This document is in review. It is published for reference and is not yet the operative version. For the terms currently governing your relationship with the Bank, contact legal@centruebank.com.
Introduction
Centrue Private Bank Limited ("CenTrue", "the Bank", "we", "us" or "our") takes the privacy of its site visitors, users and clients very seriously, and ensures that their personal information and confidential information are securely stored. This notice applies to the legal entities that provide CenTrue services under the CenTrue name.
This Privacy Policy is intended to help you understand what data we collect, why it is collected, and what we do with your data. The information collected is used to verify your identity, to meet our legal and regulatory obligations, to understand our clients' requirements and eligibility for the Bank's products and services, and to allow us to provide a better service to our clients.
From the moment you access our website you agree to this Privacy Policy. It is your responsibility to read, understand and agree to the terms set out in this document, and to consent to the use of your data as described. For any questions or concerns regarding this Privacy Policy, contact us at legal@centruebank.com, and refrain from using our website in the meantime.
Please be aware that, while this Privacy Policy sets out our approach to your personal data, you may have different rights under the data protection legislation that applies to you — including the data protection laws of Saint Christopher and Nevis, the General Data Protection Regulation (EU) 2016/679 ("GDPR") for clients in the European Economic Area, the UK Data Protection Act 2018 for clients in the United Kingdom, and any other legislation applicable to CenTrue's services in the relevant jurisdiction.
1. Information We Collect from You
We collect your personal information and confidential information in order to provide you with our services and to meet our regulatory obligations. When you apply for a CenTrue account, you provide us with personal information, including but not limited to your name, email address, date of birth, and bank account information.
1.1. Registration and onboarding information
We collect information when you apply for a CenTrue account. Depending on how you intend to use your account, we may ask you to provide some or all of the following: bank account numbers, payment card details and relevant expiry dates, telephone number, date of birth, identity document number, photographs of identity documents, a photograph of the individual applying, a video recording of the individual applying, occupation or industry, the purpose of the account, source of wealth and source of funds documentation, tax residence and taxpayer identification numbers, and transaction information.
The same documents may be requested from the individual representatives of an applying legal entity, and from directors, shareholders, ultimate beneficial owners, settlors, protectors, trustees and beneficiaries where applicable. We may also request additional information as part of our verification and ongoing monitoring process.
1.2. Additional information
We may request further details, or ask you to answer further questions, in order to verify your information. We may also obtain additional information about you from third parties, including third-party partners, credit reference agencies, sanctions and adverse-media screening providers, and public registers. This information includes information about your bank accounts or payment methods issued by third-party financial institutions that are linked to your CenTrue products. We also collect information about which pages you visit on our site, your browser information, your location, and the frequency of your use of our site.
1.3. Transaction information
Information about your transactions is collected and reviewed, including but not limited to: date, time, amount, currency, devices associated with the transaction, IP address of sender and receiver, the sender's name and registration information, the receiver's name and registration information, messages sent or received with the payment, the device information used to facilitate the payment, and the payment instrument used.
1.4. Corporate, trust and entity clients
We gather, use, and may disclose data relating to our corporate, trust and entity client accounts. When such a client applies for a CenTrue account, it is required to provide information about its structure and activities in order for us to perform the relevant credit, risk and financial-crime assessments. This includes collecting information about the entity's key controllers, directors, partners, shareholders, ultimate beneficial owners and, in the case of trusts and foundations, its settlor, protector, trustees and beneficiaries, together with confidential information.
CenTrue shall use your confidential information only for the purposes of the evaluation set out in the Terms and Conditions and this Privacy Policy, and not for any other commercial or operational purpose, nor in connection with any similar project undertaken by it, nor in any manner detrimental to you, your affiliates, or their respective representatives. In addition to these specific obligations, CenTrue shall protect and safeguard your confidential information with at least the same degree of care with which it protects and safeguards its own confidential information.
By accepting the Terms and Conditions and this Privacy Policy, you also agree that you shall not use or disclose CenTrue's confidential information other than in the way CenTrue uses or discloses your confidential information.
This information is used to verify our clients and their key controllers. This includes verifying certain data provided by our clients and reviewing their eligibility to use our products and services. Third-party partners may be used to validate the information provided at account application.
CenTrue reserves the right to review client accounts periodically. This may involve requesting a credit reference from a credit or fraud agency in respect of any account. As part of such a review, CenTrue reserves the right to close an account on the basis of the information found.
For certain entity accounts, we may collect information about the client's business and online profile in order to review its size, client base, and expected transactional activity.
1.5. Maintaining updated information
In addition to the information provided when you apply for your account, we also collect information we receive from you as a result of your use of our services. This allows us to verify your identity periodically and to monitor activity in order to meet our regulatory obligations and provide better client service. The information collected includes but is not limited to: log-in details, location information, device information, transaction information, third-party information, identity information, and cookies.
2. Use of Personal Information and Retention
Registration information is used to verify your identity. This includes verifying certain data provided by you and reviewing your eligibility to use our products and services. We use the information we collect about you to provide you with the products we offer, to notify you about changes to our products, and to improve our products.
Transactional information is retained in order to maintain our service levels and to meet regulatory requirements. This includes checks in relation to anti-money laundering, counter-terrorist financing, know-your-client, sanctions and politically-exposed-person requirements, and any other checks that CenTrue is obliged to conduct having regard to the jurisdiction and category of the services provided.
Unless otherwise stipulated in this Privacy Policy, or where a regulatory or legal requirement exists, CenTrue will delete your personal information when your relationship with CenTrue ceases.
2.1. Internal use
By using our website and our services, you consent to our collecting, retaining and using your information. Examples of how we may use your information include:
- to develop a more usable site with tailored functionality;
- to provide you with tailored information regarding our products and services;
- to analyse client support interactions in order to improve our services;
- to offer you features suited to your requirements; and
- to ensure your continued eligibility for our products and services.
This information is shared only with our internal stakeholders on a need-to-know basis, under the data security standards to which we adhere.
2.2. Third-party use
We may share your personal information or confidential information with trusted third parties in order to deliver and improve our services, as permitted by data protection legislation, or in the limited circumstances set out below. These third parties are limited by law or by contract from using the information for secondary purposes beyond those for which the information is shared.
We may share your information with trusted third parties when:
- providing you with a service you have requested, including services delivered through correspondent banks, custodians, brokers and other Institutional Partners;
- responding to a subpoena, warrant, court order, regulatory request, or as otherwise required by law;
- conducting or co-operating in investigations of fraud, financial crime or other unlawful activity, where we believe it is reasonable and appropriate to do so;
- interacting with our approved business service partners, who are held to contractual and legal requirements as to how they are permitted to handle your data; and
- collecting your IP address, browser type and access times in order to improve our site.
In the case of a merger with another company, or of any rebranding, the new company or brand would have access to the personal information provided by you. The current Privacy Policy would continue to apply unless amended or otherwise stated.
3. Information Disclosure
You consent to our collection, use and disclosure of the personal information and confidential information you have provided, as set out below.
We may disclose your information:
- To other members of the group structure within which CenTrue is established, for the purposes described in this Privacy Policy, including across borders, wherever members of the group are located. In the event of a cross-border transfer of data, CenTrue is committed to providing appropriate protection for your information and to meeting the standards of data protection required under applicable law.
- To trusted third-party partners, in order to validate the information you provided when applying for your account.
- To correspondent banks, custodians, brokers, clearing systems and other Institutional Partners, to the extent necessary to execute and settle your instructions and to satisfy their own regulatory obligations.
- To third-party service and technology providers, for the purposes of onboarding and identity verification, sanctions and adverse-media screening, transaction monitoring, core banking technology, cloud hosting and communications. This may involve the transfer of your information across borders. It will only be transferred to third parties who have agreed to protect and handle your data to the standards expected at CenTrue.
- To the Regulator of International Banking, the Nevis Financial Services Regulatory Commission, tax authorities and other competent authorities, where required under applicable law, including under FATCA, the Common Reporting Standard, and applicable AML, CTF and sanctions legislation.
- As we deem necessary or appropriate under applicable law in order to: respond to police or government requests, both within and outside your country of residence; comply with legal process; enforce our terms and conditions; protect our operations and those of members of our group; pursue or limit damages that we sustain; and protect the rights, privacy and safety of CenTrue or members of our group.
4. Cookies
We use cookies on our site to collect and store certain information when you access CenTrue. Cookies are small files that may enable us to know some additional information about you. The information provided by cookies may tell us whether you have previously visited our site, whether you are using the same computer, whether you have previously contacted us for support, whether you prefer a specific browser, or whether you have certain preferences when using CenTrue.
5. Your Rights
You have the right to access the personal information we hold about you and about your use of our site and services.
Where applicable, you may have certain rights under data protection legislation, including the right to access, correct, update or delete your personal information; to object to or restrict its processing; to request the transfer of certain of your personal information to another service provider (data portability); or to withdraw any consent you have given.
These rights are subject to the Bank's overriding legal and regulatory obligations. In particular, we may be unable to delete personal information that we are required by law to retain, and we may be prohibited by law from disclosing information relating to a suspicious activity report or an ongoing investigation.
To exercise any of these rights, contact us at legal@centruebank.com or through your relationship manager.
6. Legal Basis for Processing
We will process your personal information only where we have one of the following grounds:
- On the basis of your consent — for example, to send you marketing messages, to the extent that consent is required by law;
- Where necessary to enter into a contract with you and to perform our obligations under that contract;
- Where we have a legitimate interest, subject to that processing not overriding your own rights and freedoms;
- Where we have a legal obligation to collect your personal information, including under banking, AML, CTF, sanctions and tax-transparency legislation, or where we otherwise need your personal information to protect your vital interests or those of another person; or
- Exceptionally, where necessary in the public interest — for example, where law enforcement agencies request information in order to investigate a crime.
7. Contacting Us
To contact us regarding any question you may have about this Privacy Policy, please write to:
Centrue Private Bank Limited Juris Building, P.O. Box 480, Main Street Charlestown, Nevis Saint Christopher and Nevis
Data protection and legal enquiries: legal@centruebank.com Client support: support@centruebank.com General enquiries: info@centruebank.com
Existing clients may also contact their relationship manager, or send a secure message through the client portal.
8. Definitions
Please refer to our Terms and Conditions for the defined terms referred to in this Privacy Policy.
9. Updates and Amendments
We reserve the right to amend this Privacy Policy at any time and for any reason. Any variation will not reduce your rights under this Privacy Policy without your consent.
All changes will be posted on our site, and you may be asked to re-confirm your consent to the terms of this Privacy Policy. If the amendments are significant, we may notify you directly. For reference, we will retain prior versions of our Privacy Policy.
Centrue Private Bank Limited · Company registration number 51 of 2025 · LEI 8945000B6690PTKX2V92 · GIIN HWM6BZ.99999.SL.659 · Incorporated in Saint Christopher and Nevis and licensed to carry on international banking business from the Island of Nevis under the Nevis International Banking Ordinance, Cap. 7.05 (N).