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Privacy Statement

Last Updated: August 08 , 2022

1. Our Commitment to You

Metalloid Capital Management Limited (“Company”, “us” or “we”) is committed to protecting the privacy and security of our client’s personal information, as well as providing users with the highest level of transparency and control over their data. For us to provide you with our services we are required to collect and process certain personal information about you and your activity.
By entrusting us with your personal information, we would like to assure you of our commitment to keeping such information private. We have taken measurable steps to protect the confidentiality, security, and integrity of this Information. We operate with the following privacy principles:
  1. We will always use your data lawfully. We will never sell, rent, make public, or distribute your personal information, except where consent has been granted or we are legally required to do so.
  2. We will never spam you with irrelevant emails
  3. You may opt-out or in of our email communications at any time
  4. You have the right to remove any information we may hold on you
  5. Data is a liability and therefore we only collect and process when it is necessary.
This policy describes how we collect, hold, use and whenever necessary, disclose your personal information. It also summarizes your right to have access to correct the information as necessary. If you have any questions about our privacy policy or your personal information, please contact us at dataprotection@metalloidcm.com

2. The purpose of data collection

Processing of your Personal Information (meaning any information which may potentially allow your identification with reasonable means) is necessary for the performance of our contractual obligations towards you and providing you with our services and the operation of our website (hereinafter the “Services” and ” Website”), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.

By using our service or website, you consent to the terms and conditions of this Privacy Policy including the collection, storage, use, disclosure and other uses of your personal information that you submit or that is processed or collected through or in connection with your use of the Services or Website, in the manner and for the purposes as described in this Privacy Policy.

Importantly, you are not legally required to provide us with your Personal Information. If you choose to withhold any Personal Information required in respect of the use of the Services or Website, it may not be possible for you to use the Services or Website. If you do not agree to the terms and conditions outlined in this Privacy Policy, please do not access and/or use the Services or Website.
If you have any questions about this Privacy Policy, please feel free to contact us via email at dataprotection@metalloidcm.com or telephone at +1 (876) 837 4251. .

3. Methods for collecting data

We receive and collect your Personal Information from various sources:
  1. Registration data – When you voluntarily provide us with your personal information Services (for example, your name and email address) to create an account or apply for a loan on the website;
  2. When you communicate with us – For example when you send us an email, we collect the Personal Information you provided us with and retain those communications to process your inquiries, respond to your requests and improve our Website and Services.
  3. Technical data – When operating our Services, we use various technological tracking tools to collect data regarding your use of the Services and Website. Along with our partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage, which are used to store content data and preferences to manage and maintain the Services and record your use of the Services. You can learn more about the tracking tools we use as well as how to enable tracking tools by reading the Tracking Technologies section below.
  4. Third-party data – We also collect information about you from third-party sources such as suppliers that help us prevent money laundering and fraud; marketing agencies; identity verification services; and analytics providers. The categories of information that we collect about you from other sources are:- where permissible under applicable law, personal details (e.g., name, date of birth); – contact details (e.g., phone number, email address, postal address or mobile number); – employment information
  5. Live Chat – Our website uses WhatsApp, a chat platform that connects users to our customer support. We collect names, email addresses and IP Address for users who start a chat. The messages and data exchanged are stored within the WhatsApp application. For more information, please refer to their Privacy Policy.

4. Types of Data we collect

Personal Information

In the course of using the Service, we may ask you to provide us with certain Personal Information to provide and improve the Service, to contact or identify you, to enable you to access certain parts of the Website, and as otherwise indicated in this Policy. We collect the following Personal Information about you:
  • Registration data such as your name, address, your email address, your age.
  • Device information – when using our Services our webserver will collect your IP address and Unique Identity Number (UID).
  • Information from third parties – to provide our Service, we may receive Personal Information from our business partners. This may include Personal Information such as your contact details (name, phone, email) as well as details relating to your company, your job, your activities and publications.
  • Data provided voluntarily by user – to improve our services and develop additional tools and services you may provide us additional information such as income, profession, investment risk tolerance, investment horizon preference, etc.

Non-Personal Information

We also collect data about the use of our Service and the characteristics and activities of users, to operate it and improve it. We may collect the following non- Personal Information:
  • Technical data – this category includes data such as website visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), cookie data and your general location (city and country).
  • Data from third parties – this category includes data we receive from our business partners. This may include pseudonymous advertiser identifiers that some Advertisers or other third-party ad platforms choose to share with us. This data is also used to enhance data points about a particular unique browser or device.
Please note that if we combine Personal Information with Non-Personal Information, the combined data will be treated as Personal Information. Furthermore, Personal Information will only be stored and processed if you voluntarily provide it to us, e.g. through a loan application form, contact form, or complaint form.

