrusion prevention, and detection protocols, user access reviews, maintenance of network and application firewalls, vulnerability scanning, data encryption, penetration testing, and patching.
9. PERSONAL DATA WE RECEIVE FROM YOU ABOUT THIRD-PARTIES
9.1 Adlinc requires that where you wish to disclose the Personal Data of third-parties, you must first ensure that:
9.1.1 you are entitled to divulge the Personal Data to us and have obtained their consent to such disclosure; and
9.1.2 there are no agreements in place which would prohibit us from disclosing the Personal Data in a manner as contemplated by this Policy and that no further steps are required by our office to disclose the Personal Data.
9.2 More specifically, it is a requirement that when you disclose any Personal Data of third-parties to us, such third-parties should be made aware as to who we are, how their Personal Data will be used, what disclosure practices we have in place and the rights of any such third-party to contact our office and to inquire about the purposes for which we collect data.
10. TRANSFER OF PERSONAL DATA
10.1 During our engagement with you, we may need to transfer Personal Data to third-parties located in a territory outside of Jamaica for further processing in accordance with the purposes for which the Personal Data was originally collected or for purposes to which you have subsequently consented.
10.2 By using our services, you hereby consent to the transfer of your Personal Data to a territory outside of Jamaica whenever such need may arise.
10.3 You shall not hold us liable for the manner in which your Personal Data is processed and/or used by any third-parties which are situated outside Jamaica.
11. RETENTION OF PERSONAL DATA
11.1 Adlinc retains Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, Adlinc refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data;
- Whether the data is necessary to provide our Site or Services; and
- Whether our Clients would reasonably expect that we would retain the data until they remove it or until their accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
11.2 It is a requirement that when you disclose any Personal Data of third-parties to us, you shall obtain the consent for us to retain for a similar period the Personal Data of such third-parties and you shall wholly indemnify and keep us indemnified against any loss, damage or claim made against or incurred by us resulting from the retention of such Personal Data by us.
12. WHAT ARE YOUR RIGHTS WITH RESPECT TO DATA PROTECTION
12.1 You will have the following rights with respect to your Personal Data:
- Access: You are entitled to ask us if we are processing your Personal Data and, if so, you can request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and certain other information regarding the Personal Data.
- Rectification: You are entitled to request that any incomplete or inaccurate Personal Data we hold about you is rectified. If you are entitled to rectification and if we have shared your Personal Data with others, we will notify such other persons about the rectification where possible. If you make such a request, where possible and lawful to do so, we will also tell you the person(s) with whom we have shared your Personal Data so that you may contact such person(s) directly.
- Erasure: You are entitled to ask us to delete or remove Personal Data in certain circumstances such as where we no longer need it or if you withdraw your consent (where applicable). There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Data is required for compliance with local laws or in connection with claims. If you are entitled to erasure and if we have shared your Personal Data with others, we will notify such other persons about the erasure where possible.
- Restriction: You are entitled to ask us to suspend the processing of your Personal Data, for example, if you would like for us to establish its accuracy or the reason for processing it.
- Transfer: You may request that we transfer certain of your Personal Data to another party.
- Objection: You are entitled to ask us to stop processing your Personal Data in certain circumstances, for example, where the processing is likely to cause substantial damage or distress except if we can demonstrate compelling legal grounds for the processing. You also have the right to object where we are processing your Personal Data for direct marketing purposes. You may opt-out of receiving direct marketing from us at any time.
- Automated decisions: You may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
- Consent: If we rely on your explicit consent as our legal basis for processing your Personal Data, you may withdraw your consent at any time. However, we note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide our services to you. We will of course advise you, if this is the case, at the time you withdraw your consent.
12.2 Full details of these rights can be found in Part II of the Data Protection Act, 2020.
12.3 Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process your Personal Data.
12.4 If you would like to exercise any of the abovementioned rights, you may contact the Data Privacy contact set out in this Policy below.
13. CORRECTING AND UPDATING PERSONAL DATA
13.1 You must inform us immediately where your Personal Data has changed, or where you believe that the Personal Data we hold is inaccurate, incomplete or otherwise deficient.
13.2 Adlinc will not be held responsible for any loss, damage or claim that may arise due to any inaccurate, incomplete, or otherwise deficient Personal Data which you or any third-party entity have provided to us.
14. CHANGES TO THIS POLICY
This Policy was last updated on November 30, 2023. We will update this Policy from time to time to reflect any changes to our use of your Personal Data. We may also update this Policy as required to comply with changes in applicable law or regulatory requirements. Our obligations will be determined having regards to the policy as amended from time to time and not the policy at the time the Personal Data was collected by us. We will use reasonable efforts to notify you of any changes to this Policy.
14. APPLICABLE LAW
This Policy shall be governed by and construed in accordance with the laws of Jamaica.
15. HOW TO CONTACT US
Please contact us if you have any questions or comments about our privacy practices or this Policy. Our contact information are as follows:
Telephone No: 888-922-4009
Email Address: info@adlinc.com
Address: 1-3 Pimento Way, Suite A105, Montego Bay Freeport, St. James, Jamaica