Privacy Policy
This Privacy Policy should be read in conjunction with the CHANCES Terms of Service. Defined terms used in this Policy shall, unless otherwise defined herein, have the meanings ascribed to them in the Terms of Service.
You must be 18 years or older to use CHANCES. No exceptions.
Your Wallet is for gameplay and prizes only. No cash withdrawals unless game rules say otherwise.
You can self-exclude from the Platform at any time by contacting support@chances.show.
We use your personal data to run the game and keep you safe. We do not sell your data.
CHANCES is a game of chance. Outcomes are random and fair. You can request human review of any automated decision.
All amounts are in Nigerian Naira (₦). Standard mobile data charges may apply.
This summary is provided for convenience only. The full legal terms below govern your use of the Platform.
Introduction
This Privacy Policy ("Policy") describes how Tantainment Limited (RC 455252), a private company limited by shares incorporated under the Companies and Allied Matters Act 2020 and registered with the Corporate Affairs Commission of Nigeria, with its registered office at 74 Oduduwa Crescent, GRA, Ikeja, Lagos State, Nigeria ("Tantainment", "we", "our", or "us"), collects, processes, stores, discloses, and protects personal data in connection with the CHANCES by Tantainment platform ("the Platform").
The Platform comprises: (a) the CHANCES mobile application (available on iOS and Android); (b) the CHANCES web portal; (c) the CHANCES live broadcast studio experience in Lagos, Nigeria; (d) the CHANCES agent distribution network; and (e) all related digital and physical services operated by or on behalf of Tantainment in connection with the CHANCES game.
Tantainment is a subsidiary of Tantalizers Plc, a company listed on the Nigerian Exchange Group (NGX). The Platform operates under a licence issued by the Lagos State Lotteries and Gaming Authority ("LSLGA") pursuant to the Lagos State Lotteries and Gaming Authority Law 2021.
This Policy is issued in compliance with the Nigeria Data Protection Act 2023 ("NDPA"), the General Application and Implementation Directive 2025 ("GAID"), the Child Rights Act 2003, the Cybercrimes Act 2015 (as amended), the Lagos State Lotteries and Gaming Authority Law 2021, and all applicable subsidiary legislation.
This Policy applies exclusively to the CHANCES Platform. The Tantainment corporate website at tantainment.com is governed by a separate Tantainment Website Privacy Policy, available at tantainment.com/privacy.
By registering for, accessing, or using the Platform in any manner, you acknowledge that you have read, understood, and agree to the collection, processing, and use of your personal data in accordance with this Policy. If you do not agree, you must immediately cease using the Platform.
Data Controller and Data Protection Officer
2.1 Data Controller
The data controller responsible for processing your personal data under this Policy is Tantainment Limited (RC 455252).
- Registered Address: 74 Oduduwa Crescent, GRA, Ikeja, Lagos State, Nigeria
- Privacy Enquiries: support@chances.show
- General Support: support@chances.show
2.2 Data Protection Officer
Pursuant to Section 32 of the NDPA and the GAID, Tantainment has designated a Data Protection Officer ("DPO") with responsibility for overseeing compliance with applicable data protection laws and this Policy.
- Email: support@chances.show
- Postal Address: Data Protection Officer, Tantainment Limited, 74 Oduduwa Crescent, GRA, Ikeja, Lagos State, Nigeria
The DPO shall serve as the primary point of contact for data subjects exercising their rights under the NDPA and for the NDPC in relation to any data protection matter concerning the Platform.
Definitions
In this Policy, the following terms shall have the meanings set out below, unless the context otherwise requires:
- "Agent" means an authorised third party within the CHANCES agent distribution network, appointed to facilitate user onboarding and related services.
- "CHANCES Game" or "the Game" means the live broadcast interactive gaming show operated by Tantainment, including all gameplay mechanics, prize structures, and associated entertainment content.
- "Data Subject" means any identified or identifiable natural person whose personal data is processed by or on behalf of Tantainment in connection with the Platform.
- "Home Play" means participation in the CHANCES Game via the mobile application or web portal, as distinct from in-studio participation.
