ng.7k.bet is an online entertainment website operated by Vibes Technology Ltd, a company duly incorporated and registered in Lagos under registration number 8704044, which has duly complied with all applicable regulatory requirements and is duly authorized to operate as a gaming operator in Lagos State in the Online Casino and Sports Betting categories, holding an Online Casino License under license number LSLGA/OP/OCAS/7KB030925 and a Sports Betting License under license number LSLGA/OP/OSB/7KB030925, both valid until 02 September 2026.

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Terms and Conditions

Last Updated Date: January 28, 2026

1. ACCEPTANCE

1.1. These General Terms and Conditions of Vibes Technology Ltd (“Terms”), a company registered under number 8704044, with its registered office at Jubilee Road, Magodo II, Kosofe, Lagos State, govern the access to and use of the online platform https://ng.7k.bet/ by internet users (“Users”).

1.2. The User may only use the services provided by Vibes Technology Ltd after expressly agreeing to these Terms.

1.3. The sections set out below are complementary to these Terms and may contain relevant information about the use and operation of the Services in addition to those provided in these Terms. Therefore, the User undertakes to become aware of their full content.

2. SERVICES

2.1. The Services offered through the platform consist of:

Supplying, marketing, promoting, managing, supporting and operating all types of remote gaming activities, comprising all types of games, betting and other interactive games.

2.2. Vibes Technology Ltd holds a valid Certificate of Operation issued in Lagos, Nigeria, under application number LSLGA/OP/OCAS/7KB030925, for the online casino category and a Sports Betting License under license number LSLGA/OP/OSB/7KB030925 both valid until 02/09/2026, granted by the Lagos State Lotteries and Gaming Authority. Under these Certificates of Operation, the company is permitted to continue its operations.

2.3. Any questions about the Services offered can be resolved through the platform itself or through the Customer Service Center (via email or chat), whose details will be made available on the platform.

3. CONDITION FOR PARTICIPATION

3.1. To use the Services, the User must be a natural person, over 18 years of age, and legally capable. Prior registration on the platform will be necessary, simply by following the instructions contained in the \"How to Participate\" section or equivalent.

3.2. The User guarantees and is responsible for the veracity, accuracy, validity and authenticity of the data contained in the registration filled out by them, committing to keep it duly updated.

3.2.1. Vibes Technology Ltd assumes no obligation to police or supervise the information provided by the User, but may, at its sole discretion, exclude information that appears to be untrue or offensive.

4. PLATFORM ACCESS PASSWORDS

4.1. The password used by the User is personal and non-transferable, and it is the User's responsibility not to pass it on to third parties, for their own security.

4.2. It is forbidden to pass on the access password to third parties.

4.3. Vibes Technology Ltd will not have access to the User's personal password, as their personal password is encrypted. No employee or representative of Vibes Technology Ltd is authorized to request, for any reason whatsoever, the User's password.

4.4. The password may be changed by the User at any time, through the Digital Platform.

4.5. The User undertakes to immediately inform Vibes Technology Ltd via support channels of the loss, theft or misplacement of the password, so that the appropriate measures can then be taken.

4.6. The User undertakes not to authorize, and to take all measures within their reach to prevent their registration from being accessed and/or used by any third parties, paying special attention to access and/or use via mobile application, being responsible for any assignment of their private password.

5. GAME AND BETTING MODALITIES

5.1. Vibes Technology Ltd will make various game and betting modalities available on its Digital Platform, in accordance with applicable licenses and regulations. The specific rules for each game and bet will be detailed on the platform itself.

5.1.1. It is the responsibility of Vibes Technology Ltd to include, change and even exclude services and/or products from the Digital Platform, regardless of prior notice, and the User has no right to indemnification and/or reimbursement for the changes made.

5.1.2. Bets and participation in games may be placed on the Vibes Technology Ltd Digital Platform within the deadlines and conditions established for each specific game or event, as informed on the platform.

5.2. In case of impossibility of processing bets or games in a timely manner for the event chosen by the USER, due to unforeseeable circumstances or force majeure, such as technical and/or operational problems, adverse weather conditions, exclusive fault of a third party, among others, Vibes Technology Ltd is exempt from any liability, automatically canceling the bets placed with a full refund of the amount paid.

