## 1. Introduction
**Your Privacy Matters to Us**
Welby Trust Bank ("the Bank," "we," "us," or "our") is committed to protecting the privacy and confidentiality of your personal information. This Privacy Policy explains what personal information we collect, how we use it, with whom we share it, and the rights you have regarding your data when you interact with us through our branches, website, mobile applications, and other banking channels .
By opening an account with us, accessing our services, or using our digital platforms, you consent to the collection, use, and processing of your personal information in accordance with this Privacy Policy .
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## 2. Information We Collect
### 2.1 Personal Information You Provide
We collect personal information you provide directly to us when you:
- Apply for or open an account
- Apply for a loan or other financial product
- Subscribe to our banking services (online banking, mobile banking, ATM cards, etc.)
- Complete forms, surveys, or contest entries
- Contact our customer service or visit our branches
This information may include:
- **Identity Data**: Name, date of birth, gender, nationality, signature, and identification documents (passport, driver's license, national ID, or similar)
- **Contact Data**: Postal address, email address, phone number(s)
- **Financial Data**: Bank account details, payment card information, income, employment details, and credit history
- **Credentials**: User ID, password, PIN, security questions, and biometric identifiers used for authentication and account access
- **KYC Data**: Bank Verification Number (BVN), Tax Identification Number, and other information required for regulatory compliance
### 2.2 Information We Collect Automatically
When you use our digital platforms (website, mobile app, ATM, etc.), we may automatically collect:
- **Device Information**: IP address, device type, operating system, browser type, unique device identifiers (MAC address, IMEI number)
- **Usage Data**: Pages visited, time spent on pages, links clicked, transaction history, and navigation patterns
- **Geolocation Data**: Location-based information from your mobile device (with your permission) to provide location-based services
- **Cookies and Tracking Technologies**: We use cookies, web beacons, and similar technologies to enhance your experience, analyze usage, and deliver relevant content
### 2.3 Information from Third-Party Sources
We may collect information about you from:
- **Credit Reference Agencies**: To assess your creditworthiness and verify your identity
- **Publicly Available Sources**: Social media platforms (to the extent you choose to make information public), government databases, and other lawful sources
- **Marketing and Research Companies**: To better understand customer preferences
### 2.4 Sensitive Personal Information
We may collect sensitive personal data, including:
- Biometric data (e.g., facial images, fingerprints, typing patterns) for fraud prevention and authentication
- Racial or ethnic origin, religious or philosophical beliefs, health data (only where required or permitted by law)
- Criminal records or ongoing investigations for due diligence purposes
We process sensitive personal data only where:
- We have obtained your explicit consent, or
- It is necessary for legal or regulatory compliance, or
- It is necessary to establish, exercise, or defend legal rights
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## 3. How We Use Your Information
We use your personal information for the following purposes:
| **Purpose** | **Description** |
|---|---|
| **Providing Products and Services** | To open and manage your accounts, process transactions, disburse loans, issue cards, and deliver services you have requested |
| **Verification and Security** | To verify your identity, prevent fraud, detect unauthorized activities, and comply with anti-money laundering (AML) and Know Your Customer (KYC) obligations |
| **Customer Service** | To respond to your inquiries, resolve complaints, and provide support |
| **Risk Management** | To assess creditworthiness, manage risks, and make informed lending decisions |
| **Marketing and Communications** | To send you promotional offers, product updates, and relevant information (with your consent where required) |
| **Analytics and Improvement** | To analyze usage patterns, improve our products and services, and optimize user experience |
| **Legal and Regulatory Compliance** | To comply with applicable laws, regulations, court orders, and regulatory requests |
### 3.1 Legal Basis for Processing
We process your personal information based on one or more of the following legal grounds:
- **Performance of a Contract**: Processing necessary to provide you with our products and services
- **Legal Obligation**: Processing required to comply with legal and regulatory requirements
- **Legitimate Interests**: Processing for our legitimate business interests (e.g., fraud prevention, improving services) where your rights and interests do not override these interests
- **Consent**: Processing for specific purposes where you have given us your explicit consent (e.g., marketing communications)
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## 4. How We Share Your Information
We may share your personal information with the following parties:
- **Affiliates and Subsidiaries**: Within the Welby Trust group of companies, where necessary to provide services or for internal business purposes
- **Third-Party Service Providers**: Companies that perform services on our behalf, such as IT support, payment processing, credit reference agencies, marketing, and document storage. They are contractually obligated to safeguard your information and use it only for specified purposes
- **Regulatory and Law Enforcement Authorities**: When required by law, court order, or regulatory request
- **Fraud Prevention Agencies**: To detect and prevent fraud, money laundering, and other financial crimes
- **Business Transfers**: In connection with a merger, acquisition, or sale of all or part of our business (we will notify you of any such change)
- **With Your Consent**: Where you have given us permission to share your information with third parties for specific purposes
We do **not** sell your personal information to third parties .
