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LOOTJIE GROUP (PTY) LTD – PRIVACY POLICY

THIS PRIVACY POLICY IS SUBJECT TO THE TERMS AND CONDITIONS OF THE LOOTJIE

GROUP (PTY) LTD.

BY CONTINUING TO USE THE LOOTJIE PLATFORM, WEB OR MOBILE APPLICATION, YOU AGREE THAT YOU READ

AND THAT YOU WILL COMPLY WITH THE TERMS AND CONDITIONS SET OUT IN THIS PRIVACY

POLICY.

PLEASE NOTE LOOTJIE USES COOKIES TO COLLECT AND GATHER INFORMATION

AND THAT BY CLICKING OR SUBMITTING INFORMATION VIA ANY FORMAT TO THE LOOTJIE

APP OR LOOTJIE GROUP (PTY) LTD, YOU CONSENT TO THE COLLECTION, COLLATION,

PROCESSING AND STORING OF SUCH INFORMATION AND THE USE AND DISCLOSURE OF

SUCH INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

WE RECOMMEND THAT YOU READ THIS PRIVACY POLICY TOGETHER WITH OUR TERMS AND

CONDITIONS PRIOR TO SUBMITTING INFORMATION AND / OR USING THE LOOTJIE APP.

 

INTRODUCTION

1. Lootjie Group (Pty) Ltd with registration number: 2021/849363/07, a private company with limited

liability, duly incorporated and in terms of the company laws of the Republic of South Africa,

(hereinafter referred to as “Looitjie”) undertakes to abide by all applicable Laws and regulations of

the Republic of South Africa The contract between Lootjie and the Customer is made in terms of

these laws and the terms and conditions herein contained. Customers agree to abide by all

legislated requirements and these terms and conditions. It remains the Customers sole

responsibility to ensure that they agree and understand all terms and conditions on an ongoing

basis.

2. The opening of a Lootjie account and more particularly the conduct of entering competitions or 

transacting with Lootjie and its Customers shall be exclusively governed by the Laws of the

Republic of South Africa.

3. Lootjie is not an online gambling and / or lottery platform and as such is not regulated by the

National Gambling Act 33 of 1996 and is not licenced by the National Gambling Board of South

Africa.

4. The Laws of the Republic of South Africa recorded are, inter alia, the following:

4.1. the Financial Intelligence Centre Act 38 of 2001 read with its regulations (as amended from time to

time) (“FICA”);

4.2. the Protection of Personal Information Act 4 of 2013 read with its regulations (as amended from

time to time); and

4.3. the Electronic Communications and Transactions Act No 25 of 2002 read with its regulations (as

amended from time to time)

1. GENERAL

The Bill of Rights under the Constitution of the Republic of South Africa, 1996 gives everyone the right to

privacy, which includes the right not to have the privacy of their communications infringed. The

Protection of Personal Information Act 2013 (“POPIA”) gives effect to the constitutional right to privacy.

In compliance with POPIA, Lootjie Group (Pty) Ltd (“the Company”) wishes to inform its users of the

way it processes their Personal Information in this privacy policy.

2. DEFINITIONS

The definitions to key terms for the purpose of this policy can be found below.

2.1. “Information Officer” - The role assigned to a person who is responsible for encouraging the

Company to remain compliant with POPIA.

2.2. “Operator” - A person who processes personal information for a responsible party in terms of a

contract or mandate without coming under the direct authority of that party.

2.3. “Personal Information” - Information relating to an identifiable, living, and natural person. Personal

Information can include but is not limited to a person’s name, race, gender, marital status, address,

identity number, e-mail address, physical address, telephone number, location, face data and

online identifier.

2.4. “Processing” - Any operation, activity or set of operations, whether or not by automatic means,

concerning personal information which includes but is not limited to the collection, receipt,

recording, organisation, collation, storage, updating or modification, retrieval, alteration,

consultation or use, dissemination by means of transmission, distribution or making available in

any other form, merging, linking, restriction, degradation, erasure or destruction of information.

