Privacy Policy

About this policy

Effective date: 24 October 2026.

This policy covers thegamedao.com (“the site”) and the services that come with it: our lotteries (such as USDT Weekly), prediction games, the membership NFT and staking, and the DAO pages where BNGX holders vote. It also covers player accounts and ID checks, the referral programme, partner campaigns, the contact form and our posts on X.

It explains how we handle personal data: any information that can identify you, directly or indirectly, such as your email address or your wallet address.

It is based on the Nigeria Data Protection Act 2023 and the Nigeria Data Protection Commission’s General Application and Implementation Directive 2025. It also explains your rights if you are in the United Kingdom or the European Economic Area. Please read it together with our Terms of Use.

Who is responsible for your data

The Game DAO is run by Bullion Labs (“we”, “us”). Bullion Labs decides how and why your personal data is used. This makes it the data controller: the organisation responsible for your data under data protection law.

You can contact us about your data through our contact form. See “Contact us” at the end of this policy for other ways to reach us. Our office address is 18 Kaara Street, Ajao Estate, Lagos, Nigeria. Visits are by appointment only, so please don’t come to the office without one: contact us first, and we’ll arrange a visit if one is needed.

The games run on smart contracts: programs on a public blockchain that carry out the games’ rules. A blockchain is a public record of transactions, kept by many computers. We don’t run the blockchains the site uses (BNB Smart Chain and Polygon).

What we collect and where it comes from

Here is what we collect and where it comes from:

