CUTT Consumer Club Limited and our affiliates (“CUTT”, “we”, “our” or “us”) are committed to respecting your privacy and to complying with applicable data protection and privacy laws. This Privacy Policy is provided to help you understand how we may collect, use, disclose, protect and otherwise deal with your information, whether you are a person acting on your own behalf or on behalf of a business, entity or charitable organization. This Privacy Policy applies to information collected in connection with your access to and use of our Services.

You acknowledge that by providing your information to CUTT, you consent to the processing of your data in accordance with this Privacy Policy. You should read this policy in conjunction with the Consumer Terms of Use and Merchant Terms of Use associated with our services.

This Privacy Policy complies with the Trinidad and Tobago Data Protection Act, 2011, and covers all CUTT businesses and entities in all countries in which CUTT operates.

 

INFORMATION WE COLLECT ABOUT YOU

We use your data to make CUTT’s products and services work better for you and for others. This describes what data we collect about you (which can vary depending on your country of residence).

CUTT collects and uses your personal information with your knowledge and consent and typically when you:

• Use CUTT’s range of services that are offered, including our online, mobile and smart terminal services and products;
• Respond to communications from us (such as SMS, emails, questionnaires or surveys);
• Participate on CUTT’s social media pages such as Facebook and Instagram;
• Participate in CUTT’s promotional events, incentives or loyalty programs;
• Provide information through CUTT’s customer support centre, authorized agents or any other affiliates or business dealings with CUTT for which you have consented to provide your personal information.

Types of Information Collected

The types of information that CUTT may collect include, but are not limited to:

• contact information (such as name, mailing address, email address and telephone number)
• identification information (such as passport details, driver’s license details, national ID details)
• demographic information (such as age, gender)
• banking information (such as bank account number, name on bank account, name of bank, routing number)

Information We Collect From Other Sources

We also need to check that you are using our services legally, that you are eligible for the services you want to use, and we protect your data and our services from fraudsters who may put you and your money at risk. To do this, we may collect data about you from companies that help us verify your identity, do a credit check, prevent fraud or assess risk.

• Background check information, including credit report information, identity verification information, and information about any person or corporation with whom you have had, currently have, or may have a financial relationship;
• Credit, Compliance and Fraud. Information about you from third parties for any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

INFORMATION WE MAY COLLECT ABOUT YOUR CUSTOMERS

We also obtain information about your customers when they transact with you. We collect this data when they transact with you through your use of CUTT’s services, for instance when they make a payment to you or receive a request for payment from you. The particular customer data we collect will vary depending on how you use our services and which products and services you use. The customer data may include:

• Identification Information. Your customer’s name; email address; mailing address; phone number; government-issued identification.
• Transaction Information. When your customers use CUTT’s services to make payments to you, we collect information about when the transactions occur, a description of the transactions which may include item-level data, the payment or transfer amounts, and the payment methods used to complete the transactions.

HOW WE USE YOUR INFORMATION

We use your data to do things like make sure the products you are using work, help you log in to your account, verify who you are, secure your data, fight fraud, follow the law, enforce our agreements, figure out what new products we can build, and market products to you that we think could make it easier for you to run your business.

We may collect, use and share information about you for the following reasons:

Performing, Improving and Developing our Services

• Delivering the information and support you request, including technical notices and providing assistance for problems with our Services or your CUTT account;
• Determining whether the Services are available in your country;
• Developing new products and services;
• Displaying your transaction history;
• Processing payment transactions;
• Providing, maintaining and improving our Services;
• Doing internal research, measuring, tracking and analyzing trends and usage; and
• Otherwise providing you with the CUTT Services you use.

Communicating with You About our Services

• Sending you surveys and getting your feedback about our Services;
• Providing information about and promoting our Services to you; and
• Sending you information we think you may find useful or which you have requested from us about our Services.

WHEN AND WITH WHOM WE SHARE YOUR INFORMATION

We may share your information with others in the circumstances described in this section. For example, with other people with whom you interact when you use our services; within the CUTT group of companies; with service providers who help us run our services; with ad platforms that help us market and advertise our services to you; or if we need to share your information to comply with the law.

With other Users of our Services with Whom You Interact

• With other users of our Services with whom you interact through your own use of our Services. For example, we may share information with your customers when you make or accept a payment using our Services.

With our Affiliates and Group Companies

• With other companies in the CUTT group and business affiliates, for the reasons outlined above. For example, we may share your information internally to understand how you interact with CUTT to help make our Services better for you, and to help us build Services tailored to your preferences.

With our Service Providers

• With service providers who help us provide, maintain, and improve our Services (e.g. vendors who help us with fraud prevention, identity verification, and debt collection services), as well as financial institutions and other entities that help us provide the Services;
• With service providers that help us run our events, advertising campaigns, competitions, special offers or other activities.

Safety and Compliance with Law

• If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request; (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our Consumer Terms of Use, Merchant Terms of Use or other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Your Consent

• With your consent (e.g. at your direction or as described at the time you agree to share).

Aggregated and Anonymized Information

• We also may share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and anonymized information that does not specifically identify you or any individual user of our Services.

HOW LONG WE KEEP YOUR INFORMATION

We keep your information as long as you keep using our products and services. After that, we keep it for as long as we need it to do things like fight fraud, collect fees you owe, resolve disputes with (or involving) you, follow the law, enforce our agreements and defend our rights in court.

We keep your information for a minimum period of six (6) years to comply with prevailing law and guidelines. So even after you deactivate your account, we retain copies of information about you and any transactions or Services in which you may have participated for a minimum of six (6) years. This period of time allows us to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Consumer Terms of Use, Merchant Terms off Use or other applicable agreements or policies, or to take any other actions consistent with prevailing law.

 

SECURITY

We do a lot to keep your data safe. While we think we have strong defenses in place, no one can ever guarantee that hackers won’t be able to break into our sites or steal your data while it is stored or flowing from you to us or vice versa.

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. We also engage well-known technologies including but not limited to firewalls, intrusion detection, encryption, SSL (Secure Sockets Layer) and vulnerability assessments. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.

 

CHANGES TO THIS PRIVACY POLICY

We reserve the right to make changes to this privacy policy at any time and in response to changes in applicable data protection and privacy legislation. When the changes impact your rights or how we use your data in important ways, we’ll notify you by email (if we have your email address) and post the revised policy on our website.

We may amend this Privacy Policy from time to time by posting a revised version on our website. We will provide you thirty (30) days’ prior notice of material changes in how we use your information, including by email if you have provided one. If you disagree with these changes, you may cancel your CUTT account and/or discontinue use of our Services. If you keep using our Services, you consent to any amendment of this Privacy Policy.

 

CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us as follows –

Customer Experience

CUTT Consumer Club Limited

14-17 Park Street, Victoria Square, Port of Spain

Email: info@citizensuniontt.org 

Phone: (868) 486-2888

Updated: December 18, 2023