Privacy Policy

Unicomer (Antigua and Barbuda) Limited and Redstart Investments (A&B) Limited (collectively, “Unicomer Antigua”) is committed to respecting the privacy of our customers, third-party vendors, and all individuals who provide personal data to Unicomer Antigua. As part of our commitment to protecting your privacy and complying with our data protection obligations under the Data Protection Act, 2013 of Antigua and other applicable laws, we have developed this Privacy Policy (the “Policy”) to outline how we protect the personal data you have provided to us.

This Policy applies to all personal data you may provide to us, and information that we collect from our customers, or any other person who may interact with us. It outlines:

  • What data we might collect about you
  • How we might use that data
  • When we might use your details to contact you
  • What data of yours we might share with others
  • Your rights in relation to the personal data you give us

What Does This Policy Cover?

This Policy covers all services or products offered by all brands within Unicomer Antigua, that is, Courts, Courts Ready Cash, and Courts Optical under which Unicomer Antigua conducts business within Antigua and Barbuda. This policy applies to you when you are in Antigua and Barbuda.

The companies identified within Unicomer Antigua are the controllers for the purposes of this Policy. This means that we are responsible for deciding how your personal data is used and ensuring that it is used in compliance with applicable data protection law. Sometimes, we may work with other companies to decide how your personal data is used. In those scenarios, we are joint controllers with these companies because we jointly determine the purposes and means of processing your personal data.

If you have any comments, queries, or questions about this Policy, feel free to contact us at dpo@unicomer.com.

1. Personal Data That We Process

We collect the following information from you, directly and through third parties. The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed:

  • Personal Data: For example: name, driver’s license number, passport number, photo ID, taxpayer number, social security number, NIS, voter’s identification.
  • Contact Details: For example: email address, telephone numbers, residential address, mailing address.
  • Employment Information: For example: employment status, employer name and address, nature of self-employment, type of business, salary and benefits, employment history.
  • Demographic Details: For example: date of birth, gender, age, nationality, marital status.
  • Financial Information: For example: credit report, credit card statement, bank statement, income, expenses, PEP status, and other AML/KYC data as required by law.
  • Payment Information: For example: credit or debit card details, bank account information, to the extent that it identifies you.
  • Background Check Information: For example: sanction list checks.
  • Account Login Credentials: For example: username and password.
  • Health Information: For example: medical history, health status and outcomes of medical reports, family medical history.
  • Electronic Communications Data: For example: IP address, geographic location, operating system, and browser type, when you visit our sites or use our online services.
  • Image: For example: CCTV surveillance in our stores may capture your image and likeness on camera.
  • Religious Beliefs: We may receive information about your religious beliefs specifically as it relates to your delivery preferences and timelines.

2. How Your Personal Data Is Collected

We collect most of this personal data directly from you (in person), by telephone, letter, or email and/or via our website. However, we may also collect information:

  • When you register and/or attend any of our events, webinars, or the conferences we host, sponsor, or are represented.
  • From publicly accessible sources, e.g., government authorities or social media websites.
  • Directly from a third party, e.g.:
    • Sanctions screening providers.
    • Credit reference agencies.
    • Customer due diligence providers.
  • From a third party, which may be with your consent or pursuant to a legal obligation, e.g., banks or building societies.
  • Through our IT systems, e.g.:
    • Automated monitoring of our websites and other technical systems, such as our computer networks and connections.
    • CCTV and access control systems, including in our branch.
    • Communications systems, such as call recordings.
    • Email and instant messaging systems.
  • From cookies on our website – for more information on our use of cookies please see Section 11 of this Policy.

3. Accuracy of Your Information

We rely on the availability of accurate personal information to provide services to you and operate our business. You should therefore notify us of any changes to your personal information, such as changes concerning your contact details or any other information that may affect the proper management and administration of the services we provide to you.

4. Why Do We Process Your Data

Under data protection law, we can only use your personal data if we have a valid purpose for doing so.

We may process your personal data for the following purposes:

  • To provide you with retail of goods or our services.
  • To deliver any goods to your designated location and verify your location.
  • To enable our Contact Centre to initiate the resolution of any issues you may raise in the provision of our goods or services.
  • To process any payments or refunds to you.
  • To process and investigate any complaints or queries you may have about our goods or services.
  • To process and enable any service request relating to any of our goods.
  • To initiate any collections, debt recovery efforts, or litigation against any defaulting customer, as may be necessary.
  • To assess your medical needs for the provision of prescription eyewear and other ophthalmic needs.
  • To share information with a contracted optometrist to provide you with prescription eyewear.
  • To assess your suitability for any credit facility or retail finance which you have requested.
  • To collect information on behalf of our remittance partners.
  • To carry out “Know Your Customer” due diligence checks including data validation and verification, sanction checks, credit reference checks, and other customer acceptance, vetting, and risk management checks as required under anti-money laundering law.
  • To capture your image and likeness through CCTV surveillance systems, which monitors and records activities at our properties to maintain a safe and secure environment for our employees, customers, and visitors to our properties.

