TERMS AND CONDITIONS

Last Updated Date: June 23, 2026.

1. ACCEPTANCE

1.1. These Terms and Conditions ("Terms") govern the access to and use of the online platform operated

by Vibes Technology Ltd, registered under number 8704044, with its registered office at Jubilee Road,

Magodo II, Kosofe, Lagos State, Nigeria ("Company").

1.2. By accessing, registering on, or using the platform https://ng.7k.bet/ (the "Platform"), the User

expressly agrees to be bound by these Terms, the Privacy Policy, and the Responsible Gaming Policy.

1.3. If the User does not agree, they must immediately cease use of the Platform.

1.4. Continued use of the Platform after any amendments constitutes acceptance of the updated Terms,

per Clause 21.

2. REGULATORY STATUS

2.1. The Company is licensed by the Lagos State Lotteries and Gaming Authority (LSLGA) to operate

online gaming services in Lagos State, Nigeria.

2.2. The Company holds the following licenses, both valid until 02 September 2026:

• Online Casino Certificate No. LSLGA/OP/OCAS/7KB030925

• Sports Betting License No. LSLGA/OP/OSB/7KB030925

2.3. The Company operates in compliance with the National Lottery Act, Cap N91 (as amended), and the

Lagos State Lotteries and Gaming Authority Law, 2021.

2.4. The Platform is intended for users in jurisdictions where online gaming is lawful. Users are responsible

for ensuring compliance with local law.

3. ELIGIBILITY AND ACCOUNT REGISTRATION

3.1. To register and use the Platform, the User must:

• Be at least 18 (eighteen) years of age;

• Be a natural person with full legal capacity under Nigerian law;

• Reside in a jurisdiction where online gaming is not prohibited;

• Not be an employee, director, or agent of the Company or its affiliates;

• Not be prohibited under applicable regulations;

• Not have been previously self-excluded or permanently barred from the Platform.

3.2. Each User may hold only one (1) account. Registration of multiple accounts — directly or through an

intermediary — is strictly prohibited and may result in cancellation of all associated accounts and forfeiture

of balances.

3.3. The User must provide accurate and complete information at registration and update it promptly upon

any change.

3.4. The User is solely responsible for the confidentiality of login credentials and all activity under their

account.

3.5. Each account is personal and non-transferable. Sharing credentials is strictly prohibited.

4. PROHIBITED USERS

4.1. The following persons may not register or maintain an account on the Platform:

• Persons under 18 years of age;

• Owners, shareholders, directors, persons with significant influence, managers, or employees of the

Company with access to the Platform's betting systems;

• Public officials with regulatory or supervisory responsibilities over the gaming sector;

• Persons with direct or indirect influence over sporting event results, including directors, coaches,

referees, athletes, and sports governing body members;

• Spouses, partners, and relatives up to the second degree of the persons listed above;

• Persons previously self-excluded or permanently barred;

• Persons diagnosed with pathological gambling disorder;

• Persons in FATF-listed high-risk jurisdictions.

5. USE OF SERVICES

5.1. The Platform provides online gaming and sports betting services for personal, non-commercial

entertainment only.

5.2. The Company may modify, suspend, or discontinue any part of the Services at its discretion.

5.3. The following activities are strictly prohibited:

• Registration or maintenance of multiple accounts;

• Use of bots, scripts, or automated means to interact with the Platform;

• Exploiting technical errors or software vulnerabilities;

• Use of VPN or proxy servers to circumvent geographic restrictions;

• Match-fixing, collusion, or sports integrity violations;

• Chip dumping or coordinated artificial transfer of value between accounts;

• Arbitrage betting against the Company's interests;

• Any use of the Platform in connection with money laundering or terrorism financing;

• Use of payment methods not registered in the User's own name;

• Systematic exploitation of promotional offers through multiple accounts.

5.4. The Company reserves the right to void bets, withhold payments, and suspend or terminate accounts

upon suspected violation.