5.3. Vibes Technology Ltd will be responsible for the registration and processing of bets placed on its platform.

5.4. In extraordinary situations, if a game or betting modality is discontinued, Vibes Technology Ltd undertakes to return the amount wagered to the User's account in the form of platform debit or bank deposit, according to internal policies.

5.5. Under no other circumstances will amounts already disbursed, whether as payment for Services, be returned to Users, except for extraordinary reasons duly justified, considering the deadlines stipulated in Chapter 6 below.

6. CANCELLATION AND WITHDRAWAL

6.1. Once bets are confirmed on the Vibes Technology Ltd platform, no refund or cancellation of any betting modality will be allowed, except in the situations mentioned in item 6.2 of these Terms of Use or in the specific rules of each game.

6.2. The refund and/or cancellation of bets will only be allowed in the following ways: (i) within the withdrawal period established for each game/bet, if applicable and explicitly informed on the platform; (ii) in cases of proven technical failure of the platform that prevents the bet from being placed; or (iii) as determined by Vibes Technology Ltd's fair gaming policies.

6.3. Refunds or withdrawals of bets will not be allowed after the start of the event or draw to which the bet refers.

6.4. If any suspicious actions constituting fraud (inconsistencies or irregularities in the purchase/bet) are detected, Vibes Technology Ltd reserves the right to cancel the order immediately.

6.5. Refunds and/or cancellations allowed under item 6.2 above must be requested through Vibes Technology Ltd's customer service channels, whose details will be made available on the platform.

7. REMUNERATION FOR SERVICES

7.1. For the provision of services offered to Users, Vibes Technology Ltd will receive a fixed remuneration consisting of the difference between the total amount paid by the User and the operational costs and/or commissions retained by Vibes Technology Ltd for the execution of the respective bet or game participation.

7.1.1. The remuneration does not include any expenses with bank transfers, taxes or others possibly due as a result of the withdrawal and/or payment of prizes to winning Users.

7.2. In case of a prize, Vibes Technology Ltd may retain a commission on the prize, as detailed in the specific rules of each game or bet.

7.3. Vibes Technology Ltd may charge access fees or participation fees for certain games, with all informative content (tips, information, statistics, etc.) being accessed free of charge, unless otherwise stated.

8. PAYMENT OF BETS

8.1. Payments for bets are processed by specialized payment methods, which facilitate communication between credit/debit card issuers and the Vibes Technology Ltd Platform, or by other payment methods made available.

8.2. All transactions are submitted to risk assessment by the specialized service provider, without any direct participation or influence from Vibes Technology Ltd in the credit approval process, reserving the final acceptance of the transaction.

8.3. Payment for the services available on the ng.7k.bet platform may be made through the payment methods offered on the platform (e.g., bank transfers, credit card, e-wallets), within the deadlines and conditions specified for each game or bet.

8.3.1. Installment payments for purchases on the platform are not permitted; only single payments are accepted, unless expressly indicated otherwise for specific promotions.

8.4. After payment confirmation, the platform will register the games selected by the User.

8.4.1. The registration of the game will be informed to the user via email and/or notification on the platform, confirming that the game has been duly registered.

8.4.2. The payment receipt is not proof of game registration, as informed in item 8.4.1. above.

8.4.3. The User can also track the process of their game by accessing \"My Account\" > \"My Orders\" or equivalent and checking if the selected game appears as “confirmed”.

9. PRIZES AND PRIZE REDEMPTION ON THE PLATFORM

9.1. In case of a prize, ng.7k.bet platform will notify the winning User directly via platform, email and/or telephone number provided in their registration. The User may request the respective credit to their platform account or to their bank account, subject to the provisions below.

9.2. The bank account used for receiving amounts must necessarily be held by the User who placed the winning bet, as per the registration made on the Portal. No amount will be delivered to the User in cash, nor will it be deposited into bank accounts held by third parties.

9.3. Prizes shall be paid by the ng.7k.bet website directly to the User, in accordance with the specific rules applicable to each game and subject to the minimum and maximum limits displayed on the withdrawal request screen, up to a maximum of 500,000 Nigerian Naira per day, and up to 300,000 Nigerian Naira for automatic withdrawals.

9.4. Vibes Technology Ltd will define limits for prize redemption directly on the platform and for redemptions that require contact with support, with these limits being informed on the ng.7k.bet support team and subject to change without prior notice.

