Table of Contents
1. INTRODUCTION
This Privacy Policy is issued by GlobalTrust Mortgage Bank Limited ("the Company"), previously known as GlobalTrust Savings & Loans Ltd. As part of its strategic business development and operational enhancement, the Company adopted its current name to better reflect its expanded vision, business objectives, and growth strategy. This change constitutes a change of name and corporate identity only and does not affect the Company's legal status or continuity. Accordingly, GlobalTrust Mortgage Bank remains the same legal entity formerly known as Global Trust Savings & Loans, and continues to own, manage, and operate all of its business activities, assets, rights, obligations, contracts, and customer relationships without interruption. All references to Global Trust Savings & Loans Ltd in any agreements, policies, records, correspondence, or other documents shall, where applicable, be construed as references to GlobalTrust Mortgage Bank.
This Privacy Policy applies to all personal data previously collected, currently processed, or subsequently obtained by the Company, whether under its former name or its current name, and such data shall continue to be processed in accordance with applicable data protection laws and the terms of this Privacy Policy.
GlobalTrust Mortgage Bank ("GTMB," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal and corporate data. This Privacy Policy outlines how we collect, use, process, share, and protect information when you access and use the GlobalTrust Mobile Application (the "App") for both Retail (Individual) and Corporate banking services.
This Policy is formulated in strict compliance with the Nigeria Data Protection Act (NDPA) 2023, the Central Bank of Nigeria (CBN) Consumer Protection Framework, and all applicable Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) regulations.
2. INFORMATION WE COLLECT
To provide seamless banking, savings, and investment services, we collect various categories of information during onboarding and continuous usage of the App:
A. Retail Onboarding & Identity Data
Personal Identifiers: Full name, Date of Birth, gender, and residential address. Regulatory Data: Bank Verification Number (BVN) and National Identity Number (NIN). Supplemental Identity Data: Government-issued IDs (such as Driver's License, International Passport, or Voter's Card) explicitly requested for Step-Up Verification in the event of naming discrepancies between BVN and NIN records.
B. Corporate Onboarding & Business Data
Business Identifiers: Corporate name, business address, and nature of business (Sole Proprietorship, Partnership, LLC, or PLC). Registration Documents: Corporate Affairs Commission (CAC) business registration documents and certificates. Director & Shareholder Data: NIN and BVN details of Directors and Shareholders holding more than 5% equity, as required by law. Mandate & Approval Data: Details of authorised signatories, account initiators, and approvers utilised within our multi-tier (e.g., 3-level) corporate approval workflows.
C. Financial & Transactional Data
Account Information: Wallet balances, account numbers, and transaction history. Transfer Data: Originating and destination account details for intra-bank and inter-bank (NIP) transfers, including beneficiary names. Product Usage Data: Information related to goal-based savings (TrustTarget), structured equity savings (TrustMortgage), and fixed-income investments (Fixed Deposit, TrustLock, and VaultPlus™), including defined targets, tenors, and auto-save direct debit mandates. Payment Data: Utility account numbers and details for bill payments.
D. Technical & Device Information
Device Specs: Operating system (Android or iOS), app version (e.g., 1.0.2), and unique device identifiers. Log Data: IP addresses, time of login, transaction timestamps, and error logs (such as failed gateway routing instances) to monitor app stability and performance.
3. HOW WE USE YOUR INFORMATION
We process the collected information for the following specific purposes:
Service Delivery
To create your account, generate account numbers, and process fund transfers, bill payments, and automated savings mandates.
Identity & Fraud Management
To authenticate user identities, resolve BVN/NIN mismatch exceptions, and prevent unauthorised access or fraudulent transactions.
Corporate Governance
To map corporate mandates, enforce up to 3-level transfer approval logic, and verify signatory bypass configurations.
Yield Computation
To accurately calculate and apply accrued interest rates (ranging from 8% to 22%) across our various liability and investment products based on your holding periods.
System Optimisation
To troubleshoot third-party integration drops, manage transaction reversal logic for failed outflows, and improve overall app efficiency.
Regulatory Reporting
To process applicable Withholding Tax (WHT) on accrued interest and record statutory stamp duty charges on transaction receipts.
4. INFORMATION SHARING AND DISCLOSURE
We do not sell your personal or corporate data. We may share your information strictly with authorised third parties under the following circumstances:
Core Banking & Infrastructure Partners
We share necessary transactional and account mapping data with our core banking system provider for ledger updates.
Payment Gateways & Switches
Data required to process and resolve outward and inward transfers is shared with payment switching partners (such as EasyPay and NIBSS).
Regulatory & Government Agencies
We are mandated to share KYC, KYB, and transactional data with the Central Bank of Nigeria (CBN), National Identity Management Commission (NIMC), the Nigeria Financial Intelligence Unit (NFIU), and the Corporate Affairs Commission (CAC) to fulfil legal obligations.
5. DATA RETENTION
We retain your personal, corporate, and transactional data for as long as your GlobalTrust account remains active and for a minimum statutory period of five (5) years following the closure of the account, as mandated by Nigerian AML/CFT laws. Investment data for locked products (e.g., the 36-month VaultPlus) is securely maintained for the duration of the tenor and subsequent regulatory retention periods.
6. DATA SECURITY
We deploy robust security architectures, including end-to-end encryption, multi-factor authentication (such as PIN, biometric access, and hardware tokens), and continuous API monitoring to safeguard your data against unauthorised access, alteration, or breach.
7. YOUR PRIVACY RIGHTS
Under the NDPA 2023, you possess the following rights regarding your data:
Right to Access
You can request a copy of the personal or corporate data we hold about you.
Right to Rectification
You can request corrections to inaccurate data (e.g., resolving name misarrangements).
Right to Restriction
You may request a temporary hold on the processing of your data under specific legal disputes.
Right to Erasure
You can request the deletion of your data, subject to GTMB's overriding regulatory obligations to retain banking records.
8. CHANGES TO THIS POLICY
GTMB reserves the right to update this Privacy Policy to reflect evolving regulatory frameworks or new app features. Material changes will be communicated proactively via in-app notifications, registered email, or SMS prior to their effective date.
9. CONTACT US
For any inquiries, requests, or concerns regarding this Privacy Policy or our data processing practices, please contact the GTMB Data Protection Officer (DPO) via the in-app Support module or through our official corporate communication channels.
GlobalTrust Mortgage Bank152, Obafemi Awolowo Way, Ikeja Lagos.support@mygtmb.com+234 803 715 6716