Privacy Policy of Synovus Diamond Bank

This Privacy Policy explains how Synovus Diamond Bank ("Synovus", "we", "us", or "our"), operating as a bank in England, collects, uses, discloses, and protects your personal information when you use our banking products, services, websites, and mobile applications.

By using any Synovus Diamond Bank service, you acknowledge that you have read and understood this Privacy Policy and agree to the practices described herein.

1. Who We Are Synovus Diamond Bank is a financial institution based in England. We provide banking and related financial services to individual and business customers. For the purposes of applicable data protection laws, we are the data controller of your personal information.

2. Information We Collect We may collect and process the following categories of personal information:

2.1 Identification and Contact Details

• Full name, title, date of birth, nationality
• Residential and correspondence address
• Email address, telephone numbers
• Identification documents (passport, national ID, driving licence), including ID numbers and copies where required

2.2 Financial and Account Information

• Bank account numbers and sort codes
• Transaction history and payment details
• Credit and debit card details (where applicable)
• Account balances, deposits, loans, mortgages, and other banking products
• Creditworthiness data, credit history, and risk assessments

2.3 Regulatory and Compliance Information

• Information obtained for Know Your Customer (KYC) and anti-money laundering (AML) checks
• Tax identification numbers and tax residency information
• Information related to sanctions, politically exposed person (PEP) checks, and fraud prevention

2.4 Technical and Usage Data

• IP address, browser type and version
• Device identifiers and operating system
• Log data related to access, authentication, and use of our websites, mobile apps, and online banking services
• Cookies and similar technologies (see the section on Cookies below)

2.5 Communication Data

• Records of communications with us (phone calls, emails, in-app messages, online chats, letters)
• Feedback, complaints, and survey responses

2.6 Marketing and Preference Data

• Your marketing preferences and consents
• Information about your use of our products and services for profiling and segmentation, where permitted by law

3. How We Collect Your Information We collect personal information from various sources, including:

• Directly from you, when you apply for or use our products and services
• Through our online and mobile banking platforms
• Through correspondence and communications with us
• From publicly available sources and registers (e.g., Companies House)
• From credit reference agencies and fraud prevention agencies
• From other financial institutions and payment service providers involved in your transactions
• From service providers and business partners acting on our behalf

4. Legal Bases for Processing We process your personal information only where we have a lawful basis to do so. These bases typically include:

• Performance of a contract: To provide you with banking products and services, manage your accounts, and fulfil our contractual obligations.
• Legal and regulatory obligations: To comply with applicable laws, including banking regulations, AML and counter-terrorist financing requirements, tax reporting, and other statutory duties.
• Legitimate interests: To manage and improve our business, prevent fraud and security threats, maintain accurate records, and conduct internal analysis, provided that such interests are not overridden by your rights.
• Consent: Where required by law, for certain types of marketing, cookies, or data sharing. When processing is based on your consent, you may withdraw it at any time as described in this Privacy Policy.

5. How We Use Your Information We use your personal information for the following purposes:

5.1 To Provide Banking Services

• Opening, administering, and closing accounts
• Processing payments, transfers, and transactions
• Providing loans, credit facilities, and other financial products
• Issuing and managing bank cards
• Providing online and mobile banking services

5.2 To Comply with Legal and Regulatory Obligations

• Conducting identity verification, KYC, and AML checks
• Monitoring transactions to detect and prevent fraud, financial crime, and abuse
• Fulfilling obligations to regulators and law enforcement authorities
• Complying with tax, accounting, and reporting requirements

5.3 To Manage Our Relationship with You

• Communicating with you about your accounts, products, or services
• Handling enquiries, complaints, and disputes
• Notifying you of changes to our terms, conditions, or policies

5.4 To Improve and Develop Our Services

• Analysing how our services are used
• Testing and developing new products, features, and technologies
• Enhancing the security and performance of our systems

5.5 Marketing and Personalisation

• Sending you information about products, services, and offers from Synovus Diamond Bank that may be of interest to you, where permitted by law
• Customising content and offers based on your profile and usage, where permitted and subject to your choices

You can opt out of certain marketing communications at any time by following the instructions in those communications or contacting us as described below.

6. Sharing Your Information We may share your personal information with the following recipients, always on a need-to-know basis and subject to appropriate safeguards:

• Other entities within the Synovus group, if any, for internal administrative and support purposes
• Service providers and contractors who perform services on our behalf (e.g., IT hosting, payment processing, customer support, analytics, document storage)
• Credit reference agencies and fraud prevention agencies
• Other financial institutions, payment networks, and intermediaries involved in your transactions
• Professional advisers such as lawyers, auditors, and consultants
• Regulators, supervisory authorities, law enforcement agencies, and courts where disclosure is required by law or necessary to protect our rights
• Third parties involved in corporate transactions, such as mergers, acquisitions, or restructurings, subject to confidentiality obligations

We do not sell your personal information.

7. International Transfers Your personal information may be transferred to and processed in countries outside England, including countries that may not provide the same level of data protection. Where we transfer your data internationally, we will ensure that appropriate safeguards are in place, such as:

• Relying on adequacy regulations or equivalent legal mechanisms where applicable
• Implementing standard contractual clauses or other approved contractual protections
• Applying additional technical and organisational measures to protect your data

8. Data Retention We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements.

In determining appropriate retention periods, we consider:

• The nature and sensitivity of the data
• The potential risk of harm from unauthorised use or disclosure
• Our legal obligations and regulatory guidance

When your personal information is no longer required, we will securely delete or anonymise it.

9. Data Security We implement technical and organisational measures designed to protect your personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

Such measures may include:

• Encryption and secure transmission of data
• Access controls and authentication procedures
• Network and system monitoring, intrusion detection, and regular security testing
• Physical security controls at our premises and data centres
• Staff training on data protection and information security

While we take reasonable steps to protect your information, no system or transmission can be guaranteed to be completely secure.

10. Your Rights Depending on applicable law, you may have the following rights in relation to your personal information:

• Right of access: To obtain confirmation of whether we process your data and to request a copy of your data.
• Right to rectification: To request correction of inaccurate or incomplete data.
• Right to erasure: To request deletion of your data in certain circumstances.
• Right to restriction: To request restriction of processing in specific situations.
• Right to data portability: To receive your data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller where technically feasible.
• Right to object: To object to processing based on legitimate interests or for direct marketing.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing before withdrawal.

To exercise your rights, please contact us using the details provided in the Contact section. We may need to verify your identity before responding to your request.

11. Cookies and Similar Technologies We may use cookies and similar technologies on our websites and online services to:

• Enable essential site functionality and security
• Remember your preferences and improve user experience
• Analyse usage and performance of our services
• Support marketing and promotional activities, where permitted

You can manage your cookie preferences via your browser settings or any cookie management tools we provide. Disabling certain cookies may affect the functionality of our services.

12. Children’s Privacy Our services are not directed at children below the minimum age required to hold a bank account under applicable law. We do not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe a child has provided us with personal information without such consent, please contact us so that we can take appropriate action.

13. Third-Party Websites and Services Our websites or services may contain links to third-party websites or services that are not operated by Synovus Diamond Bank. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party sites or services you visit.

14. Changes to This Privacy Policy We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will take appropriate steps to inform you, such as by posting a notice on our website or contacting you directly.

The date of the latest update will always be indicated at the top of this Privacy Policy.

15. Contact If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, you may contact Synovus Diamond Bank using the contact details provided on our official website.

Please include sufficient information for us to identify you and respond to your query in a timely manner.