Privacy Policy

1. INTRODUCTION

PredictBeta Nigeria Limited (“WonCut”, “Company”, “we”, “our”, or “us”) operates WonCut, an AI-powered sports rewards marketplace that helps users discover partner offers, earn cashback rewards, accumulate loyalty benefits, access lifestyle rewards, and engage with participating betting operators, merchants, restaurants, hotels, travel providers, entertainment providers, and other partners.

This Privacy Policy explains how WonCut collects, uses, stores, shares, transfers, protects, and otherwise processes personal information when users access or use the WonCut platform, including its websites, mobile applications, wallet services, rewards programmes, artificial intelligence services, attribution systems, partner integrations, and related services (collectively, the “Platform”).

We are committed to protecting personal information and processing personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA), regulations issued by the Nigeria Data Protection Commission (NDPC), and other applicable privacy, cybersecurity, consumer protection, and digital services laws in Nigeria.

By accessing or using the Platform, you acknowledge and agree that your personal information may be processed in accordance with this Privacy Policy.

2. ABOUT WONCUT

WonCut is a technology-enabled sports rewards marketplace operated by PredictBeta Nigeria Limited.

The Platform enables users to:

• submit and analyze eligible betslips and betting opportunities;
• discover participating licensed betting operators;
• compare available partner offers;
• access enhanced payout opportunities;
• receive cashback rewards and bonuses;
• participate in loyalty programmes;
• earn and redeem reward points;
• access restaurant, hotel, travel, retail, entertainment, and lifestyle rewards;
• receive promotional offers and incentives; and
• engage with participating partners through a unified rewards ecosystem.

WonCut's core functionality includes AI-powered betslip analysis, partner offer discovery, rewards attribution, cashback administration, loyalty programme management, Points Wallets, Cash Wallets, and wallet-based rewards across participating betting operators and lifestyle partners.

WonCut is not a sportsbook, bookmaker, casino operator, lottery operator, betting exchange, or gambling operator.

All wagering activity occurs exclusively with independently operated third-party licensed betting operators.

3. DATA CONTROLLER

PredictBeta Nigeria Limited acts as the Data Controller responsible for personal data processed through the Platform.

For privacy-related enquiries, users may contact:

Email: privacy@predictbeta.com

4. WHY WE COLLECT INFORMATION

WonCut operates a rewards marketplace and rewards ecosystem that depends upon the collection and processing of information necessary to:

• analyze user-submitted betslips;
• identify relevant partner offers;
• compare available opportunities;
• calculate cashback rewards;
• administer loyalty programmes;
• operate Points Wallets and Cash Wallets;
• verify reward eligibility;
• process redemptions;
• administer referrals;
• support attribution systems;
• facilitate partner reporting;
• prevent fraud and abuse;
• improve platform functionality; and
• provide customer support.

The information we collect enables these services to function properly and helps ensure rewards are accurately administered across participating operators and partners.

5. INFORMATION WE COLLECT

5.1 Information You Provide

We may collect:

• full name;
• email address;
• phone number;
• date of birth;
• username;
• password credentials;
• account profile information;
• identification or verification information;
• customer support communications;
• referral information;
• National Identification number;
• marketing preferences; and
• other information voluntarily submitted through the Platform.

5.2 Betslip and Opportunity Information

We may collect:

• betslips;
• bet codes;
• betting selections;
• wagering information voluntarily submitted by users;
• sportsbook preferences;
• offer preferences;
• opportunity selections;
• reward preferences; and
• partner interactions.

5.3 Rewards and Wallet Information

Points Wallet Information

We may process information relating to:

• loyalty points;
• reward points;
• promotional points;
• bonus points;
• points transfers;
• points redemptions;
• points conversions; and
• programme participation history.

Cash Wallet Information

We may process information relating to:

• cashback rewards;
• promotional bonuses;
• referral incentives;
• campaign rewards;
• wallet balances;
• wallet transfers;
• wallet redemptions;
• reward conversions; and
• cash-based reward activity.

5.4 Attribution and Rewards Information

We may collect information relating to:

• offer interactions;
• referral activity;
• qualifying activities;
• qualifying wagers;
• reward eligibility;
• partner confirmations;
• attribution records;
• commission validation records; and
• programme participation history.

