Privacy Policy

Effective Date: January 26, 2026
Last Updated: January 26, 2026

1. Introduction and Commitment to Privacy

ELITE.GAMES is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect your data when you access or use our electronic raffle and auction platform. We recognize that privacy is a fundamental right, and we have designed our data practices to comply with the Nigeria Data Protection Regulation (NDPR) 2019, the Nigerian Cybercrimes Act 2015, and international best practices including the General Data Protection Regulation (GDPR) principles.

By creating an account or using our services, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with our data practices, please do not use our platform. We encourage you to read this policy carefully and contact us if you have any questions or concerns about how we handle your personal information.

2. Information We Collect

ELITE.GAMES collects various categories of information to provide, maintain, and improve our services, ensure platform security, comply with legal obligations, and deliver personalized experiences. The information we collect falls into three primary categories: information you provide directly, information collected automatically, and information from third-party sources.

Information You Provide Directly includes data you submit when creating an account, completing your profile, or interacting with our platform. This encompasses your full name, email address, phone number, date of birth, residential address, and gender. During the Know Your Customer (KYC) verification process, we collect government-issued identification documents such as your National Identity Number, International Passport, Driver's License, or Voter's Card, along with proof of address documents including utility bills or bank statements. For payment processing and prize distribution, we collect bank account details, payment card information (processed securely through our payment partners), and transaction history.

Information Collected Automatically includes technical data generated through your use of our platform. We collect device information such as your IP address, browser type and version, operating system, device identifiers, and mobile network information. Usage data encompasses pages visited, features used, time spent on the platform, raffle and auction participation history, search queries, and interaction patterns. We use cookies, web beacons, and similar tracking technologies to collect this information, and you can manage your cookie preferences through your browser settings or our cookie management tool.

Information from Third-Party Sources may be obtained to verify your identity, prevent fraud, or enhance our services. This includes data from payment processors confirming transaction authenticity, credit reference agencies for fraud prevention purposes, social media platforms if you choose to link your account, and publicly available sources such as business registries or sanctions lists for compliance screening.

3. How We Use Your Information

ELITE.GAMES uses your personal information for specific, legitimate purposes that are essential to operating our platform and providing you with quality services. We process your data based on various legal grounds including contractual necessity, legal obligations, legitimate interests, and your explicit consent where required.

Service Delivery and Account Management constitutes our primary use of your information. We process your data to create and maintain your account, authenticate your identity, process ticket purchases and auction bids, facilitate payment transactions, distribute prizes to winners, and provide customer support. This processing is necessary to fulfill our contractual obligations to you as a platform user.

Security and Fraud Prevention requires us to analyze user behavior patterns, verify identity through KYC procedures, detect and prevent fraudulent transactions, investigate suspicious activity, enforce our Terms of Service, and protect against unauthorized access or security breaches. These activities are conducted based on our legitimate interest in maintaining a secure and trustworthy platform, as well as our legal obligations under Nigerian cybercrime and anti-money laundering laws.

Communication and Marketing involves sending you transactional emails and SMS notifications about your account activity, raffle draws, auction results, and prize winnings. With your explicit consent, we may also send promotional communications about new raffles, special offers, platform updates, and personalized recommendations based on your interests and participation history. You can opt out of marketing communications at any time through your account settings or the unsubscribe link in our emails.

Platform Improvement and Analytics enables us to understand how users interact with our platform, identify technical issues, develop new features, conduct research and analysis to improve user experience, and generate aggregated statistics for business intelligence purposes. This processing is based on our legitimate interest in continuously improving our services and maintaining competitive offerings.

Legal Compliance and Protection requires us to respond to legal requests from law enforcement or regulatory authorities, comply with tax reporting obligations, enforce our legal rights and agreements, resolve disputes, and maintain records as required by Nigerian law. This processing is necessary to fulfill our legal obligations and protect our legitimate interests.

4. How We Share Your Information

ELITE.GAMES does not sell your personal information to third parties. However, we may share your data with carefully selected partners and service providers under strict confidentiality obligations and only for the purposes described in this Privacy Policy.

Service Providers and Business Partners who assist us in operating our platform receive access to your information as necessary to perform their functions. Payment processors such as Paystack and Flutterwave handle your payment transactions securely without ELITE.GAMES storing your complete card details. Email and SMS service providers including SendGrid and Termii deliver transactional and marketing communications on our behalf. Cloud hosting providers store our data infrastructure, while identity verification services assist with KYC compliance. All service providers are contractually obligated to protect your information and use it only for specified purposes.

Legal and Regulatory Authorities may receive your information when we are required by law to disclose it, including responses to court orders, subpoenas, or regulatory investigations. We may also share information with law enforcement agencies to prevent or investigate suspected fraud, security breaches, or other illegal activities. In such cases, we will disclose only the minimum information necessary to comply with the legal requirement.

Business Transfers may involve the transfer of your information if ELITE.GAMES undergoes a merger, acquisition, reorganization, or sale of assets. In such events, we will notify affected users and ensure that the acquiring entity agrees to protect your information in accordance with this Privacy Policy or provide you with the opportunity to opt out of the transfer.

Prize Fulfillment Partners receive winner information necessary to deliver physical prizes, including your name, shipping address, and contact details. These partners are bound by confidentiality agreements and are prohibited from using your information for any purpose other than prize delivery.

Aggregated and Anonymized Data that cannot identify you personally may be shared publicly or with third parties for research, marketing, or analytical purposes. This includes statistics about platform usage, raffle participation rates, and demographic trends that do not reveal individual identities.

5. Data Security and Protection

ELITE.GAMES implements comprehensive security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. Our security program incorporates technical, administrative, and physical safeguards designed to ensure data confidentiality, integrity, and availability.

Technical Security Measures include end-to-end encryption for data transmission using industry-standard TLS/SSL protocols, encryption of sensitive data at rest using AES-256 encryption, secure password hashing with bcrypt algorithms, regular security audits and penetration testing, intrusion detection and prevention systems, and automated backup systems with encrypted storage. Our platform infrastructure is hosted on secure cloud servers with redundant systems to ensure business continuity.

Access Controls and Authentication restrict data access to authorized personnel only, based on the principle of least privilege. We implement multi-factor authentication for administrative access, role-based access controls, regular access reviews and revocations, and comprehensive audit logging of all data access and modifications. Employees and contractors with access to personal information are bound by strict confidentiality obligations and receive regular security training.

Payment Security is maintained through PCI-DSS compliant payment processing, with credit card information handled exclusively by certified payment processors. ELITE.GAMES does not store complete card numbers, CVV codes, or other sensitive payment credentials on our servers. All payment transactions are tokenized and encrypted to prevent unauthorized access.

Incident Response and Breach Notification procedures are in place to detect, respond to, and recover from security incidents. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and the Nigeria Data Protection Bureau within seventy-two (72) hours of becoming aware of the breach, as required by NDPR. Notifications will include the nature of the breach, the data affected, and the measures we are taking to address the incident.

6. Your Privacy Rights and Choices

Under the Nigeria Data Protection Regulation and our commitment to privacy best practices, you have several rights regarding your personal information. ELITE.GAMES provides mechanisms for you to exercise these rights, and we will respond to your requests within thirty (30) days.

Right to Access allows you to request a copy of the personal information we hold about you. You can access most of your data directly through your account settings, or you can submit a formal access request to our Data Protection Officer. We will provide the information in a commonly used electronic format.

Right to Rectification enables you to correct inaccurate or incomplete personal information. You can update most information directly through your account settings. For data that cannot be self-edited, such as KYC documents, please contact customer support with the correct information and supporting documentation.

Right to Deletion (also known as the "right to be forgotten") allows you to request deletion of your personal information in certain circumstances, including when the data is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when you object to processing. Note that we may be unable to delete information that we are legally required to retain or that is necessary to establish, exercise, or defend legal claims.

Right to Object enables you to object to processing of your personal information based on legitimate interests or for direct marketing purposes. If you object to marketing, we will cease such processing immediately. For objections based on legitimate interests, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] or through the contact details provided below.

7. Cookies and Tracking Technologies

ELITE.GAMES uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content and advertisements. Understanding how these technologies work and how to manage them empowers you to make informed choices about your privacy.

Essential Cookies are necessary for the platform to function properly and cannot be disabled. These include authentication cookies that keep you logged in, security cookies that protect against fraudulent activity, and load balancing cookies that distribute traffic across our servers. Essential cookies do not track your browsing activity outside our platform.

Analytics Cookies help us understand how users interact with our platform by collecting information about pages visited, features used, time spent, and navigation patterns. We use this data to identify technical issues, optimize performance, and improve user experience.

Marketing and Advertising Cookies track your browsing activity to deliver personalized advertisements and measure campaign effectiveness. These cookies may be set by us or by third-party advertising networks. They enable us to show you relevant raffle and auction promotions based on your interests and participation history.

Managing Your Cookie Preferences can be done through your browser settings, where you can block or delete cookies. Most browsers allow you to refuse all cookies, accept only certain cookies, or receive notifications when cookies are set. Note that blocking essential cookies may impair platform functionality.

8. Children's Privacy

ELITE.GAMES is not intended for use by individuals under the age of eighteen (18) years. We do not knowingly collect, use, or disclose personal information from children. Our Terms of Service explicitly prohibit account creation by minors, and we implement age verification measures during registration and KYC processes.

If we become aware that we have inadvertently collected personal information from a child under 18, we will take immediate steps to delete such information from our systems and terminate the associated account. Parents or guardians who believe that their child has provided personal information to ELITE.GAMES should contact us immediately at [email protected], and we will promptly investigate and address the matter.

9. Changes to This Privacy Policy

ELITE.GAMES reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform features. We are committed to transparency and will notify users of material changes through prominent notices on our platform, email notifications, or in-app alerts at least thirty (30) days before the effective date of the changes.

Your continued use of the platform after the effective date of any modifications constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should discontinue use of the platform and may request deletion of your account and personal information.

10. Contact Information and Data Protection Officer

For questions, concerns, or requests related to this Privacy Policy or our data practices, please contact our Data Protection Officer through the following channels:

Data Protection Officer
ELITE.GAMES Limited
Plot 123 Adeola Odeku Street
Victoria Island, Lagos, Nigeria

Email: [email protected]
Phone: +234 (0) 800-ELITE.GAMES
Support Hours: Monday to Friday, 9:00 AM to 6:00 PM WAT