Privacy Policy

1. Who we are and scope

LudoNaira is operated by Get Moore Services Limited (Lagos, Nigeria), the data controller for the personal data described in this policy. The policy covers the LudoNairawebsite, the Android app and every related interface (together, the "Platform"). By creating an account or using the Platform you acknowledge the processing described here; if you do not agree with it, please do not use the Platform. Capitalised terms not defined here have the meaning given in our Terms & Conditions. You can reach our data team at support@ludonaira.com.

2. Information we collect

• Account information you provide when registering or filling in forms, name, email, mobile number, date of birth and state of residence, and any optional profile details you choose to add (such as a picture or username).
• Verification information for KYC and payouts, such as NIN, BVN, photo ID and bank account details, processed in line with Nigerian law including the Money Laundering (Prevention and Prohibition) Act 2022.
• Transaction and payment data, deposits, withdrawals, contests entered, results, and the billing information needed to process payments (handled with our payment processors; we do not store full card numbers).
• Device and log data recorded automatically by our servers, IP address, device model and identifiers, operating system, browser type, screen size, mobile carrier, referring pages, pages visited, search terms and interactions with the app.
• Location data, used to confirm you are playing from Nigeria and from a state where participation is lawful.
• Communications, your correspondence with our support team, and your interactions with our community channels or social pages.
• Information from third parties who lawfully hold data about you and share it with us, for example identity-verification partners, payment providers and analytics services.

3. Cookies and similar technologies

We use cookies, tags, code snippets and similar technologies. These work by storing a small file on your device or reading information from it, and we use them to:

• recognise you and your device and keep you signed in;
• remember your preferences and customise the service;
• measure how the Platform is used so we can improve it (including via analytics tools such as Google Analytics);
• support payment and payout flows you initiate;
• enable optional interactions with third-party social platforms you choose to connect.

You can disable cookies in your browser or device settings, but some features of the Platform may not function properly without them.

4. How we use your information

• to create and operate your account, run contests and process deposits, entries and withdrawals;
• to verify your identity, age and location, and to prevent fraud, collusion, unfair play and money laundering;
• to provide customer support and respond to your requests and complaints;
• to improve, personalise, secure and develop the Platform, including through research, analytics and surveys;
• to send service messages (OTPs, receipts, important notices) and, where permitted, promotional messages, which you can opt out of at any time;
• to display advertising, which may be tailored to your interests;
• to comply with our legal and regulatory obligations and to enforce our Terms and policies.

We process your data on the lawful bases set out in the NDPA: your consent, performance of our contract with you, our legitimate interests, and compliance with legal obligations.

5. Sharing your information

We share personal data only where necessary, with:

• payment processors, banks and wallet providers, to fund your wallet and disburse withdrawals on your instruction;
• identity-verification, anti-fraud and compliance partners;
• hosting, analytics, communications and other service providers who support the Platform under confidentiality obligations;
• advertising partners, in aggregated or pseudonymised form, to measure and improve ad quality;
• government, regulatory, tax or law-enforcement bodies where disclosure is required by law, court order or valid legal process;
• professional advisers, and a successor entity in the event of a merger, acquisition, reorganisation or sale of assets, in which case this policy continues to apply to the transferred data;
• any party where disclosure is necessary to enforce our rights, protect the safety of any person, or prevent illegal activity.

We may publish or share information that cannot identify you personally (aggregated or anonymised statistics). We do not sell your personal data.

If you choose to connect the Platform with a third-party social network, that network will share data about you with us and may receive data about your use of the Platform, according to your settings on that network. Review their terms and privacy policies, they, not we, govern those services.

6. Where your data is stored and transfers abroad

Your data may be processed on secure servers located in or outside Nigeria. Where data is transferred outside Nigeria, we do so in accordance with the NDPA, including ensuring an adequate level of protection or using safeguards recognised by the Nigeria Data Protection Commission, and we require recipients to protect it to a standard no lower than this policy.

7. Data retention

We keep personal data only as long as necessary for the purposes described above, or as required for legal, tax, accounting, anti-fraud, regulatory and dispute-resolution obligations, which may continue after your account is closed. Once the applicable purpose and retention period end, we delete or irreversibly anonymise the data.

8. Your rights

Under the NDPA you have the right to:

• access the personal data we hold about you and obtain a copy;
• correct inaccurate or incomplete data, you can update most details in the app, or by contacting us;
• request deletion of your data, subject to retention required by law;
• withdraw consent where processing relies on it, without affecting prior processing;
• object to or restrict certain processing, including direct marketing;
• data portability, where applicable;
• lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise any right, email support@ludonaira.com. We will respond within the timelines required by the NDPA.

9. Marketing choices

You control the promotional messages you receive. You can opt out at any time using your account settings, the unsubscribe link in an email, or by writing to support@ludonaira.com with an opt-out instruction. It may take a short period for an opt-out to take full effect. Service messages necessary to run your account (such as OTPs and transaction receipts) will still be sent.

10. Security

We maintain technical and organisational safeguards designed to protect your data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, and we take commercially reasonable steps to confirm that third parties we share data with protect it to an equivalent standard. No method of transmission or storage over the internet is completely secure, however, so we cannot guarantee absolute security, and transmission of information to the Platform is at your own risk. Where required by law, we will notify you and the NDPC of a qualifying data breach.

11. Third-party links

The Platform may contain links to third-party websites and services. Any data you provide to them is governed by their privacy policies, not ours, and we accept no responsibility for their content or security. Your use of third-party websites is entirely at your own risk.

12. Children

LudoNaira is strictly for adults aged 18 and over. We do not knowingly collect data from anyone under 18. If we learn that a minor has provided personal data, we will delete the data and close the account. If you believe a minor has provided us data, contact support@ludonaira.com.

13. Grievances, changes and governing law

Complaints or grievances about this policy or our handling of your data should be sent to support@ludonaira.com; we aim to resolve them promptly.

We may revise this policy from time to time; material changes will be notified through the Platform. If any part of this policy is held invalid, the remainder continues to apply. This policy is governed by the laws of the Federal Republic of Nigeria, and any dispute connected with it is subject to the exclusive jurisdiction of the courts in Lagos, Nigeria.