1.1.UNICOMER (TRINIDAD) LTD. (the “Company” or “We” or “Us”) collects information from the user accounts created by individuals on the platform for the EMMA App as well as other digital sources of information relating to such individuals (each a “User”) as set out herein. The Company uses the information to undertake, among other things, an assessment of each Users’ credit worthiness and determine an approved spend limit (together “Ready Finance Spend Limit”) which in turn may enable such User to (1) make payments to approved third party vendors who have partnered with the Company for use of such (“Approved Third Party Vendors”) and (2) submit applications to the Company for one or more credit facilities (each a “Credit Facility”).

1.2.The approval of the Ready Finance Spend Limit which facilitates payments to Approved Third Party Vendors and allows Credit Facility Applications, forms part of the services offered by the Company to Users (individually and collectively the “Services”).

1.3.The Company collects information from Users at the time of account creation as well as on an on-going basis and uses it to create unique profiles for Users to determine whether or not a particular individual should be offered the Service.

1.4. Please note that not all individuals whose information is collected by the Company will be offered the Services.

1.5.Each offer of Service made by the Company is based on the Company’s proprietary and discretionary decision making methodologies and also relies on the credit risk requirements determined by the Company from time to time.

1.6.The Company values your privacy and is committed to ensuring that you are aware of how your information is being used. The Company actively seeks to minimise unauthorised access to your information. The Company will take reasonable efforts to ensure that access to your information as stored in the Company’s databases is limited to that necessary for servicing your account in accordance with your requests from time to time.

1.7.The Company will collect, store and use your information only for the purposes of the providing the Services to you.

1.8.This Privacy Policy endeavours to inform you of the types of information that may be collected, and the manner in which such information is collected, used, processed, disclosed and maintained. This Privacy Policy must be read in conjunction with the terms of use and any other terms and conditions in relation to the Service that may be set out by the Company.

1.9.PLEASE READ AND UNDERSTAND THIS PRIVACY POLICY CAREFULLY. YOUR INSTALLATION OF THE EMMA APP AND/OR USE OR ACCESS OF THE SERVICES SHALL CONSTITUTE YOUR AGREEMENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND OUR PRACTICES AS DESCRIBED IN THIS PRIVACY POLICY, YOU ARE FREE TO NOT USE THE SERVICES. YOU WILL ALWAYS HAVE THE ABILITY TO OPT-IN AND OPT-OUT OF THE SERVICE BY SENDING US A REQUEST AT trinidademmasupport@unicomer.com HOWEVER, THE COMPANY WILL RETAIN CERTAIN OF YOUR INFORMATION TO THE EXTENT REQUIRED BY THE COMPANY FOR COMPLIANCE PURPOSES.

1.10.BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY CONSENT TO COMPANY’S COLLECTION, RETENTION, ANALYSIS, USE, PROCESSING AND DISCLOSURE OF YOUR PERSONAL INFORMATION AND SENSITIVE PERSONAL INFORMAITON IN ACCORDANCE WITH THIS PRIVACY POLICY.

2. Applicability of the Privacy Policy

2.1.This Privacy Policy shall apply to all personal information and sensitive personal information (as defined in the Data Protection Act of Trinidad and Tobago) the Company collects from you or about you from third party service providers.

3. Use of Your Information

3.1.The information that We collect from you will be used:

• 3.1.1.For determining whether or not you should be offered the Services;
• 3.1.2.For the provision of Services including the maintenance and continuous improvement of the Services, the refinement of the proprietary methodologies used to power the decision making central to the Services and for other analytical purposes;
• 3.1.3.To create a single profile on you, based on information received from the activity on your smart phone, your use of the Company’s EMMA App and your use of the Services, if made available to you;
• 3.1.4.The development and addition of new features to the Services, including data analysis, testing and other forms of data processing to help optimize the provision of Services;
• 3.1.5.To contact you and deliver information, administrative notices, targeted advertisements and any other communication relevant to your use of the Services.
• 3.1.6.By third parties who the Company contracts with to the extent required for the provision of Services to you.

