Privacy Notice for NIB Limited Mobile App

National Investment Bank Limited (Hereinafter “NIB Limited, “we”, “us”, “our”) recognizes the importance of privacy and security of our customers’ personal information. We value the trust you place in us to protect your personal information and respect your right to privacy. While new technologies have dramatically changed the way information is gathered, used and stored, preserving customer trust and the privacy of personal information at NIB Limited remains a core objective. We believe it is important to make clear to our customers how information is being collected, used and shared at NIB Limited, the benefits such use provides, and the protections put in place against unauthorized access and use. We respect the privacy and the confidentiality of your personal information, and we appreciate the opportunity to do business with you

1. Our Privacy Principles

      i.         We will only collect, transfer, process and store your personal information and and contact list with your express permission unless legally required to do so, and will only use such information for the lawful purpose for which it is required.

     ii.         We will disclose the specific purpose for which we use, request and store your personal information and contact list.

    iii.         We will also keep a record of that personal information and contact list and the specific purpose for which we collect it.

   iv.         We will not use your personal information and contact list for any other purpose, other than that which we disclosed to you, unless you give us your express consent to do so, or unless we are permitted to do so by law.

2. What information do we collect?

      i.         We may collect information from you when you register on our mobile app. We may collect your name, email address, phone number, date of birth, gender, residential address, ID number, device ID, device location and contact list depending on how you choose to register on our mobile app and the consents you give. When you request a new account to be opened through the mobile app, we may ask you to upload your image for this purpose. 

     ii.         We may collect and combine information when you register for our mobile banking services including information you provide to us, device IDs, cookies, and other signals, including information obtained from third parties, to associate accounts and/or devices with you. We collect information about you when we receive it from third parties and affiliates. 

    iii.         We collect information from devices such as mobile phones and tablets about how you interact with our services and those of our third-party partners and information that allows us to recognize and associate your activity with your device. This information includes device specific identifiers and information such as IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings, and software data.

3. How do we use the information we collect?

      i.         Services

We use your data we have collected to authenticate you and authorize access to our Services on the mobile app. Typical services include customer registration, performing financial transactions, card management services, account management services, payment of bills. We use your personal data to enable you perform the services listed below;

a.    Your registration unto the Mobile App Service.

b.    Balance Enquiry: Check account balance 

c.     Account Summary: See all your account summary at a glance 

d.    Account Activity/Statement: View activities on your account.

e.     Funds Transfer (NIB TO NIB): Transfer funds from your NIB Account to another account in NIB 

f.      Domestic transfers: (NIB to other banks in Ghana): Transfer funds from one NIB account to an account in another bank within Ghana through GHIPSS instant transfer.   

g.    Check book request: Request for cheque book from NIB.

h.    Secured platform: Login password authentication and One Time Password (OTP) to effect funds transfer and Security questions

i.       Loan Application: Initiate the Loan Application process and follow up physically at any Branch of the Bank. 

j.      Change / Forgot Password: Ability to change and reset your password

k.      Branches and ATM Locator: Locate NIB ATM /Branches.

l.      Airtime Top-up: Purchase Airtime from Telcos.

m.   Mobile Wallet Services: (to wallet, to account, to other Mobile Money wallets) etc. 

n.    Bill Payment: Paying for certain subscription services. 

o.    School Fees Payment: Payment of fees to schools/institutions signed on to our service.

p.    Add Accounts: You may add other personal accounts to your account on the Mobile App. 

    ii.         Communication

We may contact you through email, short message services (SMS), phone call, and other ways through our Services, including text messages and push notifications. We may send you messages about the availability of our Services, security, or other service-related issues. We may also send messages about how to use the Services and network updates.

   iii.         Marketing

We may use data and content about our customers for invitations, promotions and communications solely for promoting our services.

   iv.         Customer Support

We may use the data needed to investigate, respond to and resolve complaints and Service issues

    v.         Security, Fraud and Investigations

We may use your data (including your communications) if we think it is necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our users.

 

4. Legal Basis for Collecting and Processing Data

NIB Limited may collect and process personal data only when we have a legal basis for doing so. Ghana’s Data protection legislation gives us a list of possible legal basis we can choose from. Due to the myriad of laws and regulations, a financial institution like NIB Limited is subject to, we may rely on different legal basis depending on the type of processing we are doing.

