1.0 Privacy Policy
Alt Bank values and respects the privacy of the people we deal with. Alt Bank is committed to protecting your privacy and complying with the Nigeria Data Protection Act (2023) and other applicable data privacy laws and regulations.
This Privacy Policy ("Policy") describes how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information. Throughout this document, "Alternative", "Bank", "we", "us", "our" and/or "ours" refer to Alt Bank Limited incorporated under the laws of the Federal Republic of Nigeria with its registered office at 22 Marina, Lagos. References to "you" or "your" mean the individual whose personal data is being processed.
2.0 Data Collection
2.1 The information we collect about you
We collect several different types of information for various purposes to provide and improve our services to you. Some replies from our Contact Center may be generated, in whole or in part, by an AI email agent. All AI-assisted responses are subject to monitoring and review in line with our established quality, security, and regulatory standards.
2.1.1 Personal Data
While using our services, providing services or seeking employment with the Bank, we may ask you to provide certain personal data that can be used to contact or identify you.
2.1.1.1 Identification Data
First, middle, and last name; date of birth; gender; nationality; biometric identifiers (where applicable); government-issued identification numbers such as NIN, BVN, passport, driver's license; and identification documents or photographs used for verification.
2.1.1.2 Contact Details
Residential or mailing address, email address, phone numbers, and any similar contact information you provide during account creation, onboarding, service usage, or customer support.
2.1.2 Financial Information
Bank account details, transaction history, card information (card number, expiry date, security codes), tax-related information, credit or loan information. All payment data is handled in accordance with PCI DSS. You are responsible for keeping card credentials confidential.
2.1.3 Sensitive Personal Data
We only collect sensitive personal data when strictly necessary and legally required. Biometric data is collected only for enhanced security authentication where you have explicitly opted in. We do not collect information about health, political opinions, religious beliefs, sexual orientation, or racial origin unless specifically required by law with your explicit separate consent.
2.1.4 Access Credentials
When you subscribe to our e-channel products, you may provide a User ID, password, token responses, and biometric identification. Appropriate security measures are implemented including encryption and secure storage.
2.1.5 Usage Data
Information your browser sends when accessing our online services โ IP address, browser type and version, pages visited, timestamps, unique device identifiers, and diagnostic data.
- 2.1.5.1 Geo-Location: We may request permission to track location-based information from your mobile device to provide location-based services. You can change permissions in your device settings.
- 2.1.6 Mobile Device Access: Camera, calendar, Bluetooth, contacts, storage, and other features.
- 2.1.7 Mobile Device Data: Device ID, model, manufacturer, operating system, version, IP address, and diagnostic data.
- 2.1.8 Analytics: We may use third-party service providers such as Google Analytics to monitor and analyse use of our Service.
- 2.1.9 Cookies: Session, preference, security, and third-party cookies. You can instruct your browser to refuse cookies, but some portions of the Service may be degraded.
- 2.1.10 Social networks: Information from any social media profiles or accounts you share with us.
- 2.1.11 Other consented data: Includes CCTV image recordings at branches, offices and ATMs for surveillance and crime prevention.
3.0 Purposes of Processing
We collect and process your personal data through secure systems for the following lawful and legitimate purposes:
3.1 Provision of Banking and Financial Services
- Create, verify, and manage accounts, agent profiles, and enrolments.
- Process transactions, payments, transfers, card issuance.
- Authenticate users via passwords, PINs, tokens, or biometrics.
3.2 Customer Support and Relationship Management
- Communicate about accounts, enquiries, requests, complaints, updates.
- Provide technical support, resolve disputes, enhance experience.
3.3 Security, Fraud Prevention, and Risk Management
- Verify identities, prevent impersonation, authenticate transactions.
- Detect and prevent fraud, money-laundering, and unauthorized access.
- Monitor systems, networks, ATMs, and digital channels.
3.4 Legal, Regulatory, and Compliance Obligations
- Comply with NDPA 2023, CBN regulations, AML/CFT, KYC, tax obligations.
- Report to regulatory bodies and maintain statutory audit trails.
3.5 Employment, Recruitment, and Vendor Management
- Assess job applications and conduct pre-employment checks.
- Manage staff access rights and system monitoring.
- Conduct vendor due diligence and compliance monitoring.
3.6 Service Improvement and Business Operations
- Analyse service performance and improve products and platforms.
- Conduct data analytics and quality assurance.
3.7 Marketing, Communications, and Personalization
- Send relevant product information based on your preferences and consent.
3.8 Protection of Individuals, Assets, and Bank's Interests
- Safeguard vital interests of customers, staff, and the public.
- Protect the Bank's facilities and assets via CCTV.
3.9 Other Legitimate and Lawful Purposes
Any additional purpose compatible with the original reason for collection, permitted under applicable laws.
4.0 Lawful Bases for Processing
4.1 Consent
Where required by law, we obtain your consent before processing. You may withdraw consent at any time, subject to legal or contractual restrictions.
4.2 Performance of a Contract
Necessary to enter into or perform a contract โ including opening accounts, onboarding, managing employment or vendor relationships, and providing digital channels.
4.3 Compliance with Legal Obligations
KYC, AML/CFT, tax obligations, regulatory reporting, and CBN-mandated obligations.
4.4 Protection of Vital Interests
Emergency situations, fraud prevention, and public safety matters.
