Legal
Privacy policy
This policy explains what personal data Bet Gaffer collects, why, where it is stored, how long we keep it and your rights under the Nigeria Data Protection Act 2023. Today the answer is short: if you join the waitlist, an email address and the time you gave it to us.
Bet Gaffer is football match intelligence: football data and probability analytics, not betting tips. We are not a bookmaker. We take no bets, hold no stakes and pay no winnings.
How to read this page. Every section has two columns. Now (this site) is what applies today, on this site. At full launch is what we intend once accounts and paid plans open; it does not apply yet, and we will publish an updated version of this page before it does.
01 Who we are
Now (this site)
BETGAFFER LTD (RC 9885410), 1 Bouar Close, off Bangui Street, Wuse 2, Abuja runs Bet Gaffer and is the data controller for personal data collected on this site.
For anything in this policy, email contact@betgaffer.com.
At full launch
The same controller will run the full Bet Gaffer service. If we appoint a data protection officer, we will name them here.
02 What we collect
Now (this site)
If you join the waitlist, we keep your email address and the time you submitted it. Nothing else: no name, no phone number, no account, no payment data.
The form asks you to confirm you are 18 or over. We do not store that answer; an address without it is not accepted.
If you only read the site, we collect no personal data ourselves. Cloudflare, which hosts the site, processes technical data such as your IP address in order to deliver pages and protect the site from abuse.
If you email us, we have your message and your email address.
At full launch
When accounts open we will also collect:
- Account details: your email address and a display name.
- Google sign-in, if you choose it: your name, email address and profile picture. We get no access to any other Google data: not your email, files or contacts. We use it only to create your account and sign you in. We do not share it, and we delete it when you close your account.
- Payment data, processed by Paystack. Your card details never reach us; we receive a payment reference and whether the payment succeeded.
- Your Credits balance and history, and the plan you are on.
- Your notification preferences.
- Support correspondence: the messages between you and our support.
- Usage data: which pages and features you use, so we can run and improve the service.
03 Cookies and analytics
Now (this site)
This site sets no cookies. If Cloudflare's security check challenges your connection, Cloudflare may set one strictly necessary cookie (cf_clearance) to remember that you passed.
We use Cloudflare Web Analytics, which is cookieless: it counts page views in aggregate without identifying individual visitors and without following you across other sites.
At full launch
Signing in needs cookies that keep you signed in and protect your account. These are strictly necessary for a service you have asked for.
We will not set analytics or marketing cookies that are not strictly necessary without asking you first, and we will describe any we use here before they are set.
04 Why we use it, and our lawful basis
Now (this site)
- Your waitlist address is used only to tell you when your invite is ready. Lawful basis: your consent, given when you submit the form. You can withdraw it at any time.
- Security and abuse prevention. To stop automated abuse of the waitlist, the form counts sign-up attempts from each IP address (for IPv6, each /56 network) using a keyed one-way hash of that address, held only in Cloudflare's short-term cache for up to an hour, never stored with your email address. Lawful basis: our legitimate interest in keeping the site and the waitlist working.
- Emails you send us are used to answer you. Lawful basis: legitimate interest.
We do not sell personal data, and we do not use it for advertising.
Our probabilities are statistical estimates about football matches, not decisions about you. We make no automated decisions about you.
At full launch
- Contract: to provide your account, your plan and the features you use.
- Legal obligation: to keep the payment and tax records the law requires.
- Legitimate interest: security, fraud prevention and improving the service.
- Consent: marketing messages and optional notifications, which you can switch off at any time.
We will still not sell personal data.
06 Transfers outside Nigeria
Now (this site)
Waitlist addresses are stored by Cloudflare, Inc., a company in the United States, on its global network. Your address therefore leaves Nigeria.
The waitlist form tells you this at the point you submit your address. The transfer relies on your consent, given there, and on Cloudflare's contractual data-processing terms, which require it to protect the data and process it only to provide its service to us.
Data protection law in the United States may protect your address less than Nigerian law does.
Emails you send us are forwarded by Cloudflare to the operator's mailbox, hosted by an email provider, which may store them outside Nigeria. We use your message only to answer it.
At full launch
Some processors, including Cloudflare and Google, are outside Nigeria. Before launch we will list each transfer here, with its destination and the safeguard it relies on under the Nigeria Data Protection Act 2023.
07 How long we keep it
Now (this site)
- Waitlist addresses: until 12 months after full launch, and never more than 24 months after you joined, unless you withdraw your consent sooner.
- Rate-limit hashes: up to an hour, in Cloudflare's short-term cache.
- Emails you send us: as long as we need them to deal with your message.
At full launch
- Account data: until you close your account, plus any period the law requires us to keep records (for example, payment and tax records).
- Usage data: 2 years after your last activity.
- Marketing consent: until you withdraw it.
08 Your rights
Now (this site)
Under the Nigeria Data Protection Act 2023 you have the right to:
- be told how your data is used (this page);
- access the data we hold about you;
- rectification of data that is wrong;
- erasure of your data;
- restrict how we use it;
- withdraw your consent at any time (this does not affect what we did before you withdrew it);
- object to our use of it;
- data portability: receive your data in a common electronic format;
- complain to the Nigeria Data Protection Commission.
How to use them: email contact@betgaffer.com from the address concerned and say what you want. The operator handles every request by hand. We will reply within 30 days, and we may ask you to confirm the request from that address before acting on it. Removing your waitlist address is a one-line email.
At full launch
You will have the same rights. We will publish how to exercise each one from your account before accounts open; email will always work, and we will reply within 30 days.
09 Children
Now (this site)
This site is for adults aged 18 and over and is not directed at anyone under 18. The waitlist requires you to confirm you are 18 or over. If we learn that we hold a waitlist address belonging to someone under 18, we delete it.
At full launch
Accounts will be for adults aged 18 and over only. If we learn that an account belongs to someone under 18, we will close it and delete its data, except records the law requires us to keep.
10 Security
Now (this site)
The site is served over HTTPS only. Waitlist addresses are held in Cloudflare's storage. Access to them is limited to the operator, through the operator's Cloudflare account and the site code the operator deploys. We collect as little as we can, so there is little to lose: an email address and a time.
If a breach affects personal data we hold, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware of it, and tell the people affected without undue delay.
At full launch
The same commitments apply. Card details are handled by Paystack and never reach our systems.
11 Changes to this policy
Now (this site)
When this policy changes, we update this page and its "Last updated" date. If we ever want to use waitlist addresses for anything other than your invite, we will ask for your consent first.
At full launch
The same applies at full launch.
Questions about this policy
Email contact@betgaffer.com. We reply to every request about your data within 30 days. You can also complain to the Nigeria Data Protection Commission.
BETGAFFER LTD (RC 9885410), 1 Bouar Close, off Bangui Street, Wuse 2, Abuja