The safekeeping of your personal information is important to Republic Bank (Ghana) PLC (the “Bank”) and its subsidiaries, (collectively referred to as the “Group”). The Bank is a subsidiary of Republic Financial Holdings Limited of Trinidad and Tobago. The safekeeping of your personal information applies to all personally identifiable information (“Personal Information”) about you that is obtained by the Group. Personal Information as used in this Privacy Statement refers to information such as your name, email address, mailing address, telephone number(s), account numbers, limited location information (for example, a city name to help you find a nearby ATM), user name and password and answers to security questions for password recovery purposes. At any time you decide to close your account or become an inactive customer, we will continue to adhere to the procedures described in this statement and any proper opt-out requests you make. This Privacy Statement also serves as our Privacy Notice. This Privacy Statement contains important information about your choices in relation to sharing Personal Information with the Group.
You regard your Personal Information as yours, and so do we. We do not sell or share your information with third parties not associated with the provision of services or activities of the Group or as allowed by law. Further, any sharing of information with third parties requires your consent and are identified under the ‘Disclosure of Information’ section. Limited information related to your credit history may be shared with credit reference bureaus and/or other credit providers.
This Privacy Statement explains how the Group may collect, share, use, and protect information when you visit or use any digital services offered by the banking and non-banking affiliates and subsidiaries that link to or reference this statement (the “Online Services”). This Privacy Statement covers the Group’s websites, online, mobile services, branded social media sites or pages as well as any interactions you may have while viewing content provided through one of the Bank’s digital advertising campaigns.
As you review this Privacy Statement, here are a few general principles to keep in mind:
- Our Online Services are not intended for children under 13 years. We do not knowingly collect Personal Information from children under 13 years without parental consent
- If you have a financial product or service with the Group, we may use and share any information that we collect from or about you as outlined in the section entitled “Use of Information” of this document.
- The Group’s Online Services may have additional terms to this Privacy Statement about the privacy of your information. Please review the privacy statement for the specific online service you are using
D. Collection, Retention and Use of Customer Information Personal Information
We collect and use various types of information to service your accounts, to save you time and money and better understand your needs. We collect Personal Information about you from the following sources:
- Information we receive from you on applications, information updates or other forms;
- Information we receive from you on surveys (originated from the entities within or contracted by the Group), complaints, problem reports and other contact correspondence;
- Information about your transactions with us, our affiliates or others;
- Information we receive from a consumer reporting agency;
When you visit or use our Online Services, we will collect Personal Information from or about you. We may also collect payment card information when you provide such information while using our Online Services and where we believe it is reasonably necessary for ordinary business purposes. When you visit or use our Online Services, we will collect Personal Information from or about you. We may also collect payment card information when you provide such information while using our Online Services and where we believe it is reasonably necessary for ordinary business purposes
E. Usage and Other Information
F. Social Media Channels
When you use any of our social media channels we may record and retain information (anonymous or otherwise) about you. This may include your use of our sites and the frequency of your visits. The individual social media platforms may also be permitted to share certain information with the Group in accordance with your personalised privacy settings on those platforms.
Any information you provide or that we record through your use of our social media channels may be shared with other subsidiaries of the Group, and any third parties who are acting on our behalf to enhance your user experience of our social media channels, and provide you with customer assistance and/or provide you with information about our products and services. We are always striving to understand our customers better, so we may also record comments and opinions that you make publicly on our social media channels.
By using our social media channels and providing us with, or posting Personal Information to our social media channels, you agree that you accept these terms. If you disagree with any of these terms you should not access our social media channels.
G. Online and Mobile Services
For your convenience, the Group offers you the ability to access some products and services through mobile applications and mobile-optimised websites. When you interact through online and mobile services, information such as unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location and analytical information about how you use your mobile device will be collected.
H. Additional Sources of Information
We may also collect information about you from additional online and offline sources including from co-branded partner sites or commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Online Privacy Statement.
I. Use of Information
We use the information discussed above in a number of ways:
- Processing applications and transactions;
- Verifying your identity (such as when you access your account information);
- Preventing fraud and enhancing the security of your account or our Online Services;
- Responding to your requests and communicating with you;
- Managing your preferences;
- Performing analytics concerning your use of our Online Services, including your responses to our emails and the pages and advertisements you view;
- Providing you tailored content and marketing messages;
- Operating, evaluating and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);
- Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
- For any other purposes that we may specifically disclose at the time, you provide or we collect your information.
J. Use of Location Data
We collect precise or approximate location data of mobile devices of existing and prospective customers to prevent and detect fraud, enhance the use of the mobile application, social media platforms and websites to provide security and to satisfy regulatory requirements. The mobile application collects this data during the registration process (onboarding) when it is running in the foreground (App open and on-screen) or background (App open but not on screen).
