EAZEEBET PRIVACY POLICY

Pendulum Gaming Solutions Limited (RC 8529517)
Trading as Eazeebet
Effective Date: March 1, 2026

1. INTRODUCTION AND PURPOSE

1.1 Pendulum Gaming Solutions Limited, trading as Eazeebet (“Eazeebet”, “we”, “us”, “our”), is committed to protecting the privacy, confidentiality, and security of personal data entrusted to us by our customers, users, partners, and visitors.

1.2 This Privacy Policy explains how we collect, use, store, process, disclose, and protect personal data in connection with:

· Registration and operation of betting accounts;

· Use of our website and mobile applications;

· USSD and SMS betting services;

· Retail betting operations (where applicable);

· Customer support interactions;

· Promotional and marketing activities.

1.3 This Privacy Policy is designed to comply with:

· The Nigeria Data Protection Act 2023 (NDPA);

· Applicable Nigerian financial crime legislation;

· Gaming regulatory requirements;

· Consumer protection obligations.

1.4 By using the Eazeebet Platform, you acknowledge that you have read and understood this Privacy Policy.

2. DATA CONTROLLER

2.1 Pendulum Gaming Solutions Limited is the Data Controller responsible for determining how and why your personal data is processed.

2.2 Our registered office is located in Nigeria.

2.3 For data protection enquiries, customers may contact us through our official support channels as published on the Platform.

3. TYPES OF PERSONAL DATA WE COLLECT

3.1 We may collect and process the following categories of personal data:

3.1.1 Identity Information

· Full legal name

· Date of birth

· Gender

· Government-issued identification numbers

· Photographic identification

3.1.2 Contact Information

· Mobile number

· Email address

· Residential address

3.1.3 Financial Information

· Bank account details

· Payment method details

· Transaction history

· Deposit and withdrawal records

3.1.4 Account and Betting Data

· Betting history

· Wagering activity

· Account balance records

· Bonus usage

3.1.5 Technical Data

· IP address

· Device type

· Operating system

· Browser type

· Device fingerprint information

· Geolocation data (where permitted)

3.1.6 Communications Data

· Customer support conversations

· Emails

· Chat transcripts

· Complaint records

3.2 We may also collect data necessary to comply with AML and fraud prevention obligations, including source-of-funds documentation.

4. HOW WE COLLECT PERSONAL DATA

4.1 Personal data is collected:

· Directly from you during registration;

· When you deposit or withdraw funds;

· When placing bets;

· Through cookies and tracking technologies;

· Through communication with customer support;

· From third-party verification providers;

· From payment processors and financial institutions;

· From regulatory or integrity monitoring bodies.

4.2 We may also obtain data from publicly available sources where permitted by law for AML verification.

5. LAWFUL BASIS FOR PROCESSING

5.1 Under the Nigeria Data Protection Act 2023, we process personal data on the following lawful bases:

5.1.1 Performance of Contract

To provide betting services, manage your Account, process transactions, and settle bets.

5.1.2 Legal Obligation

To comply with AML laws, regulatory reporting requirements, and taxation obligations.

5.1.3 Legitimate Interests

To prevent fraud, protect platform integrity, conduct risk assessment, improve services, and enforce Terms and Conditions.

5.1.4 Consent

For direct marketing communications where required by law.

5.2 Where processing is based on consent, you may withdraw consent at any time without affecting prior lawful processing.

6. PURPOSES OF DATA PROCESSING

We process personal data for the following purposes:

6.1 Account registration and identity verification.

6.2 Fraud prevention and AML compliance.

6.3 Risk profiling and integrity monitoring.

6.4 Processing deposits and withdrawals.

6.5 Settling bets and resolving disputes.

6.6 Providing customer support.

6.7 Complying with regulatory reporting obligations.

6.8 Conducting responsible gambling monitoring.

6.9 Marketing and promotional communications (where permitted).

6.10 Improving platform functionality and user experience.

7. AUTOMATED DECISION-MAKING AND PROFILING

7.1 Eazeebet may use automated systems to:

· Detect suspicious transactions;

· Identify duplicate accounts;

· Monitor betting patterns;

· Assess bonus abuse risk;

· Manage exposure levels.

