General

In order to regulate the processing of personal data of its users, in accordance with the Nigeria Data Protection Regulations (NDPR) 2019, Digibay Ltd (hereinafter, the Company) guarantees full respect and total protection of personal information provided by members (hereinafter referred to individually as Users), the Company intends to inform its users of the following:

Data controller

The Data Controller is the Company, with registered office in Flat B11 Redmenn House, Plot Dideolu Estate. T.Y Danjuma Street Victoria Island, Lagos, for online gaming and betting services, through its own brands (hereinafter, Betway). The User may, at any time, contact the data controller and request in writing any information regarding the Code and its privacy rights.

Information that we collect

We collect personal information about you (“Personal Data”) either because (i) it is required to be able to offer our Services to you or (ii) to improve our Services to you. A full list of why we process your information can be seen below under “How we use your information”. You are under no obligation to provide Personal Data to us, but much of the Personal Data we request is essential for the provision and quality of the Services we offer to you (for example, enabling you to play the games on our Websites). We may not be able to provide you with our Services if you choose to withhold requested information. When you navigate to websites and mobile applications of brands which are managed by Digibay Limited (“Websites”), we collect browser and cookie information. In addition, we may also collect your IP address and technical information relating to the device you are accessing our websites from. During the registration process and when you subsequently use your account, you are requested to submit specific personal data including, but not limited to, your first and last name, date of birth, credit card or other payment data, home or another physical address, e-mail address, phone/mobile number or other contact data. In addition, you will be asked to create a unique user name and password combination for your account. This information is required to be able to access our Services. Once you have created an account and have become a registered customer, additional information is processed on an on-going basis to ensure that our Services are offered to you in the best possible manner. You must use your unique password to access your account. When you are logged into your account, we may collect: • a record of all internet communications and details of your visits to our Websites; • technical information relating to the device, such as device identifier, and browser you use to access our Websites • details of transactions you carry out through the site, such as payments, withdrawals and wagers; • communications with us or our employees, for examples calls, emails, and messages sent through the live chat service; • information regarding your location, including IP address. In certain instances, we may also request that you send us additional information to verify your identity. This may include copies of photographic identification documents, proof of address, and source of funds for your account. Your documents are stored and treated in a secure manner at all times. In some limited instances we may conduct open source checks which access public records and publicly available information about you, such as news articles, social media, forums and official records such as the electoral roll. To protect both you and us, we use services provided by third parties to help us decide whether to accept transactions from you by assessing your method of payment, and the devices you use to visit our Websites. These third-party services check whether the device or method of payment has been identified with fraudulent or abusive transactions in the past, such as reported instances of identity theft, promotion abuse or credit card fraud.

How we use your information

We use the information we collect to provide, maintain, protect and improve our Services, to develop new ones and to protect both the Operator and You. We also use this information to offer you tailored content – like giving you more relevant promotional offers. We process your Personal Data for the purposes of: • creating and managing your account; • providing you with gambling services; • if necessary, contacting you via your registered contact information in connection with the management and operation of your account; • processing your online financial and wagering transactions; • researching your preferences, to develop new features, functionality, products and services; • ensuring our Websites function correctly and identifying any technical issues; • complying with all our legal and regulatory requirements, such as those relating to the identification of individuals under anti-money laundering legislation and ensuring responsible gambling; • preventing fraudulent activity or cheating; • determining what promotions and bonuses to offer you; and • providing you, unless you have opted out, with information by the contact methods you authorise us to use about our, and selected third party services, products, competitions, prizes and offers. We actively manage our financial liabilities and risk on events and markets. Liability and exposure controls can be applied across betting markets and or across individual accounts to manage those liabilities. The Operator may assess your data to determine motivations for opening an account or placing a bet. Should your activity stand out from what we consider to be usual and expected behaviour, or fit into certain known patterns that denote potential exposure and liability concerns, further analysis is performed. In line with our terms and conditions, we may exclude you from certain promotions or from placing certain bets as a result of this investigation. Examples of unusual betting behaviour can be, though is not limited to: • larger than expected bets appearing on a very specific outcome, for example a correct set score in an ITF Tennis match; • a bet being placed by a customer who may be privy to information regarding the potential outcome of an event; • a customer changing their established betting pattern; • an alert from a sport’s governing body or monitoring agency; and • a large number of bets placed in a short time period on one specific outcome. Any analysis performed is a private business owned commodity and is not transmitted to any third party. We reserve the right to apply restrictions to customer accounts where it believes it to be appropriate to their betting activity.

Who we share your data with

Certain trusted third party companies provide services essential to our ability to offer our gambling products to you, including: • those that supply the software and games for our Websites; • banking and payment services; • identity verification companies; • fraud prevention and risk management companies. We are required to share some of your information with these companies to be able to offer our Services to you. In these instances, we ensure that the third party has appropriate security and privacy arrangements in place, so that your data is protected. We may also be required to disclose your information to government authorities, such as the police or our regulators, to comply with our legal obligations. Personal information may also be shared with regulators, agencies or relevant sports bodies where there are suspicions of involvement in match-fixing or breach of sports regulations. We will also disclose information as required to enforce our terms of use as stated in the Terms and Conditions. In the event of the sale of our business, or other business event, which results in us having to transfer your personal data to a third party, you will be notified via email, or notice posted on our website, to explain the identity of the new data controller and your options regarding your personal data. Our site may contain links to and from the Websites of third party organisations. Please note that these Websites may have their own privacy policies and that we do not accept any responsibility whatsoever for these policies. Please check these policies carefully before you submit any personal data.

