- ‘Personal Data’
- any data (whether stored in an electronic or printed form) relating to a
living individual who can be identified
- from the data; or
- from the data and other information in the possession of, or likely to come into
the possession of the Company; or
- any data (whether stored in an electronic or printed form) pertaining to the
financial record of a living individual.
- ‘Services’ mean
financial related services which include but are not limited to the
- Creation of an online account via a mobile application software or a web login;
- Provision of electronic consumption record services which include uploading,
storing, and accessing records electronically;
- The transmission of records electronically between authorized representatives;
- Generation of anonymous statistical reports.
‘Software’ means the
mobile application, website, platform or systems developed and maintained by POOJA for
the purposes of carrying out the Services;
Provider’ means any person i.e. individual or entity who has entered into an
agreement with POOJA to provide the Services; and
means any person i.e. individual or entity who POOJA has engaged to provide the
Types of Personal DATA
its own business purposes. We may collect the following types of Personal Data:
- Contact Information that allows us to communicate with you, such as your name, D.O.B.,
username, mailing address, telephone numbers, email address or other addresses that allow us
to send you messages.
- Relationship Information that helps us do business with you, such as the types of products
and services that may interest you.
- Transaction Information about how you interact with POOJA including inquiries, online
account information, and information about how you use the Software.
How POOJA collects Personal DATA
- In many cases, we collect Personal Data directly from you. We will ask you for Personal Data
(including Contact Information and Relationship Information) when you interact with us, such
as when you create an online account and enroll in the Program via the Software. We may
collect additional Relationship Information from third party data suppliers who enhance our
files and help us better understand our customers. We will also collect Transaction
Information when you interact with us, such as when you create an online account and enroll
in the Program via the Software.
How POOJA uses Personal Data
POOJA will use your Personal Data to:
- Create an online account for the purposes of enrolling you in the Program and facilitating
the use of the Services by you;
- Provide you with marketing communications and offers for additional products and services
- Administer surveys and other promotional events;
- Generate anonymous statistical reports; and
- Manage our everyday business needs, such as payment processing and financial account
management, product development, contract management, website administration, forum
management, fulfillment, analytics, security and fraud prevention, corporate governance,
reporting and legal compliance, and business continuity.
Why Personal Data is disclosed by Pooja
POOJA understands that you do not want us to provide your Personal Data to third parties for
their own marketing purposes. We will limit our sharing of your Personal Data as follows:-
- We may share your Personal Data with an affiliate or associated entity of POOJA, which may
only use your Personal Data for the purposes listed above.
We may also share your Personal Data with a Third-Party Service Provider or a Third-Party
Supplier, who will be bound by law or contract to protect your Personal Data and only use
your Personal Data in accordance with our instructions PROVIDED HOWEVER THAT in
circumstances where your Personal Data is transferred to a territory outside of Jamaica,
such territory may not provide for an adequate level of data protection as granted in
We may also disclose Personal Data where needed to enforce our rights, protect our property,
or protect the rights, property or safety of others, or as needed to support external
auditing, compliance and corporate governance functions. We will also always disclose
Personal Data when required to do so by law.
Please note that we may also use and disclose information about you that is not personally
identifiable. For example, to generate reports that contain aggregated and statistical data
about our clients. These reports do not contain any information that would enable the
recipient to contact, locate or identify you.
Cookies and Other Data Collection Technologies
- When you use our Software, we will collect certain Transaction Information by automated
means, using technologies such as cookies, pixel tags, browser analysis tools, server logs
and web beacons. For example, when you visit our website, we will place cookies on your
computer. Cookies are small text files that websites send to your computer or other
internet-connected device to uniquely identify your browser or to store information or
settings in your browser. Cookies allow us to recognize you when you return. They also help
us provide a customized experience and enable us to detect certain kinds of fraud. In many
cases, you can manage cookie preferences and opt-out of having cookies and other data
collection technologies used by adjusting the settings on your browser. All browsers are
different, so visit the “help” section of your browser to learn about cookie preferences and
other privacy settings that may be available.
We may collect many different types of information from cookies and other technologies. For
example, we may collect information from the device you use to access our website, your
operating system type, browser type, domain, and other system settings, as well as the
language your system uses and the country and time zone where your device is located. Our
server logs also record the IP address assigned to the device you use to connect to the
internet. An IP address is a unique number that devices use to identify and communicate with
each other on the internet. In many cases, the information we collect using cookies and
other tools is only used in a non-identifiable way, without any reference to Personal Data.
For example, we use information we collect about all website users to optimize our websites
and to understand website traffic patterns.
In some cases, we do associate the information we collect using cookies and other technology
with your Personal Data.
- POOJA has relationships with third party advertising companies to place advertisements on
this website and other websites, and to perform tracking and reporting functions for this
website and other websites. These third party advertising companies may place cookies on
your computer when you visit our website or other websites so they can display targeted
advertisements to you. These third party advertising companies do not collect Personal Data
in this process, and we do not give any Personal Information to them as part of this
information collected by these vendors. You can opt out of being targeted by many third
party advertising companies. [ ].
POOJA’s mobile application will allow you to access your online account, utilize the Services,
interact with us online and receive other information via your smartphone. All Personal Data
You can always limit the information you provide to POOJA. You can also limit the
communications, if any, that POOJA sends to you. To opt-out of commercial emails, if any, simply
click the link labeled “unsubscribe” at the bottom of any email we send you. Please note that
even if you opt-out of promotional emails, we may still need to contact you with important
Transactional Information about your online account. For example, even if you opt-out of emails,
we may still send you activity confirmations. If you have any questions about your choices or if
you need any assistance with opting-out, please contact us via email at [email@example.com]
or by telephone at [1-888-429-5765].
Access and Rectification
POOJA respects your right to access and rectify your Personal Data. You can log into your online
account at any time to access and update the information you have provided to us. Additionally,
POOJA complies will all local data protection laws or regulations regarding access and
rectification. If you need assistance updating your Personal Data, please contact us via email
at [firstname.lastname@example.org] or by telephone at [1-888-429-5765].
POOJA has implemented an information security program that contains administrative, technical and
physical controls that are designed to safeguard your Personal Data. For example, we use
industry standard encryption technology to secure sensitive Personal Data when it is being
collected and transmitted over the internet as well as firewalls, site monitoring and intrusion
detection software. Please note that you should also take steps to protect your Personal Data.
POOJA, however, does not make any representations or warrants that your Personal Data may not be
accessed, disclosed, altered, or destroyed by breach of such safeguards. POOJA will notify you
immediately in the event of a security breach and will maintain an incident response policy that
includes notifications consistent with applicable law.
Changes to this Privacy Statement
Additionally, if the changes will materially affect the way we use or disclose previously
collected Personal Data, we will notify you about the change by sending a notice to the primary
email address associated with your online account.
Retention Of Personal Data
POOJA will retain your Personal Data only for as long as we have a valid business purpose and in
accordance with applicable laws.
POOJA reserves the right at any time without notice to revise the content of the Software and the
Company’s website and by continuing to use our Software following any such change you hereby
agree to be bound by the revised terms and conditions.
How to Contact Us
Please contact us if you have any questions or comments about our privacy practices or this