• Your wallet address and blockchain activity. Your wallet address is the public code, starting with 0x, that identifies your crypto wallet. When you connect a wallet, the site reads its address and the blockchain information its pages need. For example: your lottery entries, prediction-game stakes, prizes and referral rewards; your NFT mints, staking balances and rewards; and your DAO votes and proposals, with their dates and amounts. This comes from your wallet and the blockchain, and it is public. We keep a copy of your entries, stakes and mints in our database (see “Sales records”), which your profile page shows you.
• Sales records. We keep a record of every paid entry into our games (lottery entries and prediction-game stakes), and we record membership NFT mints in the same way. Each record holds the wallet address that entered or minted, the transaction reference (the unique ID of a blockchain transaction, also called its hash), the game and round (or the NFT), the number of entries or NFTs (and, for a prediction game, the side chosen), the amount paid and its value in US dollars at the time, the platform fee, and the referral wallet and reward, if any. Our server takes these from the blockchain, both when you enter through the site and in a daily check of the blockchain, which finds every mint and also entries made without the site. They are our sales and accounting records. Our team sees them on our private admin dashboard, and our accountants and auditors receive them for our accounts and tax returns; your profile page shows you your own.
• Entry and mint records for campaigns. When you enter a lottery through the site, our server also counts the entry for the current partner campaign (see “Partner campaigns”). When you mint a membership NFT through the site, we record your wallet address, the transaction reference, the number of NFTs minted, the date and the referral it came through.
• Where an entry came from. When you enter through the site, we record the country your internet connection is in, as a two-letter code such as NG. Cloudflare, which carries all the site’s traffic, works it out from your IP address; we don’t store the IP address. We use it only for statistics about where our players are, and we delete it after 90 days.
• Referral links you arrive through. If you open the site through someone’s referral link (a link ending in ?ref= and a wallet address), the site asks our server whether the link is still in use (we switch off links that break our rules), then keeps that wallet address while you browse, in the page’s memory only (not in cookies or browser storage), and shows it under the Enter button at the top of the home page. Your lottery entries then include it, so the lottery contract pays that person a share of our platform fee (it doesn’t change what you pay); this is public on the blockchain.
• Referral sign-ups. If you sign up on the Referrals page, we record the X handle (your @name on X) that you give and the date. We also record the wallet that receives your referral rewards and the wallet you were connected with, if any. Please give only your own X handle. Treat this as public. Your referral link shows your wallet address to anyone who sees it, and referral sign-ups are kept in a database that anyone can read (see “How we protect your data”).
• Account details. You sign in by signing a free message with your wallet (this is not a transaction). We then hold your wallet address, records of when you signed in, and records of what you agreed to and when (consent records). If you choose a username, we hold it, with the date you chose it and a record that you agreed to it being shown publicly. We may also ask you to verify an email address with a one-time code before you enter; we’ll tell you on the site when we start. If you verify one, we store that address encrypted: scrambled so that it can only be read with a secret key. We also keep a one-way code made from it (see “How long we keep your data”). If an admin moves an email address to a new wallet, for example after a wallet is lost, we keep a record of the change. If you ask us for a break from playing, we note your wallet and when the break ends, so that the site stops entries from it and stops any draw results and news we email you (they don’t restart unless you turn them on again, which you can do 30 days after the break ends). If we suspend a wallet (see our Terms of Use), we note when.
• Marketing email choices. If you tick the box to get draw results and news by email, or turn them on in your profile, we record your choice, the version of the wording you agreed to and when, and each later change (for example when you unsubscribe). Only a verified email address can get them. We also keep a record of each of these emails we send you: whether it was sent, by your wallet, never your email address (see “How long we keep your data”).
• ID checks (when we ask for them). Our verification partner Didit photographs your ID document and records a short selfie video, to check that the document is genuine and valid, that you’re a real person who is there, and that your face matches the photo on the document. Your face in these images is biometric data, which the law treats as sensitive. Didit sends our server the result together with the details it read from your document (such as your name, date of birth and document number) and links to the images; our server uses those details only for a moment, to work out what we keep, and never downloads the images. We keep: whether the check passed (or why not, in general words such as “document expired”), Didit’s reference for it, its dates, the type of document and the country that issued it, whether its date of birth shows you’re 18 or over, Didit’s warnings that the same document or face was seen in another of our checks, one-way codes made from the document’s number and from any personal number on it (such as a NIN), and, if our team asks you to pass the check again, when and why. The codes can’t be turned back into the numbers; they only show us when one document is used for more than one wallet. We never keep your photos, your video, your name, your date of birth or your document’s number (see “ID checks”).
• From thirdweb. thirdweb runs the email and phone login for in-app wallets (wallets created for you when you log in with an email address or phone number). thirdweb keeps the email address or phone number you log in with, and our team can look it up in thirdweb’s dashboard. We don’t copy your login email address or phone number into our own systems: if we ask you to verify an email address, you verify it with a code, like everyone else.
• Contact form messages. Your name, email address and message. They are emailed to our team through our email provider (see “Who we share your data with”). The site doesn’t keep them in its own database.
• Messages you send us elsewhere. If you write to us on X or Discord, we receive your username there and your message.
• Partner campaigns. Our entry records also count each wallet’s entries for the current campaign period, as they did for our past campaign with Intract. A partner can ask us about a wallet address only while we run a campaign with them (see “Who we share your data with”).
• Technical data. Your IP address (the number that identifies your internet connection), your browser and device type, and the pages you request. Cloudflare, which carries all the site’s traffic, and our host receive these, and our host keeps them in server and security logs. The “are you human?” check and thirdweb’s services, which our pages use to connect wallets and read the blockchain, also receive them. If you allow analytics, thirdweb’s wallet software also tells thirdweb each time you connect a wallet or send a transaction through the site, with your wallet address, the type of wallet and details of the transaction. If you don’t, the site stops these reports.
• Analytics, only if you allow it. Google Analytics records how the site is used: pages viewed, how you arrived, your device and browser, and events such as a confirmed lottery entry (which lottery, how many entries, the amount and whether it came through a referral link, but not your wallet address or the transaction reference). It also works out your approximate location from your IP address. Google says that Google Analytics doesn’t store the IP address itself.
• Cookies and browser storage. See “Cookies and browser storage” below.

You don’t have to give us personal data. But some parts of the service need it: to enter through the site, you need to connect a wallet and sign in, and we may also ask you to verify an email address and your identity.

We never ask for your private keys or recovery phrase, and the site never holds your funds. Apart from the ID check, which uses biometric data only with your explicit consent, we don’t ask for sensitive personal data, such as health information or political opinions, so please don’t send it to us. A stake in a prediction game, such as one on an election, is public on the blockchain like any other transaction. If you choose a username, the game’s page also shows it in the list of entries for the side you backed, and others may take that as a sign of your political views. That is why we ask you to agree to this when you choose a username (see “Usernames and our posts on X”). We don’t use stakes to work out or record anyone’s political views.

What is public on the blockchain and can’t be deleted

Entries, stakes, prizes, referral rewards, mints, staking and votes are all blockchain transactions. Each one is recorded on BNB Smart Chain or Polygon with the wallet addresses, amounts and times involved. Anyone can see these records, for example on a blockchain explorer (a website that shows blockchain records) such as BscScan. They are permanent: no one, including us, can change or delete them.

A wallet address doesn’t show your name. But you may link yourself to your wallet, for example by sharing your referral link, choosing a username people know you by or posting about a win. Others may then connect the wallet, and its whole history, to you.

