Guaranty Trust Bank (UK) Limited (“GT Bank UK”) is deeply committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Notice explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information.
Please read the following carefully to understand our views and practices regarding your personal information, and how we will treat it.
- Who we are
For the purposes of applicable data protection laws, the responsible party is GT Bank UK of 60-62 Margaret Street, London W1W 8TF, registered number 05969821. Please see below for our contact details.
- Information covered by this Privacy Notice
This Privacy Notice covers all personal information collected and used by GT Bank UK. “Personal data” or “personal information” means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. This includes the types of information set out below.
- What information do we collect from you?
We may collect information about you from the following sources:
3.1 Information we receive from you
We may collect personal information (such as your name, postal and email address, previous addresses, telephone and fax number, occupation, assets income, nationality, marital status, passport or other identification details, employment details, account details) that you provide to us when you:
- submit account-opening applications or applications for a mortgage;
- register to use our secure services, such as online banking; and
- subsequently correspond with us.
3.2 Information we collect about you
- Technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
- Information about your visit, including the websites you visit before and after our website and products you viewed or searched for; and
- Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.
4. How do we use your personal information?
|We may use your personal information to:||How do we use personal information for this purpose?||What is the legal basis for us processing your information in this way?|
|Verifying your identity when we receive applications for our products and services.||We will need to use your personal information (such as your name, postal and email address and passport or other identity documents) to comply with our requirements to verify your identity. We may share such information with third parties to authenticate identification documentation.||This processing is necessary for the purposes of complying with legal requirements to which we are subject.|
|Reviewing credit or loan eligibility.||We may use your personal information such as previous addresses, and information from the electoral roll, bankruptcy and insolvency data in order to gather information on your financial history and assess your suitability for credit or a loan/ mortgage.||It is necessary for our legitimate interests to process personal information for the purposes of assessing your eligibility for credit or loan. We need to manage our risks whilst granting you the mortgage or loan you have requested. We manage this credit check process internally.|
|Processing your application.||We will need to use your personal information to assess your application and make decisions as to whether we are able to provide you with the products/services you have requested. Where you are applying for a mortgage, we may need to use your personal information to organise a valuation of your property prior to making you an offer.||It is in necessary for legitimate interests to process personal information for the purposes of assessing your application form.|
|Pricing and designing our products and services.||We will need to use your personal information to ensure that new products and services we are developing best suit our customers’ needs and are priced competitively.||It is necessary for our legitimate interests to process personal information in order to more effectively price and design our products and improve our offerings as a business.|
|Administering our products and services.||We will need to use your personal information (account number, signature, your name and address or other form of identification) where this is necessary to administer our products and services, for example providing you with a mortgage, carrying out a withdrawal, cashing a cheque or facilitating payments to and from your accounts with us on your instructions.||We need to process your information in this way in order to perform our obligations under a contract with you, for example where you have opened an account with us and to comply with legal requirements to which we are subject.|
|Managing our risks and monitoring transactions to help identify illegal activity.||We may need to use your personal information in order to identify and investigate illegal or fraudulent activity such as fraudulent transactions, money laundering, terrorist financing or provision of services to persons who may be subject to sanctions. We may also contact you to request further information about yourself or any person/entity receiving the payment.||This processing is necessary for the purposes of complying with legal requirements to which we are subject.|
|Dealing with your enquiries and requests.||We will need to use your personal information (such as your contact details) to assist you with enquiries and requests.||It is necessary for our legitimate interests to process personal information in order to provide you with a tailored answer to your queries and requests.|
|Monitoring and/or recording your communications with us.||We may monitor and/or record your communications with us including telephone calls and conversations we have with you in our bank. These communications may include your personal information.||It is necessary for our legitimate interests to monitor/record communications in order to carry out your instructions accurately, help us to improve our service and in the interests of security.|
|Contacting you with important matters concerning your account(s) or mortgage(s) with us.||We may use your personal information (such as email and postal address and phone number) to contact you with important news or information, for example, to inform you about suspicious activity on your account, to verify that instructions we receive from you by email or telephone are genuine or to inform you of any changes to your account terms and conditions.||We need to process your information in this way in order to perform our obligations under a contract with you in relation to your account(s) or mortgage(s).|
|Complying with legal requirements and assist government and law enforcement agencies or regulators/supervisors.||We may sometimes need to process personal information to comply with legal requirements to which we are subject (for example money laundering, bribery and corruption and other financial crime).||This processing is necessary for the purposes of complying with legal requirements to which we are subject.|
|For the purpose of keeping internal records and managing our relationship with you.||We will keep records of your personal information, such as your name, address, account details and marketing preferences in order to administer our services and products, keep our records up to date and for internal audit purposes.||It is necessary for our legitimate interest to keep records of your personal details and update these when necessary. It is also in our legitimate interests to keep records of any correspondence with you. Our customers are important to us and so we need to keep track of your details and preferences.|
|Processing your personal information where this is necessary to keep our website safe and secure.||We may need to process your personal information in order to keep our website safe and secure and protect against illegal or fraudulent activity such as cyber attacks.||It is necessary for our legitimate interests to monitor how our website is used to detect and prevent fraud, other crimes and the misuse of our website. This helps us to ensure that you can safely use our website.|
|Keeping an up-to-date suppression list where you have asked not to be contacted, so we do not inadvertently re-contact you.||We understand that you may prefer for us not to contact you with details of our products, services, or promotions. We keep records of your preferences to ensure that we do not contact you if you have asked us not to. We may need to process certain of your personal information (such as your name and email address) in order to do this.||It is necessary for our legitimate interests to process personal information in order to maintain an up-to-date suppression list and ensure that we do not contact you where you have asked us not to.|
- Children’s privacy
We will never knowingly collect personal information from individuals under the age of thirteen (13) without first obtaining verifiable parental consent. If you are under the age of 13 you should not provide information to us. If we become aware that a person under 13 has provided personal information to us without verifiable parental consent, we will remove such personal information from our files.
