Ecobank Privacy Notice

Ecobank Group recognizes the importance of privacy and security of our customers' personal information. We value the trust you place in us to protect your personal information and respect your right to privacy. While new technologies have dramatically changed the way information is gathered, used, and stored, preserving customer trust and the privacy of personal information at Ecobank remains a core objective. We believe it is important to make clear to our customers how information is being collected, used, and shared at Ecobank, the benefits such use provides, and the protections put in place against unauthorized access and use. We respect your privacy and the confidentiality of your personal information, and we appreciate the opportunity to do business with you.

1 . Our Privacy Principles

We will only collect, transfer, process and store your personal information with your express permission unless legally required to do so and will only use such information for the lawful purpose for which it is required. We will disclose the specific purpose for which we use, request, and store your personal information. We will also keep a record of that personal information and the specific purpose for which we collect it. We will not use your personal information for any other purpose, other than that which we disclosed to you, unless you give us your express consent to do so, or unless we are permitted to do so by law.

 

2. Information We Collect

The personal data we would like to collect from/process on you is:

Personal Data Type Sources
Name such as full name, maiden name, etc. Account opening forms, Registers, etc.
Date of Birth, Place of birth, Racial or Ethnic origin, Employment information, etc. Account opening forms, Employment forms, etc.
Address (Email/Home/Office) Account opening forms, Employment forms, etc.
Bank Details/Bank Verification Number, Passport number, Tax number, Debit/credit card number, etc.  
Medical Information/History Employment forms, HMOs, etc.
Religious or Philosophical beliefs  
Asset information such as IP Address, MAC address, etc. Intranet tracking activity, Domain login information records, etc.
Sexual Orientation  
Personal characteristics such as Biometric Records, Fingerprints, Face /Selfie Data, Handwriting, Photographic image, etc. CCTV coverage, passport photographs, Phone cameras etc.

The personal data we collect will be used for providing essential banking services to clients and customers, as well as for marketing purposes and fulfillment of our contract obligations, etc.

Ecobank is bounded by the following legal basis for processing the personal data we collect:

  • Legal/regulatory obligation
  • Data subjects’ consent
  • Performance of contract obligations

Any legitimate interests pursued by us, or third party we use, are as follows

  • Vital interest
  • Public interest

The special categories of personal data concerned are:

  • Names
  • Addresses
  • Identification number • Email address, etc.
 

3. Consent

Ecobank requires your explicit consent to process collected personal data. By consenting to this privacy policy, you are giving us the permission to use/process your personal data specifically for the purpose identified before collection.

If, for any reason, Ecobank is requesting sensitive personal data from you, you will be rightly notified why and how the information will be used. You may withdraw consent at any time by requesting for Withdrawal of Consent form, following the Ecobank’s Withdrawal of Consent Procedure.

3.1 Disclosure

Ecobank will not pass on your personal data to third parties without first obtaining your consent.

3.2 Data Subject Right Request

At any point while Ecobank is in possession of or processing your personal data, you, the data subject, have the right to:

  • Request a copy of the information that we hold about you.
  • Correct the data that we hold about you that is inaccurate or incomplete.
  • Ask for the data we hold about you to be erased from our systems/record.
  • Restrict processing of your personal data where certain conditions apply.
  • Have the data we hold about you transferred to another organization.
  • Object to certain types of processing like direct marketing.
  • Object to automated processing like profiling, as well as the right to be subject to the legal effects of automated processing or profiling.
  • Judicial review, if Ecobank refuses your request under rights of access, we will provide you with a reason as to why. And you have the right to complain as outlined in clause 3.5 below.

All the above requests will be forwarded, should there be a third party involved in the processing of your personal data.

3.3 Complaints

If for any reason you wish to make a complaint about how Ecobank (or any of our third parties described in 3.1 above) processes your personal data, or how your complaint has been handled, you have the right to lodge a complaint directly with the Data Protection Officer of Ecobank.

When you wish to file a data privacy complaint, you are required to send a request to groupdataprivacy@ecobank.com. Ecobank shall contact you within fourteen days to validate the request for processing.

 

4. Online Privacy Statement

How We Use Your Information

This privacy notice tells you how we, Ecobank, will collect and use your personal data for relationship management, profiling, business analytics/development, communication, registration, subscription, cookies, and all-round efficient service delivery.

Information We Collect On Our Various Channels

We may collect some personal information from you directly. We may collect information from you when you register on our various platforms which includes Internet banking portal, Mobile App, Rapid Transfer, Personal banking channels, WhatsApp/Facebook.

