Privacy Policy

Privacy Policy

Turn By Turn (TBT) • Last Updated: May 19, 2026 | Effective: June 1, 2026

1

Introduction

TBT collects, uses, and protects your personal data in compliance with the Nigeria Data Protection Regulation (NDPR) and applicable lottery licensing laws.

2

Data We Collect

Account Registration:

  • Full name, date of birth, phone number, email
  • National ID number (NIN), or valid ID (photo uploaded)
  • Bank account details for payouts

Gameplay:

  • Ticket purchases, numbers selected, draw participation
  • Payout history and amounts
  • Login activity and device information

Technical:

  • IP address, device type, app version
  • Crash reports and error logs
  • Location (city-level only)
3

How We Use Your Data

  • Compliance: Verify identity, prevent fraud, meet regulatory requirements
  • Gameplay: Process tickets, determine winners, issue payouts
  • Support: Respond to inquiries and resolve disputes
  • Security: Monitor for fraud and terms violations
  • Marketing: Send updates only with your consent

We do not sell your personal data to third parties.

4

Data Sharing

We share data only with:

  • Payment processors (for payouts)
  • Regulatory bodies (NLC, FIRS, EFCC, etc. when legally required)
  • Law enforcement (if legally compelled)
  • Banking partners (for KYC/AML compliance)
5

Data Security

  • All data is encrypted in transit (TLS 1.3) and at rest (AES-256)
  • Access restricted to authorized personnel only
  • Annual security audits conducted
  • Servers located in Nigeria (NG-CSIRT compliant)
6

Data Retention

  • Account data: Retained while account is active + 3 years after closure
  • Transaction data: Retained for 7 years (tax & regulatory requirement)
  • Support records: Deleted after 2 years (unless dispute ongoing)
7

Your Rights (NDPR)

You have the right to:

  • Access your personal data
  • Correction of inaccurate information
  • Request erasure of your data
  • Restrict processing
  • Withdraw consent for marketing

To exercise these rights, email This email address is being protected from spambots. You need JavaScript enabled to view it. with your Account ID.

8

Children

TBT is strictly for users 18 years and above. If we discover a minor has created an account, it will be immediately closed and all data deleted.

9

Third-Party Links

TBT may contain links to external websites. We are not responsible for their privacy practices. Please review their policies before sharing any data.

10

Policy Updates

We may update this Privacy Policy with 30 days’ notice. Continued use of our services after updates constitutes acceptance of the revised policy.

11

Contact Us

For any privacy-related questions or requests, please contact us at:

This email address is being protected from spambots. You need JavaScript enabled to view it.

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