MyCash Privacy Policy
Welcome to the MyCash Privacy Notice.
At Paymaster (Jamaica) Limited, we respect your privacy and we are committed to protecting your personal data and earning your trust. This Privacy Notice is to give you clarity and transparency on the ways we may use your personal data.
Our goal is for you to understand i) how we look after your personal data when you visit or interact with our website and application, and ii) your privacy rights and how the law protects you.
This Privacy Notice applies to all interactions with our web application and any related webpages (collectively “Website”), and Android and iOS applications, available only through Google Play and App Store, respectively (collectively “Application”).
1. Scope of This Notice and Who We Are
Who we are
We are Paymaster (Jamaica) Limited, a company registered under the laws of Jamaica, with registered office at 9 Molynes Road, Kingston 10, St. Andrew.
Paymaster (Jamaica) Limited (referred to as “Paymaster”, “we”, “us” or “our” in this privacy notice) is a multi-transaction agency – a subsidiary of Prism Services Holdings Limited, and a part of the Prism Group of Companies (Prism) and Digicel Group of Companies (Digicel).
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how Paymaster collects and processes your personal data through your use of our MyCash Website and Application. This includes any data you may provide through our Website or Application when you register, browse or utilise our services, take part in a promotion or competition, or get in contact with us.
Personal data is collected for all users of the Website and Application. We do not knowingly collect data from or about individuals under the legal minimum age without the permission of their parent or guardian. When we do collect that data, we might do it inadvertently, like if they attempt to sign up for a service or initiate a transaction. We might also collect it automatically if, through your permission or supervision, your child uses the products or services we offer. If you believe your child may have provided us with personal information without proper consent, you can contact us and request that we delete the information.
Different products and services collect different kinds of data. It is important that you read this Privacy Notice together with any other privacy, customer or regulatory notices we may provide for specific products and services, and on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices published by the Prism and Digicel Group of companies, and is not intended to override them.
Data Controller
Paymaster (Jamaica) Limited is the Data Controller of data collected solely for and through the use of the MyCash Application.
Contact details
We have a Privacy Team responsible for handling all enquiries in relation to the privacy practices of Paymaster. The Privacy Team is available to address queries about this Privacy Notice and Paymaster’s privacy practices, including any requests to exercise your legal rights; and may be contacted via e-mail at privacy@digicelgroup.com.
Depending on the market or territory within which you reside, you may have the right to make a complaint to your regulator of privacy rights or data protection issues. However, we would appreciate the chance to deal with your concerns before you approach your regulator, so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We endeavour to keep our Privacy Notice under annual review. This version was last updated on 29 November 2023
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our MyCash Website and Application may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy statements. Where necessary, we will provide a notice and link to the third party’s notice. When you leave our Website or Application, we encourage you to read the privacy notice of every other application and website you visit.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. Depending on the country or market within which you reside, this definition may extend to personally identifiable information for individuals who have been deceased for less than thirty (30) years.
Personal data shall not be extended to or include any data where identifiable information has been removed (anonymous data) or an individual’s identity is not ascertainable from the data set, whether on its own or combined with other known information.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
We may collect and process biometric data for the purposes of account management, or to verify your identity and validate payment, where applicable. Save for this, we do not intentionally seek to collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a subscription, product or service you have with us but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer for use of the services offered through our Website and Application | (a) Identity
(b)Contact |
(a) Performance of a contract with you (b) Consent |
| To process and deliver services, including: (a) To verify your identity and validate your account or profile (b) To process and effect transfers, bill payments, mobile top up and other remittances (c) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Profile/Account (d) Financial (e) Transaction (f) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (c) Consent |
| To manage our relationship with you which will include:
(a) Notifying you about changes to our services, terms, or privacy notice (b) Asking you to leave a review or take a survey |
(a) Identity
(b) Contact (c) Profile/Account (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you
(b) Necessary to comply with a legal (c) Necessary for our legitimate interests |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity
(b) Contact (c) Profile/Account (d) Usage (e) Marketing and Communications |
a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Consent |
| To administer and protect our business including our services , Website and Application (such as troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation(c) Consent |
| To deliver relevant website and application content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity
(b) Contact (c) Profile/Account (d) Usage (e) Marketing and Communications (f) Technical |
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)(b) Consent |
| To use data analytics to improve our Website and Application, products/services, marketing, customer relationships and experiences |
(a) Technical
(b) Usage (c) Aggregated Data |
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website and Application updated and relevant, to develop our business and to inform our marketing strategy)(b) Consent |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity
(b) Contact (c) Technical (d) Profile/Account (e) Usage (f) Marketing and Communications |
(a) Necessary for our legitimate interests (to develop our products/services and grow our business)(b) Consent |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers from Us
We may use data we gather to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving direct marketing communications.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting Out
You can ask us to stop sending you marketing messages at any time by following the opt-out links or directions on any marketing message sent to you, or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Cookies
Cookies are small text files placed on your computer, tablet or smartphone, by websites you visit, generally used to make websites function efficiently.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly.
