Last updated August 2025

1. Introduction

At Signature Creed & Associates (“SCA”), we are committed to protecting the information we hold about you. This Privacy Notice applies to person’s information held by SCA as data controllers. This privacy notice describes what information we collect about you, how we may use that information, who we share it with, the circumstances under which it is shared and most importantly, your rights relating to that information. It further details what steps we will take to ensure that at all times, your information is kept private and secure. This notice continues to apply even after your agreement for our services ends.

Wherever we say ‘you’ or ‘your’, this means: -

• You;

• Our clients and their representatives (e.g., directors, officers, shareholders, trustees, or attorneys);

• Website visitors, vendors, suppliers, and professional contacts; or

• Employees and job applicants

When we say “we”, we mean Signature Creed & Associates which act as data controllers for your personal data.

2. What information we collect

At SCA we only collect personal information necessary to provide our services, manage our business relationships, and comply with legal obligations. The information may come directly from you, from our website, from public sources, or from third parties acting on your behalf

That information will include the following: -

(a) Client Engagements

i. Identification and contact information (e.g., name, email, phone number, address).

ii. Financial information (e.g., financial statements, payroll records, tax filings, valuation data, compliance records).

iii. Contracts, transaction details, and related business information.

iv. Sensitive information where required for audits, advisory work, or compliance (e.g., tax compliance, AML/KYC).

(b) Recruitment & Employment

i. CVs, references, qualifications, and professional background.

ii. Background check results, conflict checks, and suitability assessments.

iii. Employee HR data (e.g., payroll, benefits, performance evaluations, compliance).

(c) Website & Digital Interactions

i. IP address, browser type, and device information.

ii. Website usage data collected through cookies and analytics tools.

iii. Marketing preferences and communications history.

(d) Public & Regulatory Sources

i. Information from government registries (e.g., Companies Office of Jamaica, TAJ, NLA).

ii. News articles, court filings, or publicly available business records.

If information is uploaded to our systems in connection with the services, we retain this information in line with our Data Retention Policy.

3. What we use your information for and the legal basis for doing so

At SCA we may use the information collected from you for varying reasons. These may include: -

• Deliver audit, tax, advisory, valuation, and CFO services.

• Meet regulatory and legal obligations (e.g., AML/KYC, professional standards).

• Manage our business operations (e.g., billing, collections, IT support, risk management)

• Communicate with you regarding services, updates, and changes.

• Conduct recruitment and HR management.

• Improve our website and digital services.

• Send you marketing updates (where you have consented or where allowed by law).

 

Legal Basis

We must have a legal basis (lawful reason) to process your personal data. In most cases, the legal basis will be one of the following:

• To allow us to take actions that are necessary for us to provide you with the service you want.

• To allow us to meet our legal obligations (for example, getting proof of your identity to meet our anti-money laundering obligations).

• To protect our legitimate interests (for example, to improve services, manage risk, ensure business continuity).

• We have your permission to use your information.

Compliance with laws and regulatory compliance obligations

We may use your information to meet our compliance obligations. We may also use it to comply with other laws and regulations. At times, we may be required to share your information with regulators and other authorities that we are subject to. This may include using it to help detect or prevent crime (including terrorism financing, money laundering and other financial crimes). We will only do this if it is needed to comply with a legal requirement, if it’s in our legitimate interests and that of others, or to prevent or detect unlawful acts.

Marketing

We may use your information to provide you with details about our products and services. We may send you marketing messages by email, telephone, text, secure messages or through social media. You can change your mind on how you receive marketing messages, or you can stop receiving them at any time. To make that change, you may contact our marketing department at info@signaturecreed.com. If you ask us not to send you marketing communication, it may take us a short period of time to update our systems and records to reflect your request, during which time you may continue to receive marketing messages. If you tell us not to send you marketing messages, we may continue to use your contact details to send you important notifications subject to your agreement for our services or if we need to inform you of something to comply with our regulatory obligations.

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4. Who we might share your information with

We will keep your information confidential, but we may share it with third parties (who also must keep it secure and confidential) in the following circumstances: -

· Regulators and Authorities - Tax Administration Jamaica (TAJ), Bank of Jamaica, Financial Services Commission, or other regulators as required.

· Auditors and Professional Advisers - Independent auditors, lawyers, and consultants.

· Technology & Service Providers - Secure cloud service providers, payment processors, IT and data storage providers.

· Debt Recovery or Legal Agencies - Where required to recover outstanding amounts.

· Public Authorities: If required by law, to detect or prevent fraud, money laundering, or other unlawful activity.

5. How long we keep your information for

We keep your information in line with our data retention policy. We will keep your personal data for as long as you are our customer. Once our relationship with you has ended (for example, after your contract has expired, or you decide not to go ahead with an engagement), we will only keep your personal data for a period that is appropriate for the type of personal data, and what we hold it for. This is usually for a period of seven (7) years from when our relationship ends. This allows us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as dealing with any disputes or concerns that may arise. We may need to keep your information for longer where we need the information to comply with regulatory or legal requirements, help detect or prevent fraud and financial crime, answer requests from regulators, etc. If we do not need to keep information for this length of time, we may destroy, delete or anonymize it sooner.

6. Your rights

You have certain rights relating to your personal data. These include the right to: -

a) be informed about how your personal data is being processed.

b) request access to your personal data.

c) consent and withdraw consent.

d) request the correction or rectification of your personal data.

e) object to the processing of your personal data.

f) request transfer of your personal data

g) Right to require that your personal data is not subject to automated decision making only.

Your ability to exercise these rights will depend on a number of factors, and in some instances, we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right doesn’t apply to the particular information we hold about you). If you would like more information on your rights, or want to exercise them, you can do so by contacting us at info@signaturecreed.com.

7. What we need from you

You are responsible for making sure the information you give us is accurate and up to date, and you must tell us if anything changes as soon as possible.

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8. How we keep your information secure

We use a range of measures to keep your information safe and secure, which may include encryption and other forms of security. We require our staff and any third parties who carry out any work for us to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.

9. How to contact us

If you have any questions about our privacy notice, you may contact our Data Protection Officer at: -

Signature Creed & Associates

9th Floor PanJam Building,

60 Knutsford Boulevard,

Kingston 5,

Jamaica Email: info@signaturecreed.com

Telephone: 876-345-1147

If you are unhappy about the way we have dealt with your privacy, you can contact our Data Protection Officer or make a complaint to the Information Commissioners Office.

10. Changes to our Privacy Notice

This Privacy Notice may be updated from time to time. You are encouraged to check back regularly to see any changes that may have occurred.

This notice was last updated in August 2025.