2.5. “Responsible Party” - A public or private body, or any other person which, alone or in conjunction

with others, determines the purpose of and means for processing personal information.

2.6. “Services” - The goods and services, which includes the access to the Lootjie App, promoted,

offered, or provided by the Company.

3. RESPONSIBLE PARTY

The Responsible Party is Lootjie Group (Pty) Ltd, with registered office as indicated on Lootjie's official web site,

 ( www.lootjie.co.za) for online competition services through its own mobile application (hereinafter referred to as “Lootjie”).

4. INFORMATION COLLECTED

4.1. We collect Personal Information either because (i) it is required to be able to promote, offer or

supply our Services to you; or (ii) to improve our Services. A full list of why we process your

information can be found below under “How we use your information”. You are under no obligation

to provide Personal Information to us. However, much of the Personal Information we request is

essential for the provision and quality of our Services (for example, enabling you to buy tickets on

our App). We may not be able to provide you with our Services if you choose to withhold requested

information.

4.2. When you navigate through the mobile application which is managed by us, we collect browser

and cookie information. In addition, we may also collect your IP address and technical information

relating to the device you are accessing our mobile application from.

4.3. During the registration process and when you subsequently use your account, you are requested

to submit specific Personal Information including, but not limited to:

4.3.1. Your first and last name;

4.3.2. Date of birth;

4.3.3. Credit card or other payment data;

4.3.4. Identity number;

4.3.5. Source of Income;

4.3.6. Home or another physical address;

4.3.7. E-mail address; and

4.3.8. Phone/mobile number or other contact data.

4.3.9. Face Data (“Selfie”)

4.4. In addition to the above, you will be asked to create a unique username and password combination

for your account. This information is required to enable easy access to our services.

4.5. Once you have created an account and have become a registered customer, additional information

is processed on an on-going basis to ensure that our services are offered to you in the best

possible manner. You must use your unique username and password to access your account.

4.6. When you are logged into your account, we may collect:

4.6.1. a record of all internet communications and details of your visits to our mobile application;

4.6.2. technical information relating to the device, such as the device identifier, and application

version you use to access our mobile application;

4.6.3. details of transactions you carry out through the mobile application, such as payments,

withdrawals and engagement in promotional activity;

4.6.4. communications with us or our employees which includes calls, emails, and messages

sent through to Lootjie;

4.6.5. information regarding your location, including IP address.

4.7. In certain instances, we may also request that you send us additional information to verify your

identity. This may include:

4.7.1. copies of photographic identification documents;

4.7.2. proof of address; and

4.7.3. source of funds for your account.

4.7.4. Your documents are always stored and treated in a secure manner.

4.8. In some limited instances, we may conduct open-source checks which involves the access of

public records and publicly available information about you including news articles, social media

accounts, forums posts and official records such as the electoral roll.

4.9. To ensure your safety and that of the Company, we use services provided by third parties to help

us decide whether to accept transactions from you by assessing your method of payment and the

devices you use to visit our mobile application. These third-party services check whether the

device or method of payment has been utilised for fraudulent or abusive transactions in the past

such as reported instances of identity theft, promotion abuse, or credit card fraud.

5. FACE DATA (“SELFIE”) POLICY

5.1. What is face data: A selfie or multiple selfies — for example, a selfie looking straight at the camera,

as well as profile selfies looking left and right.

5.2. The Lootjie Group may verify your identification by comparing an identity document with your

image (e.g., selfie).

5.3. Selfie identity verification is a verification process that requires the user to take and submit a selfie in

order to have their identity verified.

5.4. Selfie checks offer increased protection against fraud caused by database breaches and serve as an

easy way to verify users.

5.5. The user takes and submits a photo of their government-issued ID, such as a driver’s license,

mobile or passport.

5.6. The information from the ID is cross-checked against official databases as well as other user-

supplied information to check for discrepancies.

5.7. To confirm that the user is in fact the person on the ID, the user may be asked to take and submit a

selfie or series of selfies.

5.8. We will not share your face data with any third party, nor will we store any face information you

submit, and the photos you upload will be deleted after the analysis process is complete.

