Lottomania Nigeria Ltd - Privacy Policy

Lottomania Nigeria Ltd ("Lottomania", "we", "our", "us") operates the Lottomania online gaming and lottery platform accessible via www.lottomania.ng, mobile applications, SMS and USSD channels (collectively, the "Platform"). We are committed to protecting your privacy and handling your personal information in accordance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR), and related regulatory frameworks under the Nigeria Data Protection Commission (NDPC) and National Lottery Regulatory Commission (NLRC).

1. Information We Collect

We collect the following categories of personal data:

• Identification Data: Name, date of birth, gender, address, email, phone number, and government-issued IDs (NIN, BVN, driver's licence, passport).
• Account and Transaction Data: Usernames, passwords, wallet details, deposit/withdrawal records, bet history, and payment methods.
• Device and Technical Data: IP address, browser type, operating system, device ID, network provider, and geolocation (where permitted).
• Marketing and Communication Data: Player preferences, interaction history, feedback, and responses to promotions.
• AML/KYC Data: Verification documents, source of funds, and transaction monitoring records required by law.

2. Purpose of Processing

We process your data for the following essential purposes:

• To create and manage your Lottomania account.
• To verify your identity (KYC) and comply with AML/CFT laws.
• To process deposits, bets, and withdrawals.
• To conduct draws and credit winnings.
• To detect, prevent, and investigate fraud or misuse.
• To communicate with you about your account, gameplay, and promotions.
• To improve our services, personalize content, and optimize performance.
• To comply with regulatory and legal obligations under the NDPA, NLRC, FIRS, and CBN frameworks.

3. Lawful Basis for Processing

Our lawful basis for processing your data includes:

• Performance of a contract: To provide gaming services as agreed.
• Compliance with legal obligations: Such as anti-money laundering (AML), tax reporting, NDPA, and NLRC requirements.
• Legitimate interests: For security, fraud prevention, and service improvement.
• Consent: For marketing, optional notifications, and non-essential cookies. You may withdraw consent at any time where processing is based on consent.

4. Data Sharing and Transfers

We may share your data with the following parties under strict contractual controls:

• Licensed Payment Service Providers (PSPs), settlement banks, and aggregators.
• Regulatory authorities such as NLRC, NDPC, EFCC, and FIRS when legally required.
• Verified technology service providers (hosting, analytics, CRM, messaging) who process data under confidentiality and data-processing agreements.
• Our affiliates and marketing partners.

5. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes above or as required by law. Gaming, KYC, and transaction records are typically retained for five (5) years after account closure for regulatory compliance.

6. Data Security

We employ industry-standard security measures, including:

• End-to-end encryption of sensitive data in transit and at rest.
• Multi-factor authentication for access to player and admin accounts.
• Restricted access on a "need-to-know" basis.
• Regular vulnerability and compliance audits.

7. Your Rights Under the NDPA

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

• Access and obtain a copy of your personal data.
• Request correction or update of inaccurate data.
• Withdraw consent for marketing or optional processing.
• Request deletion ("right to erasure"), subject to legal retention obligations.
• Data portability (to move your data to another service).
• Object to processing for direct marketing or profiling.

8. Data Protection Officer (DPO)

Lottomania Nigeria Ltd has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the NDPA.

9. Updates and Complaints

We may update this Privacy Policy periodically to reflect legal, technical, or business developments. When changes are made, we will notify users via email or in-app notification.

If you believe your data has been mishandled, you may contact our DPO or lodge a complaint directly with the Nigeria Data Protection Commission (NDPC) at https://ndpc.gov.ng.

Legal Compliance Notes

This Privacy Policy complies with:
- Sections 24–32 of the Nigeria Data Protection Act 2023;
- Articles 2–4 of the NDPR 2019;
- NLRC Digital Gaming Guidelines on secure storage of player data and AML compliance.