9.5. For high-value prizes, the website ng.7k.bet may require additional identity verification procedures and/or request the User to appear in person at a designated location for prize collection, or to formally authorize the prize withdrawal for subsequent credit to their bank account. The deadlines for bank account credit may vary from 5 (five) to 10 (ten) business days, or more, depending on the analysis and security procedures.

9.6. For prize receipt purposes, the total prize amount of the winner will be considered.

9.7. Prizes can only be redeemed in their entirety and cannot be partially redeemed, unless otherwise specified in the rules of specific games.

9.8. Amounts resulting from prizes may be credited to the User's account on the Vibes Technology Ltd Platform for use in new purchases or games, if this option is made available. Otherwise, this amount is exclusively for redemption.

9.9. Bank transfers made by ng.7k.bet to Users, resulting from prize amounts, will be subject to bank fees already established by the competent regulatory agency.

10. ACCESS TO SERVICES

10.1. Vibes Technology Ltd may, at its sole discretion, at any time, and without the need for prior communication to the User:

10.1.1. Terminate, modify or suspend, totally or partially, the User's access to the Application, or even to the platform, when said access or registration is in violation of the conditions established in these Terms.

10.1.2. Exclude, totally or partially, the information registered by the User that is not in accordance with the provisions of these Terms.

10.2. At any time, provided that authorized by the User, the website ng.7k.bet may send the User email messages or other informative, commercial and/or promotional correspondence, unless the User expressly does not consent to the use of their data for sending mailings. If the client no longer wishes to receive emails, they can deactivate them by following the procedure indicated on the platform.

10.3. Communication automatically sent in response to a specific User action, such as a purchase confirmation or order status update, cannot be unsubscribed, as it contains essential information related to the transaction performed.

11. LIMITATIONS OF USE

11.1. The User may not:

a) Copy, assign, sublicense, sell, lease or pledge, reproduce, donate, alienate in any way, transfer totally or partially, under any modalities, gratuitously or onerously, temporarily or permanently, the Vibes Technology Ltd, as well as its modules, parts, manuals or any information related thereto;

b) Employ software, techniques and/or artifices with the intent to unduly use the ng.7k.bet website for practices harmful to Vibes Technology Ltd or third parties;

c) Reproduce, adapt, modify and/or employ, in whole or in part, for any purpose, the ng.7k.bet website or any content without the express authorization of Vibes Technology Ltd;

d) Publish or transmit any file that contains viruses, worms, Trojan horses or any other contaminating or destructive program, or that may otherwise interfere with the proper functioning of the Vibes Technology Ltd;

e) Perform reverse engineering.

12. LIMITATION OF LIABILITY AND INDEMNIFICATION

12.1. Vibes Technology Ltd will not be liable, under any circumstances, not even jointly or subsidiarily:

a) For any losses suffered by the User due to decisions made based on the information provided on the platform or Application;

b) For any losses suffered by the User due to failures in the computer system, telephony or servers that are independent of ng.7k.bet website’s fault, or in its connectivity to the internet in general, and the User must maintain, at their own expense, a telecommunication line, modem, communication software, email address and other resources necessary for communication with Vibes Technology Ltd;

c) For any losses suffered due to fraud committed by third parties, and the User must maintain, at their own expense, software and measures for protection and prevention against viruses, Worms, etc.;

d) For situations of unforeseeable circumstances or force majeure.

12.2. Vibes Technology Ltd DOES NOT guarantee that the functions contained in the Platform meet all User needs, that the operation of the Platform will be uninterrupted or error-free, that any functionality will continue to be available, that defects in the Platform will be corrected or that the Platform will be compatible or work with any Application, third-party applications or services.

12.3. The User agrees to defend, indemnify and hold harmless Vibes Technology Ltd and its affiliates, directors, employees and agents, from and against any charges, actions or demands, including, but not limited to reasonable attorneys' fees, resulting from: (i) their eventual improper use of the platform and the Application, or (ii) their violation of the conditions now agreed upon.

12.4. In no event will Vibes Technology Ltd be liable for personal damages or any incidental, special, indirect or consequential damages, lost profits, including, without limitation, damages for loss of profit, corruption or loss of data, failure to transmit or receive data, loss of chance, business interruption or any other commercial loss or damage, arising out of or related to their use or inability to use the Application, for any other reason.

