Privacy Policy – Parkway Microfinance Bank

Parkway Microfinance Bank Limited

Parkway Microfinance Bank Limited (Parkway MFB) is a microfinance bank duly registered in Nigeria and authorized and regulated by the Central Bank of Nigeria to offer banking services.

This Privacy Policy (“Policy”) regulates how Parkway Microfinance Bank Limited (“Parkway MFB”, “we”, “us”, “our”) processes the personal information of our data subjects such as customers, staff, vendors, third parties and visitors to our website(s) and mobile application(s) (hereinafter referred to as, the “Sites”, including existing websites [www.parkwaymfb.com], mobile applications, and all other additional websites and mobile applications produced and/or managed by Parkway MFB from time to time). This Policy discloses our data protection practices on our Sites, products and subscriber-based services (“Services”), inclusive of what personal information we collect, what we do with it and how we protect it.

We are committed to protecting your personal data (i.e. any information you provide to us or that we collect from you, through which you can be identified) in accordance with the provisions of the Nigeria Data Protection Act (NDPA) 2023 and its General Application Implementation Directive (GAID) 2025.

This policy sets out the basis on which your personal information will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By continuing to visit or use the Sites and other Parkway MFB customer touch points, you accept and consent to the practices described in this policy.

Principles for Processing Personal Data

Parkway Microfinance Bank Limited is committed to processing data in accordance with its responsibilities under the Nigeria Data Protection Act.

Part 5 of the Nigeria Data Protection Act requires that personal data shall be:

processed lawfully, fairly and in a transparent manner in relation to individuals;

collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay;

kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the NDPA to safeguard the rights and freedoms of individuals; and

processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Lawful Basis for Processing Personal Data

All data processed by Parkway Microfinance Bank Limited must be done on at least one of the following lawful bases: Consent, Performance of a Contract, Legal Obligation, Vital Interest, Public Interest, Legitimate Interest.
Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Parkway Microfinance Bank Limited systems.

INFORMATION WE MAY COLLECT FROM YOU

When you use the Sites or services, we collect and store your personal data, which is provided by you (for example, we collect information when you register or log on to the Sites, create an account, subscribe to a Service, participate in any interactive features on our Services, fill out a form, take part in surveys, upload any documentation, request customer support, make an enquiry, communicate with us by email, phone or post, interact with us on social media, etc.) from time to time.

While using our services, we may obtain contact, financial and transaction data from providers of technical, payment, credit referencing and delivery services based both inside and outside Nigeria. We utilise third-party service providers to secure information related to financial crime, fraud, sanctions and politically exposed persons. We may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal data”). Personally identifiable information in this context may include, but is not limited to:

Identity Data: Full Name, maiden name, marital status, title, national identification number (NIN), international passport details, driver’s licence details, date of birth, gender, address, and citizenship. We may also request for your next of kin’s details, such as name, phone number, email address and residential address;
Contact Data: Address, Email Address and Telephone Numbers;
Financial Data: Bank account information and bank statements, Bank verification Number (BVN), income and outgoings, financial position, status, and credit history, payment card information and account number;
Transaction Data: Information regarding the products and services a data subject may have benefited from by using Parkway MFB, transactional information in respect of products purchased and location data of transactions where a data subject may have used their debit card;
Profile Data: This includes username and password;
Other Data: (CCTV / Video footage, telephone conversation made via calls to our contact centre lines, use of analytics to collect, monitor and/or analyze data, interests, feedback and survey responses.

Our primary goal in collecting the above stated personal data is to provide you with a safe, efficient, smooth and customised experience. This allows us to provide services and features that most likely meet your needs.

We will not sell, share, transfer or rent out any personal information to others in ways different from what is disclosed in this Policy, and our terms and conditions of use. We may share generic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers.

Parkway MFB will require the explicit consent of data subjects to process personal data. Irrespective of initial consent given, data subjects can withdraw their consent at any time by filling out ourConsent Withdrawal Form However, this will not affect the lawfulness of any processing carried out before the withdrawal of consent. Where consent is withdrawn, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Who Is Responsible for Your Personal Information?

Parkway Microfinance Bank Limited is your data controller and is responsible for processing your personal information described in this Privacy Policy. Parkway Microfinance Bank Limited uses the personally identifiable information you provide to communicate with you in response to your enquiries, to provide the services you request, and to manage your account. Any personally identifiable information gathered by Parkway Microfinance Bank Limited will be used for these purposes only. We will not disclose or divulge such data outside of Parkway Microfinance Bank Limited, other than to third-party providers that assist us in providing the services. Parkway Microfinance Bank Limited does not share, sell, rent or trade personally identifiable information with third parties for their promotional purposes.

Why does Parkway Microfinance Bank Limited need to collect and store personal data?

In order for us to provide you with a service, we need to collect personal data. When you sign up for any Parkway Microfinance Bank Limited Online Solution or other Parkway Microfinance Bank Limited service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, such as our payment services, we require your debit or credit card information. We typically do not store this information and when we do, we maintain the data in encrypted form on secure servers. We may combine the information you submit under your account with information from other Parkway Microfinance Bank Limited services or third parties in order to provide you with a better experience and to improve the quality of our services. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Parkway Microfinance Bank Limited would contact you for additional consent.

How will Parkway Microfinance Bank Limited use the personal data it collects about me?

Parkway Microfinance Bank Limited will process (collect, store and use) the information you provide in a manner compatible with the Nigeria Data Protection Act (NDPA). We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary, but we depend on our users to update or correct their personal information whenever necessary. Parkway Microfinance Bank Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept 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.

Parkway Microfinance Bank Limited only processes personal information for the purposes described in this Privacy Policy and/or the supplementary privacy notices for specific services. In addition to the above, such purposes include:
Providing our services to users, including the display of customised content;
Auditing and analysis in order to maintain, protect and improve our services;
To respond to your enquiries and fulfil any of your requests for information;
To process transactions and send you notices about your transactions;
To verify your identity;
To provide customer care and support services;
To resolve disputes and troubleshoot problems;
To improve our services by implementing aggregate customer preferences;
To manage and protect our information technology infrastructure;
To monitor and/or prevent fraud, and comply with applicable anti-money laundering laws;
To monitor traffic patterns and usage of the Sites to help to improve the Sites design and layout;
To record and store communications with customers by phone, emails, app and website chat function, etc;
To personalise your experience on our Sites or communications;
To send you important information regarding the services and/or other technical notices, updates, security alerts, support and administrative messages;
To send you marketing, promotional communications and targeted advertising for our business purposes with your consent;
To poll your opinions through surveys or questionnaires; and
As Parkway MFB believes to be necessary or appropriate:
To comply with a legal obligation. This applies where the processing is necessary for Parkway MFB to comply with the law.
To protect Parkway MFB’s legitimate interests, privacy, property or safety, and/or those of a third party, as long as it does not conflict with the requirements for the protection of your personal data.
To protect your vital interests.

DATA PROTECTION IMPACT ASSESSMENTS

Further to our commitment to protecting your personal data and in compliance with applicable data protection laws and regulations, Parkway MFB conducts Data Protection Impact Assessments (DPIAs) where data processing activities are likely to result in high risks to the rights and freedoms of data subjects. We maintain a record of DPIAs conducted and review them periodically or when significant changes occur in our processing operations.

DATA SUBJECT RIGHTS

Your personal data is protected by legal rights enshrined in Data Protection Laws. These rights include the following:

Right to be informed about the processing of personal data;
Right to access personal data held by us;
Right to rectify inaccurate or incomplete information;
Right to request erasure of personal data from the Bank’s systems/records under certain conditions;
Right to withdraw consent for processing personal data at any time, in cases where consent has previously been given, to the extent our processing relies on your consent as the lawful basis for processing. This right may not apply if there are other legal justifications to continue processing or we need to retain certain personal data where required or permitted under applicable law.
Right to object to the processing of personal data, for example, direct marketing;
Right to object to the automated processing of your personal data or to object to any decisions based on the automated processing of personal data, including profiling. Where we use AI to make a decision that has a significant legal impact on you, you have the right to request human intervention or request a review of the decision. However, we may refuse your request where such automated decisions are permitted by applicable law.
Right to data portability i.e., the right to request that personal data be sent to a third party;
Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

If you would like to exercise any of the above stated rights, you can fill out our Data Subject Request Form specifying the right you wish to exercise.

We will endeavour to process all subject access requests within thirty (30) days and if any further extension is required, we will communicate same through existing consented channels – at no cost. However, please note that you may continue to receive existing communications for a transitional period whilst we update your preferences.

Please note that if you request for a copy of your personal data, you may be required to pay a fee if the requests are considered manifestly unfounded or excessive.

RETENTION OF YOUR DATA

We will not retain your personal data for longer than is necessary for the purposes for which such personal data is processed. This means that your personal data will only be retained for as long as it is still required to provide you with the services or is necessary for legal reasons. When calculating the appropriate retention period of your personal data, we consider the nature and sensitivity of the personal data, the purposes for which we are processing such personal data, and any applicable statutory/regulatory retention periods.

