CICSA Cooperative Credit Union Privacy Statement & Policy

Last Revised - 30 September 2019

At CICSA Cooperative Credit Union Limited (Our Credit Union), we are committed to protecting your privacy and safeguarding your personal, business and financial information. This Privacy Statement applies to Our Credit Union.

The purpose of this Privacy Statement is to inform you about the types of Personal Information, as defined below, that Our Credit Union processes. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. It is designed to meet the standards prescribed by Cayman Islands Data Protection Act (“DPA”) and best practice. 

From time to time, we may make changes to this Privacy Statement. It is current as of the “last revised" date which appears at the top of this page.

We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected and our Privacy Policy, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

The Statement covers the following:

1. What is Personal Information?

2. How do we collect your Personal Information?

3. Where do we store your Personal Information?

4. How do we use your Personal Information?

5. To whom do we provide your Personal Information?

6. When and how do we obtain your consent?

7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?

8. How long will we use, disclose or retain your Personal Information?

9. How can you access your Personal Information that we have collected, utilized or disclosed?

10. How do you know that the Personal Information we have on you is accurate?

11. What if the Personal Information we have on you is inaccurate?

12. How fast will we respond to your written requests?

13. Are there any costs to you for requesting information about your Personal Information or our Privacy Policy or practices?

14. How do we know that it is really you requesting your Personal Information?

15. What safeguards have we implemented to protect your Personal Information?

16. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

1. What is Personal Information?

"Personal Information" is any information that can be used to identify you or that we can link to you as an individual. This refers to an identifiable natural person that can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We may collect your personal information when you provide it to us, which may include, but is not limited to: 

• Full name, date of birth, age, gender, nationality, marital status, passport, driving licence;
• Contact information including physical address, postal address, email address and telephone number(s); 
• Company, organisation and job title;
• Your Internet Protocol (“IP”) address;
• You health information, financial status, credit card information and credit history;
• Images and/or expression of personal opinion when you leave feedback, contact us, or approve its use;
• Your work status and other required employment or immigration-related data; and
• Details of your employment/education history, if applying for scholarship or employment position with Our Credit Union.

We may also collect information from other sources, such as social media platforms or applications that may share your device information/content and/or how you interact with our social media content.

2. How do we collect your Personal Information?

We will always collect your Personal Information by fair and lawful means (for example, when you engage us to provide services, use Our Credit Union website or speak to a Our Credit Union representative). We collect Personal Information directly from you, or indirectly from third party sources as otherwise permitted by applicable law.

Information you provide to us voluntarily

Periodically, you may voluntarily provide Our Credit Union with unsolicited Personal Information (for example, through Our Credit Union website). If you provide such information for any reason, you consent to Our Credit Union using that information in the ways described in this Privacy Statement or as described at the point where you choose to disclose this information. When providing Our Credit Union with unsolicited information, we ask that you do not provide any sensitive information (for example, Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or health information) unless you provide us with explicit consent to collect this information from you.

Information we may collect automatically through cookies and similar technologies

With respect to our website, Our Credit Union may use cookies, log files and web beacons to collect information regarding the use of the website. Generally, this information is non-identifiable and would likely not be considered Personal Information.

• Cookies: Cookies are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is Our Credit Union policy to use cookies to make navigation of our websites easier for visitors and to facilitate efficient registration procedures. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites.
• Log files: In order to properly manage our websites, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters and are generally non-identifiable.
• Web beacons: To gather visitor statistics and manage cookies, we use electronic images called a "single-pixel GIF" or "web beacon." Web beacons allow our third-party tracking tools, to gather information such as the IP address of your computer, the time the material was viewed, and the type of Internet browser used to access the page. This information is tracked on the third party tracking tools' servers and reported in aggregate to our webmasters. If you are concerned about the use of Web beacons you can turn off your browsers' cookies. This action will prevent Web beacons from tracking your specific activity; however, the Web beacon may still record a visit from your IP address.

3. Where do we store your Personal Information?

Personal Information provided to us is primarily stored on servers maintained by Our Credit Union. However, except where restricted by contractual arrangements or legal requirements applicable to specific individuals, Our Credit Union may also leverage the services of select third party service providers. Personal Information that is "in the cloud" may be stored on multiple servers in a number of locations around the world. Our Credit Union has taken appropriate steps for the protection of Personal Information handled by our service providers. However, information transmitted to other countries may be subject to the laws and lawful disclosure requirements of the jurisdiction(s) where the information is stored.