6. USER OBLIGATIONS

6.1. The User agrees to: provide truthful information at all times; maintain confidentiality of credentials;

promptly notify the Company of any unauthorised account access; use the Platform lawfully; and provide

documentation requested for regulatory compliance purposes.

6.2. The User is responsible for all activity under their account, whether or not authorised.

7. DEPOSITS AND PAYMENT METHODS

7.1. Deposits may be made via the payment methods available on the Platform (bank transfers, Visa,

Mastercard, USSD, and other local methods), processed in Nigerian Naira (NGN).

7.2. Deposits must come from a payment account registered in the User's own name. Third-party deposits

are prohibited and may trigger transaction reversal and account suspension.

7.3. Minimum and maximum deposit limits apply as displayed on the Platform. The Company may reject

deposits or request additional verification where fraud or money laundering is suspected.

8. WITHDRAWALS

8.1. Withdrawals are subject to: satisfaction of any applicable bonus wagering requirements; compliance

with applicable AML obligations; and no active investigation into the account.

8.2. Withdrawals will be processed to a bank account held in the User's own name only. Third-party

withdrawals are prohibited.

8.3. The Company will endeavour to process withdrawal requests within 3 to 5 (three to five) business days

of approval. Processing times may be extended where additional due diligence is required.

8.4. The Company may hold withdrawals pending investigation of suspected fraud or irregularity, with

notification to the User to the extent permitted by law.

9. BILLING AGENT

9.1. Stonefield Technologies Limited, incorporated in Cyprus (HE487162), with registered office at Arch.

Makariou III 1-7, Mitsis Building No. 3, 3rd Floor, Flat/Office 310, 1065 Nicosia, Cyprus, acts as billing

agent for certain payment operations on the Platform.

9.2. Stonefield Technologies Limited may process payments on behalf of the Company but does not

provide gaming services, which remain the Company's sole responsibility.

10. PRIZES AND PAYOUTS

10.1. Winnings will be credited to the User's account upon verification and in accordance with applicable

game rules.

10.2. The Company reserves the right to void bets and withhold payment where there is evidence or

reasonable suspicion of: breach of these Terms; material technical error; match-fixing; fraud; or any other

violation of fair play or applicable regulations.

11. BONUSES AND PROMOTIONS

11.1. All bonuses and promotions are subject to specific terms communicated at the time of the offer and

may be subject to wagering requirements before withdrawal.

11.2. Any attempt to abuse promotional offers — including through multiple accounts or coordinated activity

— will result in disqualification, account suspension, and forfeiture of associated balance.

11.3. Bonuses are non-transferable and non-redeemable for cash except in accordance with applicable

bonus terms.

12. RESPONSIBLE GAMING

12.1. The Company's Responsible Gaming Policy (https://ng.7k.bet/page/responsible-gaming) forms an

integral part of these Terms. Gaming is entertainment only and should not be treated as income.

12.2. The following tools are available to all Users:

• Deposit, bet, and loss limits (daily, weekly, monthly);

• Session time limits and reality checks;

• Temporary pause (1–45 days);

• Temporary self-exclusion (3 months – 5 years);

• Permanent self-exclusion.

12.3. Increases to self-imposed prudential limits take effect after a mandatory 24 (twenty-four) hour cooling-

off period.

12.4. The Company monitors player behaviour for problem gambling indicators and may apply a unilateral

preventive suspension of up to 60 (sixty) days, with email notification.

12.5. RNGs in casino games are audited and certified. The Theoretical Return to Player (RTP) is disclosed

in each game's description.

13. SPORTS INTEGRITY

13.1. The Company partners with the International Betting Integrity Association (IBIA) and Sportradar

Group AG to monitor suspicious betting patterns.

13.2. Match-fixing and manipulation of sporting results are strictly prohibited and constitute criminal

offences under applicable Nigerian law.

13.3. The Company cooperates fully with regulatory and law enforcement authorities and sports governing

bodies in integrity investigations.

