Privacy Statement

Data controller:  FirstBank UK –  This privacy policy applies to all processing activities involving personal data carried out by FirstBank UK .

Our main address is 28 Finsbury Circus, London, EC2M 7DT.

We are a member of FirstBank Holdings (the Group). More information about the the  Group can be found at https://www.fbnholdings.com.

FirstBank UK is the data controller in respect of personal data that we process in connection with our business (including the products and services we provide).

FirstBank UK collects personal information about you when you visit our website, when you enrol for our services, when you use our online or offline services, or when you contact us. We may use this personal information along with other information collected or generated during our relationship with you. We collect your contact information, information about your use of our services, details of any payors or beneficiaries or yours, and marketing choices.

FirstBank UK is committed to protect and respect your privacy by being transparent about how it collects and uses that data and to meeting its data protection obligations. The purpose of this notice is to explain:

  1. What information does FirstBank UK collect?
  2. How we collect personal data?
  3. Why does FirstBank UK process personal data?
  4. How and why we share your personal data
  5. Transferring personal data overseas
  6. How does FirstBank UK protect data?
  7. For how long does FirstBank UK keep data?
  8. Your rights
  9. Links to other websites
  10. Changes to the privacy policy

 

It is important that you read this privacy notice carefully to ensure you are fully aware of how and why we are using your data.

If you have any questions about this privacy notice, data protection generally or you wish to exercise your legal rights please contact our Data Protection Officer (DPO) using the details set out in “Your rights” section below.


 

  1. What information does FirstBank UK collect?

We may collect, use, store and/or transfer different kinds of personal data about you. What we mean by personal data is any information about an individual from which that person can be identified (either by itself or when combined with other information). We will limit the collection and processing of personal data to what is necessary to achieve one or more purpose(s) as identified in this notice. The personal data we collect may include:

  1. Basic personal data to identify you such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth;
  2. Your contact information including your email address, address and telephone numbers;
  3. Financial information – including bank account details, card payment details and transactional information and history;
  4. Products and services provided to you;
  5. Online information and online activity based on your interaction with us, our websites and applications for example your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types, searches, site visits and versions, operating system and platform, and other technology on the devices you use to access this website;
  6. Images and personal appearance such as copies of your passport or driver’s licence or CCTV images;
  7. Profile Data which may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses; and
  8. Usage Data including statistical data including information about how you use our website, products and services.
  9. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  1. How we collect personal data?

FirstBank UK collects this information in a variety of ways. For example:

  1. data is collected through application forms, CVs or biographies;
  2. obtained from your passport or other identity documents;
  3. from forms completed by you;
  4. from correspondence with you;
  5. or through calls, meetings or other types of exchange;
  6. while providing customer support, consultation, live chat, or other interaction;
  7. through the process of maintaining and upgrading our services; through means such as communications protocols and e-mail communications;
  8. through our mobile applications;
  9. when information is provided to us from third parties authorized under applicable law to initiate transactions or perform account-related services on your behalf, such as account information service providers or payment initiation service providers.

 

 

  1. Why does FirstBank UK process personal data?

FirstBank UK needs to use your personal information to perform its contract with you or provide our services to you. To conduct a payment or money transfer, or to enter into a foreign exchange derivative contract with us and thus enable you to become a client, you must provide certain information required by us to execute the transaction and to enable us to comply with our legal obligations associated with providing our services. Failure to provide some of your personal information may affect our ability to provide our services to you. We will inform you when information is required in order to use our services.

We use the information you provide and that we collect from other people for the following legal bases and legitimate business purposes:

 

Providing our services to you:

This includes using information necessary performing contracts or for taking steps to enter into a contract with you, including conducting money transfers, payment services, or delivering other products or services.