5.5 Device and Technical Information

We may automatically collect:

• IP addresses;
• browser information;
• operating system information;
• device identifiers;
• application identifiers;
• session information;
• usage analytics;
• log information;
• network information; and
• cookie-related information.

5.6 Information Received From Partners

We may receive information from:

• licensed betting operators;
• restaurants;
• hotels;
• hospitality providers;
• travel providers;
• retailers;
• merchants;
• payment providers;
• marketing partners; and
• other participating partners.

Such information may include attribution confirmations, qualifying activity confirmations, reward eligibility information, referral information, redemption confirmations, and other programme administration information.

6. HOW WE USE PERSONAL INFORMATION

We may use personal information to:

• create and manage user accounts;
• verify eligibility;
• authenticate users;
• provide Platform services;
• analyze betslips;
• identify relevant partner offers;
• generate recommendations;
• compare opportunities;
• calculate cashback rewards;
• administer loyalty programmes;
• administer Points Wallets and Cash Wallets;
• validate referrals;
• process redemptions;
• communicate with users;
• provide customer support;
• prevent fraud and abuse;
• improve Platform functionality;
• conduct analytics and reporting;
• enforce our Terms of Service;
• fulfill contractual obligations; and
• comply with legal and regulatory obligations.

7. AI, ANALYTICS AND AUTOMATED PROCESSING

WonCut may utilize artificial intelligence, machine learning systems, analytics technologies, automation tools, and predictive models to:

• analyze submitted betslips;
• identify relevant partner offers;
• compare opportunities;
• surface promotional opportunities;
• support cashback calculations;
• administer rewards programmes;
• facilitate attribution processes;
• improve user experience; and
• enhance platform functionality.

AI-generated outputs may include:

• recommendations;
• rankings;
• comparisons;
• opportunity scores;
• projected value assessments;
• rewards opportunities; and
• promotional opportunities.

Such outputs are intended to assist users in discovering available opportunities and rewards.

AI-generated outputs do not constitute financial advice, investment advice, legal advice, or guarantees of profitability, winnings, performance, or success.

8. ATTRIBUTION, REFERRALS AND REWARDS TRACKING

WonCut operates attribution and rewards systems that enable the administration of cashback programmes, loyalty benefits, referral incentives, wallet-based rewards, and partner offers.

We may track:

• offer clicks;
• registrations;
• account creations;
• referrals;
• qualifying activities;
• qualifying wagers;
• reward redemptions;
• wallet activity;
• partner interactions; and
• programme participation.

Attribution information may be used to:

• verify reward eligibility;
• calculate cashback rewards;
• issue rewards;
• administer referrals;
• validate partner commissions;
• support partner reporting;
• prevent fraud;
• administer loyalty programmes; and
• improve programme performance.

9. COOKIE, ATTRIBUTION AND REWARDS TRACKING NOTICE

WonCut operates a rewards ecosystem that relies on attribution technologies to verify qualifying activities, administer cashback programmes, allocate rewards, validate referrals, and support partner reporting.

To support these functions, WonCut and participating partners may use:

• cookies;
• pixels;
• SDKs;
• unique identifiers;
• referral links;
• API integrations;
• server-to-server integrations; and
• similar technologies.

These technologies help determine whether qualifying activities were completed through WonCut and whether rewards, cashback, bonuses, loyalty points, commissions, or other benefits should be issued.

9.1 How Offer Tracking Works

When a user interacts with an offer presented through WonCut, the Platform may generate identifiers or tracking records that help associate subsequent qualifying activities with the user's account.

Tracked activities may include:

• clicking a partner offer;
• registering with a partner;
• linking an account;
• completing a qualifying activity;
• placing an attributed wager through a participating operator;
• completing a qualifying purchase;
• redeeming an offer;
• earning a reward; or
• completing another eligible activity.

9.2 How Rewards Are Calculated

Rewards may be calculated based upon:

• qualifying activities;
• partner programme rules;
• attribution confirmation;
• promotional campaigns;
• reward multipliers;
• referral activity;
• loyalty status;
• wallet eligibility requirements; and
• other programme criteria.

Reward calculations may vary across operators, merchants, restaurants, hotels, travel providers, entertainment providers, and other participating partners.

9.3 Referral Validation

WonCut may validate referrals, rewards, cashback claims, and programme benefits using:

• attribution systems;
• partner confirmations;
• account verification procedures;
• device information;
• session information;
• anti-fraud systems; and
• other verification measures reasonably necessary to protect programme integrity.