14. ANTI-MONEY LAUNDERING AND COMPLIANCE

14.1. The Company complies with the Money Laundering (Prevention and Prohibition) Act 2022, the

Terrorism (Prevention and Prohibition) Act 2022, NFIU Guidelines, and the EFCC Act 2004.

14.2. The Company's AML/CFT programme includes:

• Enhanced due diligence and monitoring of high-risk profiles;

• Continuous monitoring of transactions and betting patterns;

• Screening against sanctions lists, including those of the UN Security Council (UNSC);

• Suspicious Transaction Reports (STRs) to the NFIU where required by law;

• Cooperation with law enforcement authorities.

14.3. Enhanced due diligence is applied to Politically Exposed Persons (PEPs) and their close associates

and family members.

14.4. AML-related disclosures are strictly confidential and will not be shared with the User except as

required by law.

14.5. The Company applies a risk-based approach consistent with FATF recommendations.

15. FRAUD PREVENTION, MONITORING AND ACCOUNT SECURITY

This clause sets out the Company's comprehensive framework for fraud prevention and response, establishing

prohibited conduct, monitoring mechanisms, applicable measures, and User rights in the event of investigation.

15.1. General Principles and Definitions

15.1.1. The Company adopts a robust fraud prevention framework in compliance with the Cybercrimes

(Prohibition, Prevention, Etc.) Act 2015, the Money Laundering (Prevention and Prohibition) Act 2022, the

EFCC Act 2004, and the ICPC Act 2000.

15.1.2. For purposes of these Terms, fraud means any act, omission, misrepresentation, or scheme carried

out with the intent to deceive the Company, obtain undue financial benefit, circumvent the Platform's

security or compliance controls, or cause harm to the Company or other Users.

15.1.3. The occurrence of a fraud indicator does not constitute conclusive evidence of fraud. The Company

will conduct a proportionate investigation before taking definitive measures, subject to the due process

provisions in Clause 15.6.

15.2. Prohibited Conduct and Fraud Indicators

15.2.1. The following behaviours constitute fraud or strong indicators of fraudulent activity and are strictly

prohibited:

(a) Multiple accounts: Creating, maintaining, or operating more than one (1) account on the Platform,

directly or through an intermediary.

(b) Accounts sharing the same IP address: Registration or active use of multiple accounts from the

same IP address. Where a shared network is involved, the Company may request evidence of distinct

identities.

phone number. Each account must be linked to a unique, verified number.

(d) Accounts sharing the same identity document: Registration of multiple accounts using the same

NIN, BVN, passport number, voter's card, or driver's licence. The Company performs automated cross-

referencing of identity documents across all registered accounts.

(e) Accounts sharing the same payment method: Use of the same bank account number, card, or

payment credential across multiple accounts.

(f) False or improper documents: Submission of falsified, altered, expired, or stolen identification

documents for any purpose on the Platform.

(g) Use of third-party identity: Using another person's personal data — with or without their knowledge —

to create or maintain an account.

(h) Third-party payments: Deposits from accounts, cards, or instruments registered in a third party's

name, or withdrawal requests to accounts not held in the User's own name.

(i) Coordinated account activity: Operating multiple accounts in coordination to circumvent limits, obtain

bonuses multiple times, generate artificial winnings, or create any undue advantage.

(j) Bonus abuse: Exploiting promotions in a manner inconsistent with their purpose, including strategies

designed to extract guaranteed profit from promotional terms.

(k) Bots and automation: Use of bots, scripts, macros, or any automated means to interact with the

Platform to circumvent security controls or obtain an artificial advantage.

(l) Device and identity spoofing: Use of emulators, virtual machines, SIM swapping, or spoofing

techniques to conceal the User's true device identity, location, or network characteristics.

(m) Exploitation of technical vulnerabilities: Deliberately identifying and exploiting bugs, errors, or

technical weaknesses to gain an undue advantage or manipulate outcomes.

(n) Velocity abuse: Abnormally rapid sequences of deposits, bets, and withdrawals designed to extract

funds while minimising genuine risk exposure.