 

Legal and compliance purposes:

This includes using your personal information to comply with legal and regulatory duties, such as anti-money laundering and counter-terrorist financing, detection, prevention and prosecution of fraud and theft as well as preventing illegitimate or prohibited use of our services. This may also include establishing, exercising, or defending legal rights and claims, monitoring and reporting compliance issues, or responding to legal process. Additionally, this includes using your details to validate and authenticate your identity and using third parties to help us do this, as well as retaining records containing your personal information as required under applicable law.

 

Legitimate business purposes:

We use your personal information to analyse and improve our products, services, operations, the running of our websites and your customer experience. We also use your personal information to provide customer service, to conduct other administrative tasks necessary to provide our services, to help manage risks related to security, fraud and identity, and to protect the security and integrity of our technology, systems, and services. We conduct analysis of the information we hold to better understand our customers. We may also conduct credit checks on you and your business using a licensed credit reference agency.

 

  1. How and why we share your personal data

FirstBank UK may from time to time share your personal data with the following organisations who are also required to keep your information confidential, safe and secure:

  1. Our parent company and any member of the Group;
  2. Third parties, commercial partners, agents, professionals and subcontractors who provide products, services and administrative support to the Group;
  3. Third parties or professionals who may be engaged on your behalf;
  4. Where we are required by law and law enforcement agencies, judicial bodies, credit reference agencies, fraud prevention agencies, governmental entities, tax authorities or regulatory bodies around the world;
  5. Where required as part of any proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or business assets;
  6. Anyone else with your permission.

 

  1. Transferring personal data overseas

From time to time we may share your personal data with organisations in other countries including organisations within the Group.

 

Additionally, when you send or receive money to or from another country, we may send some of your personal information to country as required or permitted by law. The privacy law in countries to which personal information is transferred may not provide the same level

of data protection as is in force within the EEA. If this is the case, personal information transferred outside the EEA will be protected by EU-approved mechanisms for transferring data internationally, including appropriate contractual clauses, as required by law.

 

  1. How does FirstBank UK protect data?

FirstBank UK takes the security of your data seriously. FirstBank UK has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

Where FirstBank UK engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

  1. For how long does FirstBank UK keep data?

We will not retain your personal data longer than is necessary. The retention periods for which FirstBank UK will hold your personal data will vary depending on its category including but not limited to the nature and type of record, the nature of the activity, the product or service and any applicable legal or regulatory requirements. Your personal information will be retained in accordance with statutory periods contained in regulations applicable to financial transactions, including those in anti-money laundering, anti-terrorist financing and other laws applicable to us. For the most part, your personal data will be retained for no longer than seven years after the end of our relationship, unless there is an overarching regulatory reason for holding onto it for longer.

  1. Your rights

You have the right to know if we are processing your personal information, and to ask us for a copy of your information free of charge. You have the right to request a structured and machine-readable copy of certain information you have provided to us. We may charge you a reasonable fee for providing the information, or not act upon your request, if the request is manifestly unfounded or excessive. You have the right to stop us sending you marketing communications. You have the right to ask us to correct information about you that is incomplete, inaccurate or out-of-date. You have the right to ask us to erase certain information about you, to restrict certain uses of your information, and also to object to certain uses of it. You also have the right to lodge a complaint with a supervisory authority about our processing of personal information. When we receive a request, we may ask for additional information from you to verify your identity.

To exercise these rights, please contact our data protection officer (DPO) at FirstBank UK through the following channels:

 

 

Data Protection Officer

FirstBank UK  Limited

28 Finsbury Circus,

London,

EC2M 7DT

 

Email: DataOffice@fbnbank.co.uk

Telephone: 02035951173

  1. Links to other websites

Within our website we may have links to third party websites, plug-ins and applications. Clicking those links may enable third parties to share or collect your personal data. FirstBank UK do not control such third-party websites and are not responsible for their privacy statements or the contents of those websites. We would encourage you to read the privacy policy of every website you visit.

  1. Changes to the privacy notice

We keep our privacy notice under regular review. Any changes to our privacy notice in the future will be posted on this page. We encourage you to review this page regularly to identify any updates or changes to our privacy notice.

 

April 2023