Table of Contents
1. INTRODUCTION
At GlobalTrust Mortgage Bank, we are committed to safeguarding your personal and financial information. This Loan Services Privacy Policy is an addendum to our general Privacy Policy and explicitly outlines how we collect, process, store, and protect your data when you apply for, manage, or interact with our credit facilities.
We process all personal data in strict compliance with the Central Bank of Nigeria (CBN) regulations and the Nigeria Data Protection Act (NDPA) 2023.
2. INFORMATION WE COLLECT
To evaluate your eligibility, disburse funds, and manage credit facilities, we must collect and process specific categories of data:
Identity & Regulatory Data
Your Bank Verification Number (BVN), National Identity Number (NIN), government-issued identification, and biometric data (such as facial or fingerprint scans used to authorise loan activations and disbursements).
Financial & Investment Data
To facilitate our investment-backed credit lines (Liquid Loans), we continuously monitor the real-time status, tenure, and balances of your active GlobalTrust investment portfolios, specifically your TrustLock, Fixed Deposit, and VaultPlus accounts. We also monitor your TrustWallet transactional history for disbursement and repayment capabilities.
Property & Asset Data
For mortgage applicants, we collect data regarding the target property, including listings interacted with via our Developers Hub, independent property valuations, and geographic location data.
Credit History
Data obtained from licensed Nigerian Credit Bureaus regarding your external financial obligations, repayment history, and general creditworthiness.
3. HOW WE USE YOUR DATA
We strictly limit the processing of your data to the fulfilment of our contractual obligations and regulatory requirements. Your information is utilised to:
Determine Creditworthiness
To assess your eligibility for our credit facilities.
Execute Automated Workflows
To facilitate instant, straight-through processing of approved funds directly into your TrustWallet, and to execute proactive repayment debits.
Manage Default & Recovery
In the event of a maturity breach to initiate debt recovery.
Fraud Prevention & Compliance
To monitor for suspicious activities, prevent financial crimes, and report to regulatory bodies such as the CBN and the Nigeria Financial Intelligence Unit (NFIU) as mandated by law.
4. AUTOMATED DECISION-MAKING
GlobalTrust utilises automated processing algorithms to enhance the speed and efficiency of our loan services.
You have the right to request human intervention or contest any decision made solely via automated processing by contacting our Support or Risk teams.
5. DATA SHARING AND DISCLOSURE
We do not sell your personal data. We may share your information with trusted third parties strictly for operational and legal compliance, including:
Credit Bureaus & Registries
To report loan issuance, performance, and defaults, as legally required.
Valuation & Legal Partners
To independently verify the structural and legal integrity of properties financed through our mortgage desk.
Regulatory Authorities
When compelled by law, subpoena, or regulatory mandate to share data with the CBN, NDPC, or law enforcement agencies.
6. DATA RETENTION
We retain your loan and financial data for the duration of your active credit facility. Upon the closure, repayment, or liquidation of a loan, we are legally mandated by Nigerian financial regulations to securely archive this data for a minimum period of five (5) to ten (10) years before secure destruction.
7. YOUR PRIVACY RIGHTS
Under the NDPA 2023, you retain the right to:
- For privacy-related enquiries, please utilise the "Contact Us" module within the GlobalTrust application or email us directly.
Request Access
Obtain a copy of the personal and financial data we hold regarding your loan applications.
Request Rectification
Correct any inaccurate or incomplete information regarding your profile.
Withdraw Consent
Where processing is based on consent, you may withdraw it; however, doing so may compel the bank to immediately recall outstanding credit facilities or restrict access to future loans.
Lodge a Complaint
Direct grievances to our internal Data Protection Officer (DPO) or escalate to the Nigeria Data Protection Commission (NDPC).
8. LOAN PRODUCTS
The variety loan products available to individual and corporates are highlighted hereunder;
Product Summary
| Item | Details |
|---|---|
| Individual Products | 3 (SALAD, HOME NOW, TOGETHERNEST) |
| Corporate Product | 1 (BUILDA PLAN) |
| Fast Disbursement | Individual loans disbursed within 24 hours (subject to approval). |
| Lowest Interest Rate | HOME NOW - 24.5% p.a. |
| Highest Interest Rate | SALAD - 36% p.a. |
| Common Charges | 2% Admin & Advisory Fee and 1% Insurance for individual loans. |
| Collateral | Not required for the listed individual products. |
| Verification | Individual loans require BVN/NIN and eligibility checks; corporate lending requires comprehensive business and project documentation. |
| Product | Target Customer | Eligibility | Key Features | Tenor / Rate | Fees | Collateral / Disbursement |
|---|---|---|---|---|---|---|
| SALAD (Salary Advance Loan) | Individual Salary Earners | Full-time employees earning ₦100,000+ monthly | Top-up after 50% repayment; DTI 33.3%; BVN & NIN verification; employer verification; digital application; early repayment without penalty; insurance cover | 18 months; 36% p.a. | Admin & Advisory: 2%; Insurance: 1% | No collateral; 24-hour disbursement |
| HOME NOW (Mortgage Loan) | Individuals | Minimum monthly salary ₦250,000; minimum credit score 650; maximum age 60 years at maturity | BVN & NIN verification; insurance cover; 35% equity contribution; early repayment without penalty | 12 years; 24.5% p.a. | Admin & Advisory: 2%; Insurance: 1% | No collateral; 24-hour disbursement |
| TOGETHERNEST | Families, friends & associations | Minimum monthly income ₦250,000 per member; age 25–60 years | Individual underwriting; group guarantee; compulsory insurance; 3–6 months FD repayment in GTMB account; BVN & NIN verification; DTI 33.3% | Not specified | Admin & Advisory: 2%; Insurance: 1% | No collateral; 24-hour disbursement |
| BUILDA PLAN | Construction companies | Registered company with 2+ years development experience and 6 months satisfactory banking relationship with GTMB | Acceptable credit profile; equity contribution; project viability; legal title; project domiciliation. Requires incorporation documents, KYC, audited financials, bank statements, tax clearance, feasibility study, BOQ, approvals, drawings, cash flow projections, insurance, environmental compliance, and related project documents. | Subject to approval | Subject to approval | Project-based security; disbursement subject to approval |