Privacy Policy

We're Confidence Microfinance Bank Limited (‘we’, ‘our’, ‘us’) and operate under the brand name Confidence or Confidence Bank. We're registered with the Corporate Affairs Commission with the number RC270471 and licensed by the Central Bank of Nigeria as a microfinance bank.

This Privacy Policy describes what information we collect about our customers, how we collect and use the information you share with us, and with whom we share that information. You don't have to share any information with us, but to use our services, we'll need some information from you. This policy also contains information about when we share your personal information with third parties (such as our service providers and credit bureaus). References to “you” or “your” throughout this policy shall refer to our customers (individuals or businesses) or persons who use or try to use any of our services through any of our platforms.

This Privacy Policy does not apply to services that are not owned or controlled by Confidence including third-party websites and the services of other Confidence partners, or merchants. This Privacy Policy applies to all forms of systems, operations and processes within the Confidence environment that involve the processing of personal data.

By using or accessing any of our services, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Your use of our services is also subject to our regular terms and conditions for account opening.

Should you disagree to abide by such terms, or if you revoke your consent to the processing of your personal data, your account will be disabled and you will no longer be able to access or interact with us on any of our platforms.

We collect and use any information you supply when you interact with any of our touch points. When you open an account with us, you share details like your names, Bank Verification Number (BVN), identification documents, address and pictures. By using our card or any Confidence Application to transact, you also share details of your transactions with us.

Other details we collect and what we do with them include:

• Details you give when you sign up for a Confidence account, like your BVN, names, date of birth, gender, phone number, residential address, and email address are in fulfillment of regulatory requirements.
• Your profile picture.
• We collect a video of your face during a liveness check done to confirm that you're the one opening or upgrading your Confidence account. We share this video with a third-party service provider to facilitate our liveness check.
• You may choose not to upload a video of your face on the Confidence app, however, this will limit what you can do with your Confidence account as the identification and verification will be incomplete.
• We will not share the video of your face that we collect during a liveness check with advertisers or anyone else other than the third-party service provider that facilitates the liveness check process.
• If at any time you choose to withdraw your consent for us to use this video for your liveness check, we will delete it. However, please note that this would affect your ability to use your account as certain services are dependent on us processing your video for the liveness check.
• Information you give us through the in-app chat so we can help you.
• To help protect you against fraud by tracking the location of your phone if you've authorised it.
• View your contact list for airtime purchases or access your SMS and related data.

The above is not exhaustive as we may need to collect additional information and data as our services evolve or as a result of changes in regulatory requirements.

Additionally, we may collect special or sensitive data about you such as gender/sex, personal identifiable information and sensitive financial information. Additionally and with particular reference to credit applications you make to us, from your device, we may collect your SMS logs, contacts, location and applications, to enable us to determine your creditworthiness, handle credit related fraud cases or comply with KYC requirements, as applicable.

If you contact us via other means than the in-app chat, we collect the following information so we can answer your questions or take action:

• The phone number you're calling from and information you give us during the call
• The email address you use and the contents of your email (and any attachments) sent to us.
• Public details from your social media profile like Facebook, Instagram or X (formerly Twitter), if you reach out to us via these platforms, and the contents of your messages or posts to us.

As part of our Know Your Customer (KYC) process, we run checks on the identity information you supply during signup. We will verify the authenticity and validity of the identification document that you have provided, either directly from the issuing authorities or through authorized service providers. We may also retrieve or verify information about you from public sources such as government databases.

Also, when you request for credit or lending related products and services, we run further checks with the licensed credit bureaus for eligibility checks in line with regulations.

The Nigeria Data Protection Act, 2023 (NDPA) and the Nigerian Data Protection Regulations 2019 (NDPR) requires that we have a lawful basis for processing your personal data. At least one of the following lawful basis must apply before we process your personal information:

• you have given us consent to do so;
• contractual or legal obligations require us to do so;
• legitimate interest of the data controller;
• processing is necessary for the performance of a task carried out in the public interest;
• processing is necessary to protect the vital interest of the data subject or of another natural person.

