Language Notice: This Privacy Policy is drafted in English. Any translation is for reference only. The English version shall prevail in the event of any discrepancy.
1. Introduction
1.1 Tenscore Technology Limited ("the Company", "we", "us", "our") operates the WinSlots mobile application and related services (collectively, "the Services"). We are committed to protecting your privacy and to processing your personal data in a lawful, fair, and transparent manner. This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, how long we retain it, how we protect it, and what rights you have in relation to it.
1.2 This Privacy Policy applies to all users of the Services, including visitors who browse the application without registering an account, registered players, and users who contact our customer support team. It applies regardless of the device or platform you use to access the Services.
1.3 This Privacy Policy should be read together with our Terms and Conditions, which govern the contractual relationship between you and the Company. In the event of any conflict between this Privacy Policy and the Terms and Conditions regarding the processing of personal data, this Privacy Policy shall prevail.
1.4 We process personal data in accordance with the Data Protection Act 2012 (Act 843) of Ghana, and, where applicable, other relevant data protection laws and regulations. As a licensed gaming operator, we are also subject to the supervisory requirements of the Gaming Commission of Ghana, which may impose additional obligations relating to the collection, verification, and retention of player data.
1.5 By registering an account, accessing, or using the Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, you should not use the Services.
2. Data Controller and Contact
2.1 The data controller responsible for the collection and processing of your personal data is Tenscore Technology Limited, a company registered under the laws of the Republic of Ghana and licensed by the Gaming Commission of Ghana under licence number GCRG26E29244Z.
2.2 Our full contact details are as follows:
Tenscore Technology Limited
Licence No.: GCRG26E29244Z (Gaming Commission of Ghana)
Address: HSE NO. 5, DZORWULU, KENTE MBLI STREET, NEAR NIYO APARTMENT, ACCRA (GA-122-6802), Ghana
Website: https://www.tenscoreltd.com
Email: help@tenscoreltd.com
2.3 For any questions, requests, or complaints relating to this Privacy Policy or the processing of your personal data, please contact us at help@tenscoreltd.com. We aim to respond to all enquiries within a reasonable period and, where required by law, within the statutory time limits.
2.4 We have designated a data protection contact who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may reach this contact using the email address above, marking your message "Data Protection Enquiry" in the subject line.
3. Personal Data We Collect
3.1 We collect and process the following categories of personal data. The specific data collected depends on how you interact with the Services and which features you use.
(a) Account data
When you register an account, we collect your mobile phone number and email address. Your mobile phone number serves as your username and is used to identify your account, to send you service-related notifications, and to enable secure login. Your email address is used for account communications, password recovery, and, where you have consented, promotional messages. We do not collect your home address or physical mailing address.
(b) Identity and age verification data
To comply with the Gaming Act 2006 (Act 721) and the requirements of the Gaming Commission of Ghana, we are required to verify the identity and age of every player before they can place bets or make withdrawals. For this purpose, we collect your full legal name, your identity document number, and your date of birth. We accept the following forms of identification: Ghana Card issued by the National Identification Authority (NIA), passport, driver's licence, or any other government-issued identity document. We collect only the document number and related details necessary for verification; we do not retain copies of the physical documents themselves.
(c) Regional restriction data
Because our licence authorises us to offer real-money gaming services only within the territory of Ghana, we are required to verify that users are physically located in Ghana. For this purpose, we collect your network IP address each time you access the Services. This information is used to enforce regional access restrictions and to block users connecting from outside Ghana.
(d) Attribution and analytics data
To measure the effectiveness of our marketing campaigns and to understand how users discover and use the Services, we collect your device ID, your advertising identifier (Google Advertising ID, or GAID), and an AppsFlyer ID assigned by our attribution provider. This data helps us determine which marketing channels are most effective and how to improve the Services. It is not used to identify you personally.
(e) Transaction and activity data
When you use the Services, we collect details of your transactions, including deposits, withdrawals, bets placed, winnings, and bonus credits. We also maintain account statements and transaction history, which are necessary for the operation of your account, for resolving disputes, and for complying with anti-money laundering and gaming regulations.
(f) Customer support data
When you contact our customer support team through the in-app chat, by email, or through any other channel, we collect the content of your communications, including any attachments, screenshots, or documents you provide. This information is used to respond to your enquiry, to resolve issues, and to improve the quality of our support services. Chat sessions may be recorded and stored for quality assurance and training purposes.
(g) Technical and usage data
We may automatically collect technical information about your device and how you interact with the Services, including the type of device you use, your operating system version, application version, language settings, and general usage patterns. This data is used for troubleshooting, security monitoring, and service improvement.