- "Participant" means a User who is actively selected or called upon to play in a game session, whether in-studio or via Home Play.
- "Personal Data" has the meaning given to it under Section 65 of the NDPA.
- "Studio Audience" means persons present in the CHANCES broadcast studio as spectators who are not actively participating in a game session at the relevant time.
- "User" means any natural person who accesses, registers for, or uses the Platform in any capacity.
- "Wallet" means the internal digital ledger maintained on the Platform for each registered User, used solely for recording gameplay credits, prizes, and related Platform transactions. The Wallet is not a bank account, does not bear interest, is not insured by the NDIC, and does not permit withdrawals of cash or monetary value except as expressly provided in the applicable game rules.
Categories of Personal Data We Collect
4.1 Account Registration Data
When you create a CHANCES account, we collect: your full legal name; date of birth; gender; telephone number (mobile); email address; residential address; nationality; and a valid government-issued means of identification (including, as applicable, National Identification Number (NIN), Bank Verification Number (BVN), voter's card, international passport, or driver's licence). We may also collect a photograph or live selfie for identity verification and KYC purposes.
4.2 Financial and Transactional Data
When you fund your Wallet, receive prizes, or conduct transactions on the Platform, we collect: bank account details; payment card information (where applicable, processed by our authorised payment partners); Wallet transaction history; and records of transactions conducted through Agents. Financial data is processed through our enterprise resource planning ("ERP") system and Wallet infrastructure.
Clarification: The Wallet is an internal ledger for gameplay and prize-tracking purposes only. It is not a deposit account, does not bear interest, and is not insured by the NDIC. No withdrawals of cash or monetary value are permitted from the Wallet except as expressly defined in the rules of a specific game episode.
4.3 Gameplay and Interaction Data
We collect data relating to your participation in the CHANCES Game, including: game session identifiers; dice rolls and board positions; quiz questions presented and responses given; prizes won, forfeited, or transferred; gameplay suspension events; interactions with branded game boxes and sponsored content; Home Play participation records; and timestamps associated with all gameplay events.
4.4 Technical and Device Data
We automatically collect: your Internet Protocol (IP) address; device type, manufacturer, and model; operating system type and version; browser type and version; unique device identifiers (including advertising identifiers); mobile network carrier information; application version; crash logs, error reports, and diagnostic data; and usage analytics (session duration, feature usage frequency, navigation paths).
4.5 Location Data
With your prior consent (obtained through your device's operating system permission settings), we may collect approximate or precise geolocation data. Location data is used to: (a) verify that you are accessing the Platform from a jurisdiction in which you are eligible to participate; (b) comply with regulatory and licensing requirements; and (c) improve service delivery. You may revoke location access at any time through your device settings; however, this may limit certain Platform functionalities.
4.6 Live Broadcast and Studio Data
4.6.1 Studio Audience
If you attend the CHANCES studio as a member of the Studio Audience, your image, likeness, and voice may be captured by studio broadcast cameras, production cameras, and closed-circuit television ("CCTV") surveillance systems. By entering the studio premises, you acknowledge and consent to being filmed, recorded, and potentially included in broadcast footage. Signage at the studio entrance shall inform all attendees of this practice.
4.6.2 Participants
If you are selected as a Participant in a CHANCES Game session, your image, likeness, voice, name, seat number, biographical information shared on-air, and gameplay performance shall be recorded and broadcast. Participation in the Game requires your explicit, informed, written consent to be filmed, recorded, and broadcast, which shall be obtained through a separate Participant Release and Consent Form prior to your participation. This consent is a precondition of participation and cannot be implied.
4.6.3 CCTV
The CHANCES studio premises are equipped with CCTV surveillance systems for the purposes of security, safety, and incident investigation. CCTV footage is processed on the lawful basis of legitimate interest and legal obligation. CCTV signage is displayed at all entry points to the studio facility.
4.7 Communications Data
We collect the content of any correspondence you send to us, including: customer support enquiries submitted through the Platform or by email; complaints and feedback; and interactions with CHANCES or Tantainment accounts on social media platforms.
4.8 Agent Network Data
If you register as a CHANCES Agent, we additionally collect: your business registration details (including CAC registration number); agent location and operating address; commission records; customer onboarding activity logs; and any additional information required by the LSLGA or other regulatory body.
Purposes of Processing and Lawful Bases
We process your personal data for the purposes set out below. Each purpose is linked to a specific lawful basis under Section 25 of the NDPA.
We process your registration and identity data to create and maintain your account, verify your identity (including NIN against NIMC records and BVN against NIBSS records), and comply with applicable KYC and anti-money laundering obligations.
We process your gameplay data, Wallet data, and related information to operate the Game, track game progress, allocate and record prizes, and administer the Wallet ledger.
We process financial and transactional data to facilitate Wallet funding, record credits and debits, and maintain accurate financial records as required by law.
We process broadcast and studio data to produce, broadcast, distribute, and archive the CHANCES live game show and related content.
We process technical data, transactional data, and gameplay data to detect and prevent fraud, money laundering, collusion, manipulation of game outcomes, and other security threats.
We process personal data as necessary to comply with requirements imposed by the LSLGA, the NDPC, the NBC, law enforcement agencies, and any other competent authority.
We process communications data and account data to respond to your enquiries, resolve complaints, and manage disputes.
We process technical data, device data, and aggregated usage data to analyse Platform performance, improve features, develop new products, and enhance user experience. Where practicable, analytics are performed on anonymised or pseudonymised data.
We process your name and contact details to send promotional offers, newsletters, and marketing communications relating to the Platform. You will only receive marketing communications where you have provided your prior, express, informed consent. You may withdraw consent at any time (see Section 6).
Where the Game includes charitable prize elements, we process relevant transactional data to record and verify donations.
We shall not process your personal data for any purpose that is incompatible with the purposes set out above, unless we have obtained your specific consent or are required to do so by law.
Consent
Where processing is based on consent, your consent must be freely given, specific, informed, and unambiguous, in accordance with Section 26 of the NDPA.
You have the right to withdraw your consent at any time by: (a) adjusting your account preferences on the Platform; (b) clicking the "unsubscribe" link in any marketing communication; or (c) contacting us at support@chances.show.
Withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal. Withdrawal of consent for processing that is essential to Platform functionality (for example, location verification for eligibility) may result in the restriction or termination of your access to affected features.
Disclosure of Personal Data
We may disclose your personal data to the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements or binding legal obligations:
- Technology partners and data processors: our ERP provider, Wallet infrastructure provider, game engine developer, mobile application developers, web hosting providers, Amazon Web Services (AWS) and other cloud service providers, and analytics providers, each acting as a data processor on our behalf pursuant to written data processing agreements compliant with Section 29 of the NDPA.
- Banking and payment partners: authorised banking institutions and payment service providers engaged for the processing of Wallet funding transactions and financial settlement.
- Identity verification and KYC providers: authorised third-party identity verification providers engaged to authenticate User identity by verifying NIN data against NIMC records and BVN data against NIBSS records.
- Regulatory authorities: the LSLGA, the NDPC, the NBC, the Central Bank of Nigeria, the Economic and Financial Crimes Commission, and any other competent regulatory or law enforcement authority, as required by law or valid legal process.
- Broadcast and content distribution partners: television networks, digital streaming platforms, and content distribution networks engaged for the production and distribution of the CHANCES broadcast.
- Professional advisers: legal counsel, auditors, tax advisers, and consultants engaged by Tantainment, each subject to professional duties of confidentiality.
- Agents: authorised CHANCES Agents within the agent distribution network, to the extent necessary for customer onboarding and related Agent functions.
- Affiliated entities: Tantalizers Plc (our parent company) and its subsidiaries, for internal administrative, reporting, and compliance purposes, subject to appropriate intra-group data sharing arrangements.
We do not sell, rent, or trade your personal data to any third party.
Any third-party recipient of personal data shall be required to process such data in compliance with the NDPA and this Policy, and only for the purposes for which the data was disclosed.
Cross-Border Data Transfers
The Platform engages technology partners and service providers located outside Nigeria, including partners based in India (game engine development and ERP services), Amazon Web Services (AWS) and other cloud service providers whose servers may be located in jurisdictions including the United States, the European Union, and other territories, and analytics providers operating internationally.
Where personal data is transferred to a jurisdiction outside Nigeria, Tantainment shall ensure that one or more of the following safeguards is in place, in accordance with Part V of the NDPA:
- The recipient country or territory has been determined by the NDPC to provide an adequate level of data protection
- Tantainment has executed binding contractual clauses with the data recipient that impose obligations substantially equivalent to those imposed on Tantainment under the NDPA
- The transfer is necessary for the performance of a contract between the data subject and Tantainment
- The transfer is necessary for important reasons of public interest recognised under Nigerian law
- The data subject has given explicit, informed consent to the transfer after being informed of the possible risks
Details of the safeguards applicable to specific cross-border transfers may be obtained by contacting the DPO at support@chances.show.
Data Security
Tantainment implements appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage, in accordance with Section 39 of the NDPA. These measures include:
- Encryption of personal data in transit (TLS 1.2 or higher) and at rest
- Network segmentation isolating game engine systems, ERP/Wallet infrastructure, and broadcast systems
- Role-based access controls with the principle of least privilege
- Multi-factor authentication for administrative access
- Regular penetration testing and vulnerability assessments
- Intrusion detection and prevention systems
- CCTV monitoring and physical access controls at the studio facility
- Documented incident response and business continuity procedures
- Regular staff training on data protection and information security
No method of electronic transmission or storage is completely secure. In the event of a personal data breach, Tantainment shall: (a) notify the NDPC within 72 hours of becoming aware of the breach, in accordance with Section 40 of the NDPA; (b) notify affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms; and (c) document the breach, its effects, and the remedial actions taken.
Data Retention
Tantainment retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law, regulation, or regulatory directive.
| Data Category | Retention Period |
|---|---|
| Account and identity verification data | Duration of account relationship + 6 years thereafter |
| Financial and Wallet transaction records | 6 years from the date of the transaction |
| Gameplay session logs | 3 years from the date of the game session |
| Broadcast recordings | As long as reasonably required for regulatory compliance, archival, and lawful promotional purposes |
| CCTV footage | 90 days from date of capture (unless retained for a specific incident or legal proceeding) |
| Marketing consent records | Duration of consent period + 2 years following withdrawal or expiry |
| Communications and support records | 3 years from the date of the last interaction |
| Agent network records | Duration of the Agent relationship + 6 years thereafter |
Upon expiry of the applicable retention period, personal data shall be securely and irreversibly deleted or anonymised using methods appropriate to the sensitivity of the data and the storage medium.
Your Rights as a Data Subject
Under the NDPA, you have the following rights in respect of your personal data. These rights are subject to the conditions and limitations set out in the NDPA and the GAID:
Obtain confirmation of whether Tantainment processes your personal data, and receive a copy of that data in an intelligible form. (Section 34 NDPA)
Request the correction of inaccurate personal data or the completion of incomplete personal data. (Section 35 NDPA)
Request the deletion of your personal data where it is no longer necessary for the purpose collected, or has been unlawfully processed. (Section 36 NDPA)
Request the limitation of processing in certain circumstances, including where you contest the accuracy of the data. (Section 37 NDPA)
Receive your personal data in a structured, commonly used, and machine-readable format, and transmit it to another controller, where technically feasible.
Object to processing based on legitimate interest or for direct marketing purposes. Where you object to direct marketing, processing for that purpose shall cease immediately. (Section 37 NDPA)
Not be subject to a decision based solely on automated processing that produces legal effects or similarly significant effects. (Section 36(2) NDPA)
Withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal. (See Section 6)
To exercise any of these rights, contact the DPO at support@chances.show. Tantainment shall respond to a valid request within 30 days of receipt. If you are unsatisfied with Tantainment's response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).
Age Restriction
The Platform is strictly restricted to persons aged 18 and over. We do not knowingly collect, process, or store the personal data of any person under the age of 18. No exceptions are made and no parental or guardian consent is accepted as a substitute for the age requirement.