6. DELIVERY POLICY

6.1. A confirmation message will be displayed on the App and an email sent to the Customer’s email

address when a ticket has been purchased and / or a bet has been placed successfully.

Transactions are deemed to have been accepted as soon as they have been registered on our

systems and a transaction has been processed against the Player’s account and a ticket has

generated, regardless of whether or not the confirmation message is received by the Player.

6.2. All transactions are accepted after the official start of an event will be void, unless the event is

specifically labelled as being available in running.

6.3. The Customer is solely responsible for ensuring that transactions are processed accurately.

Transactions and purchases cannot be cancelled by the Customer once accepted by Lootjie.

7. HOW WE USE YOUR INFORMATION

7.1. We use the information we collect to protect you or other third parties, provide, maintain, protect

and improve our Services, and develop new Services. We also use this information to offer you

tailored content like giving you more relevant promotional offers, should you consent to receive our

promotional marketing material.

7.2. We process your Personal Information for the purposes of:

7.2.1. creating and managing your account;

7.2.2. providing you with gambling services;

7.2.3. if necessary, contacting you via your registered contact information in connection with the

management and operation of your account;

7.2.4. processing your online financial transactions;

7.2.5. researching your preferences to develop new features, functionality, products and

services;

7.2.6. ensuring our mobile application is functioning correctly and identifying any technical

issues;

7.2.7. complying with all our legal and regulatory requirements, such as those relating to the

identification of individuals under anti-money laundering legislation and ensuring

responsible gambling;

7.2.8. preventing fraudulent activity or cheating;

7.2.9. determining what promotions and bonuses to offer you should you consent to receive

marketing material; and

7.2.10. providing you, unless you have opted out, with information, by the contact methods you

authorise us to use, about our services, and selected third party services, products,

competitions, prizes and offers.

7.3. We actively manage our financial liabilities and risk on events and markets. Liability and exposure

controls can be applied across markets and/or individual accounts to manage those liabilities. The

Operator may assess your data (including Personal Information) to determine motivations for

opening an account or buying a ticket. Should your activity stand out from what we consider to be

ordinary and expected behaviour, further analysis is performed. In line with our terms and

conditions, we may exclude you from certain promotions or from placing certain bets as a result of

this investigation. Examples of unusual purchasing behaviour can be, though is not limited to:

7.3.1. a ticket purchased by a customer who may be privy to information regarding the potential

outcome of an event;

7.3.2. a customer changing their gambling pattern;

7.3.3. a large number of tickets purchased in a short time period on one specific outcome.

7.4. Any analysis performed is a private business owned commodity and is not transmitted to any third

party. We reserve the right to apply restrictions to customer accounts where the Company believes

it to be appropriate due to their gambling activity

8. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

8.1. Certain trusted third-party entities provide services essential to our ability to offer our gambling

products to you. These third parties include but are not limited to:

8.1.1. those that supply the software and games for our mobile application;

8.1.2. banking and payment services;

8.1.3. identity verification companies;

8.1.4. fraud prevention and risk management companies.

8.2. We are required to share some of your information with these entities to offer our Services to you.

In these instances, we take reasonable measures to ensure that the third party has appropriate

security and privacy arrangements in place to ensure your data is protected.

8.3. In compliance with regulatory obligations, we may be required to disclose your information to

government authorities, such as the police or our regulators. Personal information may also be

shared with regulators, agencies, or relevant sports bodies in instances where we become

suspicious that an account holder may be involved in fixing or the breach of governing regulations.

We will also disclose information as required to enforce our terms of use as stated in our Terms

and Conditions.

8.4. In the event of the sale of our business, or other business event, which results in us having to

transfer your Personal Information to a third party, you will be notified via email or notice posted on

our mobile application to explain the identity of the new Responsible Party and your options

regarding your Personal Information.

8.5. Our mobile application may contain links to and from the websites of third-party organisations.

Please note that these websites may have their own privacy policies and that we do not accept any

responsibility whatsoever for these policies. Please check these policies carefully before you

submit any Personal Information.

