Mobile Banking – Privacy Policy

Applicability

This Policy is applicable to personal information collected by the Bank directly from the customer or prospective customer — or through the Bank's online portals, electronic communications — as also any information collected by the Bank's server from the customer's computer, mobile, or other similar electronic devices.

Specifically, it covers all natural persons whose personal information is:

• Collected, received, possessed, stored, dealt in, or handled by the Bank
• Provided while using the Bank mobile application
• Shared while visiting the Bank's official website: sircilla.bank.in
• Provided to the Bank through any online or electronic communication channel

Information Collected by the Bank

The Bank collects, retains, and uses personal information only when it reasonably believes that it is for a lawful purpose and that it will help administer its business or provide products, services, and other opportunities to the visitor or customer. The information which is provided by the customer online is held by the Bank that maintains your account or is processing your application for a new product or service. The Bank collects three categories of information:

Personal Information

• Name, address, telephone number, e-mail address
• Occupation and employer details
• Date of birth and gender
• Any other information capable of identifying the individual

Sensitive Personal Data (SPDI)

• Financial information such as bank account details, credit card, debit card, or other payment instrument details
• Passwords and authentication credentials
• Bio-metric information, if applicable (fingerprint, facial recognition, iris scan, etc.)

Non-Personal Information

Non-personal information includes the IP address of the device used to connect to the Bank's server, along with other information such as:

• Browser type and version
• Operating system used
• Name of the website that redirected the visitor to the Bank's website
• Online preferences and session data

Purpose and Usage of Information

The Bank uses the data collected — with proper notification to the customer or prospect customer — to:

• Manage its business and administer customer's account by offering an enhanced, personalized online and mobile banking experience
• Verify the customer's identity and detect fraudulent activities
• Process transactions and recharge services initiated by the customer
• Send notifications and confirmations related to customer's banking activities
• Enable features such as Pay to Contact, bio-metric login, and bill recharge
• Comply with all applicable laws, regulations, and regulatory guidelines
• Conduct statistical analysis and credit scoring
• Advise the customer on the Bank's products, services, and other opportunities

Data Collection: Feature-Specific Details

Phone Number

• To verify the bank account associated with customer's registered mobile number.
• For device identification and fraud detection purposes. Collected information will not be shared with any third-party platform.

Contact List

In order to provide mobile bill recharge services and payment features, the Bank may collect and utilize the customer contact list. This is done in accordance with applicable data protection laws and regulations.

Why We Collect Contact Lists:

• Contact Verification: To ensure accuracy of mobile numbers for recharging by cross-referencing with numbers the customer may wish to recharge.
• Recharge Convenience: To simplify the recharge process by allowing the customer to select recipients directly from his contacts.
• Notification and Confirmation: To send notifications and confirmation messages related to recharge transactions.
• Pay to Contact: To enable the 'Pay to Contact' fund transfer feature using the customer's phone directory.

How We Use Contact Lists:

• Contact Matching: To match mobile numbers in customer's contact list with numbers provided for recharge, ensuring the correct recipient.
• Recharge Transactions: Contact list data is used exclusively for initiating and processing mobile bill recharge transactions as per customer's instructions.
• Notifications: To send customer's transaction confirmations, bill payment reminders, and recharge status updates to him and his selected recipients.

Bio-metric Information (presently not enabled)

The Bank's mobile application may offer bio-metric authentication (such as fingerprint or facial recognition) for secure and convenient login. The following conditions apply:

• Bio-metric data is processed locally on the customer's device using the device's secure hardware and operating system.
• The Bank does not store raw bio-metric data on its servers.
• Enabling bio-metric login is entirely optional. PIN or password-based authentication may be used at any time.
• Customer may revoke bio-metric access at any time through device or app settings.

Accuracy of Information

The Bank has processes in place to ensure that the personal information it holds is complete, accurate, and current. If at any point a customer believes that the personal information held by the Bank is incorrect or outdated, the customer may inform the Bank accordingly. The Bank will promptly investigate and correct any erroneous information upon verification.

For KYC-related corrections or to obtain a copy of your KYC details, please write to us from your registered email ID at scub.srcl@gmail.com.

Sharing and Disclosure of Information

The Bank does not disclose sensitive personal information of a customer except as directed by law or as per mandate received from the customer or applicant. No specific information about customer accounts or personally identifiable data is shared with non-affiliated third parties unless any of the following conditions is met:

• To complete a transaction initiated by the customer
• To provide support services through an authorized outsourced entity
• The disclosure is necessary for compliance with a legal obligation
• The information is shared with Government agencies mandated under law
• The information is shared with any third party by an order under the law
• The customer or applicant has specifically authorized such disclosure
• For purposes of credit reporting, verification, and risk management, the Bank may exchange information about customers with reputed credit bureaus and clearing house centers

We do not share customer's contact list data or personal information with third parties for marketing or promotional purposes. Any third-party service providers engaged by the Bank are bound by confidentiality obligations and are required to conform to the Bank's Privacy Policy standards.

Security of Personal Information

The security of personal information is a Bank's priority and is protected by maintaining physical, electronic, and procedural safeguards that meet applicable laws and regulatory standards.

• Encryption: All data — including contact list information — is transmitted and stored using industry-standard encryption protocols to prevent unauthorized access.
• Access Controls: Access to personal data is restricted to authorized personnel only, used solely for the purposes outlined in this Policy.
• Employee Training: Bank employees are trained in proper handling of personal information, with internal policies governing data access and usage.
• Third-Party Compliance: Service providers must protect the confidentiality of personal information in the same manner the Bank protects it.

Mobile and telebanking calls may be recorded and monitored for security and service quality purposes.

The Bank mobile application may contain links to external Government and private organization websites. Accessing such links is at the customer's own risk, as the Bank cannot guarantee the information handling practices of linked third-party websites.

Data Retention

Personal information may be retained for a duration required by regulatory clauses or as long as required to achieve the identified (and notified) purpose, specifically:

• Contact list data is retained only as long as necessary to fulfill the purposes described in this Policy, after which it is securely deleted.
• Transaction and account data is retained as per Reserve Bank of India (RBI) and applicable regulatory guidelines.
• After the retention period lapses, personal information is securely purged from the Bank's systems.

The Customer's Consent

By using the Bank's mobile application and agreeing to this Privacy Policy, it is construed that the customer has given consent to the collection and use of the personal data, contact list, bio-metric data (if enabled), and other relevant information as described herein.

The customer may withdraw his/her consent at any time by:

• Adjusting the customer's device's app permissions for contact list or bio-metric access.
• Contacting the Bank through official channels for further assistance.

Withdrawal of consent may affect the customer's ability to use certain features of the application.

Do's and Don'ts of Mobile Banking

Grievance Redressal Mechanism

In order to address any discrepancies or grievances related to personal information residing with the Bank, customers may use the following channels:

• Online Form: Lodge a complaint via the Customer Grievance Form — sircilla.bank.in
• Email Support: For KYC-related queries, write from your registered email ID — scub.srcl@gmail.com
• Visit a Branch: Visit your nearest Sircilla Co-Operative Urban Bank branch for in-person assistance.

Changes to This Policy

The Bank has the right to change the terms and conditions of this policy and it may, from time to time, change the content of this Policy to reflect changes as per applicable law, regulatory requirements, or improvements to the Bank's products and services. Any material changes will be communicated through the Bank mobile application notification or through the Bank's official website. Continued use of the application following such changes constitutes customer's acceptance of the revised Policy.

Contact