Introduction

This page informs you of our policies regarding the collection, use, and disclosure of personal information when you use our Service and the choices you have associated with that data. We are committed to treating and using your personal information responsibly. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your Personal Information.

By using the Service, you agree to the collection and use of your personal information in accordance with this policy.

Data Collection and Use

We collect different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Information Submitted Through Our Platform or Website

Personal data, or personal information, means any information provided by you with which you can be identified. When you sign up to the platform and provide details such as your name, ID (passport data page, national ID), biometric data/BVN, Business Tax Identification Number, photograph, house address, email address, phone number, voice recordings (when you call our helpline), collateral information and other details which would enhance your Service experience.

Details about your banking activities and transactions with us

This includes information on any bank accounts you use, debit card numbers, financial history, information you provide to deliver payment initiation services, and account information services regarding accounts you hold with other providers.

Information on How You Use Your Device / Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, and the time spent on those pages amongst other diagnostic data.

When you access the Service by or through a mobile device this Usage Data may include information such as the type of mobile device you use, your mobile device's unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You can also refuse permission to read your device data by the Platform. However, if you do not accept cookies on your browser or allow permissions on your mobile device, our online service experience to you may be degraded and you may not be able to use some portions of our Service.

Examples of cookies we use:

• Session Cookies. We use Session Cookies to operate our Service. Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
• Preference Cookies. We use Preference Cookies to remember your preferences and actions across multiple sites.
• Security Cookies. We use Security Cookies for security purposes.

Information From Social Networks or Online Accounts

Information from any social media profiles or any accounts that you share with us.

Other Information

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.

Use of Collected Data

We use the collected data for various purposes such as to:

• Verify your identity when you access your profile on the service
• Respond to your requests and communicate with you
• Provide and maintain the Service
• Process service requests, design products, and profile customers
• Notify you about changes to our Service
• Allow you to participate in interactive features of our Service when you choose to do so
• Provide customer care and support for internal operations, including troubleshooting, data analysis, testing, research, security, fraud detection, and account management
• Provide analysis or valuable information so that we can improve the Service
• Monitor the usage of the Service
• Detect, prevent, and address technical issues
• Prevent fraud and enhance the security of your account or our service platform
• Comply with and enforce applicable legal and regulatory requirements, relevant industry standards, contractual obligations, and our policies
• Provide you with tailored content and marketing messages such as recommending services we believe you may be interested in

Automated Processing and Profiling Disclosure:

We may use automated processes, including profiling, to analyse your data for the purposes of product personalisation, credit assessment, transaction monitoring, fraud detection, and service improvement. Profiling means any form of automated processing of your personal data to evaluate, analyse, or predict aspects concerning your financial behaviour, creditworthiness, preferences, or reliability. Where an automated process produces a decision that has a legal or similarly significant effect on you such as a decision affecting your credit limit, account features, or access to services you have the right under Section 37 of the NDPA to: (i) request human review of that decision; (ii) express your point of view; and (iii) contest the decision.

To exercise any of these rights, please contact our Data Protection Officer using the contact details set out in this Policy. Where automated decision-making is necessary for entering into or performing a contract with you, or is authorised by applicable law, we will inform you of this at the relevant point in your user journey.

Disclosure of Data

Your information, including Personal Data, may only be accessed by employees that have a business reason to do so. We do not share your information with third parties for marketing purposes or any other purpose unless otherwise stated here or you have given your consent.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to a third party or a country without notice to you and adequate controls in place including the security of your data and other personal information.

We may disclose your Personal Data in the good faith and belief that such action is necessary and will not disclose your Personal Information to anyone except in any of the following circumstances:

• We have your consent to share the information
• To comply with a legal obligation
• To bring you improved service across our array of products and services, when permissible under relevant laws and regulations, by disclosing your personal information with Sterling Bank’s affiliated websites and businesses
• To protect and defend the rights or property of the Bank
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
• We find that your actions on our websites violate any part of our Privacy Policy; or
• We provide the 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 this privacy policy and any other appropriate confidentiality and security measures

Information From Locations Outside Nigeria

If you are located outside Nigeria and choose to provide information to us, please note that the data, including Personal Data, will be processed in Nigeria. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

How Long We Will Keep Your Information

We will keep your data for as long as we have a relationship with you, i.e. for as long as you use the service, remain validly subscribed to our newsletter, or partake in surveys. Once that relationship with you has come to an end (e.g. following closure of your account) or cancellation of your subscription to the Service, we will not gather or collect any new information about you.

Once the relationship is over, we will only retain personal data for a period of time. This period will vary depending on the purpose for which we hold that information and is subject to business or legal and regulatory requirements.

