Terms and Conditions of Service

Welcome to GlobalTrust Mortgage Bank (“GTMB”, “the Bank”, “we”, “us”, or “our”). These Terms and Conditions (“Terms” or “Agreement”) constitute a legally binding contract between you (whether acting as an individual "Retail User" or on behalf of a business as a "Corporate User") and GTMB.

GlobalTrust Mortgage Bank Limited ("the Company"), previously known as Global Trust Savings & Loans Ltd (GTSL). 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 Agreement governs your access to and use of the GTMB Mobile Application (the “App”) and all associated retail, corporate, credit, and wealth management services. By downloading, registering, or using the App, you explicitly acknowledge that you have read, clearly understood, and agreed to be bound by these Terms.

Our operations and these Terms are strictly regulated by the Central Bank of Nigeria (CBN), the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) guidelines, and the Nigeria Data Protection Act (NDPA) 2023. If you do not agree with any provision of these Terms, you must immediately cease use of the App and delete it from your device.

1.1. App Licensing and Permitted Use

GTMB grants you a limited, non-exclusive, non-transferable, and revocable license to use the App on your mobile device strictly for accessing our financial services. You shall not reverse-engineer, decompile, modify, or distribute the App’s source code.

1.2. Account Security & User Responsibilities

You are solely responsible for the absolute confidentiality of your 6-digit Login PIN, 4-digit/6-digit Transaction PIN, passwords, One-Time Passwords (OTPs), and biometric data (Facial ID/Fingerprint).

Device Binding:

To mitigate fraud, your account is bound to a single mobile device. Logging into a new device will trigger an automatic 24-hour "Cooling-Off Period," during which your outward transfer limit is strictly capped at ₦20,000.

Liability for Unauthorized Access:

Any transaction executed using your PIN or biometrics is legally presumed to have been authorized by you. GTMB shall bear no liability for financial losses arising from compromised devices, shared PINs, or social engineering (e.g., phishing).

1.3. Emergency Account Lock (Panic Button)

If you suspect your credentials have been compromised, you must immediately invoke the "Emergency Account Lock" feature (available on the pre-login screen, via our security email links, or inside the App settings). This action places an immediate Post-No-Debit (PND) restriction on your account and terminates all active sessions. Accounts can only be unlocked via an automated facial liveness check that matches your BVN profile or through manual back-office clearance.

In strict compliance with CBN AML/CFT regulations, all accounts must satisfy our Know Your Customer (KYC) or Know Your Business (KYB) requirements.

2.1. Retail Banking (Individual) Onboarding

Identity Verification:

You must provide a valid Bank Verification Number (BVN) and National Identity Number (NIN).

Name Matching & Liveness Check:

The names across your BVN and NIN must match precisely. You consent to a real-time facial liveness check. Any discrepancies between your provided details, biometric selfie, and the NIMC/NIBSS databases will trigger a mandatory step-up verification process, resulting in temporary account restriction until cleared by a manual review from our Compliance Team.

Address Verification:

You must upload a valid utility bill (not older than 3 months) or grant GPS geolocation permissions to verify your residential address.

2.2. Corporate Banking Onboarding

Sole Proprietorships & Partnerships:

Require validation of your Business Name (BN) number with the Corporate Affairs Commission (CAC), alongside the BVN and NIN of all listed partners/proprietors.

LLCs & PLCs:

Require validation of your Registration Company (RC) Number, upload of the Certificate of Incorporation (COI), Memorandum and Articles of Association (MEMART), Board Resolution, and the BVN/NIN of all Directors and Ultimate Beneficial Owners (UBOs) holding more than 5% equity.

2.3. The ₦10,000 Activation Deposit Rule (LLCs/PLCs)

Upon successful document submission, LLC and PLC accounts are generated in a strictly restricted Post-No-Debit (PND) status. To trigger our internal compliance review and activate full account features, the Corporate Administrator must make a minimum initial activation deposit of ₦10,000 into the account. Outward corporate transactions remain completely locked until this deposit is made and the compliance team approves the submitted KYB documents.

3.1. Wallets & Cards

Card Account: Your Prepaid/Virtual Prepaid Card balance accrues an interest rate of 8% p.a. You are empowered to manage your card security (blocking, unblocking, and setting daily channel-specific spending limits) directly via the App. You remain liable for all transactions executed prior to formally reporting a card lost or stolen via the App's blocking feature.