If Tantainment becomes aware, or has reasonable grounds to believe, that a User is under the age of 18, Tantainment shall: (a) immediately suspend and terminate the relevant account; (b) delete all personal data associated with that account; and (c) forfeit any Wallet balance or prizes associated with that account.
If you believe that a person under the age of 18 has created an account or provided personal data to the Platform, please notify us immediately at support@chances.show.
Automated Decision-Making and Profiling
The CHANCES Game engine employs automated processes for core game mechanics, including random number generation for dice rolls, shuffle validation for board progression, and algorithmic prize allocation. These automated processes determine game outcomes, which may have financial consequences for Users.
Tantainment acknowledges that automated game mechanics may produce effects of financial significance to Users. Accordingly:
- The game engine is subject to independent fairness certification and periodic audit
- The random number generation process is designed to ensure statistical fairness and is not influenced by user identity, transaction history, or profile
- Users have the right to request human review of any automated decision that has produced a legal or similarly significant effect, by contacting support@chances.show. Tantainment shall respond within 14 days
- Game rules, including the mechanics governing automated outcomes, are published and communicated before or at the start of each game session
Tantainment may employ automated fraud-detection systems that analyse transactional patterns. Where such systems produce a decision that restricts your account or Wallet, you shall be notified and provided with the opportunity to request human review.
Data Protection Impact Assessment
Pursuant to Section 28 of the NDPA, Tantainment has conducted, and shall continue to maintain and update, Data Protection Impact Assessments ("DPIAs") for processing activities that are likely to result in a high risk to the rights and freedoms of data subjects. DPIAs have been completed for the following processing activities:
- Gaming systems: automated game mechanics, random number generation, prize allocation, and shuffle validation
- Financial records and Wallet operations: processing of financial and transactional data, including Wallet funding, credit allocation, and transaction logging
- Broadcast and biometric-adjacent data: capture and processing of image, likeness, and voice of Studio Audience members and Participants
- Cross-border data transfers: transfer of personal data to technology partners located outside Nigeria
- Identity verification: transmission of NIN and BVN data to third-party verification providers for authentication against NIMC and NIBSS national identity databases
Where a DPIA indicates that processing would result in a high risk that cannot be mitigated, Tantainment shall consult the NDPC prior to commencing such processing. DPIAs are reviewed and updated at least annually, or upon any material change to the relevant processing activity.
Cookies and Similar Technologies
The CHANCES web portal and mobile application may use cookies, software development kit (SDK) analytics, pixels, and similar technologies to: (a) enable essential Platform functionality; (b) analyse usage patterns; (c) improve user experience; and (d) deliver targeted content (with consent).
You may manage your cookie and tracking preferences through: (a) the cookie consent mechanism presented upon first access to the web portal; (b) your device or browser settings; or (c) your account preferences on the Platform. Essential cookies required for core Platform functionality cannot be disabled.
For detailed information about the cookies and tracking technologies used on the Platform, their purposes, and retention periods, refer to the Cookie Notice accessible from the Platform.
Third-Party Links and Services
The Platform may contain links to, or embedded content from, third-party websites, sponsor content, branded game boxes, and partner services. Tantainment is not the data controller for any personal data collected by such third parties and is not responsible for their privacy practices.
We encourage you to review the privacy policies of any external service before providing your personal data.
Changes to This Policy
Tantainment reserves the right to amend this Policy at any time to reflect changes in our data processing practices, applicable law, regulatory guidance, or business operations.
Material changes shall be notified to Users by: (a) publishing the updated Policy on the Platform with a revised "Last Updated" date; and (b) where practicable, issuing a push notification, in-app notice, or email notification at least 14 days before the changes take effect.
Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the amended Policy. If you do not agree with any amendment, you must cease using the Platform and may request deletion of your account.
Governing Law and Jurisdiction
This Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act 2023 and all applicable subsidiary legislation.
Any dispute arising from or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts of Lagos State, Nigeria, without prejudice to the right of a data subject to lodge a complaint with the NDPC.
Contact Information
Contact Us
For questions, concerns, or requests regarding this Policy or the processing of your personal data, reach us through any of the channels below.