13. TERMS OF USE OF OTHER PARTNERS AND THIRD PARTIES

13.1. The ng.7k.bet website or applications may contain links to partner companies, and these have their own terms and conditions.

13.2. Vibes Technology Ltd is not responsible for the terms and conditions of use of any other website that is related to ng.7k.bet website or applications, whether through links or other forms of dissemination and access.

14. VALIDITY

14.1. These Terms will be effective for an indefinite period, from the User’s acceptance, and may be modified or terminated unilaterally by Vibes Technology Ltd at any time, without any burden, upon simple communication through the Portal itself or by message to the email indicated in the User’s personal registration.

16. PREVENTION OF MONEY LAUNDERING AND PROHIBITED EVENTS

16.1. Transaction Monitoring:

16.1.1. Vibes Technology Ltd is committed to maintaining a fair and ethical online environment. Recognizing the importance of integrity in our services, we have implemented rigorous measures to monitor transactions and prevent money laundering. If, in our reasonable discretion, we determine that a user has been involved in any Prohibited Event, we reserve the right to:

a) Annul any transaction associated with the Prohibited Event.

b) Retain all or part of the balance in any account or registration with ng.7k.bet website used by the user.

16.1.2. Vibes Technology Ltd will carry out additional verification procedures for any transaction or transactions and reserves the right to carry out these verification procedures even in the case of lower payments. All transactions will be verified to prevent money laundering.

16.2. Defined Prohibited Events:

For the purposes of this section, Prohibited Events are considered to be:

16.2.1. If at any time the user provides incorrect or misleading registration details for their Account;

16.2.2. If at any time the user fails to meet or comply with any of the verification requirements and/or any verification or request for information reasonably necessary to meet our legal, regulatory or internal requirements;

16.2.3. If the user deliberately or fraudulently holds one or more duplicate accounts;

16.2.4. If it is discovered or there are reasons to believe that the security of the user's account has been compromised, for example, because the user failed to maintain the confidentiality and security of their Login credentials;

16.2.5. If it is discovered or there are reasons to believe that the user has violated the security of another user's account;

16.2.6. If a fraudulent chargeback and/or return notification is received through a payment method used in the user's account;

16.2.7. If it is discovered or there are reasons to believe that the user has abused or taken advantage of any error, malfunction or interruption;

16.3. User Obligations:

Immediately inform Vibes Technology Ltd of any suspicion or knowledge of a Prohibited Event committed by any user.

Cooperate reasonably in investigations, providing the requested information.

16.4. Restriction, Suspension and Termination of Accounts:

16.4.1. Vibes Technology Ltd reserves the right to restrict, suspend or terminate user accounts in situations that compromise the integrity of gaming services. Such measures may include:

a) Restriction of access to certain games or functionalities.

b) Temporary suspension of the account.

c) Permanent termination of the account.

16.4.2. Reasons for Restriction, Suspension or Termination:

a) Participation in Prohibited Events.

b) Violation of Vibes Technology Ltd's usage policies.

c) Activities that compromise the security or integrity of the services.

d) Non-compliance with legal or regulatory requirements.

16.4.3. Communication to the User:

16.4.3.1. We will communicate to the user the specific reason for any restriction, suspension or termination of account, whenever possible.

17. GENERAL RULES, APPLICABLE LAW AND CHOICE OF FORUM

17.1. By using the Services, the User undertakes to act responsibly and moderately, as well as to respect the law, morality and good customs.

17.2. The provisions contained herein and any other policies disclosed by Vibes Technology Ltd constitute the rules that specifically govern the relationship between the User and Vibes Technology Ltd, superseding and revoking any and all understandings, proposals, agreements, negotiations and discussions that may have occurred previously between the parties, so that the User is presumed to have full knowledge and irrevocable and irreversible consent.

17.3. The relationship between the User and Vibes Technology Ltd. is governed by the laws of Lagos, Nigeria, where the company is incorporated.

17.4. Due to national and international rules for the prevention of money laundering and the financing of criminal activities, Vibes Technology Ltd may voluntarily share with governmental bodies information in any way related to the registration, operations and eventual prizes of its Users. It may also forward any information of which it is aware, and which may be requested by governmental bodies, regardless of notification or warning to the User.

17.5. The inability or impossibility of Vibes Technology Ltd to exercise or enforce any right or provision contained herein does not constitute a waiver of that right or provision.