  • We may collect information from you when you register on our Internet Banking portal.

    We may collect, amongst others, your name, e‐mail address, phone number, date of birth, nationality, gender, residential address, identity (ID) number, copy of your ID and a photograph, biometric data, device ID, device location, and details of your Debit/Credit/Prepaid Card. We collect information about you based on your use of our products, services, or service channels (like our websites, applications, ATMs).

    In addition to creating an Internet Banking Profile, we collect and process your Debit/ Credit/Prepaid Card information such as the Card PAN, Expiry Date, Card Currency, Name on Card, and Card Billing Address

    In certain circumstances, we collect information about you whereas you do not have a direct relationship with us, for example if you are a beneficiary of transfer of funds made by our customer.

  • We may collect information from you when you register on our mobile app.

    We may collect your name, e‐mail address, phone number, date of birth, gender, residential address, ID number, Face/Selfie Data, device ID, and device location when onboarding on our MySME App.

    Our identity verification Third Party SDK Provider collects your personal data via our Mobile App (MySME) through the use of Apple's Inc. 's (“Apple”) TrueDepth Application Programming Interface (“TrueDepth API”).

    The use of your personal data collected as a result of this is to ensure liveness and confirm that the user is a real person. This data is used exclusively for real-time analysis during the verification process and is not stored. We use ARKit to capture your face 3D spatial orientation and facial expressions. Once liveness is verified, we proceed to capture your facial image.

    Importantly, TrueDepth data is never persistently stored on the user's device nor transmitted outside the device. Its usage is strictly limited to ensuring that the captured selfie image is of a live user.

    For debit card onboarding, we may collect debit card number and PIN from you and collect other personal information from our core banking system as part of your profile creation in the mobile app. For internet banking onboarding, we collect username and password from you and collect other personal information from our core banking system as part of the profile creation. For Xpress account onboarding we may collect your name, e‐mail address, phone number, date of birth, gender, residential address, ID number, device ID, and device location.

  • We may collect information from you when you register on our channels.

    We may collect your name, e‐mail address, phone number, date of birth, gender, residential address, ID number, device ID, and device location (when onboarding on our Xpress Account service).

  • We may collect information from you when you register on our Rapid transfer App.

    We may collect, amongst others, your name, e‐mail address, phone number, date of birth, nationality, gender, residential address, identity (ID) number, copy of your ID and a photograph, biometric data, device ID, device location, and details of your Debit/Credit/Prepaid Card. We collect information about you based on your use of our products, services, or service channels (like our websites, applications, ATMs).

    To create a Rapid transfer Profile, we collect and process your Debit/Credit/Prepaid Card information such as the Card PAN, Expiry Date, Card Currency, Name on Card and Card Billing Address.

  • We may collect information from you when you register on our chatbot.

    We may collect your name, e‐mail address, phone number, date of birth, gender, residential address, ID number, device ID, and device location. When onboarding on our Xpress Account service, we may also collect information about you from your profile on Facebook.

    We may collect information identifiers and information such as IP address, browser version, operating system, and software data. When we collect information about you from your profile on Facebook, the privacy notice between you and Facebook shall apply.

  • We may collect and combine information when you register on our mobile banking services

    including information you provide to us, device IDs, cookies, and other signals, including information obtained from third parties, to associate accounts and/or devices with you. We collect information about you when we receive it from third parties and affiliates. We may collect information about you based on how you engage or interact with us on social media, emails, telephone calls and surveys.

  • We collect information from devices such as mobile phones and tablets about how you interact with our services and those of our third-party partners and information that allows us to recognize and associate your activity across devices and services. This information includes device specific identifiers and information such as IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings, and software data.
  • In certain circumstances, we collect information about you whereas you do not have a direct relationship with us, for example if you are a beneficiary of transfer of funds made by our customer.
 

Why Does Ecobank Need to Collect and Store Personal Data?

We need to collect your personal data in order for us to provide you with our services as mentioned in clause 3.1 above. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose(s) only and will in no way invade your privacy. If there is a need to use your personal data for marketing purpose, Ecobank will ensure to seek additional consent from you.

Will Ecobank Share My Personal Data with Anyone Else?

Ecobank only shares personal information with other companies or individuals in the following limited circumstances:

We have your consent. We require consent for the sharing of any sensitive personal information.

