Last Updated: May 7, 2026

1. Introduction: Laborie Co-operative Credit Union Ltd (“LCCU”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the LCCU FinX application (“the App”). By using the App, you consent to the data practices described in this policy.

    

2. Information We Collect

          2.1  Personal Information: We collect personal information that you provide directly, including:

• Account Information: Name, email address, phone number
• Authentication Data: Username, password (encrypted), role assignment
• Student Information: Student ID, class assignment, school affiliation
• Guardian Information: Guardian-student relationships, contact details.
  
  2.2. Financial Information: We collect and process financial data, including:
• Account balances
• Transaction history (deposits, withdrawals, contributions)
• Pending deposits and discrepancies
• Payment information processed through the App

     2.3.Usage Information: We automatically collect certain information when you use the App:

• Device information (model, operating system, unique device identifiers)
• Log data (IP address, access times, app features used)
• Error reports and performance data

      2.4.      Location Information: LCCU FinX does not collect precise device location data. If this changes in the future, we will update this                               policy and request permission before collecting location data.

     2.5.      Data We Do Not Collect: We do not collect the following:

• Date of birth
• Government-issued identification numbers
• Biometric data
• Precise geolocation
• Behavioural
  or advertising identifiers
• Social media profile data

3. How We Use Your Information: We use collected information for the following purposes:

       3.1.      Service Provision

• Provide, operate, and maintain the App
• Process financial transactions
• Manage user accounts and authentication
• Generate reports and statements

       3.2.      Communication

• Send account notifications and updates
• Respond to inquiries and support requests
• Send administrative information about the App

  3.3 Security and Fraud Prevention

• Detect and prevent fraudulent transactions
• Verify user identity
• Monitor for security threats
• Comply with legal obligations

    3.3.      Improvement and Analytics

• Analyze usage patterns to improve the App
• Develop new features and services
• Conduct research and data analysis

4. Information Sharing and Disclosure

         4.1.      Within LCCU We share information internally on a need-to-know basis:

• Administrators have access to user management data
• Principals have access to school-level financial data
• Teachers have access to class-level data
• Tellers have access to transaction processing data

    4.2. Third-Party Service Providers: We may share information with trusted third parties who assist us in:

• Data storage and hosting (Supabase)
• Authentication services
• Analytics and performance monitoring
• Technical support

These providers are contractually obligated to protect your information and use it only for specified purposes.

     4.3. Legal Requirements: We may disclose information when required by law or to:

• Comply with legal processes or government requests
• Enforce our Terms of Use
• Protect the rights, property, or safety of LCCU, users, or others
• Prevent or investigate fraud or security issues

    4.4. Business Transfers: In the event of a merger, acquisition, or sale of assets, user information may be transferred as part of that                                 transaction.

 
5.  Data Security

         5.1.      Security Measures: We implement appropriate technical and organizational measures to protect your information:

• Encryption of data in transit and at rest
• Secure authentication mechanisms
• Regular security assessments
• Access controls and user permissions
• Monitoring for suspicious activity

5.2.      Limitations: While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

6.      Data
Retention

We retain your information for as long as necessary to:

• Provide
  the App services
• Comply
  with legal, regulatory, and accounting requirements
• Resolve
  disputes and enforce our agreements

Account information and transaction history are typically
retained for a minimum of 7 years for regulatory compliance.

7.      Your
Rights and Choices

7.1.      Access
and Correction

You have the right to:

• Access
  your personal information
• Request
  corrections to inaccurate data
• Request
  a copy of your data

Contact LCCU administrators to exercise these rights.

7.2.      Data
Deletion

You may request deletion of your account and associated data,
subject to:

• Legal
  and regulatory retention requirements
• Legitimate
  business needs
• Pending
  transactions or disputes

7.3.      Opt-Out
Options

You may opt out of:

• Non-essential
  communications (marketing emails)
• Location
  tracking (via device settings)
• Analytics
  cookies (where applicable)

Note: Opting out of certain data collection may limit App
functionality.

7.4.      Rights on
Behalf of a Minor

Parents and guardians may exercise any of the rights in
Sections 7.1 – 7.3 on behalf of a minor child. In addition, as detailed in
Section 8.7, parents and guardians have the right to object to any processing
of student data that is not strictly necessary for the operation of the savings
programme. To exercise rights on behalf of a child, contact the Privacy Officer
(see Section 12) and provide sufficient information to verify your identity and
your relationship to the child.

8.      Children’s
Privacy and Student Data Protection

8.1.      Scope and
Age Threshold

The App is designed for use within educational institutions
and is expected to be used by minors (users under 18 years of age) as part of
school-based financial literacy programmes. LCCU treats all student accounts as
accounts that may belong to minors regardless of whether the actual age of the
student is known.