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## 5. International Data Transfers
As a global financial institution, we may transfer your personal information to countries outside your home country . These countries may have different data protection laws. When we transfer your data internationally, we take appropriate measures to ensure that your information is adequately protected, such as:
- Ensuring the recipient country has an adequate level of protection
- Using standard contractual clauses approved by relevant data protection authorities
- Implementing binding corporate rules
- Obtaining your explicit consent where required
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## 6. Data Security
We take the security of your personal information seriously. We maintain physical, electronic, and procedural safeguards that comply with applicable legal standards and industry best practices to protect your data from unauthorized access, use, alteration, and destruction .
Our security measures include:
- Encryption of sensitive data during transmission and storage
- Secure access controls and authentication mechanisms
- Regular security audits and vulnerability assessments
- Employee training on data protection and confidentiality
- Monitoring and oversight of third-party service providers
In the event of a data breach that may affect you, we will provide timely notification in accordance with applicable laws .
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## 7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, or reporting requirements .
The retention period varies depending on:
- The type of information
- The purpose for which it was collected
- Legal and regulatory requirements
- Business needs (e.g., to resolve disputes or enforce agreements)
Once your information is no longer needed, we securely destroy or anonymize it in accordance with our data retention policies .
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## 8. Your Rights
Depending on your jurisdiction and applicable data protection laws, you may have the following rights regarding your personal information:
| **Right** | **Description** |
|---|---|
| **Right to Access** | Request a copy of the personal information we hold about you |
| **Right to Rectification** | Request correction of inaccurate or incomplete information |
| **Right to Erasure** | Request deletion of your personal information where there is no compelling reason for continued processing |
| **Right to Restrict Processing** | Request restriction of processing in certain circumstances |
| **Right to Data Portability** | Request transfer of your data to another organization in a structured, machine-readable format |
| **Right to Object** | Object to processing for marketing purposes or where processing is based on legitimate interests |
| **Right to Withdraw Consent** | Withdraw consent for processing where consent is the legal basis |
| **Right to Lodge a Complaint** | Lodge a complaint with the relevant data protection authority |
### 8.1 How to Exercise Your Rights
To exercise any of these rights, please contact us using the details provided in Section 12. We may ask you to verify your identity before processing your request . We aim to respond to all valid requests within one month, although complex requests may take longer .
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## 9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to:
- Ensure our website and mobile app function properly
- Remember your preferences and settings
- Analyze usage to improve our services
- Deliver relevant content and advertisements (with your consent where required)
You can manage your cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of our digital platforms .
For more details, please refer to our separate **Cookie Policy**.
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## 10. Children's Privacy
Our products and services are not directed to individuals under the age of 18 . We do not knowingly collect personal information from children. If you believe we have collected information from a child without appropriate consent, please contact us immediately .
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## 11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance . We will notify you of any material changes by:
- Posting the updated policy on our website and digital platforms
- Sending you a notification via email or SMS (where we have your contact details)
- Displaying notices at our branches
The date at the top of this policy indicates when it was last updated. Your continued use of our services after any changes constitutes your acceptance of the updated policy .
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## 12. Contact Us
If you have questions, concerns, or complaints about this Privacy Policy or how we handle your personal information, please contact us:
**Data Protection Officer**
Welby Trust Bank
[Full Address]
[City, Postcode]
[Country]
**Email**: dpo@welbytrust.com
**Phone**: [Phone Number]
**Website**: www.welbytrust.com
### 12.1 Complaints to Regulatory Authorities
If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction .
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## 13. How You Can Help Protect Your Privacy
While we are committed to protecting your information, you also play an important role. Please follow these guidelines to safeguard your privacy:
- Keep your PIN, passwords, and security credentials confidential
- Do not share your login details with anyone
- Memorize your PIN and do not write it down or store it with your card
- Report lost or stolen cards immediately
- Regularly review your account statements and transaction history
- Report any unauthorized transactions promptly
- Be aware of your surroundings when using ATMs
- Never give your financial information over the phone unless you initiated the call
- Do not use the same password for multiple online accounts
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