Privacy Policy

Ogberuru Micro Finance Bank Limited (OMFB) is committed to protecting the privacy and security of the personal data of our customers, prospective customers, and visitors to our premises and digital platforms. This Privacy Policy explains how we collect, use, store, share, and protect your personal information in the course of providing our financial services to you, in full compliance with the Nigeria Data Protection Act (NDA) 2023 and other applicable regulations, including the guidelines issued by the Central Bank of Nigeria (CBN).

By using our services, visiting our website, accessing our digital platforms (including our mobile banking app), or visiting any of our branches, you acknowledge that you have read and understood the practices described in this policy.

1. Lawful Basis for Processing Your Personal Data

OMFB will only process your personal data when we have a lawful basis to do so. The primary lawful bases we rely on are:

• Performance of a Contract: Processing necessary for the execution of a contract with you or to take steps at your request before entering into a contract (e.g., opening an account, providing a loan).

• Legal Obligation: Processing necessary for compliance with a legal obligation to which we are subject (e.g., anti-money laundering laws, CBN directives, tax regulations).

• Legitimate Interests: Processing necessary for our legitimate business interests or those of a third party, provided such interests are not overridden by your fundamental rights and freedoms (e.g., fraud prevention, network security, direct marketing).

• Consent: In specific circumstances, we will rely on your explicit consent for certain processing activities (e.g., marketing communications). You have the right to withdraw your consent at any time.

2. What Personal Data Do We Collect?

We collect various types of personal data to provide and improve our services. This includes, but is not limited to:

• Identity and Contact Data: Name, address, date of birth, gender, email address, phone number, government-issued identification numbers (BVN, NIN, International Passport), and signature.

• Financial and Transactional Data: Account numbers, transaction history, payment records, credit history, bank verification number (BVN), and details of your interactions with our products and services.

• Biometric and Image Data: Photographs for account opening and KYC purposes, and CCTV footage collected for security and safety reasons when you visit our premises.

• Technical and Usage Data: IP address, browser type, device information, log data, and how you use our website and digital platforms.

• Data from Third Parties: We may receive information from credit bureaus, the National Identity Management Commission (NIMC), NIBSS, and other regulated entities for identity verification, credit checks, and fraud prevention.

3. Information of Minors

Our services are not directed at individuals under the age of 18. We do not knowingly collect data from minors. In instances where a minor's account is opened, it is done in strict compliance with CBN regulations and with the explicit consent and involvement of a parent or legal guardian.

4. How Do We Use Your Personal Data? (Purposes of Processing)

We process your personal data for the following purposes:

• Service Delivery: To open and manage your account, process transactions, execute payments, and provide customer support.

• Security & Fraud Prevention: To verify your identity, protect your accounts, monitor for and prevent fraudulent transactions, and ensure the security of our platform.

• Regulatory Compliance: To comply with our legal and regulatory obligations, including reporting to the CBN, NIBSS, and other relevant authorities.

• Risk Management: To assess creditworthiness, manage our risks, and develop our risk models.

• Communication: To communicate with you about your accounts, transactions, and changes to our terms or policies.

• Marketing: With your consent, to inform you about our products, services, and promotional offers that may be of interest to you.

5. How Do We Share Your Personal Data?

We may share your personal data with the following categories of recipients under strict confidentiality agreements:

• Regulatory and Government Bodies: As required by law, with entities such as the Central Bank of Nigeria (CBN), Nigeria Data Protection Commission (NDPC), law enforcement agencies, and courts.

• Service Providers: Trusted third-party vendors who perform services on our behalf, such as cloud storage, IT support, payment processing, and credit reference bureaus.

• Financial Institutions: Other banks and financial institutions to process transactions you have authorized (e.g., interbank transfers).

• Professional Advisers: Our auditors, lawyers, and consultants where necessary.

• Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets.

• With Your Consent: For any other purpose, we will disclose to you and seek your consent at the point of collection.

6. International Data Transfers

Your personal data may be transferred to and stored in countries outside Nigeria. Where such transfers occur, we implement appropriate safeguards as required by the NDPA, such as Standard Contractual Clauses, to ensure the protection of your data.

7. Data Retention

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. Our retention periods are determined based on the nature of the data and the legal or operational reasons for retaining it.

8. Your Data Subject Rights

Under the NDPA 2023, you have the following rights regarding your personal data:

• Right of Access: You can request a copy of the personal data we hold about you.

• Right to Rectification: You can request correction of inaccurate or incomplete data.

• Right to Erasure (Right to be Forgotten): You can request the deletion of your personal data under certain conditions.

• Right to Restrict Processing: You can request that we limit the way we use your data.

• Right to Data Portability: You can request the transfer of your data to another organization.

• Right to Object: You can object to the processing of your data based on our legitimate interests.

• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time.

• Right related to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling.

To exercise any of these rights, please contact us using the details in Section 13.

9. How We Protect Your Personal Data

We implement robust technical, physical, and organizational security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure networks, and regular security assessments. We also require our third-party service providers to adhere to similar security standards.

10. Use of Cookies and Tracking Technologies

Our website uses cookies to distinguish you from other users, improve your browsing experience, and analyze site traffic. You can control cookie settings through your browser. Disabling cookies may affect the functionality of our website.

11. Changes to This Privacy Policy

We may update this policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. The updated version will be posted on our website with a revised effective date. We encourage you to review this policy regularly.

12. Remedies for Violation and Timeframe for Redress

If you believe your data protection rights have been violated, please contact our Data Protection Officer immediately. We are committed to resolving any issues promptly and effectively. We will acknowledge your complaint and seek to address it within 30 days. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection Officer (DPO) at:

The Data Protection Officer

Ogberuru Micro Finance Bank Limited

Eke Market Square, Ogberuru

Orlu L.G.A., Imo State, Nigeria

Email: info@ogberurumfbltd.com.ng