COK Sodality Co-operative Credit Union Ltd (COKCCU) is committed to keeping and protecting the privacy and confidentiality of its member’s personal information. COKCCU has therefore
adopted this policy to comply with its obligation under current data protection and privacy legislation.
This information is being made available to you to outline how COKCCU protects the privacy of individual member’s personal information by outlining how we collect, hold, use or share your information.
COKCCU Privacy Agreement
This Privacy Agreement may be amended from time to time. In addition, it outlines the information practices of COKCCU. This Privacy Agreement is applicable to each member or customer that uses any of our financial products or services. This includes any guarantors(s) and is extended to members who take part in our contest, survey and event or has otherwise provided personal information to us.
In this Privacy Agreement:-
In this terms of agreement “we”, “our”, “us” and “COKCCU”, means COK Sodality Co-operative Credit Union Ltd, or any of its branches, satellite offices, subsidiaries and affiliates.
What is Personal Information?
“Personal Information” refers to information about a member, such as financial and account information, contact information, gender, age, income and employment information and identification details. This may include information that members or customers provided or collected by COKCCU from the use of its products and services, third parties, public sources, and includes information in any format, including digital format.
Dated June 24, 2019
Websites and Mobile Applications
Privacy issues, including security and confidentiality of personal information disclosed via this web site or any other electronic channels maintained by COKCCU, are viewed very seriously by us. Policies governing the protection of privacy are firmly adhered to and enforced to ensure the highest standards of protection of privacy and personal information.
Accessing of our services through any of our electronic channels including our website and our Mobile App where you visit different pages, read pages, download content onto your electronic device from these pages, or, in the case of our Mobile App, download the App to your device, the following information may be recorded:
- Which pages visited
- The address you are connecting from
- What content is downloaded
- The address of the web sites that you visited immediately before coming to our web site
- The amount of time you spend logged in to the particular electronic channel
- Details of the types and number of transactions completed
- Information about your computer or device
- Your operating system
- Internet connection or telephone account
- IP address, device locational dataCOKCCU may use this information to improve its electronic channels, address your specific needs, and provide you with a better member experience, for marketing purposes and for general operation of our business. The information may also be used to provide records of communication between COKCCU and you, and to comply with any legal and/or regulatory requirements.
COKCCU may also use this information to find out how many people use our electronic channels and to provide insight as to areas that are most frequently used.
Collecting, Holding, Using and Disclosing Personal Information
COKCCU may collect, hold and use your personal information in your member record as well as disclose to the third parties for the following purposes:
- To confirm your identity;
- To understand your needs;
Dated June 24, 2019
- To determine suitability of our Services for you;
- To determine your eligibility for our Services
- To set up, manage and offer Services that meets your needs;
- To provide you with on-going services:
- To provide you with various options for applying for and accessing Services;
- To meet our legal and regulatory requirements
- To help us collect a debt or enforce an obligation owed to us by you;
- To release your information to the purchaser in the event that we sell your assets to recoveran outstanding loan balance;
- To respond to request by another bank, financial institution, or credit bureau that has to beadhered to.
- To facilitate an investigation of or prosecution for fraud, money laundering or offencesassociated with money laundering, terrorism or terrorist financing in accordance with the
- To respond to a local or foreign court order or other lawful demand or request that webelieve to be valid, or to comply with the rules of production of a local or foreign court
- To manage and assess our risk;
- To verify information previously given by you with any other organization whennecessary;
If information relating to your health is collected for the purpose of providing an insurance service that is attached to any of our products, we use and disclose such information strictly for that purposes.
Sharing of Your Information with Third Parties
COKCCU does not provide directly all Services related to your relationship with us. In some instances we may use third party service providers who process or handles your personal information on our behalf.
When Personal Information is provided to third parties, COKCCU will take precautionary steps to protect the Personal Information they receive in line with our policies and practices, and that any such information will only be used for its identified purposes.
We may share some or all of the information we collect, as described above, with the following third parties (including our affiliates):
- Companies that perform services for us or on our behalf for one or more of our productsand services; and
- Companies that perform marketing services on our behalf
Dated June 24, 2019
The contractual arrangements between us and these third parties require them to keep the information we provide to them confidential and to use the information only for the purposes authorized by us.
Verification of Your Identity
You may agree that we collect, use and disclose your tax registration number, social security number or any other type of government-issued personal identification number where permitted by law. This may be for the purpose of fulfilling other regulatory requirements.
Verification of your identity allows us to separate your Personal Information from that of other members, especially those with a similar name, this also enhances the steps that we carry out to keep your Personal Information safe.
We may also verify your information with your employer, your references or other reliable independent sources based on your authorization that they provide such information to us.
Disclosure of Your Information
It should be noted that your information may also be disclosed to foreign taxation authorities such as the U.S. Internal Revenue Services or to any local taxation authority as outlined under U.S. Foreign Account Tax Compliance Act(‘FATCA”), or any other similar legislation that is covered under local laws.
Recording and Monitoring
We will monitor your accounts with us to ensure that they adhere to our legal and regulatory responsibilities.
We may, with notice and consent where applicable, monitor, record and retain any telephone call or electronic communication with you. This is done to ensure that an accurate record of the information provided by you is maintained, to ensure that your directives are followed properly, ensure member service levels are maintained, resolve complaints and for training purposes.
We will destroy records of calls and electronic communications after a period of time and when we deem it as no longer needed while at the same time safeguarding your Personal Information.
Location of Your Records
Your record, whether electronic or paper, is kept at the COKCCU offices. Paper records forming part of your member record may also be kept at our offsite storage facilities. Your member record may also be transferred to other offsite locations for disaster recovery purposes.
Dated June 24, 2019
Right to Access and Correct Your Personal Information
You are entitled to access your personal information subject to legal, regulatory and contractual requirements. You can do so by visiting any of our branch offices, by accessing your account online, or through our Customer Care Centre at 876-960-4226.
For personal information contained in your member record, a written request will be required. Your request will be facilitated once we have verified your identity and confirm the nature of your request.
Retention of Personal Information
You agree that COKCCU may keep and use your information in our records for as long as it is necessary or as required by law. When we destroy the information, we will use safeguards to prevent unauthorized access to your information during the process.
Safeguarding of Your Personal Information
The information that we collect is used strictly for the organization’s business purposes. Our employee’s access to your information is restricted and limited to facilitation of our business services.
COKCCU maintains suitable technical and organization safeguards to protect your personal information against loss, theft, modification and unauthorized access.
It is important that you are knowledgeable and that you give consent to COKCCU’s collection, use and disclosure of your personal information. The following actions undertaken by you is an indication to us of your consent to our personal information practices:
- You voluntarily providing in-person your personal information to COKCCU or through any of our electronic channels;
- Your written, verbal or electronic consent expressed consent or acknowledgement
- Your consent be sought by COKCCU for a stated purpose;
- Your consent is given through your authorized representative such as a legal guardian orholder of a power of attorney.
Dated June 24, 2019
Refusing or Withdrawing Consent
Subject to certain legal, regulatory or contractual restrictions you may withdraw your consent at any time giving us reasonable notice. 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 prevent us from providing you or continue to provide you with products and services that COKCCU offers.
Changes to this Privacy Agreement
You agree that we can modify, amend replace or change this Privacy Agreement at any time in light of changes in law, regulations, internal procedures and practices or respond to issues.
The revised Privacy Agreement will be placed on our public website and at our branch locations notifying you of the amendments to this Privacy Agreement.
Dated June 24, 2019