1.     Introduction

Winlot 888 (“KBET”) respects the privacy rights of all individuals who access or use our services, including our website, mobile applications, gaming platforms, and any other related services (collectively, the “Services”).

This Privacy Policy explains how we collect, use, disclose, store, safeguard, and otherwise process Personal Data in accordance with the Nigeria Data Protection Act 2023 (NDPA), under the oversight of the Nigeria Data Protection Commission (NDPC), as well as applicable gambling, financial, and anti-money laundering laws of the Federal Republic of Nigeria.

By accessing or using our Services, you acknowledge that you have read and understood this Privacy Policy.

2.     Definitions

For the purposes of this Privacy Policy:

●   “Personal Data” means any information relating to an identified or identifiable natural person.

●   “Data Subject” means an individual whose Personal Data is processed by KBET.

●   “Processing” means any operation performed on Personal Data, including collection, storage, use, disclosure, alteration, or deletion.

●    “Data Controller” means the Company, which determines the purposes and means of processing Personal Data.

3.     Data Controller and Contact Information

Winlot 888 is the Data Controller responsible for the processing of Personal Data under this Privacy Policy.

KBET has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data protection laws and responding to data protection enquiries.

Contact Details:
Email: [email protected]
Address: No. 107 Bamgbose Street, Lagos Island, AGBEKE HOUSE

4.     Personal Data We Collect

We may collect and process the following categories of Personal Data:

●      Identity Information: Full name, date of birth, gender, nationality.

●      Verification and KYC Information: National Identification Number (NIN), passport or driver’s license details.

●      Contact Information: Email address, telephone number, residential address.

●      Account Information: Username, password, betting activity, wagering history, and account balance.

●      Financial Information: Bank account details, payment card details, and transaction history.

●      Technical Information: IP address, device identifiers, browser type, operating system, log data, and geolocation data.

●      Communications: Correspondence with customer support or through our platforms.

Personal Data is collected directly from you when you register, transact, interact with customer support, or otherwise use the Services.

5.     Lawful Basis for Processing

We process Personal Data on one or more of the following lawful bases under the NDPA:

●  Consent: Where you have explicitly agreed to the processing of your Personal Data for specific purposes.

●  Contractual Necessity: Where processing is necessary to perform our contractual obligations to you.

●  Legal Obligation: Where processing is required to comply with applicable laws, including gambling, financial, and anti-money laundering regulations.

● Legitimate Interests: Where processing is necessary for our legitimate business interests, provided such interests do not override your fundamental rights and freedom.

6. Purpose of Processing

Personal Data is processed for the following purposes:

●      To create, manage, and administer user accounts.

●      To verify identity, age, and eligibility to participate in gambling activities.

●      To process deposits, withdrawals, and other financial transactions.

●      To comply with gambling regulations, anti-money laundering (AML), and counter-financing of terrorism (CFT) financing obligations.

●      To detect, prevent, and investigate fraud, security incidents, or unlawful activities.

●      To operate, maintain, secure, and improve the Services.

●      To communicate with users regarding account activity, service updates, and operational notices.

7. Disclosure of Personal Data

We may disclose Personal Data to:

●      Service Providers: Including payment processors, hosting providers, verification services, analytics providers, and technical support partners.

●      Regulatory Authorities: Including the Nigeria Data Protection Commission and relevant gambling regulators, where required by law.

●      Law Enforcement Agencies: Where disclosure is required to comply with lawful requests or legal obligations.

●      Professional Advisers: Legal, financial, audit, or compliance advisers where necessary.

Personal Data is not sold or shared for unauthorized commercial purposes.

8. Data Security

We implement appropriate technical, organizational, and administrative measures to protect Personal Data against loss, misuse, unauthorised access, disclosure, alteration, or destruction. These measures include encryption, access controls, secure servers, monitoring systems, and internal data protection procedures.

9. Data Retention

Personal Data is retained only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by applicable law, regulatory obligations, or legitimate business needs. Once Personal Data is no longer required, it is securely deleted or anonymised.

10. International Data Transfers

Where Personal Data is transferred outside Nigeria, such transfers are carried out in accordance with the NDPA and subject to appropriate safeguards. These safeguards may include contractual data protection agreements, adequacy determinations, or other mechanisms approved or recognised by the NDPC to ensure an adequate level of protection.

11. Cookies and Tracking Technologies

We may use cookies, web beacons, and similar tracking technologies to enhance user experience, analyze usage trends, and administer the Services. Where required by law, cookies will be deployed only with your consent. You may manage or disable cookies through your browser settings

12. Data Subject Rights

Under the NDPA, Data Subjects have the right to:

●      Access their Personal Data.

●      Request correction of inaccurate or incomplete Personal Data.

●      Request deletion of Personal Data, subject to legal or regulatory limitations.

●      Object to or restrict the processing of Personal Data.

●      Withdraw consent where processing is based on consent.

●      Lodge a complaint with the Nigeria Data Protection Commission.

Requests relating to these rights may be submitted using the contact details provided above.

13. Personal Data Breaches

In the event of a Personal Data breach that is likely to result in a risk to the rights and freedoms of Data Subjects, KBET shall notify the Nigeria Data Protection Commission and affected Data Subjects in accordance with the requirements of the NDPA.

14. Underage Users

Our Services are strictly intended for individuals who have attained the legal gambling age in Nigeria. We do not knowingly collect or process Personal Data belonging to minors. Where such data is identified, it will be promptly deleted.

15.  Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in legal obligations, regulatory guidance, or our data processing practices. Material changes will be communicated as required by law.

16.  Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria.

17.  Policy Review

This Policy is approved by senior management and will be reviewed periodically, and at least annually, to ensure ongoing compliance with applicable laws, license conditions, and regulatory expectations.