Privacy Policy

Information we collect and use.

• Your personal information we collect may include the personal identifiable information (name, email address, username, phone number etc) and any other information required to enable you experience a suitable use of our website.
• Your personal information is collected from various sources and at different times, which include the following;
  • website visits,
  • during account opening and maintenance,
  • filling of request forms,
  • while making applications for access to services or enquiries or financial statements,
  • interactions with relationship managers,
  • through our third parties
  • subscription for newsletters on our website
  • other written or electronic communication containing personal information.
• Leverage True Depth Application Program Interface (API) Data on our Mobile Application using;
  • Camera module to record video for liveness check during the Know Your Customer (KYC) process to aid customer identity verification in line with regulation.
  • Camera intrinsic matrix, facial expressions, orientation, head position, and the position of the camera to verify video recording liveness.

  Video sharing with a third-party service solely to verify identity, after which it is deleted as required under the applicable laws and regulations.

  Third-party service is obligated to protect shared data in accordance with data protection laws and is not allowed to use data for any form of marketing or venture outside its agreement with us.

  You can opt out of the video capture process at any time

• We may also use
  • your transactional account history such as account balance, payment records, and card usage.
  • information received from third parties such as family, solicitors, friends or employers, website/ social media pages made public by you, government agencies, regulators, supervisory or finance agencies.
• We may also collect other information such as video footages of you whenever you use our ATMs, come into our branches or from phone conversations when you call our contact centre lines

Non-personal information collected by us.

To achieve our goal of providing you with great service, we collect information when you visit our website, which include information about your computer (or mobile device), including where available your IP address, operating system and browser type which shows statistical data about our users' browsing actions and patterns, and does not identify any individual. We use this information to better your experience and improve our services. We will not disclose your information to any person outside our organization except as described in this Privacy Notice.

Cookies

Cookies are small text files stored on the browser of your computer or mobile device used to access a website when you visit. They help that website remember information about your visit, which can both make it easier to visit the site again and make the site more useful to you

LOTUS Bank uses cookies to improve user experience while on the website. Kindly refer to our cookie policy for more information on cookies.

Use of personal information.

The collection and use of personal data by LOTUS Bank are guided by the extant data protection laws, which state that personal data should:

• be processed fairly, lawfully and in a transparent manner.
• be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with such purposes.
• be adequate, relevant and limited to what is necessary to fulfil the purpose of processing.
• be accurate and where necessary, up to date. In the event data is inaccurate, steps should be taken to rectify or erase such data.
• Not be kept for longer than necessary for the purpose of processing.
• be processed in accordance with the data subject's rights.
• be kept safe from unauthorised processing, and accidental loss, damage or destruction using adequate technical and organizational measures.

Any personal information provided by you to LOTUS Bank will be used with your consent, or when we have another lawful reason. These include.

• Instances where processing of personal data is required for the fulfilment of a contractual obligation.
• Instances where processing of personal data is required for compliance with legal and/or regulatory requirements.
• Instances where processing is required to protect your vital interest or that of any other natural person.
• Instances where processing is required for an activity to be carried in significant public interest.
• Instances where processing is required for legitimate interests of LOTUS Bank or a third party insofar as this does not conflict with the requirements for the protection of your personal data.

Purpose/Activity	Lawful basis for the processing of personal data
Provision of services, including opening an account with us.	Performance of a contractual agreement with you
Establishing your identity and managing your account.	Performance of a contractual agreement with you Consent from you
Updating and enhancing our records	Performance of a contractual agreement with you
Managing our relationship with you	Performance of a contractual agreement with you
Identifying and informing you about other services	Consent from you
Complying with our legal obligations and assisting government and law enforcement agencies or regulators	Compliance with a legal obligation Processing in the Public Interest Fulfilment of a legitimate interest

• Updating and enhancing LOTUS Bank's records
• Managing our relationship with you
• Executing your instructions
• Reviewing financing eligibility.
• Establishing your identity and assessing our products and services
• Pricing and designing our products and services.
• Administering our products and services
• Identifying and informing you about other products or services that we think may be of interest to you
• Managing our risks
• Identifying and investigating illegal activities such as fraud.
• Contacting you, for example in instances where we suspect fraud on your account or when the need arises to tell you about recent occurrences in the banking sector or some event(s) of significance.
• Conducting and improving our businesses and your experience with us.
• Preventing money laundering and terrorism financing activities.
• Complying with legal obligations and assisting government and law enforcement agencies or regulators/supervisors.
• Processing your job application if you apply for a job with us.

We may also collect, use and exchange your information in other ways permitted by law.

Automated Processing

We also use automated systems for decision making, for example, to make financing decisions, to carry out security, fraud and money laundering checks, or to process your data when you apply for some of our products and services.

This type of processing is carried out on a lawful basis, and you can contact us to request that automated processing be reviewed by a human being if you detect any inaccuracies in your personal data.

Information we share.

We may share the information about you and your dealings with us, to the extent permitted by law, with the following:

• LOTUS Bank Branches
• Regulators/Supervisors, Government Agencies/courts - It may be necessary by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for LOTUS Bank to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
• External Auditors.
• LOTUS Bank's Staff.
• Financial Agencies.
• Correspondent banks.
• Credit Risk Agencies.
• LOTUS Bank's strategic partners/service providers - for the purpose of improving and providing our products and services to you, verify identity, after which it is deleted as required under applicable laws and regulations. Your personal information will not be shared with third parties for their marketing purposes.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer all personal information we collect to the relevant third party.

