Privacy Policy of Anchor Centrier Bank

1. Introduction Anchor Centrier Bank ("Anchor Centrier Bank", "we", "us", "our") is committed to protecting your privacy and handling your personal data in a fair, transparent, and lawful manner. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use our banking services, visit our websites, mobile applications, or interact with us in any other way in England.

By using our products and services, you acknowledge that you have read and understood this Privacy Policy.

2. Who we are Anchor Centrier Bank is a banking institution operating in England. We act as a data controller in relation to the personal data we collect and process about you. This means that we determine the purposes and means of processing your personal data.

3. Personal data we collect We may collect and process the following categories of personal data about you: 3.1 Identification and contact details

   • Full name
   • Date and place of birth
   • Nationality
   • Residential and correspondence address
   • Email address
   • Telephone and mobile numbers
   • Identification documents (e.g., passport, driving licence, national ID), identification numbers, and copies where required by law

3.2 Financial and account information

• Bank account numbers and sort codes
• Payment card details (where applicable)
• Transaction history, including incoming and outgoing payments
• Account balances and statements
• Credit and debit records
• Information relating to loans, mortgages, overdrafts, and other banking products

3.3 Regulatory and due diligence information

• Information required for Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
• Sanctions and politically exposed person (PEP) screening results
• Information obtained from identity verification providers, credit reference agencies, and fraud prevention agencies

3.4 Technical and usage data

• IP address and approximate location derived from it
• Device identifiers, browser type, and operating system
• Login data, security logs, and authentication data
• Usage data related to our websites, online banking, and mobile applications (e.g., pages visited, features used, session time)

3.5 Communication data

• Records of communications with us, including emails, messages, letters, and chat logs
• Call recordings and notes from telephone conversations (where permitted or required by law)
• Feedback, complaints, and survey responses

3.6 Special categories of data (limited circumstances) We generally do not seek to collect special category data (e.g., health, biometric, or data revealing racial or ethnic origin) unless it is strictly necessary and you have provided your explicit consent or we are otherwise legally permitted or required to do so (for example, where we use biometric data for secure customer authentication).

4. How we collect your personal data We collect personal data from various sources, including:

   • Directly from you when you apply for or use our products and services, contact us, or update your information
   • Through your use of our online banking, mobile applications, and websites
   • From third parties such as credit reference agencies, fraud prevention agencies, identity verification providers, and public records
   • From other banks and financial institutions involved in payment transactions
   • From business partners and service providers acting on our behalf

5. Legal bases for processing We process your personal data only where we have a lawful basis to do so under applicable data protection laws in England, which may include:

   • Performance of a contract: to provide you with banking products and services you have requested or to take steps at your request before entering into a contract
   • Legal obligation: to comply with applicable laws and regulations, including banking, financial, AML, and sanctions requirements
   • Legitimate interests: to pursue our legitimate business interests in a way that does not override your rights and freedoms, for example to improve our services, prevent fraud, or manage our business
   • Consent: where you have explicitly given us permission to process specific personal data for particular purposes, such as certain marketing activities or specific optional features
   • Vital interests or public interest: in limited circumstances, to protect your vital interests or those of another person, or where processing is necessary for reasons of substantial public interest as permitted by law

6. How we use your personal data We may use your personal data for the following purposes: 6.1 Providing and managing accounts and services

   • Opening, maintaining, and closing bank accounts
   • Processing payments, transfers, and other transactions
   • Providing cards, cheques, and related services
   • Operating online and mobile banking channels

6.2 Compliance and risk management

• Conducting identity verification and KYC checks
• Carrying out AML, counter-terrorist financing, and sanctions screening
• Performing credit and affordability assessments
• Preventing, detecting, and investigating fraud, financial crime, and security incidents

6.3 Customer support and communication

• Responding to your inquiries, requests, and complaints
• Notifying you about changes to our terms, services, or this Privacy Policy
• Sending operational and service-related communications (e.g., transaction alerts, security notifications)

6.4 Improving our services and security

• Monitoring and analysing the use of our digital channels and services to improve functionality, user experience, and security
• Developing new products, features, and services
• Conducting testing, research, and statistical analysis (where possible, using aggregated or pseudonymised data)

6.5 Marketing and information about our products

• Providing you with information about products and services of Anchor Centrier Bank that may be of interest to you
• Customising marketing messages based on your profile and preferences, where permitted by law
• Managing your marketing preferences and opt-out requests We will only send you direct marketing communications by electronic means (such as email or SMS) where you have consented or where otherwise permitted by applicable law. You may opt out at any time.

