PRIVACY POLICY

At Cooperative Mortgage Bank, we are given to protecting the privacy of our users and ensure the protection of their personal information. We are compliant with the Nigerian Data Protection Act (NDPA)2023 and other applicable data protection laws and regulations.

This privacy policy informs you about what type of your data we collect and how we collect, store, use and for which purposes your data are used.

It applies to our website and mobile app, and if you will be accessing either or both, you will be agreeing to the terms outlined in this privacy policy. If not, kindly refrain from using our services.

Information we collect

Cooperative Mortgage Bank ltd. collects personal and financial information from you that we use, share and store. Information may include:

  • Identity data: First name, middle name, last name, marital status, title, date of birth and gender.
  • Contact data: billing address and telephone numbers, email address.
  • Financial data: bank account, BVN and payment card details.
  • Profile data: your username and password, your interests, preferences, feedback and survey responses.
  • Usage data: information about how you use our website, products and services.
  • Marketing and communication data: your preferences in receiving marketing from us and our third parties and your communication.
  • Technical data: internet protocol (IP) address, your login data, browser type and versions, time zone setting and location, browser plug-in-types and versions, operating system and platform and other technology on the devices you use to access this website.

How We Collect Your Personal Information:

We collect personal information in various ways, including when you:

Register an Account: When you sign up for an account, we may collect your name, email address, phone number, residential address, identification documents, and other necessary details for identity verification and customer service.

Make a Loan Application: We collect financial information such as your income, employment history, credit score, and other related data to process your mortgage application.

Use Our Services: We collect transactional data, including payment details, loan status, and correspondence with our customer support team.

Cookies and Tracking Technologies: We may use cookies, web beacons, and similar technologies to collect non-personal data, such as device type, browser type, location, and other usage details to improve our services.

How We Use Your Information:

We use your data for the following purposes:

  • To process and manage mortgage applications.
  • To communicate with you regarding your account, loan status, and new services.
  • To verify your identity and perform necessary background checks.
  • To personalize your experience on our website and mobile app.
  • To comply with legal and regulatory requirements.
  • To improve our services, including customer support and website functionality.

   

How We Share Your Information:

We can share your information with:

Third-Party Service Provides: We may share your information with trusted third parties who help us provide services such as payment.

Regulatory Authorities: As required by Nigerian law, we may disclose your Information to regulatory bodies or law enforcement agencies.

Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction.

We ensure that any third party with access to your data complies with relevant data protection regulations and safeguards your information.  

Data Security

We implement reasonable technical and organizational measures to protect your personal data from unauthorised access, loss, or misuse. However, no method of internet transmission or electronic storage is 100% secure, and we cannot guarantee absolute security.  

Your rights as a Data Subject

You have the following rights regarding your personal data:

  • Right to access: You can have the right to request access to the personal data we hold about you.
  • Right to correction: you have the right to require us to correct any inaccuracies in your data.
  • Right to deletion: you have the right to request the deletion of your personal data, subject to legal and contractual obligations.
  • Right to withdraw consent: you have the right at any time to withdraw consent allowing us to process your personal data. This will not affect the legality of any processing prior to the date of such withdrawal.

To exercise any of these rights, please contact us at [info@cmbankng.com]

Maintaining Accurate Information

You are responsible for making sure the information you share with the bank are valid, and accurate. If any change occurs to your details, kindly reach out to the bank so we can update your information.  

Personal Data Breach Notification

Cooperative Mortgage Bank will inform the data protection authorities and the affected individuals in the event of a breach. The information will across within 72 hours of being aware of a breach. A personal breach can be unauthorized access, loss, or disclosure. We will take immediate response measures to contain the breach, investigate its cause and scope, and implement remediation steps to prevent further breaches.

Retention of Your Data

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by applicable laws and regulations.  

