TONZO PRIVACY POLICY
Last updated: 28 August 2025
1. INTRODUCTION
This Privacy Policy explains how LFGC Limited (“Tonzo”, “we”, “us”, or “our”) collects, uses, stores, and protects your personal information when you use the Tonzo Lottery, Scratch Cards, Referral Program, Rewards Program, and related services (the “Service”).
By using the Service, you agree to this Privacy Policy in addition to our Terms and Conditions. If you do not agree, you must not use the Service.
2. INFORMATION WE COLLECT
We may collect the following categories of information:
- Identity Information: Name, date of birth, proof of identity (passport, driver’s license, national ID).
- Contact Information: Address, email, phone number.
- Wallet Information: Blockchain wallet addresses and transaction history necessary to process payments, ticket purchases, and withdrawals.
- Verification Information: Documents submitted to meet Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Know Your Customer (KYC) obligations.
- Technical Data: IP address, device identifiers, browser type, operating system, usage logs, and geo-location (to prevent use from prohibited jurisdictions).
- Communications Data: Records of messages or interactions with our support channels.
3. HOW WE USE YOUR INFORMATION
We use your data for the following purposes:
- To provide access to the Lottery, Scratch Cards, and Rewards Program.
- To verify your identity, eligibility, and compliance with our Terms.
- To process transactions, ticket purchases, and withdrawals.
- To detect, prevent, and investigate fraud, money laundering, terrorism financing, and other illegal activity.
- To comply with legal obligations under applicable gambling and financial regulations.
- To communicate with you regarding updates, winnings, rewards, or account verification.
- To improve the Service, including user experience and security.
4. LEGAL BASIS FOR PROCESSING
We process personal data under the following lawful bases:
- Contractual necessity: To perform our obligations under the Terms and Conditions.
- Legal compliance: To meet AML, CTF, gambling regulation, and taxation requirements.
- Legitimate interests: To protect the integrity of our platform, prevent fraud, and improve services.
- Consent: Where required for specific uses (e.g., marketing communications).
5. HOW WE SHARE YOUR INFORMATION
We may share your information with:
- Regulators and Authorities: Where required by law or regulatory obligations. Service Providers: Identity verification, payment processors, and IT support partners.
- Law Enforcement: In cases of fraud, suspected crime, or legal request.
- Affiliates and Partners: Where necessary to provide referral or rewards benefits.
We do not sell or rent your personal data to third parties.
6. DATA STORAGE AND SECURITY
- Your personal data is stored securely and protected using encryption, access controls, and monitoring systems.
- Blockchain transactions associated with your wallet are publicly visible by design, but Tonzo does not disclose wallet ownership details except as required by law.
- Verification records and financial data may be retained longer in line with AML/CTF requirements.
7. INTERNATIONAL DATA TRANSFERS
As the Service is operated from the Autonomous Island of Anjouan, Union of Comoros, your data may be transferred to and processed in jurisdictions outside your country of residence. We take steps to ensure such transfers comply with applicable data protection laws.
8. YOUR RIGHTS
Depending on your jurisdiction, you may have the following rights:
- Access to the personal data we hold about you.
- Rectification of inaccurate or incomplete information.
- Erasure of your data, subject to regulatory retention obligations.
- Restriction or objection to processing in certain circumstances.
- Data portability where technically feasible.
Requests can be made via our community support channel on the Telegram messaging application.
9. COOKIES AND TRACKING
We may use cookies, analytics tools, and device identifiers to improve the Service, monitor usage, and detect suspicious activity. You may disable cookies in your browser settings, but some features may not function properly.
10. UNDERAGE USE
We do not knowingly collect information from persons under the age of 18 or the minimum legal gambling age in your jurisdiction. If we determine that you are underage, your account will be terminated, and winnings forfeited.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. Updates will be published on the Tonzo website. Your continued use of the Service constitutes acceptance of the updated policy.
12. CONTACT US
If you have questions about this Privacy Policy, please contact us via the Tonzo Community Support Channel on the Telegram messaging application.
