Privacy Policy

Universal Banks

Privacy Policy

This privacy notice applies to personal information held by Universal Banks – UB, herein referred to as the bank and its banking partners and associates. It describes the information we will collect about you and how we intend on using such information. It further explains who we will share your information with and when and also, what we intend on doing to ensure it stays safe and secure. It continues to apply even if your agreement for investment banking or other products and services with us ends. It should also be read alongside your investment banking terms and conditions.

This notice covers any personal products and services you may have with us. This includes your savings, investments on any portfolio, loans and credits as well as insurance.

Wherever we have used ‘you’ or ‘your’, this implies you or any authorized person on your account, anyone who does your banking or any related entries with us for you - for example, trustees, executors or attorneys and any other related persons or authorized entities which may include signatories, partners, members or trustees. When we use ‘we’, we mean Universal Banks – UB which acts as a data controller in respect to your provided personal information unless otherwise stated below, the data controller for the purposes of this notice is the bank, Universal Banks – UB.

The address for the bank, Universal Banks – UB is Paphos Banking Center, Griva Digeni Ave., CY - Paphos, Cyprus. If the need to get in touch arises, please visit our website – and view our other contact information and use as it suits you most.

1. The information we collect

We will only collect information about you as allowed by regulations and law. We may collect it from a range of places and it may relate to any of our products or services you apply for, currently hold or have held in the past. We may also collect information about you when you interact with us. This includes when you visit our websites or mobile channels, call us or visit one of our branches, or ask about any of our products and services. Some of it will come directly from you, for example, when you provide ID to open an account.

It can also come from your financial advisor, broker or mortgage intermediary, the insurance company which provides the insurance policies we offer, or other places you have asked us to get information from. We might also get some from publicly available places. The information we collect will depend on the type of product you hold. It may include:

1.1. The information you provide to us, for example:

  • personal details, for example, names, gender, date and place of birth;
  • contact details, for example, address, email address, and telephone numbers;
  • information about your identity for example, photo ID, passport information, National Insurance number, National ID card and nationality;
  • market research, for example, information and opinions given;
  • user login and subscription data, for example, login details for phone, online banking and mobile banking apps;
  • other information about you that you give us when you fill forms in or by communicating with us, whether face-to-face, by phone, email, online, or otherwise;
  • if our relationship is because of an insurance policy or claim, we may also collect:
  • information regarding your family or other people who might be covered by or benefit from your insurance policy, or be financially dependent on you;
  • relevant details including details of previous policies and claims history;
  • lifestyle information, for example, if you smoke and how much alcohol you drink
  • relevant details about your physical or mental health for example, if you make a claim we may ask for medical information
  • details about any criminal convictions or related information. This includes details of offences or alleged offences
  • any other information which is relevant to a claim that you make

1.2. The information we collect and provide about you, for example:

  • your financial information and information about your relationship with us, including the products and services you hold, the channels you use, how you deal with us, your ability to get and manage credit, your payment history, transactions records, market trades, and information about complaints and disputes
  • information we use to identify you, for example, your signature and other information, such as your voice for voice for voice ID, or additional information that we receive from external sources that we need for compliance purposes
  • information included in customer documentation, for example, a record of advice that we may have given you
  • marketing and sales information, for example, details of the services you receive and your preferences;
  • information about your device or the software you use, for example, its IP address, technical specification and uniquely identifying data;
  • cookies and similar technologies we use to recognize you, remember your preferences and tailor the content we provide to you
  • risk rating information, for example, credit risk rating, transactional behavior and underwriting information
  • investigations data, for example, due diligence checks, sanctions and anti-money laundering checks, external intelligence reports, content and metadata related to relevant exchanges of information between and among individuals or organizations, including emails, voicemail, live chat, etc
  • records of correspondence and other communications between us;
  • information we need to support our regulatory obligations;
  • detection of any suspicious and unusual activity and information about parties connected to you or these activities

1.3. The information we collect from other places, for example:

  • information you have asked us to collect for you, for example, details about your accounts with us or other companies including transaction data
  • information from third party providers, that helps us to help prevent or detect fraud or that relates to your social interactions. This includes your communications via social media, between individuals, organizations, prospects and other stakeholders acquired from companies that collect combined information;

2. How we will use your information

We will only use your information if we have your permission or we have another legal reason for using it. These reasons include:

  • if we need to pursue our legitimate interests;
  • to enter into or carry out an agreement we have with you
  • where we are required to by law;
  • where we believe it is in the public interest for us to do so for example, to help prevent or detect crime
  • to establish, utilize or defend our legal rights
  • for insurance purposes

The reasons we use your information include to:

  • provide you with our products and services;
  • carry out your wishes, for example, make a payment you request or a change to your insurance policy;
  • carry out credit checks
  • manage our relationship with you
  • prevent or detect crime including fraud and financial crime
  • manage risk, ensure security and business continuity
  • provide online services such as online banking and mobile apps
  • market our products and services to you and others
  • improve our products and services, from seeing how you use them
  • protect our legal rights and comply with our legal obligations
  • correspond with solicitors, surveyors, valuers, other lenders, conveyancers and third-party intermediaries
  • carry out system or product development and planning, insurance, audit and administrative purposes;
  • recover money that you owe us for example, where you have not paid for your insurance policy

2.1. How we make decisions about you

We may use automated systems to help us make some of our decisions, for example, when you apply for products and services, to make credit decisions and to carry out fraud and money laundering checks. We may also use technology to help us identify the level of risk involved in customer or account activity, for example, for credit, fraud or financial crime reasons, or to identify if someone else is using your account without your permission.