3.2 We do not collect the following categories of data: credit card numbers, bank account details, home or physical addresses, camera images, media files, storage contents, precise GPS location, contacts, calendars, or biometric data stored on your device. If you believe we have collected any such data in error, please contact us immediately so that we can investigate and, where appropriate, delete it.
3A. 18+ Only
3A.1 The Services are intended exclusively for users aged 18 and over. Gambling is an adult activity and is strictly prohibited for minors. We do not knowingly collect, process, or retain personal data from persons under 18 years of age.
3A.2 To enforce this age restriction, we collect your date of birth and identity document number during registration and verify your age before you can place bets or make withdrawals. We accept the Ghana Card issued by the National Identification Authority (NIA), passport, driver's licence, or any other government-issued identity document for verification. If we cannot verify that you are 18 or older, we will not allow you to use the Services.
3A.3 If we become aware that we have collected personal data from a person under 18, we will promptly delete such data and close the relevant account. We will also report the matter to the Gaming Commission of Ghana and other appropriate authorities where required by law.
3A.4 Parents and guardians are encouraged to monitor their children's online activity and to use device-level parental controls to restrict access to gambling applications. If you are a parent or guardian and believe that a minor has provided personal data to us or has accessed an account, please contact us immediately at help@tenscoreltd.com.
3A.5 This section should be read together with section 12 (Children's Privacy) and our Terms and Conditions, which contain further provisions on age verification and underage gambling.
3B. Service Region: Ghana Only
3B.1 The Services are available exclusively to users who are physically located within the territory of Ghana and who are Ghanaian citizens. Our gaming licence, issued by the Gaming Commission of Ghana, authorises us to provide real-money gaming services only within Ghana. We do not offer, and do not intend to offer, real-money gaming services to users outside Ghana or to non-Ghanaian citizens.
3B.2 To enforce this regional and citizenship restriction, we use IP address detection to determine your geographic location each time you access the Services. If our checks indicate that your connection originates from outside Ghana, access to the Services will be blocked, and you will not be able to register, log in, place bets, or make withdrawals.
3B.3 We also verify citizenship as part of our identity verification process. If we are unable to verify that you are a Ghanaian citizen, we may refuse to provide the Services, suspend your account, or close your account in accordance with applicable law and our Terms and Conditions.
3B.4 The use of VPNs, proxies, or any other tools to circumvent regional restrictions is strictly prohibited. If we detect such tools, we may suspend or close your account and take any other action permitted by law.
3B.5 It is your responsibility to ensure that you comply with all applicable laws in your jurisdiction when accessing or using the Services. We are not responsible for any consequences arising from your failure to comply with local laws.
3B.6 This section should be read together with section 3.1(c) (Regional restriction data) and our Terms and Conditions, which contain further provisions on regional restrictions and eligibility.
4. How We Collect Personal Data
4.1 We collect personal data through the following means:
(a) Directly from you. We collect personal data when you register an account, complete identity and age verification, make a deposit or withdrawal, place a bet, contact customer support, respond to surveys or promotions, or otherwise interact with the Services.
(b) Automatically. When you access or use the Services, we automatically collect certain information, including your IP address, device ID, advertising identifier, and data about your usage of the application. This collection is carried out through the application itself and through the third-party SDKs described in section 6.
(c) From third parties. We may receive information about you from our attribution provider AppsFlyer, which supplies attribution and campaign measurement data. We may also receive information from the Google Advertising ID service, which provides an advertising identifier for analytics purposes. Where you have been referred to us through a marketing partner, we may receive confirmation of the referral together with limited campaign data.
(d) From identity verification sources. Where you provide a Ghana Card issued by the National Identification Authority (NIA), we submit the information you provide (your name, Ghana Card number, and date of birth) to the NIA database for verification. For other identity documents, such as a passport or driver's licence, we verify the information through other appropriate means, which may include manual review or third-party verification services. We receive only the outcome of the verification, that is, whether the data matches, and we do not receive any additional personal data from the verifying source.
5. Purposes and Legal Bases for Processing
5.1 We process your personal data only for specific, legitimate purposes and only where we have a valid legal basis to do so. The purposes for which we process your personal data, and the corresponding legal bases, are as follows.
(a) Account management. We process your account data (mobile phone number and email address) to create and manage your account, to authenticate you when you log in, to communicate with you about your account, and to provide customer support. The legal basis is the performance of our contract with you.
