DATA PRIVACY POLICY

A. ACCOUNT OPENING & MANAGEMENT

I/We hereby request and authorize you to:

1. Open an account in my/our names; and at any time subsequently, to open further accounts as I/we may direct.

2. Honour all withdrawal instruments which may be drawn on the said account, provided that such withdrawal instructions to the said account (whether the account is in credit or overdrawn or may become overdrawn in consequence of such withdrawal) are without prejudice to the Bank's right to refuse to allow any overdraft, and in consideration of this, I/we agree:

• 1. to assume full responsibility for the genuineness, correctness and validity of endorsements appearing on all documents deposited in my/our account(s)
• 2. to be bound by the Bank's rules for the conduct of the account(s), receipt of which I/we hereby acknowledge
• 3. to free the Bank from responsibility or liability for any loss or damage to funds deposited with the Bank due to any future government order, law, levy, tax, embargo, or such other causes beyond the Bank's control
• 4. that all funds standing to my/our credit are payable only in the currency as may be in circulation in Nigeria at any given time
• 5. to be bound by any notification of change in conditions governing the account(s) or information relating thereto, directed to my/our last known physical or e-mail address. I/We hereby agree that any mail sent to my/our last known physical or e-mail address shall be considered duly delivered and received by me/us at the time it is delivered at such last known address.
• 6. that the Bank will not in any way whatsoever be liable for funds handed by me/us, or my/our representative(s) to members of staff, or persons purporting to be members of staff outside banking hours or outside the Bank's premises
• 7. that the Bank's statement(s) on my/our account(s) shall be sent to the e-mail address I/we supplied and from time to time, such other information relevant to the account may be sent to the mobile telephone number I/we supplied
• 8. that interest will be paid on deposits in my/our savings account at the Bank's ruling rates and subject to prevailing conditions
• 9. that I/we would promptly and clearly communicate any changes to my/our details to the Bank in writing immediately the changes occur
• 10. not to use my/our account(s) as a medium for fraud, or to convert funds belonging to other persons
• 11. to honour all cheques or other orders which may be drawn on my/our current account, provided that such cheques or orders to the said account (whether such account is in credit or overdrawn or may become overdrawn in consequence of such debit) shall be without prejudice to the Bank's right to refuse or allow any overdraft or increase in overdraft on the account
• 12. that if any cheque credited into my/our account(s) is/are returned dishonoured, the Bank may notify me/us through my/our telephone numbers or e-mails
• 13. that my/our attention has been drawn to the necessity of safeguarding my/our cheque book, debit card, credit card, other bank instruments, personal identification number (PIN) and codes so that unauthorised persons are unable to gain access to them. I/We hereby agree that my/our failure to protect any of these information, or neglect of this precaution in whatsoever way may be grounds for any consequential loss being charged to my/our account
• 14. that the Bank is not under any obligation to honour any cheque(s) drawn on my/our account(s) unless there are sufficient funds to cover the value of the instrument (and any associated cost). I/ We also agree that any such instrument may be returned to me/us unpaid, but, if paid notwithstanding the insufficiency of funds, I/we are obliged to repay the Bank any outstanding sum on my/our account in addition to charges and interest accrued thereon
• 15. that any sum standing to the debit of my/our account shall be liable to interest charges at the rate fixed by the Bank from time to time. The Bank is authorized to debit from the account the usual banking charges, interests, commissions, and any service charges set by the management from time to time
• 16. that in addition to any general lien or similar right to which the Bank may be entitled to by law as bankers, the Bank may at any time and without notice to me/us combine or consolidate all or any of my/our accounts without any liabilities to it, and set-off or transfer any sum or sums standing to the credit of any one or more of such accounts or any other credit, be it cash, cheques, valuables, deposits, securities, negotiable instruments or other assets belonging to me/us towards the satisfaction of any of my/our liabilities to any other account or in any other respect, whether such liabilities be actual or contingent, primary or collateral and several or joint
• 17. to comply with all rules and regulations issued by the Bank governing the use of electronic banking services which the Bank may from time to time offer and provide to me/us, in order to ensure banking convenience
• 18. to honour all online instructions to transfer funds from the said account to another account held by me/ us, or any other person, or to make payments for services, without prejudice to the Bank's right to refuse to allow any overdraft or increase in overdraft and without liability to the Bank for such transfer(s)
• 19. to Report any incidence of dishonoured/returned cheques to regulatory and/or law enforcement agencies as may be required by law or regulations from time to time
• 20. that Wema Bank/ALAT have the right to apply restrictions to my/our account and report to appropriate law enforcement agencies if a fraudulent activity is associated with the operation of my/our account.
• 21. my/our (Authorised Signatory)’s successful Facial Biometric Data verification serves as my/our valid mandate/authorisation upon which Wema Bank/ALAT may validly rely to carry out of my/our instructions on my/our account and I/we hereby waive any right to dispute the validity of any access granted or action carried by Wema/Alat on my/our account(s) in reliance of a successful facial biometric data verification.
• 22. that my/our account profile comes with a free Virtual Card. I/we agree and authorise Wema Bank/ALAT to issue the virtual card and share necessary data with Card Schemes, Payment Processors, and regulators for card operations, including cross-border data transfers where required. Furthermore, I/we understand that standard transaction charges and fees apply as per the Bank's Guide to Charges shall apply to the use of the free virtual card.
• 23. agree to be bound by the Bank's rules, safeguards, and all instruments (including Virtual Card details, PINs, and OTPs), and to promptly notify the Bank of any changes to my/our details or suspected compromise.