- Sharing your data with third parties
Your personal information is intended for GT Bank UK, and may be shared with third parties in certain circumstances.
Our website may, from time to time, contain links to and from the websites of our partners or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal information. You should check the privacy policies of third party websites before you submit any personal information to them.
We may share your personal information with the following third party organisations:
- GT Bank UK’s group of companies
We may share your personal information among our group of companies, including our subsidiaries, head office and branches (including GT Bank UK’s Liaison Desks), in order to open your account with us, administer our services and products, provide you with customer support, process your payments, understand your preferences and conduct the other activities described in this Privacy Notice.
- Our service providers
We use other companies, agents or contractors (“Service Providers”) to perform services on our behalf or to assist us with the provision of the GT Bank UK services and products to you. We may share personal information with the following categories of Service Provider:
- infrastructure and IT services providers, including in relation to card issuing, email archiving and banking software
- Credit reference agencies
- Agents who help us collect what is owed to us
In the course of providing such services, these Service Providers may have access to your personal information. However, we will only provide our Service Providers with the information that is necessary for them to perform the services, and we ask them not to use your information for any other purpose. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.
- Third parties permitted by law
In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, fraud prevention agencies, government agencies or to judicial or administrative authorities).
We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our Terms and Conditions or protect your rights or those of the public.
Examples may include sharing your information with (i) third parties to obtain verification of the authenticity of ID documentation and (ii) the recipient’s bank when you make a payment out of your account.
- Third parties connected with business transfers
We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.
We will not sell your personal information to third parties.
- Where we store your personal information
The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) (for example, any of our group entities in Africa). It may also be processed by staff operating outside the EEA who works for us as part of our GT Bank UK Liaison Desks or for one of our Service Providers.
By providing us with your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information.
- Your rights (EEA residents only)
If you are a resident in the European Economic Area, you have the right to:
- Access. You have the right to request a copy of the personal information we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal data, we may charge a reasonable administration fee.
- Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
- Deletion. You have the right to request that we delete personal information that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you (such as to administer your account).
- Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
- Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.
You have access to your account information, which includes your contact information, account balances, transactions, SMS Banking and Internet Banking. If you discover inaccuracies in your personal information, please promptly notify us so that we can make the necessary updates or changes.
You can make any of these requests in relation to your personal data by sending the request by mail to Data Protection Officer GT Bank UK of 60-62 Margaret Street, London W1W 8TF or email to email@example.com.
You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.
If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:
Telephone: +44 0303 123 1113
Address: Water Lane, Wycliffe House, Wilmslow, Cheshire, SK9 5AF
If you are based or the issue you would like to complain about took place elsewhere in the European Economic Area (EEA), please click on the following link for a list of local data protection authorities in the other EEA countries: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
- How long do we keep your personal information?
We will only retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).
- How do we keep your personal information secure?
We have implemented technical and organisational security measures in an effort to safeguard the personal information in our custody and control. Such measures we have implemented include, for example, limiting access to personal information only to employees and authorised service providers who need to know such information for the purposes described in this Privacy Notice]
While we endeavour to always protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
To provide you with increased security, your internet banking account is only accessible via your username, password and by using a token generated code. You are responsible for maintaining the confidentiality of your online account credentials and other confidential account details, and we strongly recommend that you do not disclose your internet banking log in details, card details, PIN or codes from your token device to anyone. We will never ask you for your password, token generated codes, card details or PIN in any unsolicited communication. You should also ensure that you keep your ATM card safe and that you shield your PIN when conducting transactions at an ATM or when making transactions at retail stores. Please notify us immediately (see How to Contact us section below) of any unauthorised use of your online account credentials or any other suspected breach of security.
For more guidance on keeping your cards and security details secure, please see our Terms and Conditions
How to Contact Us
If there are any questions or concerns regarding this Privacy Notice or the data collection practices outlined herein, please contact us as follows:
- by email: firstname.lastname@example.org
- by post: 60 – 62 Margaret Street, London W1W 8TF
Alternatively, you can contact our Data Protection Officer:
- by email: [email@example.com]
- by post: [60-62 Margaret Street, London W1W 8TF ]
Changes to this Privacy Notice
This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.
We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice we will [notify you of these changes via email] and [post an alert on the home page of our global website].