PRIVACY POLICY

Unicomer (Barbados) Ltd is committed to respecting the privacy of our customers, third-party vendors, and all individuals who provide personal data to Unicomer Barbados. As part of our commitment to protecting your privacy and complying with our data protection obligations under the Data Protection Act, 2019 of Barbados and other applicable laws, we have developed this Privacy Policy (the “Policy”) to outline to you 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 Barbados, that is, Courts, Courts Ready Cash, and Courts Optical under which Unicomer Barbados conducts business within Barbados. This policy applies to you when you are in Barbados.

The companies identified within Unicomer Barbados 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.

Most times we will ask for your consent to process your personal information. Other times, when you may reasonably expect us to use your personal data, we may do so without your consent. Where we do not obtain your consent, we will only use your personal information when we have one or more of the following lawful bases for processing:

  • Performance of a contract: Where the processing is necessary for the performance of our contract with you 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 include:
    • 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 any 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. For example, compliance with 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.

6. WHEN DO WE SHARE YOUR DATA

There may be instances where we share your personal data with third parties. This includes:

  • 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, 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
  • 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

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 involved in your care.
  • For Payment: We may use and disclose health information about you to bill and collect payment from you, an insurance company, or a third party.
  • For Health Care Operations: We may use and disclose health information about you to run Unicomer Barbados and ensure quality care for our patients.

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 Barbados, or to other entities in our group of companies. These transfers may include countries such as El Salvador (our headquarters), the Caribbean, USA, UK, EU, or Canada.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We only permit them to process your personal data for specified purposes and in accordance with our instructions and 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. Customer account records are normally kept for up to five years after your relationship ends, after which the information is securely destroyed. We may keep data longer if required for legal, regulatory, or dispute resolution purposes.

9. AUTOMATED DECISION MAKING

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

For fraud prevention, your personal information may be processed via systems designed to assess data for fraudulent patterns. For example, suspicious account activity may indicate fraud, influencing our decision-making process. Should it be determined that activity surrounding your account is fraudulent or suspicious, you will be entitled to an explanation as to why such conclusions were reached. You will also have the opportunity to rectify any misinformation to ensure fair reassessment.

10. RIGHTS YOU HAVE OVER YOUR DATA

You have the legal right to the following:

  • The right to be informed of your personal data being processed and the right of access to the same
  • The right to have inaccurate information rectified or completed
  • The right to have your personal data erased without undue delay
  • The right to have the processing of your personal data restricted
  • The right to receive personal data in a portable manner
  • The right to prevent processing likely to cause damage or distress
  • The right to prevent processing for direct marketing purposes
  • The right not to be subject to automated decision-making
  • The right to information from Unicomer Barbados (at the time when personal data is obtained)
  • The right to lodge a complaint with the Commissioner
  • The right to withdraw consent

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

11. OUR USE OF TECHNOLOGY

When using our technology, whether online or offline, certain personal information is automatically processed, such as via CCTV, foot traffic, website visits, or mobile app usage. This data is used to monitor capacity, traffic, and improve services.

CCTV at Unicomer Barbados Sites

We use CCTV systems to monitor and record activities at our properties and premises to maintain a safe and secure environment for employees, customers, and visitors. The data may be used for security, risk management, loss prevention, incident investigation, and analyzing customer behavior or demographics (aggregated anonymously). Data is securely discarded when 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 carry a Wi-Fi-enabled device within range, data such as device ID, IP address, MAC address, and geo-location may be collected. To avoid this, disable Wi-Fi and Bluetooth functions or refrain from connecting to our network.

Cookies

When visiting our website, cookies may store or retrieve information such as your preferences or device details. Cookies are used to enhance user experience but do not identify you specifically. You can manage cookie preferences via our website’s banner, but this may affect functionality.

Use of Third-Party Cookies

We use third-party providers, such as Social Media Channels, Adobe Analytics, and Google Analytics, to collect information like visitor numbers, site origins, and visited pages. These providers may also use cookies for targeted advertising and campaign measurement. We do not combine this data with other personal information.

12. CONTACT US

If you have any queries or complaints about privacy, please contact our Data Protection team at:

Email: dpo@unicomer.com

13. CHANGES TO THIS PRIVACY POLICY

Unicomer Barbados reserves the right to reasonably amend this Policy from time to time to ensure it accurately reflects how we collect and use personal information. We encourage you to regularly review this Policy for updates.

This Privacy Policy was last updated on July 4, 2024.