Privacy Policy – MTN Lucky Pick

1. Who We Are

MTN Lucky Pick is operated by MTN Eswatini, a telecommunications company licensed to operate in the Kingdom of Eswatini. For privacy-related questions, contact our Privacy Officer (details in Section 10).

2. Data We Collect

2.1 Information You Provide

Data	Purpose	Source
MTN phone number	Account creation, OTP authentication, payment processing, SMS notifications	You, at login
Ticket & prediction history	Game operation, results calculation, prize disbursement	Your game activity
Wallet & transaction records	Balance management, deposits, withdrawals, fraud prevention	Your financial activity
MoMo payment data	Transaction processing, billing, refunds	MTN Mobile Money integration

2.2 Automatically Collected Data

When you use the MTN Lucky Pick web application, the following data is collected automatically and stored in our analytics system for platform improvement and security:

Data	Purpose	How collected
IP address	Rate limiting, fraud prevention, approximate location analytics	Server (every request)
Browser name & version	Platform compatibility, analytics	User-Agent header (server-side parsing)
Operating system & device type	Platform compatibility, analytics	User-Agent header (server-side parsing)
Pages visited & time spent	Understanding how users navigate the app, improving UX	Client-side event sent on each page navigation
JavaScript errors	Detecting and fixing bugs that affect users	Client-side error event
Referrer URL	Understanding how users arrive at the platform	Browser (sent with page-view event)

Analytics data is tied to an anonymous session identifier generated in your browser. It is viewable only by authorised MTN Lucky Pick administrators and is never shared with third parties.

3. How We Use Your Data

3.1 Primary Purposes

Game operation: Processing ticket purchases, determining results, and crediting prizes.
Authentication: Verifying your identity via SMS OTP before each session.
Payments: Facilitating deposits, withdrawals, and refunds through MTN MoMo.
Communication: Sending OTP codes, transaction confirmations, and result notifications via SMS.
Customer support: Investigating queries, disputes, and technical issues.

3.2 Secondary Purposes

Analytics: Understanding platform usage to improve the experience.
Fraud prevention & security: Detecting suspicious activity and protecting user accounts.
Legal compliance: Meeting obligations under Eswatini law and MTN Group policies.

4. Data Sharing & Disclosure

4.1 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to any third party for marketing or commercial purposes.

4.2 Limited Sharing

We may share your data only in the following circumstances:

MTN Mobile Money: For payment processing and transaction verification.
SMS gateway providers: For OTP delivery and transactional notifications.
Cloud infrastructure providers: For secure data hosting and backups.
Legal authorities: When required by law, court order, or regulatory authority.
Business transfers: In the event of a merger, acquisition, or sale of assets, with appropriate data-protection safeguards.

5. Data Security

All data in transit is encrypted using TLS/SSL.
Sensitive data at rest is encrypted and access-controlled.
We do not store your MTN MoMo PIN or any sensitive payment credentials.
Regular security audits and vulnerability assessments are performed.
Access to personal data is restricted to authorised personnel only.

While we take every reasonable precaution, no transmission over the internet is 100% secure. Please use the Platform on trusted networks.

6. Data Retention

Data Type	Retention Period	Reason
Account / phone number	Until account deletion	Service provision
Ticket & game history	3 years	Analytics, dispute resolution
Financial / payment records	7 years	Legal & tax compliance
Security & access logs	1 year	Fraud monitoring
Support communications	2 years	Quality assurance

Data is securely deleted or anonymised when retention periods expire.

7. Your Rights

Subject to applicable Eswatini data protection law, you have the right to:

Access – request a copy of the personal data we hold about you.
Correction – request that inaccurate data be corrected.
Deletion – request deletion of your account and associated personal data (subject to legal retention obligations).
Objection – object to certain processing activities such as analytics.
Portability – receive your data in a portable, machine-readable format.

To exercise any of these rights, contact our Privacy Officer (see Section 10). We will respond within 30 days.

8. Cookies & Tracking

8.1 What We Use

Session storage / local storage: To keep you logged in during your session and store preferences.
Analytics cookies: Anonymous usage statistics to improve the Platform.

8.2 Your Control

You can clear browser storage at any time through your browser settings.
Disabling storage may affect the Platform's functionality (e.g., you will be logged out).

9. Children's Privacy

MTN Lucky Pick is not intended for anyone under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has registered, please contact us immediately and we will delete the account.

10. Contact Our Privacy Officer

For any privacy questions, data requests, or concerns:

Email: [email protected]
Email (support): [email protected]
Phone: +268 7820 7540
Address: MTN Eswatini, Privacy Officer, Mbabane, Eswatini
Hours: Monday – Friday, 08:00 – 17:00 SAST

11. Changes to This Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated by SMS or in-app notification. The "Last updated" date at the top of this page will always reflect the most recent revision. Continued use of the Platform after changes are posted constitutes your acceptance.