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Mobile Banking Application Privacy Policy

Mobile Banking Application Privacy Policy

1. INTRODUCTION

This Privacy Policy explains how OmniBSIC Bank ("we," "us," or "our") collects, uses, discloses, and safeguards your data when you use our mobile application (the "App"). Please read this Privacy Policy carefully. By using the App, you agree to the terms and conditions of this Privacy Policy, including those concerning the collection and processing of information from your device. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE APP.

2. DEFINITIONS

• "Act 843" means the Ghana Data Protection Act, 2012.
• "Affiliate" refers to any entity or person that directly or indirectly controls, is controlled by, or is under common control with OmniBSIC Bank.
• "App" or "Application" refers to the OmniBSIC Bank Mobile Application (“OmniBSIC Mobile App”).
• "Last updated" refers to the most recent date this Privacy Policy was revised.
• "Personal data/information" means any information that identifies or can be used to identify a natural person.
• "Services" includes all services provided by OmniBSIC Bank via the App, such as account management, bill payments, and transaction alerts.
• "Third Party" refers to any entity other than you, us, or our affiliates.

3. WHAT IS THE JUSTIFICATION FOR PROCESSING YOUR DATA

We process your personal data based on the consent you provide when downloading and using the app. This consent grants us the right to process your information as outlined in this privacy policy. You are encouraged to thoroughly review our Terms and Conditions and Privacy Policy, which explain how your personal data is collected, used, and safeguarded.

Right to Withdraw Consent

You have the right to withdraw your consent at any time. This can be done by:

• Adjusting your app permissions through your device's settings.
• Deleting the app to stop future data collection.
Please note that while deleting the app stops future data collection, it does not retroactively erase data that has already been collected. Some data may be retained for legal or regulatory purposes, even after consent is withdrawn. Please contact our Data Protection Officer (DPO) at the contact details below Dataprotection@omnibsic.com.gh should you require any further details or clarification on managing your consent with us.

Managing App Permissions

After downloading the app, you may be asked for permission to access specific types of data like storage. If there are certain permissions you do not wish to grant, you can:

1. Modify your app permissions in your device’s settings.
2. Enable your device to automatically revoke permissions for unused apps.
3. Uninstall the app to stop further data collection.
If the app does not provide a direct option to delete your data, you can reach out to us to request the deletion of any collected information. However, please note that certain data may be retained due to legal or regulatory obligations.

4. WHAT DATA DO WE COLLECT ON YOU?

We collect three Categories of information through the App: Ordinary Personal Information, Special Category and Other Information.

Category Data Type Description
Personal Information Personally Identifiable Data

Financial Data

Location Data

Full name, email address, phone number, home address, date of birth, government-issued ID details (e.g. Ghana Card), and

Bank Account numbers, transaction details, card information, and loan data.

Precise geographic location if you enable location services for our Mobile App.

Special Category of Personal Data Biometric Data (Optional) If you enable biometric authentication (e.g. fingerprint or facial recognition), we collect and process biometric data solely for login and security purposes<
Other forms of data Usage Data App usage information such as features accessed, session length, and interaction with our services, the date and time the App accesses our servers, app version, operating system version, device model and manufacturer
Device Data Device type, mobile operating system, unique device identifiers (such as IMEI), mobile network information
5. HOW DO WE COLLECT YOUR PERSONAL DATA

Category Data Type
Using the App for banking transactions and activities When you perform any actions related to your accounts, transfers, payments, or other financial services
Applying for new products or services When you request or apply for new accounts, credit facilities, or any other products, we collect the necessary information to process your application.
Logging into the App Your login details, including credentials and associated metadata, are collected to authenticate your identity and maintain account security
6. USE OF DATA

We use your personal data collected through the OmniBSIC Mobile App for the following purposes:

Category Data Type
Account management Used for the setup and management of your account of the App with OmniBSIC Bank and to facilitate transactions, and manage your relationship with us.
Transaction Processing To process deposits, withdrawals, transfers, payments, and other banking services initiated through the OmniBSIC Mobile App.
Advertising or marketing (with your consent) We may use your information to send you promotional offers or updates, but only with your explicit consent is provided.
App functionality To improve the functionality of the app and offer you personalized services based on your preferences and past activities.
Analytics performance measurement This is to know how you use the app and how it performs. This helps us to monitor your feedback and improve on the app’s efficiency and user experience.
Communications To share with you news and notifications about the app, services and updates.
Fraud prevention, security, and compliance Used for fraud prevention, security, or compliance with applicable data protection and banking related laws.
Personalization Used to customize your app, such as showing recommended content or suggestions.
Customer Support To assist with customer service queries, resolve complaints, and improve user experience.
Location-based Services To provide location-based services, such as ATM locator functionality, if you have enabled location tracking.
We will not use your personal data for purposes other than those for which it was collected unless we receive your permission or are required by law.

7. DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

We take the confidentiality of your data seriously and will only share your data under specific circumstances:

• Third-Party Service Providers: We may share your data with vendors or partners who assist us in delivering banking services, such as payment processors, cloud storage providers, or customer support platforms.
• Regulatory and Law Enforcement: We may disclose your personal information to governmental authorities, regulators, or law enforcement as required by applicable laws, such as for anti-money laundering (AML) compliance.
• Affiliates and Partners: With your consent, we may share your information with other financial institutions or partners to provide additional services.
• Fraud Prevention Agencies: To combat fraudulent activities and enhance security, we may share data with fraud prevention and anti-fraud agencies.
• Under Compulsion of Law: We may disclose Personal Information if required by law, court order, or to assist in fraud investigations.
We do not sell or trade your personal information to third parties for advertising purposes.

8. How long we store your information

We retain your data for as long as is necessary for the purpose(s) that it was collected. Storage of your data is also determined by legal, regulatory, administrative or operational requirements. We only retain information that allows us to comply with legal and regulatory requests for certain data, meet business and audit requirements, respond to complaints and queries, or address disputes or claims that may arise. Data which is not retained is securely destroyed when it is identified that is no longer needed for the purposes for which it was collected.

9. TRANSFER OF USER’S DATA

Personal data may be transferred to third-party vendors who provide services on our behalf. We ensure such parties comply with applicable data protection legislation and the requirements under Act 843 and maintain data protection standards.

10. SECURITY MEASURES

We take the security of your Personal Information seriously and employ a variety of robust security measures to ensure its protection against unauthorized access, use, disclosure, or destruction. These measures are designed to meet the highest industry standards for data protection and privacy.

11.1 Data Encryption

• Encryption in Transit: All sensitive data transmitted through our App, including your login credentials and financial transactions, is encrypted using industry-standard Transport Layer Security (TLS) to ensure confidentiality.
• Encryption at Rest: Your data, once stored on our servers, is protected using strong encryption protocols, ensuring that even in the unlikely event of a breach, your information remains secure and unreadable.
11.2 Multi-Factor Authentication (MFA)

• We utilize Multi-Factor Authentication (MFA) to enhance the security of your account. This requires you to verify your identity using at least two different factors, such as your password and a one-time code sent to your mobile device, ensuring unauthorized users cannot access your account.

11.3 Continuous Monitoring and Threat Detection

• Our systems are continuously monitored 24/7 using advanced Intrusion Detection Systems (IDS) and Intrusion Prevention Systems (IPS) to detect, block, and respond to any malicious activity in real time.
• We conduct regular security audits, vulnerability assessments, and penetration testing to identify and rectify potential weaknesses in our infrastructure before they can be exploited.
11.4 Data Access Controls

• Access to your Personal Information is strictly controlled on a need-to-know basis. Only authorized personnel with legitimate business purposes are granted access to your data, and all access is logged and monitored.
• All employees handling sensitive data undergo background checks, and we enforce strict policies on data access, storage, and sharing.
11.5 Regular Security Updates

• We ensure that all our systems, including the App, are regularly updated with the latest security patches and software updates to protect against newly discovered vulnerabilities and threats. • Our App is continuously reviewed and updated to incorporate the latest in security protocols and best practices.

11.6 Secure Data Storage

• Your Personal Information is stored on secure servers located in controlled environments with physical and technical safeguards such as biometric access controls, firewalls, and intrusion prevention systems.
• We use secure cloud storage solutions that comply with international data protection standards to provide redundancy and backup, ensuring data is always recoverable even in cases of disaster. 11.7 Secure Transactions

• All financial transactions performed through our App are secured by end-to-end encryption and are monitored for any suspicious activity. In addition, we utilize tokenization to replace sensitive data with unique identification symbols that retain essential information without compromising security. • To enhance security, we partner with PCI-DSS-compliant payment processors to ensure that your payment data is handled securely.
11.8 Data Anonymization

