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Pearl Bank App – Privacy Policy

Last Updated: 17 November 2025
Effective Date: 17 November 2025

This Privacy Policy describes how Pearl Bank Uganda Limited (“Pearl Bank”, “we”, “us”, or “our”) collects, uses, discloses, and protects your information when you use the Pearl Bank Mobile application (the “App”) and related services.

By downloading, installing, registering on, or using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you disagree, please do not use the App.


1. Who We Are

Pearl Bank Uganda Limited is a licensed financial institution regulated by the Bank of Uganda. We provide banking and financial services, including mobile banking, through the Pearl Bank Mobile App.

If you have any questions about this Privacy Policy or how we handle your data, please get in touch with us:

  • Legal Name: Pearl Bank Uganda Limited

  • Registered Address: Plot 4/6 Nhrumah Road, Kampala, Uganda.

  • Telephone: +256 800 217200

  • Email: customerservice@postbank.com

  • Website: www.pearlbank.co.ug


2. Scope of This Policy

This Privacy Policy applies to:

  • The Pearl Bank Mobile App downloaded from Google Play Store (and any other official distribution channel we may add), and

  • Any related features, services, and digital channels that link to or reference this Privacy Policy.

It does not apply to:

  • Third-party websites, apps, or services that are not controlled by Pearl Bank, even if accessed via links from within the App.

  • Services provided by third parties under their own privacy policies.


3. Information We Collect

We collect information to provide secure banking services, comply with legal and regulatory obligations, and improve our products. Depending on how you use the App, we may collect the following categories of information:

3.1 Information You Provide Directly

a) Registration & Profile Information

  • Full name

  • Mobile phone number

  • Email address

  • Date of birth

  • National ID / Passport number or other identification numbers

  • Customer / account numbers

  • Username and security credentials (e.g., PIN, passwords – stored in encrypted form)

  • Contact address and other profile information

b) Banking & Transaction Information

Through the App, we may collect and process:

  • Account numbers and account types

  • Transaction details (amount, date, time, beneficiary, description)

  • Bill payments, airtime purchases, merchant payments, and transfers

  • Loan applications, balances, and repayment history

  • Card details (to the extent necessary – we do not store full card PAN and CVV in plain text)

c) Customer Support & Communication

  • Information you provide when contacting support (via in-app chat, phone, email, or branch)

  • Feedback, complaints, and survey responses

  • Call recordings (where applicable and permitted by law)


3.2 Information Collected Automatically

When you use the App, we may automatically collect certain information from your device:

a) Device & Technical Information

  • Device model, manufacturer, operating system and version

  • Unique device identifiers (e.g., IMEI, Android ID, device ID)

  • Mobile network information (e.g., carrier, network type)

  • IP address

  • App version, language, and time zone

  • Log data (e.g., access dates/times, features used, system activity, error reports, performance diagnostics)

b) Usage Information

  • Features and screens accessed within the App

  • Frequency and duration of App sessions

  • Clicks, navigation paths, and interactions

This information helps us secure the App, detect fraud, and improve performance and user experience.


3.3 Location Information

Depending on your settings and explicit permissions, we may collect:

  • Approximate location (network-based)

  • Precise location (GPS or similar technologies) – only where necessary for security, regulatory, or service features (e.g., branch/ATM finder, fraud monitoring, risk-based authentication).

You can control location permissions in your device settings. However, restricting location access may limit certain App functionalities.


3.4 Contacts & Other Sensitive Permissions (If Applicable)

If the App includes features that request special permissions, we will always request your explicit consent via system prompts:

  • Contacts – e.g., to allow you to select beneficiaries from your contact list when sending money.

  • Camera – e.g., to scan QR codes, capture documents or perform facial verification.

  • Storage / Photos / Media / Files – e.g., to upload documents for KYC or support.

  • Microphone – e.g., for certain support channels or voice-based features.

We will only access these data types for the specific purpose explained in the permission request.


3.5 Cookies and Similar Technologies

When accessing our online services through web views or related platforms, we may use cookies, SDKs, and similar technologies to:

  • Authenticate you

  • Remember your preferences

  • Analyse App usage and performance

  • Improve security

You may control cookie settings through your browser or device, but disabling them may impact functionality.


4. Why We Collect Your Information (Legal Bases / Purposes)

We use your information for the following purposes, based on one or more legal grounds such as: performance of a contract, compliance with law, legitimate interests, and your consent (where required by law).

4.1 To Provide and Operate the App and Banking Services

  • Register and verify your identity as a Pearl Bank customer

  • Enable login, authentication, and authorisation

  • Provide account viewing, transfers, payments, and other mobile banking features

  • Process your transactions and instructions

  • Maintain and administer your accounts and relationships with the Bank

4.2 To Secure the App, Your Accounts, and Our Systems

  • Prevent, detect, and investigate fraud, cyber-attacks, and unauthorised access

  • Monitor transactions for suspicious activity and regulatory compliance

  • Implement multi-factor authentication and risk-based security checks

  • Maintain logs and audit trails for security and compliance purposes

4.3 To Comply with Legal and Regulatory Obligations

  • Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) checks

  • Know Your Customer (KYC) obligations

  • Regulatory reporting to authorities (e.g., Bank of Uganda and other competent regulators)

  • Responding to lawful requests (e.g., court orders, law enforcement)

4.4 To Improve, Personalise and Develop Our Services

  • Analyse usage trends to enhance features, user experience, and performance

  • Conduct analytics and research to improve products and services

  • Develop new features and offerings

  • Conduct service quality monitoring and training

4.5 To Communicate with You

  • Send service-related notifications (e.g., OTPs, alerts, confirmations)

  • Notify you about changes to our terms, policies, or security updates

  • Respond to your inquiries and support requests

  • Send transactional and relationship-based messages

4.6 Marketing & Promotional Communications (If/When Applicable)

Subject to your consent, where required by law, we may:

  • Inform you about new products, promotions, or special offers

  • Send targeted communications based on your use of our products and services

You can opt out of marketing communications at any time by using the unsubscribe options in the message or contacting us through our support channels. However, we will still send service-critical and transactional messages.


