2. Information We Collect

We collect different types of personal information based on the services you use.

• A. Information You Provide to Us

  When you interact with our banking services, we may request:

  • Personal Identification: Full name, date of birth, gender, nationality, and identification numbers (e.g., BVN, NIN, passport number).
  • Contact Information: Email address, phone number, residential and business address.
  • Financial Information: Bank account details, transaction history, salary information, and loan application details.
  • Login Credentials: Username, passwords, and security questions to access our digital banking services.
  • Customer Support Data: Information shared through customer service inquiries, surveys, or feedback forms.

• B. Information We Collect Automatically

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

  • Device Data: IP address, browser type, device ID, and operating system details.
  • Usage Information: Pages visited, time spent on our platforms, and navigation behaviour.
  • Location Data: We may collect your location with your consent for fraud prevention and personalised banking services

• C. 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.

3. How We Use Your Information

We use your personal data for the following purposes:

• A. Providing Banking Services

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

• B. 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.

• C. Improving Our Services

  • To conduct customer analytics and market research.
  • To enhance user experience through personalised banking solutions.
  • To develop new products and improve existing financial services.

• D. Marketing and Communication

  • To send notifications, newsletters, and promotional offers (automatic opt-in once you register for our services).
  • To inform you about changes to our policies, terms, or service updates.
  • To provide customer support and respond to inquiries.

• E. Legal and Regulatory Compliance

  • To comply with tax laws, anti-money laundering regulations, and court orders.
  • To report suspicious transactions to regulatory authorities as required by law.

4. Legal Basis for Processing Your Data

We process your personal data under the following legal grounds:

• A. Providing Banking Services

  We process data necessary to fulfil our banking contracts with you, such as account management, loan processing, and payment transactions.

• B. Legal Obligation

  As a regulated financial institution, we are legally required to collect and process certain personal data to comply with Nigerian banking regulations.

• C. Legitimate Interests

  We may process your data for fraud prevention, security monitoring, and business analytics, provided it does not override your privacy rights.

• D. Consent

  For marketing and optional services, we seek your explicit consent, which you can withdraw at any time.

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.

• 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 implement industry-standard security measures, including:

• 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

In case of a data breach, we will promptly notify affected individuals and regulatory authorities as required by law.

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 dpo@lightwaymfb.com.

8. How Long We Keep Your Data

We retain your personal data only as long as necessary to:

• Provide banking services.
• Fulfil legal and regulatory obligations.
• Resolve disputes and enforce agreements.

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.

9. Use of Cookies and Tracking Technologies

We use cookies to:

• Improve website functionality.
• Analyse user behaviour for better service.
• Remember your preferences and login details.

You can control cookie settings through your browser. However, disabling cookies may affect the website’s performance.

10. Updates to This Privacy Policy

We may update this policy periodically. Any significant changes will be communicated through:

• Our website.
• Email notifications.
• SMS alerts.

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

11. 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.