We may also, with your consent, use your personal data to contact you about products, services, and special offers from us or our affiliates that may interest you. While we may process personal data with your consent, you have the right to withdraw consent to processing for specific purposes, as outlined below.

5. Lawful Bases for Processing

We must have a valid reason to use your personal information. This is called the “lawful basis for processing”.

Consent

Where we process your personal data with consent, you may choose whether you wish to provide us with the information we request, or not. You are free to choose to provide your information or not, and you may choose to withdraw your consent at any time after. If you wish to withdraw your consent at any time, please contact dpo@unicomer.com with your request. We will collect your consent through any forms or agreements you may sign with us.

Performance of a contract

Where the processing of data is necessary for the performance of our contract to provide you with products and/or services (for example, cash and credit transactions, delivery of goods, open accounts, maintain account details, perform administrative tasks, and provide services to fulfill our obligations in the contract with you, etc.).

Legitimate interests

The collection and use of some aspects of your personal information may be necessary to enable us to pursue our legitimate commercial interests. Where collection and processing of your personal data is based on the ground of legitimate interest, appropriate steps will be taken to ensure that there is no infringement of the rights and freedoms granted to you under the applicable data privacy laws.

Examples of where your personal information will be processed based on legitimate interest includes:

  • To improve suitable products and/or services.
  • For CCTV surveillance on our properties.
  • To prevent fraud.
  • To ensure network and information security of our systems.
  • To operate our business and manage and develop our relationship with you.
  • For intra-group administrative transfers.
  • To understand how you use our products, services, and websites and effect improvements.

Administration of justice

We may process your personal data to aid with the administration of justice. This may occur when we initiate legal action against a defaulting customer or when we are legally required to provide information or allow access to law enforcement and other governmental authorities/agencies.

Medical purposes

For Courts Optical, we may process sensitive personal data through contracted health professionals in order to provide you with eye examinations and treatment, and to offer you prescription eyewear.

Legal obligations to which we are subject

In some instances, we are required by law to collect and process certain personal information about you when you apply for a product or service and on an ongoing basis. This is where the processing of your personal data is necessary for compliance with a legal obligation to which we may be subject to (for example, our obligations under the Proceeds of Crime Act 1993 where we are required to collect information about your identity – Know Your Customer).

Please note that if we are not provided with this information, it may not be possible for us to continue to operate your account or provide services to you, given that we are legally required to collect this information.

6. When Do We Share Your Data

There may be instances where we may share your personal data with third parties. We may share your personal data, in the following limited circumstances, with:

  • Companies within Unicomer Group.
  • Contractors we engage to help us run our business, e.g., marketing agencies, bailiffs, debt collection agencies, delivery drivers, technicians, or website hosts.
  • Banks to help trace funds where you are a victim of suspected financial crime and you have agreed for us to do so, or where we suspect funds have entered your account because of a financial crime.
  • Credit reference agencies; our insurers, brokers, and other professional advisers.
  • Regulatory bodies or government authorities or executive agencies, as may be necessary to record any security interest we may have, to notify any pending insolvency or bankruptcy proceedings, or in accordance with any regulatory requirement.
  • Our payment protection insurers.
  • Fraud prevention agencies if false or inaccurate information is provided and/or fraud is identified or suspected.
  • Law enforcement agencies and other organizations to report any suspected crime in accordance with anti-money laundering regulations or as part of a criminal investigation.
  • External auditors where necessary for the conduct of company audits.
  • Remittance partners in order to facilitate a remittance service to you.
  • In the event that any additional authorized users are added to your account, we may share information regarding any indebtedness, about the use of the account by any authorized user with all other authorized users.

We may also disclose health information for the following purposes:

  • For Treatment. We may disclose health information about you to doctors, nurses, technicians, staff, or other personnel who are involved in taking care of you and your health.
  • For payment. We may use and disclose health information about you so that the treatment and services you receive at Unicomer Antigua may be billed to, and payment may be collected from you, an insurance company, or a third party.
  • For Health Care Operations. We may use and disclose health information about you in order to run Unicomer Antigua and make sure that you and our other patients receive quality care.

7. International Transfer of Your Information

We may transfer personal data that we collect from you to our third-party data processors, vendors, remittance partners or hosting partners acting on our behalf located in countries outside of Antigua and Barbuda or to other entities in our group of companies, such as El Salvador, where our headquarters are located, in connection with the purposes set out above. We may transfer your personal data to data processors located in the Caribbean, USA, UK, the EU, or Canada.

In particular, we may make such transfers to offer, administer and manage the services provided to you, to improve the efficiency of our business operations, in keeping with your directives and to comply with a legal duty to do so.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies, and we require them to have data processing agreements with us. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions and our established procedures.

If you would like further information, please contact our Data Protection team at dpo@unicomer.com.

8. How Long We Keep Your Data

We take the principles of data minimization and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.

We normally keep customer account records for up to five years after your relationship ends, then the information is securely destroyed. We may also keep your data for longer than five years if we cannot delete it for legal, regulatory, or as necessary to resolve disputes and enforce our agreements.

9. Automated Decision Making

The information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with. When you apply for a loan or any other form of credit, we will need to assess your creditworthiness based on several factors. We may use an automated decision-making process for that decision.

