Confidentiality Clause & Disclaimer COPYRIGHT
(C) 2021 BY SUNTRUST BANK All rights reserved.
These materials are confidential and proprietary to SunTrust Bank Nigeria Limited and no part of these materials should be reproduced, published in any form or by any means, electronic or mechanical, including photocopy, recording or otherwise or stored in any information storage or retrieval system of any nature nor should the materials be disclosed to third parties without the prior express written authorization of SunTrust Bank Nigeria Limited.
Background
At SunTrust Bank Nigeria Limited, we care about your privacy. This Online Privacy Policy explains what information we collect, how we collect, share, use, and protect your personal information when you visit or use this site and other services offered by us. As a customer of SunTrust Bank Nigeria Limited (hereinafter referred to as “SunTrust Bank”), be assured that we will keep protecting your personal information, and treating it with a high degree of confidentiality, as we have always done.
SunTrust Bank’s customers can make choices about how their personal information may be shared, and we encourage you to make choices that enable us to provide you with quality products and services that help you meet your financial needs.
Security of Your Personal Information
We take appropriate measures to keep your personal information with us secure and further ensure that such information are protected against loss, unauthorized access, misuse, modification, and disclosure. Your personal information with us remains secure in view of :
– The strict security measures and technologies we use to prevent fraud and to protect our systems from intrusion.
– Security controls and processes that are updated regularly to meet or exceed industry standards.
– Our employees are trained to strictly treat customer’s personal information with utmost care and high level of confidentiality.
Protecting Your Privacy
– To help you in protecting your personal information, we recommend the following:
– Regularly check your account balance and bank statements and report promptly any discrepancies to our nearest branch.
– Contact us immediately if you believe someone else may have access to your password, user ID, PIN, or other confidential information.
– Do not share confidential information via the telephone or online, unless you know or can verify the recipient.
– Ensure that your account records are properly disposed.
– Utilize a secure browser when conducting transactions online, close online applications when not in use, and ensure virus protection is regularly updated.
The Information We Collect
SunTrust Bank will only collect your information in line with relevant regulations and laws (GDPR, NDPR IFRS9 e.t.c)
What Information We Collect and Use
We collect and use information about you to administer our business and provide you with high quality financial products and services, all tailored to meet your needs. Such information we collect and keep are not limited to the under-listed:
o Name
o Telephone/Mobile Phone Number(s),
o Residential Address
o Personal e-mail address
o Date of birth
o Gender
o Occupation/Employment history
o CCTV footage
o Passport Photograph
o Bank Verification Number (BVN)
o National Identification Number (NIN)
And more sensitive personal data such as:
o Religion/faith
o Medical/Health record
o Biometric data etc.
o Personal financial statements, and other written or electronic communications reflecting information.
o Occupation
o Transactional account history including your account balance, payment records, and credit card usage.
o Information received from third parties, (e.g. government, regulatory, KYC Policy or credit bureau agencies).
Consent
– SunTrust Bank requires your explicit consent to process collected personal data, and by consenting to this privacy policy, you are giving us the permission to use/process your personal data specifically for the purpose identified before collection. o If, for any reason, SunTrust Bank is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used.
– You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the SunTrust Bank Nigeria Withdrawal of Consent Procedure.
How We Use Your Information
Any personal information provided by you to SunTrust Bank will be used for the purpose of providing and operating the products and services you have requested for and other related purposes which may include, but not limited to updating and enhancing our records, understanding your financial needs, conducting credit checks, reviewing credit or loan eligibility, prevention of fraud, debt collections, KYC purposes, and for purposes required by law or regulation.
Sending E-mails to SunTrust Bank
When inquiring or requesting information about a specific product or service, or in case of volunteering information using any of SunTrust Bank’s contacts, (e.g. General Inquiry form) we will use your e-mail address to reply, and we may store your e-mail address, your message, and our response for quality assurance purposes. We may also do this to meet our legal and regulatory requirements. We retain such records in accordance with out ‘Record Retention Policy’
Who We Share Your Information With
We may share the information about you and your dealings with us, to the extent allowed by law, only where it is necessary to disclose the working relationship with you. This will, in some circumstances, involve sharing sensitive personal data. The following third parties will receive your personal data as part of the processing activities.
– Central Bank of Nigeria (CBN)
– Nigeria Inter-Bank Settlement System (NIBSS)
– Nigeria Police Force (Police Character Certificate processing)
– Branches and Subsidiaries
– Regulators (CBN, NIBSS,
– External Auditors o Third party service providers
– Agents acting on behalf of SunTrust Bank.
– Any other body authorized by law to access your personal information.
– Staff as well as third parties with permitted access to your information are required to observe our confidentiality obligations.
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 and transactions, and similar information, through various means, such as account statements, Phone Banking, and Internet Banking. If you discover inaccuracies in your personal information, please promptly notify the branch or office where you do business, so that we can make the necessary updates or changes.
Your Individual rights
Right to be informed
To emphasize the need for transparency over the usage of personal data, we ensure fair processing of information typically through this privacy policy.
Rights to access
Individuals have the right to access information the Bank holds by requesting information the we hold about you or any other supplementary information on how we process your information.
Court Order
Judicial review.
In the event that SunTrust Bank Nigeria limited refuses your request under rights of access, we will provide you with a reason as to why. And you have the right to complain as outlined in clause 3.6 of the NDPR Act.
Right to restrict processing
Individuals have a right to ‘block’ or withdraw their consent to our processing of your information, which you can do at any time. When processing is restricted, we are permitted to store the personal data, but not further process it.
Right to rectification
Individuals are entitled to have personal data rectified if it is inaccurate or incomplete. If this personal data in question has been disclosed to third parties, they must be informed of the rectification where possible. The Bank must also inform the individuals about the third parties to whom the data has been disclosed where appropriate.
Right of erasure
Individuals have the right to request the deletion or removal of personal data where there is no compelling legal or regulatory requirement for its continued processing. The Bank will make sure that this right is protected.
Right to data portability
We will ensure that personal data is moved, copied or transferred easily from one IT environment to another in a safe and secure way, without hindrance to usability or transfer to another geographical location/country or to a third party where SunTrust Bank has satisfied that:
– the country of the recipient has adequate data protection controls established by legal or self-regulatory regime
– there is a contract in place that uses existing or approved data protection clauses to ensure adequate protection
– making the transfer under approved binding corporate rules
– relying on approved codes of conduct or certification mechanisms, together with binding and enforceable commitments in the foreign country or international organization to apply the appropriate safeguards in relation to data subject rights
– Provisions inserted into administrative arrangements between public authorities or bodies authorized by the competent supervisory authority
Right to object
Individuals have the right to object to our processing of their information in some circumstances such as automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling.
Individual Responsibility
Customers are responsible for making sure the information provided to the Bank is accurate and should inform the Bank on any changes as it occurs, this will enable us to update your information with us.
Changes to This Policy
From time to time, it may be necessary for us to amend our Privacy Policy without a recourse to you.
For More Information
Should you have any questions regarding this statement please contact dpo@suntrustng.com or call +234 908 733 1440 <br>
#1, Oladele Olashore Street,
Off Sanusi Fafunwa Street,
Victoria Island,
Lagos State, Nigeria.