5. Tracking Technologies

When you visit or access our Services we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect data about you, your device and your online behavior, to enhance your navigation in our Services, improve our Websites performance, perform analytics and customize your experience on it. In addition, we may merge data we have with data collected through these tracking technologies with data we may obtain from other sources and, as a result, such data may become Personal Information.
We also use a tool called Google Analytics to collect data about your use of the Services. Google Analytics collects data such as how often Users access the Services, what pages they visit when they do so, etc. We use the data we get from Google Analytics only to improve our Services. Google Analytics collects the IP address assigned to you on the date you visit, rather than your name or other identifying data. We do not combine the data collected through the use of Google Analytics with personally identifiable data. Google’s ability to use and share data collected by Google Analytics about your visits to our Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

6. Managing your cookie settings and opting out of 3rd party cookies

There are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.
  • Turning off cookies via your web browser – Most web browsers will provide you with some general data about cookies, enable you to see what cookies are stored on your device, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third-party cookies separately. Please note that the settings offered by a browser or device often only apply to that particular browser or device.
  • Data about cookies is usually found in the “Help” section of the web browser. Below are some links to some commonly used web browsers:

7. How do we use the data we collect?

Provision of service – for the provision and improvement of our Services, including for support and responding to your queries.
Service announcements – we will use your Personal Information to communicate with you and to keep you informed of the latest updates to our Services and offer you service offers.
Marketing and advertising purposes – We may use your Personal Information in the following ways: we may send you promotional material concerning our Services, or our partners’ services, which we believe might interest you; we may also display certain adverts on our site, which we believe will be relevant for you. Furthermore, by subscribing to our newsletter you will receive tips and announcements straight to your email account. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, building an automated profile based on your Personal Information. You may however choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the unsubscribe link in the emails that you receive from us. Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates and notifications or reply to your queries and feedback you provide us. You may also object to the use of your Personal Information for advertising purposes by disabling your cookies, as described in the tracking technologies section above.

Opt-out of receiving marketing materials – If you do not want us to use or share your Personal Information for marketing purposes, you may opt-out in accordance with this “Opt-out” section. Please note that even if you opt-out, we may still use and share your Personal Information with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Information are authorized to use your Personal Information only as necessary to provide these nonmarketing services.

Analytics, surveys and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all to improve our Services and think of new and exciting features for our users.
Protecting our interests – we may use your Personal Information when we believe it is necessary to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our services and protect the rights and property of Metalloid Capital Management Limited, its users and/or partners. Enforcing of policies – we may use your Personal Information to enforce our policies, including but limited to our Terms.
Compliance with legal and regulatory requirements – we may use your Personal Information to investigate violations, and as required by law, regulation, or other governmental authority, or to comply with a subpoena or similar legal process.
Analytical tools and services – we may use anonymized data such as holdings in portfolios to extract, aggregated, non-identifiable, high-level statistics (such as average sector distribution, popular stocks, etc.) to provide the Service and share with third parties. We may use unidentifiable Personal Information provided voluntarily by the user (such as age, profession, country of residence, income, etc.) to provide the Service and redistribute to third parties. For the avoidance of doubt, any information shared with third parties will be completely anonymized and non-identifiable.

8. With whom do we share your Personal Information

Internal concerned parties – we share your data with companies in our group, as well as our employees, to provide you with our services.
Business partners – we share your data with business partners, such as storage and analytics providers who help us provide you with our service. These third parties may have access to your Personal Information so that they may perform these tasks on our behalf, but they are obligated to comply with this Privacy Policy and may not use your Personal Information for any other purpose.
Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to the government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
Merger and acquisitions we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Privacy Policy.

9. How we protect your data

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. Your data is stored on secure servers and isn’t publicly available. We limit access to your data only to those employees or partners on a need-to-know basis, to enable the carrying out of the agreement between us.

While we seek to protect your data to ensure that it is kept confidential, users have a role to play in this process. You must assist with preventing unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting data over the internet. While we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your Personal Information or other content you transmit using the service, and you do so at your own risk.

10. Retention

We will retain your Personal Information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of data that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused data at the earliest reasonable time. Under applicable regulations, we will keep records containing client Personal Information, trading data, account opening documents, communications and anything else as required by applicable laws and regulations.

11. Security

We have put in place certain safeguards to help prevent unauthorized access and maintain data security relating to your Personal Information. Despite these protections, however, we cannot guarantee that your data will be 100% secure. You should take measures to protect your Personal Information.
Your online access to your Personal Information may be protected with a password you select. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, or email messages). You have an obligation to keep your user ID, password and personal information secure. As part of maintaining this obligation we recommend you do the following:
  1. Keep your user ID and password confidential;
  2. Utilize a unique password and change it frequently;
  3. Make sure others are not watching you enter your user ID and/or password on your keyboard when using protected elements of the Services.
  4. Do not leave your computer unattended while logged onto protected elements of the Services. After you finished accessing your information, exit the protected area.

