Orbital Lottery and Gaming Limited (“OrbitBet”, “we”, “us” or “our”) with head offices located at 17 Ligali Ayorinde Street, Victoria Island, Lagos State, will treat the data you provide us with as private and we shall only utilize it in accordance with this Privacy Policy. This Privacy Policy discusses how we collect and process your personal information through your use of our website (the “site”) and your online account you open with us (the “Account”), to create your Account profile, to ensure security of the website and to enable you to use the products and the Account (collectively the “Services”). For the purposes of the Services, OrbitBet is the data controller of your Personal Data.

1. PERSONAL DATA

• All references to ‘Personal Data’ in this Privacy Policy refer to any personal information about a natural person which enables that individual to be identified directly or indirectly by reference to the data provided.

• The Personal Data we receive helps us provide, personalize, and continually improve the Services. We use the information to enable you to use the Services, process payments, communicate with you about your Account activity, products, services and promotional offers, update our records and maintain your Account with us, display content, and recommend our products and services that might be of interest to you. We also use this information to improve our Services, prevent, detect or report fraud or abuses of our Services and enable third parties to carry out technical, logistical, or other functions on our behalf.
• We may collect the following information when you open an Account with us: first name, surname, gender, date of birth, place of birth, postal address, email address, phone number, language, currency, a valid original copy of an official document bearing your names and photographs (international passport or ID card). You may give us additional information that qualify as Personal Data as part of your use of the Account and/or any of the Services.
• We receive and store certain types of information including Personal Data whenever you interact with us. For example, like many websites, we use “cookies,” and other unique identifiers and we obtain certain types of information when your Web browser or device accesses our Services. Refer to your Web browser cookies setting options for more information on how to manage your cookies settings. Please note that we may not be able to provide you with all the site features and Services functionalities should you block or reject the cookies.
• We may receive information about you from other sources (such as from the payment providers or third-party identity verification service provider) and add it to your Account information.
• For your Account opening, you will also be required to provide login details of your choice, namely a username, password which will be kept by us. We additionally require you to provide us with a payment method and payment details (such as bank transfer, credit card or another acceptable means of payment) in order that you can credit your Account and make the withdrawals.
• You can access a broad range of information about your Account and your interactions with us, including your Personal Data. You may access that information about you by logging into your Account. You also have the right to access your personal data at any time in order to make alterations to any personal information that may have changed or become obsolete. Should you believe that any personal information we hold for you is incorrect, please contact our customer support.

2. PROCESSING OF PERSONAL DATA

• We process your Personal Data to operate, provide and improve the Services. These purposes include to process your bets, payments to and from Account and communicate with you about gaming activity, products, services, and promotional offers; to provide functionality, analyze performance, fix errors, and improve usability and effectiveness of the Services; to recommend features, products, and services that might be of interest to you and to identify your preferences; to communicate with you in relation to the Services via different channels (e.g., by phone, email, chat); to display interest-based ads for features, products, and services that might be of interest to you; to prevent or detect fraud and abuse in order to protect the security of our customers, OrbitBet, and others; and in situations where the law requires same.
• You are however free to object to processing your Personal Data for the purpose of marketing and your objection will be processed free of charge.

3. DATA PROCESSING PRINCIPLES

• collected and processed in accordance with specific, legitimate and lawful purpose consented to by You; provided that:

1. further processing may be done only for archiving, scientific research, historical research or statistical purposes for public interest;
2. any person or entity carrying out or purporting to carry out data processing under the provision of this paragraph shall not any Personal Data to any unauthorized person not required to have the data;

• adequate, accurate and without prejudice to the dignity of human person;
• stored only for the period we need it;
• Secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulation of any kind, damage by rain, fire or exposure to other natural elements.

II. Anyone who is entrusted with your Personal Data or who is in possession of your Personal Data owes a duty of care;

III. Anyone who is entrusted with your Personal Data or who is in possession of your Personal Data shall be accountable for his acts and omissions in respect of data processing, and in accordance with the principles of the Nigeria Data Protection Regulation.

4. DISCLOSURE OF PERSONAL DATA

• Depending on which payment service you use, you may need to disclose your Personal Data or part of it to your payment provider. Note that the payment provider already has your Personal Data to provide you with the payment services and their use of any Personal Data disclosed by us will be regulated by the payment provider’s privacy policy
• We engage with third party service providers such as technology providers, financial institutions, other companies, and individuals to perform functions on our behalf and transactions that you request or authorize by reason of your signing up to our platform and Services. Examples include sending e-mail, analyzing data, providing marketing assistance, processing payment transactions, verifying identity, fraud screening, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes and must process the personal information in accordance with this Privacy Policy and as permitted by the applicable data protection legislation. Such third-party service providers may be based within and outside of Nigeria in jurisdictions including the EEA jurisdictions, and undertake to provide adequate levels of protection of personal data in line with the relevant data protection legislation(s).
• We may display interest-based ads to you when you are using Facebook through advertising tools offered by Facebook. We do not share any of your Personal Data with Facebook as the tools Facebook operate allow us to convert your email address to a unique identifier to match the unique identifiers Facebook generates from the email addresses of its users. We may also use third-party analytics providers, including Google, to collect information about the usage of our Services and to enable us to improve how our Services work. Google Analytics and comparable providers use cookies and other similar technologies to collect information about the usage of our Services and to report website trends to us.
• As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, the user or other customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy. Also, in the unlikely event that OrbitBet or substantially all of its assets are acquired, user information will of course be one of the transferred assets.
• We disclose Account and other Personal Data when we believe disclosure is appropriate or required to comply with the law; enforce or apply our General Terms and Conditions and other agreements we have with you; or protect the rights, property, or safety of our business, our users, or others. This also includes exchanging information with other companies and organizations/government authorities for fraud protection reduction as well as sharing information with our attorneys, auditors, and other representatives.

