• • when you interact with us using our various social media platforms and/or through our online electronic messaging and chat option like Emails, Whatsapp etc;
• • when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
• • when you interact with our staff, including relationship managers and their assistants, example via telephone calls (which may be recorded), letters, fax, face-to-face meetings, electronic meetings and emails;
• • when your images are captured by us via closed-circuit television cameras (“CCTVs”) while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
• • • when you use some of our services provided through online and other technology platforms,
• • such as websites and apps, including when you establish any online accounts with us;
• • when you request that we contact you, or include you in an email or other mailing lists;
• • or when you respond to our request for additional Personal Data, our promotions and other initiatives;
• • when you are contacted by, and respond to, our marketing representatives, agents and other service providers;
• • when we seek information about you and receive your Personal Data from third parties in connection with your relationship with us, for example, from referrers, business partners, external or independent asset managers, public agencies or the relevant authorities;
• • through physical access, internet and information technology monitoring processes;
• • in connection with any investigation, litigation, registration or professional disciplinary matter, criminal prosecution, inquest or inquiry which may relate to you or any Connected Person; and/or;
• • when you submit your Personal Data to us for any other reason.

ix. DISCLOSURE OF DATA

We only share and disclose your information in the following situations:

Compliance with Laws:

We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital interests and Legal Rights:

We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Vendors, Consultants, and Third-party Service Providers:

We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work, which is necessary to provide the envisaged banking services. Examples include but not limited to: payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. For the purpose of service improvement, we may allow selected third parties to use tracking technology on the services which will enable them to collect data about how you interact with the services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. Business transfers: we may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company

x. DATA TRANSFER

Transfer of Data: The world today is interconnected and so is the provision of banking services. For instance, there could be many counterparties involved for a card transaction to be successfully completed. These include the personalization companies, the switching companies, processors, acquirers, merchants, and card schemes. Certain personal data will traverse these parties in the normal course of carrying out transactions. Save as related to the provision of banking services and meeting legal, regulatory, contractual, and other uses tangential or incidental to these, FFS Microfinance Bank will not share your personal data with a third party. Where it becomes necessary to do so, adequate security measures will be taken to protect the data from access by recipients other than those for which it is intended. All data we collect will reside in FFS Microfinance Bank’s computer systems in Nigeria. Where cloud services are used, adequate governance measures that apply to such cloud services will be complied with. FFS Microfinance Bank Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Transfer of Personal Data To Foreign Country

Where Personal Data is to be transferred to a country outside Nigeria, the Bank shall put adequate measures in place to ensure the security of such Personal Data. In particular, The Bank shall, among other things, conduct a detailed assessment of whether the said country is on the National Information Technology Development Agency (NITDA) White List of Countries with adequate data protection laws.

Transfer of Personal Data out of Nigeria would be in accordance with the provisions of the Nigeria Data Protection Regulation, 2023 (NDPR). The Bank will therefore only transfer Personal Data out of Nigeria on one of the following conditions:

(a) The consent of the Data Subject has been obtained
(b) The transfer is necessary for the performance of a contract between the Bank and the Data Subject or implementation of pre contractual measures taken at the Data Subject’s request;
(c) The transfer is necessary to conclude a contract between the Bank and a third party in the interest of the Data Subject;
(d) The transfer is necessary for reason of public interest;
(e) The transfer is for the establishment, exercise, or defense of legal claims;
(f) The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.

Provided, in all circumstances, that the Data Subject has been manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country, this proviso shall not apply to any instance where the Data Subject is answerable in duly established legal action for any civil or criminal claim in a third country.

The Bank will take all necessary steps to ensure that the Personal Data is transmitted in a safe and secure manner. Details of the protection given to your information when it is transferred outside Nigeria shall be provided upon the Data Subject’s request. Where the recipient country is not on the White List and none of the conditions stipulated in this Privacy Policy are met, the Bank will engage with NITDA and the Office of the Honourable Attorney General of the Federation (HAGF) for approval with respect to such transfer.

xi. DATA SECURITY

FFS Microfinance Bank will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example, no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites and take any necessary precautions.

