Terms of Service

Effective Date: March 30, 2026  |  Last Updated: April 7, 2026
Subsecute is operated by Trust Commerce — Lagos, Nigeria

1. Acceptance of Terms

These Terms of Service ("Terms") constitute a legally binding agreement between you ("User," "you," or "your") and Trust Commerce, trading as Subsecute ("Company," "we," "us," or "our"), governing your access to and use of the Subsecute platform available at subsecute.com, including our mobile applications and all related services (collectively, the "Service").

By creating an account, accessing, or using the Service in any way, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy. If you do not agree to these Terms, you must not access or use the Service.

Subsecute operates as a technology platform in partnership with CBN-licensed entities. Payment processing is provided through Paystack (licensed by CBN). Banking services are provided through SafeHaven Microfinance Bank (licensed by CBN). Subsecute may in the future offer virtual card services through a card-issuing partner.

2. Definitions

In these Terms, the following words and expressions carry the meanings set out below:

• "Account" means the personal Subsecute account you create to access the Service.
• "CBN" means the Central Bank of Nigeria.
• "Gift Link" means a shareable payment link generated through the Service that allows a third party to fund or contribute to a subscription on your behalf.
• "KYC" means Know Your Customer, the identity verification process required to access full Service functionality.
• "Naira Wallet" or "NGN Wallet" means the Nigerian Naira-denominated digital wallet within your Account.
• "Platform" means the Subsecute website, mobile applications, APIs, and all associated technology infrastructure.
• "Shared Plan" means a subscription plan that allows multiple users to share the cost or access of a single subscription service.
• "Subscription" means a recurring payment obligation to a third-party service provider managed through the Platform.
• "USD Wallet" means the United States Dollar-denominated digital wallet within your Account.
• "Virtual Card" means a digital payment card that may in the future be issued through the Platform (via a card-issuing partner) for the purpose of funding subscriptions or making online payments.
• "Wallet" means, collectively, the NGN Wallet and USD Wallet associated with your Account.

3. Eligibility & Account Registration

3.1 Eligibility

To use the Service, you must:

• Be at least 18 years of age or the age of legal majority in your jurisdiction, whichever is greater;
• Be a resident of the Federal Republic of Nigeria;
• Have the legal capacity to enter into a binding contract;
• Not have been previously suspended or removed from the Service; and
• Not be prohibited from using the Service under any applicable law or regulation, including but not limited to CBN directives, anti-money laundering laws, and sanctions regimes.

3.2 Account Creation

You must provide accurate, current, and complete information during the registration process. Each person may maintain only one (1) Account. You must not create an Account on behalf of another individual or entity without proper authorisation. We reserve the right to reject any Account registration at our sole discretion, without providing a reason.

3.3 Account Security

You are solely responsible for maintaining the confidentiality of your Account credentials, including your password, PIN, and any other authentication mechanism. You agree to immediately notify us at hello@subsecute.com of any unauthorised use of your Account or any other breach of security. We shall not be liable for any loss or damage arising from your failure to secure your Account credentials.

4. KYC & Identity Verification

4.1 Verification Requirement

Full access to the Service, including wallet funding and transactions, requires successful completion of our KYC verification process. We may restrict Service functionality until verification is complete.

4.2 Information Required

You will be required to provide:

• Your full legal name;
• Email address;
• Phone number; and
• A password for your account.

4.3 Ongoing Obligations

You agree to keep your KYC information accurate and up to date. If any of your information changes, you must update your Account promptly. We may periodically require re-verification, and failure to comply may result in suspension of your Account or restriction of Service features.

4.4 Regulatory Compliance

Our KYC process is conducted in compliance with the Money Laundering (Prohibition) Act 2011 (as amended), the CBN Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) regulations, and all other applicable Nigerian laws and regulations. We may share your verification data with regulatory authorities as required by law.

5. Description of Services

Subsecute provides a technology platform that enables you to:

• Manage recurring USD subscriptions — Track, organise, and control all your subscription services from a single dashboard;
• Virtual USD cards (coming soon) — Subsecute may in the future offer dedicated virtual cards linked to individual subscriptions, issued through a card-issuing partner;
• Auto-fund bills — Automatically convert Naira from your NGN Wallet and fund your bill payments;
• Maintain a digital wallet — Store funds in both NGN and USD denominations;
• Pay bills — Purchase airtime, data bundles, cable TV subscriptions, and pay utility bills through our bill payment partner, SafeHaven MFB;
• Create gift links — Generate shareable payment links that allow others to contribute towards your subscriptions; and
• Share subscription plans — Set up shared plans for teams, families, or friends, splitting subscription costs across multiple users.

