For Bank Clients
Purposes for which we may process your Personal Data
To enable us to fulfil the contract between us for the products or services you have requested.
We need to process your personal data for purposes including the following:
- Processing applications for products and services, effecting payments, transactions and completing instructions or requests;
- Providing products and services (including electronic banking services);
- Assessing suitability for products and services;
- Credit assessment, including conducting credit checks and setting credit limits;
- Operational purposes;
- Statistical purposes;
- Establishment, continuation, and management of banking relationships and accounts;
- Surveillance of premises and ATMs.
These purposes include:
- The prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
- Identity verification, government sanctions screening and due diligence checks;
- To comply with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.
We may also process your Personal Data in line with any voluntary codes; to effect agreements between any member of the Kush Bank Plc and any authority, regulator, or enforcement agency; to comply with policies (including the Kush Bank Plc.’s policies) and good practice standards where it is in our legitimate interest to do so.
We may also process your Personal Data where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.
To whom we may disclose Personal Data
Any member of Kush Bank, including our officers, employees, agents and advisers, may disclose your Personal Data to any of the following parties for any of the purposes specified above:
- Any member of the Kush Bank Plc anywhere in the world, including any officer, employee, agent or director;
- Professional advisers (including auditors), third-party service providers, agents or independent contractors providing services to support Kush Bank’s business;
- Our business alliance partners who may provide their product or service to you;
- A merchant or a member of a card association where the disclosure is in connection with use of a card;
- Upon your death or mental incapacity, your legal representative and their legal advisers, and a member of your immediate family for the purpose of allowing him/her to make payment on your account;
- Any security provider or any person authorized to operate your account and to act on your behalf in giving instructions, to perform any other acts under our banking agreement or use any product;
- Any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
- Any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offense) or their agents;
- Any debt collection agency, credit bureau or credit reference agency, rating agency correspondents, insurer or insurance broker, direct or indirect provider of credit protection and fraud prevention agencies;
- Any financial institution to conduct credit checks, anti-money laundering related checks, for fraud prevention and detection of crime purposes;
- Anyone we consider necessary to facilitate requests for services or applications for products with any member of the Kush Bank Plc;
- Anyone we consider necessary in order to provide services in connection with a product;
- Any actual or potential participant or sub-participant in relation to any of our obligations in respect of any banking agreement, assignee, novatee or transferee (or any officer, employee, agent or adviser of any of them);
Security
Personal Data may be transferred to, or stored at, a location outside of your country of residence, which may not have data protection law. The security of your personal data is important to us. Kush Bank has technical and organizational security measures in place to safeguard your personal data. When using external service providers, we require that they adhere to security standards mandated by Kush Bank. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.
You should be aware that the Internet is not a secure form of communication and sending us any personal data over the Internet carries with it risks including the risk of access and interference by unauthorized third parties. Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence.
Other Terms and Conditions
There may be specific terms and conditions in our banking and product agreements that govern the collection, use, and disclosure of your personal data. Such other terms and conditions must be read in conjunction with this Privacy Statement.
Retention
Automated decisions and profiling
We may use profiling, including behavioral analysis, to assist us to provide you with better services, to make decisions and to prevent money laundering, terrorism, fraud and other financial crime, for example using profiling may help us to try and detect whether use of your credit card may be fraudulent. If any profiling will result in an automated decision relating to you, we will let you know and you will have the right to discuss the decision with us.
Marketing
We may use your Personal Data:
- To conduct market research and surveys with the aim of improving our products and services;
- For marketing purposes, promotional events, competitions and lucky draws.
We process your personal data for these purposes because it is in the interest of our business to do so with the intention of improving our products and services and generating business. We will not send you marketing material if you have specifically asked us not to do so. You have the right to opt-out of receiving marketing material at any time. To do so, please contact your branch or relationship manager.
If you change your mind and ask us not to send you marketing material or other promotional or research material you have subscribed to receive, we may need to retain a record that you have asked us not to do so to ensure that you do not receive anything further.
Monitoring
To the extent permitted by law, we may record and monitor your electronic communications with us to ensure compliance with our legal and regulatory obligations and internal policies for the purposes outlined above.
Your Rights
Subject to applicable law, regulations and/or banking industry guidelines, you may have the following rights:
Access
To request a copy of the personal data processed in relation to you. KUSH BANK may be allowed by law to charge a fee for this.
Correction
To request that we correct your personal data. You can do this at your branch or through your relationship manager.
Erasure
To ask us to delete your personal data, for example, if we no longer have a valid reason to process it.
Object
To object to how we process your personal data. This does not mean you can decide or choose how we process your personal data other than in relation to marketing. If you have any concerns about how we process your personal data, please discuss this at your branch or with your Relationship Manager. We may not be able to offer you services if you do not want us to process the personal data, we consider it necessary to process to provide the services.
Restriction
To restrict how your personal data is processed in certain cases, such as when the accuracy of your Personal Data is contested. If you have any concerns about how we process your Personal Data, please discuss this at your branch or with your Relationship Manager.
Portability
To request a copy of the personal data you have given to us in a machine-readable format.
For Non-bank clients
When visiting our website, you may choose to provide personal data to us for the following purposes:
- Subscribe to our publications and research
- Contact us for information, either through an online form or through email
