SMARTBRANCH Privacy Policy

In this privacy policy, ‘We’ Us’ ‘Our’ ‘Ourselves’ ‘Company’ and ‘The Bank’ means:

CRDB Bank PLC, a fully-fledged commercial Bank established in 1996. The Bank was listed on the Dar es Salaam Stock Exchange (DSE) in June 2009. Currently operating four subsidiaries, CRDB Bank Burundi (S.A), CRDB Bank Congo S.A, CRDB Insurance Brokers Limited and CRDB Foundation.

The Bank is committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and informs You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

1. Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1. Account: A unique account created for You to access our Service or parts of our Service.
2. Affiliate: An entity that is controlled by or is under common control with a a Bank, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
3. Application: Refers to Smartbranch App, the software program provided by the Bank.
4. Country: refers to Tanzania.
5. Data: means character, symbols and binary on which operations are performed by a computer, which may be stored or transmitted in the form of electronic signals or stored in any format or any devices.
6. Data Protection Officer or DPO: means the person appointed as such the Data Protection Laws and in accordance with its requirements responsible for advising the Bank (including its employee) on their responsibility under the Data Protection Laws, for monitoring compliance with Data Protection Law.
7. Data Subject: means any person who can be identified directly or indirectly, by reference to an identification number or to one or more factors specific to his physical, physiological, economic, cultural or social identity. 
8. Device: Any device that can access the Service such as a computer, cellphone, or digital tablet.
9. Personal Data: Any information that relates to an identified or identifiable individual means any information relating to an identified or identifiable natural person (Data Subject); an identifiable natural person is one who can be identified, directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical physiological, genetic, economic cultural or social identity of that natural person, it can be anything from name, address, a photo, an email address, or bank details
10. Service: Refers to the Application developed for banking services provided by the Bank to the customer which include but not limited to account opening
11. Service Provider: Any natural or legal person who processes the data on behalf of the Bank. It refers to a third-party companies or individuals employed by the Bank to facilitate the Service, provides the Service on behalf of the Bank, perform services related to the Service, or assist the Bank in analysing how the Service is used.
12. Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).
13. You: The individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2. Collecting and Using Your Personal Data

We collect several different types of information for various purposes to provide an improve our services to you. 

Our collection points include but not limited to our branches, Head Office location Automated Teller Machines (ATM), Mobile Application, Website or Bank’s Agents.

1. Types of Personal Data Collected

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include but is not limited to:

1. Full name (First Name, Middle Name, Last Name)
2. Date of Birth
3. Place of Birth
4. Nationality
5. Gender
6. Marital Status
7. Customer ID

2. Usage Data

We may also collect information that your browser sends whenever you access our services and or when you access the services by or through a mobile device. Usage Data is collected automatically when using the Service. This may include information such as:

1. Your Device's Internet Protocol address (e.g., IP address)
2. Browser type and version
3. Pages of our Service that You visit
4. Time and date of Your visit
5. Time spent on those pages
6. Unique device identifiers
7. Diagnostic data

When You access the Service by or through a mobile device, We may collect additional information automatically, including but not limited to:

1. The type of mobile device You use

2. Your mobile device unique ID

3. The IP address of Your mobile device

4. Your mobile operating system

5. The type of mobile Internet browser You use

6. Unique device identifiers

7. Other diagnostic data

3. Information Collected While Using the Application

With Your prior permission, We may collect:

1. Location information

2. Contacts information

3. Photos and camera information

We use this information to provide features of Our Service, improve and customize Our Service, and store it securely on servers or locally on Your device.

4. Use of Your Personal Data

The purpose of collecting personally identifiable information is to enable us to provide you with banking services you have subscribed to and ensure that you are able to carry out transactions. The use of data may be extended beyond the above whenever necessary for purpose of meeting legal, regulatory, contractual obligation, and other legitimate business interest. The Bank may use Personal Data for the following purposes:

1. To provide and maintain our Service, including to monitor the usage of our Service.

2. To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

3. For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

4. To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

5. To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

6. To manage Your requests: To attend and manage Your requests to Us.

7. For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

8. For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

1. With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to contact You.

2. For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

3. With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

4. With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

5. With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

6. To comply with laws and regulations

7. To detect, prevent and address technical issues

8. To monitor our conversation with you when we speak on the telephone (for example, to check your instruction to us, to analyse, to assess and improve customer services, for training and quality assurance purpose, for verification, fraud analysis and prevention purpose

9. To comply with our internal policies. 

10. With Your consent: We may disclose Your personal information for any other purpose with Your consent.

3. Basis for Lawful Processing

The Bank processes data in accordance with the Country’s Data Protection Laws and Regulation. The Bank relies on the basis for lawful processing stated below.