We reserve the right to modify, suspend, or discontinue any feature of the Service at any time, with or without notice, subject to applicable law. We will make reasonable efforts to notify you of material changes.

6. Wallet & Funding

6.1 Wallet Overview

Your Account includes an NGN Wallet and a USD Wallet. The Wallet is a digital record of funds available for use within the Platform. It is not a bank account and does not earn interest. Funds held in the Wallet are not deposits within the meaning of the Banks and Other Financial Institutions Act (BOFIA) 2020.

6.2 Funding Your Wallet

You may fund your NGN Wallet via debit card or bank transfer through our payment processing partner, Paystack. All funding transactions are subject to successful processing by Paystack and your issuing bank. We are not responsible for delays, failures, or errors caused by your bank, card network, or Paystack.

6.3 Wallet Limits

Transaction and balance limits may apply to your Wallet based on your KYC verification tier and applicable CBN regulations. We may adjust these limits at any time to comply with regulatory requirements.

6.4 Wallet Balance Responsibility

7. Virtual Cards

7.1 Card Issuance

Subsecute may in the future offer virtual USD card services through a card-issuing partner. When available, virtual cards will be subject to the partner's terms and conditions in addition to these Terms. Each virtual card would typically be assigned to a specific subscription. We reserve the right to limit the number of virtual cards per Account.

7.2 Card Usage

When available, virtual cards issued through the Service will be intended for online subscription payments and related transactions. You agree that:

• Virtual cards may only be used for lawful purposes;
• Virtual cards may be declined by certain merchants at their discretion, and we have no control over merchant acceptance;
• Transaction authorisation is subject to card network rules, merchant requirements, and available card balance;
• Virtual cards are non-transferable and may only be used by the Account holder; and
• We may freeze or terminate a virtual card at any time if we suspect fraudulent or unauthorised activity.

7.3 Card Transaction Failures

Virtual card transactions may fail due to reasons beyond our control, including but not limited to: merchant-side processing errors, card network outages, incorrect merchant configurations, currency restrictions, or fraud prevention measures implemented by the card network or merchant. We will make reasonable efforts to inform you of failed transactions but accept no liability for losses arising from such failures.

7.4 Card Termination

We or our card-issuing partner may revoke, suspend, or terminate any virtual card at any time for security, regulatory, or operational reasons. Any remaining balance on a terminated card will be returned to your USD Wallet, subject to any applicable holds or deductions.

8. Subscription Management

8.1 How It Works

When you add a bill or subscription to the Platform, Subsecute records the renewal date, amount, and frequency. Before each renewal, the Platform will attempt to process the payment from your NGN Wallet (converting Naira to USD at the prevailing exchange rate if applicable) or your USD Wallet. Subsecute may in the future offer virtual card auto-funding for subscriptions.

8.2 Renewal Failures

Subscription renewals may fail if: (a) your wallet balance is insufficient; (b) the currency conversion cannot be completed; or (c) there is a technical issue with our systems or third-party services. While we will make reasonable efforts to notify you of potential or actual failures, we do not guarantee uninterrupted subscription renewals.

8.3 Cancellation of Subscriptions

You may cancel a managed subscription at any time through the Platform. A cancellation fee of 5% of the subscription value applies to cover administrative and processing costs. This fee represents a genuine pre-estimate of administrative, processing, and partner costs including exchange rate hedging and notification services. Cancellation through Subsecute only removes the subscription from our management system; it does not automatically cancel your subscription with the third-party service provider. You remain responsible for cancelling directly with the provider if required.

8.4 Subscription Accuracy

You are responsible for ensuring that the subscription details you enter (including renewal dates, amounts, and frequency) are accurate. We are not liable for incorrect charges or missed renewals resulting from inaccurate information provided by you.

9. Bill Payments

9.1 Supported Services

The Platform enables you to make payments for airtime, data bundles, cable TV subscriptions, and utility bills through our bill payment partner, SafeHaven MFB. The availability of specific billers and services may vary and is subject to change without notice.

9.2 Payment Processing

Bill payments are deducted from your NGN Wallet. Once a bill payment is initiated, it will be submitted to SafeHaven MFB for processing. You acknowledge that:

• Bill payments are processed on a best-effort basis and are subject to the availability and responsiveness of the biller and SafeHaven MFB;
• If a bill payment fails, the Platform will automatically retry the payment up to three (3) times before marking the transaction as failed;
• Failed bill payment amounts will be credited back to your NGN Wallet after all retry attempts are exhausted; and
• Processing times vary by biller and may not be instantaneous.

9.3 No Liability for Biller Issues

We are not responsible for delays, errors, or service interruptions on the part of any biller or service provider. If a payment is successfully deducted but the biller fails to credit your account, you should contact us at hello@subsecute.com, and we will make reasonable efforts to resolve the issue with the biller on your behalf.

10. Gift Links

10.1 Creating Gift Links

You may generate shareable gift links through the Platform. These links allow third parties to make a payment towards a specific subscription on your behalf. Gift links are tied to your Account and to a specific subscription or purpose.

10.2 Contributor Responsibility

Anyone who uses a gift link to make a payment does so voluntarily. Subsecute is not responsible for any disputes between you and contributors. Payments made via gift links are non-refundable to the contributor once successfully processed, unless required by law.

10.3 Misuse

Gift links must not be used for fundraising, solicitation, or any purpose other than subscription funding. We reserve the right to disable gift links and suspend your Account if we detect misuse.

Gift link payments from a single contributor are limited to applicable thresholds in compliance with CBN AML/CFT regulations. We reserve the right to decline or reverse gift link payments that trigger our fraud or AML monitoring systems.

11. Shared Subscription Plans

11.1 Overview

Shared Plans allow you to split the cost of a subscription across multiple Subsecute users. The user who creates a Shared Plan is the "Plan Owner," and the users who join are "Plan Members."

11.2 Plan Owner Responsibilities

The Plan Owner:

• Is responsible for ensuring the subscription is properly configured and maintained;
• Is responsible for managing Plan Members, including invitations and removals;
• Bears primary responsibility for the subscription renewal if Plan Members fail to contribute their share on time; and
• Agrees that Subsecute is not liable for disputes between the Plan Owner and Plan Members.

11.3 Plan Member Responsibilities

Each Plan Member:

• Must maintain a sufficient wallet balance to cover their share of the subscription before each renewal;
• Acknowledges that failure to fund their share may result in removal from the Shared Plan; and
• Agrees that contributions made to a Shared Plan are non-refundable once applied to the subscription renewal.

11.4 Liability

Subsecute does not provide tax advice. You are solely responsible for determining and fulfilling any tax obligations arising from your participation in Shared Plans.

12. Fees & Charges

12.1 Processing Fees

Subsecute charges a processing fee of 7% to 8% on transactions processed through the Platform, including but not limited to subscription funding, currency conversion, and bill payments. The applicable rate will be clearly displayed before you confirm any transaction.

12.2 Cancellation Fee

A fee of 5% of the subscription value is charged when you cancel a managed subscription through the Platform. This fee represents a genuine pre-estimate of administrative, processing, and partner costs including exchange rate hedging and notification services.

12.3 Third-Party Fees

Additional charges may be imposed by third parties, including but not limited to: your bank (for wallet funding), card networks, merchants, or billers. These fees are not controlled by Subsecute and are your sole responsibility.

12.4 Fee Changes

We reserve the right to modify our fee structure at any time. We will provide at least fourteen (14) days' notice of any fee increase via email or in-app notification. Your continued use of the Service after such notice constitutes acceptance of the revised fees.

12.5 Fee Transparency

All applicable fees, including the exchange rate and total cost, will be presented to you for review before you confirm any transaction. By confirming a transaction, you authorise the deduction of all applicable fees from your Wallet.

13. Currency Conversion

13.1 Exchange Rates

Currency conversion between NGN and USD is performed at market rates. The exchange rate displayed at the time you confirm a transaction is the rate that will be applied. Exchange rates fluctuate constantly; the rate at which a transaction is processed may differ from the rate at the time you initiated the transaction if there is a delay in processing.

13.2 Exchange Rate Risk

13.3 Regulatory Compliance

All currency conversion transactions are conducted in compliance with applicable CBN foreign exchange regulations. We reserve the right to refuse or delay any conversion that we reasonably believe may violate applicable regulations.

14. Withdrawals & Refunds

14.1 Withdrawals

You may withdraw funds from your NGN Wallet to a bank account saved in your Account profile. Withdrawals are processed through our payment partners and are subject to standard banking processing times. We may impose daily or per-transaction withdrawal limits.

