2. Information We Collect

Lightway Microfinance Bank collects only adequate and relevant information limited to the specific. When you engage with our services, we may collect the following information from you:

• Personal Identification: Such as your full name, date of birth, gender, nationality, and identification numbers (including BVN, NIN, or passport number).
• Contact Information: This includes your email address, phone number, as well as residential and business addresses.
• Financial Information:Details like your bank account information, records of transactions with us, salary details, and any information you provide when applying for a loan.
• Login Credentials: Your username, password, and responses to security questions for accessing our digital banking platforms.
• Customer Support Data: Information shared while interacting with our customer service channels, responding to surveys, or submitting feedback.
• Other Information: Additional details provided to verify identity, recover lost accounts, or meet regulatory requirements.

All personal data is processed in accordance with applicable Nigerian data protection laws and banking regulations.

• Information We Collect Automatically

  When you access our website, mobile app, or digital platforms, we may collect:

  • We may collect information about how and when you access or use our services. This data may be stored in log files or other records linked to your account and may be combined with other information we have about you. Collected usage data can include details such as your IP address, date and time of access, browser type, and actions performed on our website or mobile applications. We use this information to enhance the functionality, security, and user experience of our services for you and all our users.
  • Your location with your consent for fraud prevention and personalised banking services.
  • Information We collect using cookies and similar technologies.

• Information We Obtain from Third Parties

  To verify your identity and assess financial risk, we may collect additional data from:

  • Credit bureaus and financial institutions.
  • Regulatory agencies such as the CBN and anti-fraud agencies.
  • Payment processors, financial technology partners, and loan service providers.
  • Information that We receive if you decide to connect to a third-party social network.
  • Information for advertising and analytics purposes, so we can provide you with better Services.

3. How We Use Your Information

To the extent permissible under applicable law, we may use your information when you have consented or where necessary for the following actions:

• Providing Banking Services

  • To process account openings and transactions.
  • To offer loans, savings, and investment products.
  • To facilitate payments, withdrawals, and transfers.

• Ensuring Security and Fraud Prevention

  • To verify your identity and prevent unauthorised access.
  • To detect and prevent fraudulent activities such as money laundering, terrorism financing, and identity theft.
  • To comply with regulatory requirements on financial crime prevention.

• Improving Our Services

  • To conduct and analyze User trends and market research.
  • To enhance user experience through personalised banking solutions.
  • To develop new products and improve existing financial services.
  • To adequately verify and communicate effectively with customers

• Marketing and Communication

  • Where you have opted in, we may use your data to send promotional messages or newsletters (You can opt-out at any time).
  • In the event of a merger, acquisition, or sale of all or a portion of Our assets, your information may be transferred as part of the transaction. We will notify you via email and/or prominent notice on Our website of any such change in ownership or control of your personal information.
  • To provide customer support and respond to inquiries.

• Legal and Regulatory Compliance

  • To comply with legal obligations, especially privacy & data protection laws, tax laws, anti-money laundering regulations, and other applicable laws and regulations, including responding to court orders.
  • To report suspicious transactions to regulatory authorities as required by law.

4. Legal Basis for Processing Your Data

We or any third party acting on Our behalf shall only process your data if at least one of these conditions is met:

• Consent: For marketing and optional services, we seek your explicit consent, which you can withdraw at any time.
• Legal Obligation: As a regulated financial institution, we are legally required to collect and process certain personal data to comply with Nigerian banking regulations.
• Legitimate Interests: We may process your data for fraud prevention, security monitoring, and business analytics, provided it does not override your privacy rights.
• Contractual Obligation: We process data necessary to fulfil our banking contracts with you, such as account management, loan processing, and payment transactions.

5. Who We Share Your Information With

We do not sell, rent, or trade your personal information. However, we may share your data with:

• A. Regulatory and Law Enforcement Agencies

  • The Central Bank of Nigeria (CBN) for compliance monitoring.
  • The Economic and Financial Crimes Commission (EFCC) and anti-fraud bodies to prevent financial crimes.
  • The Federal Inland Revenue Service (FIRS)for tax reporting.
  • Any other statutory body mandated by law to receive data from us, to which we are obligated.

