Privacy Policy

Privacy Policy

Effective: January 1, 2026 Version 1.0.0

Legal Disclaimer: This document is subject to legal counsel review. Please read carefully as it contains important information about your rights and obligations.

PRIVACY POLICY

Effective Date: 01 January 2026

1. INTRODUCTION & SCOPE

This Privacy Policy ("Policy") explains how Confidiance Bank ("Confidiance Bank", "the Bank", "we", "us", or "our") collects, processes, stores, shares, and protects personal and business information of its members ("Member", "you", "your").

This Policy applies to:

  • Website usage
  • Digital banking platforms and applications
  • IBAN-linked member accounts
  • Treasury, payment, credit, insurance, and crypto-related services

By accessing or using the Confidiance Bank platform, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

2. OPERATING STRUCTURE & DATA ROLES

2.1 Confidiance Bank operates as a membership-based digital banking and treasury platform.

2.2 All IBAN accounts are issued and regulated by third-party Electronic Money Institutions ("EMIs"), primarily Valens Pay, and their correspondent banking partners.

2.3 Confidiance Bank maintains a Treasury Office in the United Kingdom, which performs treasury coordination, administrative oversight, and compliance liaison functions.

2.4 Confidiance Bank acts as:

  • A data controller for member registration, platform usage, and treasury administration data
  • A data processor or joint controller where data is processed on behalf of EMI partners or third-party service providers

3. APPLICABLE PRIVACY LAWS & STANDARDS

This Policy is designed to comply with, and be interpreted in accordance with, the following privacy frameworks:

3.1 United States (USA)

  • Privacy principles derived from federal and state privacy and consumer protection laws
  • Core principles include:
    • Transparency
    • Reasonable security safeguards
    • Lawful and fair processing
    • Purpose limitation

3.2 European Union & United Kingdom

  • General Data Protection Regulation (GDPR) principles, including:
    • Lawfulness, fairness, and transparency
    • Purpose limitation
    • Data minimisation
    • Accuracy
    • Storage limitation
    • Integrity and confidentiality
    • Accountability

3.3 South Africa

  • Protection of Personal Information Act (POPIA), including conditions of lawful processing:
    • Accountability
    • Processing limitation
    • Purpose specification
    • Further processing limitation
    • Information quality
    • Openness
    • Security safeguards
    • Data subject participation

Where multiple laws apply, the highest standard of protection shall prevail.

4. INFORMATION WE COLLECT

We may collect the following categories of information:

4.1 Personal Information

  • Full names
  • Identification numbers or passport details
  • Date of birth
  • Contact details
  • Proof of address

4.2 Financial & Transactional Information

  • IBAN details (issued by EMI partners)
  • Transaction histories
  • Account balances
  • Source of funds and source of wealth information

4.3 Business Information

  • Company registration details
  • Ownership and control information
  • Directors and beneficial owner data

4.4 Technical & Usage Data

  • IP addresses
  • Device identifiers
  • Login timestamps
  • Platform usage activity

5. LAWFUL BASIS FOR PROCESSING

Personal data is processed on one or more of the following lawful bases:

  • Performance of a contract (membership and service delivery)
  • Compliance with legal and regulatory obligations
  • Legitimate interests of Confidiance Bank and its service providers
  • Consent, where required by law
  • Prevention of fraud, financial crime, and sanctions breaches

6. PURPOSE OF DATA PROCESSING

We process personal data for the following purposes:

  • Member onboarding and verification (KYC/KYB)
  • AML, CTF, and sanctions compliance
  • IBAN and payment facilitation through EMI partners
  • Treasury operations and internal accounting
  • Risk management and fraud prevention
  • Regulatory reporting where required by law
  • Customer support and dispute resolution

7. DATA SHARING & DISCLOSURE

7.1 By using the platform, the Member expressly authorises Confidiance Bank to share relevant information with:

  • EMI providers and correspondent banks
  • Compliance, screening, and monitoring service providers
  • Credit, insurance, and crypto service providers
  • Auditors, insurers, and professional advisors

7.2 No personal information will be shared with third parties unless:

  • Required under a commercial or operational agreement
  • Required by law or regulatory authority
  • Internally validated and approved by Confidiance Bank

7.3 Confidiance Bank does not sell personal data.

8. INTERNATIONAL DATA TRANSFERS

8.1 Due to the international nature of services, personal data may be transferred to and processed in multiple jurisdictions, including the USA, Europe, the United Kingdom, and South Africa.

8.2 All international transfers are subject to:

  • Appropriate safeguards
  • Contractual confidentiality obligations
  • Compliance with applicable data protection laws

9. DATA RETENTION

9.1 Personal data is retained only for as long as:

  • Required to fulfil contractual obligations
  • Required by AML, CTF, and regulatory record-keeping laws
  • Necessary for dispute resolution or legal defence

9.2 Retention periods may extend beyond account closure where legally required.

10. DATA SECURITY

10.1 Confidiance Bank implements reasonable and appropriate technical and organisational measures to protect personal data against:

  • Unauthorised access
  • Loss or destruction
  • Alteration or misuse

10.2 Despite safeguards, no system can be guaranteed to be completely secure. Use of the platform is at the Member's own risk.

11. DATA SUBJECT RIGHTS

Subject to applicable law, Members may have the right to:

  • Access their personal data
  • Request correction or updating of data
  • Request deletion where legally permissible
  • Object to certain processing activities
  • Withdraw consent where processing is consent-based

Requests may be limited where:

  • Legal obligations require continued processing
  • AML, sanctions, or fraud prevention rules apply

12. LIMITATION OF LIABILITY

12.1 Confidiance Bank, its directors, shareholders, officers, and representatives shall not be liable for:

  • Losses arising from lawful data processing
  • Regulatory or compliance-mandated disclosures
  • Actions taken by EMI partners or correspondent banks

13. CONTACT INFORMATION

14. POLICY UPDATES

14.1 Confidiance Bank reserves the right to amend this Privacy Policy at any time.

14.2 Continued use of the platform constitutes acceptance of any updated version.

15. FINAL PROVISION

This Privacy Policy forms an integral part of Confidiance Bank's membership framework and must be read together with the Terms & Conditions and AML/CTF Policy.

Document Version: 1.0.0 | Last Updated: January 1, 2026

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Terms & Conditions
AML Policy
Risk Disclosure