Privacy Policy

Privacy Policy

Lottorbit · Version 1.0

1. Introduction and Scope

1.1. Lottorbit is in the process to be licensed and regulated by the Tobique Gaming Commission ("Commission"). This Privacy Policy ("Policy") explains how Lottorbit ("we", "us", "the Company") collects, uses, discloses, and protects personal data belonging to customers who register an account ("you", "the Customer") to access our remote gaming services ("Services"), which we intend to operate under a licence from the Commission pursuant to the Tobique Gaming Act 2023 ("Gaming Act") and the General Code of Practice for Remote Gaming License Holders ("the Code").

1.2. This Policy forms part of, and should be read together with, our Terms and Conditions. It is published on our homepage and must be read and agreed to when you register an Account.

1.3. As the operator with a direct contractual relationship with you, we act as the controller of your personal data and comply with applicable data protection laws in the jurisdictions where you are based and where we operate.

2. Information We Collect

2.1. Registration information: to open an Account, we collect your full name, email address, date of birth, and physical address.

2.2. Identity and age verification information: to verify your identity and age, and to meet our anti-money laundering obligations, we may collect supporting documentation such as a passport, driving licence, or birth certificate, and may use electronic verification services or third-party databases.

2.3. Electronic footprint: as part of registration and ongoing use of the Services, we record technical data about you, including your IP address, device and computer identifiers, internet cookies, and other relevant technical data.

2.4. Transactional and account information: we maintain records of your deposit and withdrawal history, current balance, gambling transaction history, any gaming management tools or exclusions you have applied, and details of any previous or related accounts, including reasons for deactivation.

2.5. Communications: records of correspondence between you and our customer support or complaints teams, including any complaint or dispute details.

3. How We Use Your Information

3.1. We collect and use only the minimum information required for the purposes described in this Policy. We use your information to:

• open, administer, and secure your Account;
• verify your identity and age, and screen for money laundering, sanctions exposure, and fraud;
• process deposits, withdrawals, and gaming transactions;
• provide customer support and investigate complaints or disputes;
• apply gaming management tools, self-exclusion, and other responsible gaming measures you have requested or that we are required to apply;
• meet our obligations to the Commission, including record-keeping, reporting, and responding to lawful requests for information; and
• with your additional specific consent, send you marketing communications.

3.2. We do not use your information for any purpose other than those described in this Policy or otherwise disclosed to you at the time of collection.

4. Data Accuracy and Updates

4.1. We keep your registration and account information accurate, up to date, and relevant to the purpose for which it was disclosed. We may periodically ask you to confirm or update your information, and may carry out further verification where required by our anti-money laundering obligations.

4.2. It is your responsibility to notify us promptly of any change to your registration details.

5. How We Share Your Information

5.1. Information provided by, or relating to, you will not be disclosed to a third party or used for any purpose other than the purpose for which it was given or obtained, unless the disclosure or use is: approved by you in writing; reasonably necessary for the conduct of the Services; or required to comply with a legal obligation, a request from the Commission, or an official investigation.

5.2. We may share your information with: the Commission, to the extent they are entitled to access account information for regulatory or supervisory purposes; law enforcement or regulatory authorities, where required by law or in connection with a suspected money laundering or other illegal activity; identity verification and payment service providers, to the extent necessary to verify your identity or process a transaction; and our approved dispute resolution provider, where a complaint has been escalated.

5.3. Gaming software providers and other suppliers who handle your personal data on our behalf act as data processors. We maintain agreements with these processors requiring them to protect your information to a standard consistent with this Policy and applicable data protection laws.

5.4. We do not sell your personal data.

6. Marketing Communications

6.1. Where we intend to use your data for a purpose not directly related to providing the Services, such as marketing, we will ask for your additional specific consent.

6.2. You may withhold or withdraw this consent at any time without affecting your ability to use the Services. Withholding consent to marketing is never used as grounds to refuse to conduct business with you.

7. Data Retention

7.1. We retain your customer transactional information, including the particulars described in Clause 2 above, for a period of five (5) years from the date of your last activity with us, and will provide this information to the Commission upon request.

7.2. Where information is backed up for disaster recovery purposes, the backup does not contain personal information beyond the Transaction ID, Player ID, transaction amount, and final account standing.

7.3. Where we are no longer required to retain your information under this Clause or applicable law, we will take reasonable steps to delete or anonymise it.

8. Data Security

8.1. We maintain information security processes designed to protect your information from unauthorised access, use, copying, disclosure, disruption, modification, or destruction, and maintain an audit trail of relevant actions.

8.2. Our security policies and procedures are documented, communicated to relevant staff, and reviewed at least annually or following any material change or system failure.

8.3. Access to your Account is controlled by a unique username and password, or an equivalent secure method, and all system user actions are logged.

9. Your Rights

9.1. Depending on the data protection laws applicable to you, you may have rights to access, correct, or request the deletion of your personal data, to object to or restrict certain processing, and to receive a copy of your data in a portable format.

9.2. To exercise any of these rights, please contact us using the details in Clause 12 below. We will respond within the timeframe required by applicable law.

9.3. Some of these rights may be limited where we are required to retain or process your information to meet our obligations under the Gaming Act, the Code, or to the Commission.

10. Cookies and Electronic Footprint

10.1. We use cookies and similar technologies to operate our website, secure your Account, and, where you have provided consent, for analytics and marketing purposes.

10.2. You can manage cookie preferences through your browser settings; disabling certain cookies may affect the functionality of our website.

11. Children and Minors

11.1. Our Services are not available to persons under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we hold data belonging to an underage individual, we will take the steps described in our Terms and Conditions and Underage Gaming information, including suspending the relevant Account.

12. Contact Us

12.1. If you have any questions about this Policy, or wish to exercise any of your data protection rights, please contact us via our customer support at support@lottorbit.com.

12.2. If you are not satisfied with our response, you may also have the right to lodge a complaint with the data protection authority applicable in your jurisdiction.

13. Changes to This Policy

13.1. We will notify you when we make significant changes to this Policy, and will keep a record of how and when such notifications were made. We will notify the Commission of significant changes within 24 hours, together with the rationale for making them.

13.2. This Policy is date-stamped and version-controlled. Previous versions are available on request.