1. Introduction
FirstTrust Mortgage Bank Plc ("the Bank", "we", "our", or "us") values your privacy and is committed to protecting the personal information you share with us. This Privacy Policy outlines how we collect, use, store, disclose, and protect your personal data in compliance with the Nigeria Data Protection Act 2023 (NDPA) and other applicable data privacy regulations.
By engaging our services, visiting our website, or using our digital platforms, you consent to the practices described in this Privacy Policy.
2. Information We Collect
We collect the following categories of personal data:
- Identification Data: Full name, date of birth, gender, BVN, NIN, signature, and other official identification details.
- Contact Data: Residential and mailing address, phone numbers, and email address.
- Financial Data: Bank account details, credit history, income records, and mortgage information.
- Employment Data: Employer name, job title, employment status, and salary details.
- Digital Data: Device identifiers, IP address, browser type, cookies, and log-in activity when you use our online platforms.
- Other Data: Any information you voluntarily provide during inquiries, surveys, or interactions with our support teams.
3. How We Use Your Information
We use your personal data for the following purposes:
- To open, maintain, and manage your mortgage or banking account.
- To verify your identity and comply with Know Your Customer (KYC) requirements.
- To process transactions and provide banking or mortgage services.
- To communicate with you regarding account updates, product offerings, or regulatory notifications.
- To detect and prevent fraud, money laundering, or other unlawful activities.
- To enhance customer experience, improve our digital platforms, and conduct market analysis.
- To comply with legal obligations and respond to lawful requests by public authorities.
4. Legal Basis for Processing
We process your personal data based on one or more of the following grounds:
- Your consent.
- The performance of a contract with you.
- Compliance with legal or regulatory obligations.
- Our legitimate interests in providing efficient banking services and protecting the integrity of our systems.
5. Data Sharing and Disclosure
Your information may be shared with:
- Regulatory authorities such as the Central Bank of Nigeria (CBN), NDPC, and NIBSS.
- Credit bureaus and mortgage guaranty institutions.
- Service providers and partners that support our business operations (under strict confidentiality agreements).
- Law enforcement agencies, when required by law.
We do not sell, rent, or trade your personal data with third parties for marketing purposes.
6. Data Retention
We retain personal data for as long as necessary to fulfill the purposes for which it was collected, to comply with applicable legal, tax, or regulatory obligations, and to resolve disputes.
7. Data Security
We employ technical and organizational measures to protect your data from unauthorized access, loss, misuse, or alteration. These include encryption, access controls, firewalls, and regular security audits.
8. Your Rights
Under the Nigeria Data Protection Act, you have the right to:
- Access your personal data held by us.
- Request correction or deletion of inaccurate or outdated data.
- Withdraw consent for processing (where applicable).
- Object to processing based on legitimate interest.
- Lodge a complaint with the Nigeria Data Protection Commission (NDPC).
Requests to exercise your rights can be made through the contact details provided below.
9. Cookies and Online Tracking
Our website uses cookies and similar technologies to enhance your browsing experience and analyze usage. You may modify your browser settings to decline cookies, but some features may not function properly as a result.
10. Cross-Border Data Transfer
If it becomes necessary to transfer your data outside Nigeria, such transfers will be carried out in accordance with NDPA requirements and adequate safeguards will be implemented.
11. Updates to this Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Updates will be posted on our website with the effective date clearly indicated.
12. Contact Information
For questions, requests, or complaints about this Privacy Policy or how we handle your personal data, please contact:
Data Protection Officer (DPO)
FirstTrust Mortgage Bank Plc
124 Awolowo Road, Ikoyi, Lagos, Nigeria
Email: info@ftmortgagebankplc.com
Phone: 23481-2743-3340