• Where possible, we anonymize or pseudonymize your Personal Information to reduce the risk of exposure, ensuring that your identity remains protected even in cases of limited data access.
11.9 Incident Response and Data Breach Notification

• In the unlikely event of a data breach, we have a comprehensive incident response plan in place. This includes immediate steps to contain and mitigate the breach, notify affected users, and report the incident to relevant authorities in compliance with applicable laws.
• You will be informed promptly if your Personal Information is involved in any breach that poses a risk to your rights or privacy, and we will provide guidance on any actions you may need to take to protect yourself.
11.10 User Responsibility

• While we implement best-in-class security measures, your actions also play an important role in keeping your information secure. We recommend that you:
o Use strong, unique passwords for your account.
o Enable multi-factor authentication (MFA).
o Regularly update your device's operating system and the App to the latest versions.
o Refrain from sharing your login credentials with anyone.
o Immediately report any suspicious activity on your account.

We encourage users to safeguard their app login details, PINs, and any other sensitive information.

12. YOUR RIGHTS

As a user of the OmniBSIC Mobile App, you have several rights concerning your personal data:
• Access: You have the right to request a copy of the personal data we hold about you. Your right of access can be exercised by sending an email to Dataprotection@omnibsic.com.gh
• Correction: If any of your data is incorrect or outdated, you can request for corrections.
• Deletion: You can request that we delete your personal data, subject to legal obligations requiring retention (e.g., for anti-money laundering or tax laws).
• Portability: You have the right to request a copy of your data in a structured, machine-readable format for transfer to another service.
• Opt-out of Marketing: You can opt out of receiving marketing messages through the app settings or by contacting us directly.
• Restriction of Processing: You may request a restriction on the processing of your data if you believe the data is incorrect or has been unlawfully processed.
• To exercise these rights, please contact our Data Protection Officer (DPO) at the contact details below Dataprotection@omnibsic.com.gh
Provide proof of identity with your request. We will respond within fourteen (14) working days.

13. TERM, TERMINATION, AND DATA RETENTION

We retain your data for the duration necessary to provide Services and comply with legal requirements. Data may be retained for statutory periods, even if you discontinue use of the App.

14. LOCATION SERVICES AND TRACKING

The OmniBSIC Mobile App may request access to your location to provide features such as branch or ATM locators or to enhance security for certain transactions. You can disable location tracking through your device settings. Please note that disabling location services may limit certain features of the app

15. DATA RETENTION

We retain your personal information for as long as is necessary to provide our services or as required by law. Specifically:
• Transactional Data: Retained for as long as needed to complete the transaction and for a period afterward as required by regulatory and compliance obligations.
• Account Data: Retained for the duration of your relationship with us and beyond if required by law (e.g., anti-money laundering regulations).
• Deletion Requests: Upon receiving a valid deletion request, we will delete your data unless we are legally required to retain it.

16. COOKIES AND SIMILAR TECHNOLOGIES

The OmniBSIC Mobile App may use cookies and similar tracking technologies to enhance functionality and improve your user experience. These cookies may be used to:
• Store Preferences: Remember your preferences, such as language and login information.
• Performance Tracking: Track usage data to help us understand how the app is being used.
• Security: Ensure the secure operation of the Mobile App.
You can manage your cookie preferences through the app settings or device settings.

• CHILDREN’S PRIVACY

Our Mobile App is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children under 18 without parental consent. If we learn that we have collected personal information from a child under 18 without appropriate consent, we will take steps to delete the information.
• CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our services or legal obligations. Significant changes will be communicated via app notifications or email. Continued use of the Mobile App following any changes signifies your acceptance of the revised policy.
• PRIVACY POLICY REVIEWS

This policy may be revised as and when it may be required in order to to reflect the legal, regulatory and operating environment and such revised versions will automatically become applicable to you. We will upload any reviews we make to our Privacy Policy on this page and such revised policy becomes effective as at the time it is uploaded. We will notify you when any changes to our privacy policy have been made. We also encourage you to check this page from time to time for updates to this policy.