5. How We Share Your Information

We do not sell your personal data. We may share your information with:

5.1 Within Pearl Bank Group

  • Our branches, departments, and affiliated entities, where necessary to provide our services, manage risk, and comply with regulations.

5.2 Service Providers and Contractors

We may share information with trusted third-party providers who perform services on our behalf, such as:

  • IT infrastructure, hosting, and cloud service providers

  • Payment processors, card schemes, and switch providers

  • SMS/USSD and email gateway providers

  • Customer support tools and call centers

  • Analytics, security, and fraud detection service providers

These providers are bound by contractual obligations and are required to protect your information and use it only for the purposes we specify.

5.3 Regulators, Authorities, and Legal Requirements

We may disclose information where required to:

  • Comply with the law, regulations, or legal processes

  • Respond to lawful requests from public authorities, regulators, law enforcement, or courts

  • Protect the rights, property, or safety of Pearl Bank, our customers, or the public

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of the transaction, subject to continued protection consistent with this Privacy Policy.


6. International Data Transfers

Where personal data is transferred outside Uganda (or outside your jurisdiction), we will ensure that:

  • The receiving country has adequate data protection laws; or

  • Appropriate safeguards (such as contractual clauses) are in place to protect your data; and

  • Transfers are done in compliance with applicable data protection and banking regulations.


7. Data Retention

We retain your information for as long as necessary to:

  • Provide the App and related services

  • Fulfil the purposes described in this Privacy Policy

  • Comply with legal, regulatory, accounting, and reporting obligations

  • Resolve disputes and enforce agreements

Retention periods may be determined by laws and regulations applicable to financial institutions. When data is no longer needed, we will securely delete, anonymize, or archive it.


8. Data Security

We take security seriously and implement appropriate technical and organisational measures to protect your information, including but not limited to:

  • Encryption of data in transit and at rest, where appropriate

  • Strong authentication and access controls

  • Network and application security controls

  • Security monitoring, logging, and incident response procedures

  • Regular security assessments and compliance with recognised information security standards

However, no system is completely secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for:

  • Keeping your device secure and updated

  • Keeping your PINs, passwords, and OTPs confidential

  • Informing us promptly if you suspect any unauthorised access or compromise


9. Your Rights and Choices

Subject to applicable laws and regulations, you may have the following rights regarding your personal data:

  • Right to access – Request confirmation that we hold your personal data and obtain a copy.

  • Right to rectification – Request correction of inaccurate or incomplete data.

  • Right to erasure – Request deletion of your data where legally permissible (e.g., where it is no longer needed for the purposes for which it was collected).

  • Right to restriction of processing – Request that we limit how we use your data in certain circumstances.

  • Right to object – Object to processing based on our legitimate interests or for direct marketing.

  • Right to data portability – Where applicable, request a copy of your data in a commonly used, machine-readable format to transfer to another service provider.

  • Right to withdraw consent – Where processing is based on your consent, you may withdraw your consent at any time (without affecting prior lawful processing).

To exercise any of these rights, please get in touch with us using the details in Section 1. We may need to verify your identity before we can respond to your request. We may not always be able to comply with legal or regulatory obligations that require us to retain or continue processing specific data.


10. Children’s Privacy

The App and our services are not intended for children under the age of 18 unless they are customers under products specifically designed and approved by the Bank, and subject to appropriate consent from a parent or legal guardian in line with applicable law.

We do not knowingly collect personal data from children without such consent. If you believe that a child has provided us with personal data without the necessary consent, please contact us so that we can take appropriate action.


11. Third-Party Links and Services

The App may contain links to third-party websites, apps, or services that are not operated or controlled by Pearl Bank. We are not responsible for the privacy practices of these third parties.

We encourage you to review the privacy policies of any third-party services you access.


12. Permissions Used by the App (Google Play Disclosure)

For transparency, the App may request the following Android permissions (actual list may vary based on your App’s features; adjust accordingly):

  • PHONE / DEVICE ID – For device binding, fraud prevention, and security checks.

  • LOCATION (Approximate / Precise) – For security, risk-based authentication, and optional services such as nearby branch/ATM locator.

  • CONTACTS – To allow you to select beneficiaries from your contact list for transfers (if this feature is enabled).

  • CAMERA – To scan QR codes, capture documents, or enable biometric verification.

  • STORAGE / PHOTOS / MEDIA / FILES – To upload or store documents for KYC and support, and to cache app content.

  • BIOMETRICS (Fingerprint/Face) – To enable biometric login and transaction authorisation on supported devices, where you activate this feature.

We will request your consent for these permissions via the standard Android permission prompts. You may revoke permissions at any time via your device settings, though this may affect certain functionalities.


13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

  • Our services

  • Legal or regulatory requirements

  • Industry best practices

When we make material changes, we will:

  • Update the “Last Updated” date at the top of this Policy, and

  • Notify you via the App, our website, or other appropriate channels.

Your continued use of the App after changes take effect will constitute your acceptance of the updated Privacy Policy.


14. How to Contact Us or Lodge a Complaint

If you have any questions, concerns, or complaints regarding this Privacy Policy or our handling of your information, please contact us:

  • Email: customerservice@pearlbank.com

  • Telephone: +256 800 217200

  • Postal Address: P.O Box 7189 Kampala, Uganda

If you are not satisfied with our response, you may have the right to complain to the relevant data protection or financial services regulator in your jurisdiction.