Scope of this privacy document

Types of personal data we collect

• Identity data: full name, date of birth, nationality, identity document details, selfie or live photo for verification
• Contact data: address, email, phone number
• Account data: username, settings, responsible gambling preferences, self-exclusion status
• Financial and transaction data: deposits, withdrawals, account balances, payment method tokens (no full card storage), chargebacks
• Compliance data: KYC records, AML screening results, sanctions and PEP checks, source of funds where required
• Technical data: IP address, device details, operating system, app logs, approximate location, cookies
• Usage data: pages visited, time spent, interactions, error reports, customer support records

Why we collect this data

• To open and manage accounts and provide online services
• To process payments, verify identity, and prevent fraud
• To meet legal and regulatory obligations in Nigeria
• To improve website performance, user experience, and product safety

Security measures

• Encryption in transit and at rest, strong access controls, multi-factor authentication
• Segmented networks, firewalls, anti-malware, continuous monitoring, and logging
• Regular vulnerability testing and staff training on data protection
• Payment handling aligned to PCI DSS through approved processors

User rights under Nigeria law

• Right to be informed about collection and use of data
• Right of access, correction, and deletion, subject to legal retention
• Right to restrict or object to processing, and to data portability where applicable
• Right not to be subject only to automated decisions that have legal or similar effects
• Right to complain to the Nigeria Data Protection Commission

Compliance framework

• Nigeria Data Protection Act 2023 and guidance from the NDPC
• National Lottery Regulatory Commission requirements and relevant state gaming rules
• Money Laundering (Prevention and Prohibition) Act 2022 and NFIU directives
• Central Bank of Nigeria rules for payment services

We use personal data only where lawful and necessary:

• Account services: registration, login, profile management, responsible gambling tools
• Transactions: deposits, withdrawals, refunds, dispute handling
• Verification and safety: KYC, AML, fraud prevention, geolocation checks for regulatory compliance
• Service improvement: troubleshooting, analytics, testing, and website performance
• Customer support: responding to requests and resolving incidents
• Marketing: sending product updates and offers based on consent or legitimate interest, with an opt-out at any time
• Compliance and reporting: audit, tax, regulatory disclosures, and record keeping

Legal bases for processing

• Consent for optional features such as marketing and certain cookies
• Contract where processing is needed to deliver requested services
• Legal obligation for AML, sanctions screening, tax and regulatory reporting
• Legitimate interests to maintain platform security, prevent abuse, and improve services, balanced against user rights

Requests

• To access a copy of personal data, request correction, or ask for deletion, contact the Data Protection Officer at [email protected]
• We may ask for proof of identity to protect accounts
• A response will be provided within 30 days, or we will inform you if more time is needed for complex requests

Corrections and deletions

• Incorrect information will be rectified on request
• Deletion will be carried out where no legal reason exists to keep the data
• Certain records must be kept for at least 5 years under AML and bookkeeping laws

Security checks and payments

• By using this website, users consent to security checks, identity verification, and processing of payment information by approved providers
• These checks help prevent fraud and support compliance duties

• This website is intended for persons 18 years and above
• Age cannot be confirmed without documents, so verification may be requested at any time
• If a minor’s account or information is found, the account will be closed and personal data will be deleted as permitted by law
• Parents or guardians can write to [email protected] to request deletion of a minor’s information

• Personal data may be processed in other countries where partners, payment providers, cloud services, or verification vendors operate
• Using this website indicates consent to such international transfers, subject to applicable safeguards
• We implement standard contractual protections, encryption, and strict access controls
• All partners are required to keep information confidential and to process data only for agreed purposes

• This disclaimer sets boundaries for how rules in this policy apply, including exceptions required by law or regulator directives
• The disclaimer applies once a user accepts this policy by signature, acceptance during registration, or other form of accession recognised by law
• Nothing here limits statutory rights under Nigeria law or regulatory oversight

What cookies are

• Cookies are small files stored on a device to remember settings and improve online services

How we use them

• Essential cookies for security and core features
• Analytics to understand usage and improve websites
• Personalisation to remember preferences and language
• Behaviour analysis to detect errors and enhance performance

Controls and retention

• Non-essential cookies operate on consent that can be withdrawn in browser settings or through our cookie controls
• Cookie retention is up to 1 year unless earlier deletion by the user

• Using this website means full acceptance of this privacy policy
• The most recent version of the policy prevails over earlier versions
• Material updates will be signposted on the website or by email where feasible
• Continued use of services after an update indicates acceptance of the revised policy

We may share personal data in limited cases:

• Service providers: payment processors, identity verification partners, fraud prevention tools, hosting and IT vendors
• Regulatory and legal: National Lottery Regulatory Commission, state regulators, law enforcement, courts, and Nigeria Data Protection Commission when required
• Business needs: professional advisers, auditors, and insurers under confidentiality

Dispute and contract situations

• Data may be shared to establish, exercise, or defend legal claims, or to enforce agreements

Transparency

• A list or categories of key processors and partners is available on the website or on request
• If a new third party is engaged, we will inform users of purpose and scope where required by law
• Providing data for a specific service indicates consent to processing by the relevant third party

• This website may contain links to other websites that have their own privacy policies
• We are not responsible for how external websites collect or use information
• Users should review the privacy policies of any external site before providing personal data

Additional information

Contact details

• Data Protection Officer: [email protected]
• Preferred language for communication: English (Nigeria)

Retention and deletion

• Business and compliance records are kept for as long as needed for the purposes stated, then securely deleted or anonymised
• AML and transaction records are retained for at least 5 years after the end of the relationship, or longer where the law requires

Automated decisions and profiling

• Fraud and risk checks may involve automated processing
• Users can request human review where an automated decision produces legal or similarly significant effects

Breach notification

• If a data breach risks user rights, we will notify the NDPC and affected users without undue delay, taking into account regulatory timelines