7.2 Such systems may result in automated restrictions or flags, which may then be reviewed by human compliance staff.

7.3 Customers may contact support if they believe automated processing has unfairly affected their Account.

8. DATA SHARING AND DISCLOSURE

8.1 We may share personal data with:

· Gaming regulators;

· Financial intelligence units;

· Law enforcement agencies;

· Payment service providers;

· Identity verification services;

· Cloud hosting providers;

· Fraud prevention and analytics providers;

· Integrity monitoring organizations.

8.2 Data is shared only where:

· Required by law;

· Necessary to perform our contract;

· Necessary to protect legitimate interests;

· Required to protect against fraud or crime.

8.3 We do not sell personal data to third parties.

9. INTERNATIONAL DATA TRANSFERS

9.1 Where personal data is transferred outside Nigeria (for example, through cloud service providers), we implement appropriate safeguards in compliance with NDPA requirements.

9.2 Such safeguards may include contractual data protection clauses or equivalent protective mechanisms.

10. DATA RETENTION

10.1 Personal data is retained for as long as necessary to:

· Fulfil contractual obligations;

· Comply with AML recordkeeping requirements;

· Resolve disputes;

· Comply with regulatory audit obligations.

10.2 In many cases, gaming and AML regulations require retention of customer records for several years after account closure.

10.3 After expiration of retention periods, data will be securely deleted or anonymized.

11. DATA SECURITY

11.1 Eazeebet implements technical and organizational measures designed to protect personal data, including:

· Encryption technologies;

· Secure server infrastructure;

· Access control mechanisms;

· Monitoring systems;

· Fraud detection systems.

11.2 While we take reasonable measures to protect data, no internet transmission can be guaranteed to be 100% secure.

11.3 Customers are responsible for safeguarding their login credentials.

12. CUSTOMER RIGHTS UNDER NDPA

Under the Nigeria Data Protection Act 2023, you may have the right to:

12.1 Request access to your personal data.

12.2 Request correction of inaccurate or incomplete data.

12.3 Request deletion of personal data where retention is no longer required (subject to legal obligations).

12.4 Object to certain processing activities.

12.5 Request restriction of processing.

12.6 Withdraw consent where processing is based on consent.

12.7 Lodge a complaint with the relevant data protection authority.

12.8 Certain rights may be limited where processing is required by AML or regulatory obligations.

13. COOKIES AND TRACKING TECHNOLOGIES

13.1 The Platform uses cookies and similar technologies to:

· Authenticate sessions;

· Maintain account security;

· Improve performance;

· Analyze traffic;

· Detect fraud.

13.2 Customers may adjust browser settings to refuse cookies; however, certain functionality may be impaired.

14. MARKETING COMMUNICATIONS

14.1 We may send marketing communications where permitted by law.

14.2 You may opt out of marketing communications at any time through account settings or unsubscribe links.

14.3 Transactional or regulatory communications cannot be opted out of where required for account operation.

15. RESPONSIBLE GAMBLING DATA PROCESSING

15.1 We may process behavioural data to detect potential harmful gambling patterns.

15.2 This may include analysis of deposit frequency, bet size escalation, and session duration.

15.3 Such processing is conducted to protect Customers and comply with regulatory expectations.

16. CHILDREN’S DATA

16.1 Eazeebet does not knowingly collect data from individuals under 18.

16.2 If we become aware that an underage individual has provided personal data, we will take steps to delete such data and suspend the Account.

17. DATA BREACH MANAGEMENT

17.1 In the event of a data breach that poses a risk to Customers, Eazeebet will:

· Investigate promptly;

· Contain the breach;

· Notify affected individuals where required;

· Notify regulators where required under NDPA.

18. POLICY UPDATES

18.1 This Privacy Policy may be updated periodically.

18.2 Material updates will be communicated via the Platform.

18.3 Continued use of the Platform after updates constitutes acceptance.

19. CONTACT INFORMATION

For data protection enquiries, requests, or complaints, customers may contact Eazeebet via official support channels published on the Platform.