Lead City Microfinance Bank Data Privacy Policy refers to our commitment to treat information of employees, customers/clients, vendors, stakeholders and other interested parties with the utmost care and confidentiality. With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights. As part of our operations, Lead City Microfinance Bank Limited collects and processes certain types of information (such as name, telephone numbers, address, date of birth, BVN etc.) of individuals that makes them easily identifiable. These individuals include current, past and prospective employees, vendors, customers/clients and their representatives, next-of-kin and other individuals whom Lead City Microfinance Bank communicate or deals with, jointly and/or severally (“Data Subjects”). Maintaining the Data Subject’s trust and confidence requires that Data Subjects do not suffer negative consequences/effects as a result of providing Lead City Microfinance Bank with their Personal Data. To this end, Lead City Microfinance Bank is firmly committed to complying with applicable data protection laws, regulations, rules and principles to ensure security of Personal Data handled by the Company. This Data Privacy Policy (“Policy”) describes the minimum standards that must be strictly adhered to regarding the collection, storage, use and disclosure of Personal Data and indicates that Lead City Microfinance Bank is dedicated to processing the Personal Data it receives or processes with absolute confidentiality and security. This Policy applies to all forms of systems, operations and processes within the Lead City Microfinance Bank environment that involve the collection, storage, use, transmission and disposal of Personal Data.
By using our website, application and other media, you hereby consent to our Privacy Policy and agree to its terms.
Cookies are small text files stored on your computer or mobile devices whenever you visit a website. Cookies have many uses, such as memorizing your preferences to tailor your experiences while on our site– or to help us analyse our website traffic. Lead City Microfinance Bank uses cookies to improve your experience while on this site. We would like to let you know a few things about our cookies. Apart from the data that you elect to disclose and share with us, we cannot access your computer or any other information about you with cookies. Although most browsers automatically accept cookies, you can amend your browser settings to disable cookies. This may however prevent you from fully experiencing the website as it was intended.
Personal Data must be processed lawfully, fairly, and in a transparent manner at all times. This implies that Personal Data collected and processed by or on behalf of The Bank must be in accordance with the specific, legitimate, and lawful purpose consented to by the Data Subject, save where the processing is otherwise allowed by law or within other legal grounds recognized in the NDPR.
Personal Data must be accurate and kept up-to-date. In this regard, Lead City Microfinance Bank: a) shall ensure that any data it collects and/or processes is accurate and not misleading in a way that could be harmful to the Data Subject; b) will make efforts to keep Personal Data updated where reasonable and applicable; and c) will make timely efforts to correct or erase Personal Data when inaccuracies are discovered
Lead City Microfinance Bank collects Personal Data only for the purposes identified in the appropriate Lead City Microfinance Bank Privacy Notice or any other relevant document or based on any other non – written communication (where applicable), provided to the Data Subject and for which Consent has been obtained. Such Personal Data cannot be reused for another purpose that is incompatible with the original purpose, except a new Consent is obtained.
Lead City Microfinance Bank limits Personal Data collection and usage to data that is relevant, adequate, and absolutely necessary for carrying out the purpose for which the data is processed. Lead City Microfinance Bank will evaluate whether and to what extent the processing of personal data is necessary and where the purpose allows, anonymized data must be used.
Lead City Microfinance Bank shall ensure that employees who collect, access and process Personal Data receive adequate data privacy and protection training in order to develop the necessary knowledge, skills and competence required to effectively manage the compliance framework under this Privacy Policy and the NDPR with regard to the protection of Personal Data. On an annual basis, The Bank shall develop a capacity building plan for its employees on data privacy and protection in line with the NDPR.
The Consents of minors (under the age of 18) will always be protected and obtained from minor’s representatives in accordance with applicable regulatory requirements.
Lead City Microfinance Bank may sometimes contact you with products or services that we think may be of interest or benefit to you. If you do not want to receive such promotional materials from us, you can opt out at any time by sending email or call.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, Lead City Microfinance Bank shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Nigeria Data Protection Bureau.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and making it available at our branches. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Lead City Microfinance Bank and its subsidiary. • Third-Party Sites and Services Lead City Microfinance 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 Lead City Microfinance 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 Media Platforms Lead City Microfinance Bank may interact with registered users of various social media platforms, including Facebook, Twitter, Instagram, and YouTube. 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.
The security of your data is important to us. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our services is at your own risk. You should only access the services within a secure environment.
We collect information about you from a variety of sources, such as: website visits, applications, identification documents, curriculum vitae, opening of accounts, personal financial statements, interactions with relationship managers, and other third parties (credit bureaus, payment gateways, other financial institutions…) and other written or electronic communication reflecting information such as your name, address, passport details, identification numbers, biometric information, telephone number, occupation, assets, income and any other information we deem necessary.
We may use your transactional account history including your account balance, payment records, and debit/credit card usage. We may also use 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 credit agencies. We may also collect other information such as video footages of you whenever you step into any of our offices or telephone conversations when you call any of our contact centre lines.
In order to achieve our goal of providing you with the best banking service, we sometimes collect certain information during your visits to perform certain tasks such as grant you access to some parts of our website or conduct research on your behavior on our site in order to improve our services. We will not disclose your information to any person outside our organization except as described in this Privacy Policy.
The collection and use of personal data by Lead City Microfinance Bank is guided by certain principles. These principles 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 unauthorized processing, and accidental loss, damage or destruction using adequate technical and organizational measures. Any personal information provided by you to Lead City Microfinance Bank will be used with your consent, or under the following under listed instances: • Cases where processing of personal data is required for the fulfillment of a contractual obligation. • Cases where processing of personal data is required for compliance with legal and/or regulatory requirements. • Cases where processing is required to protect your vital interest or that of any other natural person. • Cases where processing is required for an activity to be carried in significant public interest. • Cases where processing is required for legitimate interests of Lead City MFB or a third party insofar as this does not conflict with the requirements for the protection of your personal data.
Lead City Microfinance Bank in efforts to provide you with excellent products and services may need to outsource its product delivery, this will be done in line with relevant regulations and law. We may share your information in order to provide you with products or services you’ve requested. We may also share your information where we have a public or legal duty to do so, when we need it to conclude regulatory reporting and when we have requested and received your permission to share it. Your personal information can be used in the following: • Updating and enhancing Lead City Microfinance Bank records • Executing your instructions. • Establishing your identity and assessing applications for our products and services • Pricing and designing our products and services • Administering our products and services • Managing our relationship with you
We may share the information about you and your dealings with us, to the extent permitted by law, with the following: • Lead City Microfinance Bank Branches and Subsidiaries. • 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 Lead City Microfinance 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 • Lead City Microfinance Bank staff • Credit Agencies • Correspondent banks • Lead City Microfinance Bank’s strategic partners’/service providers – for the purpose of improving and providing our products and services to you. 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 any and all personal information we collect to the relevant third party.
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 confidentiality and that information is protected in use, when stored and during transmission. Our security controls and processes are also regularly updated to meet and exceed industry standards.
All Personal Information you provide to us is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). 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 policy.
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 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 is no longer needed for the purposes for which it was collected.
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 e-channels, branch network or Contact Centre, and provide the required documentary evidence, to enable us to implement the necessary updates or changes
If you have any questions or comments about this policy, you may contact our Data Protection Officer (DPO) by email at DPO@leadcitymfb.com or by calling our office on 09166994035. If you have any further questions or comments about us or our policies, email us at info@leadcitymfb.com or by visiting our office: Lead City Microfinance Bank Limited, 1A Oba Otudeko Avenue, Lagos-Ibadan Expressway, Tollgate Ibadan, Oyo State.
