Privacy Policy

Illunwo Bank ("we," "our," or "us") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our banking services, digital platforms, and related products. We operate under the principle that your financial data is among the most sensitive personal information you possess. We treat it with the highest level of care, discretion, and security. This Policy applies to all information collected through our website, mobile applications, and any other digital or physical touchpoints with Illunwo Bank. By using our services, you consent to the data practices described in this Privacy Policy. If you do not agree with this Policy, please discontinue use of our services and contact us to close your account.

We collect several categories of information to provide and improve our banking services: Identity Information: Full legal name, date of birth, government-issued identification numbers, nationality, and country of residence. This information is required for KYC verification and regulatory compliance. Contact Information: Email address, phone number, mailing address, and emergency contact details. Used for account communications, security alerts, and regulatory notices. Financial Information: Account balances, transaction history, source of funds declarations, beneficial ownership information, and financial statements. Required for banking operations and regulatory compliance. Technical Information: IP addresses, device identifiers, browser type and version, operating system, access times, pages viewed, and referring URLs. Collected automatically when you use our digital platforms. Behavioral Information: How you interact with our platform, features you use, transaction patterns, and service preferences. Used to improve our services and detect fraudulent activity. Communications: Records of your communications with our support team, feedback you provide, and survey responses.

We use your personal information for the following purposes: Service Delivery: To open and manage your account, process transactions, execute transfers, and provide all banking services you request. Identity Verification & KYC: To verify your identity, conduct due diligence, and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations. Security & Fraud Prevention: To monitor for suspicious activity, detect and prevent fraud, protect against unauthorized access, and maintain the security of our systems and your account. Legal & Regulatory Compliance: To comply with applicable laws, regulations, court orders, and requests from regulatory authorities. This includes transaction reporting, sanctions screening, and record-keeping obligations. Service Improvement: To analyze usage patterns, troubleshoot issues, develop new features, and improve the overall quality of our services. Communications: To send account statements, transaction confirmations, security alerts, service updates, and responses to your inquiries. Marketing: With your consent, to send information about new products, services, and promotions that may be of interest to you. You may opt out at any time.

Illunwo Bank does not sell your personal information to third parties. We may share your information in the following limited circumstances: Service Providers: We engage trusted third-party service providers who assist us in operating our platform, processing payments, conducting identity verification, and providing other services. These providers are contractually bound to protect your information and use it only for the purposes we specify. Regulatory & Legal Requirements: We may disclose your information to government authorities, regulatory bodies, law enforcement agencies, or courts when required by law, court order, or regulatory directive. This includes mandatory reporting under AML/CFT regulations. Financial Partners: To facilitate transactions, we may share necessary information with correspondent banks, payment processors, and other financial institutions involved in processing your transactions. Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. With Your Consent: We may share your information with third parties when you have given us explicit consent to do so. We require all third parties to maintain appropriate security measures and to use your information only for the purposes for which it was shared.

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically: • Account information is retained for the duration of your account relationship plus a minimum of 7 years after account closure, as required by financial regulations • Transaction records are retained for a minimum of 7 years from the date of the transaction • KYC documentation is retained for 5 years after the end of the business relationship • Communication records are retained for 3 years • Technical logs are retained for 12 months After the applicable retention period, we securely delete or anonymize your information. Where anonymization is not possible, we ensure the information is stored securely and isolated from further processing.

Depending on your jurisdiction, you may have the following rights regarding your personal information: Right of Access: You may request a copy of the personal information we hold about you, including information about how it is used and with whom it is shared. Right to Rectification: You may request correction of inaccurate or incomplete personal information. Note that some information cannot be changed once verified for regulatory purposes. Right to Erasure: In certain circumstances, you may request deletion of your personal information. This right is subject to our legal obligations to retain certain data. Right to Restrict Processing: You may request that we limit how we use your information in certain circumstances. Right to Data Portability: You may request a copy of your personal information in a structured, machine-readable format. Right to Object: You may object to certain types of processing, including direct marketing. Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing. To exercise any of these rights, please contact our Data Protection Officer at privacy@illunwobank.com. We will respond to your request within 30 days.

Illunwo Bank implements comprehensive technical and organizational security measures to protect your personal information: Encryption: All data is encrypted in transit using TLS 1.3 and at rest using AES-256 encryption. Database fields containing sensitive information use additional field-level encryption. Access Controls: Access to personal information is restricted to authorized personnel on a need-to-know basis. All access is logged and regularly audited. Authentication: Multi-factor authentication is required for all administrative access to systems containing personal data. Infrastructure Security: Our systems are hosted in SOC 2 Type II certified data centers with physical security controls, redundant power, and environmental monitoring. Monitoring: We employ continuous security monitoring, intrusion detection systems, and regular penetration testing to identify and address vulnerabilities. Incident Response: We maintain a documented incident response plan and will notify you of any data breach affecting your information as required by applicable law. Despite these measures, no security system is impenetrable. We encourage you to use strong passwords, enable MFA, and report any suspicious activity immediately.

We use cookies and similar tracking technologies to enhance your experience on our platform. For detailed information about our use of cookies, please review our Cookie Policy at /cookie-policy. In summary, we use: • Essential cookies required for platform functionality and security • Analytics cookies to understand how our platform is used • Preference cookies to remember your settings and preferences You can manage your cookie preferences through our Cookie Preference Center or your browser settings. Note that disabling certain cookies may affect the functionality of our platform.

For privacy-related inquiries, requests to exercise your rights, or concerns about our data practices, please contact: Data Protection Officer Illunwo Bank Email: privacy@illunwobank.com Support: support@illunwobank.com If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority. This Privacy Policy was last updated on August 21, 2026. We will notify you of material changes via email or prominent notice on our platform.