Legal

Union Bank of Nigeria Plc. (“Union Bank” or “the Bank”) is committed to conducting its business activities in a fair, honest and transparent manner. Union Bank has zero tolerance for bribery and corruption, and strives to apply the highest standards of corporate ethics and professionalism in the conduct of its business. This zero tolerance approach also means the Bank is committed to the mitigation, deterrence and detection of bribery, corruption and other unethical practices.

The Board of Directors is ultimately responsible for the Bank’s Anti-Bribery and Corruption Compliance Program which covers prohibition of receipt of gifts, entertainment and benefits, Vendor Management, Whistleblowing and other related activities.

Union Bank   requires compliance with applicable Anti-Bribery and Corruption laws in all markets and jurisdictions in which it operates. As a result, all employees, directors, vendors, related third parties, business partners and other stakeholders must comply with the provisions of the Bank’s Anti-Bribery and Corruption Policy

All stakeholders within the scope of Union Bank’s Anti-Bribery and Corruption Policy are required to comply with the following minimum standards:

• Giving, promise to give, or offering payment, benefits, entertainment or hospitality in return for business advantage is prohibited.
• Facilitation payments or kickbacks of any kind is strictly prohibited. (Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government or quasi-government official.)
• Prior to engaging a third party stakeholder, Union Bank will conduct relevant due diligence on the third party stakeholder in line with International best practice requirements. This process will be aimed at identifying relevant insider related interests and confirming that acceptable standards are applied by these third party stakeholders in their sphere of operation.
• No Union Bank director, employee, or third party stakeholder is allowed to give, accept a gift, or receive hospitality from a third party knowing or suspecting that it is offered or provided with an expectation that a business advantage will be provided to them by the Bank in return
• Stakeholders are to report any observed bribery and corruption related practices via the Bank’s Whistleblowing channels through the following channels; (i) Whistle blower hotline: 0800TIPOFFS (0800 847 6337) (ii)Email: tip-offs@deloitte.com.ng
• The bank’s website :  https://tip-offs.deloitte.com.ng

Reporters of unethical practices will be protected against retaliation of any kind. No director, employee, or third party stakeholder will be allowed to threaten or retaliate against anyone who has raised concerns about, or who has refused to engage in bribery, corruption or other unethical practices.

Welcome to the UnionMobile Privacy Policy
This Privacy Policy explains what personal data the UnionMobile application collects, and what we do with it. Please take the time to read through it carefully. If you have any questions, please send them to us at customerservice@unionbankng.com.

Summary
Using the following services, we collect your data for the following purposes:

• Access to Third party accounts: Facebook account access Permissions: Access Friend lists and Activities
• Analytics: Google Analytics with anonymised IP
  Data collected: Cookies and Usage Data
• Device permissions for Personal Data access
  Data collected: Approximate location permission (continuous), Camera permission and Contacts permission
• Location-based interactions: Geolocation
  Data collected: Geographic position

Privacy Policy

Data Controller and Owner
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Geographic Position, Cookies, Usage Data, Contacts Permission, Camera Permission and Approximate Location Permission (continuous).
Other Personal Data collected may be described in other sections of this Privacy Policy or by dedicated explanation text contextually with the Data collection.
The Personal Data may be freely provided by the User, or collected automatically when using this Application.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by our customers.
When we are unable to collect Personal Data, it makes it impossible for us to provide the services of this Application.
Ultimately, you are responsible for any Personal Data of third parties obtained, published or shared through this Application and must confirm that you have the third party’s consent to provide the Data.

Mode and place of processing Data
Methods of Processing
The Data Controller processes your data in a proper manner and will take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. We process data using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For more information, please contact the Data Controller.

Retention time
The Data is kept for the required time as prescribed by the Data Controller Policy to provide the services that you request, or as stated by the purposes outlined in this document. You can always request that the Data Controller suspend or remove the data.

The use of the collected Data
We collect your information to provide you with better services, as well as for the following purposes: Location-based interactions, Analytics, Access to third party accounts and Device permissions for Personal Data access.
The personal data used for each purpose is outlined in specific sections of this document.

Facebook permissions requested by this Application
This Application may ask for some Facebook permissions in order to allow it perform actions with your Facebook account and to retrieve information, including personal data. This service allows this Application to connect with the User’s account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, please refer to the Facebook permissions documentation and to the Facebook Privacy Policy.
The permissions asked are:

• Activities
  Provides access to your list of activities.
• Access Friend Lists
  Provides access to any friend lists you have created.
• Contacts permission
  Used for accessing contacts and profiles on your device, including the changing of entries.
• Camera permission
  Used for accessing the camera or capturing images and video from the device.
• Device permissions for Personal Data access
  Depending on your specific device, this Application may request certain permissions that allow it to access your device data as described below.
  By default, you must grant these permissions before the respective information can be accessed. Once the permission has been given, you can revoke it at any time. In order to revoke these permissions, please refer to your device settings or contact the Owner for support at the contact details provided in the present document.
  The exact procedure for controlling app permissions may be dependent on your device and software.
  Please note that the revoking of such permissions might impact the proper functioning of this Application.
  If you grant any of the permissions listed below, the respective personal data may be processed (i.e. accessed to, modified or removed) by this Application.
• Basic information
  By default, this includes certain data such as ID, name, picture, gender, and your locale. Certain connections of yours, such as friends, are also available. If you have made more of your data public, more information will be available.
• Approximate location permission (continuous)
  Used for accessing your approximate device location. This Application may collect, use, and share your location data in order to provide location-based services.

