Privacy Policy

Consistent Trust Microfinance Bank ("CTMFB," "We," "us," or "our") is dedicated to safeguarding your privacy. We are committed to protecting your privacy because we value it. Accordingly, our data collection, processing, sharing, management, and storage policies are open and compliant with legal and regulatory obligations.

This Privacy Policy explains our approach to handling your data and your rights concerning our collection, use, storage, and sharing of your data while providing exceptional products and services across all our delivery channels.

1. CTMFB AND YOU

This Privacy Statement describes how CTMFB, and its Subsidiaries gather, utilize, keep, and disclose your personal information while providing products and services through many channels. You consent to process your data using our services by this policy.

2. INFORMATION COLLECTION AND USE

We gather a variety of information to offer all of our users a high-quality service. Consequently, depending on how you use our Service, we may collect the following Personal Data:

2.1. FOR REGISTERED USERS:

We may gather the following information during the registration process: Name, Date of Birth, Bank Verification Number, Image, Mobile Phone Number, access to Audio, Camera, and contact information. We also collect specific data such as:

a. Details for identity verification and liveness checks may involve advanced technology processes, including facial recognition or biometric data if used.

b. Information from your interactions with our app, such as usage data and preferences, to enhance our services.

c. We capture an image of your face as part of a liveness check to verify your identity when opening or upgrading your account. To facilitate this process, we share the image with a third-party service provider. Rest assured, the image capture of your face collected during the liveness check is exclusively shared with the third-part service provider involved in the verification process. No other parties will have access to this information. If you decide to revoke your consent to us to use this image capture for the liveness check, we will promptly delete it. However, it's important to note that such a withdrawal may impact your account functionality, as certain services rely on the processing of your image capture for the liveness check. Access to the camera may contribute to the security of our application by monitoring and detecting potential security threats or unauthorized activities. In addition, the collection and usage of your image information is connection with regulatory KYC (Know Your Customer) purposes.

d. When you make a bill payment for airtime and data, we collect your contact information which includes your phone number, and any additional contact details provided during the transaction.

2.2. FOR UNREGISTERED USERS:

We gather non-active data from registered and unregistered users alike. This information comprises cookies, IP addresses, location, and browser-specific data.

2.3. SALES AND BILLING INFORMATION:

We may collect your credit and/or debit card information, including your card number, expiry date, security code, billing address, and contact information, as well as any other information necessary to complete your transaction.

2.4. USER EXPERIENCE:

Occasionally, we may additionally seek Personal Data essential for enhancing our Service and the Products and Services we provide for sale through the Application.

3. HOW WE USE YOUR INFORMATION

We utilize collected information for a variety of reasons, including the following:

a. To provide, maintain, and improve our services.

b. To process transactions and manage your account.

i. Your contact is essential for processing bill payments for airtime and data.

ii. Image Information: We collect and use your image (upload, storage, and use) information to support account opening and verification process. In addition, the collection and usage of your image information is in connection with the regulatory KYC (Know Your Customer) purposes.

iii. Communication: We may use your email address or phone number to communicate with you regarding your transactions, account status, or important updates.

iv. Customer Support: If you reach out to customer support, we may use your contact information to assist you with any queries or concerns.

v. Service Updates: We may send you periodic updates about our services, promotions, or new features. You can opt out of these communications at any time.

c. Communicating with you includes sending you crucial alerts, updates, and promotional items.

d. To verify your identity and prevent fraud or other unauthorized activities.

e. To monitor and analyze usage trends and preferences.

f. To comply with legal obligations and regulatory requirements.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to third parties in the following situations:

• With your consent or at your direction.

• To our trusted service providers, who assist us in offering and developing our services and are subject to strong confidentiality standards.

• To comply with legal requirements, regulatory requirements, or to protect the rights, property, or safety of the Bank, our users, or others.

• In the event of a merger, acquisition, or transfer of the Bank's assets, the acquiring party will be subject to the provisions of this Privacy Statement.

5. USER DATA USAGE POLICY

Our User Data Usage Policy is incorporated into this Privacy Policy and provides additional details on how we collect, use, store, and disclose your personal information. Please refer to the User Data Usage Policy for details.