17.6. The declaration of nullity or unenforceability of any item, term or provision contained herein will not imply the nullity or unenforceability of any other items, terms or provisions contained herein, which will remain in full force and whose effects will not be affected.

17.7. The User does not acquire any intellectual property rights over or in any way related to the platform, the Application or any functionality or component that may be made available by Vibes Technology Ltd.

17.7.1. Under no circumstances will the User have access to the source code of the Application, as it is the intellectual property of Vibes Technology Ltd.

17.8. Any and all content made available by Vibes Technology Ltd, on the platform or in the Application, including, but not limited to texts, graphics, images, logos, icons, photographs, editorial content, notifications, software and any other material, belong exclusively to Vibes Technology Ltd., and are protected by applicable law regarding intellectual property and copyrights.

17.9. Vibes Technology Ltd is not a financial institution.

17.10. Vibes Technology Ltd and its contracted collaborators undertake to act in accordance with the legislation in force on the protection of data relating to an identified or identifiable natural person (\"Personal Data\") and the determinations of the Regulatory/Supervisory Bodies on the matter, especially the provisions of the applicable data protection law, as well as other applicable personal data protection laws, norms and policies.

17.10.1. In this sense, Vibes Technology Ltd has a document called Privacy Policy (\"Policy\") that explains clearly and accessibly how your information and data will be collected, used, shared and stored through our systems. The Privacy Policy can be consulted at any time.

17.11. The parties elect the forum of Lagos, Nigeria as the sole competent to resolve any disputes and/or demands that may involve the Parties in relation to the use of the Services and access to the platform.

17.12. The User declares to be aware of the rights and obligations arising from these Terms, having read, understood and accepted all terms and conditions.

","term_file","created_at","28/01/2026 03:01","updated_at","deleted_at","countries","[]","all_countries","all_languages",{"_381":42,"_509":510,"_511":526,"_513":234,"_514":527,"_516":-5,"_517":518,"_519":518,"_520":-5,"_23":528,"_521":522,"_523":241,"_524":234},"ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING POLICY","

VIBES TECHNOLOGY LTD

ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING POLICY

Address: 90, Allen Avenue, Ikeja, Lagos, Nigeria

Gaming License: Online Casino Category, issued by the Lagos State Lotteries and Gaming Authority (LSLGA), License No. LSLGA/OP/OCAS/7KB030925, valid until 02 September 2026.

Date of Issue: 20th of January 2026

Policy Drafted and Approved by: Legal and Compliance teams.

Version: 01.

Table of content

Purpose
Regulatory Framework
Integration with International AML and CFT Standards
Application of Nigerian Legislation
Money Laundering (Prevention and Prohibition) Act, 2022
Terrorism (Prevention and Prohibition) Act
Economic and Financial Crimes Commission Act
Lagos State Lotteries and Gaming Authority Regulations
Governance Structure and Compliance Team Activities
Risk-Based Approach
The Bettor as the Subject of the Policy
Bet Analysis and Corruption Prevention
Cryptoassets and Enhanced Controls
Reporting of Suspicious Transactions
Recordkeeping, Audit and Data Retention
Legal Effect and Review

1. Purpose

The purpose of this Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) policy is to establish a clear framework for the identification, prevention, and reporting of potential money laundering (ML) and terrorist financing (TF) activities within Vibes Technology Ltd in compliance with the relevant laws and regulations of Nigeria, including the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism Prevention and Prohibition Act, 2022 and the Central Bank of Nigeria (CBN) Regulations.

Vibes Technology Ltd is committed to ensuring that its operations are free from involvement in any financial crimes, including but not limited to money laundering and the financing of terrorism. This policy is designed to mitigate the risks of the company being used as a vehicle for such illicit activities, promote transparency, and maintain the integrity of the gaming industry in Nigeria.

This Policy constitutes a mandatory compliance instrument with international AML and CFT standards and with the applicable legislation of the Federal Republic of Nigeria, forming an integral part of the Company’s governance, integrity and compliance framework.

2. Regulatory Framework

Vibes Technology Ltd acknowledges its legal obligations under the applicable laws and regulations in Nigeria governing Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) and commits to operating in full compliance with these frameworks.