B. ELECTRONIC BANKING TRANSACTIONS

The Customer hereby confirms and agrees that the following terms and conditions shall govern his/her electronic banking transactions with WEMA Bank Plc ("the Bank"):

1. INTERPRETATION

• 1.1 Service means the electronic banking services of the Bank, including: mobile banking, secure message facility, and bills payment services.
• 1.2 Login Password means the enabling code with which the Customer accesses the system and which is known only to the customer.
• 1.3 Transaction Personal Identification Number ("PIN") means the enabling code with which the Customer can pay bills, transfer or move fund from one account to the other, and authorize several processes and transactions.
• 1.4 Account means a current or savings account or other account maintained by the Customer with the Bank at any of the Bank's branches in Nigeria
• 1.5 Mailing Address means the Customer's mailing address in the Bank's records.
• 1.6 Instruction means the Customer's request to the Bank for the Services.
• 1.7 Switch means an online electronic transaction processing payment infrastructure that connects different payment channels to the payment processors and enablers.
• 1.8 One Time Password ("OTP") means the second factor enabling code with which the Customer can authorize transactions and processes. This can be sent to customer's telephone number, email or gotten from a hardware token.
• 1.9 Facial Biometric Data means the unique physiological characteristics of the Customer's face captured via digital imaging, processed into a secure mathematical template, and used for identity verification, authentication, and consent recording.
• 1.10 Virtual Card means the complimentary digital payment card (NGN denominated) issued by the Bank, linked to the Customer's account, accessible via the ALAT platform, and usable for online and contactless transactions.
• 1.11 Biometric Consent means the Customer's explicit authorization whereby the successful capture and verification of Facial Biometric Data constitutes the Customer's electronic signature and binding acceptance of this Agreement.
• 1.12 ALAT Platform or “the Platform” means the mobile application, web portal, and associated digital channels provided by Wema Bank Plc.

2. SCOPE AND MODE OF SERVICE

2.1 The Service allows the Customer to give the Bank instructions by use of a username, login password, security answer to predefined questions, and a transaction PIN (individual and collectively, "Account Security Details") for the following:

• 2.1.1 to obtain information regarding Customer's balance as at the last date of business with the Bank;
• 2.1.2 to obtain information with regards to any instrument in clearing or any credit standing in the Customer's account as at the last date of transaction on the Customer's account;
• 2.1.3 to authorize the Bank to debit the Customer's account to pay utility bills such as NITEL, PHCN, DSTV, water rate and/or any other bills as may be specified by the Customer, subject however to availability of such bill payment under this service;
• 2.1.4 to authorize the Bank to effect transfer of funds from the Customer's account to any other account with the Bank or outside the Bank;
• 2.1.5 to authorize the Bank to effect a stop payment order on any previously authorized transaction;
• 2.1.6 to authorize the Bank to effect any other transaction offered by the Bank on its electronic banking services platform.

