1.1. This Privacy Policy (also referred to as the "Policy") sets forth the general rules of User's Personal Data collection, processing, distribution, use and keeping by the Company during the Platform use and/or directly on our request.
1.2. Each User must carefully read and comply with this Policy. It is understood and presumed per se that by the fact of the Platform or otherwise or by providing Us the Personal Data directly on our request, the respective User fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User must not access and use the Platform.
1.3. The Company reserves the right to modify or amend this Policy at its sole discretion. Any revisions to this Privacy Policy will be posted on our platform. If we make changes, we will notify you by revising the date at the top of this Policy. In addition, if the revised version includes any substantial changes to the manner in which your personal information will be processed, we will provide you with prior notice by posting notification of the change on the Privacy Policy area of our Platform. We strongly recommend you to periodically visit the Platform to review any changes that may be made to this Privacy Policy to stay informed about our information practices and your privacy rights and choices. Your continued usage of the Platform shall mean your acceptance of those amendments.
1.4. This Policy shall be considered an inalienable part of the Lotto Nigeria Account Terms and Conditions (hereinafter - the "Terms"). In terms not regulated by this Policy, the Terms and the Applicable Law shall apply to the relationships that arise hereunder.
1.5. It is the personal obligation and responsibility of each Employee to act in a manner consistent with this Policy.
1.6. All Employees must report any breaches, violations, risks, incidents, and complaints, as appropriate.
2.1. Account - a personal accounted, created and maintained by the User on the Platform.
2.2. Applicable Law - laws of Nigeria applicable under this Policy to any and all relations between a User and Company.
2.3. PISI Integrated Services Limited (also referred to as the "Company", "we", "us") - a company incorporated under the laws of Nigeria for the purpose of providing Lottery Services to Users of the Platform.
2.4. Employee - a PISI Integrated Services Limited employee.
2.5. Game - any game, carried out by the Company on the Platform as part of its Lottery Services.
2.6. Lottery Services - any (public or private) lottery and gambling services, provided by the Company on the Platform.
2.7. Personal Data/Information - information or totality of information that can be associated with a specific person (the User) and can be used to identify that person.
2.8. Privacy Policy - this Privacy Policy posted on the homepage of our Platform which may be revised or updated from time to time as stated in clause 1.3 of this Privacy Policy.
2.9. Prize - a prize won by a User by a Ticket.
2.10. Registration - the procedure of setting up an Account on the Platform.
2.11. Ticket - an entry into a Game.
2.12. User (also referred to as "you", "your") - owner of the Account on the Platform, that has not been terminated, suspended or closed.
2.13. Platform - the platform maintained and owned by the Company at https://spinlotto.com.ng or *20077#.
3.1. We collect from the Users only the Personal Data that we need for their proper use of the Platform to provide Lottery Services. In particular, we use your Personal Data to:
4.1. You have a right to access to your Personal Data, withdraw your consent for data processing, obtain the information whether or not your personal data is being processed and to require the correction, updating or deletion of incorrect or/and inaccurate data by contacting us at info@spinlotto.com.ng. Nevertheless, this request must comply with the Terms. We shall delete your respective Personal Data from any sources within 24 hours from the moment we receive such request from you.
4.2. To terminate your account and remove your Personal Data completely, please email us at info@spinlotto.com.ng with a request that complies with the Terms and the Applicable Law.
4.3. You have the right to receive notices of processing activities from the Company.
4.4. You have the right to transfer data in a machine-readable format.
4.5. You have the right to lodge a complaint with the local supervisory authority, authorized to review such complaints.
4.6. You are entitled with and may exercise any of the rights and freedoms guaranteed by the General Data Protection Regulation (the GRPR) with regard to the processing of personal data if you fall under its' material and territorial scope as defined in the GDPR.
5.1. We collect Personal Data from running the Platform and use Personal Data, provided to us by you. We may collect such Personal Data:
5.2. We reserve the right to engage a third party to conduct a KYC procedure. If such events take place, procedures comply with this third party's internal privacy policy.
5.3. When registering on the Platform and providing consent to the collection, storing and processing of your personal data, you warrant that you have read and understood this Policy.
5.4. We reserve the right to collect any other Data, including data which is not Personal per se such as:
5.5. When you visit the Platform or use our products, we automatically collect the Personal Data sent to us by your computer, mobile phone, or another access device. This Personal Data may include:
5.6. The Company collects some data automatically, namely information about devices (including mobile devices), which you may use to access the Platform, IP-address of your devices, used browsers and operating systems, date, time, geographical location data of your access to the Platform. However, we will not release your personally-identifying information of such kind to any third party without Your consent, except as set forth herein.
5.7. We do not process any sensitive Personal Data, such as religion, race, ethnicity and/or political views.
5.8. We may also use third party service providers, which we entrust storing data, its collection and analysis. This is made in order to enable you to get the best services possible and to make our cooperation the most effective and with the best benefit for you. These third parties have their own privacy policies and their own conditions, whether to collect your data or opt-out from it. Thus, we do recommend you to get yourself acquainted with the terms of the third party service provider if you use other services on our Platform. We will not seek any of your Personal Information through any other software platforms, data web resources etc., even if this information is necessary for You or your usage of the Platform.
