Legal
Privacy Policy
GoalWin works two ways — as a mobile subscription and as an online account. Tell us which one is you and we'll show only the part that applies.
Which GoalWin do you use?
The short version
We only collect what the game actually needs to run. We don't sell your data, and we don't pass your number to anyone else's advertising.
On the mobile channel, we identify you by your phone number. We don't need your name to run the game.
We only charge you after you've confirmed twice, and we always show the price before we charge it.
You can stop any time: send STOP to our short code, dial *305#, or text STOP to 2442. It's free and takes effect right away.
We never see your PIN, your airtime balance, your call records, your location, or anyone else's messages.
Your leaderboard name is public. Nothing else about your account is.
Your full card number never touches our systems — payments run through certified processors.
We only ask for ID when money is about to move, not just to play a free spin.
Marketing messages are opt-in, sent separately from game updates, and one tap to stop. They're never a condition of playing.
You can see your data, correct it, take a copy, or ask us to delete it. See 'Your rights' below for how.
1.About this policy
SMSWebThis policy explains how EsTu Digital Limited collects, uses, shares, secures and keeps your personal data when you use GoalWin. GoalWin works two ways, so at each step we tell you which one we're talking about.
Marker What it means SMSWeb Mobile subscription. You subscribed on your phone by SMS short code, USSD, a WAP page or an operator confirmation, and you're billed through your airtime. SMSWeb Web and app. You registered an account on goalwinit.com or in the GoalWin app, with a wallet, card, bank transfer or mobile money account. SMSWeb Both. Applies to you either way. Swipe sideways to see the full table →
- If you use both, both halves apply. We keep the two sets of data separate unless you link the accounts yourself.
2.Who we are
SMSWebEsTu Digital Limited is the data controller for GoalWin. "We", "us" and "our" mean EsTu Digital Limited throughout this policy.
3.Who is responsible for what
SMSWebOn the mobile channel, GoalWin, your mobile network and the licensed VAS aggregator each handle a different part of the service. On the web and app channel, we're responsible for GoalWin, and our processors support payment, verification and hosting.
Party Role Responsible for EsTu Digital Limited Data controller Everything inside GoalWin: subscription records, consent records, predictions, scores, draw entries, prize administration and messages we send you. Your mobile network Independent data controller SIM registration, airtime and billing account, network traffic, DND status and its own customer care records. The licensed VAS aggregator Data processor Carrying messages and charging requests on our written instruction. Swipe sideways to see the full table →
4.Who can use GoalWin
SMSWebGoalWin is for adults aged 18 and over, in places where we're lawfully allowed to offer it.
- We ask you to confirm your age before your first charge or first deposit.
- If we learn a line belongs to someone under 18, we unsubscribe it and keep only enough to evidence the action.
- If we find an account holder is under 18, we suspend the account, void entries and refund deposits to source where required.
5.What we collect
SMSWebWe ask for data at the point the game actually needs it, not up front just in case. A free spin doesn't require an identity document.
- We never ask for or receive your SIM PIN, PUK, network password, banking PIN, BVN PIN or payment OTP.
- We don't receive your airtime balance, call records, messages with anyone else, contact list or precise location.
- Your full card number and CVV never touch our systems. Payments run through certified processors.
6.Your face and your ID
SMSWebWhen verification needs a selfie, a liveness check or a face match against your document, we treat it as sensitive personal data and hold it to a higher standard.
7.Why we use it, and our legal basis
SMSWebEvery use of your data needs a lawful basis. We use data to run the game, keep records, process payments, prevent fraud, meet legal duties and support you.
8.Consent, and how you stop
SMSWebConsent and stopping should both be simple. We show the price before charging, we record consent, and we let you stop without a phone call or a hidden condition.
- Send STOP to the short code, dial *305#, or text STOP to 2442.
- Manage marketing under Profile > Communications, or use the unsubscribe link on any message.
9.What other players can see
SMSWebThe leaderboard is a competition, so a small part of it is public. Your leaderboard name may be shown there, but your private account details aren't.
12.Sending data outside Nigeria
SMSWebSome of our processors may operate outside Nigeria. Any transfer uses a lawful route, documented safeguards, and a record of the destination, recipient, data category and assessment date.
13.Automated decisions and draws
SMSWebAutomation may support draws, fraud checks, eligibility checks and account safety. Where a decision significantly affects you, we explain it and offer a human review.
14.Your rights
SMSWebYou can access your data, correct it, ask us to delete it, restrict or object to some uses, take your data with you, and complain to the regulator if you're not satisfied.
15.How long we keep things
SMSWebWe keep data only as long as we have a purpose and a lawful basis for it. Once that runs out, records are deleted or irreversibly de-identified on a logged cycle.
16.How we protect your data
SMSWebWe use encryption, access controls, logging, testing, backups, governance records and written processor agreements to protect the data GoalWin handles.
- Mobile network links use encrypted, authenticated routes, and raw phone numbers are masked by default for most staff.
- Passwords are stored as salted hashes, card data is tokenised by our processors, and wallets use an auditable ledger.
17.Complaints
SMSWebWe'd rather fix a problem than have it reported, but you're free to contact us, your network, the NCC, the NDPC, sector regulators or the courts, depending on what the complaint is about.
18.Changes to this policy
SMSWebWe review this policy at least once a year, and whenever the game, the law, or what we do with your data changes in a meaningful way.
- Where a change needs your consent, we ask for it again — we don't assume it.
- Every version is dated and archived at goalwinit.com/privacy/archive, with a short note on what changed and why.
19.Contact us
SMSWebUse these details for privacy questions, security reports and general enquiries.
- Data controller
- EsTu Digital Limited (company registration number to follow)
- Registered address
- To be added here — in the meantime, reach us using the contact details below.
- Data Protection Officer
- To be appointed. Until then, send privacy questions to info@estudigitallimited.com.
- Security reports
- Email info@estudigitallimited.com with "Security" in the subject line.
- General enquiries
- info@estudigitallimited.com · estudigitallimited.com
- Mobile channel
- Short code and USSD details will be published here once the mobile subscription channel is live. VAS management: *305# · Network Do-Not-Disturb: 2442.
This policy is issued under the Nigeria Data Protection Act 2023 and should be read alongside the GoalWin Terms and Conditions.
Have a question about this policy? Contact us.