• OrbitBet shall in no manner whatsoever be held responsible for the manner in which third parties process and/or store the personal data of our customers.
• OrbitBet shall only be responsible for its obligations to you in relation to your Personal Data as the data controller under the applicable laws and it does not warrant the standard of the privacy policies of any of the third parties.
• Our Services may include third-party advertising and links to other websites and apps. We do not provide any personally identifiable user information to these advertisers or third-party websites. If you access a page via a link on our site which takes you to an external website, you take time to read through the privacy policy of the new website which you enter.

5. SECURITY

• We design our systems with your security and privacy in mind.
• We work to protect the security of your information you provide to our web sites by using secure softwares to encrypt your information during transmission.
• We maintain physical, electronic and procedural safeguards in connection with the collection, storage, and disclosure of personal customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
• It is important for you to take steps to protect against unauthorised access to your account and your password. You should keep your password and any security questions confidential. The security of your Account relies on your protection of your password and security questions. DO NOT SHARE YOUR PASSWORD. If you do share your password with a third party for any reason, the third party may have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately and also contact us right away via our customer support.

6. PERSONAL DATA RETENTION

We keep your Personal Data to enable your continued use of the Service, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Policy, as may be required by law such as for anti-money laundering and counter-terrorist financing, tax and accounting purposes, or as otherwise communicated to you. This applies to us retaining your data after you close the Account.

7. PROTECTION OF MINORS

The online betting and gaming services that we offer are strictly prohibited for persons less than 18 years of age or under the age of legal consent for using online betting and gaming services under the laws of the jurisdiction in which you are located. Consequently, minors shall not register and play on our Site. We collect proof of identification from our customers as part of our age verification process. Any minor who is found to be gambling on OrbitBet shall have his/her Account immediately blocked. OrbitBet reserves the right to conduct a security review to validate your identity and age. Registration of the Account authorizes us to conduct such security reviews supplied by you against third party databases.

8. DATA PROTECTION OFFICER

In compliance with Nigeria Data Protection Regulation (2019), we have designated our Head of Legal as our data protection officer. Enquiries regarding your data may be directed to legal@orbitalltd.net.

9. INDIVIDUAL RIGHTS

By opening an Account with us and using our website, you have certain rights available toyou, including –

• the right to be informed, given the need for fairness and transparency over the processing of your personal data;
• the right to access your personal information held by us. Your right of access can be exercised by sending an email to legal@orbitalltd.com.
• the right to ‘block’ or withdraw your consent to our processing of your information, which you can do at any time by closing your Account. When processing is restricted, we might continue to retain such data if there are valid legal, regulatory or operational reasons, but not to further process it. Withdrawal of consent does not affect the lawfulness of the data processing and/or retention that occurred before the withdrawal of the consent by the data subject.
• You are entitled to have personal data rectified if it is inaccurate or incomplete. If this personal data in question has been disclosed to third parties, they must be informed of the rectification where possible. OrbitBet may also inform you about the third parties to whom the data has been disclosed where appropriate.
• You have the right to request the deletion or removal of personal data without prejudice to compelling legal or regulatory requirement for its continued processing or retention.
• You are responsible for making sure the information provided to OrbitBet is accurate and should inform OrbitBet on any changes as it occurs, this will enable us to update your information with us.
• If you are dissatisfied with the way and manner your personal data is being handled by us as your personal data controller, you have a right to first notify us of such dissatisfaction before lodging any complaint with the National Information Technology Development Agency (NITDA).

10. GENERAL

• OrbitBet shall take no responsibility whatsoever for events beyond its control inclusive of, but not limited to, acts of God, natural disasters, flooding, lockdowns, and including power cuts and strikes and all such acts of related nature amounting to a force majeure.
• Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your Account. It may become necessary, at any time, for us to make modifications to this Privacy Policy and we will publish such modifications on the website. Such modifications will not impact your Account registration details unless required to the contrary by law. It is your to regularly check the General Terms and Conditions and Privacy.
• In the event of a perceived violation of this Privacy Policy, you are entitled to seek redress within 7 days of the said violation at a court of competent jurisdiction within Nigeria. Such remedy shall be provided within a period of 30 days from the date of institution of the alleged cause of action.
• Aforementioned provisions in this privacy policy notwithstanding, by registration of an Account, you hereby agree that you are at least 18 years old and have the legal capacity to give consent. Your use and continued use of the Services shall be considered as consent and your acceptance of the terms stated herein.

The Laws of Nigeria shall govern this Privacy Policy. Effective date: August 25, 2022

Updated: August 25, 2022]