14.2 Withdrawal Verification

For security purposes, we may require additional verification before processing withdrawals, particularly for large amounts or unusual activity patterns.

14.3 Refund Policy

Refunds for failed transactions (where funds were deducted but the service was not delivered) will be credited to your Wallet. Refund processing times depend on the nature of the failure and any third-party involvement. Refunds to your original payment method (bank account or card) are not available; all refunds are credited to your Subsecute Wallet. Where you have closed or are closing your Account, or where the refund amount exceeds NGN 10,000, you may request a refund to your original payment method, subject to standard processing times.

14.4 Transaction Reversals

Where a transaction fails and funds have been debited from your Wallet, the reversal will be processed within twenty-four (24) hours for on-platform transactions and within five (5) business days for transactions involving third-party providers.

14.5 Chargebacks

If you initiate a chargeback or payment dispute with your bank for a transaction used to fund your Wallet, we reserve the right to immediately suspend your Account, freeze your Wallet balance, and deduct the disputed amount. Fraudulent chargebacks may result in permanent termination of your Account and referral to law enforcement authorities.

15. User Obligations

By using the Service, you agree to:

• Provide truthful, accurate, and complete information at all times;
• Maintain accurate and up-to-date KYC information and promptly update any changes;
• Keep your Account credentials, PINs, and authentication tokens confidential and secure;
• Maintain sufficient wallet balance to cover scheduled subscription renewals and associated fees;
• Use the Service only for its intended purpose of managing personal subscriptions, making bill payments, and related activities;
• Comply with all applicable laws and regulations, including CBN regulations, anti-money laundering laws, and tax obligations;
• Not attempt to circumvent any security feature, access restriction, or rate limit of the Platform;
• Review transaction confirmations and promptly report any errors or unauthorised activity; and
• Cooperate with our support team and provide information reasonably requested for dispute resolution or regulatory compliance.

16. Prohibited Activities

You must not use the Service to:

• Engage in money laundering, terrorist financing, or any form of financial crime;
• Process transactions for the proceeds of illegal activity;
• Evade or circumvent foreign exchange controls, sanctions, or any CBN regulations;
• Fund subscriptions or make payments related to illegal goods, services, or activities;
• Create multiple Accounts or use another person's identity for Account registration;
• Use automated scripts, bots, or crawlers to access the Platform without prior written consent;
• Reverse-engineer, decompile, disassemble, or otherwise attempt to derive the source code of the Platform;
• Interfere with or disrupt the integrity or performance of the Platform or its underlying infrastructure;
• Exploit gift links or shared plans for commercial fundraising, pyramid schemes, or fraudulent purposes;
• Use the Platform to conduct business-to-business (B2B) transactions without express authorisation from us;
• Resell, sublicense, or commercially exploit any aspect of the Service without our prior written consent; or
• Engage in any activity that, in our sole judgment, is harmful to other users, third parties, or the integrity of the Platform.

We reserve the right to investigate suspected violations and to cooperate with law enforcement authorities, including the Economic and Financial Crimes Commission (EFCC) and the Nigerian Financial Intelligence Unit (NFIU), in the prosecution of users who violate these Terms.

17. Third-Party Services

17.1 Service Partners

The Service relies on the following third-party providers, among others:

• Paystack — Payment processing for wallet funding;
• SafeHaven MFB — Bill payment processing.

17.2 Third-Party Terms

Your use of the Service may be subject to the terms and conditions of our third-party partners. By using the Service, you agree to comply with any applicable third-party terms to the extent they apply to you.

17.3 No Liability for Third Parties

17.4 Service Continuity

If a third-party provider discontinues its service or materially changes its terms, we may need to modify or suspend affected features of the Platform. We will make reasonable efforts to find alternative providers and minimise disruption to you.

18. Intellectual Property

18.1 Our Property

The Platform, including all software, designs, text, graphics, logos, icons, images, and the selection and arrangement thereof, is the exclusive property of Trust Commerce (trading as Subsecute) or its licensors and is protected by Nigerian and international copyright, trademark, and other intellectual property laws.

18.2 Limited Licence

We grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform solely for your personal, non-commercial use in accordance with these Terms. This licence does not include the right to modify, reproduce, distribute, or create derivative works of any part of the Platform.