• B. Third-Party Service Providers

  • Payment Processors: To facilitate transactions.
  • Credit Bureaus: For credit scoring and loan eligibility checks.
  • Technology Partners: For mobile banking and cybersecurity protection.

• C. Affiliates and Business Partners

  We may share limited data with affiliated companies or partners who help us deliver specialised financial services, ensuring they meet our privacy standards.

6. How We Protect Your Information

We have implemented industry-standard security measures to safeguard and help prevent unauthorised access, maintain data security, and correctly use the personal information collected through the Services we provide. Specifically, we implement the following industry-standard security measures:

• Data Encryption: To secure sensitive information.
• Multi-Factor Authentication: To prevent unauthorised access.
• Regular Security Audits: To detect vulnerabilities and enhance cybersecurity.
• Access Control Measures: To limit employee access based on job responsibilities

We take reasonable steps to ensure that applicable third parties take reasonable precautions to protect your personal information against loss, misuse, unauthorised disclosure, alteration, and destruction. However, no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while We strive to protect your information, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorised use of, or access to, your information that is under Our control. In case of a data breach, we will promptly notify affected individuals and regulatory authorities within the notification threshold provided by the
Nigeria Data Protection Commission – General Application and Implementation Directive (NDPC - GAID) 2024.

7. Your Rights as a Data Subject

You have the following rights regarding your personal data:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Correction: Request corrections to inaccurate or incomplete data.
• Right to Deletion: Request deletion of personal data no longer needed for legal or business purposes.
• Right to Object: Opt out of marketing or certain data processing activities.
• Right to Data Portability: Request a transfer of your personal data to another financial institution.
• Right to Withdraw Consent: Revoke consent for optional services at any time.

To exercise these rights, contact our Data Protection Officer at c.olaniyan@lightwaymfb.com.

8. How Long We Keep Your Data

We retain your personal data only as long as necessary for the purposes described in this policy. We may also retain aggregated and anonymized information indefinitely. For clarity, anonymized data refers to information from which your personal identifiers have been removed, making it impossible to attribute the data back to you. In addition, we may retain your personal information for a reasonable period beyond the active use of your account as permitted or required by applicable law. This retention enables us to fulfil legal and regulatory obligations, resolve disputes, enforce our agreements, and comply with tax or financial reporting requirements.

NOTE: Personal data related to financial transactions is typically retained for at least 5 years in compliance with CBN and anti-money laundering laws. After this period, data is securely deleted or anonymised.

If you request the deletion of your account and removal of your personal data from our records, we will retain the necessary information only as required by law. This retained information will be handled strictly to meet legal compliance and audit purposes and will not be used for any other purposes

10. Privacy of Children

We do not knowingly collect personal information from individuals under the age of 18, except as permitted by the Nigeria Data Protection Act and other relevant laws. If you believe we have collected information from a child, please contact Us immediately.

11. Use of Cookies and Tracking Technologies

The Site uses cookies. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are useful because they allow a website to recognize a user’s device as well as do a lot of other tasks, you may see examples below.

You can control cookie settings through your browser. However, disabling cookies may affect the website’s performance. You can know more about this by reading our cookie note (Insert link to cookie policy on the highlighted text).

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in Our practices or legal requirements. We will notify you of any material changes by posting the updated Privacy Policy on Our website or by sending you a notification. We encourage you to review this Privacy Policy periodically for any updates.

The effective date at the top of this page indicates when the latest version was published.

13. GOVERNING POLICY

This Privacy Policy is made according to the Nigeria Data Protection Act (NDPA), 2023, Nigeria Data Protection Commission, General Application and Implementation Directive (NDPC - GAID) 2024 and other relevant laws, regulations, or international conventions applicable to Nigeria.

By using Our website, you acknowledge that you have read this Privacy Policy and consent to the collection, use, disclosure, and retention of your information as described herein.

14. How to Contact Us

For questions, complaints, or to exercise your rights, contact:

Data Protection Officer

Lightway Microfinance Bank

4b Sola Oguntade Close lekki Phase 1

We are committed to addressing privacy concerns promptly and in accordance with regulatory requirements.