Privacy Policy

Naijabingo® is committed to protecting and respecting your privacy. The following information will help you to understand how we collect and use information about users of our websites, www.naijabingo.com including versions of our websites viewed on mobile phones, tablets or other electronic devices (in all cases referred to as the ‘websites’) and when you purchase our game slips.

The Privacy Policy should be read along with our Terms and Conditions and any additional applicable terms posted to the websites.

We collect information from you when you buy our game slips, visit our website, use our app, deposit funds with us, play our games, contact us by telephone or email or receive a communication from us. However, we hold this information on our servers securely.

The provision of information to us is voluntary but where you do not provide us with the required information, we may not be able to provide our service or parts of it to you.

Under Age Children

We do not use the Application to knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at complaints@naijabingo.com and we will delete such information from our files within a reasonable time.

What data do we collect about you?

When you are using our services (online and offline) we may collect certain data about you, such as:

Basic Contact Information

If you decide to purchase our game slip or register for an account on our Website, then we will collect your name and various contact details such as your home address, country of residence, email address and telephone number during the sign-up process and retain this information as part of your records. You also may provide us with additional contact information if you contact our customer support team.

Your account details and accounts Profile

When you setup an account you will provide us with your chosen username and password. You may also provide us with certain additional information about yourself which forms part of your account profile, such as your gender and a profile picture that you choose to upload. You may provide us further information or edit your existing information during the course of using your account.

Proof of age and identity

In order to verify your eligibility to use the Website, we collect your age and date of birth and we may also require proof of your identity and address such as a copy of your passport or driving license along with other documentation such as your National ID card, electoral card or birth certificate and a proof of address such as a utility bill or bank statement.

Your payment details

If you wish to deposit money in order to participate in real-money games on the Website then you will need to provide us with your credit/debit card information. We will also use the same details to pay out your winnings.

Technical information about your device and website usage

When you use our Website we will collect certain technical information including:

Records of how you use our services

This may include a log of your stake and gaming history, deposits you have made, payment methods you have used, your session durations and other transactions made on your account. We will also hold records of any consent you provide to participate in marketing campaigns or promotions offered by us or through third party suppliers.

Sensitive information

This may include records of any suspected or known gaming addictions or associated health issues that you may have.

Offence information

We may hold information regarding criminal or civil offences you may have committed, where we are notified by the police or other authority in connection with any potential criminal activity.

Public sources

Where we detect suspicious activity on your account or identify some other regulatory risk, then we may examine and collect information about you from online sources, such as your publicly available social media profiles. This may include your name, occupation, social media profile, and other information you make available to us when you connect with or contact us through a social media account for verification purposes.

Records of communications you have with us

If you contact us with a question or to provide feedback, for instance, we will collect records of your communications with us through chat, email, support tickets that you raise, telephone, and live chat conversations.

Other information that you provide to us voluntarily

This may include data that you provide to us if you enter a competition or prize draw on our Website or the details of any feedback that you provide to one of our online surveys or focus groups.

For what purposes do we use data about you, and on what legal basis?

We use your data for various purposes connected with the Website, including:

In order to use your data we must have a legal basis for doing so. The legal bases that we rely upon are explained further in the table below. Except when using any of your sensitive data (e.g. criminal records history) we will only use your data where it is necessary for:

Where none of the above applies, we will generally request your consent (which we will ask for before we process the data). For sensitive data or information relating to criminal offences, the legal basis that we will rely upon is set out in the section below.

The table below sets out further information about the purposes for which we use data about you, with the corresponding methods of collection and legal basis that we rely upon for its use.

Table 1

In some instances, we may intend to use your data in ways that are not described above. However, we will seek to inform you before doing so.

Who do we share your data with, and for what purposes?

We may share data about you with:

E-verification companies

We use e-verification companies to confirm your eligibility to use the gaming services on our Website when you first register and this may involve the transfer of your personal data to their secured serve

Payment processors

We use certain third parties such as payment processors and financial institutions to administer and process payments to and from you

Marketing

To send you marketing communications in accordance with your stated preferences, we may share your email address with email service providers, SMS providers and mailing houses.

Data analytics

We may use Google Analytics and other data analytics companies to track your Website usage and behaviours, in order to perform an analysis based upon your location, age, staking activity, and preferences in order to provide an enhanced player experience, and for risk and regulatory purposes.

Gaming providers

Many of the games that we host on our Website are developed and managed by third party gaming providers. We will share certain limited data about you with gaming providers to help to provide you with a smooth gaming experience.

IT suppliers

We make use of certain IT providers to support our business, including for services such as customer support, live chat, push notifications, and to send emails.

Risk and fraud monitoring providers

We conduct regular anti-fraud audits and may be required to provide results of these checks to a credit reference or fraud prevention agency or law enforcement.

