1. Who we are
Monaire Financial Services Limited is a microcredit institution authorized by the Bank of Jamaica. [Confirm legal entity name, company number and registered office with the DPO.] For the purposes of the Data Protection Act, 2020 we are the data controller for the personal data you give us through this portal.
Our Data Protection Officer can be reached at [dpo@monairefinancial.com] or at the address above.
2. What we collect
Identity and contact details; the information you enter on an application (product, amount, tenure, employment, income, expenses and existing obligations); identity, address, income and, for students, enrolment documents you upload; your repayment history with us; and the technical details of how you use the portal.
3. Why we use it and our lawful basis
To assess and decide your application, to enter into and manage a loan agreement with you, to meet our obligations under the Bank of Jamaica's microcredit framework, the Proceeds of Crime Act and the Credit Reporting Act, and to protect against fraud. [DPO to set out each purpose against its lawful basis.]
Underwriting is assisted by an automated scoring model; a Monaire loan officer reviews and makes every decision. [DPO to confirm the wording on automated processing and the right to human review.]
4. Credit bureau and screening checks
With your written consent, given on the application form, we obtain a credit report from a credit bureau licensed under the Credit Reporting Act, 2010. We also screen every applicant against sanctions and politically exposed persons lists as required of us. [Name the bureau(s) used and the screening provider once contracted.]
6. How long we keep it
[Retention periods per record type, set against the Proceeds of Crime Act and Bank of Jamaica requirements. Records of a withdrawn or declined application are retained for the period the law requires even after withdrawal.]
7. Your rights
Under the Data Protection Act, 2020 you may ask for access to your personal data, correction of inaccurate data, erasure where we no longer have a lawful reason to keep it, restriction of processing, and portability of data you provided to us; you may object to processing based on our legitimate interests; and you may withdraw consent at any time, which does not affect processing before withdrawal. [DPO to set out the procedure and the response time.]
8. Security
Documents and application data are stored encrypted, access is limited by role to the Monaire staff who need it, and every access to a customer record is logged. [DPO and IT to confirm the statement against the deployed controls.]
9. Contact and complaints
Contact the Data Protection Officer first. If you are not satisfied with our response you may complain to the Office of the Information Commissioner, Jamaica. [Confirm registration with the OIC and insert its contact details.]