9. MARKETING AND OPTING OUT

9.1. The Operator reserves the right to process personal Information for marketing purposes. In certain

limited circumstances, we also reserve the right to provide this information to our third-party

partners for the purpose of marketing our services to you provided that you have already

consented or give us your consent to do this.

9.2. We request your consent to market to you when you first create an account with us, you can

choose not to receive marketing/promotional material at any time. By opting out or denying such

consent has no influence on the registration of a Lootjies account.

9.3. If you have opted out of marketing from us, we will take all reasonable steps to ensure you no

longer receive promotional material about our services. This may affect your eligibility for certain

promotional bonuses.

9.4. Even if you unsubscribe from our marketing mailing list, we may continue to send out periodic e-

mails and/or SMSes informing you of technical, service or security issues related to a product or

service you requested, confirming you requested a product or service, or providing periodic

updates or information relating to the product or service you requested or any other form of

communication we are obliged to send you in terms of legislation.

9.5. Please note that should you opt out of receiving marketing/promotional material from us, there

might be a delay in removing you from our marketing/promotional lists. We estimate 7 days from

opting out to remove you from our mailing list. Should you continue to receive

marketing/promotional material after 7 days from opting us, we ask that you notify us in order to

investigate why you have not been removed from the mailing list.

10. YOUR RIGHTS

10.1. We respect your privacy rights and therefore you may contact us at any time and request the

following:

10.1.1. the Personal Information we hold about you;

10.1.2. to rectify your Personal Information if it becomes inaccurate or incomplete;

10.1.3. to have incomplete Personal Information completed. This may include providing a

supplementary statement. Whether or not this is appropriate in any particular case

depends on the purposes for which your information is being processed;

10.1.4. to erase your Personal Information if:

10.1.4.1. your Personal Information has been processed unlawfully by us; or

10.1.4.2. your Personal Information is no longer necessary for the purposes for which it was

collected by us; or

10.1.4.3. You object to processing and there is no overriding legitimate interest for continuing to

process your Personal Information.

10.1.4.4. to restrict our processing of your Personal Information if:

10.1.4.5. you contest the accuracy of the Personal Information held by us (for a period enabling

us to verify the accuracy of the Personal Information);

10.1.4.6. our processing activities are unlawful; or

10.1.4.7. we no longer need your Personal Information but you would like us to retain it to

ensure its continued availability to you in connection with any legal claims.

10.1.4.8. You undertake to update us if there are any changes or inaccuracies in your Personal

Information.

10.2. Please note that objecting to our processing of your Personal Information will result in us being

unable to continue to offer our Services to you which may lead to us closing your account. When

requesting any of the above information from us, you have the right to ask that your Personal

Information be provided to you in a generally understandable format.

10.3. Kindly note that the above rights are not absolute. There are instances where applicable law or

regulatory requirements allow or require us to refuse your request. For example, we may refuse

your request in instances where we need to process the Personal Information to exercise or

defend legal claims. In addition, in certain instances, your Personal Information may have been

destroyed, erased, or made anonymous in accordance with our record retention obligations and

practices.

10.4. To exercise your rights, you are required to submit a request detailing what information you wish to

enquire about, together with proof of identity to customer support at info@lootjie.co.za We may

then request further details in order to process your request.

10.5. If you are not satisfied with how we have processed your Personal Information and want to raise a

complaint, please contact us directly at sales@tribedaholdings.co.za.

10.6. If you are still not satisfied with our response or believe we are not collecting or processing your

Personal Information in accordance with the applicable laws, you can lodge a complaint with the

Information Regulator of South Africa whose contact details are available at

https://justice.gov.za/inforeg/.

11. COOKIE POLICY

11.1. Cookies are text files containing a small amount of information that are downloaded to your device

when you visit a website or a web enabled mobile application. Most websites and web enabled

mobile applications utilise cookies to improve your online experience and to ensure that content

and functions are delivered and used more effectively.

11.2. Cookies perform various different functions. Persistent cookies can be used to help our mobile

application remember you as a returning visitor or to ensure the online adverts you receive are

more relevant to your specific needs and interests.

