GETSUB TELECOMMUNICATIONS LTD PRIVACY POLICY

Effective Date: 20th March, 2026

1.0 INTRODUCTION

GETSUB TELECOMMUNICATIONS LTD (“we”, “us”, “our”, or “the Company”) is committed to protecting the privacy and personal data of all users, customers, and visitors who engage with our services.

This Privacy Policy explains how we collect, use, store, disclose, and protect your personal data in compliance with applicable data protection laws, including the Nigeria Data Protection Act 2023 (NDPA).

This Policy applies to all services provided by GETSUB TELECOMMUNICATIONS LTD, including but not limited to:

1. VTU services (airtime, data, electricity, cable subscriptions)
2. Telecommunication services
3. Software and technology solutions
4. Network design, optimization, and technical support services

By using our services, you agree to the terms of this Privacy Policy.

2.0 DATA CONTROLLER INFORMATION

GETSUB TELECOMMUNICATIONS LTD is the Data Controller responsible for your personal data.

For all data protection-related inquiries, please contact:

Data Protection Officer (DPO) at support@getsub.com.ng

3.0 INFORMATION WE COLLECT

We collect only personal data that is necessary and relevant for the provision of our services.

3.1 Personal Data You Provide

We may collect:

1. Full name
2. Phone number
3. Email address
4. Billing and payment details
5. Transaction history
6. Account login details
7. BVN details

3.2 Automatically Collected Data

When you use our website or services, we may collect:

1. IP address
2. Device type and operating system
3. Browser type
4. Usage data (pages visited, time spent, interactions)

3.3 Information from Third Parties

We may receive data from:

1. Payment processors (e.g., Flutterwave, Paystack, Monnify, VPay, Paga, Palmpay)
2. Service providers and partners

4.0 PURPOSE OF DATA PROCESSING

We use your personal data for the following purposes:

1. To provide and manage our services
2. To process transactions and payments
3. To verify user identity and prevent fraud
4. To improve service delivery and user experience
5. To provide customer support
6. To comply with legal and regulatory obligations
7. To send service-related communications
8. To send marketing communications (where consent is given)

5.0 LEGAL BASIS FOR PROCESSING

We process your personal data based on the following lawful grounds:

1. Performance of Contract: To deliver services requested by you
2. Legal Obligation: To comply with applicable laws and regulations
3. Legitimate Interest: To improve services, ensure security, and prevent fraud
4. Consent: For marketing communications and optional services

6.0 SHARING OF PERSONAL DATA

We may share your personal data in the following circumstances:

6.1 Service Providers: With trusted third parties who support our operations, including:

1. Payment processors
2. IT service providers
3. Hosting and analytics providers
4. Regulators or law enforcement (when required)

6.2 Business Transfers; In connection with mergers, acquisitions, or asset sales.

6.3 Legal Compliance: Where required by law, regulation, or legal process.

6.4 With Your Consent: Where you have expressly agreed to such sharing.

7.0 INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and processed outside Nigeria, particularly through third-party service providers.

Where such transfers occur, we ensure appropriate safeguards are in place to protect your personal data in accordance with the Nigeria Data Protection Act.

8.0 DATA RETENTION

We retain personal data only for as long as necessary to:

1. Fulfill the purposes outlined in this Policy
2. Comply with legal and regulatory obligations
3. Resolve disputes and enforce agreements

When data is no longer required, it will be securely deleted or anonymized.

9.0 COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to:

1. Improve user experience
2. Analyze website usage
3. Support security and fraud prevention
4. Deliver personalized content and advertisements

You may control or disable cookies through your browser settings. However, this may affect certain functionalities of our services.

10.0 DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data, including:

1. Encryption
2. Secure servers
3. Access controls
4. System monitoring

While we strive to protect your data, no system is completely secure. We encourage users to take appropriate precautions.

11.0 DATA BREACH NOTIFICATION

In the event of a data breach that may affect your rights or freedoms, we will:

1. Notify affected users promptly
2. Report to relevant regulatory authorities where required

12.0 YOUR RIGHTS

Under the Nigeria Data Protection Act, you have the right to:

1. Request access to your personal data
2. Request correction of inaccurate data
3. Request deletion of your data
4. Object to processing
5. Request restriction of processing
6. Request data portability
7. Withdraw consent at any time
8. Lodge a complaint with the appropriate regulatory authority

To exercise your rights, please contact us using the details provided in this Policy.

13.0 CHILDREN’S PRIVACY

Our services are not intended for individuals under the age of 18.

We do not knowingly collect personal data from minors. If such data is identified, it will be deleted promptly.

14.0 MARKETING AND OPT-OUT

You may opt out of receiving marketing communications at any time by:

1. Clicking the unsubscribe link in emails
2. Contacting us directly
3. Please note that you may still receive essential service-related communications.

15.0 CHANGES TO THIS POLICY

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

1. Changes in legal requirements
2. Changes in our services or operations
3. Updated versions will be published on our platform with a revised effective date.

16.0 CONTACT US

If you have any questions, requests, or complaints regarding this Privacy Policy or your personal data, please contact:

GETSUB TELECOMMUNICATIONS LTD  at support@getsub.com.ng