Privacy Policy for Vision Arvest Bank

This Privacy Policy explains how Vision Arvest Bank ("Vision Arvest Bank", "we", "us", or "our") collects, uses, discloses and protects your personal information when you use our banking products and services, visit our branches, websites or mobile applications, or otherwise interact with us in England.

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

1. Who We Are Vision Arvest Bank is a banking institution operating in England. We are the controller of your personal data for the purposes of applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Personal Data We Collect We may collect and process the following categories of personal data:

   • Identification data: name, date of birth, nationality, gender, national insurance number or other government-issued identifiers, customer ID, signatures.
   • Contact details: residential and mailing address, email address, telephone numbers.
   • Financial information: bank account numbers, sort codes, card details, account balances, transaction history, payment instructions, direct debits, standing orders, credit history, income and employment information.
   • Regulatory and compliance data: information required for anti-money laundering (AML), know-your-customer (KYC), fraud prevention and sanctions screening (e.g., proof of address, identity documents, source of funds, adverse media, politically exposed person (PEP) status).
   • Online and technical data: IP address, device identifiers, browser type, operating system, access logs, usage data for our websites and mobile apps, cookies and similar technologies.
   • Communication data: records and content of communications with us, including emails, letters, secure messages, phone calls, and chat interactions.
   • Marketing and preference data: your marketing preferences, responses to surveys, participation in promotions or events related to Vision Arvest Bank or arvest-branded services.

3. How We Collect Your Data We collect data in the following ways:

   • Directly from you: when you apply for an account or loan, use our services, complete forms, contact us, or participate in surveys and promotions.
   • Automatically: when you use our online services, through cookies, analytics tools, and similar technologies.
   • From third parties: credit reference agencies, fraud prevention agencies, public databases, social media (where you choose to connect with us), payment service providers, and business partners.

4. Legal Bases for Processing We process your personal data only where we have a lawful basis, including:

   • Contract: to enter into and perform a contract with you (e.g., opening and managing your bank accounts, processing transactions).
   • Legal obligation: to comply with our legal and regulatory duties (e.g., AML/KYC checks, tax reporting, record-keeping).
   • Legitimate interests: to pursue our legitimate business interests, provided your interests and fundamental rights do not override these (e.g., improving services, preventing fraud, ensuring network and information security).
   • Consent: where you have given us clear consent (e.g., certain marketing communications). You may withdraw your consent at any time, without affecting the lawfulness of processing before withdrawal.

5. How We Use Your Personal Data We use your personal data for the following purposes:

   • Providing banking services: opening and maintaining accounts, enabling deposits and withdrawals, processing payments and transfers, issuing cards, providing loans, credit, and other products.
   • Customer support: responding to your enquiries, managing complaints, and providing assistance in branch, by phone, or online.
   • Security and fraud prevention: verifying your identity, monitoring transactions for suspicious activity, preventing and detecting fraud, financial crime and abuse of our systems.
   • Compliance and risk management: fulfilling legal and regulatory duties, conducting audits, managing risk, and enforcing our terms and conditions.
   • Service improvement: analysing usage of our services, developing new products, testing systems, and enhancing the performance and security of our digital platforms, including arvest-branded tools and services.
   • Marketing and communications: sending you information about our products, services, and offers that may be relevant to you, in accordance with your marketing preferences and applicable laws.

6. Cookies and Online Tracking Our websites and mobile applications may use cookies and similar technologies to:

   • Enable core functionality and security.
   • Remember your preferences and settings.
   • Analyse traffic, usage, and performance of our online services.

Where required by law, we will request your consent before setting non-essential cookies. You can manage your cookie preferences through your browser or device settings; however, disabling certain cookies may affect the functioning of our services.

7. How We Share Your Personal Data We may share your personal data with:
   • Group entities and service providers: companies that provide IT, payment processing, cloud hosting, identity verification, customer support, analytics, and other services on our behalf.
   • Credit reference and fraud prevention agencies: to assess creditworthiness, verify identity, prevent fraud and financial crime, and manage risk.
   • Professional advisors: auditors, lawyers, consultants, and other professionals who assist us in managing our business.
   • Business partners: payment networks, correspondent banks, and other financial institutions involved in processing your transactions.
   • Authorities and regulators: law enforcement agencies, regulatory bodies, courts, and other public authorities, where required or permitted by law.

We require all third parties that process personal data on our behalf to implement appropriate security measures and to process your data only in accordance with our instructions and applicable data protection law.

8. International Transfers Your personal data may be transferred to and processed in countries outside the United Kingdom and the European Economic Area that may not provide the same level of data protection as in the UK. When we do so, we will ensure appropriate safeguards are in place, such as:
   • Using standard contractual clauses approved by the UK authorities.
   • Transferring data to countries recognised as providing an adequate level of protection.
   • Implementing additional technical and organisational safeguards where appropriate.

You may contact us to obtain more information about the safeguards we use for international transfers.

9. Data Retention We retain your personal data only for as long as necessary for the purposes for which it was collected, including:
   • The duration of your relationship with Vision Arvest Bank.
   • The time required to comply with legal, regulatory, tax, and accounting obligations.
   • The time required to resolve disputes or enforce our agreements.

In many cases, this means we will retain your data for a number of years after your relationship with us ends, in accordance with applicable laws and regulations for banks in England.

10. Data Security We take 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 and pseudonymisation where appropriate.
    • Access controls and authentication mechanisms.
    • Network and infrastructure security.
    • Regular testing, assessments, and staff training.

While we strive to protect your data, no system is completely secure. You are responsible for keeping your login credentials and personal security information confidential.

11. Your Data Protection Rights Under UK data protection law, you have the following rights (subject to conditions and legal limitations):
    • Right of access: to obtain confirmation as to whether we process your data and to receive a copy of your personal data.
    • Right to rectification: to have inaccurate or incomplete data corrected.
    • Right to erasure: to request deletion of your data where there is no compelling reason for us to continue processing it.
    • Right to restriction: to request that we limit the processing of your data in certain circumstances.
    • Right to data portability: to receive certain data you have provided to us in a structured, commonly used and machine-readable format and to 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.
    • Rights relating to consent: where we rely on your consent, you may withdraw it at any time.

To exercise your rights, please contact us using the contact details provided in the "Contact Us" section below. We may need to verify your identity before responding to your request.

12. Children’s Privacy Our services are generally not directed to children under the age of 18. We do not knowingly collect personal data from children under 18 without appropriate consent or legal basis. If you believe a child has provided us with personal data, please contact us so we can take appropriate steps.

13. Marketing Preferences We may use your personal data to send you marketing communications about Vision Arvest Bank products and services, including arvest-related offers, where permitted by law. You can manage your marketing preferences or opt out at any time by following the instructions in our communications or by contacting us.

14. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will indicate the date of the latest revision at the top or bottom of the policy, and, where appropriate, notify you of significant changes.

15. Contact Us If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact us through the customer service channels available on our official Vision Arvest Bank website or at our branches in England.

If you are not satisfied with our response, you have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).