As an operator licensed by the Lagos State Lotteries and Gaming Authority, the Company is legally required to adopt effective controls for the prevention of money laundering and terrorism financing, due to the inherent risk associated with gaming and betting activities, as recognized by both Nigerian authorities and international regulatory bodies.

Failure to comply with the obligations set forth herein may result in administrative, civil and criminal sanctions, including license suspension, monetary penalties and personal liability of directors, officers and employees.

3. Integration with International AML and CFT Standards

Vibes Technology Ltd is committed to maintaining the highest standards of compliance with international norms and practices regarding Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).

The structure of this Policy reflects the Recommendations of the Financial Action Task Force (FATF), requiring gaming operators to adopt a risk-based approach, conduct customer identification, monitor transactions, and report suspicious activities.

The United Nations Conventions against Transnational Organized Crime and the Financing of Terrorism underpin this Policy.

4. Application of Nigerian Legislation

This Policy has been drafted in strict compliance with Nigerian laws, including:

Money Laundering (Prevention and Prohibition) Act 2022:

Customer due diligence, suspicious transaction reporting, and record keeping.

Terrorism Prevention and Prohibition Act, 2022:

Monitoring and reporting of terrorism financing.

Central Bank of Nigeria (CBN) AML/CFT Guidelines:

Customer identification, transaction monitoring and reporting to NFIU.

Economic and Financial Crimes Commission Act:

Full cooperation with EFCC investigations.

Lagos State Lotteries and Gaming Authority Regulations:

Maintenance of integrity, transparency and internal control.

5. Governance Structure and Compliance Team Activities

The Company maintains an independent compliance team responsible for:

• Validating KYC and due diligence processes

• Monitoring transactions and betting behavior

• Assessing ML/TF risks

• Account suspension or termination

• Reporting to authorities

• Training staff annually

6. Risk-Based Approach

The Company adopts a Risk-Based Approach (RBA) including:

• Customer risk assessment

• Transaction monitoring

• Enhanced due diligence

• Reporting to NFIU

• Ongoing review of risks

Risk factors include bettor profile, transaction volume, crypto usage and geographic origin.

7. The Bettor as the Subject of the Policy

All bettors are subject to AML controls. The Company may:

• Request documentation

• Restrict or suspend accounts

• Cancel transactions

• Terminate relationships

These measures are legal obligations.

8. Bet Analysis and Corruption Prevention

The Company monitors betting behavior to detect:

• Abnormal patterns

• High-volume low-risk bets

• Financial circulation behavior

• Match-fixing indicators

Employees are trained to identify suspicious activity.

9. Cryptoassets and Enhanced Controls

Enhanced monitoring applies to crypto transactions, including:

• Wallet analysis

• Transaction tracing

• Risk scoring

• Internal audits

10. Reporting of Suspicious Transactions

Suspicious activities are reported to the Nigerian authorities without notifying the bettor.

Monitoring systems are reviewed regularly for effectiveness.

11. Record-Keeping, Audit and Retention

The Company maintains records for a minimum of five (5) years, including:

• Customer data

• Transactions

• Compliance reports

Records are available for audits and regulatory review.

12. Legal Effect and Review

This Policy is legally binding on all employees, contractors and partners.

Failure to comply may result in disciplinary or legal action.

The Policy is reviewed periodically to ensure compliance with Nigerian law and international standards.

","aml-policy",{"_381":46,"_509":510,"_511":530,"_513":234,"_514":531,"_516":-5,"_517":532,"_519":532,"_520":-5,"_23":533,"_521":522,"_523":241,"_524":234},"PRIVACY POLICY","

VIBES TECHNOLOGY LTD

PRIVACY POLICY

Address: 90, Allen Avenue, Ikeja, Lagos, Nigeria

Gaming License: Online Casino Category, issued by the Lagos State Lotteries and GamingAuthority (LSLGA), License No. LSLGA/OP/OCAS/7KB030925, valid until 02 September 2026.

Date of Issue: 20th of January 2026

Policy Drafted and Approved by: Risk, Legal and Compliance teams.

Version: 01.

