Personal Information at Imperial Homes.
We’re Imperial Homes Mortgage Bank Limited (‘we’, ‘our’, ‘us’) and operate under the name Imperial Homes Mortgage Bank Limited. We’re registered with the Corporate Affairs Commission with the number RC177098.
This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information. You don’t have to share any information with us, but to use our services, we’ll need some information from you. This policy also contains information about when we share your personal information with third parties (such as our service providers and credit bureaus).
What information do we collect?
Information you give us on Imperial Homes app
We collect and use any information you supply when you interact with any of our touch points. When you open an account with us, you share details like your name, BVN, ID, address and a picture. By using our card or the app to transact, you also share details of your transactions with us. Additionally, we may request explicit permission to see other information like your address book, location, photos and data from your camera.
· Details you give when you sign up for a Imperial Homes account, like your BVN, name, date of birth, gender, phone number, residential address, and email address.
· Your passport photograph, utility bill, ID and signature are also collected and stored for KYC purposes
· Information you give us through the in-app forms so we can help you.
Information you give us when you contact us
If you contact via other means than through the app, we collect the following information so we can answer your questions or take action.
· The phone number you’re calling from and information you give us during the call
· The email address you use and the contents of your email (and any attachments).
· Public details from your social media profile (like Facebook, Instagram or Twitter) if you reach out to us via these platforms, and the contents of your messages or posts to us.
Information we collect when you use Imperial Homes website
· The mobile network and operating system you use,
· Your IP address and device ID
· Your phone contacts so you can make airtime purchases or pay contacts on Imperial Homes
Information we get from third parties
As part of our KYC (Know Your Customer) process, we run checks on the ID information you supply during signup. Also, we run further checks with the credit bureaus to check if we can offer you an overdraft.
How do we use your information?
The Nigerian Data Protection Regulation says we need to have a lawful basis for using your personal information. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent.
1. Contractual Obligation
We collect certain data from you to fulfil the contract we have with you, or to enter into a contract with you. We use this data to:
· Give you the services we agreed to in line with our terms and conditions.
· Send you messages about your account and other services you use if you get in touch, or we need to tell you about something.
· Exercise our rights under contracts we’ve entered into with you, like managing, collecting and recovering money you owe us.
· Investigate and resolve complaints and other issues.
2. Legal Duty
We have to ensure we aren’t breaking any laws by banking you by preventing illegal activities like money laundering and fraud. To do this, we need your data to
· Confirm your identity when you sign up or get in touch.
· Prevent illegal activities like money laundering, tax evasion and fraud.
· Keep records of information we hold about you in line with legal requirements.
· Adhere to banking laws and regulations (these mean we sometimes need to share customer details with regulators, tax authorities, law enforcement or other third parties).
3. Legitimate Interest
In some instances, we need to use the data you supply us for our legitimate interests. This means we’re using your data in a way that you might expect us to, for a reason which is in your interest and doesn't override your privacy, interests or fundamental rights and freedoms.
4. Public interest
Where processing is necessary for the performance of a task or function carried out in the interest of the public
For certain information, we’ll ask for your consent. We’ll ask for your consent to:
· Market and communicate our products and services. You can always unsubscribe from receiving these if you want to
· Help protect you against fraud by tracking the location of your phone if you’ve authorized it
· View your contact list for airtime purchases.
Who do we share your information with?
We will usually not share your Personal Data with other third parties without your consent.
Where we need to transfer your data to another country, such country must have an adequate data protection law.
Where we need to send your data to a country without an adequate data protection law, we shall ensure that such transfer is subject only to the exceptions contained in Article 2.12 of the Nigeria Data Protection Regulation 2019.
In some instances, we will share the information provided with some third parties that we do business with, like card producers and credit agencies, or with law enforcement agencies when required.
How long do we keep your data?
We keep your information as long as you are an Imperial Homes customer and for any additional period as required under applicable law or regulations.
These retention requirements supersede any right to erasure requests under applicable data protection laws. We cannot therefore erase your data in relation to your Imperial Homes Account until after this time period, however we can assure you that your data will be held safely and securely whilst under our supervision.
Where do we store your data?
The Personal Data that we collect from you will be transferred to and stored at destinations within Nigeria. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy.
How do we secure your data?
We adopt robust technologies and policies to ensure the Personal Data we hold about you is suitably protected. We take steps to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.
Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
We have also taken measures to comply with global Information Security Management Systems (ISMS). We therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.
When do we delete your data?
We are basically storing and processing your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires us to store it.
If you choose to delete your Imperial Homes account, we will delete any data you have previously given us.
What are your rights?
· You have a right to consent to this Policy and to withdraw your consent at any time
· You have the right to access and request the information that we have of you in our records, ask that we update the personal information we hold about you or correct such personal information which you think is incorrect or incomplete, and we will grant this request as long as we’re legally allowed to
· You may also ask us to delete our record of you, restrict the way in which we use your personal information.
· You also have the right to object to us using your information for our marketing purposes or any additional services we may be offering you.
How to make a complaint
At Imperial Homes, we are extremely committed to respecting and protecting your information. If you have any worries or reservations about your personal information, please contact our Data Protection Officer by:
· Sending a message via the app · Emailing us at firstname.lastname@example.org
· Writing to us at 27 Keffi Street, Off Awolowo Road, Lagos, Nigeria.
Changes to this document
This document will be reviewed on a yearly basis by our Data Protection Officer. If we make any changes, we will add a note to this page and if they are significant changes, we will let you know by email.