Marketing and Opting Out

The Operator reserves the right to process personal data for marketing purposes and in certain limited circumstances to provide this to our third-party partners for the purpose of marketing our services to you. We request your consent to market to you when you first create an account with us. You can choose not to receive marketing/promotional material at any time. Opting Out or denying such consent has no influence on the registration of a gaming account. If you have opted out of marketing from us, we will take all reasonable steps to ensure you no longer receive promotional material about our services. This may affect your eligibility for certain promotional bonuses. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send out periodic e-mails informing you of technical, service or security issues related to a product or service you requested, confirming you requested a product or service, or providing periodic updates or information relating to the product or service you requested.

Access to your information

We respect your privacy rights and therefore you may contact us at any time and request the following: • You have the right to access the Personal Data we hold about you. • You have the right to ask us to rectify your Personal Data if it becomes inaccurate or incomplete. o Note that you should update us if there are any changes or inaccuracies in your Personal Data. o You may also have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement. Whether or not this is appropriate in any particular case depends on the purposes for which your information is being processed. • You have the right to ask us to erase your Personal Data if: o your Personal Data has been processed unlawfully by us; or o your Personal Data is no longer necessary for the purposes for which it was collected by us; or o You object to processing and there is no overriding legitimate interest for continuing to process your personal data. • You have the right to restrict our processing of your Personal Data if: o you contest the accuracy of the Personal Data held by us (for a period enabling us to verify the accuracy of the Personal Data); o our processing activities are unlawful; or o we no longer need your Personal Data but you would like us to retain it to ensure its continued availability to you in connection with any legal claims. o You can object to our processing of your Personal Data under certain circumstances, including where processing takes place in line with our legitimate business interests as set out above. Where you object to processing, we must stop processing your Personal Data unless we can show that our legitimate grounds for processing of your Personal Data overrides your interests or where we need to process the data to establish, exercise or defend legal claims. o Request your data to be transmitted to another data controller. • To ask that your Personal Data will be provided to you in a machine readable portable format, where possible This right only applies: o to Personal Data you have provided to us; o where the processing is based on your consent or for the performance of a contract; and o when processing is carried out by automated means. Kindly note that the above rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request, for example, refuse your request where we need to process the data to exercise or defend legal claims. In addition, in certain instances, your Personal Data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. To exercise such rights, you are required to submit a request, detailing what information you wish to enquire about, together with proof of identity to customer support at [email protected]. If you wish to raise a complaint on how we have handled your Personal Data, please contact us directly at [email protected]. If you are not satisfied with our response or believe we are collecting or processing your Personal Data not in accordance with the laws, you can complain to the applicable data protection authority.

Cookie Policy

Cookies are text files containing a small amount of information that are downloaded to your device when you visit a website. They are generally used by most websites to improve your online experience and to ensure that content and functions are delivered and used more effectively. Cookies perform various different functions. For example, some cookies are session cookies, which are downloaded to your device temporarily for the period that you browse a particular website; these cookies might allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Other cookies are persistent cookies, which can be used to help websites remember you as a returning visitor or ensure the online adverts you receive are more relevant to your specific needs and interests. The primary use of cookies on our Websites, either directly by ourselves or our chosen partner(s), is to: enable you to save time and facilitate future access to the site; identify how people navigate through our website to improve our Service, content and the effectiveness of our communications; collect and share device data to detect and prevent devices associated with fraud and money laundering; identify account and device irregularities and detect and prevent fraudulent transactions and abuse of our customer accounts and our Services. You agree that the Operator may, from time to time, place cookies on your device to save information (such as user name, password, other personal details, e-mail address, technical device information such as the model and its IP address) to make full use of the functionality and Services on our website and to allow your browser to identify you as a user. This enables you to not have to re-enter this information each time you visit the Betway site. These cookies cannot be used to run programs or deliver viruses to your computer, and are uniquely assigned to you. These cookies can only be read by the web server(s) that placed the cookies on your device. At any time, you can amend your browser settings to block some or all cookies from the Operator. However, if you block cookies from us some or all the website's functions may not perform as intended. For example, you may not actually be able to place any bets. Further information about cookies can be found at: https://:www.allaboutcookies.org

Storage of Personal Data

The data we collect from you may be transferred to, and stored at, a destination outside of the Federal Republic of Nigeria. It may also be processed by staff operating outside Nigeria who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and the requirements established by the applicable data protection regulations, including by ensuring that such territories ensure an adequate level of protection, or were deemed as the use of standard data protection clauses (where applicable). Once we have received your information, we will use strict procedures and security measures to prevent unauthorised access and ensure the integrity and availability of personal data. We are required to keep full records of all financial and wagering transactions together with any identification provided. We will hold your Personal Data on our systems for as long as is necessary under our legal obligations.

Retention

Except as otherwise permitted or required by applicable law or regulatory requirements, we endeavour to retain your Personal Data only for as long as we believes is necessary to fulfil the purposes for which the Personal Data was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your Personal Data, make it anonymous such that it cannot be associated with or traced back to you.

How we keep your information secured

We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store. We employ industry standard procedures and controls to ensure the safety of our users’ information, such as: • Secure network topology, which includes intrusion prevention and Firewall systems; • Encrypted communication; • Authentication and Access Control; • External and Internal audit tests; etc. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Minors

The services are not designated to users under the age of 18. If you are under 18, you should not use the Services nor provide any Personal Data to us. We reserve the right to access and verify any Personal Data collected from you. In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected].

Support

If you wish to unsubscribe from marketing communications, please contact Customer Support on: [email protected] If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send it to our Data Protection Officer at: [email protected] for attn: Data Protection Officer Document Updated: 29 January 2021

Last updated: 02/11/2021

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