2.2 On receipt of instructions, the Bank will endeavor to carry out the Customer's instructions on a best effort basis, excepting all or any unforeseen circumstances such as act of God, force majeure, and other causes beyond the Bank's control.

2.3 For the service to be available to any Customer, he/she must have any one or a combination of the following: (i) an account with the Bank; (ii) a user name, login password, security answer, transaction PIN and one time password (OTP); (iii) a computer, smartphone, tablet and other similar devices; (iv) a functional e-mail address, phone number, and date of birth.

3. USE AND PROTECTION OF ACCOUNT SECURITY DETAILS

3.1 The Customer understands that his/her Account Security Details is used to give instructions to the Bank and accordingly undertakes that under no circumstance shall any part of the Account Security Details be disclosed to anybody. The Customer further undertakes to memorize the Account Security Details and not to reproduce or store any part of the Account Security Details in any accessible place or manner, or in any recognizable form, or on any other item carried along with the internet services to prevent access to same by a third-party.

3.2 The issuance of any instruction with any component of the Account Security Details shall be sufficient confirmation of the authenticity of the instruction given, and the Bank shall, without more, assume that the instructions were issued by the Customer and shall be entitled to rely on same to effect the instruction.

3.3 The Customer undertakes to immediately change his/her Account Security Details upon reasonable suspicion of it becoming known to a third-party.

3.4 The Customer hereby indemnifies and exempts the Bank from any liability whatsoever for the Bank's compliance with any or all instruction(s) given by means of any of the Account Security Details, if by any means any part of the Account Security Details becomes known to a third-party or otherwise becomes compromised.

3.5 The customer shall be responsible for any instruction given with the use of any of the Account Security Details. Accordingly, the Bank shall not be responsible for any fraudulent, duplicate or erroneous instruction given by means of any of the Account Security Details.

4. CUSTOMER'S RESPONSIBILITY

4.1 The Customer undertakes absolute responsibility for safeguarding his/her Account Security Details, and undertakes not to disclose any part of the Account Security Details to any person under any circumstance.

4.2 The Bank is hereby exempted from any liability arising from unauthorized access to the Customer's account and/or data as contained in the Bank's records via the service, which arises as a result of inability and/or otherwise of the Customer to safeguard his/her Account Security Details; and/or failure to completely log out of a system, thereby allowing on screen display of his/her account information.

4.3 The Bank is further relieved of any liability as regards the occurrence of a breach of the Bank's duty of secrecy to the Customer by hackers and other unauthorized access to the Customer's account via the service which may arise from the Customer's failure or inability to protect his/her Account Security Details as required herein.

4.4 The Customer undertakes to change his/her Account Security Details immediately he/she has reason to believe that any part of it has become known to any third-party. The Customer agrees that he/she is under a duty to notify the Bank whenever he/she has reason to believe that any part of his/her Account Security Details has become known to any third-party.

4.5 Where a customer notifies the Bank of his intention to change his password, security answer and/or transaction PIN arising from either his loss of memory of same or that it has come to notice of a third party, the Bank shall with the consent of the customer, delete same and thereafter allow the customer to enter a new password, security answer and/or transaction PIN. Provided that the Bank shall not be responsible for any losses that occur between the period of such memory loss of the password, security answer and/or transaction PIN or knowledge of a third-party, and the time the report is lodged with the Bank.

4.6 The Customer shall be responsible for any fraud, loss and/or liability to the Bank or third-party arising from the use of any of the Customer's Account Security Details by a third party. Accordingly, the Bank shall not be responsible for any fraud that arises from the use of any of the Customer's Account Security Details.

4.7 Upon enrolment of a Customer for the service, the Bank may deduct applicable monthly/quarterly/annual fees and/or charges from the Customer's account, whether or not the Customer made use of the service during the period in question, provided that the Customer had activated his/her profile by accessing the system using his/her login credentials.

4.8 The Customer hereby:

• 4.8.1 undertakes to provide true, accurate, current and complete information about himself/herself as requested in the Bank's self-registration and account opening forms, and the Customer agrees not to misrepresent his/her identity or information.
• 4.8.2 undertakes not to use the service for illegal purposes or for the transmission of material that is unlawful, harassing, libelous (untrue and damaging to others), invasive of another's privacy, abusive, threatening, or obscene, or that infringe the right of others
• 4.8.3 acknowledges and agrees that the Bank owns all rights to the website(s) used to provide the service and the contents displayed on the website. The Customer is only permitted to use content on the website only as expressly authorized by the Bank. The Customer may not copy, reproduce, distribute, or create derivative work from content on the website without the written consent of the Bank. A violation of any of the above guidelines is grounds for discontinuation of the service by the Bank without notice to the Customer.
• 4.8.4 acknowledges that copyright in the pages of the self-registration and account opening forms, in screens displaying the pages, and in the information and material therein is owned by the Bank.