Children’s Privacy

Cooperative Mortgage Bank respects the privacy of Children. We do not knowingly collect names, email addresses, or any other personally identifiable information from children through the internet or other touchpoints. We do not allow children under the age of 18 to open accounts nor provide online banking for children less than 18 years of age without the consent of a guardian. Our website may include linked 3rd party that would be of interest to children. We are not responsible for the privacy and security practices of these sites closely before allowing children to provide any personally identifiable information.  

Electronic Communication

To maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorized activities, Cooperative Mortgage Bank Ltd. reserves the right to monitor all electronic communications to make sure that they comply with our legal and regulatory responsibilities and internal policies.  

Social Media

We operate and communicate through our designated channels, pages, and accounts on some social media sites to inform, help and engage with our customers. We monitor and record comments and posts made about us on these channels so that we can improve our services. The public can access and read any information posted on these sites. Please note that any content you post to such social media platforms is subject to the applicable social media platform’s terms of use and privacy policies. We recommend that you review the information carefully to better understand your rights and obligations regarding such content.  

Transfer to A Foreign Country

Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a foreign country or to an international organization shall take place subject to the other provisions of this Regulation and the supervision of the Honorable Attorney General of the Federation (HAGF). Accordingly:

  1. a transfer of personal data to a foreign country or an international organization may take place where the Agency has decided that the foreign country, territory or one or more specified sectors within that foreign country, or the international organization in question ensures an adequate level of protection.
  2. the HAGF shall take into consideration the legal system of the foreign country particularly in the areas of rule of law, respect for human rights and fundamental freedom, relevant legislation, both general and sectoral, including public security, defence, national security and criminal and access of public authorities to personal data.
  3. implementation of such legislation, data protection rules, professional rules, and security measures, including rules for the onward transfer of personal data to another foreign country or international organization which are complied with in that country or international organization, case- law, as well as effective and enforceable Data Subject rights and effective administrative and judicial redress for the Data Subjects whose personal data are being transferred.
  4. the existence and effective functioning of one or more independent supervisory authorities in the foreign country or to which an international organization is subject, with responsibility for ensuring and enforcing compliance with the data protection rules, including adequate enforcement powers, for assisting and advising the Data Subjects in exercising their rights and for cooperation with the relevant authorities Nigeria; and
  5. the international commitments of the foreign country or international organization concerned has entered, or other obligations arising from legally binding conventions or instruments as well as from its participation in multilateral or regional systems, in relation to the protection of personal data.

Exceptions in Respect for Transfer to A Foreign Country

In the absence of any decision by the Agency or HAGF as to the adequacy of safeguards in a foreign country, a transfer, or a set of transfers of personal data to a foreign country or an international organization, shall take place only on one of the following conditions:

  1. You have explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for due to the absence of an adequacy decision and appropriate safeguards and that there are no alternatives.
  2. the transfer is necessary for the performance of a contract between you and the Controller, or the implementation of pre- contractual measures taken at your request.
  3. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between the Controller and another natural or legal person.
  4. the transfer is necessary for important reasons of public interest.
  5. the transfer is necessary for the establishment, exercise, or defense of legal claims.
  6. the transfer is necessary to protect your vital interests or of other persons, where you are physically or legally incapable of giving consent.

Provided, in all circumstances, that you shall be manifestly made to understand through clear warnings of the specific principle(s) of data protection that are likely to be violated in the event of transfer to a third country. This provision shall not apply to any instance where the Data Subject is answerable in duly established legal action for any civil or criminal claim in a third country.

   

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track the activity on our service and store certain information. Tracking technologies are beacons, tags, and scripts to collect and track information to improve and analyze our service. You can adjust your browser settings to refuse cookies, but this may affect the functionality of certain features on our platforms.

Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will notify you via email on our service before any change takes effect, and we will update the “Last updated” date at the top of this Privacy Policy.

We encourage you to review this Privacy Policy regularly for any updates. Changes to this Privacy Policy will become effective once they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

By email: info@cmbankng.com