1. Your privacy
Your privacy is important to us. This notice (Privacy Notice) applies to personal information we collect from you when you use this website. If you’re a client of the Bank, or otherwise have a relationship with us, we may also have provided you with a separate privacy notice setting out how we use your personal information, which will also apply. You can also find that privacy notice by visiting the website for the product or services we provide to you (for example, https://d1zm2628k0l6s5.cloudfront.net) or by contacting your client service team.
Some of the links on this website may lead to the Bank’s or third party’s websites with their own privacy notices, which may be different to this Privacy Notice, and you should read those notices carefully.
For the purposes of this Privacy Notice, the data controller will be the Bank, a company incorporated in the Commonwealth of Dominica.
Please note that this website is powered and issued by the Bank and may be hosted in North America or elsewhere at the Bank’s discretion. For us to address any concerns, comments or complaints about this website most effectively, we recommend that these should be directed to: a) our client service team (details on the website), b) our data protection officer, or c) the local data protection regulator (details provided below).
We’ve also set out contact details for our data protection officer towards the end of this notice.
2. Information we may collect from you
We may collect and process the following information about you:
- Information that you provide to us, such as when you fill out a contact or web form, or if you register to receive Alerts or updates.
- Information that we obtain or learn, such as information about the browser or device that you use to access this site, how you use this site and the pages you visit, traffic and location data.
- We may also ask you for information if you experience problems when using this site. We may also ask you to complete surveys for research purposes, although you don’t have to respond to these.
- If we have an existing relationship with you, and we are able to identify you from information obtained or provided by your use of the site, we may associate those sets of information to, for example, enable us to respond to a query you have submitted.
- Please note that this website is not designed or intended for children and we do not knowingly collect data relating to children.
3. How we use your information
We’ll only use your information where we have your consent or another lawful reason for using it. Unless we say otherwise below, we’ll use your personal information on the basis that it’s within our legitimate interests in operating and maintaining the Site, and providing you with site functionality and related products or services.
We use the information provided or obtained via this site to:
- Respond to your queries and reports (for example, if you’ve asked a question or submitted a report via the Site).
- Provide you with information, products or services you have requested or which we think may interest you unless you tell us otherwise.
- Carry out our obligations from any contracts entered into between you and us.
- Allow you to participate in any interactive features of the Site.
- Notify you about changes to the Site.
- Provide you with alerts or updates where you’ve consented to receive these by registering on the Site. You can opt out of these at any time by clicking the “unsubscribe” link at the bottom of each email we send you.
- Ensure site content is presented in the most effective manner for the device you’re accessing it from (for example your mobile/cell phone, personal computer or other electronic devices).
- Undertake data analytics to learn more about how you and others interact with this Site and with our advertising.
- Detect and prevent misuse or abuse of this Site, our Products or services.
We also use the information to meet our compliance obligations, to comply with applicable laws and regulations and to share with regulators and other authorities to which the Bank and Group Companies are subject. This may include using the information to help prevent, detect or investigate crime (including terrorism financing, money laundering and other financial crimes). We’ll only do this on the basis that it’s needed to comply with a legal obligation, it’s in our legitimate interests and that of others, or to prevent, detect or investigate unlawful acts.
4. Who we’ll share your information with
We may share your information in order to provide you with products or services you’ve requested (for example, if they’re not provided by the Group Company operating this Site), if we have a legitimate interest in doing so (for example to manage risk, verify your identity, to combat fraud, or to prevent abuse of our Site, products or services), or where you’ve agreed to us doing so.
We may share your information with others including other Group Companies and (where legitimate and necessary) any of our service providers, anyone else whose products and services you’ve requested, anyone to whom we are under an obligation to disclose information to or where it’s in the public interest, for example, to prevent or detect fraud, criminal activity, or abuse of our Site, products or services).
5. IP addresses
We may collect information about your computer (or mobile device), including where available your IP address, operating system and browser type, for system administration or for our own commercial purposes. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
7. How long we’ll keep your information
We keep your information in line with our data retention policy. For example, we’ll normally keep correspondence for a period of six months. This enables us to comply with legal and regulatory requirements or to use the information where we need to for our legitimate purposes such as dealing with any enquiries.
We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes, e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc.
If we don’t need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.
8. Transferring your information overseas
Your information may be transferred to and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful.
You can obtain more details about the protection given to your information by contacting us at any time.
9. Your rights
You have a number of rights in relation to the information that we hold about you. These rights include:
- The right to access the information we hold about you and to obtain information about how we process it.
- The right, in some circumstances, to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so.
- The right, in some circumstances, to receive the certain information you have provided to us in an electronic format and/or request that we transmit it to a third party.
- The right to request that we rectify your information if it is inaccurate or incomplete.
- The right, in some circumstances, to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it.
- The right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and/or to refuse that request.
You can exercise your rights by contacting us using the details set out in the ‘More details about your information’ section below.
You have also the right to complain to the data protection regulator in your local jurisdiction. In addition, if you are dissatisfied with the decision you may have a right of appeal to the courts.
10. How we keep your information secure
We use a range of measures to keep your information safe and secure which may include encryption and other forms of security. We require our staff (and any third parties who carry out any work on our behalf) to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.
11. More details about your information
If you’d like further information about anything we’ve said in this Privacy Notice, or to contact our Data Protection Officer, contact us at email@example.com