You may have a right to certain information about how we make these decisions and ask for a decision to be made by a person instead of a computer.

2.2. Tracking or recording what you say or do

To help keep you and your money safe, we may store details of your interactions with us. We may also record and keep track of conversations you have with us including phone calls, physical meetings, letters, emails, live chats, video chats and any other kinds of communication. We may use these to check your instructions to us, assess, analyze and improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also store additional information about these interactions, for example, telephone numbers that you call us from and information about the devices or software that you use.

We use closed circuit television in and around our offices and branches and these may collect photos or videos of you, or record your voice. Our websites, apps, and other digital products may also track and record your interactions with them to help keep you safe, to help us provide or improve services and features, to help keep our services secure, to help make your visit more personal, or to support our marketing. Some tracking is optional.

2.3. Compliance with laws and regulatory compliance obligations

We will use your information to meet our compliance obligations. We will also use it to comply with other laws and regulations. We will share your information with regulators and other authorities that Universal Banks – UB 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 if it is needed to comply with a legal requirement, it is in our legitimate interests and that of others, or to prevent or detect unlawful acts.

2.4. Marketing

We may use your information to provide you with details about our products and services, and also products and services from other third parties. We may send you marketing messages by post, email, telephone, text, secure messages, mobile app, or through social media. You can change your mind on how you receive marketing messages or you can stop receiving them at any time. To make that change, please contact us in the usual way. Even if you tell us not to send you marketing messages, we will continue to use your contact details to send you important information, such as changes to your terms and conditions or if we need to tell you something to comply with our regulatory obligations.

2.5. Market research

We may use your information for market research and to identify trends. Market research agencies acting on our behalf may get in touch with you to invite you to take part in research. We would not invite you to take part in research using a communication method if you have asked us not to get in touch that way. Any responses you provide will be reported back to us anonymously unless you give us permission for your details to be shared

3. Who we might share your information with

We may share your information with others where lawful to do so including where we or they:

  • need to in order to provide you with products or services you have asked for;
  • need to in order to provide you with your insurance policy or to administer your claim;
  • have a public or legal duty to do so, for example, to help with detecting and preventing fraud, tax evasion and financial crime;
  • need to for any regulatory reporting, litigation or asserting or defending legal rights and interests;
  • wish to send marketing to you or others, where you have given us your permission, or it is within our legitimate interest to do so;
  • have a legitimate business reason for doing so, for example, to manage risk, confirm your identity, enable another company to provide you with services you have asked for, or check your suitability for products and services;
  • have asked you for your permission to share it, and you have agreed.

We may share your information for these purposes with others including

  • any joint account holders, trustees, beneficiaries or executors;
  • people who give guarantees or other security for any amounts you owe us;
  • people you make payments to and receive payments from;
  • your beneficiaries, intermediaries, correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties and any companies you hold securities in through us, for example, stocks, bonds or options;
  • other financial institutions, lenders and holders of security over any property you charge to us, tax authorities, trade associations, credit reference agencies, payment service providers and debt recovery agents;
  • any fund managers who provide asset management services to you and any brokers who introduce you to us or deal with us for you;
  • any people or companies that have an interest in the products or services that we provide to you, including if they take on the risk related to them;
  • any people or companies in connection with potential or actual corporate restructuring, merger, acquisition or takeover, including any transfer or potential transfer of any of our rights or duties under our agreement with you;
  • law enforcement, government, courts, dispute resolution bodies, our regulators, auditors and any party appointed or asked for by our regulators to carry out investigations or audits of our activities;
  • other parties involved in any disputes, including disputed transactions;
  • fraud prevention agencies who will also use it to detect and prevent fraud and other financial crime and to confirm your identity;
  • anyone who provides instructions or operates any of your accounts on your behalf, for example, Power of Attorney, solicitors, intermediaries, etcetera;
  • anybody else that we have been asked to share your information with by either you, a joint account holder or anybody else who provides instructions or operates any of your accounts on your behalf;
  • our card processing supplier or suppliers to carry out credit, fraud and risk checks, process your payments, issue and manage your card;
  • If our relationship is because of an insurance policy or claim, we will also share your information with:
  • other parties involved in providing your insurance policy, for example, the intermediary or insurer who provides your policy;
  • third parties involved in the administration of the relevant insurance policy or claim including loss adjusters, claims handlers, private investigators, experts and our advisors;
  • where relevant, medical experts and rehabilitation providers.

3.1. Online advertisement

When we advertise our products and services on the internet, we may share your information with our advertising partners. For example, when we use social media for marketing purposes, your information may be shared with the social media platforms so that they can check if you hold an account with them

If you do, we may ask the social media partner or social media network:

  • to use your information to send our adverts to you, for example, because we think that you might be interested in a new service that we offer;
  • to exclude you from receiving our adverts, for example, because the advert is for a service that you already use;
  • to advertise to people who have a similar profile to you, for example, if we discover that one of our services is particularly useful to people with similar interests to the ones on your social media profile, we may ask our advertising partner or the social media network to send our adverts for that service to people who share your interests.

Social media platforms also allow you to indicate your preferences to them about the advertising you receive on their platforms

Data Privacy Notice

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