(a) Contractual Obligation

We collect certain data from you to fulfill the contract we have with you, or to enter into a contract with you. We use this data to:

• Give you the services we agreed to in line with our terms and conditions.
• Send you messages about your account and other services you use if you get in touch, or we need to tell you about something.
• Exercise our rights under contracts we've entered into with you, like managing, collecting and recovering money you owe us.
• Investigate and resolve complaints and other issues.

(b) Legal Duty

We have to ensure we aren't breaking any laws by offering our banking and related services. To do this, we need to process your data to:

• Confirm your identity when you sign up or get in touch.
• Prevent illegal activities like money laundering, tax evasion and fraud.
• Keep records of information we hold about you in line with legal requirements.
• Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).

(c) Legitimate Interest of the data controller

In some instances, we need to use the data you supply us for our legitimate interests. This means we're using your data in a way that you might expect us to, for a reason which is in your interest and doesn't override your privacy, interests or fundamental rights and freedoms.

Confidence will not share or disclose your personal data with a third party without your consent except as necessary to provide our services or as described in this Privacy Policy.

• Financial and Related Services and Payment Processing. When you provide payment data, we will share payment and transactional data with banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, or other related financial services.
• Third Party Service Providers — We share personal data with vendors or agents working on our behalf for the purposes described in this statement. The processing by such third parties shall be governed by a written contract with Confidence to ensure adequate protection and security measures are put in place.
• Related group companies and affiliates — We support and enable access to personal data across our subsidiaries, affiliates, and related companies in certain necessary circumstances.
• Law enforcement — We may access, disclose, and preserve personal data in accordance with applicable law and when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.
• Security, safety, and protecting rights — We will disclose personal data if we believe it is necessary to protect our merchants and others, operate and maintain the security of our services, or protect the rights or property of ourselves or others.

Confidence has set up secure adequate technical and organisational controls to protect the integrity and confidentiality of our customer's personal data. We protect our customer's personal data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration.

Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to our building and files and only granting access to Personal Information to only employees who require it to fulfil their job responsibilities.

We also maintain a data breach procedure in order to deal with incidents concerning personal data. You may contact our DPO upon becoming aware of any breach of your personal data. We will report any breaches that will compromise your rights and freedoms to the relevant regulatory authority within 72 hours of discovery.

As part of our service provision, we may rely on third-party servers, databases co-located with hosting providers, resident in foreign jurisdictions. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law wherever the data is located.

Where personal data is to be transferred to a country outside Nigeria, Confidence shall ensure adequate measures are put in place to ensure the security of such personal data. Any transfer of personal data outside of Nigeria will be in accordance with the provisions of relevant data protection regulations.

We and our partners use cookies and similar technologies on our website and on other platforms to help collect information and operate the site. We use cookies to: remember visitors to our websites; make your user experience easier; customise our services, content and advertising; help you ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety on our website.

Cookies are small text files placed by a website and stored by your browser on your device. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies.

Confidence will retain your personal information for the following periods:

• As long as reasonably necessary for the purpose of providing our services to you;
• For the duration your account is active and we have your consent;
• For the period needed to comply with our legal and statutory obligations;
• As needed to verify your information with a financial institution.

Under the Central Bank of Nigeria's Customer Due Diligence Regulations and Guidelines we are mandated to retain transactional records for at least five years following the completion of the transaction or the cessation of the legal relationship with a customer. Therefore, even after closing your Confidence account, we will need to retain certain personal data and transaction data to comply with these obligations.

We are storing and processing your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires us to store it. If the data is not required anymore for statutory or contractual obligations, your data will be deleted.

If you choose to delete your Confidence account, we will delete any data you have previously given us, including the video of your face uploaded during the liveness check. However, this is subject to the retention provisions of this policy.

At Confidence, we're extremely committed to respecting and protecting your personal information. If you have any worries, reservations or complaints about your personal information, please contact our Data Protection Officer by:

• Sending a message via the app
• Emailing us at support@confidencebank.ng
• Writing to us at 13 New Yidi Road, Ilorin, Kwara State.

After we receive any complaints from you, we will do our best to fix the problem.