At SubHero ("we", "us", or "our"), accessible from subhero.ng, protecting your personal data and privacy is our highest priority. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with the Nigeria Data Protection Regulation (NDPR) and applicable financial laws.

1. Information We Collect

When you register, fund your wallet, or use SubHero services, we may collect the following data:

Account Information: Full Name, Email Address, Phone Number, and Password. KYC & Identity Verification: Bank Verification Number (BVN), Date of Birth, Gender, and Residential Address (required for generating dedicated virtual bank accounts per CBN/GTBank Squad regulations). Transaction Data: Deposit history, VTU airtime/data top-up destinations, SMM order details, and wallet balance records. Technical Data: IP address, device type, browser information, and session logs for security and fraud prevention.

2. How We Use Your Information

We use your information strictly for legitimate business operations, including:

Processing VTU purchases (Airtime, Data, Cable TV, Electricity) and SMM service orders. Creating and managing your dedicated wallet funding virtual account via Squad / GTBank. Verifying your identity to prevent money laundering, unauthorized access, and financial fraud. Sending automated transaction receipts, security alerts, and customer support communications.

3. Data Security & Storage

We employ industry-standard SSL/TLS 256-bit encryption for data in transit and bank-grade row locking for database transactions. Your passwords are hashed using PBKDF2 with SHA-256. We never store raw credit card numbers or banking PINs.

4. Disclosure of Information

We do not sell, rent, or trade your personal data. We only share data with authorized partners to fulfill services:

Licensed Payment Providers: Squad (HabariPay/GTCO) for processing wallet deposits and virtual accounts. Telecommunication Vendors: MTN, Airtel, Glo, and 9mobile API gateways to dispatch airtime and data bundles. Legal & Regulatory Authorities: When mandated by Nigerian courts, Central Bank of Nigeria (CBN), or law enforcement agencies.

5. Your Data Protection Rights (NDPR)

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

Access, review, or request a copy of your personal data stored on SubHero. Request correction of inaccurate or incomplete personal details. Request account closure and data erasure, subject to financial record retention laws.

6. Contact Us

If you have questions or wish to exercise your data privacy rights, please contact our Data Protection Officer at: