When we collect and use your personal data, we ensure that we look after it properly and use it in accordance with our below privacy principles:

• Personal data is processed fairly and lawfully;
• Personal data is obtained only for specific, lawful purposes;
• Personal data is adequate, relevant and not excessive;
• Personal data is accurate and kept up to date;
• Personal data is not held for any longer than necessary;
• Personal data is processed in accordance with the rights of data subjects;
• Personal data is protected in appropriate conditions.

We collect personal data directly from you:

• Via an enquiry;
• When you create an account with us;
• When you purchase any of our products or services;
• Through quotes and application forms;
• Via our telephone calls with you;

We will mainly use your personal data where we have a lawful basis for using it, and in the normal course of business to provide you with good services. These lawful basis include:

• Perform our contract with you;
• Compare andverify information for accuracy and update our records;
• Respond toyour comments and questions and provide customer service;
• For internal statistics and reporting purposes;
• Comply with legal obligation;
• To protect our customers, premises, assets and employees from crime, we operate CCTV systems on our premises which record images for security. We do this based on our legitimate business interests;
• Carry out a task in the public interest;
• Protect the vital interests of individuals; and/or
• Where we have your consent.

We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized.

To help us do our work, we may provide limited access to some of your Personal Information to the following third parties:

• Partners: Sometimes we collaborate with other organizations to deliver the Services. In these cases, we may share your name, contact information and other details you provided when making an account with our partners.
• Service Providers: We work with a wide range of third party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, bulk SMS services, and other non-governmental organizations.

When providing you with our banking services, including where we provide you with a mortgage, credit card or personal loans, we may make minor decisions about you by automated means. For example, we use technology that helps us identify the level of risk involved in customer or account activity (e.g. for credit, fraud or financial crime reasons), likewise, we do not make decisions based solely on automated processing (Including profiling).

• Via emails;
• When you provide your details to us either online or offline;
• When you engage with us on social media, and cookies; or,
• Credit reference agencies;

We will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested) and “legitimate interests”.

We collect information that you give us when you create an account, you contact us, or otherwise access or use our Services, any information you voluntarily submit to us. Specifically, the foregoing includes:

• Your personal information such as full name, address and other contact details, date and place of Birth, gender, and nationality. Identification data such as ID/passport number, specimen of signature.
• Tax information such as country of Residence, Tax Identification Number.
• Data received from the fulfillment of our contractual obligations.
• Financial data such as payment orders, transfer orders, credit data, data regarding your creditworthiness, credit scoring / ratings, documentation data (e.g. record of advices)
• Marketing and sales information, communications data (e.g. email data, third party information, corporate and media broadcasts, disputes/ litigation, other social data (e.g. data pertaining to social interactions between individuals, organizations, prospects and other stakeholders acquired from external data aggregators and information from fraud avoidance systems).
• Browser and device information and information collected through technologies such as cookies.
• With respect to the privacy of the children, mainly individuals under the age of 18, we may only collect their personal data provided that we have prior obtained their parents or legal guardians consent or unless otherwise permitted under law.

The personal information collected will only be retained for as long as necessary to fulfill the purpose for which it was collected, thus, as long as you are benefiting from our contractual services. We may keep it even longer, after termination of your business relationship or stop using our platforms, for instance, to respond to enquiries and complaints as required by law and regulations or to protect our interests. We won’t keep any information for longer than necessary and when we no longer need this information we will securely destroy it in accordance with our policies or fully anonymize it. You may have your data deleted, blocked or corrected (as long as compliant with applicable law).

As a data subject, you have the following rights in relation to our use of your personal data:

• Access to Personal Information: You may have the right to request access to your personal information.
• Rectification: You may have the right to request that we rectify inaccurate personal information concerning you and, depending on the purposes of the processing, you may have the right to have incomplete personal information completed.
• Erasure/Deletion: Delete or ‘forget’ it, make it anonymous, or restrict, stop using or sharing it (unless that would be against the law or in order to defend or establish our legal rights).
• Object: Right to object to our processing of your information, including direct marketing information.
• Data Portability: You may have the right to receive a copy of your personal information which you have provided to us, and you may have the right to transmit that personal information to another entity without hindrance from us.
• Withdraw Consent: Where our processing of your data is based on your consent, you have a right to withdraw your consent at any time. We will stop processing your data for that purpose (but your withdrawal of consent will affect the lawfulness of any processing that we have carried out based on your previous consent).
• Right to Complain: You may have the right to lodge a complaint to the local authority or other regulator if you are not satisfied with our responses to your requests or how we manage your personal information.