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.