3.2. Transfers & Payments

Intra-bank transfers (GTMB to GTMB) are free. Inter-bank (NIP) transfers and bill payments are subject to network availability. The default daily transfer limit for retail users is ₦1,000,000. To increase this limit up to ₦25,000,000, you must digitally execute a "Highly Secured Online Funds Transfer Indemnity" validated via a biometric liveness check.

3.3. Savings & Investments (Liquidation & Penalty Clauses)

By funding any of GTMB’s wealth products, you explicitly agree to their specific lock-in periods and strict pre-liquidation penalties designed to ensure financial discipline:

4.1. The 3-Level Approval Workflow

Corporate Administrators may invite Account Operators and configure an Approval Matrix utilising a Role-Based Access Control (RBAC) system:

• Initiator: Authorised to draft and submit transactions.
• Reviewer: Authorised to verify drafted transactions and pass them forward.
• Approver: Authorised to provide final digital sign-off (via PIN and Biometrics) to execute the debit.

4.2. Corporate Liability & Operator Management

The Corporate Entity assumes absolute and unconditional liability for all actions, transactions, and errors committed by users invited as Account Operators. GTMB shall execute transactions automatically once your internal Approval Matrix logic is satisfied. We shall bear no liability for internal corporate fraud, disputes, or the mismanagement of user roles and limits by your appointed Administrator.

4.3. High-Value Transfer Limits & Indemnity

In compliance with CBN guidelines, corporate electronic transfers exceeding ₦10,000,000 per transaction are statutorily restricted. To exceed this limit (up to a cap of ₦250,000,000), the Corporate Admin must download, physically execute, and upload a Transfer Limit Indemnity Form, supported by a valid Board Resolution (for LLCs/PLCs) or Partnership Resolution, for back-office compliance approval.

By maintaining an account with GTMB, you authorize the automatic deduction of the following statutory and operational charges:

6.1. Data Privacy & NDPA 2023 Compliance

GTMB processes your Personally Identifiable Information (PII) strictly in accordance with the Nigeria Data Protection Act (NDPA) 2023. By using this App, you consent to the secure collection, storage, and processing of your data (including biometrics) and its transmission to authorised third-party identity, credit scoring, and AML partners (e.g., NIMC, NIBSS, CAC, MetaMap) strictly for regulatory compliance and service delivery.

6.2. AML/CFT & Regulatory Reporting

GTMB utilises automated AML monitoring engines. We reserve the absolute right to place a Post-No-Debit (PND) restriction on your account, block suspicious transactions, and file Suspicious Transaction Reports (STR) to the Nigerian Financial Intelligence Unit (NFIU) or law enforcement agencies without prior notice to you.

6.3. Limitation of Liability

To the maximum extent permitted by Nigerian law, GTMB shall not be liable for:

• Losses arising from your failure to protect your device, PIN, or login credentials.
• Delays, failed transfers, or unprocessed bill payments resulting from the downtime or malfunction of third-party gateways, settlement switches (e.g., NIBSS, Interswitch), or telecommunication networks.
• Any indirect, incidental, or consequential damages resulting from events of Force Majeure.

6.4. Dispute Resolution & Governing Law

First Instance:

All transaction disputes (e.g., ATM dispense errors, failed transfers) must first be logged via the App’s "Transaction Error Reporting" module for internal resolution within SLA timeframes (typically 24–48 hours).

Governing Law:

This Agreement shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.

Mediation & Jurisdiction:

These Terms shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any dispute, claim, or controversy arising out of the operation of this Account shall first be resolved through amicable mediation with the GTMB Customer Success Team within 14 days; failing which, the dispute may be referred for final determination, with the prior written consent of the Parties, the dispute may be referred to be resolved finally by mediation at the Lagos Multi-Door Courthouse (“LMDC”). The rules of the LMDC Law, 2015, shall apply with a single mediator appointed by the LMDC. Any settlement terms agreed upon by the Parties at the Mediation shall be binding on all Parties; Unresolved disputes shall be submitted to the competent courts of jurisdiction in Lagos State, Nigeria.

By tapping "I Agree", "Continue", during the onboarding process, you electronically execute this Agreement and confirm that you have read, clearly understood, and unconditionally accepted all the Terms and Conditions outlined herein.