6. YOUR PERSONAL INFORMATION

We collect the information you supply through our online forms, phone calls, and communication by mail or email, service point interfaces, and any other channels we may, from time to time, make accessible to you when using services supplied by CTMFB and its Subsidiaries.

The information we collect may include but is not limited to identity verification, services consumed, services desired/required, method of consumption, preferences, location, public events, instructions, and service-related transactions. In addition, we may use information about you collected from third parties and other business partners to meet your requirements better.

CTMFB and its Subsidiaries have no control over third-party sources; hence, we cannot be held responsible for how they utilize information.

7. CONSENT

We only request personal information when it is necessary for providing or improving our goods or services. We want to ensure that we have your permission to collect, utilize, and, if required, share your information with our partners and suppliers who assist us in delivering a superior customer experience. Moreover, when introducing new services and technology, we guarantee that you know and consent to new information processing techniques.

You are considered to have agreed to the processing of your data by CTMFB and its Subsidiaries if:

• You complete any form, brochure, or document produced by CTMFB and its Subsidiaries asking for such personal information at any of our service points (mobile, online, in-branch, etc.).

• You register, check, or click the acceptance box on any of our electronic platforms (Online or Mobile) for the terms and conditions of any service or product provided by CTMFB and its Subsidiaries.

• You send CTMFB and its Subsidiaries a request, complaint, or other contacts.

• You utilize any CTMFB and its Subsidiary service or product.

8. USE OF YOUR INFORMATION

CTMFB and its Subsidiaries will process your personal information for the following purposes.

• To offer and provide our Products and Services tailored to your unique needs.

• To fulfill the terms of any service contract(s) you might have with us

• To improve your service experience with us

• To conduct our business

• To manage our relationship with you

• To comply with Laws and Regulations

• To provide information to Credit Agencies

• To update your records

• To develop statistics as may be required

• To comply with our Internal Policies

• To communicate with you when necessary

CTMFB and/or its Subsidiaries will limit the collection and use of your personal information for the stated purposes.

9. COOKIES

Please be advised that, for our digital channels, we may collect information about your computer (or mobile device), including your IP address(es), operating system, and browser type, for system administration or our business reasons.

These are non-identifiable information on our users' browsing preferences and behavior. Our Cookie Policy has more details.

Consistent Trust Microfinance Bank (CTMFB) may use the information we obtain from your use of our cookies to:

• Identify your computer when you visit our website.

• Track your use as you visit our website.

• Enhance the usability of the website (including our Live Chat application to answer your inquiries in real-time).

• Analyze the use of our website, such as the number of daily visitors, and manage the website.

• Users may deactivate cookies and restrict their creation by adjusting their browser settings. This is not advised, however, since deleting cookies may impair necessary site functionality and features.

10. INFORMATION SHARING AND DISCLOSURE

CTMFB and its Subsidiaries will not sell or expose your personally identifiable information.

CTMFB and its Subsidiaries may release or distribute your personal information when:

• We have your consent to share or disclose such personal information.

• We are required by law to share or disclose such personal information

• We respond to subpoenas, court orders, or other legal processes.

• We find that your actions on our electronic platforms violate our Policies for investigations, reporting, and enforcing any of our rights.

• Required for audit purposes

CTMFB and its Subsidiaries may use and share your personal information with its affiliates and partners to provide services and service-related activities, such as collecting subscription fees for such services and notifying or contacting you about a problem with or the expiration of such services. In this respect, Affiliates and partners must handle the data in line with this Privacy Policy.

CTMFB and its Subsidiaries may also disclose or share your personal information where required to enforce the terms and conditions of our Products and Services or safeguard our operations and customers.

11. INFORMATION PROTECTION AND RETENTION

CTMFB and its Subsidiaries will always protect your personal information appropriately. We have created procedures and systems to safeguard your personal information from being altered, lost, compromised, or destroyed. In addition, as mentioned in this policy, our personnel are trained to prevent the disclosure of your personal information and to keep it secure.

Where access to and usage of our electronic platforms involve user authentication, you are responsible for using and securing your authentication credentials, including but not limited to your Username, Personal Identification Number (PIN), Password, One Time Passwords (OTP), and Tokens.