In the event you access any Prism or Digicel related websites, cookies may be enabled under the guidance of a cookie notice specific to that website. We advise you to read the cookie notice of our respective website for more details.
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. 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, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures Of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the above.
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.
6. International Transfers
We share your personal data within entities throughout the Prism and Digicel Group of Companies.
Whenever we transfer your personal data out of the country of origin, however, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Please be aware that although we endeavour to provide reasonable security for the information we process and maintain, no security system can prevent all potential security breaches. In any event, we will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Account Deletion & Data Retention
How Long Will You Use My Personal Data For?
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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Where you have decided to withdraw the consent you have given, we will delete your personal data unless we are required to keep it for the reasons explained herein. We may need to keep a piece of your contact information e.g. e-mail address, in our records, so we know that you have withdrawn your consent and therefore ensure we honour your choice.
Details of retention periods for different aspects of your personal data are available in our retention schedule which you can request from us by contacting us at privacy@digicelgroup.com.
9. Your Legal Rights
In some countries and under certain circumstances, you have rights in relation to your personal data. You may have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to enquire about the exercise any of the rights set out above, please contact the Privacy Team at privacy@digicelgroup.com.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within sixty (60) days. Occasionally it could take us longer than sixty (60) days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the Digicel Group may act as joint controllers or processors, and may provide IT and system administration services, and/or process personal data through leadership reporting. The list includes:
| Data Controllers/ Digicel Affiliates | Territory |
| Wireless Ventures (Anguilla) Ltd. | Anguilla |
| Caribbean Cable Communications (Anguilla) Ltd. | Anguilla |
| Antigua Wireless Ventures Limited | Antigua & Barbuda |
| New Millennium Telecom Services N.V T/A Digicel Aruba | Aruba, Netherland Antilles |
| Digicel (Barbados) Limited | Barbados |
| Digicel Caribbean Limited | Barbados |
| The Bermuda Telephone Company Ltd. | Bermuda |
| Telecommunications (Bermuda and West Indies) Ltd. | Bermuda |
| Digicel Suriname N.V. | Suriname |
| Antilliano Por N.V. T/A Digicel Bonaire | Bonaire |
| Digicel (BVI) Limited | British Virgin Islands |
| Digicel SVG Limited | St. Vincent & The Grenadines |
| Digicel Panama S.A | Panama |
| Digicel (Cayman) Limited | Cayman Islands |
| Digicel (Trinidad & Tobago) Limited | Trinidad & Tobago |
| Curacao Telecom N.V. T/A Digicel Curaçao | Curaçao |
| Digicel Bonaire Antilliano Por N.V. | Curaçao |
| Santa Barbara Utilities N.V. T/A Tres Networks | Curaçao |
| Wireless Ventures (Dominica) Limited | Dominica |
| Digicel S.A. de C.V. | El Salvador |
| Digicel (Grenada) Limited | Grenada |
| U-Mobile Cellular Inc | Guyana |
| Unigestion Holding S.A | Haïti |
| Digicel (Jamaica) Limited | Jamaica |
| Paymaster (Jamaica) Limited | Jamaica |
| Caribbean Cable Communications (Montserrat) Limited | Montserrat |
| Digicel (St Lucia) Limited | St. Lucia |
| Prism Services Holdings Limited | |
| Digicel Antilles Françaises Guyane | |
| Idom Technologies SAS (c/o Digicel Antilles Françaises Guyane) | Martinique |
| Digicel French Caribbean | Martinique |
| Southern Caribbean Fiber | Martinique |
| Digicel Investments France | Guadeloupe |
| Digicel St. Kitts Wireless Ventures (St. Kitts & Nevis ) Limited T/A Digicel St. Kitts & Nevis |
Guadeloupe |
| Digicel Turks and Caicos Ltd | St. Kitts & Nevis |
| Caicos Television Holdings Ltd | Turks and Caicos Islands |
External Third Parties
Specific Third Parties
| Third Party | Services |
| Amazon Web Services, Inc.(AWS) | Data storage provider (Cloud) |
| Ezetop Unlimited Company t/a Ding | Payment and Financial services |
| TPS Payment Platform | Payment and Financial services |
| Systems Limited | Developers/ Software solutions |
| Huawei Technologies Co., Ltd. | Developers/ Software solutions |
| Constelle Business Solutions | Developers/ Software solutions |
| AKSA (c/o Constelle Business Solutions) | Developers/ Software solutions |
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