Privacy Policy

This privacy policy ("Privacy Policy") describes how we manage, collect and use your personal information on LagosWinners.com ("the Site") provided by Ellipse Entertainment Limited of St Anne's House, Victoria Street, Alderney GY9 3UF, Channel Islands ("Ellipse", "we", "our" or "us"). The Site and the services are being offered by Ellipse as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (www.igamingontario.ca/en).

In the course of providing the services (i) Ellipse collects, uses and discloses personal information on behalf of and as agent to iGaming Ontario; (ii) Ellipse collects personal information in accordance with the Freedom of Information and Protection of privacy Act ("FIPPA") and other applicable privacy laws, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act, and the operating agreement entered into between Ellipse and iGaming Ontario.

Ellipse provides services on the Site through various software and/or platforms (collectively referred as "Platforms"):

Websites
Mobile applications
Downloadable applications
Non- Downloadable applications
Social Media Networks

For the purposes of this Privacy Policy references to the "Site" include any Platforms that we use to provide services to you.

COLLECTION OF PERSONAL INFORMATION FROM YOU OR ABOUT YOU

Definition of personal information.

Personal Information means information about an identifiable individual and includes any information that constitutes personal information within the meaning of FIPPA and other applicable privacy laws.

Information we collect directly from you.

Registration details: you will be asked to provide us with certain details about yourself, such as: first and last name, email address, login name, password, gender, date of birth, physical address, ID number, phone number, etc. when you register an account.
Payment information: payment information may be collected from you, such as your credit card number (first 6 and last 4 digits) and bank account details.
Voluntary information (including special category data): When you respond to communications from us, communicate with us via email or by telephone, or share additional information about yourself through your use of the Site, such as the chat feature, in games, by entering a competition, promotion or survey, submitting a query, and reporting a problem with the Site.

You are under no obligation to provide Personal Information to us. However, we need certain Personal Information about you in order to provide our products and services (for example, in order for you to register your account or to play the games on our Site) and you might not be able to obtain certain services if you do not provide the information required for those services.

In addition, we need certain Personal Information to fulfil our legal and regulatory obligations (including anti-money laundering requirements, responsible gaming requirements and in order to comply with the conditions of our regulatory licenses to offer the services on the Site).

Information we collect about you from your use of the site.

We will automatically collect information from you each time you visit or otherwise use the site. This includes:

Technical and device information: We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device's unique identifiers, IP address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and geo-location data (to comply with our anti-money laundering policy). We use Google Analytics and comply with the Google Analytics Terms of Service and are subject to the Google Analytics Policies.
Social networks: When you register through your social network account (such as your Facebook account) to use our services or connect your account on our Site with your social media account, we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends' list, as well as information you made publicly available on such account. You should read the relevant social media platform's privacy policy and terms and conditions to understand how your personal data may be shared when you use their services.

Information we collect about you from other sources.

We may collect Personal Information about you from other sources (e.g. third party service providers), such as information about your credit history from credit agencies and other financial information that is relevant to the provision of our products and services as well as information which is gathered in order to verify your identity and prevent fraudulent or illegal activity.

Cookies

Definition of cookies.

Cookies are small pieces of data that sit on your computer that remember what you do while you're browsing a website. We use cookies to help us customise your experience to show you relevant information when you return to the Site.

Our cookies.

We use the following types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of the Site. They include, for example, cookies that enable you to log into secure areas of the Site, purchase our products and services or make use of e-billing services.
Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us for our legitimate interests of improving the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are cookies that allow us to recognise you when you return to the Site. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting/advertising cookies. These are cookies that allow us to record your visit to the Site, the pages you have visited and the links you have followed. We will use this information (subject to your choices and preferences) to make the Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Advertising network cookies

We may also work with advertising networks that use cookies to gather information about your visits to our Site, and the information that you view on third party websites and services. This may result in you seeing advertisements on/or through the Site or advertisements for the Site when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit https://allaboutcookies.org/.

Disabling cookies

The effect of disabling cookies depends on which cookies you disable but, in general, the Site may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on the Site. If you disable all cookies, you will be unable to complete a purchase on the Site.

If you want to disable cookies on the Site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below:

For Microsoft Internet Explorer: 1. Choose the menu "tools" then "Internet Options" 2. Click on the "privacy" tab 3. Select the setting the appropriate setting

For Google Chrome: 1. Choose Settings> Advanced 2. Under "Privacy and security," click "Content settings". 3. Click "Cookies"

For Safari: 1. Choose Preferences > Privacy 2. Click on "Remove all Website Data"

For Mozilla Firefox: 1. Choose the menu "tools" then "Options" 2. Click on the icon "privacy" 3. Find the menu "cookie" and select the relevant options

For Opera 6.0 and further: 1. Choose the menu "Files"> "Preferences" 2. Privacy

Individual cookies

Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Site. You can find more information about the individual cookies we use and the purposes for which we use them in the below table:

ASP.NET_Session ID

Used to link user side and server-side communication which allows us identify how and what to display to customers

CID

Identifies from which affiliate campaign the customer came from

HTTP

Identifies the previous page from which a link to the currently requested page was followed

SPECIAL

Identifies from which affiliate campaign the customer came from

SUBID1

Identifies from which affiliate campaign the customer came from

SUBID2

Identifies from which affiliate campaign the customer came from

Country

Identifies the customer's country

Web_visitor_id

Identifies the customer's navigation across the website

Atrack

Identifies from which affiliate campaign the customer came from

displayUserName

Used to identify the customer within the game

Lang

Used to identify the language preference of the site

Optimizely-data$$custom events

Used to identify and report any errors

Plen

Password lengths are specified ensuring the correct characters and lengths are used

recentUnlock

Used to identify which level / game or bonus the customer is entitled to receive / play

returningPlayer

Used to determine if the customer is a new or a returning customer

Savepwd

Used when the customer wants to be remembered by the site

sessionId

Used to allow us to reconnect a player upon logging in

SoundCheck

Used to enable sound to be switched on or off

Uid

Identifies the customer in relation to his game play

User

Identifies the customer within the game

Username

Identifies the customer within the game

We use cookies to:

Monitor traffic on the Site
To obtain information for analysis purposes
To better understand your preferences
To offer with personalised advertising when you access the Site.

Some of the cookies used by the Site are set by us so third-party companies or advertisers may monitor and analyse your web access on our behalf.

Further information.

You can learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device.

Pixels

We use pixel based tracking to track a visit or event on the Site and to track advertisements. Deposits and registrations are tracked for affiliates and marketing partners in order for them to recognise when persons who they direct to the Site register at the Site and make deposits.

Use of information collected

We use and share Personal Information for the following purposes:

To register, manage, update and operate your account with us;
To provide you with slot games, casino games, any other games or betting services offered on the Site;
To verify your age, identity and the accuracy of your registration details and to carry out any necessary due diligence on you;
To process payments to and from you;
To notify you about updates to the Site, our software and/or services;
Where it is in our legitimate interests to do so, we or any associated company or subsidiary of Ellipse (the "Group") and/or service providers may use your Personal Information for marketing analysis. We may also, where we hold any appropriate consent required by law, send you promotions, special offers and marketing updates by email, post, telephone, direct messaging, direct mail and other digital channels (pop ups, push notification, banner advertising, etc) about our products/services. You may at any time object to further marketing by checking and updating your contact details within your account or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email to info@LagosWinners.com, or by contacting live help.
To build up your personal profile in order to gain a better understanding of your interests in our Site and services, and to improve our products and services;
To assist you with your queries;
To process any of your requests for information;
To investigate violations of our policies and User Agreement and resolve disputes about your use of our Site and services;
To comply with the conditions of our regulators;
To conduct credit searches;
To improve your user experience through data collected through analytics;
To detect and prevent fraudulent activities;
As otherwise required by law, regulation or other governmental authority.

We may also use other types of information for the purposes of monitoring Site usage in order to help us develop the Site and the services.

Data sharing

We do not sell or share your Personal Information with third parties ("Recipients") except as described in this Privacy Policy. Personal Information will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Privacy Policy.

We may share your Personal Information with any of the following Recipients:

Other users of the Site who are participating in the same game as you, or anyone else that you nominate to receive such information.
Any member of the Group which supports our processing of Personal Information under this Privacy Policy.
Organisations which process your Personal Information on our behalf and in accordance with our instructions and applicable data protection laws. This includes in supporting the services we offer through the Site in particular those service providers used by us for the purposes of providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services, providing IT support services from time to time, providing services in relation to the operation or promotion of the Site, organizing events on behalf of the Group. These organisations (which may include our third-party suppliers, agents, sub-contractors, auditors, professional advisors, and/or other companies in our Group) will only use your Personal Information to the extent necessary to perform their support functions.
Advertising service providers and advertising networks that require the data to serve relevant adverts to you on our behalf. We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
Credit reference agencies, fraud prevention agencies, payment service providers, banks, financial institutions and similar third parties.
To iGO to perform our obligations under our operating agreement with them
Any gaming authorities with whom we are licensed in order to comply with regulatory requirements.
To third parties (such as potential buyers and investors)in connection with or during negotiation of any potential sale or investment in any of the companies in the Group or in the event of a corporate transaction (e.g. a sale of a substantial part of any company in the Group's business or a merger, financing, restructuring, consolidation, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture or disclosure of all or a portion of any company in the Group's business or assets). In the event of insolvency, bankruptcy, receivership, or other disposal of assets, your Personal Information may also be transferred as a business asset.
To other third parties where we believe in good faith that such disclosure is necessary (a) to comply with relevant laws or to respond to subpoenas or warrants; (b) in connection with any legal investigation; (c) to protect or defend the rights or property of the Group or users of the Site or our services; and/or (d) to investigate or assist in preventing any violation or potential violation of law, this Privacy Policy, or our User Agreement. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

As a gambling operator, we are subject to strict legal and regulatory obligations to ensure you can use our Site. Because of this, we may share your Personal Information with certain third party service providers (such as credit reference agencies, fraud prevention agencies, payment service providers, banks, financial institutions and similar third parties) that are also "data controllers" in respect of the Personal Information about you that is held by them.

Legal bases for using your information

Where the processing is necessary for the performance of your contract with us.

We collect, use and share your Personal Information where such information is essential in order to set up, manage and operate your account, verify your identity, and process payments to and from you and generally to provide access to the Site and to provide our services, to you.

Where the processing is necessary for us to comply with our legal obligations.

In some circumstances, we are legally required to collect, use and share your Personal Information. For example, in connection with the prevention, detection or investigation of a crime or fraud, or where we are obliged to do so by the terms of our regulatory licenses. Where we process your Personal Information in order to comply with our legal obligations, we may need to retain such information, even after you have closed your account with us, in order to demonstrate that we have complied with our legal obligations.

Where we have legitimate interests in the processing.

We collect, use and share your Personal Information where such processing is necessary for our legitimate business interests, unless we determine that those interests are overridden by your interests or your fundamental rights and freedoms. For example, we have legitimate interests in delivering personalized content to you and in generally improving the Site and our services. You have the right to object to our use of your Personal Information in circumstances where it is processed on the basis of our legitimate interests. However, you should note that we may continue to process your Personal Information, despite your objection, where we consider that there are compelling legitimate grounds to do so, or where we need to process your Personal Information in connection with any legal claims, or where we have another lawful basis for processing your Personal Information.

Where you have given us consent.

We collect, use and share your Personal Information for the purpose of sending direct marketing to you, where we have your consent to do so. You may at any time object to further marketing by checking and updating your contact details within your account or selecting the "unsubscribe" link at the end of all our marketing and promotional communications to you, or by sending us an email to info@LagosWinners.com. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

Data transfers

The Group operates globally and the Personal Information that we collect may be transferred to, and stored at, a destination outside of Ontario that may not be subject to equivalent data protection laws. As Ellipse operates from Alderney your Personal Information will be processed outside of Ontario.