Security of Data

The security of your data is important to us but be aware that no method of transmission over the Internet, or method of electronic storage can guarantee 100% security at all times. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. You are responsible for securing and maintaining the privacy of your password and Account/profile registration information and verifying that the Personal Data we maintain about you is valid, accurate, and up to date. If we receive instructions using your account login information, we will consider that you have authorized the instructions and process your instruction accordingly and without incurring any liability for doing so. We reserve the right, in our sole discretion, to refuse to provide our services, terminate your subscription, or remove or edit content.

Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform specific Service-related roles, or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose outside of the service-specific need for which the data is required.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. You should note the privacy policy, terms of use, and security practices of the linked third-party website before providing any information on that website.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have erroneously collected Personal Data from children without verification of parental consent, we will promptly remove that information from our servers.

Information Update

You must notify us of any change in your Personal Information by updating your account profile through our Services. Any changes will affect only future uses of your Personal Information. Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

Your rights under this Policy

In accordance with the Nigerian Data Protection Act 2023, in certain circumstances, you have the following rights:

• The right to be told how we use your information and obtain access to your information
• The right to have your information rectified or erased or place restrictions on processing your information
• The right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests
• The right to give and withdraw consent to the processing of your personal information. We may however be unable to provide some services that you may request unless your consent to process your Personal Data is obtained
• The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller
• The right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects
• The right to lodge a complaint with the Nigeria Data Protection Commission
• The right to seek civil remedies from a court of competent jurisdiction

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We may let you know via email and/or a prominent notice on our Service, prior to the change becoming effective, and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Data Breach Notification

We maintain appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will comply fully with our obligations under Section 40 of the Nigeria Data Protection Act 2023, including: (a) notifying the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach; and (b) where the breach is likely to result in a high risk to your rights and freedoms, notifying you directly and without undue delay, in plain and clear language, and advising you of the measures available to mitigate any adverse effects.

We maintain a record of all personal data breaches in accordance with Section 40(8) of the NDPA. If you believe your personal data may have been compromised, or if you have any concerns about the security of your data, please contact our Data Protection Officer immediately using the contact details provided below.

Data Protection Officer

If you have any questions, complaints, or concerns regarding the processing of your personal data, or if you wish to exercise any of your rights under the NDPA, you may contact our Data Protection Officer at:

Data Protection Officer, Sterling Bank Ltd, Sterling Towers,20 Marina, Lagos,

Email: Dpo@sterling.ng

We will respond to all requests within a reasonable period and in any event within the timeframes required by applicable law.

Our Cookie Policy

Our website uses cookies to give you an enhanced user experience on our website and to personalize content tailored to your needs. Our website uses cookies to distinguish you from other users of the site. By continuing to browse the site, you are agreeing to our use of cookies.

What are cookies?

Cookies are small files that are stored on your computer's hard drive and which records your navigation of a website (if you permit) so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can be used to analyze traffic and for advertising and marketing purposes.

Changing your cookie preferences

If you want to check or change what types of cookies you accept, this can be done within your browser settings.

What are the cookies we use?

We use the following types of cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of the Gazelle website, e.g. to make payments on the site.
• Analytical cookies: These cookies allow us to recognize and count the number of visitors to our website and to see how visitors move around our website when they are using it. This helps us to improve the way our website performs and ensure that users of are able to easily navigate the website and access information and content seamlessly.
• Functionality cookies: We use these cookies to recognize you when you return to our website. This enables us to personalize our content to suit you. your needs, lifestyle, etc.
• Targeting cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• Session cookies: These are only stored on your computer during your web session and are automatically deleted when you close your browser. These cookies usually store an anonymous session ID allowing you to browse a website without having to log in to each page. Note that they do not collect any information from your computer.

How long do cookies last?

Some cookies are removed from your computer when you finish your session and exit the browser. Others stay for longer, sometimes indefinite, and are saved onto your device, so they're there when you return to the website.

Is it possible to reject cookies?

Yes. 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 if you do not want to receive cookies that are not strictly necessary to the functionality of, or features on our website. Check the "Help" menu of your browser to learn how to change your cookie preferences. Note however that if you disable cookies, some of the features that make our website more efficient, may not function properly on your device.

Third party cookies?

We may work with service providers who help us to provide you with a better, faster, and safer experience. These third parties are authorized to place third-party cookies on our sites or in our services, applications, and tools with our permission. With the exception of the use of such cookie technologies by our service providers or other authorized third-parties, we do not permit third-parties on our website to include or utilize any cookies, web beacons, local storage, or similar technologies for tracking purposes or to collect your personal information.