We shall preserve your personal information for as long as necessary by law, regulation, and CTMFB and its Subsidiaries' internal policies.

12. YOUR RIGHTS UNDER THIS POLICY

The following rights are available to you under this policy

• You may at any time request access to your personal information collected by CTMFB and its Subsidiaries or request that your personal information be provided to a third party. Your request may specify the format in which the information should be provided, subject to CTMFB and its Subsidiaries' ability to provide the personal data in the manner requested.

• You may request that CTMFB and its Subsidiaries update your personal information anytime.

• You have the option to revoke your permission at any time. Unless there is a legal or operational basis to continue processing your data, CTMFB and its Subsidiaries will cease processing your data upon receiving your notification to withdraw permission unless there is a legal or operational reason to continue processing your data. This withdrawal may impair CTMFB and its Subsidiaries' ability to supply you with certain products or services if your consent is required to provide such services.

• Your right to withdraw consent includes the ability to object to or restrict CTMFB and its Subsidiaries' processing of your data.

• You can ask for your personal information to be erased. However, we may continue storing your personal information to comply with legal, regulatory, or policy obligations.

13. REMEDIES

If you have any questions or issues regarding the processing of your personal information by CTMFB and its Subsidiaries, please get in touch with us using the information shown below:

Email: [email protected]

Phone: +234-80-123-2355

We will reply to your concerns within 30 days of receiving your notice.

We shall preserve your personal information for as long as necessary by law, regulation, and CTMFB and its Subsidiaries' internal policies.

DATA STORAGE DETAILS

14. DATA STORAGE AND SECURITY

CTMFB and its Subsidiaries safeguard your personal information on secure servers in data centers with full access and security controls. In addition, we deploy encryption methods that adhere to industry standards to safeguard your data during transmission and storage. These technologies include Secure Socket Layer (SSL) and Transport Layer Security (TLS) encryption protocols, but they are not restricted to these.

We regularly update and test our security systems to ensure the highest level of protection for your personal information. In addition, CTMFB and its Subsidiaries have also implemented a multi-layered security approach, including physical, electronic, and procedural safeguards, to protect your personal information from unauthorized access or disclosure.

15. DATA TRANSFERS

CTMFB and its Subsidiaries may need to transmit your personal information to third parties, including those outside your country of residence, to provide services to you. In such instances, we will verify that the transfer complies with all relevant data protection regulations and that adequate protections are in place to protect your data. These precautions may include data transfer agreements, adherence to globally recognized data protection standards, or dependence on the recipient's certification under an established data protection framework, such as the EU-US Privacy Shield.

16. DATA RETENTION PERIOD

CTMFB and its Subsidiaries maintain your personal information for as long as required to accomplish the reasons for which it was obtained, to comply with legal, regulatory, and internal policy obligations, or until you request deletion, whichever occurs first. After this time, your personal information will be erased or anonymized so that it cannot be associated with you.

Occasionally, we may be required to retain your personal information for a more extended period to comply with legal or regulatory obligations, resolve disputes, enforce our terms and conditions, or maintain the security and integrity of our systems and services.

17. DATA BREACH RESPONSE

CTMFB and its Subsidiaries will take prompt action to contain and remediate a data breach involving your personally identifiable information. As required by law, we will tell you and the relevant supervisory authorities about the data breach, including its nature, the potential impact on your personal information, and the steps we will take to resolve the issue.

CONTACT US

If you have any questions, concerns, or requests related to the storage, security, or retention of your personal information, please do not hesitate to contact us at:

Data Protection Officer

Consistent Trust Micro Finance Bank

Email: [email protected]

We are committed to addressing your concerns and ensuring the highest level of data protection for your personal information.

UPDATES TO THIS PRIVACY POLICY

This policy may be subject to periodic updates. We will notify you of any changes to our use of your personal information by prominently posting an announcement on our website.

Combining all the privacy policy sections, we have created a comprehensive document outlining Consistent Trust Microfinance Bank's data collection, use, storage, and sharing practices. This policy ensures that you, as a user, are well-informed about your rights and the Bank's obligations to protect your personal information. Remember to stay up to date with any changes in the policy to ensure that you are always aware of how your data is being handled.

This policy was last updated on the 18th of January 2024.