Privacy Policy

SUBBNOW provides digital services including data subscriptions, airtime, bill payments, subscription services, wallet funding and other related digital services.

By accessing or using SUBBNOW, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy is intended to operate in accordance with applicable Nigerian data-protection requirements, including the Nigeria Data Protection Act, 2023.

1. Who We Are

SUBBNOW is responsible for determining how and why your personal information is processed in connection with our services.

Throughout this Privacy Policy, "SUBBNOW", "we", "us", and "our" refer to SUBBNOW.

Our website is:

https://subbnow.com/

For privacy-related enquiries:

support@subbnow.com

2. Information We Collect

We collect information that is necessary to create and manage your account, provide our services, process transactions, maintain security, communicate with you, and improve our platform.

2.1 Account Information

When you create a SUBBNOW account, we may collect:

• First name
• Last name
• Email address
• Phone number
• Password or authentication information
• Account identification information
• Account preferences
• Other information you provide during registration

2.2 Transaction and Service Information

When you purchase or use our services, we may collect information relating to your transactions, including:

• Data subscription purchases
• Airtime purchases
• Cable or TV subscription transactions
• Electricity and other bill-payment transactions
• Transaction amounts
• Transaction dates and times
• Transaction status
• Service or product purchased
• Network or service provider information
• Recipient phone numbers or account identifiers where required to complete a transaction
• Transaction reference numbers
• Wallet funding and wallet transaction information

2.3 Payment Information

When you fund your SUBBNOW wallet or make a payment, your payment may be processed through third-party payment processors or financial institutions.

Depending on the payment method used, we may receive:

• Payment reference
• Transaction amount
• Payment status
• Payment date and time
• Payment channel
• Limited payment-related information necessary to identify or reconcile the transaction

Where payment processing is handled by a third-party payment provider, your payment information may also be processed by that provider in accordance with its privacy policy and applicable law.

3. Usage and Device Information

When you access SUBBNOW, certain technical information may be collected automatically.

• IP address
• Device type
• Operating system
• Browser type and version
• Application version
• Device identifiers
• Pages or features accessed
• Date and time of access
• Error logs
• Security and diagnostic information

We use this information to maintain and improve our services, monitor performance, detect technical problems, protect our systems, detect suspicious activity and improve user experience.

4. How We Collect Your Information

We may collect information:

• Directly from you when you register for an account
• When you purchase or use our services
• When you fund your wallet
• When you contact customer support
• When you communicate with us
• Automatically when you use our website or application
• From service providers involved in processing your transactions
• From payment providers where necessary to confirm or reconcile transactions
• From fraud-prevention, security or verification services where legally permitted

We will only collect information that is reasonably necessary for the relevant purpose.

5. Why We Process Your Personal Information

SUBBNOW may process your personal information for the following purposes:

5.1 Providing Our Services

To provide, maintain and operate SUBBNOW, including data subscriptions, airtime, bill payments, subscriptions and other services.

5.2 Managing Your Account

To create, authenticate, maintain and manage your SUBBNOW account.

5.3 Processing Transactions

To process purchases, wallet funding, payments, refunds, reversals and other transactions.

5.4 Customer Support

To respond to complaints, questions, enquiries, failed transactions and other support requests.

5.5 Security and Fraud Prevention

To identify suspicious transactions, prevent fraud, protect accounts and maintain the security of our systems.

5.6 Service Improvement

To understand how our services are used and improve our website, application, products and user experience.

5.7 Communication

To send service-related communications such as transaction notifications, security alerts, account notifications, service updates and important administrative messages.

5.8 Marketing

Where permitted by law, we may send information about promotions, offers, products or services that may be relevant to you.

You may opt out of promotional communications at any time.

5.9 Legal and Regulatory Compliance

We may process personal information where necessary to comply with applicable Nigerian laws, regulations, lawful requests, court orders, regulatory requirements or other legal obligations.

6. Lawful Basis for Processing

Depending on the circumstances, SUBBNOW may process personal information on one or more lawful bases recognised under applicable data-protection law.

• Your consent
• Performance of a contract or provision of a service you requested
• Compliance with a legal obligation
• Protection of your vital interests or those of another person where applicable
• Performance of a task carried out in the public interest where applicable
• Legitimate interests, where permitted by applicable law and where those interests do not override your applicable rights

Where we rely on consent, you may withdraw your consent at any time, although this will not affect processing that occurred before your withdrawal.

7. Sharing Your Personal Information

We do not sell your personal information.

