Privacy Policy | Mayberry Investments Limited

Introduction

The purpose of this privacy notice is to provide you with information on the privacy practices of Mayberry Investments Limited in accordance with The Data Protection Act, 2020. We aim to help you understand what Personal Data we collect, how we use it, and what control you have over it. For the purposes of this privacy notice, “Personal Data” means information relating to a living individual or an individual who has been deceased for less than thirty years, who can be identified from the information.

This notice outlines the following:

What Personal Data is collected from you;
How Personal Data is collected, used, shared, stored, and otherwise processed;
The security procedures implemented to protect your data; and
Your choices and rights regarding the use of your data;

Who We Are

Mayberry Investments Limited (“MIL”) is a full-service financial advisory and brokerage firm specializing in Trading, Asset Management, and Investment Banking. Its mission is to create opportunities for customers to realize their financial objectives, locally and internationally. To do so we process Personal Data that you provide.

For the purposes of this notice, we act as the “Data Controller”.

Data We Collect

We have access to data that you voluntarily provide via email, telephone, forms (both physical & electronic).

Through these means, we collect the following categories of personal data:

Your name, age, date of birth, gender, signature, and nationality;
Contact details, such as, phone number, email address, current and previous address;
Government identifiers, such as TIN/TRN, SSN, ID numbers/photo ID;
Employment information/ School information, such as occupation;
Banking information; Transactional information, such as account number, transaction dates, transaction amounts, JCSD number, trade volume and price, trade requests, transaction types, proof of address, proof of income, account balance, number of units of shares held; and

Family information.

How We Use Your Data

We process your Personal Data for the following purposes:

Account creation and administration;
Processing your applications and transactions;
Verify your identity;
Fulfilment of legal and regulatory obligations;
Completion of regulatory and internal audits;
Fulfillment of obligations outlined in any agreements;
Responding to your requests and comments; and
Carrying out marketing/ sales processes (such as AD Campaigns and social media engagement).

Legal Basis of Processing

We have different bases on which we process personal data. The bases may include:

For the purposes of our own legitimate interests, granted that the interests of MIL do not override any of your own interests, rights, and freedoms. These legitimate interests include processing for marketing, research, and business development purposes;

Consent so that we may communicate with you regarding products and services that may be of interest. You also have the right to withdraw this consent to processing for these purposes at any time;

For the purposes of fulfilling a contractual obligation; and

For compliance with any legal obligation and statutory requirements.

Specific Data Use

There are some categories of Personal Data that we collect, and process based on statutory requirements. This is to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud. We and other organisations may access and use certain Personal Data to prevent fraud, money laundering and terrorism, or other criminal offences, as may be required by applicable law and regulation and best practice at any given time. This could include checking against sanctions, politically exposed persons and other fraud or crime screening databases. If false or inaccurate information is provided and fraud is identified or suspected, we may pass your details to fraud prevention agencies and we or these agencies may store these details for record keeping purposes.

Cookies

Our website uses cookies to better understand your interests and needs so that we can serve you better and to give you the best possible experience by customizing our webpage content. Details of your activity on our websites, including browsing behaviour on our site and links, the locations you click, form data and downloads, as well as other data gathered are collected. For our company’s legitimate interest, we process personal data collected via essential cookies which are necessary for our website to function. Other cookies which purpose is to allow for a more enjoyable experience only are used following your consent. You can choose to disable these cookies through your individual browser settings or by managing your preferences. Our Cookie Notice provides details on the types of cookies and utilization of personal data collected during visits to our website.

How We Share Your Data

Depending on the service provided, your Personal Data may be shared with different internal departments and third-party vendors when necessary to facilitate provision of services and/or for other legitimate interests. Third parties include service providers, regulatory bodies, and professional advisors. It is contemplated that your Personal Data will be shared with the following regulators in compliance with statutory requirements:

Financial Investigations Division;
Bank of Jamaica; or
Financial Services Commission

How Long We Store Your Data

We have policies in place that govern the retention of your Personal Data so it will be kept only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements. These requirements also apply to third parties who work with us.

To determine the appropriate retention period, we consider different criteria, including the purposes for which we process your Personal Data, the need for maintaining your Personal Data to provide you with products and services, and all applicable legal and regulatory requirements. We may retain Personal Information beyond our designated retention periods due to regulatory requirements or in response to a legal matter.

How We Protect Your Data

Securing your Personal Data is a priority for us, while both online and offline. We have implemented appropriate safeguards to prevent the unauthorized or unlawful processing of, or accidental loss or destruction of or damage to your personal data.

Employees and third parties are provided only with Personal Data on a need-to-know basis and only the minimum amount they require to complete their specific job. We have agreements and controls in place with third party service providers, requiring them to safeguard any Personal Data we provide to them and to use the Personal Data only for the purpose of providing the service we have requested them to perform. All employees are also subject to confidentiality agreements and undergo annual training on the proper handling of personal and sensitive personal data.

Linked Websites

For your convenience, hyperlinks may be posted on our website that link to other websites (the “Linked Sites”). These linked sites have their own privacy policies and customer information practices. We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of any Linked Sites or of any companies that we do not own or control.

Linked Sites may collect information in addition to that which we collect on the Websites. We do not endorse any of these Linked Sites, the services or products described or offered on such Linked Sites, or any of the content contained on the Linked Sites. We encourage you to seek out and read the privacy notice of each Linked Site that you visit to understand how the information that is collected about you is used and protected.

Your Rights Regarding Your Personal Data

We aim to maintain data that is accurate, complete and up-to-date. Under the circumstances that your Personal Data changes (e.g. mailing address), please notify us immediately at Contact Us, so that we can make the necessary changes. Failure to notify us of changes to your Personal Data may negatively impact the way we communicate with or provide services to you.

You have the legal right to the following:

To be informed as to whether we process your personal data;
Data Subject Access Request: to request all Personal Data we have collected about you, if any;
Portability: To request transfer of your Personal Data in a commonly used machine-readable format to another data controller that determines the purposes and means for which Personal Data is processed;.
To consent and withdraw consent given for the processing of your Personal Data at any time;
To prevent the processing of your Personal Data based on our grounds for legitimate interest, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
To ensure that no decision having significant impact on you, the data subject, is made solely by automated means; and
To request rectification of any errors or omissions in the Personal Data we have collected about you.

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

Contact Information

For any questions, concerns, or requests to exercise your rights outlined in this privacy notice, please contact us via email at dpo@mayberryinv.com, phone at 876-929-1908, or mail us at:

Data Protection Officer

Mayberry Investments Limited

1 ½ Oxford Road

Kingston 5, Jamaica