Privacy Notice

Your privacy is important to us. This notice (Privacy Notice) applies to personal information we collect from you when you use this website and other digital platforms we offer. If you are a customer or otherwise have a relationship with us, we may also have provided you with a separate privacy notice setting out how we use your personal information. You can also find that privacy notice by visiting the website for the product or services we provide you (e.g Centenary Bank FlexOnline) or by contacting customer services at info@centenarybank.co.mw.

Some of the links on this website may lead to Centenary Bank or non-Centenary Bank websites with their privacy notices, which may be different from this notice, and you should read those notices carefully.

For the purposes of this Privacy Notice, the data controller is Centenary Bank with its address at: Head Office, Ekistics House, Convention Drive, City Centre, P.O Box 31567, Lilongwe 3, Malawi.

We’ve also set out contact details towards the end of this notice.

Information We May Collect from You

We may collect and process the following information about you:

• Information that you provide to us, for example, information you provided when opening an account and accessing various services the bank offers.
• Information that we obtain or learn, such as, among other things, information about the device you use to access our mobile apps (Android & iOS), how you use the apps and the services you utilize on those apps.
• We may also ask you for information if you experience problems when using our apps and or services. We may also ask you to complete surveys for research purposes, although you don’t have to respond to these.
• When we can identify you from information obtained or provided by your use of our apps and services, we may associate those sets of information, for example, to enable us to respond to a query you have submitted.

How We Use Your Information

We will only use your information where we have your consent or we have another lawful reason for using it. Unless we say otherwise below, we will use your personal information on the basis that it is within our legitimate interests to operate and maintain our services and provide you with the functionality of the related services.

We use the information provided or obtained to:

• Respond to your queries (for example, if you have asked a question or submitted a complaint via the website).
• Provide you with information, products or services you have requested or which we feel may interest you, unless you tell us otherwise.
• Carry out our obligations from any contracts entered into between you and us.
• Allow you to participate in any interactive features of the app, website or other digital services.
• Notify you about changes to the app and other digital services.
• Ensure website and digital services content is presented most effectively for the device you are accessing it from.
• Undertake data analytics to learn more about how you and others interact with this website and digital services with our advertising.
• Detect and prevent misuse or abuse of this website or our digital services.

We also use information to meet our compliance obligations, to comply with other laws and regulations, and to share with regulators and other authorities that we are subject to. This may include using it to help detect or prevent crime (including terrorism financing, money laundering, and other financial crimes). We will only do this on the basis that we are obligated to comply with a legal obligation, it is in our legitimate interests and that of others, or to prevent or detect unlawful acts.

Who We Will Share Your Information With

We may share your information to provide you with products or services you have requested (for example, if they’re not provided by the Centenary Bank entity operating this website, service, or app) if we have a legitimate interest in doing so (e.g., to manage risk, verify your identity, to combat fraud, abuse of our website or digital services), or where you have agreed to us doing so.

We may share your information with others including, among other things, other Centenary group companies and any of our service providers, anyone else whose products and services you have requested, anyone whom we are under an obligation to disclose information or where it is in the public interest, for example, to prevent or detect fraud, abuse of our site or services.

IP Addresses

We may collect information about your computer (or mobile device), including where available your IP address, operating system, and browser type, for system administration or our commercial purposes. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

Cookies

We use cookies and similar technologies to distinguish you from other users of this site, to improve your experience when accessing this site, and to improve the site. Detailed information on the cookies we use and the purposes for which we use them are set out in our cookie policy (if available).

How Long We Will Keep Your Information

We will keep your information in line with our data retention policy. For example, we will normally keep correspondence for six months. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as dealing with any enquiries.

We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes, e.g., to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc. If we don’t need to retain information for this period, we may destroy, delete or anonymize it.

Transferring Your Information Overseas

Your information may be transferred to and stored in locations outside Malawi including countries that may not have the same level of protection for personal information. When we do this, we will ensure it has an appropriate level of protection and that the transfer is lawful.

You can obtain more details of the protection given to your information when it’s transferred outside Malawi by contacting us using the details in the ‘More details about your information’ section below.

Your Rights

You have several rights in relation to the information that we hold about you. Subject to the laws and regulations on data protection in Malawi, these rights include:

• The right to access the information we hold about you and to obtain information about how we process it.
• In some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so.
• In some circumstances, the right to receive certain information you have provided to us in an electronic format and/or request that we transmit it to a third party.
• The right to request that we rectify your information if it’s inaccurate or incomplete.
• In some circumstances, the right to request that we erase your information. We may continue to retain your information if we are entitled or required to retain it.
• The right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and/or to refuse that request.

You can exercise your rights by contacting us using the details set out in the ‘More details about your information’ section below.

How We Keep Your Information Secure

We use a range of measures to keep your information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and apply appropriate measures for the use and transfer of information.

More Details About Your Information

If you’d like further information on anything we have stated in this Privacy Notice, or to contact our Alternate Channels, contact us at: P.O. Box 31567, Lilongwe 3, Malawi addressed ‘for the attention of the Alternate Channels Manager’.

This Privacy Notice may be updated from time to time, and you’ll always be able to find the most recent version on our website.

Last update: Sept 2023