Regulators and other government agencies

To comply with our legal and regulatory requirements, we may share your data with various government agencies including, but not limited to, verification agencies, public authorities, regulators (including the National Lottery Regulatory Commission, Lagos State Lotteries Board) and law enforcement agencies.

Other users of the Website and associated Websites

When you join a gaming room, your username (and nothing else) will be shared with other players who have also joined. These players may be members of the same Website or one of our associated Websites.

If you would like to receive a full list of our suppliers and other third parties who we share your data with then you can get in touch with us using the details provided in the section Who should you contact with questions?

Who might we receive your data from?

Sometimes we may receive information about you from third parties. These third parties may include:

Where might data about you be sent?

We store your data on secure servers.

As with any organisation, we are often required to transfer data internationally. Accordingly, data about you may be transferred globally.

For example, we may transfer your personal data to our vendors based outside Nigeria. In all cases, the transfer will be on the basis of adequacy decision including appropriate security measures, for the protection of personal data in those countries, territories or international organisations in accordance with applicable data protection laws. If you would like more information about any of the data transfer measures on which we rely please contact us using the details provided in the section Who should you contact with questions?.

How do we protect data about you?

We implement appropriate technical and organisational measures to protect personal data that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the data you provide. We also require our service providers to comply with strict data privacy requirements. Our data security measures currently include being ISO27001 certified.

How long will data about you be kept?

The period for which we may retain data about you will depend on the purposes for which the data was collected, whether you have requested the deletion of the data, and whether any legal obligations require the retention of the data (for example, for regulatory compliance). We will not retain data about you for longer than is necessary to fulfil the purposes for which the data was collected.

We will typically retain your data for seven years from when our relationship ends to satisfy our regulatory obligations, including anti-money laundering regulations. If we hold any information relating to problem gaming matters or any suspension or termination of your account, we may hold this for a longer period, as we reasonably deem necessary.

What rights and options do you have?

You may have some or all of the following rights in respect of data about you that we hold:

You are able to exercise these rights by contacting us using the details set out at Who should you contact with questions? below.

You have the rights set out in the table below:

Right in respect of the data about you that we hold Further detail (note: certain legal limits to all these rights apply)
• to request us to give you access to it
    This is confirmation of:
  • • whether or not we process data about you;
  • • our name and contact details;
  • • the purpose of the processing;
  • • the categories of data concerned;
  • • (if we have it) the source of the data, if we did not collect it from you;
  • • (to the extent we do any, which will have been brought to your attention) the existence of automated decision-making, including profiling, that produces legal effects concerning you, or significantly affects you in a similar way, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; and
  • • the criteria for determining the period for which we will store the data. On your request we will provide you with a copy of the data we hold.
• to request us to rectify or update it This applies if the data we hold is inaccurate or incomplete.
• to request us to erase it This applies if:
  • • the data we hold is no longer necessary in relation to the purposes for which we use it;
  • • we use the data on the basis of your consent and you withdraw your consent (in this case, we will remember not to contact you again, unless you tell us you want us to delete all data about you in which case we will respect your wishes);
  • • we use the data on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it;
  • • the data was unlawfully obtained or used; or
  • • to comply with a legal obligation.
• to request us to restrict our processing of it This right applies, temporarily while we look into your case, if you:
  • • contest the accuracy of the data we use; or
  • • have objected to our using the data on the basis of legitimate interest (if you make use of your right in these cases, we will tell you before we use the data again).

    This right applies also if:

  • • our use is unlawful and you oppose the erasure of the data; or
  • • we no longer need the data, but you require it to establish a legal case.
• to object to our processing it You have two rights here:

(i) if we use data about you for direct marketing: you can “opt out” (without the need to justify it) and we will comply with your request; and

(ii) if we use the data about you on the basis of legitimate interest for purposes other than direct marketing, you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection.

• to withdraw your consent to our using it This right applies to any data which we have collected and process based on your consent. You have the right at any time to withdraw the consent you have provided to us.
• to data portability This right applies:

(i) to data that you have provided to us; and

(ii) if we use that data on the basis either of your consent, or on the basis of discharging our contractual obligations to you.

If both (i) and (ii) apply, you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible.

• to lodge a complaint with the supervisory authority You can find their contact details here:

www.lslb.lg.gov.ng

www.nlrc-gov.ng

Who should you contact with questions?