As a regulated financial services institution, Parkway MFB will retain your personal data for a period of ten (10) years after the termination of the relationship by the data subject or as may be required by regulation; while transaction documents/data will be retained for a minimum period of five (5) years in line with CBN regulation.

Notwithstanding the foregoing and pursuant to the NDP Act 2023, we shall be entitled to retain and process personal data for archiving, scientific research, historical research or statistical purposes for public interest, while protecting your identity and privacy rights as the case may be.

KEEP YOUR DATA UP TO DATE

It is important that the personal data Parkway MFB holds about you is accurate and current. Please keep Parkway MFB informed if any aspect of your personal data changes at any time during your relationship with us. On our customer-facing products, you can easily update your personal data yourself or alternatively contact our Data Protection Officer via dpo@parkwaymfb.com when you want to exercise your right of rectification.

SECURITY OF YOUR DATA

In order to protect your personal data, we have implemented reasonable and effective organizational and technical security measures to protect your personal information from unauthorized access, data loss, misuse, alteration or destruction. These measures include data encryption, restricting access to your personal data to certain employees, ensuring that our internal information technology systems are suitably secure, and implementing procedures to deal with any suspected data breach. Additionally, our employees are trained to respect the confidentiality of any personal information that we hold. We also conduct security audits and vulnerability assessments regularly.

Where we have provided you (or where you have chosen) a password which grants you access to specific areas on our site, you are responsible for keeping this password confidential. We request that you do not share your password or other authentication details (e.g. token-generated codes) with anyone.

Despite our best efforts and intentions, we acknowledge that security cannot be absolutely guaranteed against all threat actors. Hence, you are encouraged to only access our Services within a secure environment and not share your passwords, as transmission of personal information to and from our Services is at your own risk.

In the unlikely event of a data breach, Moniepoint MFB will take steps to mitigate any loss or destruction of data and, where applicable, notify you and the Nigeria Data Protection Commission (NDPC) of such a breach.

WHERE WE STORE YOUR INFORMATION

All Personal Information you provide to us is stored on secured databases, servers and infrastructure (where applicable) for the purposes of providing seamless services to you, including but not limited to ensuring business continuity; the data that we collect from you may be transferred to or stored in cloud locations at globally accepted vendors’ data centres. Whenever your information is transferred to other locations, we will take all necessary steps to ensure that your data is handled securely and in accordance with this privacy policy.

DATA SHARING AND CROSS-BORDER TRANSFERS

Parkway MFB may be required to disclose personal data of individuals in accordance with a legal obligation in response to requests by government authorities, regulatory bodies, law enforcement agencies or law courts on matters involving public interest, national security or law enforcement requirements.

We may also need to pass your information to third party service providers which maintain, administer or develop the Sites on our behalf and the information will only be provided for such limited purposes and as detailed below. Where applicable, we execute compliant data-sharing agreements or data-processing agreements to provide an extra layer of protection for personal information shared in the process. Additionally, we may provide aggregate statistics about our customers, sales, traffic patterns and related website information to reputable third- parties, but these statistics will include no personally identifiable information.

COOKIES

Cookies are small text files stored on your device when you visit a website. These files contain information that helps enhance your browsing experience by remembering your preferences, enabling functionalities, and providing personalised services.

Parkway MFB may use the information obtained from the use of our cookies to recognise a computer when a user visits Parkway’s website, track who navigates the website, improve the website’s usability, analyze the use of its website (such as how many people visit it each day), and manage the website.

Users can disable cookies and prevent the setting of cookies by adjusting the settings on their browser.

Further details can be found in our cookie policy .

AUTOMATED PROCESSING

We sometimes use automated systems and software to help us reach decisions about you, for example, to make credit decisions, to carry out security, fraud and money laundering checks, or to process your data when you apply for some of our products and services. This type of processing is carried out under lawful basis and you have a right to request a human review of such processing as indicated under the data subject rights provisions above.

COMPLAINTS

If you believe at any time that we have not handled your personal data in accordance with this Policy, or you suspect any violation of your right, you have a right to lodge your complaint directly with the Nigerian Data Protection Commission (NDPC), at info@ndpc.gov.ng; additionally, your complaint can also be addressed to dpo@parkwaymfb.com.

Please be informed that dpo@parkwaymfb.com is a designated email that addresses data privacy complaints, requests, and inquiries ONLY.

More information

Please do not hesitate to get in touch with us via the contact page on our website if you have any questions or queries regarding our privacy policy.

To contact our Data Protection Officer, kindly address your request to “The Data Protection Officer” at 24A Campbell Street, Lagos Island, Lagos or send an email to dpo@Parkwaymfb.com