West Vigo Trust Bank

🔒 Our Commitment to Your Privacy & Security

At West Vigo Trust Bank, protecting your personal and financial information is our highest priority. We are committed to maintaining the confidentiality, integrity, and availability of your data through industry-leading security measures, strict internal policies, and full compliance with UK data protection laws. This Privacy and Security Statement explains how we collect, use, share, and protect your information when you bank with us.

We operate in full compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR). Our security framework is aligned with the standards set by the Financial Conduct Authority (FCA), the Prudential Regulation Authority (PRA), and the National Cyber Security Centre (NCSC).

📋 What Information We Collect

We collect and process personal information necessary to provide you with banking services, comply with legal obligations, and improve our products. This includes:

• Identity Information: Full name, date of birth, national insurance number, passport or driving licence details, and proof of address.
• Contact Information: Email address, phone number, and postal address.
• Financial Information: Account balances, transaction history, credit history, income details, and investment holdings.
• Technical Information: IP address, device identifiers, browser type, and login timestamps for security monitoring.
• Communication Records: Call recordings (for quality and training), email correspondence, and secure messages sent through our online banking platform.

We collect this information directly from you when you open an account, apply for a product, use our services, or contact our support team. We may also receive information from credit reference agencies (CRAs) and fraud prevention agencies as permitted by law.

⚙️ How We Use Your Information

Your personal data is used only for legitimate banking purposes, including:

• Managing and administering your accounts and transactions.
• Processing loan, mortgage, and credit applications, including credit checks.
• Detecting, investigating, and preventing fraud, money laundering, and other financial crimes.
• Complying with legal and regulatory obligations (e.g., anti-money laundering, sanctions screening).
• Communicating with you about your accounts, service updates, and important security notices.
• Improving our products, services, and website functionality through analytics (anonymised where possible).
• Providing you with relevant offers and marketing communications (you may opt out at any time).

We never sell your personal data to third parties. Any sharing of information is done strictly under legal obligations or with your explicit consent.

🤝 When We Share Your Information

West Vigo Trust Bank shares your personal data only in limited circumstances:

• Credit Reference Agencies (CRAs): To assess creditworthiness, verify identity, and prevent fraud. We share data with Experian, Equifax, and TransUnion UK.
• Fraud Prevention Agencies: To detect and prevent financial crime. Information may be retained by these agencies for up to six years.
• Regulatory and Law Enforcement: When required by law, court order, or regulatory request (FCA, PRA, HMRC, National Crime Agency).
• Service Providers: Trusted third parties who process data on our behalf (e.g., card processors, IT hosting, print/mail providers). These parties are bound by strict data protection contracts.
• With Your Consent: Any other sharing will only occur with your explicit permission.

We do not transfer your personal data outside the United Kingdom unless adequate safeguards are in place, such as UK adequacy regulations or standard contractual clauses.

📜 Your Rights Under UK GDPR

You have the following rights regarding your personal data. All requests are free of charge and will be responded to within 30 days.

• Right to Access: Request a copy of the personal data we hold about you (Subject Access Request).
• Right to Rectification: Correct inaccurate or incomplete information.
• Right to Erasure (Right to be Forgotten): Request deletion of your data where no legal obligation to retain it exists.
• Right to Restrict Processing: Limit how we use your data in certain circumstances.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Object: Object to processing for direct marketing or legitimate interests.
• Rights Related to Automated Decision-Making: Request human intervention for automated credit decisions.

To exercise any of these rights, please contact our Data Protection Officer (DPO) at dpo@westvigo.com or by post at the address above. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk.

🛡️ How We Keep Your Money and Data Safe

West Vigo Trust Bank employs multiple layers of security to protect your accounts:

• Strong Customer Authentication (SCA): Required for all electronic payments and sensitive account actions under PSD2.
• Biometric Login: Fingerprint and facial recognition available on our mobile banking app.
• Real-Time Alerts: Instant SMS, email, or push notifications for transactions over £100, failed login attempts, and profile changes.
• Card Lock/Unlock: Instantly disable your debit or credit card from mobile banking if lost or stolen.
• Secure Messaging: All communication through online banking is encrypted and audited.
• Regular Security Audits: Independent penetration testing and vulnerability assessments conducted quarterly.
• Employee Training: Mandatory data protection and cybersecurity training for all staff, refreshed annually.

🍪 Cookies & Online Tracking

Our website and online banking platform use cookies to enhance your experience, remember your preferences, and analyse site traffic. We use the following types of cookies:

• Strictly Necessary Cookies: Required for core functionality (login, security, session management). Cannot be disabled.
• Functional Cookies: Remember your preferences (language, region).
• Analytics Cookies: Help us understand how visitors use our site (anonymised data via Google Analytics).
• Marketing Cookies: Used only with your explicit consent for personalised advertising.

You can manage your cookie preferences through our cookie consent banner or your browser settings. Disabling certain cookies may affect website functionality.

⏱️ How Long We Keep Your Data

We retain your personal data only as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, and regulatory requirements. Typical retention periods:

• Account and transaction data: 7 years after account closure (per UK tax and anti-money laundering laws).
• Loan and mortgage records: 7 years after full repayment or account closure.
• Marketing consents: Until you withdraw consent, plus 2 years.
• Call recordings: 6 months for general enquiries, 7 years for complaints or disputed transactions.

After the retention period, your data is securely deleted or anonymised for analytical purposes.

🚨 What to Do If You Suspect Fraud or a Security Issue

If you believe your account has been compromised, you have received a suspicious communication claiming to be from West Vigo Trust, or you notice unauthorised transactions:

1. Call us immediately: 00 44 7774 007744 (24/7 fraud hotline).
2. Lock your cards: Use mobile banking or call the number above.
3. Change your online banking password: Do this from a trusted device.
4. Report to Action Fraud: The UK's national fraud reporting centre at www.actionfraud.police.uk or call 0300 123 2040.

Remember: West Vigo Trust Bank will never call, text, or email you asking for your full PIN, password, or to move money to a "safe account". If in doubt, hang up and call us back on a number you trust.

👶 Children's Privacy

Our student and young adult accounts (ages 13-17) require parental or guardian consent. We do not knowingly collect personal data from children under 13 without verifiable parental consent. For accounts held by minors, parents have access rights and can review transaction history.

📅 Updates to This Privacy & Security Statement

We may update this statement periodically to reflect changes in legal requirements, our services, or security practices. The "Last Updated" date at the bottom of this page indicates when changes were made. Material changes will be communicated to you via email or a prominent notice on our website. We encourage you to review this page regularly.

📬 Contact Our Data Protection Officer

If you have any questions about this Privacy & Security Statement, or wish to exercise your data protection rights, please contact:

Data Protection Officer
West Vigo Trust Bank
125 Princes Street, Edinburgh EH2 4AD, Scotland, United Kingdom
Email: dpo@westvigo.com
Phone: 00 44 7774 007744 (ask for Data Protection Office)

For general enquiries, please email contact@westvigo.com.