We may share personal information where reasonably necessary to provide our services, operate our business, protect users or comply with applicable law.

7.1 Service Providers

We may use trusted third-party providers for services such as payment processing, hosting, cloud infrastructure, SMS, email delivery, customer support, analytics, security, fraud detection and technical maintenance.

7.2 Telecommunications and Service Providers

Where necessary to complete a transaction, information may be shared with relevant telecommunications, electricity, cable/TV or other service providers.

7.3 Payment Providers and Financial Institutions

Where necessary to process or reconcile payments, information may be shared with relevant payment processors, banks, financial institutions or other authorised payment partners.

7.4 Legal and Regulatory Authorities

We may disclose information where required or permitted by law, including in response to lawful requests from courts, regulators, law-enforcement authorities or other competent public authorities.

7.5 Business Transfers

If SUBBNOW is involved in a merger, acquisition, restructuring, financing, sale of assets or similar business transaction, personal information may be transferred as part of that transaction, subject to applicable legal requirements.

8. International Transfers

Some of our technology, hosting, payment, communication or other service providers may process information outside Nigeria.

Where personal information is transferred outside Nigeria, SUBBNOW will take appropriate steps required by applicable data-protection law to ensure that the transfer is subject to appropriate safeguards.

We will take reasonable measures to protect your personal information regardless of where it is processed.

9. Data Security

We take reasonable technical and organisational measures to protect your personal information against:

• Unauthorised access
• Loss
• Misuse
• Alteration
• Disclosure
• Destruction
• Unauthorised processing

Depending on the nature of the information and the risks involved, security measures may include access controls, authentication, encryption, monitoring, secure infrastructure, backups and logging.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

Retention periods may depend on:

• The type of information
• The purpose for which it was collected
• The nature of the service
• Transaction and accounting requirements
• Fraud and security requirements
• Customer-support requirements
• Legal and regulatory obligations
• Resolution of disputes or claims

When personal information is no longer required, we may securely delete, anonymise or otherwise dispose of it in accordance with our applicable retention procedures.

11. Your Data Protection Rights

Subject to applicable law and any lawful limitations, you may have rights regarding your personal information.

12. How to Exercise Your Rights

To exercise a privacy right or make a data-related request, contact us at:

support@subbnow.com

Please include enough information for us to understand and verify your request.

For security reasons, we may need to verify your identity before completing certain requests.

We will handle valid requests in accordance with applicable law.

13. Complaints

If you believe that SUBBNOW has processed your personal information in a manner that violates applicable data-protection law, we encourage you to contact us first so that we can investigate and attempt to resolve your concern.

You may also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) where applicable.

14. Children's Privacy

SUBBNOW's services are not intended for children who are not legally permitted to use the relevant services.

We do not knowingly collect personal information from children in circumstances where such collection is prohibited by applicable law.

Where applicable law requires parental or guardian consent, we will take appropriate steps to comply with those requirements.

15. Cookies and Similar Technologies

SUBBNOW may use cookies and similar technologies to:

• Keep our website functioning
• Remember preferences
• Improve security
• Understand website usage
• Improve performance
• Analyse traffic and user interactions

Where required by applicable law, we will provide appropriate information and obtain consent for cookies or similar technologies that require consent.

You can control certain cookies through your browser settings.

16. Third-Party Websites and Services

Our website or application may contain links to third-party websites, services or applications.

These third parties operate independently from SUBBNOW.

We are not responsible for the privacy practices, security, content or policies of third-party websites or services.

17. Automated Processing and Fraud Prevention

SUBBNOW may use automated systems, rules or tools to help detect suspicious activity, fraud, abuse, unusual transactions and security threats.

Where automated processing produces a decision that has a significant effect on you and applicable law gives you rights concerning that decision, you may contact us to exercise those rights.

18. Data Breaches and Security Incidents

If SUBBNOW becomes aware of a personal-data breach, we will assess and respond to the incident in accordance with applicable law and our security procedures.

Where notification is legally required, we will notify the relevant authority and/or affected individuals within the applicable timeframe and in the manner required by law.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes to our services
• Changes to our data-processing practices
• Changes in technology
• Changes in applicable laws or regulations
• Changes in regulatory guidance

When we make material changes, we may provide appropriate notice through our website, application, email or other suitable communication channels.

The date at the top of this Privacy Policy indicates when it was last updated.

20. Contact Us

If you have questions, concerns, requests or complaints about this Privacy Policy or the way SUBBNOW processes your personal information, please contact us.