8.2.      Parental
and Guardian Consent

• Student
  accounts are provisioned only by authorised LCCU administrators or school
  principals acting on behalf of the institution.
• Enrolment
  in the programme constitutes acknowledgement by the school that parental
  or guardian consent for participation in the savings programme, including
  the creation of a digital account–has been obtained in accordance with
  applicable law and school policy.
• Parents
  and guardians may withdraw consent at any time by contacting LCCU (see
  Section 12). Upon withdrawal, the student account will be deactivated and
  personal data deleted subject to legal retention obligations.

8.3.      Student
Data – What We Collect and Why

For student accounts we collect only the minimum data
necessary to operate the savings programme:

No date of birth, government ID, biometrics, or sensitive personal data is collected for student accounts.

8.4.      Purpose
Limitation – How Student Data Is Used

Student data is used solely for:

• Operating
  and maintaining the student savings account
• Generating
  transaction records and statements for the student, their guardian, and
  authorised school staff
• Enabling
  guardian oversight of the account
• Complying
  with legal and regulatory obligations

Student data is never used for:

• Marketing,
  advertising, or promotional communications
• Behavioural
  profiling or targeted content
• Sale
  or sharing with third parties for commercial purposes
• Any
  purpose beyond the school savings programme

8.5.      Access
Controls for Student Information

Access to student data within the App is strictly
role-limited:

• Students:
  view their own account only
• Guardians:
  view accounts of their linked dependants only
• Teachers:
  view aggregate class-level transaction data; no access to other classes
• Principals:
  view school-level data for their institution only
• Tellers:
  process transactions; no unnecessary access to student profile data
• Administrators:
  full access for account management and audit purposes, subject to internal
  access controls

8.6.      Data
Minimisation and Retention for Student Accounts

• Student
  account data is retained for the duration of active enrolment plus any
  mandatory regulatory retention period (minimum 7 years for financial
  records).
• Upon
  a school’s request or when a student is no longer enrolled, non-financial
  personal data (name, email) will be anonymised or deleted; transaction
  records will be retained only to the extent required by law.

8.7.      Guardian
Rights Regarding Student Data

Parents and guardians have the right to:

• Access:
  request a copy of all personal data held for their child
• Correction:
  request correction of inaccurate or incomplete data
• Deletion:
  request deletion of their child’s account and personal data (subject to
  legal retention requirements)
• Restriction:
  request that processing be restricted pending correction or dispute
  resolution
• Objection:
  object to any processing not strictly necessary for the savings programme

To exercise these rights, contact the LCCU Privacy Officer
(see Section 12). We will respond within 30 days.

8.8.      Applicable
Student Privacy Standards

In delivering the student savings programme, LCCU applies
practices consistent with the following frameworks where applicable to its
jurisdiction:

• COPPA (Children’s
  Online Privacy Protection Act) – for users in the United States under 13
• FERPA (Family
  Educational Rights and Privacy Act) – for student education records
• GDPR and UK
  GDPR – for users in the European Economic Area or United Kingdom,
  including the principle of data protection by design and by default for
  children
• Local
  data protection regulations applicable in
  the jurisdictions where LCCU operates

Where any of the above standards impose stricter requirements
than this policy, those stricter requirements will apply.

9.      International
Data Transfers

Your information may be transferred to and processed in
countries other than your country of residence. We ensure appropriate
safeguards are in place to protect your information in accordance with this
Privacy Policy.

10.      Third-Party
Links

The App may contain links to third-party websites or services.
We are not responsible for the privacy practices of these third parties. We
encourage you to review their privacy policies.

11.      Changes
to This Privacy Policy

We may update this Privacy Policy from time to time. Changes
will be posted within the App with an updated “Last Updated” date.
Continued use of the App after changes constitutes acceptance of the updated
policy.

12.      Contact
Us

For questions, concerns, or requests regarding this Privacy
Policy or your personal information, please contact:

Laborie Co-operative Credit Union Ltd

Compliance Officer

Email: schoolthrift@mylaboriecu.com
Phone: +1 (758) 459-6900

Address: Allan Louisy Street, Laborie Saint Lucia LC11 101

13.      Regulatory
Compliance

LCCU complies with applicable data protection laws and
regulations, including:

• Local
  data protection regulations in all jurisdictions where LCCU operates
• Financial
  services regulations governing the retention and handling of financial
  records
• Educational
  institution data protection requirements
• COPPA (Children’s
  Online Privacy Protection Act) – governing the collection of personal
  information from children under 13 in the United States
• FERPA (Family
  Educational Rights and Privacy Act) – governing the privacy of student
  education records
• GDPR
  / UK GDPR – governing data protection by
  design and by default, including heightened protections for minors
• PIPEDA (Personal
  Information Protection and Electronic Documents Act) – where applicable
  for Canadian users

Where student data is involved, LCCU applies the most
protective standard available under applicable law, and follows the principle
of data protection by design: collecting the minimum data necessary, limiting
access to authorised roles, and retaining data only for as long as required.

14.      Your
Consent

By using LCCU FinX, you acknowledge that you have read and
understood this Privacy Policy and consent to the collection, use, and
disclosure of your information as described herein.

Effective Date: May 7, 2026

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