Digicel AI Agent Privacy Notice

Publication Date: May 15, 2026

Introduction

Welcome to the Digicel AI Agent Privacy Notice.

At Digicel, your privacy matters to us. We’re committed to protecting your personal data and being transparent about how it’s used, so you can interact with us with confidence.

As part of our ongoing efforts to enhance your customer experience, we use a range of tools and technologies, including AI-enabled solutions. One of these is our Digicel AI Agent (also known as Ruby) our AI-powered chatbot and voice assistant, which helps answer questions faster and support customer service interactions across our channels.

This Privacy Notice explains how we may collect, use and protect your personal data when you interact with our AI Agent. We take reasonable steps to safeguard your information by implementing appropriate technical and organisational measures, policies, and procedures, in line with applicable laws and regulations.

1.            Data Controller

Digicel Caribbean Limited is the Data Controller (referred to as “Digicel”, "we", "us" or "our" in this privacy notice) of data collected through your interaction with the AI Agent. Digicel Caribbean Limited is a company registered under the laws of Barbados with registered office at One Welches, St. Thomas, BB22025. We’re a subsidiary of the Digicel Group of Companies.

Our Group Privacy Team handles all enquiries relating to the privacy practices of Digicel. If you have any questions about this privacy notice, our privacy practices or your legal rights, you may contact our Privacy Team using the details set out at Item 13 below.

Depending on your market or territory, you may also have the right to make a complaint to your local privacy or data protection regulator. We’re willing to help and would welcome the opportunity to address any questions or concerns you may have directly, so please contact us first.

2.            Scope of This Notice

Purpose of this Privacy Notice and When it Applies

This Privacy Notice aims to give you information on:

i)        how your information is collected and processed through your interaction with the AI Agent across Digicel’s customer support channels, via voice (phone call), Digicel website, WhatsApp and the MyDigicel mobile and web applications (“support channels”); and

 ii)      your privacy rights and how the law protects you.

It’s important that you read this Privacy Notice together with any other privacy, customer, or regulatory notices we may provide for specific products and services, and on specific occasions when we’re collecting or processing personal data about you, so that you’re fully aware of how and why we’re using your data. For example, your interactions with the AI Agent chatbot on the MyDigicel App are also within scope of the use of the MyDigicel App, and are, therefore, also governed by the MyDigicel App Privacy Notice. This privacy notice supplements other notices published by the Digicel Group of Companies and isn’t intended to override them.

Use of AI Agent on Voice Channels

Some calls to Digicel customer contact centres may be answered or supported by Ruby. In this instance, artificial intelligence is used to improve response times and service efficiency. It may analyse voice inputs, call metadata and conversation content in real time.

AI-handled calls (like all other AI-integrated services and solutions within Digicel) are subject to Digicel’s privacy safeguards and are processed in accordance with applicable data protection laws and a privacy notice. You may opt to speak with a human customer care representative at any point during the call. These calls and interactions may be recorded and used to improve the accuracy, reliability, and effectiveness of the AI systems, as well as to enhance your customer experience. For this reason, we ask that you do not disclose sensitive personal information when interacting with AI agents and that you share only the information necessary to assist with your enquiry or manage your account.

Personal Data of Minors

We don’t knowingly collect data from or about individuals under the legal minimum age without the permission of their parent or guardian. When we do collect that data, we might do it inadvertently, if they interact with any of our support channels. If you believe your child/ward may have provided us with personal information without proper consent, you can contact us at privacy@digicelgroup.com.

3.            The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. Depending on your country or market, this definition may extend to personally identifiable information for individuals deceased for thirty (30) years or less. Personal data shall not include any data where identifiable information has been removed (anonymous data) or where an individual can’t be identified by the data set.

Personal data is collected from all individuals who interact with our support channels. We may process (collect, use, store and transfer) different kinds of personal data about you, which we have grouped together below. The information we process about you and how we process it may vary depending on what support channel you interact with and how you’ve interacted with it, the service or product you are enquiring about, or what we’ve obtained from a third party with permission to share it with us.

• Identity Data includes full name; username or similar identifier; title.

• Contact Data includes billing address; email address; telephone numbers.

• Profile Data includes your Digicel ID and/or Digicel+ account number; account creation date; active plans and/or subscriptions; account activity and purchase history; interests; preferences; feedback and survey responses. 

• Transaction Data includes details about payments to and from you and other details of services, and products (incl. plans and/or subscriptions) you have used or purchased from us.

• Technical Data includes internet protocol (IP) address; your login data; Mobile Station Integrated Services Digital Network (MSISDN); unique device IDs such as International Mobile Equipment Identity (IMEI)

• Communications Data comprises of any explicit communication preferences.

• Usage Data includes date/time of communication, user agent string, conversation transcripts, voice-to-text transcripts.

• Any Other Volunteered Information you share in your interactions with our support channels, which you understand and acknowledge as information made accessible by you.

• Other Data deemed necessary for any of the purposes noted under Section 4, which may be collected from our Internal and External Third Parties, as defined in the Glossary, with or upon your consent.

Depending on the support channel you use, we may collect Special Categories of Personal Data (or Sensitive Personal Data) about you. This category of data would directly apply to biometric data (voice recordings) of individuals who interact with our support channels, including via the voice feature of the Digicel AI Agent chatbot.  We’ll update you if any of our processing activities will require further collection of any Special Categories of Personal Data and request your permission to do so.

We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Transaction Data to calculate the percentage of users who use our support channels or enquire about a particular service, product, plan/subscription. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

 If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract and you fail to provide that data when requested, we may not be able to perform the task or service you’ve requested or provide you with access to our Application, Website, products and services. In this case, we may have to cancel, terminate or restrict access to the account you have with us but we’ll notify you if this is the case at the time.