(o) Other irregular conduct: Any conduct not specifically listed above but carried out with intent to deceive

the Company or obtain benefit through means that circumvent these Terms or applicable law.

15.3. Monitoring and Detection Systems

15.3.1. The Company employs automated and manual monitoring systems on a continuous basis, which

may include:

• IP address and geolocation cross-referencing across accounts;

• Device identifier and browser fingerprint analysis;

• Phone number and identity document cross-referencing across all registered accounts;

• Payment method cross-referencing across accounts;

• Behavioural pattern analysis including session duration, bet frequency, and deposit-withdrawal

cycles;

• Network and relationship analysis to identify connections between accounts.

15.3.2. The Company is not obligated to disclose the parameters, algorithms, or methods of its detection

systems. Disclosure would materially undermine security controls.

15.3.3. All alerts are reviewed by the Risk and Integrity team before formal action is taken, except in cases

of immediate precautionary action under Clause 15.4.

15.4. Precautionary Measures

15.4.1. Upon identification of credible fraud indicators, the Company may, without prior notice, take the

following precautionary measures:

• Temporary account suspension;

• Restriction of deposits, withdrawals, or bets;

• Temporary hold on available balance;

• Request for supplementary documentation;

• Cancellation of pending bets where permitted;

• Preventive hold on withdrawals during investigation.

15.4.2. Precautionary measures are provisional and do not constitute a finding of wrongdoing. They will be

lifted if the investigation does not confirm the irregularity.

15.4.3. The precautionary period will not exceed 60 (sixty) calendar days, unless extension is justified, in

which case the User will be notified of the reason and estimated timeline.

15.5. Definitive Measures Following Confirmed Irregularity

15.5.1. Where fraud or material violation is confirmed, the Company may:

• Permanently block the account;

• Forfeit account balance where it represents proceeds of fraud;

• Void bets placed in connection with the irregular conduct;

• Withhold winnings obtained through irregular means;

• Recover funds previously paid out, including by deduction from any remaining balance;

• Report to and cooperate fully with competent authorities, including the EFCC, NFIU, and LSLGA.

15.5.2. The Company reserves the right to seek recovery of losses through civil proceedings.

15.6. User's Right to a Hearing (Due Process)

15.6.1. Prior to any definitive measure, the Company will notify the User by email, stating: the nature of the

suspected irregularity; the proposed measure; and the right to respond.

15.6.2. The User has 5 (five) business days to submit a written response to compliance@ng.7k.bet,

supported by relevant documentation.

15.6.3. The Company will issue its final decision within 15 (fifteen) business days of receiving the response

or expiry of the response period, with reasons.

15.6.4. The User may appeal within 10 (ten) business days to compliance@ng.7k.bet, setting out grounds

and new evidence. The appeal will be reviewed by a team member independent of the original investigation

and decided within 20 (twenty) business days.

15.6.5. If still dissatisfied, the User may escalate to the LSLGA under Clause 22.

15.6.6. Due process obligations do not apply where: law, court order, or regulatory direction requires

immediate action; or notification would constitute AML tipping-off. Precautionary measures under Clause

15.4 also do not require prior due process.

15.7. Data Retention for Investigation Purposes

15.7.1. Data and records related to fraud investigations will be retained for a minimum of 5 (five) years and

may be provided to authorities upon lawful request.

16. LIMITATION OF LIABILITY

16.1. The Company shall not be liable for: technical issues beyond its reasonable control; acts of third-party

service providers; indirect or consequential damages; or losses arising from the User's breach of these

Terms.

16.2. Nothing in these Terms limits the Company's liability for fraud, wilful misconduct, or any liability that

cannot be excluded under the Federal Competition and Consumer Protection Act (FCCPA) 2019.

16.3. The Company's total aggregate liability shall not exceed the net deposits made by the User in the

twelve months preceding the relevant claim.