3.2. If the Company determines that any information you have provided or uploaded violates the terms of this Privacy Policy or the terms of the EMMA App, the Company has the right, in its absolute discretion, to delete or destroy such information without incurring any liability to you. The Company will not publish, sell or rent your personal information or sensitive personal information to third parties for their marketing purposes without your explicit consent. The Company will use the information collected primarily for the purpose of providing the Service.

4. Disclosure of your information

4.1.The personal information and sensitive personal information you provide may be disclosed by the Company to its agents, employees, subsidiaries and affiliates, or to other third-party service providers of the Company who require the information for the purposes of operating and maintaining the Company’s platform for the provision of Services. Particularly, the Company will disclose the personal information and sensitive personal information to relevant third parties including credit bureaus to authenticate any information given by you to the extent necessary for processing and approving a Credit Facility Application submitted by you. You also consent to the Company authenticating employment information given by you using reasonable means necessary including but not limited to interviewing or meeting with references provided and meeting with employers where deemed necessary by the Company, to the extent necessary for processing and approving a Credit Facility Application submitted by you. Further you consent to the Company providing the personal information (to the extent so required) to applicable third parties for the written verification or authentication of proof of income.

4.2.The Company will comply with requests and directions of all governmental, law enforcement, or regulatory authorities, which it believes in good faith to be in accordance with any applicable law. Such compliance may include providing your personal information and sensitive personal information, to such agency or authority. By providing any information to the Company, you consent to the Company providing such information to any governmental, law enforcement or regulatory authorities who exercise jurisdiction over the Services provided and the Company.

4.3.The personal information and sensitive personal information you provide may be disclosed by the Company to bailiffs, debt collectors and any other persons providing like services as may be required by the Company from time to time.

5. Data Security

5.1.The information that you provide, subject to disclosure in accordance with the Company’s Privacy Policy, shall be maintained in a safe and secure manner. The Company’s databases and information are [stored on secure servers with appropriate firewalls]. We maintain reasonable physical, technical, and administrative security measures to protect and limit access to your personal information.

5.2.As a User of the Services, you also have the responsibility to ensure data security. You should use the Services offered in a responsible manner. Do not share your username or password with any person. You are solely responsible for all acts done under the username you are registered under.

5.3.Given the nature of internet transactions, the Company does not take any responsibility for the transmission of information over the internet including User information shared and collected. Any transmission of User information on the internet is done at your risk. The Company does not take any responsibility for you or any third party circumventing the privacy settings or security measures it has in place or those provided to you during the use of the Services.

5.4.While the Company will use all reasonable efforts to ensure that the User information and other information submitted by you is safe and secure, it offers no representation, warranties or other assurances that the security measures are adequate, safe, fool proof or impenetrable.

6. Accessing and Updating Your Information

6.1.You can change, alter of otherwise modify or update certain types of User information at any time if the information is factually incorrect or has changed by changing the information in your User account or by contacting us. For example, you can ask the Company to update your telephone number or email address.

6.2.You may also change and/or delete any of the information you have submitted. The Company reserves its rights to retain any information pertaining to your usage of the Services and information that you have shared with the Company as is necessary to ensure the proper and accurate functioning of the Services. You are not entitled to seek the deletion of the same to the extent that it would affect the ability of the Services to analyse and make recommendations on risk. Such information including your information collected from third-party services providers may be used by the Company to determine whether or not the Services offered may be availed by you.

6.3.The Company at its sole discretion may permit or deny the change of any information, if it is believed the same is required to observe applicable laws.

7. Age Restrictions

7.1.The Services provided by the Company are only intended for Users who are 18 years of age or older. If you are not of the requisite age you are not to provide any User information or other information to the Company. If it comes to the Company’s attention, that any User information or information shared pertains to an individual under the age of 18 years, such User information will be deleted without notice to you.

8. Amendments to the Privacy Policy

8.1.This Privacy Policy is subject to change at the Company’s sole discretion. Any changes to the Privacy Policy will be notified by updates to the App or the Company’s website.

9. Complaints

9.1.If you wish to place a complaint with regard to privacy requirements or laws, access any of your information that we hold or would like to correct any errors in your User information, please contact our EMMA Department at trinidademmasupport@unicomer.com so that we can consider and respond to your request.