Privacy Notice

WHO WE ARE

JOH Investments Limited (collectively referred to as “the Company” , “we” , “us” or “our” in this Privacy Notice) is a company duly incorporated under the laws of Jamaica and is the controller responsible for your personal data. The Company respects your privacy and is dedicated to safeguarding your personal data. This notice explains what personal data we will hold about you, how we collect it, and how we will use and may share information about you.

THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymized data).

We may collect, use, store and transfer different kinds of personal data about you as follows:

HOW YOUR PERSONAL DATA IS COLLECTED

We may collect your personal data directly from you, from your broker and, where permitted by law, from publicly available sources, for example:

1. When your Insurance Broker makes a request for our services on your behalf;
2. When you complete our Application Form(s) as an individual customer;
3. When a corporate customer completes our Application Form(s) and you are a director, shareholder, contact person or authorized person of the corporate customer.
4. When you interact with us over the phone or through e-mail communications;

HOW WE USE YOUR PERSONAL DATA

We have set out below, in table format, a description of the main activities in which we use your personal data, and which of the legal bases we rely on to do so.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose in which instance we have a legitimate interest to process your personal data for that new purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose which does not meet our legitimate interests test, we will notify you and we will explain the legal basis which allows us to do so.

DIRECT MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have signed up for and/or used our services and you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at [insert email address of general inbox of JOH’s Data Protection Officer or contact person for privacy e.g. privacy@johinvestments.com].

DATA SHARING

The Company may share your personal data with third parties for specific purposes, as set out in “How We Use Your Personal Data” above. These third parties may include regulatory authorities and government organizations and service providers which help us ensure the seamless operation of our business relationship, toward fulfilment of your contract with us. These service providers may transfer your personal data out of the jurisdiction to enable cloud storage or other to facilitate any software or other technology which aids us in operating our business. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

YOUR LEGAL RIGHTS

You have the following rights under the Data Protection Act:

1. The right to request a copy of the personal data that we hold about you.
2. The right to ask us to rectify any inaccuracies in the personal data we hold about you.
3. The right to object or to prevent the processing (or further processing) of your personal data in certain circumstances.
4. The right to withdraw consent to marketing.
5. The right related to solely automated decision-making including profiling. We do not use automated decision-making processes that would significantly affect you. But, if we did, you have the right to human intervention, to be informed of the logic of the decision and to have the decision reconsidered.
6. The right to data portability to transfer your data to another controller.

If you wish to exercise any of the rights set out above or have any questions about this privacy notice or our privacy practices, please contact us at privacy@johinvestments.com.

CHANGES TO THE PRIVACY NOTICE

We keep our privacy notice under regular review. This version was last updated on October 29, 2024. We will contact you if we make significant changes to this NOTICE.

HOW TO CONTACT US