(b) Age and identity verification. We process your name, identity document number, and date of birth to verify your identity and age, to prevent minors from accessing the Services, and to comply with the Gaming Act 2006 (Act 721) and the requirements of the Gaming Commission of Ghana. The legal basis is our compliance with legal obligations and our legitimate interest in preventing underage gambling and fraud.
(c) Regional restrictions. We process your IP address to verify that you are physically located in Ghana and to enforce the territorial scope of our licence. The legal basis is our compliance with legal obligations and our legitimate interest in operating in accordance with our licence conditions.
(d) Transaction processing. We process transaction and activity data to process deposits, withdrawals, bets, and winnings, to maintain accurate account records, and to resolve any disputes. The legal basis is the performance of our contract with you and our compliance with legal obligations.
(e) Attribution and analytics. We process device ID, advertising identifier, and AppsFlyer ID to measure the effectiveness of our marketing campaigns and to understand how users discover and use the Services. The legal basis is your consent, where required, and our legitimate interest in improving the Services and operating efficiently.
(f) Fraud prevention and security. We process personal data to detect, prevent, and investigate fraud, money laundering, account takeover, and other illegal or prohibited activities. The legal basis is our compliance with legal obligations and our legitimate interest in protecting the Services, our users, and the Company.
(g) Regulatory compliance. We process personal data to comply with requests from the Gaming Commission of Ghana, law enforcement agencies, courts, and other regulatory authorities. The legal basis is our compliance with legal obligations.
(h) Marketing. Where you have consented, we process your contact details to send you promotional communications about our products, services, and promotions. The legal basis is your consent, which you may withdraw at any time.
5.2 Where we rely on our legitimate interests as the legal basis for processing, we have carried out a balancing assessment to ensure that our interests do not override your rights and freedoms. You may contact us for further information about this assessment.
5.3 Where we rely on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.
6. Third-Party SDKs and Recipients
6.1 The Application integrates the following third-party SDKs, each of which may collect and process personal data as described below. We have selected these SDKs because they support essential functions of the Services, and we require our providers to handle personal data in accordance with applicable laws.
(a) AppsFlyer (v6.16.2). AppsFlyer provides attribution, campaign measurement, and unique user identification services. AppsFlyer may collect your device ID, advertising identifier, IP address, and information about the source from which you installed the application. This data is used to determine which marketing campaigns are effective and to prevent fraudulent attribution. AppsFlyer processes data in accordance with its own privacy policy.
(b) Google Advertising ID (play-services-ads-identifier 18.0.1). This SDK reads the Google Advertising ID (GAID) assigned to your device. The GAID is a resettable, non-permanent identifier that is used for advertising and analytics purposes. It is not linked to your name or other directly identifying information.
(c) SaleSmartly Chat Widget (v1.0.3). SaleSmartly provides the in-app customer support chat function. When you are logged in with a mobile number and initiate a chat, the SDK receives your mobile number and the content of your chat messages so that our support team can identify you and respond to your enquiry. Chat content is stored for the purpose of resolving your issue and for quality assurance.
(d) Android System WebView. The Application uses Android System WebView to display H5 pages, including terms and conditions, promotional pages, and game content. When you interact with these pages, cookies, authentication tokens, and page interaction data may be processed. For game pages, authentication tokens are used to verify your session and to provide secure access to game content.
6.2 In addition to the SDKs described above, we may disclose personal data to the following categories of recipients:
(a) Regulatory and law enforcement authorities. We may disclose personal data to the Gaming Commission of Ghana, the Data Protection Commission, law enforcement agencies, courts, and other regulatory authorities where required by law, where necessary to protect our rights or the rights of others, or in response to a valid legal request.
(b) Payment service providers and mobile money operators. We share transaction data with mobile money operators (including MoMo, Vodafone Cash, and AirtelTigo Money) and other payment service providers to process your deposits and withdrawals. These providers process data in accordance with their own privacy policies.
(c) Service providers. We engage third-party service providers, including AppsFlyer and SaleSmartly, to support attribution, analytics, and customer support. These providers act on our instructions and are contractually required to protect your personal data.
(d) Professional advisers. We may share personal data with our lawyers, auditors, insurers, and other professional advisers where necessary for the operation of our business.
(e) Successor entities. In the event of a merger, acquisition, reorganisation, or sale of assets, personal data may be transferred to a successor entity, subject to the protections described in this Privacy Policy.
6.3 We do not sell your personal data to third parties. We do not share your personal data with third parties for their own marketing purposes without your consent.
7. Android Permissions
7.1 The Application requests the following Android permissions. Each permission is used only for the purposes described below.