Table of content

1. Purpose and Legal Basis

2. Scope and Applicability

3. Applicable Regulatory Framework and Integration with the Policy

4. Categories of Personal Data Processed

5. Legal Bases for Data Processing

6. Processing of Bettor Data

7. Data Sharing and Transfers

8. Information Security and Governance

9. Data Retention and Deletion

10. Bettor Rights

11. Compliance Structure and Responsibilities

12. Regulatory Impact and Consequences of Non-Compliance

1. Purpose and legal basis

1.1. This Privacy Policy establishes the principles, rules, and procedures adopted by the operator for the processing of personal data, ensuring that all operations comply with Nigerian legislation, the requirements of the Lagos State Lotteries and Gaming Authority (LSLGA), and international standards for data protection and AML.

1.2. This Policy is not merely declaratory but constitutes a mandatory regulatory compliance instrument essential for the maintenance of the gaming license and for the mitigation of legal, financial, and reputational risks.

2. Scope and Applicability

2.1. This Privacy Policy applies to all personal data collected and processed by Vibes Technology Ltd (\"we\", \"our\", or \"us\") through our gaming platform, mobile applications, websites, and any other online services we offer (\"Services\"). This policy is relevant to all users of our Services, including players, account holders, and visitors, regardless of their location, who interact with or engage with our gaming platform.

2.2. This Privacy Policy covers the collection, use, disclosure, and protection of personal data we gather through your use of our Services, as well as the management of your data rights under Nigerian data protection laws.

2.3. This Policy applies to:

• All bettors who create or maintain accounts on the platform;

• Users who place bets, make deposits, request withdrawals, or otherwise interact with the platform;

• Third parties whose data is processed in the context of regulated operations.

3. Applicable Regulatory Framework and Integration with the Policy Nigeria Data Protection Regulation (NDPR)

3.1. The NDPR establishes that any entity processing personal data in Nigeria must:

• Collect data lawfully and transparently;

• Limit processing to the stated purpose;

• Implement appropriate technical and organizational security measures.

3.2. This Policy operationalizes the NDPR by:

• Clearly defining which data is collected and for what purposes;

• Establishing access, security, and retention controls;

• Ensuring that bettor data is used exclusively for service provision, regulatory compliance, and the prevention of financial crimes.

3.3. Lagos State Lotteries and Gaming Authority Law, 2021

The legislation governing the LSLGA requires licensed operators to:

• Protect player data;

• Ensure the integrity, transparency, and reliability of operations;

• Cooperate with regulatory and supervisory authorities.

This Policy forms part of the control framework required by the LSLGA and serves as documented evidence of:

• Adequate governance;

• Bettor protection;

• Compliance with licensing obligations.

3.4. International Standards (FATF and Global Best Practices)

Although not directly binding, international standards influence local regulatory interpretation, particularly in operations involving crypto assets.

3.5. Integration with the Policy

This Policy adopts principles of data minimization, accountability, and security aligned with such standards, strengthening the operator’s regulatory and banking acceptance.

4. Categories of Personal Data Processed

4.1. We collect and process the following categories of personal data when you interact with our Services:

• Personal identification data;

• Contact information;

• Financial and transactional data;

• Data used for identity verification and AML purposes;

• Activity records and betting history.

5. Legal Bases for Data Processing

5.1. We process your personal data in accordance with Nigerian data protection laws, including the Nigeria Data Protection Regulation (NDPR) and other relevant legal frameworks.

5.2. Personal data is processed on the basis of:

• Compliance with legal and regulatory obligations;

• Performance of the betting contract with the bettor;

• Prevention of fraud, money laundering, and terrorism financing.

5.3. These bases directly reflect the requirements of the NDPR and AML legislation.

6. Processing of Bettor Data

6.1. As part of our operations, we collect and process personal data of individuals who participate in betting activities, including users who place bets, participate in contests, or engage in other gambling-related services (\"bettors\"). The processing of bettor data is necessary to ensure the integrity, security, and fairness of our betting services.

6.2. Bettor data is processed in order to:

• Create and maintain user accounts;

• Verify identity and legal age;

• Process bets, deposits, and withdrawals;

• Monitor suspicious activity;

• Comply with regulatory reporting obligations.

6.3. Bettors are informed that the provision of personal data is a necessary condition for access to the licensed platform.

7. Data Sharing and Transfers

7.1. We are committed to maintaining the privacy and security of your personal data. We may share your data with trusted third parties in the following circumstances:

• With Regulatory and tax authorities;

• AML and investigative bodies;

• Service providers essential to the operation of the platform.