Ecobank may pass your personal data to third-party service providers contracted by us. Any third party that we may share your personal data with is under an obligation to secure your details and use them only to fulfill the service for which they were contracted. When they no longer need your details to fulfill this service, the data will be disposed in line with the Ecobank’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are required to do otherwise, legally.

We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Ecobank, its users or the public as required or permitted by law.

If Ecobank becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

How Will Ecobank Use the Personal Data It Collects About Me?

We will process (collect, use, and store) the information you provide in a manner that complies with the EU’s General Data Protection Regulation (GDPR) and the Local Data Protection Regulations. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Ecobank is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. The retention period for certain kinds of personal data may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Information collected will be used for:

  • Services

    We use your data we have collected to authenticate you and authorize access to our services on the channels. These services include, amongst others, money transfer services, KYC validation, and exchange rates conversion.

  • Communication

    We will contact you through email, short message services (SMS), phone call, and other ways through our services, including text messages and push notifications. We will send you messages about the availability of our services, security, or other service-related issues. We also send messages about how to use the services and network updates.

  • Advertising and Marketing

    We serve you tailored advertisements through our apps, other channels, and media of our services. We target advertisements in our Apps and through other channels and media to customers of our services through a variety of ad networks and exchanges, using data from advertising technologies and information from advertising partners, publishers, and data aggregators.

    We use data and content about our customers for invitations, promotions, and communications solely for promoting our services.

  • Customer Support

    We use the data needed to investigate, respond to, and resolve complaints and service issues.

  • Security, Fraud, and Investigations

    We use your data for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our customers and/or visitors.

How do we secure your information?

Ensuring the security of our systems and safeguarding our users' information is of utmost importance to Ecobank. It is fundamental to upholding the integrity of our brand and providing our customers with a secure and trustworthy experience across all our platforms, including our websites, apps, advertising services, products, and technologies. Our commitment to protecting user data is integral to maintaining the trust our customers place in us:

  • Ecobank has technical, administrative, and physical safeguards in place to help protect against unauthorized access, use or disclosure of customer information we collect or store.
  • We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.
  • We offer the use of a secure transmission, processing and storage services using standardized security safeguards.
  • All supplied sensitive/credit information are encrypted via transaction layer security (TLS) technology during transmission to avoid misuse of your data. Card Number (PAN), CVV and expiry date of any debit, credit and prepaid cards attached to our apps are tokenized and stored on our backend systems at our data processor.
  • Your personal information may be accessible by those authorized with special access rights to such systems and are required to keep the information confidential. Information such as PINs and passwords are not accessible to our authorized personnel.
 

Under what circumstances will the Ecobank Contact Me?

We do not intend to be intrusive, and we will not ask irrelevant or unnecessary questions. Moreover, we will subject the information you provide to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.

Can I Find Out the Personal Data That Ecobank Holds About Me

Ecobank, at your request, can confirm what information we hold about you and how it is processed. If we do hold your personal data, you have the right to request the following information:

  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • Information about interests, if the processing is based on the legitimate interests of Ecobank or a third party.
  • The categories of personal data collected, stored, and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • Information about how we intend to securely transfer the personal data to a third party or international organization. The Attorney General of the Federation will approve sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority
  • Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if you didn’t provide it directly.
  • Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
 

How long will Ecobank Store My Personal Data?

We keep most of your personal data for as long as your account is active. We retain the personal data you provide while your account is in existence or as needed to provide you with our services.

What Forms of ID Will I Need to Provide in Order to Access This?

Ecobank accepts the following (but not limited to) forms of ID when information on your personal data is requested: International Passport, Driving License, National Identity Card, and Permanent Voter’s Card.

 

5. Account Closure

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, and prevent fraud.

 

6. Protecting Children’s Privacy

Our services are for a general audience. We do not knowingly collect, use, or share information that could reasonably be used to identify children without prior parental consent consistent with applicable law.

 

7. Changes to our Privacy Policies

We may update this Privacy Notice to reflect changes to our information practices, if we make any material changes, we will notify you by an email (sent to the email address specified in your account) or by means of a notice on this website or via a link from your mobile application prior to the change becoming effective. We encourage you to periodically review this page for updates on our privacy practices.

 

8. Contact us

If there are any questions regarding this Privacy Notice, any further information you would need, or a data breach incident you would like to report on, please contact us using the information provided below.

 

Data Protection Manager

eProcess International S. A.

2 Morocco Lane, Off Independence Avenue

P. O. Box AN 16746, Accra-North

Accra, Ghana