We may also transfer your personal information outside of Ontario:

If we have a legal or regulatory reason to do so;
If we use third parties service providers located outside of the Ontario; or
If you have consented to the transfer.

Where we transfer Personal Information from Ontario to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your personal information protect it. Please contact us if you require further information.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We take cyber-security very seriously, not only to protect us, but also our clients and their data. We implement different layers of physical and technological controls to prevent unauthorised access and to ensure data security, integrity and privacy. Controls include, but are not limited to:

Firewalls, Network Segmentation, Intrusion Detection and Prevention Systems
Penetration Testing and Vulnerability Remediation
Encryption protocols for data at rest or in transit
Strict Access control and authentication procedures

In the event of any incident involving your personal information, we will investigate the nature of the incident in line with our data protection procedures. Where required we will notify relevant individuals or organizations within the applicable time period and in compliance with applicable law. We will notify iGO within 24 hours of becoming aware of any material breach of Personal Information and aid iGO with any investigation or breach management and resolution procedure and will notify applicable parties of the relevant results.

Where required to do so we will cooperate fully with any relevant authorities in the management, handling, and investigation of any incident and will report any breach of Personal Information to the relevant regulatory authorities within the time period mandated by applicable law.

Third party websites

The Site may, from time to time, contain links to external sites. You should read these external sites' privacy policies, as we are not responsible for and have no control over information that is submitted to, or collected by, these sites when you visit them.

Public forums

We may, from time to time, make chat rooms, message boards, news groups and/or other public forums available to our users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and avoid posting any Personal Information if you are not content that it should be publically available.

Minors

The services provided by us on the Site are not designed for or directed at persons under the age of 19 ("Legally of Age"). If you are not Legally of Age, you should not use the Site, attempt to open an account, or otherwise provide any Personal Information to us.

In the event that we become aware that a user who is not Legally of Age has provided any Personal information to us, then we may delete such information to the extent we are not under a legal requirement to process it.

If a parent or guardian becomes aware that his or her child under the age of 19 has provided us with personal information, the parent or guardian may contact us at the details set out below in the "How to Contact Us" section to have such personal information deleted.

How long we keep your information

We retain Personal Information for as long as we reasonably require it for our legal and business purposes. However, subject to us not having a legal or regulatory requirement, or a risk management reason for retaining your Personal Information for longer periods, your Personal Information will be retained for no longer than 7 years after your business relationship with us ends.

We may also retain aggregate anonymised information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from anonymised information that has been retained for these purposes.

Your rights

You can ask us:

To access all the Personal Information about you held by us. On request, we will provide you with a copy of this information. You will not have to pay a fee to access your Personal Information unless your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances;
To correct your Personal Information;
To erase your Personal Information. Please note, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
To restrict the processing of your Personal Information whilst we investigate your concern;
To object to processing of your Personal Data, including for marketing purposes. Please note that in some cases, we may demonstrate that we have legitimate grounds to continue to process your information which override your rights and freedoms;
Where our processing is based on your consent or is necessary to perform a contract with you, to receive your Personal Information in a commonly used electronic format or ask us to move the data in that format to another provider, where it is technically possible and not overly onerous for us to do so; and
To withdraw your consent to us processing your Personal Information, at any time, when such processing relies upon your consent.

How to contact us

We welcome your views about the Site and our Privacy Policy. If you would like to contact us with any queries or comments please send an e-mail info@LagosWinners.com to our customer services department or via the live help facility.

Alternatively, you can contact our Privacy Officer by sending an email to: dpo@LagosWinners.com.

If you are not satisfied with how we manage your Personal Information, you have the right to make a complaint following our complaints process which can be found at: T&Cs

Updates or amendments to this privacy policy

This Privacy Policy communicates our current data collection and usage practices. We will from time to time review and revise these practices. We will post any changes to this Privacy Policy on the Site. Please refer to this Privacy Policy on a regular basis. If we make material changes to this Privacy Policy, we will notify you of those changes before they take effect either through the Site or by sending you a notification. This Privacy Policy is version 6 and was last updated on 2023-11-09.