7. Sharing your personal data We may share your personal data with the following categories of recipients, always subject to appropriate safeguards:
   • Other entities within our corporate group, where relevant, for internal administration, risk management, and regulatory compliance
   • Service providers and professional advisers who process data on our behalf (e.g., IT, cloud hosting, payment processing, identity verification, analytics, and customer support)
   • Credit reference agencies, fraud prevention agencies, and similar organisations
   • Other banks and financial institutions involved in transactions and payment schemes
   • Regulators, supervisory authorities, tax authorities, law enforcement, and other public bodies where required by law or regulation
   • Courts, legal advisers, and other parties in connection with legal proceedings or dispute resolution

We do not sell your personal data.

8. International transfers Where your personal data is transferred outside England or the United Kingdom, we will ensure that appropriate safeguards are in place to protect your data, in accordance with applicable data protection laws. These safeguards may include:
   • Transfers to countries deemed to provide an adequate level of protection by relevant authorities
   • Use of standard contractual clauses or equivalent contractual safeguards
   • Other legally recognised mechanisms ensuring an adequate level of data protection

You may contact us using the details in the "Contact us" section for more information about the safeguards we use for international transfers.

9. Data retention We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, accounting, or reporting requirements.

In general:

• Data related to your accounts and transactions is retained for the duration of your relationship with us and for a period thereafter as required by law or regulation
• Records required for AML, KYC, and other regulatory purposes may be stored for a specific minimum period mandated by applicable legislation When personal data is no longer required, we will securely delete or anonymise it.

10. Security of your personal data We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

These measures may include:

• Encryption of data in transit and at rest where appropriate
• Access controls based on role and need-to-know principles
• Secure authentication procedures and multi-factor authentication for online banking
• Regular security assessments, testing, and monitoring
• Staff training and internal policies on data protection and information security

While we take reasonable steps to protect your data, no system is completely secure and we cannot guarantee absolute security.

11. Your rights Subject to applicable law, you may have the following rights regarding your personal data:
    • Right of access: to obtain confirmation whether we process your personal data and to receive a copy of that data
    • Right to rectification: to request that inaccurate or incomplete personal data be corrected
    • Right to erasure: to request deletion of your personal data where there is no lawful reason for us to continue processing it
    • Right to restriction: to request that we restrict the processing of your personal data in certain circumstances
    • Right to data portability: to receive personal data you have provided to us in a structured, commonly used, machine-readable format and to request that we transmit it to another controller where technically feasible
    • Right to object: to object to processing based on our legitimate interests or for direct marketing purposes
    • Right to withdraw consent: where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal

To exercise these rights, please contact us using the details in the "Contact us" section below. We may need to verify your identity before fulfilling your request, and we may refuse or limit requests where permitted by law.

12. Cookies and similar technologies When you visit our websites or use our online or mobile banking, we may use cookies and similar technologies to:
    • Enable core functionality and security
    • Remember your preferences and improve your user experience
    • Analyse how our services are used so we can enhance their performance

Where required by law, we will ask for your consent before placing non-essential cookies. You can manage your cookie preferences via your browser settings or through our cookie management tools, but disabling certain cookies may affect the operation of our services.

13. Children’s data Our services are generally not directed to children under the age at which they can independently enter into a banking contract under applicable law. Where we do process personal data relating to minors (for example, for youth accounts authorised by a parent or guardian), we will do so only in accordance with applicable laws and with appropriate safeguards.

14. Links to third-party sites and services Our websites or applications may contain links to third-party websites or services that are not operated by Anchor Centrier Bank. We are not responsible for the privacy practices of such third parties. We recommend that you review the privacy policies of those third parties before providing any personal data.

15. Changes to this Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or other factors. When we make changes, we will revise the "last updated" date and, where appropriate, notify you through our services or by other means.

Your continued use of our products and services after any changes have been made will constitute your acknowledgement of the updated Privacy Policy.

16. Contact us If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact our customer support center using the contact details provided on our official website or in your account documentation.

If you are not satisfied with our response or believe that we are processing your personal data in violation of applicable law, you may have the right to lodge a complaint with the relevant data protection authority in England.