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Overview and Scope of This Privacy Notice

This notice explains how personal information is collected, processed, protected, disclosed, and destroyed on this website and related services. It outlines the purposes of collection, the safeguards in place, and the rights available to users. Use of data is based on user consent as set out here and in the consent tools provided on the site. The document applies to all online interactions, including account registration, transactions, and support.

What We Collect, Why We Collect It, and How It Is Secured

  • Categories of personal data collected:
    • Identity and verification data: full name, date of birth, national ID/passport, selfies or verification images, and age confirmation documents.
    • Contact details: mobile number, email, postal address.
    • Account and usage data: login details, preferences, responsible gambling settings, support history, device identifiers, IP address, browser type, and online activity on the site.
    • Transaction and payment data: deposits, withdrawals, payment instrument details processed by providers (e.g., mobile money, card), and anti-fraud signals.
    • Compliance data: records needed for Know Your Customer (KYC), anti-money laundering (AML), and dispute resolution.
  • Purposes of collection and processing:
    • Create and service accounts, verify identity and age, and provide the requested services.
    • Process payments, prevent fraud, manage risk, and ensure platform security.
    • Meet legal and regulatory obligations under Kenyan law, including the Betting, Lotteries and Gaming Act and AML law.
    • Improve website performance, personalise user experience, and support responsible gambling tools.
  • Security measures in place:
    • Encryption in transit (TLS), strong access controls, firewalls, and activity logging.
    • Data minimisation, role-based access, staff confidentiality and training, and vendor due diligence.
    • Secure software development practices, vulnerability management, and incident response procedures.
  • User rights under the Kenya Data Protection Act, 2019 and related regulations:
    • Access a copy of personal data, request correction, and request deletion, subject to legal retention requirements.
    • Object to certain processing, restrict processing, and withdraw consent where consent is the lawful basis.
    • Request data portability where applicable.
    • Lodge a complaint with the Office of the Data Protection Commissioner (ODPC).
  • Compliance statement:
    • Processing follows the Kenya Data Protection Act, 2019, its Regulations, standards issued by the ODPC, and applicable gambling and AML laws. International best practices, including core GDPR principles, guide our approach.
  • Contact for privacy requests:
    • Submit requests through the account area or the support channels provided on the website for the Data Protection Officer.

How Personal Information Is Used

  • Lawful bases:
    • Consent provided through site controls and notices.
    • Performance of a contract to deliver services requested by the user.
    • Compliance with legal obligations, including AML and responsible gambling requirements.
    • Legitimate interests such as security, fraud prevention, and service improvement, balanced against user rights.
  • Uses of personal data:
    • Account setup, verification, and ongoing account management.
    • Processing deposits and withdrawals through payment providers and mobile money.
    • Customer support and dispute handling.
    • Service optimisation, analytics, and product improvement using aggregated or pseudonymised information.
    • Personalisation of content and settings based on user preferences.
    • Marketing communications based on consent and preferences, with opt-out options at any time.
    • Compliance checks, security monitoring, and incident prevention.
  • Principles applied:
    • Processing is lawful, fair, and transparent.
    • Only the minimum data needed for each purpose is collected and retained for defined periods.
    • Personal data is not sold.

How to Access, Correct or Delete Your Data

  • Making a request:
    • Access, correction, deletion, restriction, and objection requests can be made through the account settings or support channels shown on the site.
    • Verification of identity may be required before actioning a request.
    • Responses are provided within timelines required by law.
  • Corrections and deletions:
    • Incorrect or incomplete information will be updated upon request.
    • Deletion will be actioned where possible; some records must be kept to comply with legal, regulatory, and AML obligations, or to establish or defend legal claims.
  • Consent and security checks:
    • By using this site, the user consents to security and identity checks, fraud screening, and processing of payment information by the chosen payment providers.
  • Charges:
    • Requests are processed free of charge unless unfounded, repetitive, or excessive.

Children’s Data and Age Restrictions

  • This website and services are intended for persons aged 18 and above.
  • Age cannot be verified without official documents; age and identity checks are conducted during registration, transactions, or at any time as needed.
  • If it is found that a user is under 18, the account will be closed and personal data will be deleted where lawful.
  • Parents or guardians may contact support to request deletion of a minor’s information.

Cross-Border Processing and Safeguards

  • Personal data may be stored or processed in other countries where technology, payment, verification, or support partners operate.
  • By using the site and services, the user consents to international data transfers as described.
  • Protections applied to such transfers include contractual safeguards, partner due diligence, encryption, and confidentiality obligations.
  • Transfers comply with the Kenya Data Protection Act, 2019 and guidance from the ODPC, including requirements for adequate protection or informed consent.

Cookies and Similar Technologies

  • Definition:
    • Cookies are small files placed on a device to store settings and identifiers. Similar tools include pixels and local storage.
  • Purposes:
    • Essential operation and security of the website.
    • Statistics and analytics to understand usage and improve services.
    • Behaviour analysis and personalisation of content and preferences.
    • Measuring effectiveness of communications and resolving errors.
  • Retention and control:
    • Non-essential cookies are retained for 1 year.
    • Users can manage cookie preferences via the cookie banner and browser settings; some services may not function if essential cookies are disabled.
  • Third-party cookies:
    • Some analytics or advertising partners may set cookies. Their privacy practices apply to their tools.

Your Acceptance and the Version That Applies

  • By accessing or using this website and services, the user accepts this Privacy Policy in full.
  • The current version published on the site is the version that applies.
  • Continued use after an update constitutes acceptance of the updated document to the extent permitted by law.

Sharing Information and Third-Party Practices

  • Situations where sharing occurs:
    • Payment processing, identity verification, fraud prevention, and security services.
    • Service providers that support hosting, customer support, analytics, and communication.
    • Legal obligations, regulatory requests, dispute resolution, or enforcement of agreements.
  • Transparency:
    • A list or description of key partners and processors is provided on the website where available. If a specific party is not listed, the purpose and scope of sharing will be communicated through notices or at the point of collection.
    • Consent and responsibility:
  • Consent and responsibility:
    • Providing information for a connected service indicates consent to share that data for that purpose.
    • Third parties have their own privacy policies and responsibilities for their processing activities.

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