The site shows this public information so that everyone can check the games. Entry lists and results show each entry’s wallet address, often shortened (such as 0x1234…abcd), with a link to its page on a blockchain explorer. If a player has chosen a username, the entry lists of the lotteries and the prediction games, and the results, show it in place of the address, still linked to the wallet’s page on the explorer. Your profile page, which only you can see while you’re signed in, brings together your wallet’s activity from the blockchain and our records. Closing your account removes your account details from our systems, as explained in “How long we keep your data”, but it can’t remove anything from the blockchain.

Usernames and our posts on X

Choosing a username is optional. If you choose one, it is public: our lottery and prediction-game entry lists and our results show it in place of your wallet address, still linked to your wallet’s page on a blockchain explorer. So anyone can see which wallet it belongs to and, in a prediction game such as one on an election, which side you backed. We ask you to agree to this when you choose or change your username: showing it is based on your explicit consent. Usernames are unique: no two players can have the same one, even with different capital letters. If you want to stay private, don’t use your real name, email address or phone number in your username. Without a username, the lists show your wallet address (often shortened, such as 0x1234…abcd).

Each Friday our X account, @bullionLabs, posts the current USDT Weekly prize pool and number of entries, with an image. These posts contain no player details. Our team also posts about the games by hand, for example to announce a draw and its winners. A post may show a winner’s username, if they have one, or their shortened wallet address. We never post about anyone’s prediction-game stakes.

Posts on X are public. X handles them under its own privacy policy, and other people can share or copy them; we can’t control those copies.

You can remove your username at any time on your profile page, even if you changed it recently. This withdraws your consent: the lists and results then show your wallet address, and our new posts won’t use the name. If you don’t want your username or wallet address in our posts at all, contact us: we will leave them out of new posts, and delete our earlier posts that show them. We may refuse, hide or remove a username that breaks our username rules.

ID checks

Before you can enter a lottery or a prediction game through the site, we may ask you to verify your identity, once for each wallet; we’ll tell you on the site when we start. The check confirms that you’re 18 or over (or the legal age where your ID was issued, if that’s higher) and that each person plays with their own identity. We need it to meet our legal obligations, including the anti-money-laundering rules and the age limits for these games, and it also helps us prevent fraud.

How it works. You tick a box to agree, then our verification partner, Didit, runs the check on its own secure page. You photograph your ID document (a passport, a national ID card or NIN slip, a driver’s licence or a voter’s card) and record a short selfie video. Didit checks the document, checks that you’re a real person who is there (a “liveness” check) and compares your face with the photo on the document. Software makes the decision; a person at Didit may review it.

Your consent. The selfie, the liveness check and the face comparison use biometric data, so we only run the check with your explicit consent, which you give by ticking the box before it starts (Nigeria Data Protection Act 2023, section 30(1)(a)). You can withdraw your consent at any time by contacting us: we then won’t start another check for you, and while we ask for the check you can’t enter through the site. Withdrawing doesn’t delete the records of your earlier checks, here or at Didit, because the law requires us to keep them (see “Records we must keep” below), and it doesn’t affect what was done before. If you don’t agree, you can still use the rest of the site; the games’ smart contracts stay open to anyone (see our Terms of Use).

What Didit does. Didit is our data processor: under a written agreement, it handles the photos, the video and the details read from your document only to run the check for us. It sends our server the result with those details; our server keeps only what “What we collect” lists and drops the rest at once. It stores them in the European Economic Area for 5 years, the period for which the law requires us to keep identity records, and then deletes them. It may also keep data that no longer names you (pseudonymised data) under its own responsibility, to prevent fraud and keep its service secure. Our settings don’t let it use our checks to train its models.

Transfer abroad. Didit handles your data in the European Union. EU law protects personal data strongly, but the Nigeria Data Protection Commission hasn’t decided that it gives adequate protection, so your rights may be harder to use there. We send your data on the basis of your explicit consent, given with these risks explained (Nigeria Data Protection Act 2023, section 43(1)(a)), and our agreement with Didit.

Automatic decisions. The check is automated, and its result decides whether you can enter through the site. If it stops you and you think it’s wrong, contact us: a member of our team will look at it, and you can give your view and challenge the result. If a check shows that you’re under age, see “Children”.

One document, several wallets. If the same document or personal number is used for more than one wallet, our team sees those wallets together so that we can look into it, and we also see Didit’s warnings that the same face or document was seen in another of our checks. Nothing is blocked automatically because of it.

Records we must keep. Anti-money-laundering law requires us to keep the records of identity checks for 5 years after your account closes or after your last entry, whichever is later. So we can’t delete them when you ask, and closing your account doesn’t delete them; at the end of that period we delete them. If our team asks you to pass the check again, for example after reviewing a result, the earlier result stops counting but is kept as a record for the same period.

