DATA PROTECTION POLICY – INTERNAL USE

1. The purpose of the policy

This Data Protection Policy states the basic principles on data protection for ClearPay
Microfinance Bank Limited. Ensuring data protection is the foundation of trustworthy
business relationships and the reputation of ClearPay Microfinance Bank Limited as an
attractive employer.

It ensures the adequate level of data protection prescribed by the European Union Data Protection Directive and the Nigeria Data Protection Act, 2023, for cross-border data transmission, including in countries that do not yet have adequate data protection laws.

2. Data protection principles

ClearPay Microfinance Bank Limited is committed to processing data in accordance
with its responsibilities under the Nigeria Data Protection Laws.
Article 5 of the General Data Protection Regulation requires that personal data shall be:
1. processed lawfully, fairly and in a transparent manner in relation to individuals.
2. 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.
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
5. 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 organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

3. General provisions

1. This policy applies to all personal data processed by ClearPay Microfinance Bank
Limited.
2. The Person Responsible shall take responsibility for ClearPay Microfinance Bank
Limited ongoing compliance with this policy.
3. This policy shall be reviewed at least annually.
4. Individuals have the right to access their personal data and any such requests
made to ClearPay Microfinance Bank Limited shall be dealt within two (2) weeks.
5. We take your privacy seriously and want to be transparent about the
information we collect. By using our online banking app, you agree that we
may collect, use and upload your contact list and image information for the
purpose of enhancing your user experience and providing personalized
services. Rest assured that we will handle this information with the utmost
care and in accordance with our privacy policy.
6. ClearPay is committed to protecting your privacy and ensuring that the data
we collect is used only for the purposes disclosed in this privacy policy. Any
information gathered from users will be used solely for the intended purpose
of providing and improving our services. We will not share, sell, or disclose
your data to any third parties without your consent, unless required by law.
7. If you have any questions or concerns about how your data is being used, you
may do so at any time by contacting our Data Protection Officer on:
a. Telephone: +2349049618880
b. Email: damilola.ogunleye@clearpaymfb.com
c. We will respond within 2 weeks of receiving your notice.

4. Lawful purposes
1. All data processed by ClearPay Microfinance Bank Limited must be done on one
of the following lawful bases: consent, contract, legal obligation, vital interests,
public task or legitimate interests.
2. Where consent is relied upon as a lawful basis for processing data, evidence of
opt-in consent shall be kept with the personal data.
3. 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
ClearPay Microfinance Bank Limited

5. Data minimization
1. ClearPay Microfinance Bank Limited shall ensure that personal data are
adequate, relevant and limited to what is necessary in relation to the purposes
for which they are processed.

6. Accuracy
1. ClearPay Microfinance Bank Limited shall take reasonable steps to ensure
personal data is accurate.
2. Where necessary for the lawful basis on which data is processed, steps shall be
put in place to ensure that personal data is kept up to date.

7. Archiving/removal
1. To ensure that personal data is kept for no longer than necessary, ClearPay
Microfinance Bank Limited shall put in place an archiving policy for each area in
which personal data is processed and review this process annually.2. The archiving policy shall consider what data should/must be retained, for how
long, and why.

8. Security
1. ClearPay Microfinance Bank Limited shall ensure that personal data is stored
securely using modern software that is kept-up to date.
2. Access to personal data shall be limited to personnel who need access and
appropriate security should be in place to avoid unauthorized sharing of
information.
3. When personal data is deleted, this should be done safely such that the data
is irrecoverable.
4. Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach
In the event of a breach of security leading to the accidental or unlawful destruction,
loss, alteration, unauthorized disclosure of, or access to, personal data, ClearPay
Microfinance Bank Limited shall promptly assess the risk to people’s rights and
freedoms and if appropriate report this breach to the Nigeria Data Protection Bureau
via dpo@ndpb.gov.ng
For more details, please address any questions, comments and requests regarding our
data processing practices to our Data Protection Officer via dpo@ClearPaymfb.com