Privacy
Policy

1. Introduction

This Privacy Policy (“Policy”) outlines how Rank Microfinance Bank Limited (“Rank,” “We,” “Us,” or “Our”) collects, uses, stores, discloses, and protects the personal data of individuals, including customers, employees, clients, vendors, and other third parties. We are committed to processing personal data in a lawful, fair, and transparent manner, in full compliance with the Nigeria Data Protection Act (NDPA) 2023 and its subsidiary regulations. This Policy explains our data handling practices and the rights available to you regarding the use of your personal data.

2. Scope

This Policy applies to all personal data collected, processed, or stored by Rank across all operational channels and touchpoints. These include, but are not limited to:

1. Our mobile and web applications,
2. Physical and digital forms,
3. Voice communications (e.g. phone calls),
4. Emails, text messages, and customer service chats,
5. In-person interactions and other communication mediums, etc.

All personal data, regardless of format or means of collection, is handled in accordance with the standards, safeguards, and user rights outlined in this Policy.

3. Legal Basis For Processing: Why We Hold Your Data

This Policy is guided by the legal requirements set out in the Nigeria Data Protection Act (NDPA) 2023, which identifies lawful grounds for the collection and processing of personal data. Rank processes personal data only when there is a valid legal basis for doing so. These include:

(a) Consent: You provide consent to our processing of your personal data when you access our website, download our mobile application, or engage with our services. Consent may be withdrawn at any time, subject to legal or contractual restrictions.

(b) Legal Obligation: We may process your personal data to comply with legal and regulatory obligations under Nigerian law. For example, we are required to collect specific data for compliance with Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations.

(c) Legitimate Interest: We may process your personal data when it is necessary to pursue our legitimate business interests, provided such interests do not override your fundamental rights and freedoms. These interests may include:

1. ensuring the security of our systems and operations,
2. preventing fraud and financial crime,
3. enhancing and improving our services,
4. supporting operational efficiency and innovation.

4. Your Privacy Rights

Under the Nigeria Data Protection Act (NDPA) 2023, you have several rights in relation to your personal data. These rights empower you to maintain control over how your personal data is collected, processed, and used by Rank Microfinance Bank Limited. They are:

4.1 Right of Access

You have the right to request a comprehensive report of all personal data we hold about you. This includes information on why and how your data is processed, the categories of data involved, and any third-party recipients with whom your data has been shared.

4.2 Right to Rectification

You have the right to request or update any of your personal information that is inaccurate, incomplete, or outdated.

4.3 Right to Erasure (“Right to be Forgotten”)

You have the right to request the deletion of your personal data from our records, especially when it is no longer necessary for the purposes for which it was collected. Please note that this right may be subject to legal or regulatory requirements, such as Know Your Customer (KYC) and Customer Due Diligence (CDD) rules that require financial institutions to retain certain information for a specified period.

4.4 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transfer it to another service provider where technically feasible.

4.5 Right to Restrict Processing

You may request that we restrict the processing of your personal data to certain purposes or services, particularly where the accuracy of the data is contested, or the processing is unlawful.

4.6 Right to Object

You have the right to object to the processing of your personal data, particularly where it involves direct marketing, profiling, or is based on our legitimate interests, if you believe it impacts your fundamental rights or freedoms.

4.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Please note that your withdrawal of consent does not affect the lawfulness of any processing carried out prior to such withdrawal.

4.8 Right to Lodge a Complaint

If you believe your data has been mishandled, you may file a complaint with our Data Protection Officer. If you are not satisfied with our response, you may escalate your complaint to the Nigerian Data Protection Commission (NDPC).

4.9 How to Exercise Your Rights

To exercise any of your rights under this Policy, please send a clear written request specifying the right you wish to invoke to our Data Protection Team at dataprotection@userank.com.

