Privacy Policy

1. Overview

SUBMEANS ("we", "us", or "our") is committed to protecting your privacy in full compliance with the Nigeria Data Protection Regulation (NDPR) and international data protection standards. This Privacy Policy describes how we collect, handle, protect, and use your personal information when you interact with our platform.

2. Information We Collect

When you create an account or perform transactions on Submeans, we collect:

• Personal Identity: Full Name, Email Address, and Nigerian Phone Number.
• Transaction Records: Recipient telephone numbers, electricity meter tokens, smartcard IUC numbers, transaction reference numbers, and timestamps.
• Financial & Payment Data: Automated virtual bank account assignments and payment reference tokens generated through certified payment partners (e.g. Paystack). We never store raw debit card numbers or banking passwords.
• Device & Analytics Logs: IP address, browser type, and operating system for security fraud monitoring.

3. Purpose of Data Processing

We process your data strictly for legitimate operational purposes:

• Fulfilling automated VTU airtime, data, bills, and exam pin purchases with telecom networks.
• Managing your virtual wallet balance and generating transaction history receipts.
• Sending critical transaction SMS/email receipts and password reset links.
• Preventing money laundering, fraudulent activities, and unauthorized access.
• Providing 24/7 customer support via our dedicated WhatsApp and support desk.

4. Third-Party Service Providers

To provide instantaneous delivery, we partner with licensed and regulated entities:

• Telecom Carriers & Aggregators: MTN, Airtel Nigeria, Globacom, 9mobile.
• Payment Processors: CBN-licensed payment gateway partners (Paystack, Monnify) that process card and bank payments securely under PCI-DSS Level 1 certification.
• Utility Providers: Nigerian Electricity Distribution Companies (IKEDC, EKEDC, AEDC, IBEDC, etc.) and Cable TV networks (MultiChoice/DSTV, StarTimes).

5. Data Security & Storage

We employ industry-grade 256-bit SSL encryption, automated firewall protections, and strict role-based data access controls. User passwords and transaction PINs are stored using salted cryptographic hashing algorithms and cannot be read by anyone, including Submeans staff.

6. Your Privacy Rights

Under NDPR guidelines, you have the right to:

• Request access to your personal information stored on our servers.
• Update or rectify inaccurate profile information.
• Request account deactivation or deletion subject to legal transaction retention obligations.

7. Privacy Queries & Support

For any data inquiries or support requests, please contact our Data Protection Officer: