PRIVACY POLICY

Banque Havilland S.A. (the “Bank” or “BH”) built the BH Online app (the “App”) as a free app. This SERVICE (the “Service”) is provided by the Bank at no cost and is intended for use as is.

This page is used to inform visitors regarding the Bank’s policies with the collection, use, and disclosure of personal information (the “Personal Information”) if anyone decided to use the Service.

If you choose to use the Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that the Bank collects is used for providing and improving the Service. The Bank will not use or share your information with anyone except as described in this privacy policy (the “Privacy Policy”).

The terms used in this Privacy Policy have the same meanings as in the Bank’s Online Banking Terms and Conditions, which were provided to each client in hard form, unless otherwise defined in this Privacy Policy, and shall be read together with the Privacy Notice, which is available at BH website.

For additional information, please consult https://www.apple.com/ legal/privacy/ or https://policies.google.com/privacy

INFORMATION COLLECTION AND USE

For a better experience, while using the Bank’s Service, the Bank may require you to provide it with certain personally identifiable information, including but not limited to Android_ID and Apple_ID. The information that the Bank requests will be retained by the Bank and used as described in this Privacy Policy.

Additional information such as account movements, account positions, payment details, and the username may as well be collected by the App. It is to be noted that for E-Banking mobile Android application (the “Mobile App”), the Android_ID and Apple_ID is collected to have a unique ID to identify the user in E-Banking. All other private information (localization, utilization time, IP, name, age, etc.) are not collected in the Mobile App.

LOG DATA

The Bank wants to inform you that whenever you use the Service, the App collects data and information on your phone called Log Data.

This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App when utilizing the Service, the time and date of your use of the Service, and other statistics.

COOKIES

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device’s internal memory.

This Service does not use these “cookies” explicitly. However, the App may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

SECURITY

The Bank values your trust in providing the Bank your Personal Information, thus the Bank is striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and the Bank cannot guarantee its absolute security.

Private information is stored in two geographically distributed data centres with controlled and secured physical access. Power, storage and servers are all redundant to ensure business continuity. Infrastructure components are maintained up to date according to a patch management policy. Data centre are interconnected through high speed redundant and encrypted leased lines. Attack surface is reduce through a multi-layered architecture with firewalls and intrusion protection system from different vendors at each layer. Data are encrypted during transit through a TLS connexion respecting the current highest encryption standards. The App is recurrently subject to code review and professional penetration testing and is designed with security features to reduce the risk of compromise on the endpoint. Sensible data modification is authenticated, authorized and accountable.

An incident response plan is defined and regularly tested in order for BH’s employee to react promptly if needed. Access to sensible data for BH’s employees is controlled through a logical access policy and employee are subject to background check and trained annually on security, confidentiality, business ethics and appropriate usage.

LINKS TO OTHER SITES

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by the Bank. Therefore, the Bank strongly advises you to review the privacy policy of these websites. The Bank has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

One of such links is https://www.apple.com/legal/privacy/ or Google Play Services, a website which you may visit in order to obtain complementary information to the Bank’s Privacy Policy.

CHILDREN’S PRIVACY

These Services do not address anyone under the age of 13. The Bank does not knowingly collect personally identifiable information from children under 13. In the case the Bank discovers that a child under 13 has provided the Bank with personal information, the Bank immediately deletes this from the Bank’s servers. If you are a parent or guardian and you are aware that your child has provided the Bank with personal information, please contact the Bank so that the Bank will be able to do necessary actions.

CHANGES TO THIS PRIVACY POLICY

The Bank may update its Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. The Bank will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

CONTACT US

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact the Bank.