Privacy Disclosure

Notice
Personal information is essential for running any organization successfully, but more important, is the handling of this information. At Sterling Bank, we respect individuals’ rights to privacy and the protection of personal information.

This Privacy Notice explains what personal information we collect online and at our physical locations, why the Bank receives such information, how the data is protected, and third parties with whom such information may be shared. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).

Please read our Privacy Notice carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal information on our website and other applications.

This Privacy Notice (the “Notice”) applies to all personal information processing activities carried out by Sterling Bank Plc. Sterling Bank is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this Notice, references to “we”, “us” or “our” are references to Sterling Bank while “you” and “your” means any business customer (a sole trader, company or partnership) or partner (suppliers or other organisations we do business with). Where an account, product or service has more than one holder, owner or signatory, “you” or “your” can refer to any, both or all of you.

Our principal address is 20 Marina Street, Lagos Island, Lagos.

What Personal Information Do We Collect?

When visiting or registering on our website, blog, online banking applications or conducting financial transactions at our physical locations, you would be required to provide personal information such as:

  • Personal details (e.g. name, date of birth, passport information or other identification information)
  • Contact details (e.g. phone number, email address, postal address or mobile number)
  • Biometric information (e.g. voice recognition when you call our call centre, as well as facial recognition for certain products)
  • Transactional details (e.g. payments you make and receive).
  • Financial information (e.g. bank account number, debit card numbers, financial history) including information you provide to deliver payment initiation services and account information services regarding accounts you hold with other providers.
  • Information about your family, lifestyle and social circumstances (such as dependents, marital status, next of kin and contact details).
  • Information about any other Sterling Bank products and services you currently have, you have applied for, or you have previously held.
  • Education and employment information
  • Visual images and personal appearance (such as copies of passports or CCTV images).
  • Online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example your banking profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile banking security authentication, mobile phone network information, searches, and site visits.

We may also process specific categories of information for specific and limited purposes, such as detecting and preventing financial crime or making our services available to customers. We will only treat particular types of information where we have obtained your explicit consent or are otherwise lawfully permitted to do so.

How We Get Information

Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions. It includes:

  • Information you give to us through our app, website or other touchpoints
  • Information that we receive from third parties – third parties who provide services to you or us, credit reference, fraud prevention or government agencies, and other banks.
  • Information that we learn about you through our relationship with you and the way you operate your accounts and or services, such as the payments made to and from your accounts.
  • Information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition).
  • Information that we gather from publicly available sources, such as the press, company registers and online search engines.

How do We Use Your Information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, provide account details at our physical locations or use other site features in the following ways:

  • Personalize your experience
  • Website and customer service improvement
  • Marketing and communication
  • Product designs
  • Transaction processing and customer profiling
  • Other business research, analytics and monitoring.
  • To administer a contest, promotion, survey or other site features

Who Will Your Information Be Shared with?

Sterling Bank processes your personal information if and only if there is a legal basis for doing so. We will NOT disclose your personal information to anyone except when:

  • We have your consent to share the information
  • The law requires it of us
  • We respond to subpoenas, court orders or legal process
  • We find that your actions on our websites violate any part of our Privacy Notice
  • We provide same to trusted third parties who assist us in conducting our business. We require that these parties agree to process such information based on our instructions and in compliance with the Privacy Notice and any other appropriate confidentiality and security measures.

Special categories of personal data (also known as sensitive personal data) are part of the information we collect from you. In particular, we may process, biometric data, for services that require it. Where we process such sensitive personal data, we will do so on the basis that it is necessary for reasons of substantial public interest, to establish, exercise or defend any legal claims. We will carry out the processing under applicable laws.


How long will we keep your information?

We will keep your personal data for as long as we have a relationship with you. Once our relationship with you has come to an end (e.g. following closure of your account or following a transaction), or your application for a product is declined or you decide not to go ahead with it, we will only retain your personal data for a period of time that is, depending on the type of personal data, and the purposes for which we hold that information. Also, the retention period will be in line with the requirements of regulatory bodies in Nigeria


Third Party Links

Occasionally, at our discretion, we may include or offer third party products or services on our application or website. These third-party sites have separate and independent Privacy Policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these sites.


How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information. Any data (including personal information) will be collected and stored on secure file servers.

Your Rights

An individual has certain rights regarding his or her personal information. However, these rights are subject to local law. You have the right to:

  • Request a copy of the personal information we hold about them
  • Request that we supply them with an electronic copy of the personal information that they or you have provided us with.
  • Inform us of correction to their personal information
  • Exercise their right to restrict our use of their personal information.
  • Exercise their right to erase their personal information.
  • Object to particular ways in which we are using their personal information

The exercising of these rights will depend on many factors and in some instances, we will not be able to comply with this request, e.g. because we have legitimate grounds for not doing so or where the right does not apply to the particular data we hold on that individual.


Cookies

Cookies are small pieces of information that a website stores on a visitor’s web browser to remind the site about the visitor the next time they visit the site. We do not store confidential or sensitive personal information in cookies.
To find out more about how we use cookies and what benefits they bring, please take a few moments to read this Cookie Policy.


Why and How We Use Cookies on Our Website

We use cookies to enhance our customers’ online banking session by making navigation easier and providing important security features. For certain applications, such as Online Banking, cookies are a requirement because they help protect the privacy of a customer’s transactions. For example, automatically terminating the online session if the customer forgets to log out.
Visitors to our website who have JavaScript enabled are tracked using Google Analytics. Google Analytics collects the following types of information from users:

  • Web browser used – software manufacturer, and version number
  • Operating system
  • Screen colours
  • JavaScript support
  • Flash version
  • Screen resolution
  • Network location and IP address
    • May include geographic
    • Hostname
    • Connection Bandwidth
  • May include geographic data
  • Hostname
  • Connection bandwidth
  • Time of visit
  • Pages visited and dwell time on these pages
  • Referring site
  • The referring website URL
  • Search engine query used

Google Analytics data is shared with Google. For more information on Google’s Privacy Policies, visit https://policies.google.com/privacy.

Cookie Category

Cookies used on this website can be classified into two categories namely:

  • Strictly Necessary Cookies: These cookies are essential to enable you to move around the website and use its features, such as accessing secure areas of the website
  • Functionality Cookies: These cookies allow the website to remember choices you make and provide enhanced, more personal features. We use these cookies to support the functionality of our live chat service. They are used in identifying visitors and enable a history of engagement to be recorded. The information these cookies collect cannot be used to track your browsing activity on other websites.

We do not use third party cookies on our website

Frequently Asked Questions

Do cookies mean I could get cold calls or junk mail?
We never use the data gathered through cookies to contact you via post, email or phone. We may use cookies to show you subtly tailored content on our website or other approved/trusted websites. The customised content may include things you might be interested in, but only about Sterling Bank products and services. You will never see advertising on our website from anyone other than Sterling Bank and our agents.

Can cookies pass on my personal information to others?

The only time we may use cookies to share personal information such as your name, address, telephone or email is when you have given us express consent to do so by applying for a product or service.

Do cookies compromise my security when I am logged on to Online Banking?

The cookies we use are completely safe. Many of them are used purely to provide important security features such as protecting your data and your accounts


What are your choices regarding cookies?

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. This can be done in your browser settings. Since browsers differ, we recommend that you access the Help Menu to learn the correct way to modify your cookies.

If you turn your cookies off, some of the features that make your site experience more efficient may not function properly

Where you can find more information about cookies

You can learn more about cookies at http://www.allaboutcookies.org/

Changes to this Privacy Policy
Based on the changing nature of privacy laws, user needs and our business, we may modify this Privacy Disclosure from time to time. Any change to our privacy policy will be communicated on our website and this will be effective as soon as published. Accordingly, we encourage periodic reviews of this Privacy Disclosure for awareness of any changes that may have occurred.

Updating our records
To keep your information with us up to date, you may contact us to review, change or delete the details previously supplied to us. You will be required to identify yourself and the information you wish to modify or remove. We reserve the right to decline this request if it is deemed impracticable or inappropriate.

Consent
By using our site or on-line banking applications, you consent to our Privacy Disclosure.

Contact Us
Sterling Bank Plc is committed to resolving your privacy complaints and concerns as quickly as possible and has procedures in place to help resolve any problems or complaints efficiently. If you have a concern, complaint or questions regarding this privacy disclosure, you may contact us through the following means:
  • customercare@sterlingbankng.com
  • (+234) 0700STERLING (070078375464)
  • 01-4484481-5

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