9.4 Circumstances Where Attribution May Fail

Attribution may fail due to:

• browser restrictions;
• ad blockers;
• private browsing modes;
• operating system privacy settings;
• device changes;
• cookie deletion;
• network interruptions;
• partner platform failures;
• incorrect account linking;
• unsupported user journeys;
• fraud prevention controls; or
• technical circumstances outside WonCut's reasonable control.

Where attribution cannot be verified, WonCut may be unable to issue associated rewards, cashback, bonuses, referral incentives, loyalty points, or other benefits.

9.5 Programme Integrity

WonCut reserves the right to investigate, adjust, suspend, reverse, withhold, or remove rewards where attribution cannot be verified, fraud is suspected, programme abuse occurs, technical errors are identified, or programme rules have been violated.

10. LEGAL BASIS FOR PROCESSING

WonCut processes personal information based on one or more lawful grounds including:

• user consent;
• performance of a contract;
• compliance with legal obligations;
• protection of legitimate business interests;
• fraud prevention and security purposes; and
• other lawful grounds recognized under applicable law.

11. SHARING OF PERSONAL INFORMATION

WonCut does not sell personal data.

WonCut may share limited information with participating operators, merchants, restaurants, hotels, travel providers, payment providers, service providers, and other partners where reasonably necessary to:

• verify reward eligibility;
• confirm qualifying activities;
• administer cashback programmes;
• process redemptions;
• calculate commissions;
• validate referrals;
• prevent fraud;
• fulfill partner offers;
• provide requested services; or
• comply with legal obligations.

WonCut seeks to limit information sharing to information reasonably necessary for the applicable purpose.

12. INTERNATIONAL DATA TRANSFERS

Personal information may be processed, stored, or transferred outside Nigeria where service providers, infrastructure providers, partners, or technology vendors are located.

Where international transfers occur, WonCut shall implement reasonable safeguards designed to protect personal information in accordance with applicable legal requirements.

13. DATA RETENTION

WonCut retains personal information only for as long as reasonably necessary to:

• provide Platform services;
• administer rewards programmes;
• operate wallet services;
• fulfill contractual obligations;
• resolve disputes;
• prevent fraud;
• enforce agreements; and
• comply with legal obligations.

Retention periods may vary depending on the nature of the information and applicable legal requirements.

14. DATA SECURITY

WonCut implements reasonable technical, administrative, organizational, and security measures intended to protect personal information against unauthorized access, disclosure, misuse, alteration, destruction, or loss.

Although we strive to protect personal information, no method of transmission or storage can guarantee absolute security.

Users are encouraged to maintain appropriate security practices for their own devices and accounts.

15. YOUR PRIVACY RIGHTS

Subject to applicable law, users may have the right to:

• access personal information;
• request correction of inaccurate information;
• request deletion of certain information;
• restrict processing;
• object to certain processing activities;
• withdraw consent;
• request portability of personal information; and
• lodge complaints with the Nigeria Data Protection Commission (NDPC).

Privacy requests may be submitted to:

privacy@predictbeta.com

16. CHILDREN'S PRIVACY

WonCut is intended only for individuals who are at least eighteen (18) years of age.

We do not knowingly collect personal information from minors.

Where we become aware that personal information relating to a minor has been collected, we may take reasonable steps to delete such information and restrict access to the Platform.

17. THIRD-PARTY SERVICES

The Platform may contain links to, integrations with, or services provided by:

• licensed betting operators;
• restaurants;
• hotels;
• travel providers;
• retailers;
• merchants;
• payment providers; and
• other third parties.

WonCut is not responsible for the privacy practices, security practices, or data processing activities of third-party services.

Users should review the privacy policies of relevant third parties before engaging with such services.

18. CHANGES TO THIS PRIVACY POLICY

WonCut may update this Privacy Policy from time to time.

Material updates may be communicated through the Platform, email, notifications, or other reasonable methods.

Continued use of the Platform following publication of an updated Privacy Policy constitutes acceptance of the revised Privacy Policy.

19. CONTACT INFORMATION

PredictBeta Nigeria Limited

Privacy Enquiries: privacy@predictbeta.com

For questions regarding privacy, personal information, data protection rights, NDPA compliance, or this Privacy Policy, users may contact WonCut through the channels made available on the Platform or through the email address above.