4.9 The Customer agrees that his/her or (their Authorised signatory’s) Facial Biometric Data constitute a valid means of authorisation for access to and the use of the services on the platform and hereby authorises Wema Bank/Alat to treat instructions authenticated/authorised via biometric data as genuine and authorized by the Customer. The Bank shall not be liable for any claims, losses or any liability howsoever arising from instructions/transaction carried out via biometric authorisation.

5. DISCLAIMER OF WARRANTIES

5.1 The customer expressly understands and agrees that use of the service is at his/her sole risk. The service is provided on an "as is" and "as available" basis. The Bank expressly disclaims all warranties of any kind, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement.

5.2 The Bank makes no warranty that:

• 5.2.1 the service will meet the Customers' requirements;
• 5.2.2 the service will be uninterrupted, timely, secure, or error-free;
• 5.2.3 the results that may be obtained from the use of the service will be accurate or reliable when data source is from a 3rd party outside ALAT or Wema Bank Plc
• 5.2.4 the quality of any product, service, information or other material purchased or obtained by the Customer through the service will meet his/her expectations;
• 5.2.5 any error in the technology will be corrected.

6. LIMITATIONS OF LIABILITY

6.1 The Customer agrees that the Bank will not be liable for any act, omission or damage, whether direct, indirect, incidental, special, consequential or exemplary damages, including but not limited to damages for loss of profits, goodwill, or other intangible losses, even if the Bank had been advised of the possibility of such damages, resulting from: (i) the use of, or the inability to use the service; (ii) the cost of getting substitute service due to the failure of any product, data, messages, or information purchased, obtained, or received from the service; (iii) unauthorized access to, or alteration, or transmission of data by third-parties; (iv) statements or conduct of anyone on the service; (v) any other matter relating to the service.

6.2 Under no circumstances will the Bank be liable for any damages, including without limitation: direct, indirect, special, incidental or consequential damages, losses or expenses arising in connection with the use or inability to use this service by any party, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation, transmission, computer virus or line or system failure, even if the Bank or its representatives thereof are advised of the possibility of such damages or losses.

6.3 Any material downloaded or otherwise obtained through the use of the service is done at the Customer's own discretion and risk and the Bank shall not be responsible for any damage to the Customer's computer system or loss of data that results from the download of any such material. No advice or information, whether oral or written, obtained by the Customer from the service will create any warranty not expressly stated in these terms.

6.4 The Bank shall not be responsible for any electronic virus or viruses that the Customer may encounter in course of making use of this service.

7. INDEMNIFICATIONS

Except when caused by the Bank's intentional misconduct or gross negligence, the Customer agrees to protect and fully compensate the Bank and its affiliates and service providers from any/and all third party claims, liabilities, damages, expenses and costs (including, but not limited to, legal fees) caused by or arising from the Customer's use of the service, violation of the terms or infringement, by any other user of the Customer's account, or any intellectual property or other right of anyone.

7.1 I/We agree to process transactions initiated via ALAT app with the sole use of my/our transaction PIN. I/We hereby fully indemnify the Bank, its directors, agents, privies, assigns, successors, employees, or any other person whomsoever acting under the Bank's authority or control against any costs, losses, damages, litigation, action, proceeding, expenses (including Attorney fees), judicial awards of any kind, or any payments of whatsoever nature made or any cost however incurred, whether directly or indirectly, remotely or otherwise, resulting from the Bank processing such Transactions.

I/We acknowledge and recognize that my transaction PIN is the last security check for effecting my Transactions on the ALAT platform. I/We undertake to be fully and solely responsible for all risks that may arise from the Transactions as well or together with all losses which may be suffered by me/us as a result of any unauthorized transfer of monies or other Transactions in my account as a result of the use of my/our transaction PIN on the Bank's Mobile Banking Platform.