Additional information about Data Collection and Processing
Legal action
Your data may be used for legal purposes by the Data Controller, in court or in the stages leading to possible legal action arising from improper use of this Application or the related services.
By using this Application, you declare to be aware that the Data Controller may be required to reveal personal data when required to by public authorities.

Additional information about Your Personal Data
In addition to the information contained in this Privacy Policy, this Application may provide you with additional and contextual information concerning particular services or the collection and processing of personal data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as IP Address) for this purpose.

Information not contained in this Policy
More details concerning the collection or processing of personal data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
Your Rights
You have the right, at any time, to know whether your personal data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
This Application does not support “Do Not Track” requests.
To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this Privacy Policy
The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page. We strongly recommend that you check this page often, referring to the date of the last modification listed at the bottom. If you object to any of the changes to the Policy, you must cease using this Application and can request that the Data Controller remove the personal data. Unless stated otherwise, the then-current Privacy Policy applies to all personal data the Data Controller has about you.

Information about this Privacy Policy
The Data Controller is responsible for this Privacy Policy, prepared starting from the modules provided by Union Bank and hosted on Union Bank’s servers.

Definition and Legal References
Personal Data (or Data)
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data
Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User
The individual using this Application, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.

Data Subject
The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)
The natural person, legal person, public administration or any other body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of personal data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application
The hardware or software tool by which the Personal Data of the User is collected.

Cookies
Small piece of data stored in the User’s device.
________________________________________
Legal information
Notice to European Users: This Privacy Statement has been prepared in fulfilment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of cookies.
This Privacy Policy relates solely to this Application.

Welcome to the Union Token Privacy Policy

This Privacy Policy explains what personal data the UnionToken application collects, and what we do with it. Please take the time to read through it carefully. If you have any questions, please send them to us at customerservice@unionbankng.com.

Summary

Using the following services, we collect your data for the following purposes:

Data collected: Cookies and Usage Data

• Device permissions for Personal Data access

Data collected: Approximate location permission (continuous), Camera permission and Contacts permission


• Location-based interactions: Geolocation

Data collected: Geographic position

Privacy Policy

Data Controller and Owner

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Geographic Position, Cookies, , Contacts Permission, Permission and Approximate Location Permission (continuous).

Other Personal Data collected may be described in other sections of this Privacy Policy or by dedicated explanation text contextually with the Data collection.

The Personal Data may be freely provided by the User, or collected automatically when using this Application.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by our customers.

When we are unable to collect Personal Data, it makes it impossible for us to provide the services of this Application.

Ultimately, you are responsible for any Personal Data of third parties obtained, published or shared through this Application and must confirm that you have the third party’s consent to provide the Data.

Mode and place of processing Data

Methods of Processing

The Data Controller processes your data in a proper manner and will take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. We process data using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For more information, please contact the Data Controller.

Retention time

The Data is kept for the required time as prescribed by the Data Controller Policy to provide the services that you request, or as stated by the purposes outlined in this document. You can always request that the Data Controller suspend or remove the data.

The use of the collected Data

We collect your information to provide you with better services, as well as for the following purposes: Location-based interactions, Analytics, Access to third party accounts and Device permissions for Personal Data access.

The personal data used for each purpose is outlined in specific sections of this document.

• Activities

Provides access to your list of activities.


• Device permissions for Personal Data access

Depending on your specific device, this Application may request certain permissions that allow it to access your device data as described below.

By default, you must grant these permissions before the respective information can be accessed. Once the permission has been given, you can revoke it at any time. In order to revoke these permissions, please refer to your device settings or contact the Owner for support at the contact details provided in the present document.

The exact procedure for controlling app permissions may be dependent on your device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If you grant any of the permissions listed below, the respective personal data may be processed (i.e. accessed to, modified or removed) by this Application.

• Approximate location permission (continuous)

Used for accessing your approximate device location. This Application may collect, use, and share your location data in order to provide location-based services.


• Camera permission

Used for accessing the camera or capturing images and video from the device.


• Contacts permission

Used for accessing contacts and profiles on your device, including the changing of entries.

Additional information about Data Collection and Processing

Legal action

Your data may be used for legal purposes by the Data Controller, in court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

By using this Application, you declare to be aware that the Data Controller may be required to reveal personal data when required to by public authorities.

Additional information about Your Personal Data

In addition to the information contained in this Privacy Policy, this Application may provide you with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

Your Rights

You have the right, at any time, to know whether your personal data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests.

To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving prompt notice to its Users on this page within a period of 24 hours. We strongly recommend that you check this page often, referring to the date of the last modification listed at the bottom. If you object to any of the changes to the Policy, you must cease using this Application and can request that the Data Controller remove the personal data. Unless stated otherwise, the then-current Privacy Policy applies to all personal data the Data Controller has about you.

Information about this Privacy Policy

The Data Controller is responsible for this Privacy Policy, prepared starting from the modules provided by Union Bank and hosted on Union Bank’s servers.

Definition and Legal References

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of personal data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.

Cookies

Small piece of data stored in the User’s device.

________________________________________

Legal information

Notice to European Users: This Privacy Statement has been prepared in fulfilment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of cookies.

This Privacy Policy relates solely to this Application.