Logo

PRIVACY POLICY

Background

We are Source Microfinance Bank Limited ('we', 'our', 'us'). This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information. You are not mandated to share any information with us, but to use our services, we 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).

What information do we collect?

Information you give us on our bank Applications.

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 of our bank Application to transact, you also share details of your transactions with us.

Additionally, we may request explicit permission to see other information like your address book, location, photos and data from your phone camera.

Details you give when you sign up for a Source MFB 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 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 our app, however, this will limit your full access to our products and services, as the identification and verification process 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 when you contact us through other channels

    If you contact us via other means than the web app, 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 Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us.
  • Information we get from third parties.

    As part of our Know Your Customer (KYC) process, we run checks on the identity information you supply during signup. We will try to verify the authenticity and validity of the identification document that you have provided, either directly from the issuing authorities or through authorized service providers.

    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.

    How do we use your information?

    The Nigerian Data Protection Regulations 2019 (NDPR) requires that we have a lawful basis for processing your personal information. At least one of the following lawful basis must apply before we process your personal information: contractual or legal obligations, legitimate interest of the data controller, public interest, vital interest of the data subject or consent.

    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 enjoy.
  • 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.
  • Legal Duty

    We have to ensure we are not breaching any laws by banking you by preventing illegal activities like money laundering, terrorism financing and fraud. To do this, we need 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).
  • 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.

    Consent

    For certain information, we will ask for your consent. We will ask for your consent to:

  • Market and communicate our products and services. You can always unsubscribe from receiving these if you want 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.
  • Who do we share your information with?

    In some instances, we will share the information provided to us with some third parties that we do business with, like card producers and credit bureaus, or with law enforcement agencies when required. Sharing of confidential customer information with these related third parties would be done in a secure manner.

    How long do we keep your data?

    We keep your information as long as you remain a customer of Source MFB and for any additional period as required under applicable law or regulations.

    These retention requirements supersede any right to erasure requests under applicable data protection laws, accordingly, we cannot erase your data in relation to your Source MFB Account until after this time period, however we can assure you that your data will be held safely and securely whilst under our supervision.

    When do we delete your data?

    We are basically 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.

    That means, if the data is not required anymore for statutory or contractual obligations, your data will be deleted.

    If you choose to delete your Source MFB account, we will delete any data you have previously given us, including the video of your face uploaded during the liveness check. This is however subject to the retention regulations that apply to such data as stipulated by the regulators.

    Bank Verification Number (BVN) Operations and Watch-List for the Nigerian Banking Industry

    You consent to us applying restrictions on your account and reporting to law enforcement agencies, including the Economic and Financial Crimes Commission (EFCC), the Nigerian Financial Intelligence Unit(NFIU), the Nigerian Police Force(NPF), e.t.c., if a fraudulent activity is associated with the operation of your account.

    You consent to us reporting to Nigeria Inter-Bank Settlement Systems Plc (NIBBS) for update on the Watchlist Database of the Nigerian Banking Industry and the CBN if a fraudulent activity is associated with the operation of your account.

    Communications via Internet

    To maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorized activities, Source MFB reserves the right to monitor all internet communications including web and email traffic into and out of its domains.

    What are your rights?

    You have the right to access and request the information that we have on you in our records. You may also ask us to delete your information on our record, restrict the way in which we use your personal information, ask that we update the personal information we hold about you or correct such personal information which you think is incorrect or incomplete, and we will grant this request as long as we are legally allowed to.

    You also have the right to object to us using your information for our marketing purposes or any additional services we may be offering you. Lastly, you may also withdraw any consent you have previously given us.

    How We Protect Your Information.

    We take appropriate technical and organizational measures to prevent loss, unauthorized access, misuse, modification or disclosure of information under our control. This may include the use of encryption, access controls and other forms of security to ensure that your data is protected. We require all parties including our staff and third-parties processing data on our behalf to comply with relevant policies and guidelines to ensure confidentiality and that information is protected in use, when stored and during transmission.

    Our security controls and processes are also regularly updated to meet and exceed industry standards.

    Where We Store Your Information

    All Personal Information you provide to us is stored on our secure servers as well as secure physical locations and cloud infrastructure (where applicable). The data that we collect from you may be transferred to and stored at a destination outside Nigeria or the European Economic Area (“EEA”). Whenever your information is transferred to another location, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy policy.

    How to make a complaint

    At Source MFB, 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@mysourcebank.com

    Writing to us at 167, Ipaja Road, Agege, Lagos.

    We will do our best to fix the problem within a reasonable time.

    Changes to this document

    This document will be reviewed on a yearly basis, or more frequently if occasioned by changes or amendment to applicable data protection regulations. If we make any changes, we will add a note to this page and if there are significant changes we will let you know by email.

    Source Microfinance Bank is Licensed by the Central Bank of Nigeria and all deposits are insured by the Nigerian Deposit Insurance Corporation.

    Products

    Company

    Source Microfinance Bank Limited - © 2024