7.2. Such sharing arises from legal obligations and does not depend on bettor consent.

8. Information Security and Governance

8.1. We are committed to safeguarding your personal data and ensuring its confidentiality, integrity, and availability. We implement industry-standard technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, and destruction.

8.2. Risk-proportionate measures are adopted, including:

• Encryption;

• Access controls;

• System monitoring;

• Segregation of duties.

8.3. These measures comply simultaneously with NDPR requirements and LSLGA standards.

9. Data Retention and Deletion

9.1. Personal data is retained for the period required under AML and gaming legislation, generally a minimum of five years following account closure, ensuring availability for audits and investigations.

10. Bettors Right

10.1. Bettors may request:

• Access to their personal data;

• Correction of inaccurate information;

• Restriction of processing where legally permitted.

10.2. Such rights are exercised without prejudice to the operator’s legal and regulatory obligations.

11. Compliance Structure and Responsibilities

1.1. The operator maintains a dedicated Compliance and Data Protection Team responsible for:

• Ensuring adherence to the NDPR;

• Validating internal controls;

• Responding to regulatory requests;

• Periodically reviewing this Policy.

12. Regulatory Impact and Consequences of Non-Compliance

12.1. Failure to comply with this Policy may result in:

• Administrative fines;

• Sanctions imposed by the LSLGA;

• Suspension or revocation of the gaming license;

• Civil and regulatory liability.

","28/01/2026 04:01","privacy",{"_381":50,"_509":522,"_511":535,"_513":234,"_514":536,"_516":-5,"_517":537,"_519":537,"_520":-5,"_23":538,"_521":522,"_523":241,"_524":241},"Responsible Gaming Policy","

Date: February 10, 2026

1. Purpose

This Responsible Gaming Policy aims to ensure that gaming activities are conducted in

a safe, fair, and responsible manner, minimizing the risk of harm associated with

gambling and promoting player well-being.

2. Commitment to Responsible Gaming

Vibes Technology Limited is committed to maintaining the highest standards of integrity

and responsibility. We recognize that gambling should be a form of entertainment and

not a source of financial or personal distress.

3. Protection of Minors

• Participation in gaming activities is strictly prohibited for individuals under the age

of 18.

• Robust age verification procedures are implemented during registration and

account verification.

• Any account found to be operated by a minor will be immediately suspended.

4. Player Awareness and Education

We provide clear information to players regarding:

• The rules of each game

• Odds and probabilities of winning

• Risks associated with excessive gambling

Educational materials on responsible gaming are made available on our platform.

5. Tools for Responsible Play

Players are encouraged to manage their gaming behavior through the following tools:• Deposit limits (daily, weekly, or monthly)

• Loss limits

• Session time limits

• Reality checks with periodic reminders of time and money spent

6. Self-Exclusion

Players may voluntarily request temporary or permanent self-exclusion. During self-

exclusion:

• Access to gaming services will be blocked

• Marketing and promotional communications will cease

Self-exclusion requests are processed promptly and confidentially.

7. Identification of Problem Gambling

We actively monitor player behavior to identify signs of problem gambling, such as:

• Excessive deposits or losses

• Extended gaming sessions

• Abrupt changes in gaming patterns

When such indicators are identified, appropriate interventions may be applied,

including player communication or account restrictions.

8. Support and Assistance

Players experiencing gambling-related difficulties are encouraged to seek professional

help. We provide references to recognized support organizations, including:

• National mental health and addiction support services

• Local and international responsible gaming organizations

9. Marketing and Advertising

All marketing and advertising materials:

• Are socially responsible and not misleading

• Do not target minors or vulnerable individuals

• Do not portray gambling as a solution to financial problems

10. Data Protection and ConfidentialityAll personal data related to responsible gaming measures, including self-exclusion, is

handled in accordance with applicable data protection laws and confidentiality

standards.

11. Staff Training

Employees receive regular training on responsible gaming practices, including:

• Recognizing problem gambling behaviors

• Proper handling of player interactions

• Compliance with regulatory requirements

12. Regulatory Compliance

This policy complies with all applicable Nigerian laws and regulations, including the

requirements of the National Lottery Regulatory Commission (NLRC), and is subject to

periodic review.

13. Policy Review

This Responsible Gaming Policy is reviewed regularly and updated as necessary to

reflect regulatory changes and industry best practices.

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