5.9. You agree to provide the Personal Data specified herein and agree that your provided Personal Data may be processed and stored by us or our counterparties (as specified in clause 5.8 hereof) during the period of time that is practically necessary for the purposes for which the information may be used.
5.10. The components of Personal Data that mentioned below may be modified from time to time according to the Applicable law and our needs that will be reflected in this Policy. We will not collect any other Personal Data except for the mentioned herein until we amend and post these amendments to the Policy on the homepage of our Platform.
5.11. You have the right to request personal information safeguards in case your data is being transferred outside of the territorial scope of the GDPR as defined in the GDPR if you fall under its' material and territorial scope.
6.1. We will do any and all efforts and actions prescribed by Applicable Law to store any of your Personal Data in secrecy, to protect your Personal Data from accidental loss, disclosure or erasure, from illegal processing or illegal access.
6.2. We store and process your Personal Data on our servers in various jurisdictions, where our facilities and/or our service providers are located. By submitting your Personal Data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy. We protect your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We also authorize access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities. All of our physical, electronic, and procedural safeguards are designed to comply with the Applicable Law and regulations. Third parties may be located in other countries where the laws on the processing of Personal Data may be less stringent than in your country. From time to time, the Personal Data may be also stored in other locations, and in such cases, we will ensure that the Personal Data will be stored and processed with the reasonable level of care and security.
6.3. We reserve our right to share your Personal Data with the following parties and with regard to the following cases:
6.4. We will not provide your Personal Data to any other Platform users or third parties other than described in clause 6.3 herein without your consent or direction.
6.5. We will not sell or rent your Personal Data and/or customer lists to third parties without your explicit consent.
6.6. We may combine your Personal Data with information we collect from other companies and use it to improve and personalize the Platform and our products, as well as our content and advertising.
6.7. We may use your name and email address to provide you with information about products or services that may be of interest to You, but we will not use your Personal Data without complying with Applicable Law and, where appropriate, obtaining your consent.
6.8. Our services may, from time to time, contain links to and from the platforms of our partner networks, advertisers, and affiliates (including, but not limited to, platforms on which the Platform is advertised). If you follow a link to any of these platforms, please note that these platforms and any services that may be accessible through them have their own terms of use privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these platforms or services, such as contact and location data. Please check these policies before you submit any personal data to these platforms or use these services.
6.9. We may allow others to provide analytics services on our behalf in connection with our services. These entities may use cookies and other technologies to collect information about your use of the services and other platforms and apps (if any), including your IP address, web browser, pages views, app performance, time spent on pages and links clicked. This information may be used by the Company and others to, among other things, analyze and track data, determine the popularity of certain content and better understand your online activity.
7.1. In accordance with the Applicable Law and as needed to provide services to our Users, we may store and retain your Personal Data provided its integrity and the appropriate approach to it. This requirement is conditioned by the need for complying with legal obligations and resolving possible disputes. We may retain your Personal Data for as long as your account is active. Moreover, your Personal Data may be held beyond the above mentioned period until it is indispensable for us to have relevant information to respond to any issues that may arise later.
8.1. We use relevant electronic and procedural safeguards to protect the privacy of the information you provide to us from loss, misuse, disclosure, alteration, and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you are transmitting over the Internet, or third-party content.
8.2. All our servers used to store and process your Personal Data are compliant with the Payment Card Industry Data Security Standard.
8.3. Any third party with whom we share your Personal Data shall provide at least the same means of data protection, as set forth in this Policy.
9.1. When you access the Platform, we (or Google Analytics or similar service provider on our behalf) may place small data files called cookies on your computer or another device. We use these technologies to recognize you as our user, customize our Platform, understand usage and determine the effectiveness of email marketing campaigns, measure promotional effectiveness and collect information about your computer (as described in clause 5.6 hereof) or other access device to mitigate risk, help prevent fraud, and promote trust and safety. Web beacons (or pixel tags) are electronic images that may be used in our web Services or emails to help deliver cookies, count platform visits, understand usage and determine the effectiveness of email marketing campaigns.
9.2. We use the following types of cookies:
9.3. You may control the use of cookies within your internet browsers' settings. If you reject or delete certain cookies, be aware that the performance of the related features and functions of our Platforms and services may be impaired. You may find further information on how to disable cookies or manage your cookie settings for the browser that you use from the following list:
Please keep in mind that simply disabling all cookies or all of our cookies in your browser settings, may lead to certain sections or features of our Platform not working. Therefore, we recommend using the Cookie Settings on our platform instead of disabling all cookies in your web browser.
9.4. If you want to opt-out of being tracked by Google Analytics, please visit Google Analytics Opt-out page.