Why we use your data and our lawful basis

The law lets us use personal data only when we have a lawful basis. We rely on four:

• Contract: we need the data to provide what you ask for under our Terms of Use.
• Legitimate interests: we have a genuine business reason, such as keeping the site secure or the games fair, and it doesn’t override your rights. You can object to these uses (see “Your rights and how to use them”).
• Consent: you have agreed, and you can withdraw your consent at any time. Where the law asks for explicit consent, as for showing your username next to your prediction-game stakes, we ask you to agree to a clear statement first.
• Legal obligation: the law requires it.

What we use your data for, and the lawful basis for each use:

• Running the games, and showing entries, prize pools, results and profiles: contract.
• Connecting your wallet and sending your transactions through thirdweb’s wallet software: contract.
• Signing you in, keeping you signed in for 7 days, and running your account: contract.
• Verifying your email address, keeping each email address linked to one wallet only, and moving it to a new wallet if you lose yours: contract, and our legitimate interest in preventing fraud, duplicate accounts and abuse.
• Running the “are you human?” check before you sign in or send a message, protecting the site from attacks and looking into misuse: legitimate interests (security).
• Keeping sales records of every paid entry and every membership NFT mint, including those found on the blockchain that weren’t made through the site, and giving them to our accountants and auditors: legal obligation (company and tax law require us to keep accounting records and to file accounts and tax returns) and legitimate interests (accurate records of our sales, fees and referral rewards).
• Recording referral sign-ups and our entry and mint records for campaigns, and running campaigns with partners: legitimate interests (keeping accurate records and running promotions), and contract when you join a campaign or the referral programme.
• Recording which country an entry made through the site came from, for statistics about where our players are (so that we can follow the rules there and plan languages and support): legitimate interests. You can object (see “Your rights and how to use them”).
• Sending you emails about your account, such as verification codes and security notices: contract.
• Sending you draw results and news by email, if you ask for them: your consent, which you give by ticking a box that is never ticked for you, or with the switch on your profile page. You can withdraw it at any time, with that switch or the unsubscribe link in each of these emails. We send news at most twice a month, and draw results only after a draw (once for each draw), and none while you’re taking a break from playing or for 30 days after it ends, or if your account is suspended or closed: we check this just before each email. Some of these emails may go only to some subscribers, chosen by the games you play and when you last played: for example the results of a draw to the players of that game, or news of a new game to players who haven’t played for a while. We never choose by how much you spend, by your country or by a side you took in a prediction game. Each email says why you get it and who sends it, with our postal address, and has a link that stops them without signing in (mail apps that support it can also do it in one click). You can object to these emails at any time by unsubscribing. We don’t send any other marketing emails, and we don’t track whether you open them or click their links.
• Answering your messages: legitimate interests, or contract when you ask about using our services.
• Posting about our lotteries on X, for example a draw’s winners with their usernames or shortened wallet addresses: legitimate interests (showing that the lotteries pay out). You can object (see “Usernames and our posts on X”).
• Showing your username, if you choose one, in place of your wallet address in entry lists and results, including next to your prediction-game stakes: your explicit consent, which you give when you choose the username and can withdraw at any time by removing it.
• Checking, when you enter a lottery or a prediction game through the site, that you’re signed in and that your wallet isn’t on a break you asked for or suspended: contract, and our legitimate interests in keeping the games fair and honouring breaks.
• Checking your identity and age with Didit, when we ask for it, and spotting one document used for several wallets: our legal obligation (the anti-money-laundering rules and the age limits for these games) and our legitimate interests in keeping under-age players out, preventing fraud and keeping one identity for each person; and your explicit consent for the biometric check and for sending your data to Didit in the European Union. Keeping the results for 5 years after your account closes or your last entry: our legal obligation.
• Measuring how the site is used with Google Analytics and thirdweb’s usage reports: consent.
• Using our own records to run and improve the service and to spot problems such as fraud or faults: for example totals of sales, fees, referral rewards and prizes; counts of sign-ups, entries and returning players; lists for our team, such as top players and referrers, spending per player and players who have stopped playing; looking up what we hold about one wallet; and checking that the site works: legitimate interests. Only our team sees these lists with wallet addresses. People we let view our admin dashboard, such as advisers, see the totals and the rankings without any wallet address. If you ask for draw results and news by email, we may use the games you play and when you last played to choose which of these emails you get (see the item on draw results and news above). We never use these lists for automated decisions about players, and we never hand out lists of players to contact them.
• Remembering your answer to the age and country notice: legitimate interests (making sure the site is used only by people who may use it). Remembering your analytics choice and keeping consent records: legal obligation (we must be able to show what you agreed to).
• Meeting legal duties, dealing with privacy requests and complaints, answering lawful requests from authorities, and making or defending legal claims: legal obligation and legitimate interests.

