Use of the Internet

Privacy issues, including security and confidentiality of personal information disclosed on or through this web site, are viewed very seriously by NCB Jamaica Limited. Policies governing the protection of privacy are strictly observed and enforced to ensure the highest standards of protection of privacy and personal information.

When you visit this web site, move from page to page, read pages, or download its content onto your computer, the following information may be recorded:

• The address you are connecting from
• Which pages are visited
• What content is downloaded
• The address of the web sites that you visited immediately before coming to this web site.

NCB Jamaica Limited uses this information to find out how many people visit this web site and which sections of the web site are visited most frequently. NCB Jamaica Limited may use this information to determine what type of information is most useful, improve this web site, address your specific needs, provide better customer service and for general marketing purposes. The information may also be used to provide records of communication between NCB Jamaica Limited and you, and to comply with any legal and/or regulatory requirements.

None of the information collected is associated with any individual. It is measured only in aggregate. NCB Jamaica Limited records the statistical information on the numbers of visitors to this web site, but no information about individuals in particular is kept or used.

Certain NCB Jamaica Limited employees will be provided with information about a web site visitor in order to serve that visitor's needs and provide the visitor with information regarding specific products. NCB Jamaica Limited employees are instructed to use strict standards of care in handling the personal, confidential information and the handling of such information is dealt with in NCB Jamaica Limited's Privacy Code. Non-compliance with this code will result in disciplinary sanctions that may include dismissal.

Client Record and Personal Information

In the course of our business relationship with you, the personal information collected about you is held in a "client record." This information likely includes, at a minimum, your name, address and telephone number(s), birth date, account holdings and if applicable, the name address of your spouse or beneficiary. Depending on the type of service you request, additional personal information may be held in your client record. This information was provided to NCB either by you or your financial advisor at the time the account was opened or as the information became necessary throughout the service process.

Collecting, Holding, Using and Disclosing Personal Information

NCB may collect, hold and use the personal information in your client record as well as collect personal information from and disclose personal information to the third parties identified below, for the following purposes:

• identifying you and ensuring the accuracy of information contained in your client record;
• establishing and administering your account, determining, maintaining, recording and storing account holdings and transaction information in your client record;
• executing transactions with or through NCB including transferring funds by electronic or other means;
• providing you and your financial advisor/dealer with investment account statements, tax receipts, financial statements for your investments, proxy mailings, transaction confirmations and other information that you or your financial advisor/dealer may request to service your account;
• protecting its own business interests including collecting a debt owed to NCB or allowing the performance of a transaction;
• meeting legal and regulatory requirements;
• verifying information previously given by you with any other organization when necessary;
• advising you of other similar NCB products, services or initiatives that may be of interest to you; and,
• for any other purpose you and NCB and/or your financial advisor may agree upon from time to time.

Consent

Your knowledge and consent to NCB’s collection, use and disclosure of your personal information is important. We rely on your actions as indications of your consent to our existing and future personal information practices:

• Your voluntary provision of personal information directly to NCB or through your financial advisor/dealer;
• Your express consent or acknowledgement contained within a written, verbal or electronic application process;
• Your consent solicited by NCB (or our agent) for a specified purpose;
• Your receipt of this Privacy Policy, until you notify NCB of a withdrawal of your consent; or
• Your consent given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.

Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent at any time. If you wish to withdraw consent or discuss the implications of such withdrawal, please contact us through one of the means described in the preface. In some circumstances, legal requirements may prevent you from withholding consent. Your decision to withhold consent may also limit the products and services that NCB is able to provide to you.

Location of Your Client Record

Your client record, whether electronic or paper, is kept at the offices of NCB in Kingston, Jamaica. Paper records forming part of your client record may also be kept in offsite storage. Your client record may be transferred to other locations for disaster recovery purposes.

Right to Access and Correct Your Personal Information

Except in limited circumstances described in the legislation, you are entitled to access, through a written request, the personal information contained in your client record. You may verify this personal information and request that any inaccurate information be corrected. For information on this process, please contact us at NCB Customer Care, at 1-888-622-3477.

Limits on How Long personal information is Kept

NCB will only retain your personal information as long as it is necessary, including updating the product or service or as required by law. When we destroy the information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.

Safeguards for your personal information

NCB maintains appropriate technical and organization safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. If you find that the proposed resolution to your privacy concerns is not adequate, you may avail yourself by contacting: