Privacy Policy

Spin Lotto Uganda

1. Introduction

This Privacy Policy explains how East Atlantic Telecoms, trading as Spin Lotto Uganda ("the Promoter", "we", "us", or "our"), collects, uses, discloses, and protects personal data of persons who participate in, or enquire about, the Spin & Win, Scratch & Win, and Trivia games offered under Spin Lotto Uganda (together, "the Games").

This Policy is issued in accordance with the Data Protection and Privacy Act, 2019 of Uganda and its Regulations, and should be read together with the Spin Lotto Uganda Terms and Conditions and Prize Claiming Procedure.

2. Data Controller

The data controller responsible for personal data processed in connection with Spin Lotto Uganda is East Atlantic Telecoms. Our privacy contact can be reached at info@eat.org.ng.

3. Scope of this Policy

This Policy applies to personal data collected from Participants and prospective Participants through any Approved Channel used to access the Games, including SMS, USSD, web portal, mobile application, customer support interactions, and any related verification or fraud-prevention process.

4. Personal Data We Collect

Depending on how a person interacts with Spin Lotto Uganda, we may collect:

• identification data: full name, date of birth, and government-issued identification details (where required for verification);
• contact data: mobile phone number, email address;
• participation data: game entered, entry timestamps, questions and answers (for Trivia), spin/scratch outcomes, session and transaction or ticket reference numbers, score and result data;
• financial/transaction data: entry fee payment confirmation and mobile money or airtime transaction references (we do not collect or store full payment card details);
• technical data: device type, operating system, IP address, and mobile network information, to the extent provided by the Approved Channel;
• communications data: records of correspondence with our customer support team; and
• verification data: any additional information reasonably required to confirm eligibility, prevent fraud, or process a prize claim.

5. How We Collect Personal Data

We collect personal data directly from Participants when they opt in to a Game, submit an entry, respond to Trivia questions, contact customer support, or complete prize verification. We may also receive data from mobile network operators or payment/aggregator partners in connection with entry fee processing, and from the Games platform's automated logging systems.

6. Purposes of Processing

We process personal data for the following purposes:

• administering entries and operating the Games, including Spin & Win and Scratch & Win RNG outcomes and Trivia question sessions;
• verifying Participant eligibility and identity, including age verification;
• determining winners and processing prize claims and fulfilment;
• preventing and investigating fraud, duplicate accounts, and system abuse;
• responding to customer support enquiries and complaints;
• complying with regulatory and legal obligations, including reporting to the National Lotteries and Gaming Regulatory Board;
• maintaining audit trails and system records for fairness and regulatory review; and
• sending lawful promotional or service communications relating to Spin Lotto Uganda, where the Participant has not opted out.

7. Legal Basis for Processing

We process personal data on the following legal bases under the Data Protection and Privacy Act, 2019: performance of the contract formed by these Terms when a Participant enters a Game; compliance with our legal and regulatory obligations, including those owed to the National Lotteries and Gaming Regulatory Board; our legitimate interests in operating a fair, secure, and fraud-resistant promotion; and, where applicable, the Participant's consent, such as for optional marketing communications.

8. Sharing and Disclosure of Personal Data

We may share personal data with:

• the National Lotteries and Gaming Regulatory Board and other competent authorities, where required by law or regulatory directive;
• mobile network operators and payment or airtime/data fulfilment partners, to process entry fees and deliver rewards;
• technology and platform service providers who support the operation, hosting, and security of the Games on our behalf, under appropriate confidentiality and data protection terms;
• fraud prevention and verification service providers, where necessary to confirm identity or investigate suspected abuse; and
• professional advisers, law enforcement, or courts, where necessary to comply with a legal obligation or to protect our rights.

We do not sell personal data to third parties.

9. Cross-Border Data Transfers

Where personal data is processed or stored outside Uganda (for example, by a cloud hosting or technology provider), we shall ensure that such transfer complies with the Data Protection and Privacy Act, 2019, including that the recipient country or organisation is subject to a law, binding corporate rules, or contractual terms that provide an adequate level of protection substantially similar to that under Ugandan law.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including the operation of the promotion, prize verification and fulfilment, resolution of disputes, and compliance with regulatory record-keeping and audit requirements. Participation and audit records may be retained for the period required by the National Lotteries and Gaming Regulatory Board or applicable law, after which the data will be securely deleted or anonymised.

11. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, including access controls, encryption where appropriate, secure system logging, and restricted access to verification and identification data on a need-to-know basis.

12. Rights of Data Subjects

Subject to the Data Protection and Privacy Act, 2019, a Participant has the right to:

• be informed of how their personal data is collected and used;
• access the personal data we hold about them;
• request correction of inaccurate or incomplete personal data;
• request deletion or restriction of processing of their personal data, subject to our regulatory record-keeping obligations;
• object to processing carried out on the basis of legitimate interest or for direct marketing purposes; and
• lodge a complaint with the Personal Data Protection Office of Uganda.

Requests may be made through the contact details set out in Clause 16 below. We will respond within the timeframe required by law.

13. Children's Privacy

The Games are open only to persons aged 18 and above. We do not knowingly collect personal data from persons under the age of 18. Where we become aware that we have inadvertently collected data from a person under 18, we will delete such data and disqualify the related entry, in accordance with the Terms and Conditions.

14. Cookies and Similar Technologies

Where Participants access Spin Lotto Uganda through a web portal or mobile application, we may use cookies or similar technologies to maintain session integrity, remember preferences, and support fraud prevention and analytics. Participants may manage cookie preferences through their device or browser settings, though disabling certain cookies may affect the ability to participate in a Game.

15. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Games, or legal and regulatory requirements. The updated Policy will be published on our Approved Channels with the date of the latest revision, and, where required, notified to the National Lotteries and Gaming Regulatory Board.

16. Contact Us and Complaints

For any questions, requests, or complaints regarding this Privacy Policy or the handling of personal data, Participants may contact our privacy team at info@eat.org.ng. If a Participant is not satisfied with our response, they may lodge a complaint with the Personal Data Protection Office of Uganda, or with the National Lotteries and Gaming Regulatory Board in respect of matters concerning the conduct of the Games.