In the interest of fraud prevention, your personal information may be processed by Unicomer Antigua via the use of systems designed to assess data in order to determine whether there is any presence of fraud or fraudulent patterns. For example, it may be revealed that an account is being used in a suspicious and unusual manner, which may allude to the presence of some fraudulent activity which may be detrimental to the customer, Unicomer Antigua, and/or our insurers. Consequently, this will influence our decision-making process.

Should it be determined that the activity surrounding a particular account is fraudulent and suspicious in nature, the customer will be entitled to an explanation as to why such conclusions were reached. The customer will also be given the opportunity to rectify any misinformation to allow for a fair re-assessment in the interest of receiving a rectified and favourable deliberation.

10. Rights You Have Over Your Data

We aim to maintain data that is accurate and up-to-date. Should there be any changes to your personal data (e.g. moving addresses, name changes etc.), please notify us as soon as possible so that we may be able to update our records accordingly. You have the legal right to the following:

  • The right to be informed about the collection and use of the personal data;
  • The right to access your personal data and any supplementary information being kept and processed by a Data Controller;
  • The right to have inaccurate personal data rectified or completed or updated;
  • The right to erasure (deletion) in certain circumstances;
  • The right to object to the processing of your personal data in certain circumstances; and
  • The right to withdraw consent at any time.

To exercise these rights, please contact us via email, mail, or phone as indicated below in the “Contact Information” section.

11. Our Use of Technology

When using our technology, whether it be online or offline, certain personal information will be automatically processed for example via CCTV, foot traffic, visits to our websites or use of the mobile app. We use this information to determine which areas of our business is frequented in order to monitor our capacity and traffic across the business. This helps us to add more value to our services.

CCTV at Unicomer Antigua sites and retail stores

We use CCTV surveillance systems to monitor and record activities at our properties and premises (including our workplace and logistics and retail centre premises), the main purpose of this is to maintain a safe and secure environment for our employees, customers and visitors to our premises.

We also use the data collected from our CCTV surveillance systems to maintain or improve our properties, premises and services; we may do this:

  • For security and risk management, loss prevention, incident investigation purposes and other purposes set out in this Policy, or as permitted by the law.
  • By collecting and analysing customer behaviour;
  • By monitoring patterns of foot traffic; and
  • By analysing shopper demographics and browsing habits. (Note, when used for these purposes the data is aggregated anonymously. We do not identify individuals for these uses.)

We securely discard the data collected from our CCTV surveillance systems when it is no longer required for business or legal purposes.

Free Wi-Fi service

Free Wi-Fi network service is offered at certain retail stores.

If you are carrying a Wi-Fi enabled device within range of one of our free Wi-Fi networks, data may be received or transmitted from your device regardless of whether or not you have joined our free Wi-Fi network. Information which may be capable of being transmitted to us from your device, may include:

  • Your device ID, device type, IP address and MAC address;
  • Your geo-location information and any movement of your device throughout our premises;
  • Any other information which you may voluntarily provide to us while accessing our Wi-Fi networks.

If you do not want this information collected, you may need to disable the Wi-Fi and Bluetooth functions on your device. You should also refrain from connecting to our free Wi-Fi network.

Cookies

When you visit any website, it may store or retrieve information from your browser, mostly in the form of cookies. Cookies are small files of information that a website generates and sends to your browser. Cookies are sent to us each time you visit our website. Cookies will allow us to retain information about your visit to our website. This information is then used by us so that we may be able to give you a better and more useful experience the next time the website is visited. This information may include details about you, your preferences or your device and is mainly used to ensure that the website works as expected. The information collected will not be sufficient to specifically identify you, it will however, give you a more personalized web experience. Because we respect your right to privacy, you may choose not to allow some types of cookies. You will have the option to adjust your preferences in the banner on our website, however this may affect or prevent the functionality of certain aspects of our websites.

Use of Third Parties Cookies

We may use third party providers, such as Social Media Channels, Adobe Analytics, and Google Analytics, to help collect and compile information such as the number of visitors to our website, where visitors are from and the pages they visit. Our third-party providers may also use cookies to deliver advertisements that are more relevant to you and your interests and to help measure the effectiveness of an advertising campaign. Interest-based advertising allows us to deliver advertisements that are more relevant to you and your interests. It works by showing you advertisements that are based on your browsing patterns and the way you have interacted with this and other sites.

These third parties may collect your IP address or device identifier on the date you visit a site, but not your name or other identifying information. We do not combine information collected using these third-party providers with other personal information we may have about you. Third party providers will have their own cookie and privacy policies. A third party’s ability to use and share information collected is restricted by their Terms of Service and Privacy Policy.

12. Contact Us

If you have any queries or complaints about privacy, please contact our Data Protection team at dpo@unicomer.com.

13. Changes to This Privacy Policy

Unicomer Antigua reserves the right to reasonably amend this Policy from time to time to ensure that it accurately reflects the way that we collect and use personal information about you. You are encouraged to regularly review this Policy to ensure that you understand how we collect and use your personal information and to see any changes that may have occurred.

This Privacy Policy was last updated on July 04, 2024.