Privacy Policy

Document Information

Policy Title: Privacy Policy. Policy Number: VBS-POL-002. Version: 1.0. Document Classification: Public. Status: Active. Effective Date: 1 July 2026. Publication Date: 26 June 2026. Approval Date: 26 June 2026. Next Review Date: 1 July 2027. Approved By: Board of Directors. Policy Owner: Compliance & Data Protection Office.

1. Introduction

SENTINEL PEAK BANK ("the Bank", "we", "our", or "us") is committed to protecting the privacy, confidentiality, and security of the personal information entrusted to us by our customers, employees, business partners, and website visitors. This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you use our banking services, visit our website, access our digital banking platforms, or otherwise interact with us. By accessing or using our services, you acknowledge that you have read and understood this Privacy Policy.

2. Scope

This Privacy Policy applies to all personal information collected through our official website, Internet Banking, Mobile Banking, branch offices, customer service centres, telephone and email communications, online account applications, loan applications, employment applications, and business relationships with third parties.

3. Information We Collect

Depending on the services you use, we may collect personal identification information such as full name, date of birth, nationality, residential and postal addresses, government-issued identification numbers, passport information, driver's licence details, and tax identification numbers. We may also collect contact information, financial information including bank account details and transaction history, technical information such as IP address, browser type, device information, operating system, login activity, cookies, session information, and website usage statistics. To comply with KYC and AML obligations, we may collect identity verification documents and supporting information.

4. How We Use Your Information

We process personal information for legitimate banking and business purposes including opening and maintaining accounts, processing payments and transfers, providing banking services, verifying customer identity, preventing fraud and financial crime, managing loans and credit facilities, meeting legal and regulatory obligations, improving customer service, sending important service notifications, responding to customer enquiries, enhancing website functionality, conducting internal audits and risk management, and protecting our systems and customers from cyber threats. We will not use your personal information for purposes incompatible with those described in this Privacy Policy without your consent or as otherwise permitted by law.

5. Legal Basis for Processing

Where applicable, we process personal information based on one or more of the following: your consent, performance of a contract, compliance with legal obligations, protection of vital interests, legitimate business interests, and regulatory requirements applicable to financial institutions.

6. Cookies and Website Technologies

Our website uses cookies and similar technologies to improve website performance, remember user preferences, enhance security, analyse website traffic, detect fraudulent activity, and support online banking functionality. You may modify your browser settings to manage or disable cookies; however, doing so may affect certain website features.

7. Information Sharing

We treat customer information as confidential. We may disclose personal information only where necessary to regulatory authorities, courts of competent jurisdiction, law enforcement agencies, payment processors, credit reference agencies, identity verification providers, technology service providers, external auditors, professional advisers, and insurance providers. All third parties receiving personal information are required to maintain appropriate confidentiality and security standards.

8. International Data Transfers

Where necessary to provide banking services or comply with legal obligations, personal information may be transferred to jurisdictions outside your country of residence. Where such transfers occur, appropriate safeguards will be implemented to protect your personal information.

9. Data Security

SENTINEL PEAK BANK maintains comprehensive technical, administrative, and organisational safeguards designed to protect personal information against unauthorised access, disclosure, alteration, loss, or destruction. Security measures include encryption of sensitive data, Secure Socket Layer (SSL/TLS) encryption, multi-factor authentication, firewalls and intrusion detection systems, access controls based on business need, regular security testing, continuous monitoring, and employee confidentiality obligations. Despite these measures, no system can guarantee absolute security. Customers are encouraged to protect their login credentials and report any suspected security incidents immediately.

10. Data Retention

Personal information is retained only for as long as necessary to provide banking services, comply with legal and regulatory obligations, resolve disputes, enforce contractual agreements, and support legitimate business operations. Once retention periods expire, information will be securely deleted or anonymised.

11. Your Privacy Rights

Subject to applicable law, you may have the right to access your personal information, request correction of inaccurate information, request deletion where legally permissible, restrict certain processing activities, object to specific processing, withdraw consent where processing is based on consent, request data portability where applicable, and lodge a complaint with the relevant supervisory authority. Requests may be subject to identity verification.

12. Children's Privacy

Our banking services are not intended for children unless offered through authorised products such as youth or custodial accounts established by a parent or legal guardian. Where required, parental or guardian consent will be obtained.

13. Marketing Communications

We may send information regarding products, services, promotions, financial education, and updates where permitted by law. Customers may opt out of marketing communications at any time without affecting essential banking notifications.

14. Third-Party Websites

Our website may contain links to third-party websites for customer convenience. SENTINEL PEAK BANK is not responsible for the privacy practices, content, or security of external websites. Users should review the privacy policies of any third-party websites they visit.

15. Changes to This Privacy Policy

We may amend this Privacy Policy periodically to reflect changes in law, technology, regulatory requirements, or our business operations. Material changes will be communicated through appropriate channels, including our website and, where appropriate, direct customer notifications. The latest version will always be available on our official website.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, please contact: Compliance & Data Protection Office, SENTINEL PEAK BANK. Email: privacy@sentinelpeakbank.com. Telephone: +000 000 000 000. Business Hours: Monday to Friday, 8:00 AM - 5:00 PM.

Revision History

Version 1.0. Effective Date: 1 July 2026. Summary of Changes: Initial Release. Approved By: Board of Directors.

Document Control

Policy Number: VBS-POL-002. Version: 1.0. Document Status: Active. Effective Date: 1 July 2026. Last Reviewed: 26 June 2026. Next Scheduled Review: 1 July 2027. Approved By: Board of Directors. Policy Owner: Compliance & Data Protection Office. Copyright 2026 SENTINEL PEAK BANK. All Rights Reserved.