Who we are

NCS eLoans is a member company of NCS Financial Services Group Limited (the parent company). Our Head Office is in Providenciales, Turks and Caicos Islands and we take data protection and information security responsibilities very seriously. The effective management of all personal data, including its security and confidentiality, lies at the very heart of our business and underpins our practices and processes.

As a firm with global connections, our aim is to be as consistent as possible and obey all applicable laws and apply the highest standard of privacy laws to our approach.

This privacy policy aims to inform you about how we collect, store, use and disclose information about you when you:

• interact with or use our websites;
• if you use any of our products, services or applications (collectively the “services”) in any manner.

1. What information do we collect?
   We gather various types of information that may identify you as an individual (“personal information”). We may collect any personal information that you choose to send to us or provide to us. If you register for a NCS eLoans account we will collect personal information from you. If you contact us through the website, we will keep a record of correspondence.

From the Services we provide: We receive and store information you provide directly to us. 

The types of information we may collect directly from our customers include but not limited to:

• Valid Photo ID, for example a Passport, Drivers Licence or ID card
• NHIP ID
• Proof of Employment
• Proof of address, for example a utility bill or credit card bill
• Email address
• Two or more character references
• Declaration of Residency or Work Permit status, if appropriate
• Employment status
• Politically Exposed Person declaration, if applicable
• Public Office Exposure, if applicable, as well as any other information the customer chooses to provide us.

If information is uploaded to our systems in connection with the loan application, we retain this information in line with our retention policy. NCS eLoans is committed to the highest level of security and privacy regarding the collection and use of our online customers’ personal information, as well as that of all visitors to our web site. This information is handled internally by our staff to process the visitor’s request.

Loan Application Information

Our website may be used to initiate and complete loan applications. We will collect information provided by you that is required to process each application (collectively, “Loan Application Information”). We will use Loan Application Information to evaluate, process, and underwrite the application on your behalf. We will also retain and use Loan Application Information, to establish and administer loan accounts, for fraud protection, and to satisfy certain regulatory requirements.

Except where prohibited by law, we may use the email, physical address, and phone number provided in the Loan Application Information to deliver marketing communications to you via email or direct mail or to contact you for information about your experience with our website, products, and services. We may still use the email address to send transactional information related to an application or a loan. You may opt-out of receiving marketing or user-experience related phone calls by contacting us at the address provided in Section 6 of this Privacy Policy.

We may use or provide to third parties certain Loan Application Information for analysis purposes. For example, we may use such Loan Application Information to analyze the effectiveness of loan solicitations or underwriting. Loan Application Information used or shared in this manner will not contain your personally identifiable information.

We may provide to third parties certain Loan Application Information for product or service offerings. For example, we may use such Loan Application Information to identify pertinent financial products and share the Information with existing and future lender partners with whom we have contractual arrangements to offer such products. In all cases, our collection, use and disclosure of Loan Application Information will be in accordance with this Privacy Policy, and the requirements of applicable law.

• How do we store your information? 

Retention policy

We normally keep customer account records for up to seven years after your relationship with the institution ends, then the information is securely destroyed. 

NCS Financial Services Group Companies:
We may also share your personal data with our parent company or group company for the purposes consistent with this Privacy Notice. When we send your data to our group companies you are protected by similar privacy policies.

Exercising your Privacy Rights
What choices do I have?

You can always opt not to disclose information to us, but keep in mind some information may be needed to transact with us or to take advantage of some of our offers and discounts.

Access to Information by Employees. 

NCS eLoans and employees of the NCS Financial Services Group have access to your information. NCS Financial Services group policy requires each employee to agree to keep all Information confidential.

Access to Information by Service Providers. 

We may share Information with service providers with whom we have contracted to perform services on our behalf such as companies that help process and service loans, and companies that market products and services. We may use third-party service providers to store Information and facilitate communication with you. All contracted third-party service providers are contractually required to safeguard all Information.

1. How do we use the information?
   We may use the information we collect from our customers in connection with the services we provide for a range of reasons, including to:

• provide, operate and maintain the services of NCS eLoans
• manage our customers’ use of the services, respond to enquiries and comments and provide customer service and support;
• send customers technical alerts, updates, security notifications, and administrative communications;
• verify customers identity and check credit with credit reference agencies (where applicable)
• investigate and prevent fraudulent activities, unauthorised access to the services, and other illegal activities; and
• for any other purposes about which we notify customers and users.

When you use the Website: When you visit our website, we may collect certain information related to your device, such as your device’s IP address, what pages your device visited, and the time that your device visited our website. These include;

• Usage information– we keep track of user activity in relation to the types of services our customers and their users use, and the performance metrics related to their use of the Services.
• Log information– we log information about our customers and their users when you use one of the services including Internet Protocol (“IP”) address.
• Information collected by cookies and other similar technologies– we use various technologies to collect information which may include saving cookies to users’ computers.

We collect this information via our websites:

• to administer our website, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;

• to improve our website to ensure that content is presented in the most effective manner for you and for your computer;

• for trend monitoring, marketing and advertising;
• for compliance purposes, for example, to comply with Know Your Client (KYC) and Anti Money Laundering (AML) laws;

• for purposes made clear to you at the time you submit your information – for example, to fulfil your request for or to apply for a loan. 
• as part of our efforts to keep our website secure.

We may access and use information from credit reference and fraud prevention agencies when you open your account and periodically to:

• manage your accounts, including assessing your credit worthiness and checks to avoid customers becoming over-indebted;
• to prevent criminal activity, fraud and money laundering;
• to check your identity and verify the accuracy of the information you provide to us;
• to trace debtors and recover debts.

Lawful basis

Our Lawful basis for processing includes:

• Performance of a contract: Our lawful basis for processing is the “Performance of a Contract” for opening an account, maintaining your account details and services connected with NCS Financial Services Group. Our Lawful basis for our notary service for the arrangement of loans is Performance of a Contract. 

• Legitimate Interest: Our use of your personal information may also be based on our legitimate interest to ensure network and information security if you use any of our systems such as NCS eMoney Services or NCS ePayment Services, and for Credit Checking your details. Our lawful basis is our legitimate interest for the purposes of direct marketing, to provide you with the most appropriate products and services. NCS eLoans will not share your information with third parties for their own marketing purposes without your permission.  For the purposes of risk reporting, general financial and accounting reporting, to internal management and supervisory bodies, our legal basis for processing your details is legitimate Interest.

• How do we Disclose your information?

Sharing Loan Application Information with Guarantors. 

If two individuals apply for a loan together as applicant and guarantor, each party will have access to the other’s Loan Application Information.

1. Changes to This Privacy Policy

We may change our policies (including this Privacy Policy) at any time. If we decide to change this Privacy Policy, we will post the changes to this page so that you may be aware of our actions. Any change to this Privacy Policy will become effective when posted here.

1. Contacting NCS eLoans

For additional information about NCS eLoans, this website or this Privacy Policy, please contact us by mail at NCS eLoans, 10 Parade Avenue, Downtown, Butterfield Square Providenciales, Turks and Caicos Islands TKCA 1ZZ British West Indies (649) 946-4227