CRMFBANK’S PRIVACY POLICY
Consent and Scope
At Cross River Microfinance Bank Limited (“CRMFB” or the “Bank”), we are committed to (i) treating your personal information as private and confidential, and (ii) dedicated to ensuring that you are provided with the highest level of security whenever you interact with us. CRMFB conducts its business responsibly and ensures that customer information is securely collected, processed, and stored based on business requirements and conformity to regulatory requirements. Thus, this Privacy Policy sets out the basis for processing personal information that we collect from you or that you provide to us. We therefore advise you to carefully read and understand this Policy to understand CRMFB’s practices regarding your personal information and how we will treat same. By continuing to visit our website, you accept and consent to the practices described in this Policy regarding the collection, use, storage, processing, transfer, and disclosure of your personal information in accordance with this Policy.
Collectable Information
- We collect personal information directly from you and where lawful and reasonable, we may collect personal information about you from third parties and publicly available sources such as credit bureaus and government/regulatory agencies. We may also collect and use information received from third parties such as family, solicitors, friends, or employers, in addition to information that is publicly made available by you on any social media or digital platform.
- We also collect personal data electronically and manually. Personal data is collected electronically during visits to our website and/or registration to use our services or products, whilst we collect customers’ data manually when they complete our product and services registration forms. Similar data is also collected when customers or visitors visit our physical office location for inquiries or in order to establish a business relationship.
- The personal information that we may collect include (but are not limited to) your name, address, age, gender, account details, passport photographs, details of identification documents (for example, international passport or, driver’s license) bank verification number, biometric information, telephone number, email address, occupation, employment details (for example, the organization you work for and, your job title), family circumstances (for example, your marital status where you enter it in a form on our website or it appears in any documentation you provide to us), financial information (for example, your income, bank statements, where you enter such information in a form on our website or it appears in any documentation that you provide to us or authorize us to access from your bank and financial institutions), and other information that the Bank deems necessary for the provision of its services to you.
- We may also collect information on your transactional account history with us including your account balance, payment records, debit/credit card usage, as well as information such as video footage of you whenever you step into our office, and audio recordings of telephone conversations conversations whenever you call our customer care contact centre.
Purpose of Collection of Personal Information
- Your information will be collected and processed for the purpose of analyzing, disbursing, and/or processing any of our products or services, to you as well as for incidental and necessary actions to be taken in respect of same by the Bank to maintain our banking relationship with you. The Bank will also collect and process your personal information to comply with applicable regulatory requirements and to assist government and law enforcement agencies or regulators.
- The Bank will process your personal information in the course of its ordinary business with you, and your information will also be used for (i) updating and enhancing the Bank’s records (ii) establishing your identity and assessing applications for our products and services (iii) administering our products and services (iv) managing our relationship with you (v) managing our risks, as well as identifying and investigating illegal activities such as fraud, money laundering, terrorist financing or other potentially prohibited or illegal activities (vi) contacting you (vii) conducting and improving your business experience with us, or (viii) reviewing credit or loan eligibility and managing risks by the Bank
- We also collect personal information to: (i) improve our services to you by customizing your user experience (ii) measure the performance of our services to improve content and layout (iii) manage and protect our information technology infrastructure (iv) provide targeted marketing and advertising, service update notices, and deliver promotional offers based on your communication preferences, and in conformity with regulatory requirements.
Technical Methods Used to Collect and Store Information
The methods used by the Bank in the collection of personal information include (a) Physical and online forms, contracts, and agreements; (b) Surveys and Questionnaires; (c) Interviews; (d) Biometric tools (e) Closed-circuit television (CCTV) recordings, (f) Telephone Conversations and Voice Loggers, and (f) Website visits.
Your personal information will be retained and securely stored in accordance with relevant legal, regulatory, administrative, or operational requirements. All personal information you provide to us is stored on our secure servers, cloud infrastructure, and secured physical location. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards.
Cookies
Cookies are small text files that are placed on your computer or mobile device when you visit our website. Cookies can be used for a variety of purposes such as identifying users, keeping track of preferences and activity (e.g. language, currency, IP address used and time zone). Our website uses both (i) Session cookies and (ii) Persistent cookies.
Session Cookies enable you to move from page to page within our website and any information you enter to be remembered. A Session Cookie is deleted when you close your browser or after a short time. Persistent Cookies allow our website to remember your preferences and settings when you visit our website in the future. Persistent Cookies expire after a set period. Cookies are used in the following ways on our website:
- Google Analytics – we use Google Analytics to provide us with information about how you use our website. We use this information to compile statistics and to help us to improve our website and the services we offer.
- Tawk.to: we use these cookies to understand how users interact with our live chat widget on the website.
- Online application system – we use session cookies on our online application system to assist in the navigation around the site.
- Contact us – we use a session cookie on our contact us page to allow you to contact us via our website.
