Controlling and processing information: We are the controller of all personal information used in our business for our own commercial purposes.
Personal information: In this policy, when we use the term “personal information” we mean personal information as defined in the Data Protection Act Chapter 22:04 (“the DPA”) i.e. information about an identifiable individual that is recorded in any form including those listed in the DPA.
Sensitive personal information: In this policy, when we use the term “sensitive personal information” we mean special categories of personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, physical or mental health, sexual orientation or sexual life or criminal or financial record.
Our website may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or the security of these websites. Please check the relevant policy before you submit any personal information to these websites.
The personal information we collect will often be shared with us by you directly (e.g. when you apply for a new service or product) and this includes but is not limited to the following information:
We may also collect, store and use the following sensitive personal information:
If you do not provide personal information that we tell you is mandatory, it may mean that we are unable to provide you with the services and/or perform all of our obligations under our agreement with you.
We will also hold information we collect about you from other sources, and this will include:
If you give us personal information about other people (such as dependents or joint account holders) which we will use to provide services, or if you ask us to share that information with third parties, for example to provide payment initiation or account information services, then you confirm that you know that they are aware of the information in this notice about how we will use their personal information.
We use the information discussed above in a number of ways:
We may process the following sensitive personal information about an individual in the following circumstances:
If you have visited our website and/or social media pages, we may sometimes use the personal information you have provided to assess usage patterns and provide you with advertising we believe may be of interest to you.
The information about you collected by the Bank shall not be disclosed for purposes other than those stated above without your prior consent PROVIDED HOWEVER that we may share information in the following circumstances:
We may also disclose personal information we hold to third parties if we are under a duty to disclose or share an individual’s personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with that individual or other agreements; or to protect our rights, property, or safety of our employees, customers or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Safeguards: If we use a third party data processor to process personal information on our behalf, we will obtain contractual commitments to safeguard the security of the personal information to ensure that the third party only acts on our instructions when using that personal information and that the third party has in place appropriate technical and organisational security measures to safeguard the personal information.
As indicated above, we may use your personal information to provide you with information about services that may be of interest to you and we may contact you about these by email, text message, post or telephone call. This is known as direct marketing.
Examples of direct marketing may include:
We may also disclose your information to third parties (including our subsidiaries, our ultimate holding company and its subsidiaries) for required reporting throughout the Group, marketing and any other purpose which would enable us to serve better serve your needs.
You have certain rights regarding your personal information, subject to applicable legislation. These include the following rights to:
Your ability to exercise these rights will depend on a number of factors and in some instances, we will not be able to comply with your request e.g. because we have legitimate grounds for not doing so or where the right doesn’t apply to the particular data we hold about you. Please contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. We may modify or update this privacy notice from time to time.
We will keep your personal information for as long as we have a relationship with you and/or as long as we are legally required to do so. We will only retain information that enables us to:
We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process information and whether we can achieve those purposes through other means, and the applicable legal requirements.
The retention period is guided by governing regulations, and the Bank’s retention period is set as seven (7) years, following the end of the business relationship or, in the case of a one-off transaction, from the date of completion of that transaction . We will retain your personal information after this time if we are required to do so to comply with the law, if there are outstanding claims or complaints that will reasonably require your personal information to be retained, or for regulatory or technical reasons. If we do, we will continue to maintain privacy of same.
We may sometimes anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further reference or notice to you.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device if you agree. Cookies contain information that is transferred to your computer or device. We use the following cookies:
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you block cookies you may not be able to access all or parts of our website.