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Draft text for legal review

This is a working draft for review by our lawyers and our data protection officer. It is not yet in force and will change before launch.

Privacy notice

Draft 0.1 · Not yet in effect · Last edited 22 Oct 2026

What personal data Watch and Win collects, why, who we share it with, how long we keep it and what your rights are under the Nigeria Data Protection Act 2023.

The short version

  • We collect what we need to run your account, check who you are, move your money and meet the law.
  • Your selfie is used only to confirm your identity, with your consent, and is deleted 30 days after the check.
  • We never store your full BVN, NIN or card number, and we never sell your data.
  • You can see, download, correct and delete your data in Privacy and data.
  • You can complain to the Nigeria Data Protection Commission (NDPC) at any time.

About us

1. Who we are

This preview describes proposed data practices. The operator and final privacy details will be confirmed before launch.

Controller
Operator and registered address to be confirmed before launch.
NDPC registration
Number to follow
Privacy contact
Our data protection officer, dpo@watchandwin.example (placeholder address)
2. What this notice covers

This notice covers the Watch and Win website and app, our support channels (WhatsApp, email, chat) and the messages we send you. It applies whether or not you have an account. Our Cookie policy explains cookies in more detail.

Your data and how we use it

3. Data we collect
  • Account: your name, phone number, email address if you give one, date of birth, state of residence, and your password and PIN, which we store only in scrambled form.
  • Identity: your BVN or NIN, the name, date of birth and photo that the national databases return, your selfie and liveness check, and ID documents if you upload them.
  • Money: the name and number of the bank accounts you use, deposits, withdrawals, and the type and last 4 digits of a card. Our payment partner handles full card details; we never see them.
  • Trading: your orders, trades, positions, payouts and the tax withheld.
  • Earn: the offers you start and complete, the ads you watch, your rewards, and the phone number or bank account you cash out to. You can earn without giving a phone number.
  • Device and location: IP address, device and browser type, and your approximate location, to confirm which state you are in.
  • Responsible trading: your limits, breaks, self-exclusion, SafePlay check results and patterns that may show harm.
  • Community: only if you agree, your short name, rank, profit and number of markets on the leaderboard, and your results and positions on a public profile. Never your balance, stakes or deposits.
  • Contact with us: support messages, feedback and the messages we send you.
4. Sensitive data: BVN, NIN and your selfie

Your selfie and liveness check are biometric data, which the Act treats as sensitive. We use them only to confirm that you are the person your BVN or NIN belongs to, and only with your explicit consent. You give it on a separate screen before the selfie, and you can refuse and have a person check an ID document instead.

To check your BVN, the Nigeria Inter-Bank Settlement System (NIBSS) asks for your consent through its iGree service, with a code sent to the phone number linked to your BVN.

We never store your full BVN or NIN. We keep the last 4 digits and a one-way code that lets us spot a second account without revealing the number.

5. Why we use your data and our legal basis

The law only lets us use personal data for a clear purpose and on a lawful basis. These are ours:

Purposes and legal bases
WhyLegal basis
Open and run your account, process trades and payoutsContract with you
Credit rewards from offers and ads, and send cash-outsContract with you
Check your identity and ageLegal obligation (gaming and anti-money-laundering law); your explicit consent for the selfie
Process deposits and withdrawals and keep recordsContract; legal obligation
Confirm which state you are inTo be confirmed before launch
Prevent fraud and keep accounts secureLegal obligation; legitimate interest in protecting you and Watch and Win
Limits, self-exclusion and spotting harmLegal obligation; vital interest where someone is at risk
Report to regulators and the tax authorityLegal obligation
Service messages about your money and accountContract
Marketing messagesYour consent, which you can withdraw at any time
Show you on the leaderboard or a public profileYour consent, which you can withdraw at any time in Privacy and data
Analytics cookiesYour consent
6. Automated decisions

Some checks run automatically: matching your selfie to your ID record, spotting fraud, and confirming your location. If an automated decision stops you from verifying, adding money or trading, you can ask a person to review it, tell us your view and challenge the decision. Write to our data protection officer.

7. Marketing

We only send marketing messages if you agree, and the box is never ticked for you. You can stop them at any time in Settings or with the link in each message. We send no marketing to anyone on a break or self-excluded.

Who we share your data with

8. Partners and authorities

We share only what each one needs, and every partner works under a written contract that protects your data. We never sell your data.

  • Payment partners: banks, payment processors and NIBSS, to move your money.
  • Identity partners: verification providers that check your BVN or NIN with NIBSS and the National Identity Management Commission (NIMC) and compare your selfie. Their names will be listed here before launch.
  • Regulators and authorities: the LSLGA (including its SafePlay register and transaction monitoring), the Lagos State Internal Revenue Service for withholding tax, the Nigerian Financial Intelligence Unit for suspicious transactions, the NDPC, and the police or courts with a valid legal order.
  • Offer and ad partners: when you start an offer or watch an ad in Earn, we share a random ID, never your name or phone number, so the partner can confirm the reward. Partners may collect data on their own pages under their own privacy policies.
  • Airtime and data partners: the phone number and amount, to send airtime or data you cash out.
  • Service providers: hosting, SMS, WhatsApp and email delivery, and support tools.
  • Advisers: our auditors, lawyers and the laboratory that certifies our system, where they need it.
9. Transfers outside Nigeria

Some service providers, for example for hosting or messaging, may store data outside Nigeria. We only transfer data where the Act allows it: to a country with adequate protection, with safeguards such as approved contract clauses, or with your consent. We record every transfer. The list of countries will be published here before launch.

Keeping your data

10. How long we keep it
How long we keep data
DataHow long
Account, identity results and transaction records5 years after your account closes, as anti-money-laundering law requires. Then we delete or anonymise them.
Selfie images and liveness checks30 days after the check. We keep only the result.
Rejected ID documents30 days
Location checks90 days
Sign-in attempts and security logs12 months
Support messages2 years after the case closes

These periods are placeholders until our legal review is complete. A regulator’s or court’s request can make us keep data longer.

11. How we protect it

We encrypt your data in transit and at rest, limit who at Watch and Win can see it, and log every access to sensitive data. If a breach puts you at risk, we tell the NDPC within 72 hours and tell you without delay, in plain language, with what to do.

12. Children

Watch and Win is only for people aged 18 and over. If we learn that we hold data about someone under 18, we close the account and delete the data we do not have to keep by law.

Your rights

13. What you can ask for
  • A copy of your data in a common format.
  • Correction of data that is wrong or incomplete.
  • Deletion of your data, where the law does not require us to keep it.
  • Restriction of how we use your data while a question is settled.
  • To object, including to direct marketing at any time.
  • To move your data to another provider.
  • To withdraw consent at any time. This does not affect what we did before.
  • A review by a person of any automated decision about you.

Use Privacy and data in your account, or write to our data protection officer. We may ask you to confirm who you are. We reply within 30 days.

14. Contact our data protection officer

Email dpo@watchandwin.example (placeholder address) or write to the Data Protection Officer, Watch and Win, at our registered address, which will be published here.

15. Complain to the NDPC

If you are unhappy with how we handle your data, you can complain to the Nigeria Data Protection Commission (NDPC) through the NDPC website (opens a new tab). We would like the chance to fix it first, but you do not have to contact us before you complain.

16. Changes to this notice

When we change this notice, we show the date and a summary of the changes at the top. If a change affects how we use your data in an important way, we tell you before it applies.