5. Personal Data We Collect

We collect personal data during various interactions with our services in accordance with the Nigeria Data Protection Act (NDPA) 2023. This data helps us provide secure, compliant, and personalised financial services. The types of personal data we collect may include, but are not limited to, the following categories:

5.1 Know Your Customer (KYC) / Customer Due Diligence (CDD) Data

To comply with regulatory requirements and verify your identity, we may collect the following:

• Full name, email address, phone number, and residential address.
• Date of birth, gender, and marital status.
• Bank Verification Number (BVN) and National Identification Number (NIN).
• Government-issued identification (e.g. passport, driver’s licence).
• Biometric data (e.g. facial recognition, fingerprint scans).
• Photographs, employment or business information.
• Credit history and loan application details.
• Financial statements and transaction records.
• Account history, company registration documents, ownership structures, and cash flow analyses.

5.2 Device and Application Usage Data

To enhance platform performance and user experience, we may collect technical data from your devices, such as device type, operating system, unique device identifiers, IP address, and browser settings. With your explicit consent, we may also access GPS location data, camera access, and contacts.

5.3 Third-Party Data Sources

We may collect additional personal data from reliable third-party sources to meet regulatory obligations, assess risk, and improve service delivery. These sources include identity verification service providers, credit bureaus, banks, and regulatory databases.

6. How We Use Your Personal Data

By creating an account or using the Rank App, you give us express, informed, and revocable consent to collect, control, and process your personal data. We use your personal data to deliver secure, compliant, and personalised financial services. Below are the primary purposes:

6.1 Service Delivery

Your personal data enables us to provide and manage our core financial services, including opening accounts, processing transactions, managing loan applications, and enabling app features.

6.2 Regulatory Compliance

We process data to perform KYC/CDD checks, conduct AML/CFT screenings, comply with tax, reporting and audit requirements, and respond to lawful government requests.

6.3 Innovation and Service Improvement

We analyse personal data to improve and innovate our services, conduct internal research, understand customer behaviour and usage trends, and enhance features and user experience.

6.4 Communication and Customer Support

We use your data to send transaction alerts, receive support requests, offer promotions (with opt-out choice), and run surveys.

6.5 Security and Fraud Prevention

Your data is vital for system safety, fraud detection, verifying transactions, and protecting our infrastructure.

6. Rank App Usage Disclaimer

You acknowledge that the Rank App is provided on an “as is” basis, and that We make no warranties regarding its ability to meet Your expectations. We are not responsible for any errors, interruptions, delays, security issues, or negative experiences. Under no circumstances shall We be liable for any damages, including but not limited to direct, indirect, special, incidental, or consequential damages, losses, or expenses, arising from Your use of Our services or any performance of its terms, errors, system issues or interruptions.

7. How We Share Your Data: Third-Party Processing And Disclosures

7.1 Third-Party Service Providers

We may share your data with third-party service providers, including payment processors, identity verification providers, credit bureaus, and IT providers. We ensure that such services comply with applicable regulatory standards.

7.2 Disclosures in Fraud Investigations and Legal Requests

In cases of actual or suspected fraud, we may disclose data to the NDPC, EFCC, NFIU or CBN. This includes contact details, BVN, and transaction records. Legal disclosures may be made without prior notice to you where required by law.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined, or as required by applicable laws. In particular, we are obligated to retain KYC and transaction records for a minimum of five (5) years after your relationship ends, in accordance with applicable regulations.

9. Data Security Measures

We implement comprehensive technical, administrative, and organisational security measures, including encryption of data in transit and at rest, secure login protocols, and regular security audits. Despite our best efforts, no system can be guaranteed to be 100% secure. Protect your credentials and contact hello@userank.com if you suspect a compromise.

10. Updates To This Policy

We reserve the right to update this Policy at any time. When material changes are made, we will notify you via email or in-app notice as appropriate. Updates take effect on the day they are published. We encourage you to review this Policy periodically.

11. Contact Us

For inquiries or assistance, please contact: