Cookie Notice
Our website uses cookies. A cookie is a small file of letters and numbers that we place on your device. Strictly necessary cookies are always active. For all other cookies (performance, analytics and advertising), we ask for your consent through the cookie banner when you first visit the site. You can accept or reject non essential cookies, and you can change your choice at any time using the “Cookie settings” link in the footer of every page.
How to control cookies
You can also manage cookies through your browser settings. The help function of your browser explains how. Further information about cookies is available at allaboutcookies.org. Google Analytics also offers an opt out add on: tools.google.com/dlpage/gaoptout
If you block or delete cookies, some features of the site may not work properly.
Cookie classification
| Classification | Description |
|---|---|
| Strictly necessary | Needed for the site to work, for example to remember your cookie choice. These do not require consent. |
| Performance and analytics | Collect information about how visitors use the site, such as which pages are visited most. Used to improve the site. Set only with your consent. |
| Advertising | Used to measure the effectiveness of our advertising and to show you relevant adverts on other platforms. Set only with your consent. |
Cookies used
[verify this list with a cookie scanner on the live Nigerian domain before publishing]
| Cookie name | Expiry | Third party | Purpose | Classification |
|---|---|---|---|---|
| _ga | 2 years | Yes (Google) | Distinguishes users for analytics | Performance and analytics |
| _gid | 1 day | Yes (Google) | Distinguishes users for analytics | Performance and analytics |
| _fbp | 3 months | Yes (Meta) | Used by the Meta Pixel to measure advertising performance | Advertising |
| fr | 3 months | Yes (Meta) | Used by Meta to deliver and measure advertising | Advertising |
| PHPSESSID | Session | No | Maintains your session on the site | Strictly necessary |
| [cookie consent cookie name] | [12 months] | No | Stores your cookie choices | Strictly necessary |
Privacy Policy
Last updated: [date]
At [domain] we take your privacy seriously. This Privacy Policy explains how we collect, use, share and protect your personal data, and what rights you have under the Nigeria Data Protection Act 2023 (the “NDPA”) and its implementing directive. Please read it carefully.
1. Who we are
The data controller for this website is [legal company name], [registered address], Nigeria/[country of incorporation] (“we”, “us”, “the Site”).
Contact for all privacy matters: [privacy email address]. [Our Data Protection Officer can be reached at the same address.]
We are an independent online comparison and information site for adults. We are not a gambling operator and we do not accept bets or deposits.
2. What personal data means
“Personal data” means any information about a person from which that person can be identified. It does not include data from which the identity has been removed (anonymous data).
3. What we collect and how
a. When you browse the Site
For each visit we may automatically collect:
- technical information such as your IP address, browser type and version, time zone setting, operating system, device type, approximate location and other online identifiers
- information about your visit, including the pages you view, the links you click and how long you stay
- information received from cookies and similar technologies, where you have given consent
If you use the Site on a mobile device, we may also collect your mobile carrier and device identifiers.
b. When you sign up to our newsletter or a promotion
We collect your name (if requested) and email address, and we record when and how you gave consent. We will send you marketing emails only if you have chosen to receive them.
c. When you contact us
We keep the details you send us and our replies, so we can respond and keep accurate records.
d. [OPTIONAL: delete if the Site has no user accounts] When you create an account
We collect your name, date of birth, email address and username.
4. Categories of data we hold
- Identity data: name, username or similar identifier.
- Contact data: email address and, if you provide it, telephone number.
- Technical data: IP address, browser type and version, time zone, location, operating system, device information.
- Usage data: how you use the Site, including pages visited and links clicked.
- Marketing and communications data: your marketing preferences and consent records.
We do not knowingly collect sensitive personal data.
5. How we use your data and our lawful basis
| Purpose | Data | Lawful basis |
|---|---|---|
| Send you our newsletter and promotional emails | Identity, contact, marketing and communications | Consent |
| Measure how the Site is used and improve it (analytics cookies) | Technical, usage | Consent |
| Measure the effectiveness of our advertising and show you relevant adverts (Meta Pixel and similar tools) | Technical, usage | Consent |
| Run, secure and protect the Site (troubleshooting, hosting, fraud and bot prevention) | Technical | Legitimate interests (keeping the Site secure and working) |
| Credit referrals to the operators you choose to visit (see section 7) | Technical (click identifier) | Legitimate interests (operating our business) |
| Respond to your enquiries | Identity, contact | Legitimate interests (answering your questions) |
| Comply with the law and respond to lawful requests | As required | Legal obligation |
Where we rely on consent, you can withdraw it at any time (see sections 10 and 11).
6. Cookies and analytics
We use cookies and similar technologies as described in our Cookie Notice. Non essential cookies are set only after you accept them.
Google Analytics. We use Google Analytics to understand how visitors use the Site. Google processes the data it collects on our behalf and under its own privacy terms. You can opt out using Google’s Ads Settings (adssettings.google.com) or the browser add on at tools.google.com/dlpage/gaoptout.
Meta Pixel. With your consent, we use the Meta Pixel to measure the results of our advertising on Facebook and Instagram and to show you more relevant adverts. Meta may combine this data with other information it holds about you. You can manage ad preferences in your Facebook and Instagram settings.
Google Tag Manager. We use Google Tag Manager to manage our tags. Tags that set non essential cookies are triggered only after consent.
7. Who we share your data with
a. Gambling operators you choose to visit. When you click an offer on the Site, you leave our Site and go to the operator’s website. We pass a technical click identifier so that the operator can credit us for the referral. We do not pass your name or email address. The operator is an independent controller and its own privacy policy applies from that point.
b. Service providers. We share data with providers who help us run the Site, such as hosting, email delivery [name of your email provider], analytics and security services. They may only use your data to provide their service to us.
c. Fraud and bot prevention. [OPTIONAL: keep only if used] To make sure our traffic is genuine, we share your IP address with [cheq.ai], which handles it as a data controller for fraud prevention.
d. Authorities and legal requests. We may disclose data where required by law or to respond to valid legal process.
e. Business changes. If we merge with, or sell all or part of our business to, another company, your data may be transferred to it. We will tell you before your data becomes subject to a different privacy policy.
f. Statistics. We may share aggregated statistics about Site usage that do not identify you.
We do not sell your personal data.
8. Transfers outside Nigeria
Some of our providers, including Google and Meta, and our hosting, are located outside Nigeria [hosting location: confirm]. Where we transfer personal data abroad, we make sure it is protected, either because the destination offers adequate protection, because we have appropriate safeguards in place, or, where the law requires it, because you have given your consent.
9. How long we keep your data
| Data | Retention |
|---|---|
| Newsletter subscription data | Until you unsubscribe or withdraw consent, then deleted within [30 days], except a minimal record that you opted out |
| Analytics data | [14 months] |
| Advertising and cookie data | Cookie lifetimes as listed in the Cookie Notice |
| Enquiries and correspondence | [24 months] after the matter is closed |
| Consent records | For as long as needed to prove consent, plus [12 months] |
We may keep anonymised data for statistical purposes without time limit.
10. Your rights
Under the NDPA you have the right to:
- be informed about how we use your personal data
- request access to the personal data we hold about you
- request correction of inaccurate or incomplete data
- request deletion of your data where there is no good reason for us to keep processing it
- request that we restrict our processing of your data
- request a copy of your data in a structured, commonly used and machine readable format (data portability)
- object to processing based on legitimate interests, and object at any time to direct marketing
- withdraw consent at any time. Withdrawal does not affect processing carried out before you withdrew
- not be subject to a decision based solely on automated processing that significantly affects you
To use any of these rights, email [privacy email address]. We will respond without undue delay and within [30 days]. We may ask you to verify your identity first. We do not charge a fee unless a request is manifestly unfounded or excessive.
Complaints. If you are unhappy with how we handle your data, please contact us first. You also have the right to complain to the Nigeria Data Protection Commission (NDPC).
11. Direct marketing
We send marketing emails only if you have actively opted in, using an unticked checkbox. Every email contains an unsubscribe link. You can also withdraw consent by emailing [privacy email address]. Withdrawing consent applies to this Site only.
12. Protection of children
The Site is an information portal about online gambling. It is intended for people aged 18 and over only, and nothing on it is directed at anyone under 18. Gambling by persons under 18 is illegal in Nigeria. We do not knowingly collect personal data from anyone under 18. If we discover that we have done so, we will delete it as soon as reasonably possible. If you believe a child has given us data, please contact [privacy email address].
13. Data security
We use appropriate technical and organisational measures to protect your personal data against loss, misuse, unauthorised access and alteration. Access is limited to staff and providers who need it. If a data breach occurs that is likely to put your rights at risk, we will notify the NDPC and affected individuals where the law requires us to.
14. Content, offers and gambling
Offers and promotions shown on the Site are provided by third party operators and may change without notice. They are subject to the operator’s own terms and conditions and may not be available in all states. Please check the offer on the operator’s site before you act. Gambling can be addictive. You must be 18 or over. Please play responsibly.
15. Other sites
When you leave the Site, for example by clicking an advert or an operator link, the terms and privacy practices of that third party site apply. We have no control over them and are not responsible for them.
16. Changes to this policy
We may update this Privacy Policy from time to time. The latest version will always be on this page with the date at the top. Where a change is significant, we will notify you where appropriate.