### Privacy Policy

1.0 Introduction

- Globus Bank Limited, located at Plot 722 Akinbo Savage, Victoria Island, Lagos State, Nigeria(hereinafter referred to as "Globus Bank"), serves as a Data Controller and occasionally as a Data Processor under the Nigeria Data Protection Regulation (NDPR) 2019 and the Nigeria Data Protection Act (NDPA) 2023. Globus Bank is committed to ensuring that all personal information entrusted to us is secure and kept confidential. We will continue to train and educate our staff on data protection and relevant privacy policies.
- Globus Bank's privacy policy describes the type of information that will be collected from our customers which will be provided when you visit the bank’s website and obtained from other sources. Also, the process to be used for collecting, using, maintaining, protecting, storing and disclosing of the information. By visiting our website, you consent to the practices described herein.

1.1 Whom the privacy policy applies

This privacy policy applies to the following individuals:

- •Employees and Contractors
- •Job Applicants
- •Customers (Internal and External)
- •Third-party Vendors
- •Website Visitors
- •ATM Users
- •On-site Visitors
- •Mobile App Users
- •CCTV Surveillance Subjects
- •Recipients of electronic or other online communication platforms that include or reference this Privacy Policy

1.2 What Information we collect

- As a financial institution that values respect for all, we are committed to collecting only the information required by relevant regulations and laws. If the personal data we collect falls within a special category of sensitive data, the Bank will rely on the individual’s explicit consent or, where applicable,compliance with a legal obligation as the lawful basis for processing

S/n | Data Subjects | Personal Data Processed
--- | --- | ---
1. | Employees and Contractors | Full name, contact Address, phone number, email address, company name and address, etc.
2. | Job Applicants | Name, address, phone number, email, passport photograph, CV/ resume, academic qualifications and certifications, employment history, and medical information.
3. | Customers (Internal and External) | Name, BVN, address, email, phone number, passport photograph, date of birth, marital status, employment details, next of kin details, biometric information, national identification number (NIN), international passport details, and driver’s license details.
4. | Third-party Vendors | Name, phone number, email address, organization name and address.
5. | Website Visitors | Name, phone number, email address, location. UniqueID, IP address, and browser information.
6. | ATM Users | Image snapshots
7. | On-site Visitors | Name, phone number, email address, location. UniqueID, IP address, and browser information.
8. | Mobile App Users | Username and password
9. | CCTV Surveillance Subjects | Physical appearance of individuals captured on video footage whenever you come into our premises or use our ATMs

1.3 Why we collect your information

- All personal information provided by you to Globus Bank will be used with your consent, compliance with various legal regulations and to enable us to meet your needs. They also include but are not limited to:

- • Creating an account with us
- • Providing, communicating and administering our services and events (such as sending updates, promotional materials, newsletters, and other marketing communications)
- • Providing customer support
- • Managing our relationship with you
- • Verifying your identity
- • Protecting against and preventing fraud and other unlawful activity, unauthorized transactions, claims, and other liabilities

1.4 How we collect your information

We can collect your information from various means that include but not limited to the following:

- •You provide the information when opening an account e.g. name, gender, contact information, Bank Verification Number (BVN), age, employment information, etc
- • When you use your login credentials to carry out online banking and mobile banking.
- • When you provide the requisite means of identification e.g. international passport, national identity card, National Identity Number (NIN), or passport photographs.
- •When we seek information from the relevant credit bureaus
- •When you apply for a loan or a card.
- •When we conduct the necessary regulatory investigations i.e. suspicious transaction reporting, KYC investigations etc.

1.5 Processing of Personal Data with Consent

- Globus Bank will, where applicable, require explicit consent from customers, visitors, and other relevant stakeholders before processing any collected personal data.
- Visitors to the Bank’s website are expected to review and understand the privacy notice and agree to Our terms and conditions. By consenting to the privacy policy, data subjects authorize Globus Bank to use and process their personal data for the specific purpose disclosed prior to collection
- Accordingly, any data subject, (customers, visitors, vendors, staff, or third parties) who do not agree to the collection and processing of their personal data will be unable to access Globus Bank’s services, where applicable
- In cases where data processing involves a child under 18, in compliance with NDPA 2023, Globus Bank must ensure that consent is given by the individual with parental responsibility (guardians or parents) and demonstrate that reasonable efforts were made to verify the child’s age.

2.0 Disclosure of Individual Information to third parties.

- •Globus Bank may share information about you and your interactions with us, as permitted by law. In cases where Globus Bank is legally required to disclose personal data in response to requests from government authorities or courts concerning national security or law enforcement, Globus Bank will not share individuals' data with third parties without first obtaining their consent.
- •Your Personal Identifiable Information (PII) will not be shared with third parties for their marketing purposes.
- •Additionally, in the event of a reorganization, merger, or sale we may transfer any, and all personal information we collect to the relevant controller. Some of the third parties may be located outside Nigeria, in which case, we will take all reasonable steps to ensure that your personal information is treated securely and in accordance with our Privacy Notice and applicable data protection laws (NDPR 2019 and NDPA 2023).

3.0 How we protect your information

- •We have put in place adequate security systems to protect and secure your personal data within our custody such as firewalls, data encryption technologies, anti-virus/malware, etc to ensure that your data is protected. from unauthorized access, alteration, disclosure, or destruction.
- •We ensure that our staff and all third parties processing data on our behalf, comply with relevant policies and regulatory guidelines to ensure the confidentiality and integrity of information in use, during storage, and transmission.

4.0 Retention of Data Records

- •All information held by Globus Bank is stored, retained, and disposed of in accordance with the NDPA 2023 guidelines on record retention and personal data management. Globus Bank will retain your personal data as long as it remains active in its systems and is necessary for delivering services.
- •As a regulated financial institution, Globus Bank will retain your personal data for ten (10)years after the termination of the relationship or as required by law. Transaction-related documents and data will be kept for a minimum of five (5) years, following CBN regulations.
- •Once personal data is no longer needed or exceeds the prescribed retention period, the Bank will either delete or destroy it from its systems, or securely archive it, ensuring your identity and privacy rights are protected.

5.0 Data Subjects Rights

- Your rights with respect to your personal identifiable information (PII) include:

- • Right to Rectification
  You are entitled to rectify any information provided where same is found to be inaccurate or incomplete.
- • Right to Deletion
  You have a right to request for the deletion of your personal data where same is no longer needed, where there is withdrawal of consent or where same should be erased in compliance with legal obligation.
- • Right to Restriction of Processing
  You have a right to restrict the processing of personal information i.e. withdraw the earlier issued consent.
- • Right to lodge a compliant
  Customers have the right to lodge a complaint with the relevant regulatory authorities such as Nigeria Data Protection Commission (NDPC), where your Personal Identifiable Information (PII) has not been managed properly.

6.0 Our Cookie Policy

- • Once you agree to allow our website to use cookies, you also agree to use the data it collects regarding your online preferences to enable us serve you better
- • Please note that cookies do not allow us to gain control of your computer in any way. They are strictly used to monitor which pages you find useful and which you do not so that we can provide a better experience for you.
- • If you want to disable cookies, you can do it accessing the settings of your internet browser.

7.0 Policy Changes

- This policy may be reviewed by us from time to time and such revisions will automatically become applicable to you. We also seek that you check our page frequently for any update.

8.0 Contact

- Globus Bank ensures customer’s privacy and is committed to protecting it through compliance with the data privacy policy.
  Kindly address all questions, comments, and requests regarding data privacy to Data Protection Officer.
  Email: [email protected] or Tel: 0201 466 1000, 0201 225 9000-1