Our systems (the site, its databases and our providers’ services) handle most of this automatically. Our team looks at personal data only when needed, for example to answer a request, check a problem or use the lists above. Each time a team member looks up what we hold about a wallet, or downloads a file of our sales records, we keep a record of it (see “How long we keep your data”). Before we use your data for a new purpose that doesn’t fit the ones above, we will tell you. Where the law requires, we will ask for your consent.

Automatic checks and decisions

Some checks run automatically. They are the “are you human?” check, the limits on sign-ins and email codes, the rule that an email address can be linked to one wallet only, the username rules and limits, the check before you enter a lottery or a prediction game through the site (that you’re signed in, that your wallet isn’t on a break or suspended and, when we ask for it, that it has passed the ID check), the ID check itself (see “ID checks”), and our server’s check that an entry or mint really happened on the blockchain. A check can stop you signing in, sending a message, verifying an email address, choosing a username, entering through the site or having an entry recorded by the site. It doesn’t change what a smart contract does with your transaction.

If a check stops you and you think it is wrong, contact us. A member of our team will look at it, and you can give your view and challenge the result.

Lottery winners are picked at random by the smart contract, using random numbers from Chainlink VRF, a service whose random numbers can be checked on the blockchain. The draw uses only the list of entries held by the contract; no other personal data is involved. We don’t use profiling (automated analysis of personal data to judge or predict things about a person) to make decisions about players. If you ask for draw results and news by email, we may sort subscribers into groups by the games they play and when they last played, only to choose which of these emails they get (see “Why we use your data and our lawful basis”).

Cookies and browser storage

Cookies are small files that a website keeps in your browser. Browser storage works in a similar way. Bullion Labs is responsible for the cookies and storage on this site. Google sets the analytics cookies for us, but only if you allow them.

Necessary cookies and storage make the site work and keep it secure, so they don’t need your consent:

• tgd_notice (cookie): your answer to the age and country notice. Kept for up to 180 days after you agree. If you decline, it is kept for up to 30 days. During that time the site shows you only a “Thank you for visiting” page, apart from this policy, our Terms of Use, our contact form and the page that the unsubscribe link in our draw results and news emails opens, unless you choose “Review my answer” on that page. Some browsers delete cookies sooner.
• tgd_analytics (cookie): whether you allowed analytics. Kept for up to 180 days.
• tgd_challenge and tgd_session (cookies): sign you in. tgd_challenge holds the message you sign, for up to 5 minutes, while you sign in; tgd_session keeps you signed in for 7 days. Both are secure cookies (sent only over encrypted connections) that the site’s pages can’t read. Signing out, pressing Disconnect Wallet on the site or switching to another wallet deletes tgd_session.
• Wallet connection data (browser storage, set by thirdweb’s wallet software and the wallet you connect): remembers which wallet you connected and keeps you logged in to an in-app wallet. Kept until you clear your browser’s storage; disconnecting your wallet ends the connection.
• thegamedao.pendingLotteryEntries (browser storage): details of a lottery entry you have just made (wallet address, lottery, transaction reference and time). The site keeps them so that it can send the entry to our server again if the first try fails. Kept until our server has dealt with the entry, usually within seconds. Details more than an hour old are removed the next time the site tries again or you open a lottery.
• theme (browser storage): your light or dark display setting. It holds no personal information.
• Cloudflare Turnstile: the “are you human?” check on the contact form and when you sign in. Cloudflare uses your IP address, browser details and similar signals to tell people from bots. Read more in Cloudflare’s Turnstile privacy addendum.

Analytics run only if you choose “Allow analytics” in the notice, or turn analytics on later. Until then, Google Analytics doesn’t load and thirdweb’s usage reports are stopped:

• Google Analytics cookies (names starting with _ga): tell visits apart, so that we can count visitors and see how the site is used. Kept for up to 2 years, unless you turn analytics off or clear your cookies.
• thirdweb’s usage reports (no cookie): thirdweb’s wallet software tells thirdweb when you connect a wallet or send a transaction through the site, with your wallet address, so that thirdweb can count how its software is used.

Changing your choice. You can turn analytics on or off at any time with the analytics setting at the top of this page. When you turn them off, we stop Google Analytics, delete its cookies from your browser and stop thirdweb’s usage reports. Your choice doesn’t affect anything else on the site. You can also block or delete cookies in your browser settings, but if you block necessary cookies, parts of the site, such as signing in, won’t work.

