1. Your Privacy is Precious
    1. You are precious and so are your data. Emeralds Microfinance Bank Limited (“Emeralds MFB” hereafter) therefore guarantees the protection and privacy of your personal data. It shall not be released to a third party except pursuant to the law permitting the use of personal data in furtherance of national security, public, health, safety and order by agencies of the Federal, State or, Local government or those they expressly appoint to carry out such duties on their behalf; the investigation of criminal and tax offences; the collection and processing of anonymised data; and personal or household activities with no connection to a professional or commercial activity.
    1. We are committed to being transparent about how we collect, process, share and manage data about you (our customers and other natural persons where applicable).

2.  Emeralds MFB and You

  1. This Privacy Policy stipulates the bank’s approach to handling your data and your rights with regards to our collection, use, storage and sharing of your personal data which may be collected by Emeralds MFB in the course of providing you with exceptional products and services, collectively referred to herein as Emeralds MFB’s “services”, across all our delivery channels to meet your needs.
  2. This Policy covers the operations of Emeralds MFB in its head office, its branch at Ifo and all its services and products offered directly by any of its personnel, directors, and shareholders or sourced by you virtually and physically.

3.  Your Personal Data

  1. In the course of consuming services provided to you by Emeralds MFB to meet your needs, through this and other channels available, information you provide are collected via forms, phone calls, and correspondence by mail or emails, service point interfaces, as well as other channel enablers as might be available. The information we collect may include but not limited to: name,

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date of birth, telephone number, email address, nationality, tax identity number, bank details, bank verification number, services consumed, and services desired/required, mode of consumption, an identity number, location, photograph, preferences, IP address, MAC address, IMEI number, IMSI number, instructions, transactions relating to the services and other information relevant which constitute Personal Data.

  1. We may also use information about you collected by a third party and other service partners to ensure we provide you with better services. Since third party sources are not controlled by Emeralds MBF, Emeralds MFB is therefore not liable for how the third party uses it.

4.  Your Consent Required

Your personal information shall be required when needed to provide or improve our products and services for you. When we introduce new services and technologies, we shall ensure you understand and agree to any new ways in which your information is handled. Your consent shall then be considered given to Emeralds MFB for the processing of your personal data when:

  1. You complete any form, brochure or material issued by Emeralds MFB at any of our service points (mobile, online, in-branch, etc.) requesting for such personal information,
  2. You register, check or tick the acceptance box on any of our electronic platforms (Online or Mobile) relating to terms and conditions of any service or product offered by Emeralds MFB,
  3. You send a complaint, request, or other communication to Emeralds MFB,
  4. You use any service or product offered by Emeralds MFB.

5.  Use of Your Data

Emeralds MFB will process your personal information for the following purposes only:

  1. To conduct our business,
  2. To provide and offer our Products and Services to meet your unique needs, iii-          To update your records with us and improve your service experience,
  3. To communicate with you and manage our relationship with you.

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  • To fulfil the terms of any service contract(s) you might have with us, vi- To fulfil the demand of the Law,
  • To provide information to Credit Agencies,
  • To provide information to governmental agencies as provided by section 2.1 of NDPR Implementation Framework 2019,
  • To develop required statistics,
  • To comply with our Internal Policies,
  • To help our affiliates and members with whom we share your personal information. These individuals or/and bodies provide services and service- related activities such as collecting subscription fees for such services, notifying or contacting you regarding any problem with, or the expiration of such services,

6.  Cookies

  1. In line with paragraph 3(i) above, please note that Emeralds MFB may collect information about your computer (or mobile device), including where available or necessary your IP address(es), operating system and browser type for system administration or for our own commercial purposes. This statistical data about our users’ browsing actions and patterns on our digital channels does not identify any individual.
  2. We use cookies to give you a better and more inclusive banking experience. We only use your information in accordance with NDPR and other applicable regulations, as explained in our Cookie Policy.
  3. A cookie is a small text file that is sent to and stored in the browser directories of your device (smartphone or PC). Cookies can be used for a variety of purposes such as identifying users, keeping track of preferences and activity (e.g. Language, Currency, IP address used and Time zone).
  4. Types of Cookies and how we use them:
    1. Session Cookies: We use session cookies to store certain information while you use our site to make navigation and your experience on our site easier and more convenient. These cookies expire when you end the session (leave the site or close your browser).