K. Disclosure of Information
We may share the information we collect from and about you with our affiliates and other third parties. For example, we may share your information with:
- The Group’s third-party service providers
- The Group’s affiliated websites and businesses in an effort to bring you improved service across our family of products and services, when permissible under relevant laws and regulations;
- Affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of the Group’s businesses;
- Credit reference bureaus and other credit providers;
We may share anonymous or aggregated information with third parties to help deliver products, services, and content that is tailored to the users of our Online Services and for other purposes.
L. Online advertising
You will see advertisements when you use any of our Online Services. These advertisements may be for our own products or services (including pre-screened offers of credit) or for products and services offered by third parties. The advertisement you see is often determined using the information we or our affiliates, service providers and other companies that we work with have about you, including information about your relationships with us (e.g., types of accounts held, transactional information, location of banking activity). To that end, where permitted by applicable law, we may share with others the information we collect from and about you.
Online behavioural advertising (“OBA”) or interest-based advertising refers to the practice of collecting information from a computer or device regarding a visitor’s web-browsing activities across non-affiliated websites over time in order to deliver advertisements that may be of interest to that visitor based on their browsing history. Through OBA, we hope to deliver advertisements that are most likely to be of interest to you using information about your other web-browsing activities (e.g., the web pages you visit, search terms you enter, and the way you move through our Online Services on your computer or device) or your personal profile (e.g., demographic or location information). Certain companies we work with may set cookies and use related tracking technologies throughout our Online Services or in our communications to support these OBA efforts.
M. Linking to Third-Party Websites
We maintain physical, electronic, and procedural safeguards to protect the integrity and confidentiality of your information. The Group also limits access to your non-public Personal Information to those employees of the Group who need to know that information in order to provide products and services to you. All our employees are trained to understand and comply with the safeguarding of this information.
Please note that the information you send to the Group electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecured channels such as public Wi-Fi connections that do not use authentication (password) and other unverified internet connections to communicate sensitive or confidential information to us. Never quote your full account number, card number, personal identification number (PIN), card verification value (CVV) or any other sensitive banking data on open forums, social media sites and emails, which can be viewed or forwarded without your consent.
O. Updating Your Information
Keeping your information up-to-date is very important. You may review or update your information using our Online Services. If you cannot change the incorrect information online, or you prefer to request changes offline, please use the Contact Us option on our site, or call or write to us using the contact information listed on your account statements, records, or other account materials. You can also speak to one of our branch representatives, your financial advisor, or your designated account representative.
P. Changes to this Online Privacy Statement
We may change this Online Privacy Statement at any time in the future. When we do, we will let you know by appropriate means such as by posting the revised statement on this page with a new “Last Updated” date. Any changes to this Online Privacy Statement will become effective immediately it is posted. You agree to revisit this page regularly and your continued access to or use of the website will mean that you agree to the changes.
Q. COLLECTING INFORMATION & COOKIES
The information we collect about you depends on how you use our websites and mobile application and may involve the use of “cookies”, as explained below.
What is a “cookie”?
A cookie is a small text file placed on your computer’s hard drive by our web page server and which we can later access. They are frequently used on websites and you can choose if and how your computer accepts them by configuring your preferences and options in your browser.
a. We allocate a cookie to your internet browser if you visit our websites (including if you visit an unsecured area such as one which does not require you to log on to the relevant page). The cookie allows us to:
- determine if you have previously visited our website
- identify pages you have accessed and third-party websites you have visited
b. We use certain ‘essential’ cookies to maintain online security and protect against online fraud in relation to the services on our websites such as:
- online banking
- online applications
Even if you say “No” in your browser’s settings to cookies on this website we’ll continue to use these ‘essential’ cookies.
If you have provided your Personal Information through the use of our online facilities, such as an online enquiry form or online banking, we would be able to identify you from the information provided and track your browsing activities on our website from the cookie.
- Make online banking login faster by remembering you between visits on your personal devices
- Simplify online transactions by remembering the last account you used and showing it as the default for your next transaction
- Remember relevant information as you browse from page to page saving you from re- entering the same information repeatedly
We also use this type of cookie to understand how visitors use our online services and look for ways to improve them. For example, a cookie might tell us that lots of people give up on an application process at a particular step – so we can ensure to make that step easier to use in attempts at subsequent logins.
R. GOVERNING LAW AND DISPUTE RESOLUTION
The terms set herein shall be governed by and construed in accordance with the laws of the Republic of Ghana. Any dispute arising out of or in relation to this Policy Statement shall be settled by the courts of the Republic of Ghana.
This Privacy Statement was last updated: March 28, 2022.