PRIVACY POLICY
This Privacy Policy (hereinafter referred to as the “Policy”) governs the collection, usage, storage, disclosure, and protection of personal and non-personal data obtained from users of the website accessible via www.todaysurewin.com (hereinafter referred to as the “Website”), owned and operated by Today Sure Win Inc. (hereinafter referred to as “we,” “our,” or “the Company”).
This Policy is made in accordance with applicable data protection laws and is binding upon all users, visitors, subscribers, or any other individual accessing or interacting with the Website (hereinafter collectively referred to as “Users”).
SECTION 1: PURPOSE AND SCOPE
1.1 This Policy is enacted for the purpose of providing Users with transparent information regarding the manner in which their data is collected, utilized, processed, and safeguarded by the Company.
1.2 By accessing and using this Website, Users hereby consent to be bound by the terms contained herein. Users who do not agree with this Policy are advised to discontinue use of the Website forthwith.
SECTION 2: INFORMATION COLLECTED
2.1 The Company may, in the ordinary course of business, collect the following categories of information:
(a) Personal Identifiable Information (PII):
This includes but is not limited to names, email addresses, and any information voluntarily submitted via contact forms or subscriptions.
(b) Non-Personal Information (NPI):
This includes IP addresses, browser types, device identifiers, geolocation data, operating system, referral URLs, and browsing behaviour, collected via cookies or analytics tools.
SECTION 3: LEGAL BASIS FOR DATA COLLECTION
3.1 The collection and processing of personal and non-personal data shall be conducted in accordance with lawful bases including but not limited to:
(a) The User’s explicit consent;
(b) The performance of a contract or pre-contractual measures;
(c) The Company’s legitimate interest in maintaining and improving the Website and services rendered thereon.
SECTION 4: USE OF INFORMATION
4.1 Data collected pursuant to this Policy shall be used for the following purposes:
(a) To personalize the User’s experience;
(b) To respond to User inquiries and customer service requests;
(c) To analyze traffic and usage patterns for the purpose of improving Website functionality;
(d) To serve contextually relevant content and advertisements;
(e) To ensure compliance with applicable laws and regulations.
SECTION 5: COOKIES AND TRACKING TECHNOLOGIES
5.1 The Website employs the use of cookies, web beacons, and other tracking technologies (hereinafter referred to as “Cookies”) for the purpose of improving User experience and measuring performance.
5.2 Users are hereby notified that third-party vendors, including but not limited to Google, may use cookies to serve ads based on a User’s previous visits to this or other websites.
5.3 Users may choose to disable or delete cookies through their browser settings; however, such action may impair certain functionalities of the Website.
SECTION 6: THIRD-PARTY SERVICES AND DISCLOSURE
6.1 The Company may employ third-party service providers for analytics, advertisement, and technical services, including Google AdSense.
6.2 The Website utilizes Google AdSense, a service provided by Google Inc., which may use cookies (such as the DART cookie) to serve advertisements based on a User’s prior visits to this and other sites.
6.3 Users may opt out of personalized advertising by visiting: https://www.google.com/settings/ads
6.4 The Company does not sell, lease, or otherwise disclose personal data to third parties except:
(a) When required by law or legal process;
(b) To enforce the terms of use or protect rights and safety;
(c) With the User’s express consent.
SECTION 7: NON-AFFILIATE DISCLOSURE
7.1 For the avoidance of doubt, the Company hereby states and affirms that:
(a) It is not affiliated with any betting, gambling, or wagering platforms;
(b) It does not promote, endorse, or receive commissions from any sports betting operators;
(c) All content, including predictions, previews, and statistical insights, is strictly intended for informational and entertainment purposes only;
(d) The Website does not offer “sure bets,” “guaranteed wins,” or promote wagering in any form or manner.
SECTION 8: DATA SECURITY
8.1 The Company adopts reasonable administrative, physical, and technical safeguards to protect User data against unauthorized access, alteration, disclosure, or destruction.
8.2 While the Company endeavors to use commercially acceptable means to protect personal data, Users acknowledge that no method of transmission over the internet is entirely secure.
SECTION 9: USER RIGHTS
9.1 Users are entitled to the following rights under applicable data protection laws:
(a) The right to access their personal data;
(b) The right to rectify inaccurate or incomplete data;
(c) The right to request deletion of their data (“right to be forgotten”);
(d) The right to restrict or object to data processing;
(e) The right to data portability (where applicable).
9.2 Users may exercise any of the above rights by submitting a request to: Mydata@todaysurewin.com.
SECTION 10: CHILDREN’S PRIVACY
10.1 This Website is not directed at persons under the age of thirteen (13) years.
10.2 The Company does not knowingly collect or solicit personal information from children under the age of thirteen. If such data is discovered, it shall be promptly deleted.
SECTION 11: RETENTION OF DATA
11.1 Data collected from Users shall be retained for as long as necessary to fulfill the purposes outlined herein, unless a longer retention period is required or permitted by law.
SECTION 12: CHANGES TO THIS POLICY
12.1 The Company reserves the right to amend, revise, or update this Policy at any time without prior notice.
12.2 Users are encouraged to periodically review this page to stay informed of any changes. Continued use of the Website after modifications constitutes acceptance of the revised terms.
SECTION 13: GOVERNING LAW AND JURISDICTIO
13.1 This Policy shall be governed and construed in accordance with the laws of the Federal Republic of Nigeria.
13.2 Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts located within Ogun State, Nigeria.
SECTION 14: CONTACT INFORMATION
14.1 For inquiries, clarifications, or exercise of rights under this Policy, Users may contact the Company through:
Email: Info@todaysurewin.com
This Policy is issued this day 21 of July, 2023.
Written and Authorized by:
M. A. Gbadubo, Esq.
Head of Legal Team
Today Sure Win Inc.