Privacy Policy

JAD Privacy Policy

This privacy policy governs the collection, storage and use of personal information collected by us, JAD, via our website at or through the JAD mobile application. It provides you with details about the personal information we collect from you, how we use your personal information and your rights to control personal information we hold about you. Please read this privacy policy carefully.  By accessing and using this website, you confirm that you have read, understood and agree to this privacy policy in its entirety. If you do not agree to this privacy policy in its entirety, you must not use this website or the services provided on it.


1)            In this privacy policy, the following terms have the meanings set out below:

a)            "JAD", "we", "us" and "our" means Genesis Innovation Management Inc (trading as JAD) with registered head office at #1 Fern Street, Greenlands, Basseterre, St. Kitts and includes its successors and any person to whom it has assigned its rights under Genesis Innovation Management User Agreement for JAD Service);


b)            "JAD Group" means JAD and any related company or Subsidiary of JAD from time to time (including but not limited to Straun’s Enterprises Incorporated, Genesis Innovation Management Inc and Genesis Payment Solutions.);


c)             “User”, "you" or "your" means you and any other person or entity entering into Genesis Innovation Management User Agreement for JAD Service or using the Service;


d)            "User Agreement" means the Genesis Innovation Management User Agreement for JAD Service;


e)            "Subsidiary" means any subsidiary company within the meaning of section 1159 of the UK Companies Act 2006 or any subsidiary undertaking within the meaning of section 1162 of the UK Companies Act 2006.


2)            This privacy policy was last updated on 18 March 2014. Please check back regularly to keep informed of updates to this privacy policy.


3)            Who we are:


a)            JAD is the registered trade name of Genesis Innovation Management Inc. a company incorporated in the Federation of St. Kitts and Nevis, whose registered number is 004620 and whose registered office and principal place of business is at #1 Fern Street, Greenlands, Basseterre, St. Kitts, St. Kitts and Nevis.


b)            We respect your right to privacy while there are no data protection regulations within the Federation of St. Kitts and Nevis we will only process personal information you provide to us in accordance with the UK Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws.


c)             If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us on the JAD website


User specific information


If you are applying to be a user of JAD services this section explains the type of personal information we collect about you and how we may store, use and disclose your information.


The personal information we collect about you

4)            When you access, browse this website (including when you submit personal information to us through data entry fields on the website) or apply to be a user of JAD services, and whilst you continue to be a user of JAD, we will collect information from you, which will include the following information:


a)            your name and your business name;

b)            your current and previous postal/residential addresses;

c)             your phone, fax and e-mail details;

d)            your bank or credit union society account details and  or details of debit cards used to make transfers on JAD;

e)            your date of birth;

f)              the details of at least two forms of official identification;

g)            your passwords and security question answers;

h)            comments you make on blogs and discussion forums on the website;

i)              correspondence with us by email and post;

j)              data about your activities using JAD.


5)            We may also collect anonymised details about visitors to the website for the purposes of aggregate statistics or reporting purposes and to calculate referral fees. However, no single individual will be identifiable from the anonymised details we collect or disclose for these purposes.


6)            We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access your JAD account or use the JAD Services, in order to help detect possible instances of unauthorised transactions.


7)            If you give us false or inaccurate information and we suspect or identify fraud, we will record this.


8)            If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.


How we may store, use and disclose your information

9)            We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information for the following purposes:

a)            to verify your identity in order to prevent and detect crime and money laundering, including by using scoring methods;

b)            to manage your JAD payment account with us and update the records we hold about you from time to time;

c)             to identify fraud;

d)            to carry out statistical analysis and market research;

e)            to carry out regulatory checks;

f)              to develop and improve our services and products;

g)            to make this website available to you and to identify the products and services which you may be interested in;

h)            where you have given us your consent, to contact you (including by SMS and e-mail) with products and services which we think may interest you; and

i)              where you have given us your consent, to disclose your personal information to carefully chosen third parties so that they may contact you (including by SMS and e-mail) with products and services which they think may interest you.


10)        Any or all of the processes above may be automated.


11)        We may disclose your personal information as follows:

a)            to other users of JAD if required to complete a payment order. If we provide you with information about other JAD members for this purpose then you must only use it to communicate with us about the payment order;

b)            to a third party if it acquires all (or substantially all) of our business and/or assets in connection with the acquisition;

c)             where we are required to do so by applicable law, by a governmental body or by a law enforcement agency; and

d)            to any member of the JAD Group for the purposes of providing and administering the JAD platform and services.


12)        We will also provide transactional information to other users of JAD but this information will not include your postal address or payment details. Your Client ID (not your name) will be used in effecting payments. We are not responsible for misuse of this transactional information by JAD users but you should let us know about any misuse of such information.



13)        We may combine your information with information we collect from other companies and use it to improve and personalise the JAD Services. If you don't wish to receive marketing communications from us or participate in our ad-customisation programmes, simply log in to your account, select My Account, Profile, then Notification settings and update your Communication preferences, or follow the directions provided with the communication or advertisement.


14)        We will not disclose, sell or rent your personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.



15)        This website uses cookies to collect information about you. If you use this website, then you accept that we can use the cookies set out below.



16)        Cookies are small data files which are placed on your computer by this website and which collect certain personal information about you.


17)        Cookies enable us to tailor our service offering (including the website) and to provide you with a better service.


18)        We use the following cookies:

a)            Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. They do not gather information about you that could be used for marketing purposes or remembering where you've been on the Internet.

b)            Analytical/performance cookies. They allow us to collect information about how you use our website, such as, how you move around our website and if you experience any errors. These cookies do not collect any information that could identify you; all of the information collected is anonymous and is only used to help us improve the way our website works, understand what interests our users and measure how effective our advertising is.

c)             Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences and improve your visit.

d)            Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. They are linked to services provided by third parties, such as "Like" and "Share" buttons. The third party provides these services in return for recognising that you have visited our website.


19)        Generally, cookies which are strictly necessary for the operation of the website will expire when you leave the website. Other cookies may be more permanent or not expire unless you actively delete them.


20)        If you want to reject any of the cookies that we use, then you will need to change your website browser settings.



21)        JAD is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption.  Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

Your rights



22)        You have the following rights:

a)            the right to ask us to provide you with copies of personal information that we hold about you at any time, subject to a fee (currently $30);

b)            the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge; and

c)             the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.


23)        If you wish to exercise any of the above rights, please contact us using the details specified above.


Mergers or Acquisitions

24)        As with any other business, it is possible that in the future JAD could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by JAD, including customer Account Information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended. 


Third party sites

25)        This website contains links to other websites operated by third parties. Please note that this privacy policy applies only to the personal information that we collect through this website and we cannot be responsible for personal information that third parties may collect, store and use through other websites. You should always read the privacy policy of each website you visit carefully.