PRIVACY & POLICY

§ 1

Status and acceptance of the Privacy Policy

a. This Privacy Policy (also referred to as the „Policy”) sets out the general rules for the collection, processing, distribution, use and storage of User’s Personal Data by PERFECTA POLSKA LTD, hereinafter referred to as PP or the Company, when using the Multi Millionaires Lottery (MML) Website and/or directly at our request,

b. Each User is obliged to carefully read this Policy and comply with it. It is understood and presumed that by the existence of the Website or otherwise, or by providing us with Personal Data directly on our behalf and at our request, a given User has fully read, understood and accepted this Policy, which is confirmed by the fact of registration on the website. If any User disagrees with this Policy in whole or in part, such User may not access or use the MML Website. And he should report his desire to resign from using the website to the PP data administrator or by deleting the account,

c. The Company reserves the right to modify or amend this Policy at its sole discretion. Any changes to this Privacy Policy will be posted on the homepage of our Site. If we make changes, we will notify you by revising the date at the top of this Policy. In addition, if the revised version contains any material changes to the way your personal data will be processed, we will inform you in advance by posting a notice of change in the Privacy Policy area of our Website. We recommend that you visit the Site periodically to review any changes that may be made to this Privacy Policy in order to stay abreast of our information practices and privacy rights and choices. Your continued use of the Site constitutes your acceptance of these changes,

d. This Policy will be considered a non-transferable part of the MML Account Regulations (hereinafter referred to as „Terms”). To the extent not regulated in this Policy, the Terms and Governing Law apply to the relationships arising from this Policy,

e. It is the personal duty and responsibility of each user and service staff to act in accordance with this Policy,

f. All site users must report any violations, threats, incidents and complaints, as applicable, to the MML administrator,

§ 2

Definitions

a. Account – a personal account created and maintained by the User on the MML Website,

b. Applicable law – Nigerian law applicable to this Policy to any relationship between the User and PP,

c. THE COMPANY (also referred to as „PP”, „we”, „us”) – a company established in accordance with the laws of Nigeria under registration number 2002249 for the purpose of providing lottery services to Users of the MML Website,

d. Employee – an employee of Perfecta Polska Ltd.,

e. Game – any game run by the PP Company on the Website as part of the Lottery Services,

f. Lottery Services – any (public or private) lottery and gambling services provided by the Company on the MML Website,

g. Personal Data/Information – information or all information that can be associated with a specific person (User) and that can be used to identify that person,

h. Privacy Policy – this Privacy Policy published on the home page of our Website, which may be changed or updated from time to time in accordance with point § 1c of this Privacy Policy,

i. Reward – a reward won by the User using a Ticket,

j. Registration – the procedure for setting up an Account on the Website,

k. Ticket – means entering the Game by the User who purchased it,

l. User (also referred to as „you”, „your”) – the owner of an Account on the Website that has not been liquidated, suspended or closed,

m. Website – a website operated and owned by the Company at https://mml.ng or https://mml.ng or www.mml.ng or https://multimillionaireslottery.ng or http://multimillionaireslottery.ngor www. multimillionaireslottery.ng,

§ 3

Purpose of using personal data

a. We collect from Users only the Personal Data that we need for the correct and safe use of the Website by Users in order to provide Lottery Services. In particular, we use your Personal Data to:

i. administering our Website and providing Lottery Services, including but not limited to:

ii. verify that you are purchasing Tickets solely on your behalf;

iii. verify that you are making withdrawals solely on your behalf;

iv. checking your eligibility to play;

v. checking whether you meet other requirements set out in the Regulations;

vi. comply with applicable AML/KYC and other regulations in accordance with Applicable Law;

vii. personalize our Website for you;

viii. sending technical notifications, etc rcia and administrative messages;

ix. to communicate with you about services, products, promotions, events and other news and information that we think may be of interest to you;

x. to monitor and analyze trends, usage and activities related to our Site and services;

x.x. provide third parties with statistical information about our Users (but these third parties will not be able to identify any specific User from this information);

xii. to detect, investigate and prevent fraudulent transactions and other illegal activities and to protect the rights and property of the Company and others;

xii. combine the Personal Data we collect from or about you,

§ 4

User rights

a. You have the right to access your Personal Data, withdraw your consent to their processing, obtain information as to whether your personal data is being processed and request rectification, updating or deletion of incorrect and/or incorrect data, confirm the data by contacting us at [email protected]. However, such a request must comply with the Terms. We will remove your personal data from any sources within 24 hours of receiving such a request from you,

b. To close your account and completely delete your personal information, please send an email to [email protected] with a request in accordance with the Terms and applicable law,

c. You have the right to receive notifications about processing activities from the Company,

d. You have the right to transfer data in a machine-readable format,

e. You have the right to lodge a complaint with the local supervisory authority authorized to consider such complaints,

f. You are entitled to and may exercise the rights and freedoms guaranteed by the General Data Protection Regulation (GDPR) in connection with the processing of personal data, if you are covered by its material and territorial scope specified in the GDPR.

§ 5

Collection and processing of personal data

a. We collect Personal Data related to running the Website and use Personal Data that you provide to us. We may collect such Personal Data:

• telephone and e-mail address;

• Full name and surname;

• date of birth and gender;

• address, country, province, city, zip code.

b. We reserve the right to engage a third party to carry out the KYC procedure. Where such events occur, the procedures are in accordance with that third party’s internal privacy policy,

c. By registering on the Website and agreeing to the collection, storage and processing of your personal data, you guarantee that you have read and understood this Policy.

d. We reserve the right to collect any other Data, including data that is not Personal in itself, such as:

• Payment information

• Any other information we deem necessary in accordance with the Privacy Policy set out herein and the Terms,

e. When you visit the Site or use our products, we automatically collect Personal Data that is sent to us by your computer, mobile phone or other access device. This personal information may include:

• your IP address;

• device information, including but not limited to ID, name and type, operating system;

• information about the mobile network;

• standard internet log information such as browser type and pages accessed on our Website, access times, website navigation paths,

f. The Company collects some data automatically, namely information about devices (including mobile devices) with which you can access the Website, IP address of your devices, used browsers and operating systems, date, time, data on the geographical location of your access to the Website. However, we will not share your personal information of this kind with third parties without your consent, except as provided herein,

g. We do not process any sensitive personal data, such as religion, race, ethnicity and/or political views.,

h. We may also use external service providers to whom we entrust data storage, collection and analysis. This is to enable you to obtain the best possible services and to make our cooperation as effective as possible and with the best benefits for you. These third parties have their own privacy policies and their own data collection or opt-out terms. Therefore, we recommend that you read the terms and conditions of the third-party service provider if you use other services on our Website. We will not seek any of your personal information through any other software platforms, data network resources, etc., even if that information is necessary for you or your use of the Site.

i. You agree to provide the Personal Data specified in this document and you agree that you provided it Personal Data may be processed and stored by us or our contractors (in accordance with point § 5h of the Regulations) for a period of time that is practically necessary for the purposes for which the information may be used,

j. The items of Personal Data listed below may be modified from time to time in accordance with Applicable Law and our needs, which will be reflected in this Policy. We will not collect any other Personal Information, except as mentioned herein, until we amend and post those amendments to the Policy on the home page of our Site,

k. You have the right to request the protection of personal data in the event that your data is transferred outside the territorial scope of the GDPR specified in the GDPR, if you are subject to its material and territorial scope.

§ 6

Protection and sharing of personal data

a. We will use all efforts and actions provided by Applicable law to keep your Personal Data secret, to protect your Personal Data against accidental loss, disclosure or deletion, against illegal processing or illegal access,

b. We store and process your personal data on our servers in the various jurisdictions where our facilities and/or our service providers are located. By submitting your Personal Data, you consent to this transfer, store or processing. We will take all reasonable steps to ensure that your personal information is treated securely and in accordance with this Policy. We protect your personal information in accordance with internationally recognized standards, using physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use include firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We also allow access to Personal Data only to those employees or contractors who require it to perform their job or job duties. All of our physical, electronic and procedural safeguards are designed to comply with applicable laws and regulations. Third parties may be located in other countries where laws regarding the processing of personal data may be less stringent than in your country. From time to time Personal Data may also be stored in other locations and in such cases we will ensure that Personal Data is stored and processed with due care and security,

c. We reserve the right to share your personal data with the following entities and in the following cases:

• companies that we plan to merge with or that will be acquired (all or part of our business);

• companies in connection with or in the process of negotiating any sale of company assets or any financing by another company;

• service providers who perform any work for us (such as hosting providers, identity verification providers, support providers, payment and email providers, game content providers);

• in response to a request for information if we believe disclosure is consistent with or required by any applicable law, regulation or legal process;

• if we believe your actions are inconsistent with our agreements or user policies or to protect the rights, property and safety of the Company or others;

• between the Company and its present and future parent companies, affiliates, subsidiaries and other companies under common control and ownership;

• when we believe, in our sole discretion, that disclosure of personal information is necessary to report suspected illegal activity or to investigate violations of our Terms;

• if we are required to disclose any Personal Data with details of any Prize won/claimed by you or paid to you,

d. We will not share your Personal Data with any other Website users or third parties other than those described in point § 6b of this document without your consent or instructions,

e. We will not sell or rent your personal information and/or customer lists to third parties without your express consent,

f. We may combine your personal information with information we collect from other companies and use it to improve and personalize the Site and our products, as well as our content and advertising,

g. We may use your name and e-mail address to provide you with information about products or services that may be of interest to you, but we will not use your Personal Data without complying with Applicable Law and, where applicable, without obtaining your consent,

h. Our Services may from time to time contain links to and from our partner networks, advertisers and affiliates (including but not limited to websites on which the Site is advertised). If you click on a link to any of these sites, please note that those sites and any services that may be accessed through them have their own terms of use for their privacy policies and that we are not responsible or liable for those policies or any Personal Data that may be collected through those sites or services, such as contact information and location data. Please review these policies before you submit any personal information to these sites or use these services,

i. We may allow others to provide analytics services on our behalf in connection with our services. These entities may use cookies and other technologies to collect information about your use of the services and other websites and applications (if any), including your IP address, web browser, page views, application performance, time spent on pages and links clicked. This information may be used by the Company and others to, among other things, analyze and track data, determine the popularity of certain content and better understand your online activity,

§ 7

Data storage and storage

a. In accordance with Applicable Law and to the extent necessary to provide services to our Users, we may store and store your Personal Data provided that they are integrity and treated appropriately. This requirement is conditioned by the need to comply with legal obligations and resolve any disputes. We may retain your Personal Information for as long as your account is active. In addition, your Personal Data may be retained beyond the aforementioned period until it is necessary for us to obtain the relevant information to respond to any issues that may arise later,

§ 8

Security

a. We use appropriate electronic and procedural safeguards to protect the privacy of the information you provide to us from loss, misuse, disclosure, alteration and destruction. Please note that the transmission of data or information (including communications via e-mail) over the Internet or other publicly available networks is not one hundred percent secure. Please note that we are not responsible for the security of any data transmitted over the internet or third party content,

b. All our servers used to store and process your personal data comply with the payment card industry data security standard,

c. Any third party with whom we share your personal data will provide at least the same data protection measures as set out in this Policy,

§ 9

Cookies

a. When you access the Site, we (or Google Analytics or a similar service provider on our behalf) may place small data files called cookies on your computer or other device. We use these technologies to recognize you as our user, customize our Site, understand usage and determine the effectiveness of email marketing campaigns, measure the effectiveness of promotions, and collect information about your computer (as described in section §5f of this document) or other access device to mitigate risk, help prevent fraud, and promote trust and security. Web beacons (or pixel tags) are electronic images that may be used in our Online Services or emails to deliver cookies, count site visits, understand usage and determine the effectiveness of email marketing campaigns,

b. We use the following types of cookies:

• session cookies;

• advertising cookies;

• third party cookies (Facebook Pixel, Google Analytics, payment operators). These third parties have their own privacy policies and their own data collection or opt-out terms. Therefore, we recommend that you read the terms and conditions of the third-party service provider,

c. You can control the use of cookies in the settings of your web browsers. If you reject or delete certain cookies, please note that the performance of related features and functions of our Sites and services may be limited. For more information on disabling cookies or managing cookie settings in your browser, see the list below:

• Google Chrome

• Mozilla Firefox

• Microsoft Edge

• Safari

• Opera

Please note that simply disabling all cookies or all of our cookies in your browser settings may result in some sections or features of our Site not working. Therefore, we recommend using Cookie settings on our website instead of disabling all cookies in your web browser,

d. If you want to opt out of being tracked by Google Analytics, visit the Google Analytics opt-out page,

§10

Contact details

a. If you have any questions about this Privacy Policy, please contact us at [email protected]

Skip to content