Privacy Policy

1. Who We Are

The data controller responsible for your personal information is:

2. Personal Data We Collect

We collect personal data only to the extent necessary for the purposes described in this Policy. The categories of personal data we may collect include:

2.1 Contact Form Submissions

When you complete a contact or enquiry form on our Website, we collect: full name; company or organisation name; email address; telephone number; country of residence; industry sector; type of enquiry; and the content of your message.

2.2 Newsletter and IR Alert Subscriptions

When you subscribe to our newsletter or investor relations email alerts, we collect your email address and, optionally, your name and professional affiliation.

2.3 Investor Relations Enquiries

For investor relations purposes, we may collect additional information including: professional accreditation and investment experience; employer or fund name; and regulatory status, where required to determine eligibility to receive certain documents.

2.4 Website Usage Data

We automatically collect certain technical data when you visit our Website, including: IP address; browser type and version; operating system; pages visited and time spent; referring URL; and device type. This data is collected through cookies and similar technologies as described in Section 9.

3. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To respond to enquiries, contact form submissions, and meeting requests;
• To send you investor relations updates, press releases, financial calendar notifications, and regulatory announcements (where you have subscribed);
• To assess eligibility for access to restricted investor documentation;
• To manage our investor relations and business development activities;
• To comply with legal, regulatory, and reporting obligations;
• To maintain and improve the functionality and security of our Website;
• To detect, prevent, and respond to fraud, abuse, or security incidents; and
• To protect our legal rights and enforce our terms and conditions.

4. Legal Basis for Processing

We process your personal data on the following legal grounds under the Jamaica Data Protection Act 2020:

• Consent: Where you have freely given, specific, informed, and unambiguous consent — for example, when subscribing to our newsletter;
• Contractual necessity: Where processing is necessary to carry out a contract with you or to take steps at your request before entering into a contract;
• Legitimate interests: Where we have a legitimate business interest in processing your data that is not overridden by your privacy rights — for example, responding to enquiries and managing investor relations; and
• Legal obligation: Where processing is required to comply with a legal or regulatory requirement to which we are subject.

5. Sharing of Personal Data

We do not sell, rent, or trade your personal data to any third party for marketing or commercial purposes.

We may share personal data in the following limited circumstances:

• Service providers: Trusted third-party service providers who assist us in operating the Website and conducting our business (such as email delivery, website hosting, and analytics providers), under strict data processing agreements;
• Professional advisors: Legal counsel, auditors, and financial advisors where disclosure is necessary to obtain professional advice;
• Regulatory authorities: The Financial Services Commission of Jamaica, the Jamaica Stock Exchange, or any other competent regulatory body where we are required to disclose information by law; and
• Corporate transactions: In the event of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred as part of that transaction, subject to confidentiality protections.

6. International Data Transfers

Where personal data is transferred to third-party service providers located outside Jamaica, we ensure that appropriate safeguards are in place, including contractual protections, to ensure that your data receives a standard of protection consistent with the Jamaica Data Protection Act 2020.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Our standard retention periods are:

• Contact form enquiries: 3 years from date of receipt, unless the enquiry leads to an ongoing business relationship;
• Newsletter subscribers: Until you unsubscribe, after which we retain a record of the unsubscribe for suppression purposes;
• Investor relations records: 7 years from the end of the relevant engagement, in compliance with applicable financial record-keeping requirements; and
• Website analytics data: 26 months in aggregated and anonymised form.

8. Your Data Subject Rights

Under the Jamaica Data Protection Act 2020, you have the following rights in relation to your personal data:

• Right of access: You may request a copy of the personal data we hold about you;
• Right to rectification: You may request that we correct inaccurate or incomplete personal data;
• Right to erasure: You may request that we delete your personal data where there is no longer a lawful basis for us to retain it;
• Right to object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances; and
• Right to data portability: You may request a copy of certain personal data in a commonly used, machine-readable format.

To exercise any of the above rights, please contact our Privacy Officer at privacy@wilberforcegroupja.com. We will respond to all valid requests within 30 days. We may require you to verify your identity before processing your request.

9. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies to improve functionality, analyse usage, and provide a personalised experience. Cookies are small text files stored on your device by your browser.

We use the following types of cookies:

• Strictly necessary cookies: Required for the Website to function. Cannot be disabled.
• Analytics cookies: Used to understand how visitors interact with the Website (e.g., pages visited, time on site). Data is collected in aggregate and anonymised form.
• Functionality cookies: Remember your preferences to personalise your experience.

You may control cookie settings through your browser settings. Please note that disabling certain cookies may affect the functionality of the Website. Full details are provided in our Cookie Policy.

10. Security of Personal Data

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include: encrypted data transmission (TLS/SSL); access controls and authentication requirements; regular security assessments; and staff training on data protection obligations.

While we take all reasonable steps to protect your personal data, no method of internet transmission or electronic storage is 100% secure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority and affected individuals as required by law.

11. Third-Party Links

Our Website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their respective privacy policies before providing any personal data to them.

12. Children’s Privacy

Our Website and services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a minor, please contact us immediately at privacy@wilberforcegroupja.com.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory developments. We will post the updated Policy on this page with a revised “Last Updated” date. For material changes, we will notify subscribers by email. Your continued use of our Website after the effective date of any changes constitutes your acceptance of the updated Policy.

14. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our data practices, please contact our Privacy Officer:

You also have the right to lodge a complaint with the Office of the Information Commissioner of Jamaica if you believe your data protection rights have been infringed.