17. INTELLECTUAL PROPERTY

17.1. All content, trademarks, logos, software, and materials on the Platform are the exclusive property of

the Company or its licensors. The User is granted a limited, non-exclusive, non-transferable, revocable

licence for personal, non-commercial use only.

17.2. The User shall not reproduce, modify, or distribute any Platform content without prior written consent.

18. DATA PROTECTION AND PRIVACY

18.1. The Company processes personal data in accordance with the Nigeria Data Protection Act 2023

(NDPA) and NDPC regulations. The Privacy Policy (https://ng.7k.bet/page/privacy) sets out full details.

18.2. Personal data is processed for: account management; transaction processing; AML/CFT compliance;

fraud prevention; responsible gaming monitoring; and marketing where consent has been provided.

18.3. Data is retained for a minimum of 5 (five) years. Data rights requests: privacy@ng.7k.bet.

19. TERMINATION

19.1. The Company may suspend or terminate access in cases of: breach of these Terms; fraud or misuse;

legal or regulatory obligation; AML non-compliance; sports integrity violation; or court order.

19.2. Users may request account closure at any time. Responsible gaming self-exclusion requests are

processed immediately.

19.3. Upon termination, the User may withdraw available balance, unless subject to legal hold or ongoing

investigation.

20. GOVERNING LAW

20.1. These Terms are governed by the laws of the Federal Republic of Nigeria.

20.2. The courts of Lagos State have exclusive jurisdiction over disputes not resolved through the

complaints procedure in Clause 22.

20.3. Prior to legal proceedings, parties may seek resolution through mediation or arbitration under the

Arbitration and Conciliation Act 2023.

21. AMENDMENTS

21.1. Material changes will be communicated by email or in-Platform notification at least 30 (thirty) calendar

days in advance, except where immediate change is required by law or regulatory direction.

21.2. Continued use after the effective date of any amendment constitutes acceptance of the updated

Terms.

22. COMPLAINTS AND DISPUTE RESOLUTION

22.1. Complaints should be submitted to customer support at https://ng.7k.bet. The Company will

acknowledge receipt within 5 (five) business days and issue a substantive response within 30 (thirty)

business days.

22.2. Unresolved complaints may be escalated to the LSLGA.

23. ANTI-CORRUPTION AND INTEGRITY

23.1. The Company maintains zero tolerance for bribery and corruption, in compliance with the ICPC Act

2000 and the EFCC Act 2004. Users and third parties must not offer, promise, or receive any undue benefit

in connection with the Platform.

24. GENERAL PROVISIONS

24.1. If any provision is held invalid, the remaining provisions continue in full force.

24.2. Failure to enforce any provision is not a waiver of that provision.

24.3. These Terms, together with the Privacy Policy and Responsible Gaming Policy, constitute the entire

agreement between the User and the Company.

24.4. These Terms are governed by the English language version for all interpretation and enforcement

purposes.

24.5. Force Majeure: The Company is not liable for failure due to causes beyond its reasonable control,

including acts of God, war, government action, or telecommunications failure.

24.6. The User confirms having read, understood, and accepted these Terms in their entirety.

____________________________________

7K is an online entertainment website operated by Vibes Technology Ltd (Lagos, Reg. No. 8704044), licensed by the LSLGA under

LSLGA/OP/OCAS/7KB030925 and LSLGA/OP/OSB/7KB030925, both valid until 02/09/2026. Stonefield Technologies Limited

(Cyprus, HE487162), Arch. Makariou III -7, Mitsis Building No. 3, 3rd Floor, 1065 Nicosia, Cyprus, acts as Billing Agent.

+18 · PLAY RESPONSIBLY | Made with ❤️ in Nigeria

","term_file","created_at","15/04/2026 07:04","updated_at","24/06/2026 01:06","deleted_at","route","terms","countries","all_countries",true,"all_languages",5,"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.

","10/02/2026 08:02","23/04/2026 02:04","responsible-gaming",4,"[\"en\"]","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",3,"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.

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