(a) INTERNET. This permission is required to enable network access. It is used for all communication between the Application and our servers, including API requests, loading WebView content, connecting to the SaleSmartly customer support service, and transmitting attribution data to AppsFlyer.
(b) ACCESS_NETWORK_STATE. This permission allows the Application to detect whether a network connection is available before attempting to load content. It is used to provide a better user experience by avoiding unnecessary delays and to display appropriate error messages when the network is unavailable.
(c) com.google.android.gms.permission.AD_ID. This permission allows the Application to access the Google Advertising ID (GAID). It is used for attribution and analytics purposes, in conjunction with AppsFlyer. The GAID is a resettable identifier that is not linked to your name or other directly identifying information.
7.2 The Application does not request permissions for camera access, storage access, media access, contacts, calendars, location, or biometric data. Where the Application allows you to upload images (for example, for verification purposes or in customer support chat), this is handled through the Android Photo Picker, which does not require additional permissions and grants access only to the specific images you select.
7.3 You can review and manage the permissions granted to the Application at any time through your device settings. Please note that revoking certain permissions may affect the functionality of the Services.
8. Cookies and Similar Technologies
8.1 We may use cookies and similar technologies on your device to store information such as your username, session tokens, and preferences, so that you do not have to re-enter this information each time you use the Services. Cookies help us to provide a smoother and more personalised experience.
8.2 Cookies used by the Services are uniquely assigned to you and can only be read by the web server that issued them. They cannot be used to run programs or deliver viruses to your device. Cookies do not give us access to your device or to any information other than what you choose to share with us.
8.3 We use the following types of cookies:
(a) Strictly necessary cookies. These cookies are required for the operation of the Services, including authentication and security. They cannot be disabled without affecting the functionality of the Services.
(b) Functional cookies. These cookies remember your preferences and settings to improve your experience.
(c) Analytics cookies. These cookies help us understand how users interact with the Services, so that we can improve them. Where required, we obtain your consent before using analytics cookies.
8.4 We do not use intrusive tracking cookies for behavioural marketing purposes without your consent. If we intend to use such cookies in the future, we will ask for your consent first and update this Privacy Policy accordingly.
8.5 You can manage or disable cookies through your device or browser settings. Please note that disabling certain cookies may affect the functionality of the Services and may prevent you from using certain features.
9. Data Retention
9.1 We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. The specific retention period depends on the type of data and the purpose for which it was collected.
9.2 In particular:
(a) Account data is retained for the duration of your account and for a period thereafter as required by applicable law. When your account is closed, we may retain certain data for a period necessary to comply with legal obligations and to resolve any outstanding matters.
(b) Identity and age verification data is retained in accordance with the requirements of the Gaming Commission of Ghana and applicable anti-money laundering regulations. These requirements typically require retention for a minimum period after the end of the customer relationship.
(c) Transaction records are retained for the period required by applicable anti-money laundering and gaming regulations, which may be several years after the transaction or the closure of your account.
(d) Customer support data is retained for as long as necessary to resolve your enquiry and for a reasonable period thereafter for quality assurance and training purposes.
(e) Attribution data is retained for the period required for analytics purposes and in accordance with the policies of the relevant SDK providers.
9.3 A dormant account is an account that has not been accessed for thirty (30) months, whether or not it holds a balance. Once your account becomes dormant, we will close it and transfer any remaining balance to a dedicated Company corporate account in accordance with applicable law. We may retain certain data relating to the dormant account for the periods described above.
9.4 When personal data is no longer required, we securely delete or anonymise it in accordance with our internal data retention procedures.
10. Data Security
10.1 We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, loss, or destruction. These measures are designed to provide a level of security appropriate to the risk of processing.
10.2 Our security measures include:
(a) Encryption. We use HTTPS to encrypt data in transit between your device and our servers. Where appropriate, we also encrypt data at rest.
(b) Access controls. Access to personal data is restricted to authorised personnel who need it to perform their duties. We use authentication, authorisation, and audit controls to enforce these restrictions.
(c) Secure storage. Identity verification data is stored securely, with additional protections to reflect its sensitivity. We limit the number of personnel who have access to this data.
(d) Monitoring and assessment. We regularly review our security practices, monitor for potential vulnerabilities, and conduct assessments to ensure that our measures remain effective.
(e) Employee training. Our personnel receive training on data protection and security practices to ensure that they handle personal data appropriately.
10.3 While we take reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security. You are responsible for keeping your login credentials confidential and for notifying us immediately if you suspect that your account has been compromised.