We have implemented technical and organisational security measures to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to employees and authorised service providers who need to know such information for the purposes described in this policy; adopting security protocols on networks and systems; using email security settings when sending and/or receiving highly confidential emails; applying physical access controls such as marking confidential documents clearly and prominently, storing confidential documents in locked file cabinets; restricting access to confidential documents on a need-to-know basis; using privacy filters; disposal of confidential documents that are no longer needed, through shredding or similar means; using a mode of delivery or transmission of personal data that affords the appropriate level of security (e.g. registered post instead of the normal post where appropriate); confirming the intended recipient of personal data as well as other administrative, technical and physical safeguards.

While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be safe from intrusion by others, such as hackers. We engage various forms of security method like Encryption, Backup and Recovery and Access control, all together put in place to ensure the authentication of users and protection against data breaches. Our web servers are secured under a strong security system with our trained and trusted IT workforce who work hand in hand to ensure confidentiality of data of clients in accordance to our laid down procedures and compliance with the Nigeria Data Protection Regulation.

While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or electronic communication or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

If applicable, you undertake to keep your username, password and/or pin secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

xii. THIRD-PARTY SITES

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

xiii. DATA RETENTION

We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. In general, we will keep your personal data for between five (5) to ten (10) years (depending on the type of information, and in accordance with our internal policies) after your relationship with us is terminated. However, there may be circumstances that mean we must retain your personal information for longer. To determine how long it is necessary to retain your personal information, we calculate retention periods in accordance with the following criteria:

• the currency of your relationship with us and the types of products or services you have with us;
• the length of time it is reasonable to keep records to demonstrate that we have fulfilled our obligations to you and under the law;
• any limitation periods within which claims might be made;
• any retention periods prescribed by law or recommended by regulators, industry bodies or associations; and
• the existence of any relevant proceedings.

xiv. CHILDREN'S PRIVACY

Our services are not intended to be provided directly to children without parental consent. We will never knowingly collect personal information from individuals under the age of eighteen (18) years without first obtaining verifiable parental consent. If you are under the age of 18 you should not provide information to us. If we become aware that a person under 18 has provided personal information to us without verifiable parental consent, we will remove such personal information from our files.

xv. YOUR RIGHTS

The data protection laws provide individuals with the following rights:

• Right of subject access: The right to make a written request for details of personal information we hold about you and to request a copy of that personal information.
• Right to rectification: The right to have inaccurate information about you rectified.
• Right to erasure (‘right to be forgotten’): The right to have certain personal information about you erased.
• Right to restriction of processing: The right to request that your personal information is only used for restricted purposes.
• Right to object: The right to object to the use of personal information (including the right to object to marketing).
• Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable formats.
• Right to withdraw consent: You have the right to withdraw any consent you have given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of the use of your personal information before the withdrawal of your consent. These rights may not apply in all cases. If we are not able to comply with your request, we will explain why. In response to a request, we will ask you to verify your identity if we need to and to provide information that helps us to understand your request better. If you would like more information about your rights or to exercise any of your rights, please contact with the details below.
• Right to lodge a complaint with a supervising authority: You have the right to lodge a complaint with the National Information Technology Development Agency or a Data Protection Compliance Organisation licensed by the Agency.

xvi. GENERAL PRINCIPLES FOR PROCESSING OF PERSONAL DATA

The Bank is committed to maintaining the principles in the NDPR regarding the processing of Personal Data. To demonstrate this commitment as well as our aim of creating a positive privacy culture within the Bank, The Bank adheres to the following basic principles relating to the processing of Personal Data:

Lawfulness, Fairness, and Transparency Personal Data must be processed lawfully, fairly, and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of The Bank must be in accordance with the specific, legitimate, and lawful purpose consented to by the Data Subject, save where the processing is otherwise allowed by law or within other legal grounds recognized in the NDPR.

Data Accuracy Personal Data must be accurate and kept up-to-date. In this regard, The Bank shall:

a) ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to the Data Subject; b) make efforts to keep Personal Data updated where reasonable and applicable; and make timely efforts to correct or erase Personal Data when inaccuracies are discovered.

Purpose Limitation The Bank collects Personal Data only for the purposes identified in the appropriate The Bank Privacy Notice provided to the Data Subject and for which consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except a new consent, is obtained.

Data Minimization:

The Bank limits Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed.

The Bank will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized data must be used.