Privacy Policy

PRIVACY POLICY

1. INTRODUCTION
Pesach Global Limited (Trading as BetNLaff) (“BetNLaff”, “we”, “us”, “our”) is committed
to protecting the privacy, confidentiality, and security of personal data belonging to our
customers, employees, partners, and visitors.
This Privacy Policy explains:
• What personal data we collect
• How we use personal data
• How we protect personal data
• Your rights under Nigerian law
• How to contact us regarding data protection
By using BetNLaff’s services, you consent to the collection and processing of your personal
data in accordance with this Privacy Policy.

2. REGULATORY & LEGAL BASIS
This Privacy Policy is issued in compliance with:
• Nigeria Data Protection Regulation (NDPR)
• NITDA Data Protection Implementation Framework
• Cybercrime (Prohibition, Prevention) Act 2015
• Nigeria Consumer Protection Regulations
• NLRC Consumer Protection Standards
• International data protection principles (lawfulness, fairness, transparency)

3. DEFINITIONS
Term Meaning
Personal Data Any information relating to an identifiable person
Processing Collection, storage, use, disclosure, deletion
Data Subject The individual whose data is processed
Controller Pesach Global Limited (Trading as BetNLaff)
Processor Third parties processing data on our behalf

Term Meaning
NDPR Nigeria Data Protection Regulation

4. CATEGORIES OF PERSONAL DATA COLLECTED
BetNLaff may collect the following categories of personal data:
4.1 Identity Data
• Full name
• Date of birth
• Gender
• Nationality

4.2 Contact Data
• Email address
• Mobile number
• Residential address

4.3 Identification & KYC Data
• National Identification Number (NIN)
• Passport or Driver’s Licence
• Proof of address
• Selfie and biometric verification

4.4 Financial Data
• Bank account details
• Transaction history
• Deposit and withdrawal records

4.5 Technical Data
• IP address
• Device identifiers
• Browser type

• Operating system
• Login timestamps

4.6 Betting & Usage Data
• Betting history
• Odds selected
• Winnings and losses
• Session duration

4.7 Compliance Data
• AML screening results
• PEP status
• Fraud flags
• Self-exclusion records

5. PURPOSES OF PROCESSING
BetNLaff processes personal data for the following lawful purposes:
• Account registration and management
• Identity verification (KYC)
• Payment processing
• Fraud prevention and detection
• Anti-money laundering compliance
• Betting settlement and account administration
• Customer support and complaint handling
• Responsible gambling monitoring
• Marketing (where consent is provided)
• Regulatory reporting
• System security and audit logging

6. LEGAL BASES FOR PROCESSING
We process personal data under the following lawful bases:
• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests
• Customer consent (marketing and cookies)

• Protection of vital interests
• Public interest and regulatory obligations

7. DATA SHARING & DISCLOSURE
BetNLaff may share personal data with:
7.1 Regulators & Authorities
• Nigeria Lottery Regulatory Commission
• Nigerian Financial Intelligence Unit (NFIU)
• Law enforcement agencies
• Courts and tribunals

7.2 Service Providers
• Payment service providers
• KYC verification vendors
• Fraud detection vendors
• Cloud service providers (AWS)
• Customer support platforms

7.3 Business Partners
• Marketing partners (with consent)
• Analytics providers
All third parties are contractually bound to protect your data.

8. INTERNATIONAL DATA TRANSFERS
Where personal data is transferred outside Nigeria:
• Transfers occur only to countries with adequate data protection
• Standard contractual clauses applied
• Encryption enforced
• Regulatory approval obtained where required
AWS hosting is configured to ensure data residency and security controls.
[28-05-2026 16:50] A Tech: 9. DATA RETENTION
BetNLaff retains personal data only for as long as necessary:
Data Type Retention Period
Account Data 5 years after closure
Transaction Records 5 years
KYC Records 5 years
AML Records 5 years
Complaint Records 5 years
Marketing Data Until consent withdrawn
[20-05-2026 15:08] T: After expiry, data is securely deleted or anonymised.

10. DATA SECURITY MEASURES
BetNLaff implements industry-standard safeguards:
• Encryption at rest and in transit
• Role-based access control (RBAC)
• Multi-factor authentication
• Secure AWS infrastructure
• Intrusion detection systems
• Audit logging
• Regular penetration testing
• Vendor security assessments

11. YOUR DATA PROTECTION RIGHTS
Under NDPR, you have the right to:
• Access your personal data
• Correct inaccurate data
• Withdraw consent
• Object to processing
• Request data portability
• Request restriction of processing
• Request deletion (right to be forgotten)
• Lodge complaints with NITDA
Requests must be submitted in writing and will be responded to within 30 days.

12. COOKIES & TRACKING
BetNLaff uses cookies to:
• Improve website performance
• Remember preferences
• Analyse traffic
• Support marketing (with consent)
Customers may manage cookie preferences via browser settings or the Cookie Policy.

13. MARKETING COMMUNICATIONS
• Marketing messages sent only with consent
• Easy opt-out mechanisms provided
• No marketing to self-excluded customers
• Marketing preferences respected at all times

14. CHILDREN’S PRIVACY
• BetNLaff does not knowingly collect data from persons under 18
• Underage accounts are closed immediately
• Underage data deleted and reported to regulator

15. DATA BREACH MANAGEMENT
In the event of a data breach:
• Incident immediately investigated
• Affected data contained
• Regulator notified within 72 hours
• Affected customers notified where required
• Remediation actions implemented
• Incident documented

16. THIRD-PARTY LINKS

BetNLaff is not responsible for the privacy practices of third-party websites linked from our
platform.
Users are encouraged to review third-party privacy policies.

17. POLICY UPDATES
BetNLaff may update this Privacy Policy from time to time.
• Changes will be published on the website
• Material changes notified to customers
• Continued use constitutes acceptance

18. CONTACT & DATA PROTECTION OFFICER
Data Protection Officer (DPO)
Pesach Global Limited (Trading as BetNLaff)
Email: dpo@BetNLaff.ng
Support Email: support@BetNLaff.ng

19. GOVERNING LAW
This Privacy Policy is governed by the laws of the Federal Republic of Nigeria.