10.4 If we become aware of a data breach that may affect your rights or freedoms, we will notify you and the relevant authorities as required by applicable law. Our notification will include information about the nature of the breach, the likely consequences, and the measures we are taking to address it.
11. Your Rights
11.1 Subject to applicable law and any retention requirements, you have the following rights in relation to your personal data:
(a) Right of access. You have the right to request a copy of the personal data we hold about you, together with information about how we process it. We will provide this information within the time limits required by law.
(b) Right to rectification. You have the right to request the correction of inaccurate or incomplete personal data. You can also update certain information directly through your account settings.
(c) Right to erasure. You have the right to request the deletion of your personal data, where we are not required to retain it by law. Please note that we may be required to retain certain data to comply with gaming and anti-money laundering regulations, and in such cases we cannot delete the data before the retention period expires.
(d) Right to restrict processing. You have the right to request that we limit the processing of your personal data in certain circumstances, such as while we verify the accuracy of the data or assess an objection to processing.
(e) Right to object. You have the right to object to processing based on our legitimate interests, in which case we will cease processing unless we have compelling legitimate grounds that override your interests.
(f) Right to withdraw consent. Where we rely on your consent for processing, you have the right to withdraw that consent at any time. This includes the right to opt out of marketing communications.
(g) Right to data portability. Where technically feasible and required by law, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transfer it to another controller.
(h) Right to lodge a complaint. You have the right to lodge a complaint with the relevant data protection authority in Ghana if you believe that we have not handled your personal data in accordance with applicable law.
11.2 To exercise any of these rights, please contact us at help@tenscoreltd.com. We may need to verify your identity before processing your request. We will respond to your request within the time limits required by law, and we will inform you if we need more time to complete a complex request.
11.3 Please note that certain rights may be limited by legal or regulatory requirements. For example, we may be unable to delete data that we are required to retain for anti-money laundering or gaming regulatory purposes.
12. Children's Privacy
12.1 The Services are intended for users aged 18 and older only. We do not knowingly collect personal data from persons under 18 years of age. Our registration process includes age verification to prevent minors from creating accounts.
12.2 If we become aware that we have collected personal data from a person under 18, we will take steps to delete such data and close the relevant account, in accordance with our Terms and Conditions and applicable law. We will also report the matter to the appropriate authorities where required.
12.3 If you are a parent or guardian and believe that a minor has provided personal data to us, or if you suspect that a minor has accessed an account, please contact us immediately at help@tenscoreltd.com so that we can investigate and take appropriate action.
12.4 We encourage parents and guardians to monitor their children's online activity and to use device-level parental controls to prevent access to gambling applications.
13. Third-Party Websites
13.1 The Services may contain links to third-party websites, including those of our partners, advertisers, and affiliates. We are not responsible for the privacy practices of these third-party websites.
13.2 When you click on a link to a third-party website, you leave the Services and become subject to the privacy policy of that website. We encourage you to review the privacy policies of any third-party website you visit before providing personal data to them.
13.3 The inclusion of a link to a third-party website does not imply our endorsement of that website or its privacy practices.
14. Changes to This Privacy Policy
14.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you through the Application, by email, or by other reasonable means before they take effect.
14.2 We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. The effective date at the top of this Privacy Policy indicates when it was last updated.
14.3 Continued use of the Services after the effective date of any change constitutes acceptance of the revised Privacy Policy. If you do not agree with the revised Privacy Policy, you may close your account by contacting us at help@tenscoreltd.com.
15. Complaints
15.1 If you have any concerns about how we handle your personal data, please contact us first at help@tenscoreltd.com. We will aim to resolve your concern promptly and will keep you informed of our progress.
15.2 If you are not satisfied with our response, you may lodge a complaint with the relevant data protection authority in Ghana. The authority responsible for data protection in Ghana is the Data Protection Commission.
15.3 Where your complaint relates to our activities as a licensed gaming operator, you may also contact the Gaming Commission of Ghana at https://gamingcommission.gov.gh/.
16. Contact Us
16.1 For any questions, requests, or complaints relating to this Privacy Policy or the processing of your personal data, please contact us:
Tenscore Technology Limited
Licence No.: GCRG26E29244Z (Gaming Commission of Ghana)
Address: HSE NO. 5, DZORWULU, KENTE MBLI STREET, NEAR NIYO APARTMENT, ACCRA (GA-122-6802), Ghana
Website: https://www.tenscoreltd.com
Email: help@tenscoreltd.com
16.2 For matters relating to gambling regulation, self-exclusion, or problem gambling support, you may also contact the Gaming Commission of Ghana at https://gamingcommission.gov.gh/.