18.3 Feedback

Any feedback, suggestions, or ideas you submit to us regarding the Service — you grant us a non-exclusive, perpetual, irrevocable, royalty-free, worldwide licence to use, implement, modify, and incorporate such feedback into the Service without obligation of compensation.

19. Privacy & Data Protection

Your privacy is important to us. Our collection, use, and protection of your personal data is governed by our Privacy Policy, which forms an integral part of these Terms. By using the Service, you consent to the data practices described in our Privacy Policy.

We process your personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation (NDPR) 2019, and all other applicable data protection laws. You have the right to access, correct, and request deletion of your personal data, subject to our legal and regulatory obligations to retain certain data.

20. Disclaimers & Limitation of Liability

20.1 "As Is" Provision

THE SERVICE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.

20.2 No Guarantees

We do not warrant or guarantee that:

• The Service will be available at all times, uninterrupted, secure, or error-free;
• Virtual card transactions, when available, will be accepted by all merchants;
• Subscription renewals will always be processed successfully;
• Bill payments will be delivered instantly or without error;
• Exchange rates offered will be the most favourable available in the market;
• Third-party services integrated with the Platform will remain available or function correctly; or
• The Platform will be free from viruses, malware, or other harmful components.

20.3 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, SUBSECUTE, ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, AND AFFILIATES SHALL NOT BE LIABLE FOR:

• Any indirect, incidental, special, consequential, or punitive damages;
• Any loss of profits, revenue, data, goodwill, or anticipated savings;
• Any losses arising from currency exchange rate fluctuations;
• Any losses arising from failed subscription renewals due to insufficient wallet balance;
• Any losses caused by third-party service provider failures or outages;
• Any losses resulting from unauthorised access to your Account caused by your failure to secure your credentials; or
• Any losses arising from circumstances beyond our reasonable control.

IN ANY EVENT, OUR TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICE SHALL NOT EXCEED THE TOTAL FEES PAID BY YOU TO SUBSECUTE IN THE SIX (6) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR FIVE HUNDRED THOUSAND NAIRA (NGN 500,000), WHICHEVER IS GREATER.

20.4 Essential Basis

The disclaimers and limitations of liability set out in this section reflect a reasonable and fair allocation of risk between you and Subsecute and form an essential basis of the bargain between us. The Service would not be provided without these limitations.

21. Indemnification

You agree to indemnify, defend, and hold harmless Subsecute, Trust Commerce, and their respective directors, officers, employees, agents, and affiliates from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or in connection with:

• Your use of the Service;
• Your breach of these Terms;
• Your violation of any applicable law or regulation;
• Your provision of false, inaccurate, or misleading information;
• Disputes between you and other users (including Shared Plan disputes);
• Your use of gift links or shared plans in a manner inconsistent with these Terms; or
• Any third-party claim arising from your use of the Service.

22. Suspension & Termination

22.1 Termination by You

You may terminate your Account at any time by using the account deletion feature in the Platform or by contacting us at hello@subsecute.com. Before account closure, you should withdraw any remaining wallet balance or it will be refunded to your saved bank account, minus any applicable fees, outstanding obligations, or pending transactions.

22.2 Suspension by Us

We may immediately suspend or restrict access to your Account, without prior notice, if we reasonably believe that:

• You have violated or are about to violate these Terms;
• Your Account is being used for fraudulent, illegal, or unauthorised purposes;
• Your KYC information is or may be false, misleading, or outdated;
• We are required to do so by law, regulation, or a valid court order;
• Continued access poses a security risk to the Platform or other users; or
• You have initiated a chargeback or payment dispute against us.

22.3 Termination by Us

We may permanently terminate your Account for cause, including but not limited to repeated violations of these Terms, involvement in financial crime, or failure to complete KYC verification within a reasonable time. We will provide notice of termination where practicable and permitted by law.

22.4 Effect of Termination

Upon termination of your Account:

• All managed subscriptions and bill payments will cease to be processed (you must make alternative arrangements directly with the service providers);
• Any remaining wallet balance will be refunded to your saved bank account, minus outstanding fees, pending transactions, or amounts subject to regulatory holds;
• Your right to use the Service terminates immediately; and
• Provisions of these Terms that by their nature should survive termination (including Sections 16, 18, 20, 21, 23, and 24) shall continue in full force and effect.

22.5 Data Retention After Termination

Following account termination, we will retain your personal data and transaction records for the period required by applicable law and regulation, including but not limited to the CBN AML/CFT requirements (minimum of five years after the termination of the business relationship). After such period, your data will be securely deleted or anonymised.

23. Dispute Resolution

23.1 Informal Resolution

Before initiating any formal dispute resolution process, you agree to first contact us at legal@subsecute.com and attempt to resolve the dispute informally within thirty (30) days. Most concerns can be resolved quickly through our support channels.

23.2 Mediation

If informal resolution fails, either party may refer the dispute to mediation under the Lagos Multi-Door Courthouse mediation rules. The mediation shall take place in Lagos, Nigeria. Both parties agree to participate in good faith and bear their own costs of mediation.

23.3 Arbitration

If the dispute is not resolved through mediation within sixty (60) days, either party may refer the dispute to binding arbitration administered under the Arbitration and Mediation Act 2023. The arbitration shall be conducted in Lagos, Nigeria, in the English language, before a sole arbitrator mutually agreed upon by both parties. The arbitrator's decision shall be final and binding and may be entered as a judgment in any court of competent jurisdiction.

For claims not exceeding NGN 100,000, either party may elect to resolve the dispute through the Magistrate Court in lieu of arbitration.

23.4 Class Action Waiver

You agree that, to the extent permitted by applicable Nigerian law, you will pursue claims against us on an individual basis, except where representative proceedings are mandated or permitted under the Federal Competition and Consumer Protection Act 2018.

23.5 Time Limitation

To the extent permitted by applicable law, you agree that any claim arising out of or related to these Terms or the Service must be filed within two (2) years after the cause of action arose, or the claim shall be permanently barred.

24. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, without regard to its conflict-of-law principles. Subject to the dispute resolution provisions in Section 23, the courts of Lagos State, Nigeria, shall have exclusive jurisdiction over any dispute arising out of or in connection with these Terms.

25. Changes to These Terms

We reserve the right to modify these Terms at any time. When we make material changes, we will notify you by email, in-app notification, or by posting the updated Terms on the Platform with a revised "Last Updated" date. Material changes will take effect no earlier than fourteen (14) days after notice is given, unless a shorter period is required by law or regulation.

Your continued use of the Service after the effective date of the revised Terms constitutes your acceptance of the changes. If you do not agree to the revised Terms, you must stop using the Service and close your Account before the changes take effect.

If you close your Account due to material changes to these Terms within thirty (30) days of notification, any remaining wallet balance will be refunded without deduction of withdrawal fees.

26. Severability & Waiver

26.1 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court or tribunal of competent jurisdiction, the remaining provisions shall remain in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving the original intent of the parties.

26.2 No Waiver

Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision. A waiver of any term shall only be effective if made in writing and signed by an authorised representative of Subsecute.

26.3 Entire Agreement

These Terms, together with the Privacy Policy and any other policies or agreements referenced herein, constitute the entire agreement between you and Subsecute with respect to the Service and supersede all prior or contemporaneous understandings, whether written or oral.

26.4 Assignment

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations under these Terms to an affiliate or successor entity without your consent, provided such assignment does not materially diminish your rights under these Terms.

27. Force Majeure

Subsecute shall not be liable for any failure or delay in performing its obligations under these Terms where such failure or delay results from circumstances beyond our reasonable control, including but not limited to: acts of God, natural disasters, pandemics, wars, terrorism, riots, government actions or orders, CBN regulatory changes, power failures, internet or telecommunications outages, cyberattacks, failures of third-party service providers, banking system failures, or any other event of a similar nature. In the event of a force majeure event, our obligations shall be suspended for the duration of the event.

We will notify affected users of a force majeure event as soon as reasonably practicable.

28. Contact Information

If you have any questions, concerns, or complaints about these Terms or the Service, please contact us:

• General Enquiries: hello@subsecute.com
• Legal & Compliance: legal@subsecute.com
• Website: subsecute.com

Trust Commerce (trading as Subsecute)
Lagos, Nigeria

29. Complaints Handling

29.1 How to File a Complaint

If you have a complaint about the Service, you may file it by sending an email to support@subsecute.com or through the in-app complaints feature.

29.2 Acknowledgment

We will acknowledge receipt of your complaint within forty-eight (48) hours of submission.

29.3 Resolution Timeframes

Standard complaints will be resolved within fourteen (14) business days. Complaints relating to fraud or unauthorised transactions will be resolved within seventy-two (72) hours.

29.4 Escalation

If your complaint is not resolved to your satisfaction within the timeframes above, you may escalate the matter to the CBN Consumer Protection Department.