Privacy Policy

Effective Date: 1 April 2026Version 1.0

Your Privacy Matters

This Privacy Policy explains how Awa Lawa Limited (operating SantiDraw by SantiLotto) collects, uses, stores, and protects your personal information. By using our Platform or entering a Draw, you agree to the practices described in this policy.

Contents

1.Who We Are 2.Information We Collect 3.How We Use Your Information 4.Legal Basis for Processing 5.How We Share Your Information 6.Data Retention 7.Your Rights 8.Data Security 9.Cookies and Tracking Technologies 10.Children's Privacy 11.Links to Third-Party Sites 12.Changes to This Privacy Policy 13.How to Complain 14.Contact Us

1Who We Are

SantiDraw is a prize draw product operated by Awa Lawa Limited, a company registered in Nigeria and the licensed operator of SantiLotto. For the purposes of this Privacy Policy, Awa Lawa Limited is the data controller responsible for your personal information.

Awa Lawa Limited (SantiLotto — SantiDraw)

Email: support@santidraw.com

Website: www.santidraw.com

2Information We Collect

We collect the following categories of personal information when you register, participate in a Draw, or interact with our Platform:

2.1 Information You Provide Directly

Full name
Nigerian mobile telephone number
Email address (where provided)
Payment information (processed securely via our payment providers — we do not store card or bank details)
Any messages or correspondence you send to us

2.2 Information Collected Automatically

Device information (type, operating system, browser)
IP address and approximate location data
Pages visited, time spent on the Platform, and clickstream data
Cookies and similar tracking technologies (see Section 9)

2.3 Information from Third Parties

Transaction confirmation data from our payment service providers
Identity verification data where required for regulatory compliance

3How We Use Your Information

We use your personal information for the following purposes:

3.1 Draw Administration

To process your Draw entry and validate payment
To notify you if you have won a Prize via SMS or email
To administer Prize delivery and fulfil our obligations to winners

3.2 Account Management

To create and manage your account on the Platform
To authenticate your identity and secure your account
To send you service-related communications

3.3 Legal and Regulatory Compliance

To comply with obligations under the Ekiti State Lotteries Board licence
To fulfil anti-money laundering (AML) and know-your-customer (KYC) obligations
To respond to regulatory enquiries or law enforcement requests

3.4 Customer Support

To respond to your queries, complaints, and requests
To investigate and resolve disputes

3.5 Platform Improvement

To analyse usage patterns and improve the Platform experience
To conduct internal research and analytics

3.6 Marketing (with your consent)

To send you promotional communications about new Draws, offers, and updates where you have opted in
You may opt out of marketing communications at any time by contacting us at support@santidraw.com

4Legal Basis for Processing

We process your personal data on the following legal bases under applicable Nigerian data protection law (Nigeria Data Protection Act 2023 and NDPR):

Contract performance — processing necessary to administer your Draw entry and deliver Prizes
Legal obligation — processing required to comply with gaming regulations, AML laws, and tax obligations
Legitimate interests — processing for fraud prevention, platform security, and service improvement
Consent — processing for marketing communications, where you have given explicit consent

5How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following limited circumstances:

5.1 Service Providers

We share data with carefully selected third-party providers who assist us in operating the Platform, including:

Payment processors — to process entry fee transactions securely
SMS service providers — to deliver Draw notifications and winner alerts
Cloud hosting and IT infrastructure providers
Analytics and fraud prevention services

All service providers are contractually bound to process your data only on our instructions and to maintain appropriate security measures.

5.2 Regulatory and Legal Disclosure

We may disclose your information to the Ekiti State Lotteries Board, the Nigeria Data Protection Commission, law enforcement agencies, or courts where required by law or to protect our legal rights.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of business assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

6Data Retention

We retain your personal information for as long as is necessary to fulfil the purposes described in this policy, subject to the following:

Account data is retained for the duration of your account and for 6 years after closure for legal and regulatory purposes
Transaction records are retained for a minimum of 6 years in compliance with Nigerian tax and financial regulations
Draw entry records are retained for 2 years following each Draw
Marketing consent records are retained until you withdraw consent, and for 2 years thereafter

When your data is no longer required, it will be securely deleted or anonymised.

7Your Rights

Under the Nigeria Data Protection Act 2023, you have the following rights in relation to your personal data:

Right of access — to request a copy of the personal data we hold about you
Right to rectification — to request correction of inaccurate or incomplete data
Right to erasure — to request deletion of your data where it is no longer necessary for the purposes it was collected
Right to restrict processing — to request that we limit how we use your data in certain circumstances
Right to data portability — to receive your data in a structured, machine-readable format
Right to object — to object to processing based on legitimate interests or for direct marketing
Right to withdraw consent — to withdraw consent for marketing at any time without affecting prior lawful processing

To exercise any of these rights, please contact us at support@santidraw.com. We will respond within 30 days. We may request proof of identity before processing your request.

8Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, destruction, or disclosure. These include:

Secure HTTPS encryption on the Platform
Access controls limiting data access to authorised personnel only
Regular security assessments and monitoring
Secure processing of all payment data through PCI-compliant payment providers

While we take all reasonable precautions, no method of transmission over the internet is completely secure. You should take steps to protect your account credentials and notify us immediately of any suspected breach.

9Cookies and Tracking Technologies

Our Platform uses cookies and similar technologies to enhance your experience. Cookies are small text files placed on your device when you visit the Platform.

9.1 Types of Cookies We Use

Essential cookies — necessary for the Platform to function (e.g., maintaining your session)
Analytics cookies — to understand how visitors use the Platform and improve its performance
Preference cookies — to remember your settings and preferences

9.2 Managing Cookies

You can control cookies through your browser settings. Disabling essential cookies may affect the functionality of the Platform. By continuing to use the Platform, you consent to our use of cookies as described above.

10Children's Privacy

SantiDraw is strictly for individuals aged 18 and over. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that a minor has provided us with personal data, we will delete it immediately. If you believe a minor has registered on our Platform, please contact us at support@santidraw.com.

11Links to Third-Party Sites

The Platform may contain links to third-party websites, including payment processors and external services. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

12Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be notified on the Platform with at least 7 days' advance notice. The effective date at the top of this document will be updated accordingly.

Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised policy.

13How to Complain

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.

We would, however, appreciate the opportunity to address your concerns directly before you approach the regulator. Please contact us first at support@santidraw.com.

14Contact Us

For all privacy-related enquiries, requests, or complaints, please contact our Privacy team:

Awa Lawa Limited (operating as SantiLotto — Santo Draw)

Email: support@santidraw.com

Website: www.santidraw.com

SantiDraw is a product of Awa Lawa Limited, licensed by the Ekiti State Lotteries Board.

This policy is governed by the Nigeria Data Protection Act 2023 and the Nigeria Data Protection Regulation (NDPR).