The use of cookies in these ways is to improve the functionality of our website and your experience when using it. Cookies can be disabled by changing the settings on your browser. If you decide to disable cookies, you may not be able to access some areas and functionalities of our website.
We use cookies to make your experience with us better. By continuing to use our website without changing the settings, you are agreeing to our use of cookies.
Third Party Access to Personal Information
The Bank is the recipient of your personal information. We will not disclose your personal information to external organisations that are not our service provider unless you give us your consent, where required by law to do so, or where necessary to the conclusion of the performance of our agreement with you. We use third parties who provide services on our behalf and will share your information with them, for example, a technology supplier may have access to your personal information when providing software support, or a company we use for a communications campaign may process the personal information of our contacts for us. Your information that we may share about your dealings with us, to the extent permitted by law are with the following:
- CRMFB’s employees
- Credit agencies
- Correspondent banks
- External auditors
- Regulators, supervisors, government agencies
Principles Governing Data Protection
The collection and use of your Personal Information by the Bank is guided by certain principles which include:
- Data Accuracy – CRMFB shall ensure that all data it collects and processes are accurate and not misleading. We will make reasonable efforts to (i) ensure that personal information is updated and kept up-to-date, and (ii) rectify and correct all inaccuracies detected regarding your personal information.
- Data Authorization – CRMFB shall ensure that personal information is obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purpose.
- Data Limitation – CRMFB shall collect personal information solely for the purposes identified in this Policy or any other relevant documentation provided to you and for which your consent has been obtained. Your personal information will not be used for any purpose other than that in respect of which it was obtained, save for where a fresh consent is obtained from you.
- Data Security – CRMFB shall secure personal information against all foreseeable hazards and breaches such as theft, cyber-attack, viral attack, dissemination, and manipulations of any kind.
- Data Confidentiality – CRMFB shall ensure that your information is kept safe from unauthorised access, processing, accidental loss, damage, or destruction using adequate technical and organizational measures.
- Data Retention – CRMFB shall ensure that personal data is retained and stored in line with relevant legal and regulatory guidelines and requirements. Your personal information will not be kept longer than is necessary for processing.
- Data Accountability – CRMFB shall ensure that your personal information is processed fairly, lawfully, and in a transparent manner. CRMFB will also ensure that anyone who is entrusted with your personal information is legally held accountable for such acts and omissions in contravention of this Policy and our data protection policy.
Available Remedies in the Event of Violation and Timeframe for Remedy
You have certain rights that you can exercise under certain circumstances in relation to your personal information that we collect and process. These are rights to:
- withdraw consent for processing your personal information in cases where consent has previously been given.
- have incomplete personal information completed.
- request rectification of inaccurate and incomplete personal data at any time.
- request deletion of personal information without delay and the Bank shall delete such personal information on any of the following grounds (i) your personal information is no longer necessary concerning the purposes for which it was collected or processed; (ii) you withdraw consent on which the processing is based; (iii) you object to the processing and there are no overriding legitimate grounds for the processing; (iv) your personal data has been unlawfully processed; and (v) the personal information is to be erased for compliance with a legal obligation in Nigeria.
- request access to your personal information that was provided to the Bank and have the same transmitted to another data controller where technically feasible.
- restrict processing of your personal information.
- object to the processing of your personal information and the right to data portability.
- be informed of the appropriate safeguards in place in a foreign country or an international organisation to which Personal Data is to be transferred.
The Bank shall upon receipt of a request relating to the processing of your personal information that it cannot provide, inform you without delay, no later than one month, of the reason(s) for not providing such information, and the possibility of lodging the complaints with the appropriate supervisory authority.
You can also contact the Bank’s Data Protection Officer at @crmfbank.com for any additional information about processing your personal information.
Third Party Sites and Services
Please note that CRMFB’s website may be linked to websites and applications that are not governed by this Privacy Policy. We encourage visitors to review the privacy practices on each of these other websites before disclosing any personal information.
Limitation of Liability Clause
The Bank will not be liable for any inaccurate personal information provided by you. Information collected by third parties, which may include such things as location data or contact details is governed by their privacy practices and CRMFB will not be liable for any breach of confidentiality or privacy of your information on such sites. We encourage you to learn about and review the privacy practices of those third parties, as CRMFB does not accept any responsibility for the use of your personal information.
Social Media Platforms
CRMFB may interact with you on various social media platforms. Please note that any content you post to such social media platforms (e.g. pictures, information, or opinions), as well as any personal information that you otherwise make available to users (e.g. your profile), is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review these information carefully in order to better understand your rights and obligations with regard to such content.
Changes to our privacy policy
We review our privacy policy periodically as well as when there is any substantial change to business or regulatory requirements, and relevant changes would be made to the policy, as and when required.
Contact Us
Customers that have concerns or questions about our privacy policy or would like to exercise their protection rights can contact us through the following channels
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139B Ndidem Usang Iso road Calabar, Cross River State Nigeria
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