17. YOUR RESPONSIBILITIES FOR SECURITY

17.1 To ensure that you alone are able to access and give instructions on your accounts using the OmniBSIC Mobile App, you must at all times adopt and maintain the security procedures described in this Agreement and any relevant User Guide.
17.2 You must keep your Access Codes and Device safe and confidential. You should not share your Access Codes with any person including but not limited to a member of our staff, the police or to someone giving assistance on a technical helpdesk in connection with the service.
17.3 Whenever you choose an Access Code, you must ensure that you do not choose a word or number that is likely to be guessed by anyone trying to access the OmniBSIC Mobile App pretending to be you. For example, you should avoid any part of your phone number or your date of birth.
17.4 You must not record your Access Codes in a way that could make them recognizable by someone else as Access Codes.
17.5 If your Device is lost or stolen, or you suspect your Access Codes have been compromised, you must immediately change the Access Codes yourself through the OmniBSIC Mobile App. If this is not possible, you must notify us immediately by contacting our customer care center.
17.6 We may suspend or terminate your use of the OmniBSIC Mobile App immediately and without notice to you if we believe your Access Codes or Device have been compromised.
17.7 After initial registration, we will never contact you (or ask anyone to do so on our behalf) with a request to disclose your Access Codes in full. If you receive any such request from anyone (even if they are using our name or logo and appear to be genuine) then it is likely to be fraudulent and you must not supply your security codes to them in any circumstances. Additionally you should report any such requests to us immediately.
17.8 Once you have accessed the OmniBSIC Mobile App, do not leave the device used to access the App unattended to or let anyone use the device. Sign out of the App once you have finished using the service or you are unable to continue use of the service for any other reason. You must follow all security measures provided to you by the manufacturer of the mobile device operating system that apply to your use of the OmniBSIC Mobile App.
17.9 You should change your Password or Mobile Pin regularly and you shall be required to do so whenever the OmniBSIC Mobile App requires you to do so. You should not choose a Password or Mobile Pin you have used before.

18. YOUR AUTHORITY TO US TO CARRY OUT INSTRUCTIONS AND LIABILITY

18.1 You agree that the use of the Access Codes agreed on between us for OmniBSIC Mobile Banking Service is adequate identification of you. We are entitled to act on instructions (using the Access Codes via the OmniBSIC Mobile App) without obtaining any further written or other confirmation from you, even if those instructions are not actually given or authorized by you.
18.2 You will be liable for any instructions sent to us through your Device.
18.3 You will be held liable for all losses and expenses that may be attributed to unauthorized use if you have acted negligently or fraudulently; or if you are in willful default of any of the security obligations described in Section 9.1 to 9.9.
18.4 You will be held liable for all losses and expenses that may be attributed to unauthorized use if you agree that OmniBSIC shall initiate the linkage of any of your OmniBSIC accounts to your Mobile Money wallet.
18.5 You will not be responsible nor have any liability for any instruction that is not authorized by you but is given using your Access Codes if:
18.5.1 Such instruction is given after you have notified us that you have discovered or suspected that your Access Codes are known to someone else in accordance with Section 9.5 or
18.5.2 Your Access Codes or Password has become known to the person giving the unauthorized instruction as a result of our gross negligence or willful default on our part.
18.6 We will not be liable to you for any loss or damage you suffer due to:
• Any delay, malfunction, interruption, or failure in the provision of the Mobile Banking App service;
• Any error or inaccuracy in the information you obtain through the OmniBSIC Mobile App; or
• Any unauthorized access to your information.

19. AMENDMENTS

We reserve the right to modify this Privacy Policy. Changes will be effective upon updating the "Last updated" date. Continued use of the App constitutes acceptance of the revised policy.

20. NOTICES; NOTIFICATIONS; IN-APP MESSAGING

You agree that OmniBSIC may send you notices, disclosures and other communications under these Terms to your device electronically, to your mailbox (which will be regarded as being in writing), in-app messaging and SMS using the registered your mobile number.
You may give notice to OmniBSIC via the live chat functionality on the Mobile Banking App or through the OmniBSIC Contact Center or the Branch. Notices may include information about OmniBSIC Bank services, including Deals, Promotions, Rewards, Service Enhancements, Updates, and other Information. You hereby consent to receive such notices from OmniBSIC.

21. GOVERNING LAW

This Privacy Policy is governed by the laws of the Republic of Ghana.

22. CONTACT INFORMATION

For any questions or concerns regarding these Terms, please contact the Data Protection Supervisor who is responsible for overseeing all queries relating to this Privacy Policy and all relevant Data Protection queries. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

The Data Protection Supervisor
Atlantic Tower,
Airport City, Accra
Tel: 233 (0) 501 450 276 / 050 145 2177
Dataprotection@omnibsic.com.gh

If you have any other queries, please do not hesitate to contact us on the following:

Tel: +233 (0) 307086000
Toll Free: 0800100790
info@omnibsic.com.gh
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