11.3. The primary use of cookies on our mobile application, either directly by the Company or our

chosen partner(s), is to:

11.3.1. enable you to save time and facilitate future access to the mobile application;

11.3.2. identify how people navigate through our mobile application to improve our Service,

content and the effectiveness of our communications;

11.3.3. collect and share device data to detect and prevent devices associated with fraud and

money laundering;

11.3.4. identify account and device irregularities and detect and prevent fraudulent

transactions and abuse of our customer accounts and our Services.

11.4. You agree that the Operator may, from time to time, place cookies on your device to save

information (such as your username, password, personal details, e-mail address, and technical

device information such as the model and its IP address) to make full use of the functionality and

Services on our mobile application and to allow your mobile device to identify you as a user. This

ensures that you do not have to re-enter your information each time you visit our mobile

application. These cookies cannot be used to run programs or deliver viruses to your mobile device

and are uniquely assigned to you. Additionally, these cookies can only be read by the web

server(s) that placed the cookies on your device.

11.5. At any time, you can amend your settings to block some or all cookies from the Operator. However,

if you block cookies from the Operator, some or all the of functionality of our mobile application

may not perform as intended. For example, you may not actually be able to buy any tickets or

partake in any promotional activity.

12. TRANSFER AND STORAGE OF YOUR PERSONAL INFORMATION

12.1. The data we collect from you may be transferred to, and stored at, a destination outside of the

Republic of South Africa. It may also be processed by staff operating outside South Africa who

work for the Company or for one of our suppliers. Such staff may be engaged in, among other

things, the fulfilment of your request, the processing of your payment details, the provision of

support services, or any other activity related to servicing any of your requests that you might place

with us from over the course of your time with us.

12.2. We will take all reasonably necessary steps to ensure that your Personal Information is treated

securely and in accordance with this privacy policy by making sure such transfers comply with

applicable laws. Once we have received your information, we will use strict procedures and

security measures to prevent unauthorised access and ensure the integrity and availability of

Personal Information.

12.3. We are required to keep full records of all financial and wagering transactions together with any

identification provided. We will hold your Personal Information on our systems for as long as is

necessary under our legal obligations.

13. RETENTION

Except as otherwise permitted or required by applicable law or regulatory requirements, we endeavour to

retain your Personal Information only for as long as we believe is necessary to fulfil the purposes for

which the Personal Information was collected (including but not limited to for the purpose of meeting any

legal, accounting, or other reporting requirements or obligations). We may, instead of destroying or

erasing your Personal Information, make it anonymous such that it cannot be associated with or traced

back to you.

14. HOW WE KEEP YOUR INFORMATION SECURED

14.1. We take great care in implementing and maintaining the security of the Services and your

information. We have put in place appropriate physical and technological safeguards to help

prevent unauthorised access, to maintain data security, and to appropriately use the information

we collect online. These safeguards vary based on the sensitivity of the information that we collect

and store.

14.2. We employ industry standard procedures and controls to ensure the safety of our users’

information, such as:

14.2.1. securing network topology, which includes intrusion prevention and firewall systems;

14.2.2. encrypted communication;

14.2.3. authentication and access Control; and

14.2.4. external and internal audit tests.

14.3. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts

of those who gain unauthorised access or abuse the Services. We make no warranty, express,

implied or otherwise, that we will prevent such access.

15. MINORS

15.1. The Services are not designated to users under the age of 18. If you are under 18, you should not

use the Services nor provide any Personal Information to us.

15.2. We reserve the right to access and verify any Personal Information collected from you. In the event

that we become aware that a user under the age of 18 has shared any information, we will discard

such information. If you have any reason to believe that a minor has shared any information with

us, please contact us at info@lootjie.co.za

16. SUPPORT

16.1. If you wish to unsubscribe from marketing communications, please contact Customer Support on:

info@lootjie.co.za

16.2. If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send

it to our Information Officer at: sales@tribedaholdings.co.za for attention to the: Information Officer.