To learn how Google uses information from sites that use Google Analytics, see Google’s page How Google uses information from sites or apps that use our services.

Who we share your data with

We share personal data only as described here. We don’t sell it, and we don’t give it to advertisers.

Service providers handle data for us, on our instructions:

• Vercel hosts the site and keeps its server and security logs.
• Neon hosts our own database: our sales records, player accounts (usernames, encrypted email addresses, sign-in and consent records), the lists our admin keeps (for example of breaks players asked for), records of admin changes and of our team’s look-ups and downloads, and copies of public blockchain activity for profile pages.
• Sanity holds our older records: entry and mint records, referral sign-ups and campaign settings.
• Amazon Web Services (AWS), through its Amazon SES service, may send our account emails, such as email verification codes, and the draw results and news you ask for, and deliver contact-form messages to our team. We keep the mailing list for draw results and news ourselves: AWS gets only the address and the content of each email it sends. We don’t turn on Amazon SES’s tracking of whether you open our emails or click their links. Like many email services, AWS may store and scan the emails it sends, to block spam, phishing, viruses and other harmful messages. If an email to you bounces because the address doesn’t exist (a “hard bounce”), or your email provider tells Amazon SES that you marked one as spam, Amazon SES keeps your address on a list so that we don’t email it again, until we remove it. After a hard bounce, AWS also keeps the address for up to 14 days on a list it uses for all its customers.
• Cloudflare carries all the site’s traffic between your browser and our host, protects the site from attacks and tells us which country a visit comes from. It also runs the “are you human?” check (Turnstile), and uses the check’s signals, under its own privacy policy, to get better at spotting bots.
• thirdweb provides the wallet connection and the email and phone login for in-app wallets, and sends those login codes. It also runs the service our pages use to read the blockchain, so it receives your IP address and the wallet addresses the pages look up. If you allow analytics, its wallet software also reports each wallet connection and each transaction sent through the site to thirdweb, with the wallet address, the type of wallet and the transaction’s details.
• Didit runs our ID checks (see “ID checks”): it holds the photos of your document, your selfie video and the details read from them, in the European Economic Area, and deletes them after 5 years (see “ID checks”).
• Google provides Google Analytics, only if you allow it.

Others who receive personal data:

• X. Our posts on X are public, and X handles them under its own privacy policy (see “Usernames and our posts on X”).
• Campaign partners. During a campaign, the partner can ask us whether a wallet address has entered our lotteries. We answer yes or no, with a score based on how many times that wallet entered during the campaign, and nothing else.
• Wallet providers. If you connect a wallet such as MetaMask or Coinbase Wallet, or connect through WalletConnect, the provider handles your data under its own privacy policy.
• Public blockchains. Your transactions go to BNB Smart Chain or Polygon, where they are public. Links to blockchain explorers such as BscScan, and to X and Discord, take you to sites with their own privacy policies.
• Authorities and advisers. We share data when the law requires it, for example to obey a court order. We also share it with professional advisers: with lawyers, when we need to make or defend a legal claim, and with our accountants and auditors, who receive our sales records for our accounts and tax returns.
• A new owner. If the service is ever transferred to another organisation, your data may be transferred with it. We will say so on this page and, if you have verified an email address with us, tell you by email.

Transfers outside Nigeria

Most of our service providers are based in the United States or Europe. They store and handle data there, and in other countries where they work. This means your personal data may be transferred outside Nigeria and, if you visit from elsewhere, outside your own country. Posts on X and records on public blockchains can be seen from anywhere.

Other countries’ laws may not protect personal data as Nigerian law does. Authorities there may be able to access data, and it may be harder for you to use your rights.

We transfer personal data abroad only on a basis allowed by the Nigeria Data Protection Act. Usually the transfer is needed to provide the service you have asked for, such as hosting the site, connecting your wallet or sending your verification code. Where the Nigeria Data Protection Commission has decided that a country, or a set of safeguards, gives adequate protection, we may rely on that instead. For Google Analytics, and for sending your ID check to Didit, we rely on your consent. We keep a record of the basis for each transfer, and you can ask us for details.

How long we keep your data

We keep personal data only for as long as we need it for the purposes above. Then we delete it, or make it anonymous so that it can no longer identify you.