12. Consent to Processing

By providing any Personal Information to us pursuant to this Privacy Policy, all users of the Website and/or Services, including, without limitation, users in the United States, Israel and member states of the European Union, fully understand and unambiguously consent to this Privacy Policy and the collection, usage, and/or processing of such Personal Information abroad. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of your Personal Information to various countries around the world that may have different levels of privacy protection than your country and may be transferred outside of the European Economic Area (EEA). By submitting your Personal Information through the Website and/or Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your Personal Information as described in this Privacy Policy.

13. Links

Links to other services, sites and applications are provided by us as a convenience to our users. We are not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This Privacy Policy applies solely to Personal Information collected and processed by us.

14. Our Policy toward Children

We understand the importance of protecting children’s privacy, especially in an online environment. The Site and Services are not designed for or directed at children under the age of 18 years old (Minors). We do not knowingly collect Personal Information from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us using the details provided above.

15. Relevant Privacy Legislation

This website was designed to comply with the Data Protection Act 2020 enacted in Jamaica and the regulations that were spawned from it.

16. How to contact us

If you wish to exercise any of the aforementioned rights, have any questions, or receive more information, please contact us via email at dataprotection@metalloidcm.com.
You can also request the removal of your personal information by completing our Request for Removal of Personal Information form.

17. Updates to this Policy

This Privacy Policy is subject to changes from time to time, at our sole discretion. The most current version will always be posted on our website (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services, any revisions become effective and you agree to be bound by the updated Privacy Policy.

1.0 INTRODUCTION AND PURPOSE

Metalloid Capital Management Limited (MCML) is committed to providing a quality customer experience for all our clients through the channels through which we serve them. MCML acknowledges the rights of a client to make a complaint regarding the Company’s operations, including our processes and the conduct of our staff and third-party vendors. Consequently, we endeavour to address all concerns or complaints through a responsive and fair process.
The purpose of the Complaint Resolution Policy is to guide the handling of customer complaints and then to achieve resolution in an efficient, effective and professional manner.

2.0 DEFINITIONS

Complaint an expression of concern or dissatisfaction regarding the Company’s product offerings, operations, staff, or third-party vendors. This dissatisfaction may be expressed orally or in writing and can be made electronically or physically.

Complainant

The party making the complaint, which could be a person or organization.

Client

The person or entity that engages in a business relationship with the Company. The duration of the relationship is irrelevant and will relate to all parties including prospects and clients.

Complaint Log

Electronic or paper records of all incoming complaints, including information about the complainant, and the steps that have been taken to resolve the matter. This log should be maintained chronologically.

3.0 HANDLING A COMPLAINT

This section describes the methodology that will be used to manage complaints

3.1 How to make a complaint

Complaints can be made orally, to any staff of Metalloid Capital, occupying a position of Supervisor or higher. However, clients are encouraged to make complaints in writing, including letters, emails or via our website at www.metalloidcm.com/file-a-complaint. Formal correspondences should be addressed to:
Chief Executive Officer
Metalloid Capital Management Limited
Unit 3, 17 Holborn Road
Kingston 10
Email should be sent to : Complaint@metalloidcm.com
All complaints, regardless of the medium of receipt, will be digitized and handled electronically by the Company.

3.2 Information required

The only mandatory requirement to file a complaint is a description of the matter. In these instances where the complainant is anonymous, the Company will investigate to identify or confirm the issue, then resolve, if necessary, through enforcing of code of conduct policy or through changes to our processes or services.
Clients are encouraged to include contact information, including, name, email, and telephone number; which will be used to communicate updates on the complaint. We also encourage clients to include supporting documents, if appropriate, to provide more context to the issue being described.

3.3 Acknowledgement and Updates

Upon receipt of a complaint, containing contact information for the complainant, the Company will respond electronically, to acknowledge receipt of the complaint within five (5) business days. We are committed to reviewing and resolving all complaints expeditiously; however, should a complaint remain unresolved for a time greater than thirty (30) days, the Company will provide an update on its progress, via email.
A complainant also has the right to follow up, at any time, on complaints, by replying to the acknowledgement email receipt.

3.4 Complaint Log

The Complaint Log will be reviewed regularly to ensure expeditious closure of all complaints. Additionally, the Log will be used to identify areas for improvement in the Company’s operations.

4.0 ESCALATION

If a client remains dissatisfied with the Company, regarding how a complaint was handled or about the outcome of an investigation, the client is encouraged to exercise your right to escalate the matter to the Consumers Affairs Commission, by visiting the website (www.cac.gov.jm) and navigating to File a Complaint.

5.0 AMENDMENTS AND DOCUMENT CONTROL

5.1 Amendments

The Complaint Resolution Policy shall be reviewed at least biennially, by Management. This Policy shall also be updated within sixty (60) days after any new or amended laws and/or regulations, or any internal changes which necessitate amendments.

5.2 Document Control

Version Date Approved Sections Changed
1.0 August 08, 2022 Policy was created