DRAFT – for legal review. Not yet approved. Placeholders in [brackets] must be completed.

Privacy Policy

This policy explains how [COMPANY] (registration number [REG NO]), [ADDRESS] ("we") processes personal information under the Protection of Personal Information Act 4 of 2013 (POPIA). Information Officer: [NAME], [EMAIL].

What we collect

• Name, email address and mobile number.
• South African ID number, used only to verify you are 18 or older and to prevent duplicate accounts. Your ID number is special personal information about you; we store it encrypted and restrict access to it.
• Date of birth (derived from your ID number), gameplay data (free coin bets, results), chat messages, IP address and device data.

Why we use it

• To run your account, the free-to-play game, chat and the daily leaderboard (performance of our agreement with you).
• To verify age and contact and verify prize winners (legal obligation / legitimate interest).
• Direct marketing by email or SMS only if you ticked the optional marketing box. You can opt out at any time via the unsubscribe link, by replying STOP, or by emailing [EMAIL]. [Specify which brands/operators may market to you – e.g. [COMPANY] and named partners – legal to confirm.]

Sharing

We use service providers (hosting, email/SMS delivery) under written agreements. [List any cross-border transfers and safeguards.] We do not sell your personal information.

Retention

[Retention period – e.g. while your account is active plus [X] years.] Prize winner records are kept for [X] years as required by the Consumer Protection Act.

Your rights

You may request access to, correction or deletion of your information, object to processing, and lodge a complaint with the Information Regulator (inforeg.org.za).

Last updated: [DATE]