• Blockchain records: permanent. No one can delete them.
• Copies of blockchain activity in our database: while we run the site. The originals stay public on the blockchain.
• Account details: while your account is open. If you ask us to close your account, we delete your username and email address within 30 days. After that, we keep only your wallet address and a one-way code made from each email address you verified (for as long as we run player accounts), plus the records listed below. The code can’t be turned back into your email address. It only lets us recognise the address if someone uses it again, so that it can never be linked to a second wallet.
• ID check results (whether it passed or why not, Didit’s reference, the dates, the document’s type and country, the 18+ answer, Didit’s warnings, the one-way codes, and any request by our team to pass the check again), whatever the result: while your account is open, then 5 years after it closes or after your last entry, whichever is later, as anti-money-laundering law requires. They can’t be deleted sooner on request, and closing your account doesn’t delete them.
• Photos, video and document details at Didit: 5 years, then Didit deletes them.
• The record of ID checks started (the wallet and the time, to apply the limits on tries): 30 days.
• Sign-in records: 6 months, for player sign-ins and for our team’s sign-ins to the admin dashboard.
• Consent records and records of admin changes (for example a break, a suspension or a moved email address): while your account is open, and for up to 6 years after it closes (for a wallet without an account, 6 years after the change), in case of a dispute or legal claim.
• Records of our team’s look-ups and downloads (a team member looking up what we hold about a wallet, or downloading a file of sales records for our accountants): 1 year.
• Breaks, suspensions and our other wallet lists: a break you asked for, while it runs and for 30 days after it ends; a suspension, until we lift it; our other lists (for example of players who asked us not to record the country of their entries, or of referral links we switched off), until we take the wallet off.
• Sales records (entries and mints): until the end of the seventh year after the year of the entry or mint (for example, records from 2026 are deleted in January 2034), because company and tax law require us to keep accounting records for at least six years. We can’t delete them earlier when asked; the same information stays public on the blockchain anyway.
• Country of an entry made through the site: 90 days.
• Entry and mint records for campaigns: while we run the campaigns they support, and up to 6 months after a campaign ends, unless we need them for a dispute. You can ask us to delete them at any time.
• Referral sign-ups: while you take part in the referral programme, or until you ask us to delete them. Your referral link keeps working, because the smart contract pays referral rewards.
• Contact form messages: up to 6 months after we have dealt with your message, unless we need them for a dispute. AWS may keep its own copy of messages that Amazon SES delivers, for its spam and malware checks, under its own terms.
• Emails we send you, such as verification codes: we don’t have Amazon SES keep a record of each one, but AWS may keep its own copy for its spam and malware checks, under its own terms. If your address goes on Amazon SES’s list of addresses we don’t email (see “Who we share your data with”), it stays there until we remove it.
• Marketing email choices: while your account is open. If you close it, we delete your choice at once; the record of what you agreed to and when is kept like other consent records (above).
• Records of the draw results and news emails we send: each email (its subject and text) and when we sent it, and for each player whether it was sent, skipped or failed and why (by wallet, never the email address): 6 months.
• Email codes: each code we send (kept only as a one-way code), the address it went to (encrypted) and how many tries were made: up to 2 days.
• Login details for in-app wallets: thirdweb keeps the email address or phone number you log in with while it is needed to log you in.
• Server and security logs: our host keeps the logs we can see for between 1 hour and 30 days, depending on our hosting plan. We may keep a copy for longer to look into a fault, misuse or an attack. Our host may also keep its own security records, under its own privacy policy.
• Google Analytics data: 14 months. Reports that show only totals, and can’t identify you, may be kept longer.
• Posts on X: until we delete them. We delete posts that show your username or wallet address if you ask (see “Usernames and our posts on X”).
• Cookies and browser storage: for the times given under “Cookies and browser storage”.

We may keep some data for longer if the law requires it, and then only for that purpose.

How we protect your data

We use technical and organisational measures to protect personal data from loss, misuse and access without permission. For example:

• the site uses an encrypted connection (HTTPS, shown by the padlock in your browser);
• email addresses are stored encrypted in our accounts database, separate from our older records;
• signing in needs a signature from your wallet, which only the holder of the wallet’s keys can make, and a sign-in lasts 7 days;
• only team members who need it can see account details and wallet addresses on our admin dashboard; admin changes, such as moving an email address to a new wallet, are recorded, and so is every look-up of a wallet’s records and every download of our sales records;
• ID checks run on Didit’s own secure page: we never receive your photos or video, and we keep document numbers only as one-way codes;
• our server checks entries and mints on the blockchain, instead of trusting what a browser tells it; and
• the site never holds your private keys or your funds.

Our older records can be read by anyone. Our records at Sanity (entry and mint records, referral sign-ups and campaign settings) are kept in a database that anyone can read. It holds no email addresses or account details. Most of what it holds is already public on the blockchain; referral sign-ups also link an X handle to wallet addresses.