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  • Persistent Cookies: are cookies that remain stored on your device until their expiry dates are exceeded or until they are deleted. They are used to store preferences so that the website can remember your choices the next time you access the site. They are used to provide a more customized experience to you whenever you access our website.
  • If you follow a link from our website to another website, please be aware that the owner of the other website will have their own privacy and cookie policies for their site over which we have no control.
  • We use google analytics to understand better how users interact with our site so as to track the performance of our site and provide inputs to further improve user experience.
  • We also use certain cookies for security purposes.
  • We use Zendesk cookies to understand how users interact with our live chat widget on the website.
  • Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you.
  • The cookies we use cannot read or search your computer or mobile device to obtain information about you or your family, or read any material kept on your device.
  • Various browsers have different methods of managing cookies (including disabling options). However, you should note that some cookies are essential and disabling them may result in some functions or services not functioning properly.
  • We may update our cookies policy from time to time. Kindly review this policy from time to time to ensure that you have up-to-date information.
  • Emeralds MFB may also disclose or share your personal information where it is necessary to enforce the terms and conditions of any of our Products and Services or any of our rights as well as to protect our operations and customers.

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8.  Information sharing and Disclosure

Emeralds MFB will not sell or let out your personally identifiable information to anyone. We may share or disclose your personal information to third parties where:

i-       We have your consent to share or disclose such personal information, ii-        We are required by law to share or disclose such personal information, iii-           We respond to subpoenas, court orders or other legal processes,

  1. We find that your actions on our electronic platforms violate any of our Policies for the purpose of investigations, reporting and enforcing any of our rights,
  2. Required for audit purposes.

9.  Information Protection and Retention

  1. Emeralds MFB will always ensure that your personal information is adequately protected. We have put in place processes and technologies to ensure that your personal information is not modified, lost, damaged or destroyed. We have trained personnel and professionals ensuring that your personal information is not disclosed and safe as stated in this policy.
  2. Where access and use of our electronic platforms requires authentication of the user, you shall be responsible for the use and safety of your authentication credential(s) including but not limited to User Name, Personal Identification Number (PIN), Password, One Time Passwords (OTP) and Tokens.
  3. We will retain your personal information for such length of time as may be required by law, regulation, the internal policies of Emeralds MFB.

10.      Your Rights Under This Policy Subsist

The following rights are available to you under this Policy:

  1. You may at any time request for access to your personal information held by Emeralds MFB or request that your personal information be made available to a third party. Your request may specify the format in which the information

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should be made available subject to Emeralds MFB having the capacity to provide the personal information in the requested format.

  1. You may request to update your personal information with Emeralds MFB at any time.
  2. You may elect to withdraw your consent at any time. Save where there is a legal or operational reason to continue with the processing of your personal data, Emeralds MFB shall discontinue the processing of your personal data upon receipt of your notice withdrawing consent. Such withdrawal however may impact Emeralds MFB’s ability to provide some products or services to you if your consent is mandatory for the execution for providing such services.
  3. Your right to withdraw consent extends to objecting or restricting the processing of your personal data by Emeralds MFB.
  4. You may request that your personal information be deleted. We may continue to retain such personal information as may be required for compliance with legal, regulatory or policy requirements.

11.      Remedies

Where you have concerns relating to the processing of your personal information by Emeralds MFB, or require any clarification on this policy, please notify us through or contact details provided below:

Email: info@emeraldsmfb.com.ng. We will respond to your concerns within 30 days of receiving your notice.

12.      Updates to this Policy

We may update this policy from time to time. Where there are changes in the way we use your personal information we will notify you by posting a prominent notice on our website.

13.      Changes to this Policy

We reserve the right to change this Policy at any time without notice to you. We will, however, notify you any time this Policy is amended and you shall reserve a right to remain our data subject or end your relationship with Emeralds MFB.