Privacy Policy

Last updated: February 4, 2025

SolarSub ("we," "our," or "us") operates the SolarSub mobile application ("App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this policy carefully.

By using SolarSub, you consent to the practices described in this Privacy Policy. If you do not agree with this policy, please do not use the App.

1. Information We Collect

We collect the following categories of information:

1.1 Personal Information

• Contact Information: Phone number, email address
• Identity Information: Full name, date of birth (where required for verification)
• Government-issued ID: BVN (Bank Verification Number) or NIN (National Identification Number) for identity verification and regulatory compliance

1.2 Transaction and Financial Information

• Transaction history, including airtime purchases, data subscriptions, electricity payments, and cable TV subscriptions
• Wallet balance and funding transactions
• Payment method details (card information is processed by third-party payment gateways; we do not store full card numbers)

1.3 Device and Technical Information

• Device type, model, operating system, and unique device identifiers
• IP address and approximate geographic location
• App usage data, including features used and session duration
• Crash reports and performance data

1.4 Authentication Data

• Login credentials (securely hashed)
• Transaction PIN (encrypted, not stored in plain text)
• Biometric data used for authentication (processed on-device; we do not receive or store biometric templates)

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our services (airtime, data, electricity, cable TV, and wallet services)
• Process and complete your transactions
• Verify your identity and comply with regulatory requirements
• Secure your account and prevent fraud
• Communicate with you about your account, transactions, and updates to our services
• Analyze usage patterns to improve the App experience
• Comply with legal obligations and respond to lawful requests from authorities

3. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: Data transmitted between your device and our servers is encrypted using TLS/SSL
• Secure Storage: Sensitive data is encrypted at rest
• Access Controls: Access to personal data is restricted to authorized personnel on a need-to-know basis
• PIN Protection: Transaction PINs are never stored in plain text

While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security but are committed to maintaining robust safeguards.

4. Third-Party Services

We use third-party services to operate the App. These providers may collect and process data on our behalf:

• Telecom and Utility Providers: To process airtime, data, electricity, and cable TV transactions
• Payment Gateways: To process wallet funding and payments
• Analytics: To understand app usage and improve performance (data is anonymized where possible)
• Cloud Infrastructure: To host and store data securely
• Push Notifications: To send transaction alerts and updates

These third parties have their own privacy policies and are contractually required to protect your data in line with applicable laws.

5. Cookies and Analytics

When you use the App or our website (if applicable), we may use cookies, pixels, or similar technologies to:

• Remember your preferences and settings
• Analyze how the App is used
• Improve performance and user experience

You can typically manage cookie preferences through your device or browser settings.

6. Your Rights

You have the right to:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal data, subject to legal retention requirements
• Objection: Object to certain processing of your data
• Data Portability: Request your data in a portable format where technically feasible

To exercise these rights, contact us using the details in the Contact section below. We will respond within a reasonable timeframe as required by applicable law.

7. Children's Privacy

SolarSub is not intended for use by children under 13 years of age. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us immediately, and we will take steps to delete such information.

8. Data Retention

We retain your information for as long as your account is active or as needed to provide services. We may retain certain data for longer periods to comply with legal obligations, resolve disputes, enforce agreements, and prevent fraud.

9. Liability Disclaimer

To the fullest extent permitted by applicable law, SolarSub and its affiliates, directors, employees, and agents shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of the App or any breach of security. Our liability is limited to the extent permitted by Nigerian law. We do not guarantee uninterrupted or error-free service and are not responsible for the actions of third-party providers.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy in the App or via email/push notification. The "Last updated" date at the top indicates when the policy was last revised. Your continued use of the App after changes constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

11. Governing Law

This Privacy Policy is governed by the laws of the Federal Republic of Nigeria. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of Nigerian courts.