1. PERSONAL DATA

Personal data comprises all the details we hold or collect about you, directly or indirectly, your transactions, transactions you effect, financial information, interactions and dealings with us, including information received from third parties, the public domain, collected through use of our website and our electronic banking services. This Privacy Policy ("Policy") outlines Chukwuneye Microfinance Bank's ("CMFB", "we", "us", "our") personal data processing activities as a data controller. This policy covers the use, storage and dissemination of personal data we obtain from you or about you when you interact with us in the provision of the banking services you request, and during your use of the website. This policy also describes our processing of the personal data of individuals representing our business partners and suppliers.

2. Personal Data Collected & How It Is Used

Customers

• Vendors
• Website visitors
• Pre-hire medical assessment
• CCTV

3. Sharing of Personal Data

When we disclose personal information for a business purpose to external third parties, the same standards of security and confidentiality described in this policy will be upheld. These third parties act as data processors, acting solely on our instructions and on our behalf, and we establish contracts with them to ensure personal data is adequately protected. These contracts prohibit them from retaining, using, or disclosing any personal data for any purpose other than performing services under our direct instructions and in line with the purposes set out in this policy. The following describes some scenarios for which we may share personal data with a third party:

• Sharing for legal/regulatory purposes
• Sharing with service providers
• Cross border personal data transfer

4. Cookies

Cookies are information often including unique identifiers that a website saves on your device or computer when you visit. Chukwunenye MFB uses cookies collected to remember you, your preferences to customize and improve your experience on our site.

• Cookie types and Purpose

Temporary/Session Cookies help websites recognize you and the information provided when you navigate through a website. This type expires when you end the session by either leaving the site or closing the browser. Permanent/Persistent Cookies unlike temporary cookies remain in use until its expiration date or you delete it.

• Cookie Consent

In accordance to NDPR and other applicable regulations, we provide a cookie consent alert which gives you the option to opt-in or out.

5. Data Retention

We will retain and use personal data for as long as is necessary, in any case until the purpose of data collection is achieved and subject to any requirements to retain information in order to comply with any applicable law, regulation, professional requirements or standards.

6. Data Security

We have implemented appropriate technical and organizational security measures (such as Secure Sockets Layer (SSL) on our website and access controls on our information systems) to protect the personal data in our care, both during transmission and once we receive it. This includes measures to protect personal data from accidental or unauthorized destruction, loss, or alteration, and from unauthorized disclosure or access.

7. Personal Data Breach Management

CMFB takes reasonable and practicable security measures to ensure privacy. In the event of a data breach, we shall report such breach to the relevant authority and if necessary, affected individuals of personal data breach (where the personal data breach will likely result in high risks to the freedoms and rights of the individual) within 72 hours of becoming aware of the breach or being notified by any processor of a personal data breach. We will take steps to investigate and recover personal data and will ensure security controls are improved to prevent a re-occurrence of the data breach. Personal data breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes.

8. Individual Privacy Rights

Depending on location and applicable data protection regulation, an individual may be able to exercise some of the following rights regarding their personal data. An individual may be able to:

• request further details about how we process personal data
• request for a copy of any personal data which we hold
• withdraw consent to process personal data, where we rely on consent as a legal basis to justify personal data processing
• restrict/object to the processing of personal data
• request to update or delete personal data which we hold
• request to transfer personal data to a third-party provider of services (data portability)

Please note that we may ask individuals to provide us with the information necessary to confirm their identity before responding. We will aim to acknowledge enquiries within 24 hours and respond within one month unless otherwise required by law. Where permitted to do so, complying with your request may be subject to a fee to meet our associated costs.
We will consider all individual requests. However, we may not fulfil requests under circumstances where exemptions exist, which include a need to keep processing information to comply with a legal obligation. If such an exception applies, we will notify individuals when responding to their request.

 

9. Right to Amend the Privacy Notice

CMFB may periodically change its privacy policy to reflect updates to personal data processing activities conducted. Changes will become effective as of the published effective date. Hence, our privacy policies will be dated to reflect the most recent update.

10. Contact Us

Chukwunenye MFB is dedicated to protecting your privacy. If you have any questions or comments regarding this policy or any complaints concerning our compliance to it, please contact our Data Protection Officer at dataprotection@chukwunenyemfb.com or the Contact Centre at support@chukwunenyemfb.com or 08164302803. We will use reasonable efforts to respond promptly to requests, questions, or concerns.