4.            How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct Interactions, where information is collected directly from you, your devices, or your activities, with your consent, when you interact with our support channels.

• Automated Technologies or Interactions. As you interact with some of our support channels, we may automatically collect Technical Data about your equipment, in-app and web activity and patterns. We collect this personal data by using application permissions where applicable, cookies and other similar technologies.

• Third Parties or Publicly Available Sources. To assist us in providing you with the best experience, we may receive and/or share any personal data about you deemed necessary for any of the purposes noted under Section 5. Generally, we receive or share your personal data from and/or with various public sources, and our Internal, External and Specific Third Parties, as defined in the Glossary, once we have your consent.

5.            How We Use Your Personal Data

We’ll only use your personal data when the law allows us to. Most commonly, we’ll use your data where:

• we need to perform the contract we are about to enter into or have entered into with you.

• it’s necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights don’t override those interests.

• we need to comply with a legal obligation such as law enforcement disclosures, or meeting regulatory obligations that are subject to strict internal policies and procedures (such as retention periods).

• you provide consent to the use of your information. Consent may be withdrawn at any time by notifying us or by terminating your account with us.

Purposes for Which We’ll Use Your Personal Data

We’ve set out in the table below, a description of all the ways we plan to use your personal data, which of the legal bases we rely on to do so, and where appropriate, what our legitimate interests are.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we’re using your data. Please contact us if you need details about the specific legal ground we’re relying on to process your personal data where more than one ground has been set out in the table.

Table 1: Purposes for use of your personal data

Marketing and Third-Party Marketing

Unless we explicitly request and you provide consent, we will not use any information you provide via our AI-enabled support channels for marketing and advertising communications, including promotional offers on our products and services.

Change of Purpose

We’ll only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we’ll notify you and we’ll explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6.            Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the Table 1: Purposes for use of your personal data above.

• Internal Third Parties as set out in the Glossary.

•  External Third Parties as set out in the Glossary.

•  Specific Third Parties as set out in the Glossary.

•  Third Parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We don’t allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7.            International Transfers

We share your personal data within entities throughout the Digicel Group of Companies.

Whenever we transfer your personal data out of the country of origin, however, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We’ll only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use special contracts that ensure that an adequate level of protection through the use of technical and organisational measures. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.

8.            Data Security

We’ve put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They’ll only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Please be aware that although we endeavour to provide reasonable security for the information we process and maintain, no security system can prevent all potential security breaches. In any event, we’ll notify you and any applicable regulator of a breach where we’re legally required to do so.

9.            Data Retention

How Long Will You Use My Personal Data for?

We’ll only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Where you’ve decided to withdraw the consent you’ve given, we’ll delete your personal data within thirty (30) days, unless we’re required to keep it for the reasons explained herein. We may need to keep a piece of your contact information e.g., email address, in our records, so we know that you’ve withdrawn your consent and therefore ensure we honour your choice.

Details of retention periods for different aspects of your personal data are available in our retention schedule which you can request from us by contacting us at privacy@digicelgroup.com.

10.          Your Legal Rights

In some countries and under certain circumstances, you have rights in relation to your personal data. You may have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we’re lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you’ve successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we’re required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we’re relying on a legitimate interest (or those of a third party) and there’s something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object, where we’re processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.

• Where our use of the data is unlawful but you don’t want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. In order to exercise any such legal claim, we may require a court or administrative order, subpoena or other such legal or regulatory proclamation.

• You’ve objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We’ll provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we’re relying solely on consent to process your personal data. However, this won’t affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to efficiently honour our relationship with you. We’ll advise you if this is the case at the time you withdraw your consent.

If you wish to enquire about or exercise any of the rights set out above, visit our Privacy & Trust Centre or contact the Privacy Team at privacy@digicelgroup.com.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data isn’t disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to complete all legitimate requests within sixty (60) days. Occasionally, it could take us longer than sixty (60) days if your request is particularly complex or you’ve made several requests. In this case, we’ll notify you and keep you updated.

11.          Glossary

i.      LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We don’t use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 Performance of Contract means processing your data where it’s necessary for the performance of a contract to which you’re a party or to take steps at your request before entering into such a contract.

 Comply with a legal obligation means processing your personal data where it’s necessary for compliance with a legal obligation that we are subject to.

Consent means your informed and explicit agreement to the processing of your personal data, given through a clear affirmative action and not withdrawn.

ii.    THIRD PARTIES

 Internal Third Parties

Other companies in the Digicel Group may act as joint controllers or processors, and may provide IT and system administration services, and/or process personal data through leadership reporting. The list includes:

Table 2: List of Data Controllers/ Digicel Affiliates

Data Controllers/ Digicel Affiliates

External Third Parties

• Service providers acting as processors who provide IT and system administration services.

•  Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

•  Relevant regulators and other authorities as required by law (that may be acting as processors or joint controllers), who may require reporting of processing activities in certain circumstances.

Specific Third Parties

Table 3: Specific Third Parties and their Services

12.          Changes to the Privacy Notice and Your Duty to Inform Us of Changes

We endeavour to keep our Privacy Notice under annual review. This version was last updated on 15 May 2026.

It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

13.          How to Contact Us in Relation to Our Privacy Practices

For all comments, concerns and complaints regarding this notice, our privacy practices, or to exercise your privacy rights, you may contact the Privacy Team via the following means:

• Post: Digicel Caribbean Limited, One Welches, St. Thomas, BB22025, Barbados

• Attention: Group Privacy, AI & Data Protection

• E-mail: privacy@digicelgroup.com

• Website: Privacy & Trust Centre