Information about our customers and their usage of our website is not shared with third parties for their marketing purposes. We do not disclose any information about any user’s usage of our web site except in specific cases, and we do not share information with any unaffiliated third parties for marketing purposes unless you expressly give us permission to do so.

How we protect your information

We take appropriate technical and organizational measures to prevent loss, unauthorized access, misuse, modification or disclosure of information under our control. This may include the use of encryption, access controls and other forms of security to ensure that your data is protected. We require all parties including our staff and third-parties processing data on our behalf to comply with relevant policies and guidelines to ensure that information is protected in use, when stored and during transmission.

Your personal information with us remains secure because:

• We strictly ensure the use of security measures and technologies to prevent fraud and intrusion with our related parties.
• Ensure Security controls and processes are regularly updated to meet industry standards and beyond at related parties.
• Our employees are trained to respect the confidentiality of any personal information held by us

Where we have provided you (or where you have chosen) a password which grants you access to specific areas on our site, you are responsible for keeping this password confidential. We request that you do not share your password or other authentication details (e.g., token generated codes) with anyone.

Where we store your Information

All Personal Information you provide to us is stored on our secure servers - physical locations and cloud infrastructure. The data that we collect from you may be transferred to and stored at a destination outside Nigeria or the European Economic Area ("EEA"). Whenever your information is transferred to another location, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy notice.

How long we store your information.

We retain your data for as long as is necessary for the purpose(s) that it was collected. Storage of your data is also determined by legal, regulatory, administrative or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise.

Data which is not retained is securely destroyed when it is identified that it is no longer needed for the purposes for which it was collected.

Your rights

Your rights include.

• The right to access your personal information held by us.
• The right to rectify inaccurate or incomplete information.
• The right to withdraw consent for processing in cases where consent had previously been given.
• The right to restrict or object to processing of your personal data. We might continue to process your data if there are valid legal or operational reasons.

You also have the right to:

• Request that your personal data be made available to you in a common electronic format and/or request that such data be sent to a third party, with the applicable cost borne by you.
• Request that your information be erased. We might continue to retain such data if there are valid legal, regulatory or operational reasons.

To exercise any of your privacy rights, send an email to dpo@lotusbank.com

Maintain accurate information.

Keeping your account information accurate and up to date is very important. You have access to your account information, which includes your contact information, account balances, transactions and similar information through various means, such as account statements and Internet Banking.

If you discover any inaccuracies in your personal information, please promptly notify us, via our branch network or Contact Centre, and provide the required documentary evidence, to enable us to implement the necessary updates or changes.

Applicability of this privacy policy

LOTUS Bank comprises of LOTUS Bank branches in Nigeria nationwide. This privacy policy applies to all LOTUS Bank branches nationwide.

Third party websites and services

LOTUS Bank's websites, products, applications, and services may contain links to third-party websites, products and services. Our products and services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details is governed by their privacy practices and LOTUS Bank will not be liable for any breach of confidentiality or privacy of your information on such sites. We encourage you to learn about the privacy practices of those third parties.

Social medium platforms

LOTUS Bank may interact with registered users of various social media platforms, including Facebook, Twitter, Google+, LinkedIn and Instagram. 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 their terms of use and privacy policies carefully in order to better understand your rights and obligations about such content.

Social Events

LOTUS Bank hosts and sponsors some social and outdoor events which include (but are not limited to) the Abeokuta Marathon, and so on. Please note that there may be photos and videos taken while attending or participating in these events and by attending this event you agree to be photographed or filmed as this forms part of these events. These pictures and videos may also be posted to our social media platforms and is subject to the applicable social media platforms terms of use and privacy policy.

Maintaining accurate information

Keeping your account information accurate and up to date is very important. You have access to your account information, which includes your contact information, account balances, transactions, and similar information through various means, such as account statements, SMS Banking, Social Media Banking, and Internet Banking. If you discover any inaccuracies in your personal information, please promptly notify us, via our branch network or Contact Centre, and provide the required documentary evidence, to enable us to implement the necessary updates or changes.

Privacy of children

LOTUS Bank's Policy contains the following disclosure statement for children:
"LOTUS Bank respects the privacy of children. We do not knowingly collect names, email addresses or any other personally identifiable information from children. We do not knowingly market to children, nor do we allow children under 18 to open online accounts."

Promotional messages

LOTUS Bank may sometimes contact you with products or services that we think may be of interest to you. If you do not want to receive such promotional materials from us, you may opt out at any time.

Right to lodge a complaint

You have the right to complain to the privacy regulatory body "Nigeria Data Protection Commission (NDPC)" at any time if we use your personal information in a way that is unacceptable under the requirements of the Nigeria Data Protection Act (NDPA) or if you object to the way in which we use your personal information.

To contact the NDPC, visit their official website at: www.ndpc.gov.ng

Privacy policy changes

This policy may be revised on an ad-hoc basis to reflect the legal, regulatory and operating environment and such revised versions will automatically become applicable to you. We will post any revisions we make to our Privacy Notice on this page and such revisions becomes effective as at the time it is posted. We will notify you when any changes to our privacy notice have been made. We also encourage you to check this page from time to time for updates to this policy.

Contact

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to dpo@lotusbank.com

To contact our Data Protection Officer, kindly address your request to "The Data Protection Officer" at 39C Ahmed Onibudo Street, Victoria Island, Lagos, Nigeria.