Accion MFB Privacy Policy

Introduction

This Website privacy policy outlines your rights as a Data Subject, basis for collection of personal data from you on our website and Accion Microfinance Bank’s (“Accion”, “we”, “us”, “our”) personal data processing activities as a Data controller. Personal data means any information or details relating to you that we hold or collect whether directly or indirectly which comprises of name, identification number, address, your transactions, transactions you effect, financial information, interactions and dealings with us, including information received from third parties, the public domain, collected through use of our website and our electronic banking services etc. This policy covers the use, storage and dissemination of personal data we obtain from you or about you when you interact with us in the provision of the banking services you request, during your use of the website, and when you complete surveys or register for our webinars. This policy also describes our processing of the personal data of individuals representing our business partners and suppliers.

Policy Statement

The Bank will ensure security and protection of all data and utmost privacy of personal data in line with the requirements of NDPA. The Bank shall comply with all legislations and regulations applicable to its business and operations regarding data protection and privacy. All personal data shall be classified in line with Accion Microfinance Bank Information Classification Policy

Personal Data Collected & How It Is Used

Categories of Data Subjects

Personal Data Processed

Business/Commercial Purpose for Processing

Lawful Basis for Processing

Customers

Personal details such as your given name(s); preferred name(s); gender; date of birth / age; marital status; government issued number(s) such as tax identification number (TIN), bank verification number(s) and driving license number(s); nationality; lifestyle and social circumstances; photographs, images of passport data pages, driving licenses, and signatures; authentication data (including but not limited to, passwords, mother’s maiden name etc.)

Fulfilling our regulatory compliance obligations, including 'Know Your Client' checks, confirming and verifying individuals' identity; and screening against relevant sanctions lists and other legal restrictions other financial due diligence

Necessary step prior to entering into a contract or for the performance of a contract Necessary for compliance with a legal obligation for the performance of a contract

Family details such as names and contact details of family members and dependents. Contact details such as residential address; telephone number; email address; and social media profile details. Employment details such as business activities; names of current and former employers; work address; work telephone number; work email address

Provision of products and services to individuals: administering relationships and related services; performance of tasks necessary for the provision of the requested services i.e., (processing applications for products and services, processing transactions, disbursing loans, processing repayments); communicating with individuals concerning those services

Necessary step prior to entering into a contract or for the performance of a contract

Financial details such as billing address; bank account numbers; total assets and overall financial position, Debit/credit card numbers; instruction records; transaction details; and counterparty details.

Electronic marketing communications with individuals via any means (including via email, telephone)

Consent

Webinar Attendees

Personal and contact details i.e., name, age range, gender, email address, location, occupation

Communicating details of webinars with attendees

Consent

Survey Respondents

Personal details i.e., name, age range

Participation in survey/research purposes

Consent

Vendors

Name of contact personnel, telephone number, email address

To establish correspondence and to facilitate the provision of the goods and services for which the vendors are contracted.

Necessary step prior to entering into a contract or for the performance of a contract

Website Visitors

Name, Phone number, company, email, location

To address requests contained within the forms.

Consent

Customers

Unique ID, IP address, online activity

To generate statistics on website usage

Consent

CCTV

Physical appearance of individuals captured on video footage

This monitoring is conducted in the public interest toward ensuring a secure environment

Public interest

Sharing of Personal Data

When we disclose personal information for a business purpose to external third parties, the same standards of security and confidentiality described in this policy will be upheld. These third parties act as data processors, acting solely on our instructions and on our behalf, and we establish contracts with them to ensure personal data is adequately protected. These contracts prohibit them from retaining, using, or disclosing any personal data for any purpose other than performing services under our direct instructions and in line with the purposes set out in this policy. The following describes some scenarios for which we may share personal data with a third party:

Sharing for legal/regulatory purposes

We may share personal data with third parties such as appropriate security agencies and competent legal/regulatory authorities where disclosure is reasonably necessary to:

We may share personal data with third parties such as appropriate security agencies and competent legal/regulatory authorities where disclosure is reasonably necessary to: (a) comply with applicable legislation and regulation; (b) comply with legal process or a regulatory investigation (e.g., a subpoena or court order); (c) investigate potential violations; (d) detect, prevent or otherwise address fraud or security issues; (e) protect against harm to the rights, property, or safety of the Bank, our customers or the public, as required or permitted by law.

Sharing with service providers

We may share any personal data we collect with our service providers, which may include providers involved in cloud services payment processing, card development, conducting credit checks, or delivering advertising. We may also share personal data with service providers who otherwise assist us to manage the applications we process. We may also share personal data with external service providers who act as legal representatives or perform external audits.

Cross border personal data transfer

During business operations, personal data that we collect may be hosted, stored or otherwise processed in and transferred to third countries as we manage servers in various locations, and our processors operate worldwide. To ensure that these transfers are in line with permissible conditions outlined by the Nigerian Data Protection Regulation, we have taken appropriate and suitable safeguards to ensure that personal data will remain protected when cross-border transfers occur. These safeguards include transferring personal data to countries with adequate data protection regulations and ensuring that standard contractual clauses are in place to mandate that personal data is secured using best practices.

Cookies

Cookies are information often including unique identifiers that a website saves on your device or computer when you visit. Accion MFB uses cookies collected to remember you, your preferences to customize and improve your experience on our site.

S/N

Cookie Name

Cookie Type

Purpose

Cookie Expiration

CONSENT

Necessary

Used to detect if the visitor has accepted the marketing

category in the cookie banner.

2 years

_GA

Statistics

Registers a unique ID that is used to generate statistical data on how the visitor uses the website

2 years

_GAT

Statistics

Used by Google Analytics to throttle request rate

1 day

_GID

Statistics

Registers a unique ID that is used to generate statistical data on how the visitor uses the website

1 day

ADS/GA- AUDENCES

Marketing

Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitors online behavior across websites

Session

VISTOR_INFO1_ LIVE

Marketing

Tires to estimate the user’s bandwidth on pages with integrated YouTube videos.

179 Days

Session

YSC

Marketing

Registers a unique ID to keep statistics of what videos from YouTube the user has seen

Session

YT.INNERTUBE:: NEXTID

Marketing

Registers a unique ID to keep statistics of what videos from YouTube the user has seen

Persistent

YT.INNERTUBE:: REQUEST

Marketing

Registers a unique ID to keep statistics of what videos from YouTube the user has seen

Persistent

YTIDB::LAST_RE SULT_ENTRY_K EY

Marketing