4. How do we use your Personal Information?

We generally use your Personal Information for the following purposes:

• To provide you with banking services;
• To process and deliver products that you have requested from us;
• To invoice and collect payment for services and products provided by us to you;
• To develop and maintain our relationship with you and communicate with you;
• To register you for events and meetings;
• To register you for, and facilitate your participation in, certain areas of our website, including any online services, discussion or message forums;
• To research, develop, manage, protect and improve our services;
• To assist Our Credit Union with improving its operational efficiency, marketing campaigns and member service efforts through the use of data analytics;
• To gather your opinion and feedback through surveys;
• To enroll you in our contests or promotional programs; and to advise you about new products and services that may be of interest to you. 

You can choose not to receive any electronic marketing communications from us by clicking the “opt-out” function contained in Our Credit Union's electronic communications. You may choose not to receive any direct mail from us by contacting us as indicated in the “Contact Us” section below. This also applies to any other such uses as may be permitted or required by applicable law.

We identify the purposes for which we use your Personal Information at the time we collect it from you. We obtain your informed, freely given and unambiguous consent prior to each specific use. When you provide us with consent to use your Personal Information, your consent covers all processing activities carried out for the same purpose(s). When the use of your Personal Information has multiple purposes, Our Credit Union will seek your consent for each separate purpose for which it will be used.

5. To whom do we provide your Personal Information?

We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.

For example, we may transfer your Personal Information to third-party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes — such as service providers that provide data storage or processing.

Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all of the business of Our Credit Union or as otherwise permitted or required by law, in which case the use of your Personal Information by the new entity would continue to be limited by applicable law.

In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. These service providers will be required to have equal, adequate protection in line with Cayman Data Protection Law requirements.

To the extent that any Personal Information is out of the jurisdiction of Our Credit Union, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

There may be places throughout the website that link to other 3rd party websites that do not operate under this Privacy Statement. When you link to other websites, Our Credit Union's privacy practices no longer apply. For this reason, we encourage visitors to review each site's privacy policy before disclosing any Personal Information.

6. When and how do we obtain your consent?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your express consent to us either orally, electronically or in writing. You may also consent to Our Credit Union collection, use and disclosure of Personal Information by voluntarily providing us with Personal Information through a clear, affirmative action (e.g. by submitting an information request, participating in a survey, etc.). Our Credit Union may also rely on your implied consent to the collection, use and disclosure of your Personal Information where implied consent is permitted under applicable law.

We will not, as a condition of the supply of our banking services or products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.

With respect to our website, should visitors subsequently choose to unsubscribe from mailing lists or any registrations, visitors may send us an email using the Contact Us page.

7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?

We ensure that all affiliates and other third parties, which are retained to perform services on our behalf and are therefore provided with Personal Information are contractually required to observe the intent of this Privacy Statement and Our Credit Union privacy and data security policies and practices. When providing information to affiliates and/or third parties, Our Credit Union complies with the requirements of the Cayman Data Protection Law.

8. How long will we use, disclose or retain your Personal Information?

We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected, or as permitted or required by law.

9. How can you access your Personal Information that we have collected, utilised or disclosed?

If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information as permitted or required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes. To submit a written access request, or to obtain further information with respect to your access rights using the details in the Contact Us page.

10. How do you know that the Personal Information we have on you is accurate?

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information unless such a process is necessary. We may request, from time to time, that you supply us with written updates to your Personal Information, as required.

11. What if the Personal Information we have on you is inaccurate?

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

12. How fast will we respond to your written requests?

Unless we advise you to the contrary, we will respond to each of your written requests not later than one month after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. As prescribed in Cayman Data Protection Law, you have the right to make a complaint to the appropriate authority in respect of this time limit.

13. Are there any costs to you for requesting information about your Personal Information or our Privacy Policy or practices?

In many circumstances, we will be able to provide you with the requested information free of charge. However, in certain circumstances in which we may lawfully charge a fee covering the cost or providing the requested data and information or even may lawfully refuse to act on the request. If a fee is payable then we will generally need to receive it before we can disclose the requested information. However, we will not charge any costs for you to access your Personal Information in our records or to access our Privacy Policy or practices without first providing you with an estimate of the approximate costs (if applicable and as permitted under relevant law). You may withdraw your requests for access to information by notifying us within the notice period disclosed on the estimate.

14. How do we know that it is really you requesting your Personal Information?

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

15. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business 'need-to-know' or whose duties reasonably require such information. On the Our Credit Union websites, we use secure socket layer technology.

16. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

For all comments, questions, concerns or complaints regarding your Personal Information or our Privacy policy, contact us using the details below:

Contact Us

If you would like to contact us with questions about our privacy or data protection practices, please contact us via one of the following methods:

Email: compliance@cicsacu.com.ky

Phone number: 1-345-815-4232

In-branch: Grand Cayman or Cayman Brac