Furthermore, I/We hereby acknowledge and consent that the Bank would not be liable for any loss, fraudulent or unauthorized transfer of monies, that may occur on my/our account as a result of the Bank processing Transactions consummated on my/our account through the ALAT app.

I/We hereby irrevocably and unconditionally agree that in addition to any general lien or right to which the Bank may be entitled to by law as bankers, the Bank may at any time and without notice to me/us combine or consolidate all or any of my/our accounts without any liabilities to it, and set-off or transfer any sum or sums standing to the credit of any one or more of such accounts or any other credit, be it cash, cheques, valuables, deposits, securities, negotiable instruments or other assets belonging to me/us towards the satisfaction of any of my/our liabilities to the Bank, or of any claim made against the Bank, or loss suffered by the Bank as a result of or pursuant to the Bank processing such Transactions, whether such liabilities be actual or contingent, primary or collateral and several or joint.

My/Our obligation herein shall not be reduced by any claim by me/us against the Bank, its Directors, agents, privies, assigns, successors, employees, or any person whomsoever acting under the Bank's authority.

This indemnity shall be continuing obligation in respect of any and all matters connected to or arising from the Bank processing such Transactions.

8. SERVICE CHANGES AND DISCONTINUATION

The Bank reserves the right to change or discontinue, temporarily or permanently, the service at any time without notice. In order to maintain the security and integrity of the service, the Bank may also suspend the Customer's access to the service at any time without notice. Customer agrees that the Bank will not be liable to the Customer or any third party for any modification or discontinuation of the service.

9. MISCELLANEOUS

9.1 The Bank shall not be considered an agent or legal representative of the Customer or any other party for any purpose by reason of this Agreement. The relationship between the Bank and the Customer shall not be deemed to create any association, partnership, joint venture, or relationship of principal, agent or master and servant, employer or employee between the parties and nothing contained in this Agreement shall be so construed.

9.2 This Agreement cannot be amended by the Customer, nor shall any of the Bank's rights be waived unless the Bank communicates such waiver to the Customer in writing.

9.3 This Agreement is personal to the Customer and the Customer may not assign its rights and obligations herein to anyone without written consent of the Bank.

9.4 All notices to the customer shall be in writing via any of the addresses (e-mail or contact) provided to the Bank.

9.5 If any of these terms is held to be unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties with other provision remaining in full force and effect.

9.6 The laws of the Federal Republic of Nigeria shall apply to this Agreement.

C. DATA PRIVACY CONSENT

I/We hereby consent to Wema Bank/ALAT collecting, processing, storing, and managing my/our personal data (including but not limited to Biometrics, Bank Verification Number (BVN), National Identification Number (NIN), contact details, and financial records) for the purposes of account opening, management, transaction processing, and regulatory compliance.

I/We hereby consent to Wema Bank/ALAT collecting, and processing my/our device’s location data. This data is utilized strictly for the purposes of Fraud Prevention and Security, Location-Based Services and Regulatory Compliance.

I/We acknowledge that my/our data may be shared with licensed credit bureaus, payment service providers, switches, regulatory bodies (such as the CBN, NDIC, EFCC), and law enforcement agencies as required by law or for the provision of banking services.

I/We understand that my/our data will be retained for the duration of the account relationship and thereafter in accordance with applicable laws and regulatory mandates (e.g., CBN Anti-Money Laundering directives).

I/we acknowledge that my/our personal data may be processed outside the geographical jurisdiction of Nigeria and hereby grant Wema Bank/Alat our consent for the processing of my/our personal data outside the geographical jurisdiction of Nigeria

I/We acknowledge that I/we have the right to request access to, update, or correct my/our personal data, subject to prevailing regulatory requirements. I/We may also request the deletion of my/our data, provided there are no outstanding legal or regulatory obligations requiring its retention.

I/We confirm that I/we have read, understood, and agree to the Wema Bank/ALAT Data Privacy Policy available on the Bank’s website and mobile application.

I/we agree to receive marketing communications regarding Wema/ALAT products via, Email, SMS, Push Notification. I understand I can withdraw this consent at any time.

I/We acknowledge that I/We have received, read, and understood the Wema Bank/ALAT Data Privacy Policy. I/We consent to the processing of my personal data in accordance with the Policy