Privacy Policy

This policy covers personal information we collect through this website. Information you provide when you open an account, apply for a loan, or otherwise bank with us is governed by the terms and privacy notice you receive as part of that relationship [confirm whether a separate customer privacy notice exists, and link it here].

Information you give us. If you complete the contact form or write to us by email, we receive your name, email address, phone number, and whatever you choose to put in your message.

Information collected automatically. Our hosting provider records standard technical information when you visit — including your IP address, browser type, device type, the pages you viewed, and the time of your visit. This is used to keep the site running securely and is not used to build a profile of you.

Information from third parties. We do not buy personal information about you, and we do not receive it from data brokers.

This website uses essential cookies and local storage only — the small amount of data needed to keep the site secure, remember that you have seen our cookie notice, and make pages work as expected. We do not currently use analytics, advertising, or tracking cookies.

Some pages include content served by third parties — the map on our contact page is embedded from Google Maps, and links to RoutePay and the app stores take you to services with their own policies. These third parties may set their own cookies once that content loads or you follow those links. We do not control those cookies, and we recommend reviewing the relevant provider’s privacy policy.

You can block or delete cookies through your browser settings, though parts of the site may stop working correctly if you block essential cookies. If we introduce analytics or marketing cookies in future, we will ask for your consent before they are set and update this policy. Our cookie policy lists exactly what is stored.

We use personal information collected through this site to:

• respond to enquiries and provide the information you ask for;
• operate, secure, and improve the website;
• meet our legal, regulatory, and supervisory obligations, including those owed to the Central Bank of Nigeria and the NDIC; and
• detect and prevent fraud, financial crime, and misuse of our services.

Under the NDPA, we rely on the following lawful bases: your consent (which you may withdraw at any time); performance of a contract or steps taken at your request before entering one; compliance with a legal obligation; and our legitimate interests in running and securing our business, where those interests are not overridden by your rights.

We do not sell personal information. We share it only where necessary: with service providers who host, maintain, or support this website and our communications, under contracts requiring them to protect it; with regulators, law enforcement, and other authorities where we are required or permitted by law; and with professional advisers where needed to establish or defend legal claims.

Our website and communications infrastructure may be operated from servers located outside Nigeria [confirm hosting locations]. Where personal information is transferred outside Nigeria, we take steps to ensure it is protected to a standard consistent with the NDPA, including through contractual safeguards with our providers.

We keep enquiry correspondence for [confirm retention period, e.g. 24 months] unless it becomes part of a customer record, in which case it is retained for the period required by applicable banking regulations and record-keeping rules [confirm against CBN and NDIC requirements]. Technical logs are kept for [confirm period]. When information is no longer needed, it is deleted or anonymised.

We apply technical and organisational measures appropriate to the sensitivity of the information we hold, including encryption of data in transit, access controls, and staff confidentiality obligations. No website or system can be guaranteed completely secure, so please avoid sending account numbers, passwords, PINs, or other sensitive credentials through the contact form or by email — we will never ask you for them that way.

Subject to the conditions in the NDPA, you have the right to request access to the personal information we hold about you; to have inaccurate information corrected; to request deletion; to object to or request restriction of certain processing; to request a portable copy of information you provided to us; and to withdraw consent where we rely on it, without affecting processing carried out before withdrawal.

To exercise any of these rights, contact us using the details below. We will respond within the timeframe required by law. If you are not satisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC).

This website is not directed at children, and we do not knowingly collect personal information from children through it. Where a product involves a minor, information is collected through our account-opening process with the consent of a parent or guardian, in line with the NDPA.

We may update this policy from time to time. The date at the top of this page shows when it was last revised, and material changes will be highlighted on this page.

For questions about this policy or about how we handle your information, contact our Data Protection Officer at [DPO name and email address], or write to us at [confirm registered office address].

For general enquiries, use the details on our contact page.