4.5 Legitimate Interests
- Securing platforms and preventing fraud or misuse.
- Improving services and customer experience.
- Protecting infrastructure, staff, and customers.
- Governance, audits, and risk management.
4.6 Public Interest or Official Authority
Required for regulatory oversight, financial stability, anti-fraud initiatives, or national security-related obligations.
5.0 How we use your personal Information
To the extent permissible under applicable law, we may use your information to:
- Determine your eligibility for our products and services.
- Verify your identity when you access your account.
- Administer accounts, products, and services.
- Respond to your requests and communicate with you.
- Understand your financial needs.
- Prevent crime, fraud, money laundering, or terrorism financing.
- Manage our risks and review credit or loan eligibility.
- Market products of the Bank and affiliates (you may opt out at any time).
- Process transactions, design products, and profile customers.
- Notify you of changes to our Services.
- Provide customer care and internal operations.
- Audit, statistical, or research purposes.
- Monitor telephone conversations for quality assurance and fraud prevention.
- Recover any debts owed to the Bank.
- Detect, prevent, and address technical issues.
- Comply with applicable legal and regulatory requirements.
6.0 How do we share your information?
We may share your personal data only as permitted by law or where necessary to provide our services. All third parties are required to comply with confidentiality, data protection, and security obligations.
6.1 Internal Sharing
Within the Bank, its branches, and subsidiaries.
6.2 Government, Regulators & Agencies
For compliance with NDPA 2023, GAID 2025, reporting, investigations, and national security matters.
6.3 Authorized Service Providers and Data Processors
- Technology and cloud service providers.
- Card processors, switching companies, acquirers, and payment partners.
- Customer support providers.
- Business continuity and infrastructure providers.
- Outsourced operational or administrative partners.
6.4 Professional Advisers and External Auditors
External auditors, legal, tax, and other advisers.
6.5 Financial Partners
- Credit bureaus and credit reference agencies.
- Correspondent banks.
- Guarantors for credit facilities.
- Card issuing/processing partners.
6.6 Third-Party Partners
Approved partners for contractual, statutory, or employment services. We do not share data with third parties for their own marketing purposes.
6.7 Law Enforcement, Courts and Public Authorities
Where required by law or necessary to protect rights and investigate wrongdoing.
6.8 Protection of Vital Interests and Safety
Sharing with emergency services when necessary to protect life or safety.
6.9 Mergers, Acquisitions or Corporate Restructuring
Data may be shared with relevant parties with appropriate safeguards.
6.10 Joint Account Holders
Information may be shared among joint account holders.
6.11 Cross-Border Transfers
Transfers outside Nigeria comply with NDPC requirements: adequacy decisions, legally binding agreements, contractual safeguards, and other lawful mechanisms.
6.12 Your Consent
Where required, we will seek your consent and you may withdraw it at any time.
7.0 How we secure your Information
We implement organisational and technical measures to keep your data confidential and secure โ including encryption and access controls. No method of transmission over the Internet can guarantee 100% security. You are responsible for safeguarding your password and authentication details.
8.0 How long we keep your information
We retain your information for as long as the purpose for collection continues, after which it is securely destroyed unless retention is required for legal, regulatory, or compliance reasons.
9.0 Information from locations outside Nigeria
If you are outside Nigeria, your data will be processed in Nigeria. Submission of your information represents your agreement to that transfer.
10.0 Accuracy and update of your Information
You are responsible for ensuring the information provided is accurate. Notify us of changes via help@altbank.ng or 02017000555 / 02018889090.
11.0 Your Rights
Under the Nigeria Data Protection Act (NDPA 2023) you have the right to:
- Confirmation and access to your personal data.
- Rectification or update of inaccurate data.
- Erasure ("right to be forgotten") subject to legal exceptions.
- Restriction of processing while a request is resolved.
- Object to processing, including direct marketing.
- Data portability in a commonly used electronic format.
- Withdraw consent at any time.
- Be informed of data sources.
- Object to automated decision-making that significantly affects you.
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC).
12.0 Privacy of minors
We do not knowingly collect personal information from children. We do not allow children under 18 to open accounts without guardian consent. Parents or guardians who believe their child has provided data without consent should contact us promptly.
13.0 Social Media Platforms
We operate designated pages on some social media platforms and monitor public comments to improve our Services. Content posted on those platforms is subject to their own terms and privacy policies.
14.0 Career Platforms
As part of recruitment, you consent to the collection and processing of data from application forms, CVs, identity documents, and interviews for assessing suitability for employment.
15.0 Third Party Websites
Our website may link to sites not operated by us. We assume no responsibility for the security, privacy practices, or content of third-party websites.
16.0 Service Providers
We may employ third-party companies to facilitate our Service. They have access to your Personal Data only to perform tasks on our behalf and are obligated not to disclose or use it otherwise.
17.0 Changes to this Policy
We may modify this Privacy Policy from time to time. Any changes will be communicated on our website, via email, or by placing a notice on our Platform. Continued use after changes constitutes acknowledgement and consent.
18.0 Contact Us
If you have questions or requests regarding this Privacy Policy, please email DPO-Altbank@altbank.ng or call 02017000555 / 02018889090, or write to:
- The Data Protection Officer
- Alt Bank Limited
- 22 Marina, Lagos