1. The data subject has given and not withdrawn his consent for the specific purpose or purposes for which it will be processed.
2. The processing is necessary:
   1. For performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract. 
   2. For compliance with a legal obligation to which the data controller or data processor is subject,
   3. In order to protect the vital interest of the data subject or another individual
   4. For purpose of legitimate interest pursued by the data controller or data processor or by third party to whom the data is disclosed so no such legitimate interest is within the scope of the Country’s Data Protection Act and Regulation.   

4. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods as required or permitted by the law

Notwithstanding the foregoing the Bank shall be entitled to retain and process Personal Data for archiving, scientific research, historical research, or statistical purposes for public interest. 

The Bank would forthwith delete Personal Data in the Bank’s possession where such Personal Data is no longer required by the Bank or in line with the Bank’s Retention Policy, provided no law or regulation being in force requires the Bank to retain such Personal Data. 

Provided that, the Bank may delete the data at the request of Data Subject where there is an express request for deletion of Personal Data by the Data Subject, and provided that such request is treated in a way that there is no legal or regulatory requirements to keep such data or the Data Subject is not under any investigation which may require the Bank to retain such Personal Data or there is no subsisting contractual arrangement with the Data Subject that would require the processing or the Personal Data. 

5. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Save as related to the provision of banking services and meeting legal regulatory, contractual, and other uses incidental to these, the Bank will not share your personal data with a third party. Where it become necessary to do so, adequate security measures will be taken to protect the data from access by recipient other than those for which it is intended. 

Where Personal Data is to be transferred to a country outside Tanzania, the Bank shall put adequate measures in place to ensure the security of such Personal Data such as conducting detailed assessment of whether the said country is on the whitelist of countries with adequate data protection laws. Transfer of Personal Data out of Country would be in accordance with the provisions of the Country’s Data Protection and Regulations. The Bank will therefore only transfer Personal Data out of the Country or process data on one of the following conditions: -

1. The consent of the Data Subject has been obtained.

2. It is necessary for performance of a contract between the Bank and the Data Subject or implementation of pre contractual measures taken at the Data Subject’s request

3. It is necessary for reason of public interest 

4. It is necessary in order to establish, exercise or defence of legal claims,

5. It is necessary in order to protect the vital interests of the Data Subject or other persons, where the Data Subject is physically or legally incapable of giving consent

6. It is necessary for purpose of the legitimate interests pursued by the Bank or by a third party to whom the data is disclosed. 

Provided, in all circumstances listed above, that the Data Subject has been manifestly made to understand through clear warning of the specific principles of data protection that are likely to be violated in the event of transfer to a third Country. 

6. Deleting Your Personal Data

You have the right to update your personal details within our service, but you are not allowed to delete data as per regulatory requirements. Our Service may allow you to update certain information about you, but deleting information is not permitted. You may update or amend your information at any time by signing into your account, if you have one, and visiting KYC update option that allows you to manage your personal information. You may also contact us to request access to or correct any personal information that you have provided. However, please note that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

7. Disclosure of Your Personal Data

1. Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

2. Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

3. Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

1. Comply with a legal obligation

2. Protect and defend the rights or property of the Company

3. Prevent or investigate possible wrongdoing in connection with the Service

4. Protect the personal safety of Users of the Service or the public

5. Protect against legal liability

8. Disclosure of Location Data Usage:

We collect your location data with your consent to provide personalized services, such as identifying nearby branches and enabling geo-specific features. This data is collected via GPS, IP address, or device settings, used solely for these purposes, and retained is Realtime. It will not be shared with any third party for any reason

9. Security of Your Personal Data

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

10. Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

11. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

12.  Accountability 

The Bank demonstrate accountability in line with the Data Protections Laws and Regulation by monitoring and continuously improving data privacy practices with the Bank.

Any individual or employee who breaches this Privacy Policy may be subject to internal disciplinary action (up to and including termination of their employment) and may also face civil or criminal liability if the actions violate the law. 

When a potential breach has occurred, the Bank will investigate to determine if an actual breach has occurred and take the necessary actions required to manage and investigate the breach. Such actions include, validating the Personal Data breach, ensuring proper and impartial investigation (including digital forensics if necessary) is initiated, conducted, documented, and concluded, identifying remediation requirements and track resolution, reporting all findings to the top management. coordinating with appropriate authorities as needed, coordinating internal and external communications, ensuring that impacted Data Subjects are properly notified, if necessary.

13. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

14. Contact Us

If you have any questions, contact us:

By email: [email protected] or  [email protected]

By visiting this page on our website: https://crdbbank.co.tz/en

By phone number: +255(0)755197700