How We Use Your Data
The purposes for which we process your personal data and the legal bases under the NDPR.
Why We Process Your Data
We process your personal data for the following specific purposes:
Service Delivery
- Creating and managing your Subsecute account
- Processing wallet funding and subscription payments
- Processing bill payments (airtime, data, cable TV, electricity)
- Sending transaction confirmations and subscription renewal reminders
Legal and Regulatory Compliance
- Verifying your identity (KYC) as required by CBN regulations
- Anti-money laundering (AML) and counter-terrorism financing (CTF) compliance
- Maintaining transaction records as required by Nigerian financial regulations
- Responding to lawful requests from regulatory authorities
Security and Fraud Prevention
- Detecting and preventing fraudulent transactions
- Monitoring for unauthorised access to your account
- Rate limiting API requests to protect against abuse
- Maintaining audit trails through activity and API logs
Communication
- Sending email verification and password reset messages
- Delivering push notifications for transaction alerts and subscription reminders
- Notifying you of important changes to our Service or this Privacy Policy
Service Improvement
- Analysing anonymised and aggregated usage patterns to improve our Service
- Debugging technical issues using API and activity logs
We will never sell your personal data to third parties. We will never use your data for automated decision-making or profiling that produces legal effects on you without your explicit consent.
Legal Basis for Processing
Under the NDPR, we process your personal data based on the following lawful grounds:
| Legal Basis | Applies To |
|---|---|
| Your Consent | Push notification delivery and email communications (other than those required for service delivery) |
| Performance of Contract | Account creation, Google OAuth2 login, processing payments, managing subscriptions and bill payments, delivering the core Service you signed up for |
| Legal Obligation | KYC/identity verification, maintaining transaction records, AML/CTF compliance, responding to regulatory requests from CBN or other authorities |
| Legitimate Interest | Fraud prevention, security monitoring, service debugging, and aggregated analytics for service improvement |
Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Please note that withdrawing consent for certain processing activities may affect our ability to provide you with the Service.