If you have any questions, or wish to exercise any of your rights, please contact us at enquiries@naijabingo.com

Changes to this notice

We may update this notice (and any supplemental privacy notice), from time to time. We will notify of the changes where required by law to do so

Purpose Method of collection and legal basis for processing
• to collect the data required to set up your account when you register on the Website This information will be provided by you directly when you first setup an account with us and then during the course of using our services.
• to identify you each time you login to the Website and retain your account profile information
Legal basis
Necessary for the performance of the contract between you and us in relation to the gaming services.
To facilitate your use of our gaming services Method of collection
• to give you access to gaming services available on our Websites and allow you to be identified This information will be provided by you directly when you first setup an account with us and then collected by us during the course of using our services. We may also collect certain information indirectly from your device or web browser.
• to retain records of the games you have played along with your playing statistics
Legal basis
Necessary for the performance of the contract between you and us in relation to the gaming services and in all other cases it is necessary to fulfill our legitimate business interests.
To administer deposits that you make and to pay your winnings Method of collection
• to process cash deposits that you may decide to make The information will be provided by you when you first choose to make a deposit on the Website.
• to retain records of the amounts you have deposited and won while playing on our site Legal basis Necessary for the performance of the contract between you and us in relation to the gaming services.
• to allow you to place stakes and withdraw winnings
Identity and age verification checks Method of collection
• to carry out the required checks on your identity for regulatory purposes This information will be provided by you directly when you first setup an account with us and supplemented by information we receive from certain third parties.
• to confirm you are of the required legal age to use our gaming services and place stakes
Legal basis
Necessary for compliance with a legal obligation to which we are subject. To facilitate a smooth account registration process, if you open another gaming account with Naijabingo, we will use the same verification documents and checks to comply with our legal and regulatory requirements.
To monitor your use of the Website for legal/regulatory purposes Method of collection
• to collect data necessary to verify your financial transactions on the Website for any potential breach of our terms of use or any applicable regulations. This information is collected indirectly by us through the use of cookies and other tracking technologies that we install on your device and through records we keep of your use of the services.
• to conduct appropriate anti-fraud checks/audits, which shall take place each month for all players and with new accounts being included in the audits upon their first deposit.
Legal basis
Necessary for compliance with a legal obligation to which we are subject
• to analyse your use of the Website and your pattern of play, in order to identify if you are considered to be vulnerable to gaming addictions.
• to identify whether you have chosen to self-exclude yourself from gaming services and
therefore should be prevented from using our gaming services
To communicate with you Method of collection
• to provide you with customer support and answers and/or respond to any queries or feedback that you send to us. This information is collected when we communicate with you or you communicate with us.
• to inform you when you have been awarded winnings.
• to assist you with any technical problems you have with the Website.
Legal basis
It is our legitimate business interest to respond to communications that you send to us and inform you of relevant information in relation to the services that we provide.
• to update you with any changes to our terms and conditions/ other policies. We may also need to inform you of updates to our terms and conditions and other policies (such as this privacy notice) because it is necessary for compliance with a legal obligation to which we are subject.
Internal management, administrative and organisational reasons Method of collection
• to manage the traffic on our Website This information is collected from you both directly and indirectly.
• to improve the functionality of the Website
• to inform decisions as to new products available on the Website • to defend ourselves against any future legal actions
Legal basis
It is our legitimate business interest to improve our services and defend ourselves against legal claims.
To share information with service providers Method of collection
• see the section Who do we share your data with, and for what purposes? for more information This may include any of the information we hold about you, whether collected by direct or indirect means.
Legal basis
It is our legitimate business interest to share your data with trusted third parties who provide us with services relevant to our provision of the Website and our gaming services, including customer support, information technology, payments, marketing, data analysis, research and surveys.
To send you offers, promotions or other marketing Method of collection
• to send you promotions, offers and bonuses that you may be interested in via email, post, telephone, SMS (which includes WhatsApp messenger), push notifications, online inbox or otherwise in accordance with your specified preferences (if applicable) Your contact details will be collected when you first setup an account with us and may be updated (along with your preferences) from time to time.
• to send you similar information through your account which can be accessed through the Website (including the mobile app)
Legal basis
It is our legitimate business interest to send you marketing and promotional materials from time to time.
Where we have obtained your consent to send marketing then we instead rely on consent as the legal basis.
If we send you a marketing email or SMS, it will include details on how to unsubscribe from receiving similar marketing messages in the future. You can also manage your information and update your marketing preferences through the ‘My Account’ section. Please allow up to 48 hours for any opt out request to be processed. We may continue to send you relevant service messages about your account and our services if you have unsubscribed from emails or SMS.
To perform data analytics and benchmarking Method of collection
• to analyse your use of the Website and preferences in order to send you tailored promotions and offer you a personalized service This information is collected across your interactions with the Website.
• to understand how our Website is used and in order to personalize and improve your experience with the Website, including by aggregating your data with that of other customers
Legal basis
It is our legitimate business interest to improve our Website and services for our customers improved experience.