At Subway Labs Infrastructure Partners, your privacy is our priority. We comply fully with the Nigeria Data Protection Act 2023, ensuring your information is handled transparently, securely, and responsibly.
At Subway Labs Infrastructure Partners Limited (SLIP), protecting the personal data of our clients, partners, and stakeholders is central to our operations. We comply fully with the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR), ensuring that all personal data is handled with the highest standards of confidentiality, integrity, and accountability.
This Privacy Policy applies to all personal data processed by SLIP in connection with our mandate engagements, project advisory services, client communications, and regulatory obligations.
We process personal data for the following purposes:
Supporting client engagement processes, including project assessment, structuring advisory, and transaction preparation;
Communicating with clients, government agencies, and relevant stakeholders;
Maintaining operational and contractual records;
Complying with applicable legal and regulatory obligations under NDPA, NDPR, and other Nigerian laws.
SLIP only collects Non-Sensitive Personal Data, which includes:
Full name and professional title
Contact information (telephone, email, business/residential addresses)
Identification numbers (e.g., national ID, passport, or corporate identifiers)
Professional and corporate information necessary to execute advisory mandates
We do not collect sensitive personal data unless explicitly required and consented to.
SLIP processes personal data in accordance with the following principles:
Lawful, Fair, and Transparent – Data is processed only for legitimate purposes, and data subjects are informed of its use.
Purpose Limitation – Data is collected solely to perform our services and meet legal obligations.
Data Minimization – Only the data necessary for service delivery is collected.
Accuracy – We maintain personal data accurately and up-to-date.
Storage Limitation – Data is retained only for as long as necessary to fulfil our purposes or as required by law.
Security – We implement technical and organizational safeguards to prevent unauthorized access, loss, alteration, or disclosure.
Accountability – SLIP takes full responsibility for all personal data under its control and demonstrates compliance when required.
SLIP does not sell or rent personal data. We may share personal data only in the following circumstances:
With panel specialists or contractors engaged for specific mandates, strictly limited to necessary information;
With regulatory authorities including NDPC, FIRS, CAC, SCUML, and SEC, as required by law;
With professional advisors such as lawyers or accountants, under confidentiality obligations;
With prospective investors or capital providers only with the client’s express written consent.
SLIP retains personal data for periods consistent with business, regulatory, and contractual requirements:
Client mandate records: minimum 7 years after completion/termination of mandate;
Financial records: minimum 6 years, in line with FIRS obligations;
Panel specialist/contractor records: minimum 3 years after last engagement.
After these periods, data is securely deleted or anonymized unless retention is legally required.
We implement both technical and organizational safeguards to protect personal data:
Encryption and password protection of digital files
Access controls and authentication protocols
Secure physical storage of paper documents
Confidentiality obligations for contractors and panel specialists
Regular reviews and audits of security measures
In case of a personal data breach, SLIP will notify the NDPC within 72 hours and affected data subjects promptly.
Under the NDPA 2023, all individuals whose data SLIP processes have the right to:
Be informed about how their data is used
Access their personal data
Rectify inaccurate data
Request deletion of data where lawful retention is not required
Restrict processing in certain circumstances
Object to processing based on legitimate interests
Data subjects can exercise these rights by contacting:
Email: dpo@subwaylabs.ng
Phone: +234 805 745 7883
This Privacy Policy is regularly and updated as necessary to ensure compliance with NDPA, NDPR, and industry best practices.
