Republic Bank (Cayman) Limited Privacy Policy

PURPOSE

Your personal information is shared with us when you become a client and utilize our products and services. Personal information refers to any data that can be used to identify a person. This includes your name, address, date of birth, account number, IP address or information about payments you’ve made from your bank account. We also use publicly available data or data provided by third parties that are legitimately obtained. Republic Bank (Cayman) Limited (“RBKY” or the “Bank”) is dedicated to protecting the confidentiality and privacy of information entrusted to it.

The Bank’s activities relating to the collection, utilization, sharing and retention of data, are governed by the Data Protection Law (“DPL”) which takes effect on September 30th, 2019. The Bank’s obligation under the DPL includes (but are not limited to) making disclosures on the collection of data, the purpose of collection, details behind the processing of data, details of transfers of data and any security and technical safeguards in place.

In accordance with the DPL, the Bank is considered a “Data Controller” as it determines the purposes, conditions, and way any personal data are or are to be, processed. By processing, we mean everything we can do with this data such as collecting, recording, storing, adjusting, organizing, using, disclosing, transferring or deleting as permitted by law.

THE BANK

The Bank was incorporated as an exempted company in the Cayman Islands on 13 January 1992 and holds a Trust licence and an Unrestricted Class B Banking licence under the Banks and Trust Companies Law (2013 Revision). The Bank commenced operations in June 1992 and its principal activity is the provision of offshore banking facilities.

The Bank’s registered office is located at Citrus Grove, 106 Goring Avenue, George Town, Grand Cayman. The Bank is a wholly-owned subsidiary of Republic Bank Trinidad & Tobago (Barbados) Limited which is a wholly-owned subsidiary of Republic Financial Holdings Limited (“RFHL”).

SENSITIVE PERSONAL DATA

We may hold information about you which includes sensitive or special categories of personal data, such as but not limited to your health or criminal conviction information. This data will be held only for the product or services that are being provided or where we are processing the data for a substantial public interest or legal obligation.

CHANGES TO OUR PRIVACY POLICY

RBKY keeps its privacy policy under regular review and places any updates on this webpage (or on onboarding documents). This policy was last updated on 30 September 2019.

WHAT DATA DO WE COLLECT?

The Bank collects the following data:

  • Contact Information (name, address, and proof of address and other contact details such as email addresses and telephone numbers);
  • Personal identification information (title, gender, date of birth, copies of forms of identification, tax identification number {TIN}, ultimate beneficial ownership information, and company directorship);
  • Emails and records of communications with you;
  • Financial information (account balances, investment holdings, sources of wealth, employer details);
  • Professional details and employment details;
  • Investment goals and risk appetite;
  • Identification information of your family members, proxyholders and inheritors;
  • Some special information, such as any criminal history, may be collected for certain limited purposes.

HOW DO WE COLLECT YOUR DATA?

You directly provide the Bank with most of the data we collect. We collect and process data when you:

  • Complete onboarding documents;
  • Use or view our website;
  • Provide information verbally to any of our employers;
  • Visit our Trinidad Representative Office.

The Bank may also receive your data indirectly from the following sources:

  • Conducting internet searches (LinkedIn, Dow Jones, etc.)
  • Utilizing legitimate third-party data providers.

WHY WE NEED YOUR DATA AND HOW WILL IT BE USED?

RBKY processes personal data on the basis that it is necessary to fulfil our contractual relationship with you and/or where we have a legal obligation to do so, as a regulated financial institution. The Bank may also process personal data when we have a legitimate interest to do so and providing that it does not infringe on your rights. Examples of how your data can be used are as follows:

  • To provide you with banking, trust and other financial services;
  • Comply with international tax reporting obligations;
  • To advise you of any important information that may impact our service to you;
  • Managing investment product services;
  • Managing complaints;
  • To exercise contractual rights;
  • To develop and market new products and services;
  • To comply with internal, external and regulatory audit requirements;
  • To ensure our businesses are operating efficiently and lawfully.

HOW DO WE STORE YOUR DATA?

Legal entities comprising the RFHL group are integrated into a group structure, and several essential functions are provided at the Group level to some or all of our businesses. Accordingly, your personal information may be shared with entities within the RFHL group that are located in jurisdictions other than where you have your banking and financial services relationships with us (your “home jurisdiction”). For customers in Europe, note that this may be outside the European Economic Area.

In order to comply with Cayman Islands Anti-Money Laundering, Terrorist Financing, Proliferation Financing and Targeted Financial Sanctions requirements, the Bank will keep your personal and financial data for as long as is necessary for the processing purpose(s) for which the personal data was collected, and any other permissible, related purpose including satisfying legal or accounting requirements.

DO WE SHARE YOUR PERSONAL DATA?

RBKY may engage various data processors for the processing of your personal data on our behalf, including IT service providers, correspondent banks, marketing agencies, entities within the RFHL Group and other business service providers. The Bank may transfer your data both within and outside of the European Union. Where we engage data processors, we will ensure that transfers of personal data take place in accordance with data protection legislation and that there will be an appropriate level of protection.

DATA SECURITY

RBKY has implemented various systems and procedures to secure the processing of personal data. These safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the personal data, and include measures designed to protect personal data from unauthorized access. These include the encryption of communications, encryption of information during storage, firewalls, access controls, separation of duties, and similar security protocols. We restrict access to personal data to personnel and third parties that require access to such information for legitimate, relevant business purposes. All our staff members, contractors and third parties who will have access to personal data will be bound to confidentiality and we use access controls to limit access to individuals that require such access for the performance of their responsibilities and tasks.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

Our Bank would like to ensure you are fully aware of all your data protection rights. Under the Cayman Islands Data Protection Law 2017, every client is entitled to the following:

  • Right to be informed – via this privacy notice;
  • Right of access – you have the right to request the Bank for copies of your personal data;
  • Right to rectification – you have the right to request that the Bank correct any information you believe is inaccurate;
  • Right to stop processing – you have the right to request the Bank to stop processing your data, subject to any other legal or statutory considerations;
  • Right to stop direct marketing;
  • Rights in relation to automated decision making which may affect you-Where a decision is made solely by automated means (without human involvement), you have the right to require that it be reconsidered on a different basis;
  • Right to complain – you have the right to complain to the Ombudsman in the event you feel your rights have been infringed;
  • Right to seek compensation – you have the right to appeal to the Ombudsman for compensation in the event you feel the severity of the breach warrants such recourse.
HOW TO CONTACT US

If you have any questions about RBKY’s privacy policy, the data we hold on you or would like to exercise one of your data protection rights, please do not hesitate to contact us.

E – mail us at: ravi.mykoo@republiccayman.com
Call us at: 345-949-7844
Or write to us at: Republic Bank (Cayman) Limited 3rd Floor, Citrus Grove, 106 Goring Avenue P.O. Box 2004, George Town KY1-1104, Cayman Islands.
HOW TO CONTACT THE APPROPRIATE AUTHORITY

Should you wish to report a complaint or if you feel that the Bank has not addressed your concern in a satisfactory manner, you may contact the office of the Ombudsman.

Email: info@ombudsman.ky
Mail: PO Box 2252, Grand Cayman KY1-1107, CAYMAN ISLANDS
Visit: 3rd Floor, Anderson Square, 64 Shedden Road, George Town, Grand Cayman
Call: +1 345 946 6283
Go to top