Introduction

This Privacy Policy explains how Digital Bank Limited (“DBL“, “we”, “our” or “us”) collect, use, disclose and transfer personal information that has been provided to us. Personal data about you when you are a Client or employee of a Client or a beneficial owner of a Client or any User of DBL (collectively, “users” “your “or “you”) means any data relating to an identified or identifiable natural person. Our Privacy Policy must be read together with any legal notices or terms and conditions which may be available on pages of our website. Unless otherwise superseded by alternative terms and conditions (such as in users or employee contracts), the method by which the user’s personal data is collected, used, distributed, and maintained will be following this policy 

Data we collect and hold about you

• Use of our Products or Services: your personal data will be used by DBL to provide you with DBL products and services. 
• By participating in one of our Events if you have attended any of our events, we may collect your name, organisation, job title, telephone numbers and email address. 
• When you visit or register to use our website we may collect some data through cookies. This may include data regarding your use of our website, including the pages you viewed, any document downloads, any subscription for alerts or newsletters and any search terms entered. Your IP address may be used by DBL to provide you with further data regarding DBL. 
• Use of Membership Data if you seek or have obtained membership in any type of DBL affiliates, then we will collect and use relevant data to carry out our regulatory due diligence processes, including amongst others, your name, phone number, title, email address and passport. This data may be shared with approved third-party service providers of DBL and with relevant regulatory authorities. 
• Use of DBL Technology Systems while using any software application made available by DBL, personal data may be collected regarding your device, operating system, browser, application name, vendor, IP address, and country of origin. 
• Use of DBL Market Data we may collect personal data such as names, titles, phone numbers and emails for our own business and administrative purposes. 
• Recruitment and Employment we may collect personal data from applicants and employees as a part of our recruitment process, to conduct interviews and employee onboarding. We may collect personal data such as name, contact details, professional background, reference, background checks and bank account information for payroll, and for employee insurance. 
• Use of Social Networks you may be able to connect your personal or business social media accounts to social media accounts maintained by DBL (LinkedIn, Facebook, Twitter, etc). Your use of this functionality shall be treated as your consent for DBL to obtain the personal data available on the social media account you link to DBL, in accordance with the privacy policies of those social media sites. 
• Records of Correspondence we keep records of communications, which take place between you and us, including emails, letters, meetings and telephone calls. 
• Other Information additional information you provide to us or created by us when providing services to you.

Purposes for which we use your Personal Data are as follows:

1. Carrying out due diligence, enhanced due diligence, politically exposed person checks and performing risk assessment on a Client or employee of a Client or a beneficial owner of a Client or any User of DBL
2. Carrying out our obligations to a Client or employee of a Client or a beneficial owner of a Client or any User of DBL under any applicable contract; 
3. Legal and regulatory compliance, which include; 
   1. Performing checks and monitoring transactions. 
   2. Sharing information on suspected financial crimes, fraud and threats with law enforcement agencies and regulatory authority. 
4. Managing users’ grievances and resolutions; 
   1. Investigating any complaints; 
   2. Providing evidence in any dispute or anticipated disputes. 
5. Sending you marketing and promotional materials about our services, news and events; 
   1. Sending our email newsletters, information about services and related information which may be on interest of you; 
   2. Notifying you about changes to our services; 
   3. Sending you invites to our events. 
6. Internal management, administrative and organisational purposes; 
   1. Records keeping, document retention/storage; 
   2. Database management;
   3. Carrying out statistical analysis, creating forecasts and research purposes. 
7. Business continuity and risk management; 
   1. For detecting and preventing fraud and for risk management purposes; 
   2. For database management; 
   3. For business and disaster recovery (creating backups); 
   4. Ensuring network and information security. 
8. Sharing data with other third parties; 
   1. Including third parties who process personal data on our behalf.