The following are the legal basis we may rely on in processing personal data on the NIB Mobile App:

                        i.         Consent given by our customers (whether express or assumed from your downloading and signing unto the App).

                       ii.         Performance of contract between the Bank and customers or third parties

                      iii.         Legal Obligation due to Government banking laws, regulations, statutory obligations and Court Orders 

                     iv.         Legitimate interest of NIB Limited.

At any point in the data processing cycle for the different services provided to our customers through this mobile app, we rely on a legal basis to do so.

5. How do we secure your information?

Protecting our systems and our users’ information is paramount to ensuring the NIB Limited brand, hence customers enjoy a secure experience and maintaining our users’ trust. We have taken the following measures to protect your information:

      i.         NIB Limited has technical, administrative and physical safeguards in place to help protect against unauthorized access, use or disclosure of customer information we collect or store. 

     ii.         We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information and or allow us to access your contact list. 

    iii.         We offer the use of a secure transmission, processing and storage services using standardized security safeguards. 

   iv.         All supplied sensitive/credit information are encrypted via transaction layer security (TLS) technology during transmission to avoid misuse of your data. Card Number (PAN), CVV and expiry date of any bank cards attached to the Mobile App are tokenized and stored on our backend systems at our data processor. We encrypt all sensitive personal and transactional data during processing and storage.

     v.         Your personal information may be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. Information such as PINs and passwords are not accessible to our authorized personnel.

 

6. How and whom do we share your information?

When you use or interact with our Mobile Banking services, you consent to the data processing, sharing, transferring and uses of your information as outlined in this Privacy Policy. You may also allow access to your contact list when necessary. NIB Limited shall endeavour to comply with all applicable data protection and privacy regulations in Ghana.

      i.         We share information concerning your transactions and experience within the NIB Limited and its key stakeholders, which includes our technology service providers who comply with the legal requirements, as far as NIB is concerned, with the data protection and privacy regulations in Ghana and the terms of the consent obtained from the customer. This sharing of information is intended only to facilitate the servicing of our customers’ accounts and to offer financial products and services we believe would be beneficial to our customers.

     ii.         Under all sharing arrangements, NIB Limited requires its service providers and marketing partners to keep such information under strict privacy regulations and prohibits them from disclosing such information to anyone for any other purpose. 

    iii.         We do not, and will not, share customer information with non-financial companies for the purpose of allowing them to market their products and services to our customers. 

   iv.         We do not disclose any non-public personal information about our customers to any other third parties, except as permitted or required by law or with the consent of the customer. 

     v.         This Privacy Policy does not govern collection and use of personal information by companies and or individuals not controlled, employed or managed by NIB Limited.

 

7. What choices do you have about your information?

      i.         Data Retention

We keep most of your personal data for as long as your account is active. We retain the personal data you provide while your account is in existence or as needed to provide you with our services. 

    ii.         Rights to Access and Control Your Personal Data

You can access your personal data from our services when you follow our procedures on data subject requests. You can always modify or update your personal data using the applicable menus in the app. 

    iii.         When you wish to deactivate yourself from this mobile app, you are required to send a request to NIB on info@nib-ghana.com. NIB Limited shall contact you within fourteen days (14) to validate the request for processing. A de-activated account may still have transactional history kept on our systems in accordance with financial laws and data retention policies of the regulator (Bank of Ghana) and the Bank.

   iv.         Account Closure

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security and prevent fraud. This may be for a period of six (6) years. Beyond that, we retain the right to continue storage or destroy the data without any recourse to you. Our retention of your personal information may also be based on; the length of time your personal information remains relevant, the existence of your consent and any other contractual terms we have with you. 

8. Are Children’s Privacy Protected?

Our services are for a general audience. We do not knowingly collect, use, or share information that could reasonably be used to identify children under 18 years without prior parental consent or consistent with applicable law.

9. How can you contact us?

If we decide to change our privacy policy, we will post those changes on the mobile app for your notice and consent when required. This policy will be effective from July 1, 2023.

If there are any questions regarding this privacy policy or a data breach incident you would like to report on, please contact us via info@nib-ghana.com