Diobu Microfinance Bank Limited

1. Introduction

Diobu Microfinance Bank ("we", "us", "our", or "the Bank") is a microfinance bank licensed in Nigeria by the Central Bank of Nigeria. We are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal data when you interact with our website, mobile application, and banking services.

This Policy is designed to comply with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR) 2019, and other applicable data protection laws. By accessing our Services, opening an account, or using our mobile app, you consent to the processing of your personal data as described in this Policy.

2. Definitions

Term	Meaning
Personal Data	Any information relating to an identified or identifiable natural person, such as name, identification number, location data, or online identifier.
Processing	Any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
Data Subject	Any individual whose Personal Data is being processed.
Data Controller	Diobu Microfinance Bank, which determines the purposes and means of processing Personal Data.
Data Processor	Any third party that processes Personal Data on behalf of the Bank.
Services	Our banking products and services offered through our website, mobile application, branches, and other channels.

3. Information We Collect

3.1 Personal Data You Provide

We collect personal information you provide directly to us, including:

Identity Data: Full name, date of birth, gender, marital status, nationality, signature
Government Identifiers: Bank Verification Number (BVN), National Identification Number (NIN), passport details, driver's license, voter's ID
Contact Data: Email address, phone number, residential address, mailing address
Financial Data: Bank account details, transaction history, income information, payment card details
Credentials: User ID, password, PIN, security questions and answers for authentication
Biometric Data: Fingerprint or facial recognition data (if used for secure login and identity verification)

3.2 Information Collected Automatically

When you use our website or mobile app, we may automatically collect:

Technical Data: IP address, browser type and version, operating system, device identifiers
Usage Data: Pages visited, time spent, date and time of access, clickstream data
Location Data: Approximate or precise location derived from GPS, Wi-Fi, or mobile network (with your permission)
Cookies and Tracking Data: Information collected through cookies, web beacons, and similar technologies

3.3 Information from Third Parties

We may receive information about you from:

Credit reference agencies
Identity verification providers
Government agencies (e.g., for KYC and AML compliance)
Social media platforms (if you grant access)

4. How We Use Your Information

We use your personal data for the following purposes:

4.1 Service Delivery

To process transactions and provide banking services
To open and manage your accounts
To verify your identity and authenticate transactions
To send account notifications and service updates
To provide customer support and resolve disputes

4.2 Legal and Regulatory Compliance

To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) requirements
To perform Know Your Customer (KYC) checks
To report to regulatory authorities as required by law
To prevent and detect fraud, financial crime, and unauthorized access

4.3 Business Operations

To improve and enhance our products and services
To analyze usage patterns and trends
To conduct market research and surveys
For internal auditing and training purposes

4.4 Marketing and Communications

To send you promotional offers and information about our products (with your consent)
To personalize your experience on our platforms
To deliver targeted advertising tailored to your interests

5. Legal Basis for Processing

We process your personal data on the following legal grounds:

Basis	Description
Consent	You have given explicit consent for specific processing activities
Contract	Processing is necessary for the performance of a contract with you
Legal Obligation	Processing is required to comply with applicable laws and regulations
Legitimate Interest	Processing is necessary for our legitimate business interests
Vital Interest	Processing is necessary to protect your vital interests

6. How We Share Your Information

We may share your personal data with:

6.1 Service Providers

Identity verification and KYC service providers
Payment processing and card scheme partners
IT and cloud service providers
Analytics and marketing service providers

6.2 Regulatory and Government Authorities

Central Bank of Nigeria (CBN)
Nigeria Data Protection Commission (NDPC)
Law enforcement agencies (in response to valid legal requests)
Other government agencies as required by law

6.3 Business Partners

Affiliates and subsidiaries
Partner financial institutions
Credit reference bureaus

6.4 Other Circumstances

In connection with a merger, acquisition, or sale of assets
To protect our rights, property, or safety, or that of others
With your explicit consent

We do not sell or trade your personal information to third parties.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy or to comply with legal and regulatory requirements.

Retention Periods:

Account Information: Retained for as long as you maintain an account with us
Transaction Records: Retained in accordance with CBN guidelines and statutory requirements
KYC Documentation: Retained for regulatory compliance and audit purposes
Closed Accounts: Historical records may be retained as required by law, though further processing ceases from account closure

When personal data is no longer required, we will securely delete or anonymize it.

8. Data Security

We implement robust security measures to protect your personal data:

Encryption: Data is encrypted during transmission using SSL/TLS protocols and stored securely
Access Controls: Role-based access controls and multi-factor authentication for authorized personnel only
Firewalls and Intrusion Detection: To protect against unauthorized access and cyber threats
Regular Audits: Periodic security assessments and monitoring
Staff Training: All employees receive data protection and privacy training

Despite our efforts, no transmission over the internet is 100% secure. You use our Services at your own risk.

9. Your Privacy Rights

You have the following rights regarding your personal data:

Right	Description
Right to Access	Request a copy of the personal data we hold about you
Right to Rectification	Request correction of inaccurate or incomplete data
Right to Erasure	Request deletion of your personal data (subject to legal obligations)
Right to Restrict Processing	Request limitation of how we process your data
Right to Object	Object to processing for marketing or other purposes
Right to Data Portability	Request transfer of your data to another organization
Right to Withdraw Consent	Withdraw consent at any time (does not affect prior processing)

To exercise any of these rights, please contact our Data Protection Officer using the details provided below.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Manage sessions and logins
Store user preferences
Monitor platform performance
Improve user experience
Analyze usage patterns

You can manage cookie preferences through your browser settings. Disabling cookies may affect some website functionalities.

11. Children's Privacy

Our Services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors without parental consent. If you are a parent or guardian and believe your child has provided us with personal data, please contact us.

12. Third-Party Links

Our website or mobile app may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Data Protection Officer

The Bank has appointed a Data Protection Officer (DPO) responsible for overseeing data protection strategy and compliance.

Contact our DPO at:

Email: dpo@diobumfb.com

Address: Data Protection Officer, Diobu Microfinance Bank, 331 Old Refinery Road Elelenwon Akpajo, Rivers State, Nigeria

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page and made available at our branches, with the "Effective Date" updated accordingly.

Your continued use of our Services after changes are posted constitutes acceptance of the updated Policy.

15. Complaints

If you believe we have processed your personal data unlawfully, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us:

By Email: privacy@diobumfb.com.ng

By Phone: 09040705399

By Mail: 331 Old Refinery Road, Elelenwon Akpajo, Rivers State, Nigeria

This Privacy Policy is compliant with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR) 2019.

Privacy Policy