Welcome to Submefast (accessible via sub.submefast.com). At Submefast (operated by Submefast Technologies Limited), your privacy and data security are our highest priorities. This Privacy Policy describes how we collect, use, store, process, and protect your personal and financial information when you use our website, mobile application, APIs, and digital financial services.
By accessing or using Submefast, you agree to the collection and use of your information in accordance with this Privacy Policy and the Nigeria Data Protection Regulation (NDPR) and other applicable data protection standards.
1. Information We Collect
To provide secure, licensed financial services, we collect specific information, including:
- Personal Identification Information: Full name, address, email address, phone number, date of birth, and — where a feature requires it, such as certain identity/document verification services or generating a dedicated virtual bank account — government identity numbers (including Bank Verification Number (BVN) and National Identification Number (NIN)) and government-issued ID documents.
- Financial and Transactional Data: Bank account details, transaction history, wallet balances, and payment records.
- Device and Technical Information: IP address, device type, operating system, browser type, and cookies.
- Communication Records: Records of your interactions with customer support and feedback submissions.
2. How We Use Your Data
We process your personal information for legitimate business and regulatory purposes:
- Identity Data for Account Issuance: Where a feature requires it — such as generating a dedicated virtual bank account — we share identifying information with our licensed banking and payment processing partners, who use it to meet their own Central Bank of Nigeria (CBN) Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) obligations.
- Service Delivery: Processing wallet funding and withdrawals, fulfilling airtime, data, and bill payment purchases, and running our digital wallet operations.
- Fraud Prevention & Security: Monitoring transactions to detect and block fraudulent or unauthorized activity.
- Product Improvement: Analyzing platform usage to troubleshoot issues and improve the service.
- Notifications: Sending transactional receipts, service updates, and — where you have opted in — marketing communications. You can opt out of marketing messages at any time.
3. Data Security & Storage
Encryption: Data in transit is encrypted using TLS. Sensitive stored data, including identity/document verification data, is encrypted at rest using AES-256.
Access Control: Access to sensitive account and identity data within our systems is restricted to authorized staff and logged.
Data Retention: We retain your information only as long as necessary to comply with Nigerian banking regulations and statutory limitation periods.
5. Your Legal Rights
Under the Nigeria Data Protection Regulation (NDPR), you have the right to:
- Access — request details of the personal data we hold about you.
- Rectification — request correction of inaccurate or incomplete information.
- Erasure — request deletion of your account and personal data, subject to regulatory retention requirements.
- Portability — request a structured export of your transaction history.
- Complaint — report a data privacy concern to the Nigeria Data Protection Commission (NDPC).
To exercise any of these rights, contact our Data Protection Officer at dpo@sub.submefast.com.