Confidentiality Policy
How we protect confidential information and handle disclosures.
1. Purpose and relationship to other documents
The purpose of this Policy is to describe the principles and safeguards we apply to maintain the confidentiality of customer information, whether or not such information constitutes "personal data" as defined under UK GDPR. In case of any inconsistency between this Policy and our Terms of Service or Privacy Policy, the Terms of Service and Privacy Policy will prevail to the extent of the conflict, but the documents are intended to operate together.
2. What we mean by confidential information
For the purposes of this Policy, "confidential information" includes any non‑public information relating to you, your accounts or your use of SBank's services. This may include, without limitation:
- your identity and contact details;
- account numbers, balances and transaction histories;
- payment instructions, counterparties and references;
- documents and data submitted for KYC/AML, credit or risk assessments;
- records of communications with our support team, including chat and call logs;
- internal notes and risk assessments related to your relationship with us; and
- technical identifiers that relate specifically to your use of our services.
Confidential information does not include information that:
- is or becomes publicly available without breach of this Policy by SBank;
- was lawfully known to us before you became our customer;
- is lawfully obtained by us from a third party who is not bound by a confidentiality obligation to you; or
- we are required or permitted to disclose under applicable law or regulation.
3. Our confidentiality commitments
Subject to the exceptions described in this Policy, SBank will not disclose your confidential information to third parties without a lawful basis and, where required, without your instruction or consent. We use such information strictly for the purposes of providing our services, managing our relationship with you, complying with legal and regulatory obligations and operating and improving our business.
We take reasonable steps to ensure that employees and other persons acting on our behalf:
- understand the importance of confidentiality and the obligations arising under this Policy;
- access confidential information only to the extent necessary to perform their job duties; and
- are subject to appropriate contractual or statutory duties of confidentiality.
4. Access controls and internal safeguards
Access to confidential information within SBank is granted on a "need‑to‑know" basis. This means that only those employees and contractors who require access to service your account, perform support, risk, compliance, technical or operational tasks will be able to view the relevant information.
We implement technical and organisational measures to protect confidential information, which may include:
- role‑based access controls and authentication mechanisms;
- segregation of duties between front‑office, operations, risk and support teams;
- logging and monitoring of access to sensitive systems and data;
- encryption of data in transit and at rest, where appropriate;
- secure development practices and periodic security testing; and
- procedures for responding to suspected or actual confidentiality incidents.
5. Support channels and communication
When you contact SBank through our support channels (for example, in‑app chat, web forms or email), our support agents may need to access certain information about your account in order to assist you. They will only access the information necessary to handle your request and will treat all such information as confidential.
For your own protection, we will never ask you to disclose your full password or multi‑factor authentication codes to our staff. We strongly recommend that you never share such information with anyone, including individuals claiming to be from SBank.
Some communications, including chat messages, may be internally visible to quality assurance, compliance or supervisory staff for the purposes of training, monitoring and ensuring that our services are delivered appropriately and in accordance with our policies. These staff members are also subject to confidentiality obligations.
6. Sharing confidential information with third parties
We may share confidential information with third parties in limited circumstances, where necessary and lawful. This may include:
- service providers who support the operation of our services, such as IT, hosting, communications, payment processing and identity‑verification providers;
- other financial institutions and payment schemes involved in the execution of your transactions;
- professional advisers, such as lawyers, auditors and consultants, who owe duties of confidentiality;
- regulatory, supervisory or law enforcement authorities where required or permitted by law; and
- other parties with your explicit instruction or consent.
Whenever we share confidential information with third parties acting on our behalf, we require them to protect the information in line with contractual confidentiality and security obligations and applicable law.
7. Legal and regulatory exceptions
In certain situations, we may be required or permitted by law to disclose confidential information without your consent. Examples include where disclosure is necessary:
- to comply with a court order, warrant, subpoena or other legal process;
- to respond to lawful requests from regulators, supervisory authorities or law enforcement agencies;
- to comply with anti‑money laundering, counter‑terrorist financing, sanctions or other financial crime obligations; or
- to protect our rights or property, or the safety of our customers or others.
Where required by law, we will seek to limit the scope of any disclosure to what is strictly necessary and, where appropriate, we may challenge requests that appear to be overly broad or insufficiently justified. In some circumstances, we may be legally prohibited from informing you that such disclosure has taken place (for example, in connection with certain AML/CTF reporting obligations).
8. Your responsibilities
While SBank takes confidentiality very seriously, you also have responsibilities to help keep your information secure and confidential. In particular, you should:
- keep your login credentials and security codes secret and separate from your device;
- ensure that you access our services only from trusted devices and networks;
- promptly review notifications and account activity to identify any unauthorised transactions; and
- inform us immediately if you suspect that your account or credentials may have been compromised.
If you choose to share information about your account with third parties (for example, by providing statements, screenshots or granting access), you do so at your own risk. We cannot control how third parties handle information that you disclose directly to them.
9. Data protection and privacy
Many aspects of confidentiality are closely linked to data protection law. Our separate Privacy Policy describes in more detail how we process personal data, the legal bases we rely on, your rights under UK GDPR and how you can exercise those rights. Nothing in this Confidentiality Policy is intended to limit your rights under data protection law or our obligations as a data controller.
10. Incident response and notifications
We operate procedures for identifying, managing and, where necessary, notifying relevant parties of incidents that may affect the confidentiality, integrity or availability of information. Where required by law, we will notify the competent supervisory authority and, where appropriate, affected individuals of certain personal data breaches.
If you believe that confidentiality may have been compromised (for example, if you receive suspicious communications purporting to be from SBank or if you notice unauthorised activity on your account), please contact us without delay using the contact details provided above.
11. Updates to this Confidentiality Policy
We may update this Policy from time to time to reflect changes in our services, in applicable law or in industry practices. The latest version will be made available on our website. Where changes are material, we will take reasonable steps to inform you in advance where this is practicable.
Last updated: 19 January 2026