No website is completely secure, so we can’t promise that your data will never be accessed without permission. If a breach of personal data is likely to put your rights at risk, we will report it to the Nigeria Data Protection Commission within 72 hours of finding out. If the risk to you is high, we will tell you straight away, in plain language, with advice on how to protect yourself. If we can’t reach you directly, we will publish a notice instead. We keep a record of every breach.

Keep your wallet’s recovery phrase and private keys to yourself. We will never ask for them, and we will never ask you to send funds to “verify” your wallet.

Your rights and how to use them

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

• be informed about how we use your data, as in this policy;
• access your data: ask whether we hold data about you, why we use it, who receives it and where it came from, and get a copy in a common electronic format;
• correction: have inaccurate, incomplete, misleading or out-of-date data corrected;
• deletion: have your data deleted when we no longer need it, when you withdraw your consent, or when you object and we have no overriding reason to keep it. We can’t delete records the law requires us to keep, such as the results of ID checks, until their period ends;
• restriction: ask us to pause using your data while we deal with a request or an objection, or while a legal claim is being made or defended;
• object to uses based on our legitimate interests, including posts on X that show your username or wallet, and to direct marketing at any time;
• withdraw consent at any time, as easily as you gave it: turn analytics off with the analytics setting, remove your username or turn off draw results and news on your profile page, or use the unsubscribe link in any marketing email. For the ID check, contact us: we then won’t start another check for you, but we keep the records the law requires (see “ID checks”). This doesn’t affect what we did before you withdrew it;
• data portability: get the data you gave us in a structured, machine-readable format, or have it sent to another organisation where that is technically possible. This applies to data we use on the basis of your consent or our contract with you;
• human review: not to be subject to a decision based only on automated processing that significantly affects you, unless the law allows it. You can always ask a person to look at such a decision, give your view and challenge it; and
• complain to the Nigeria Data Protection Commission (see below).

How to make a request. Use our contact form and start your message with “Privacy request”. To protect your data, we may first ask you to show that the request is yours. For example, we may ask you to sign a message with your wallet (free, and not a transaction) or enter a code we email to you.

We reply as soon as we can, and within 30 days. If a request is complex, we may need up to two more months; if so, we will tell you why within the first 30 days. Requests are free. If a request is clearly unfounded or excessive, or would cost an unreasonable amount to meet, we may charge a reasonable fee or refuse it, as the law allows. We will explain why.

What we can’t do. We can’t change or delete anything on a blockchain. Our entry lists and results show every entry with its wallet address, or the player’s username if they have one, so that everyone can check that the games are fair. If you remove your username or close your account, they show your wallet address instead. We may also keep data that we need to meet a legal duty or for a legal claim, such as our sales records, which we must keep as accounting records; we will tell you if this affects your request.

Complaints. If you are unhappy with how we have handled your data, please tell us first through our contact form, so that we can try to put it right. We will look into it and give you our decision within 30 days. You can also complain to the Nigeria Data Protection Commission at any time, whether or not you have contacted us. You can do this through its website, ndpc.gov.ng, by email to [email protected], or with its online form for reporting privacy violations.

In the United Kingdom or the European Economic Area, you have similar rights under the UK GDPR or the EU General Data Protection Regulation. You can also complain to your local data protection authority: in the UK, the Information Commissioner’s Office; in the European Economic Area, the authority in your country (see the list of authorities).

Children

The site is only for people aged 18 or over, or the legal age where they live if that is higher. Every visitor must confirm this in the notice before using the site. We don’t knowingly collect personal data from anyone younger.

If we learn that someone under age has used the site, for example from an ID check, we will suspend their wallet, so that it can’t sign in again, and close their account. We will also delete the data we hold about them, except: their wallet address, kept as suspended; the one-way code made from any email address they verified, so that the address can’t be used for another wallet; their consent records and our records of admin changes, including our decision, for the periods in “How long we keep your data”; and what the law requires us to keep, such as sales records. We can’t delete anything on a blockchain. If you think a child has used the site, please contact us.

Changes to this policy

We may update this policy, for example when we add features or the law changes. We will change the effective date at the top. If we make a significant change, we will tell you on the site and, if you have verified an email address with us, by email, before the change takes effect. If a change needs your consent, we will ask for it.

Contact us

For questions or requests about this policy or your personal data, use our contact form and start your message with “Privacy request”. The form sends your message to our team by email.

You can also find us on X at @bullionLabs and on Discord. If the contact form isn’t working, message us there and we will give you another way to reach us. Please don’t post your email address or other personal details in public messages.