1. Purpose and Scope

This Complaints Handling & Dispute Resolution Policy (“Policy”) sets out how Winlot 888 receives, manages, investigates, and resolves complaints and disputes from customers in a fair, transparent, timely, and consistent manner. The Policy is designed to ensure compliance with applicable Nigerian laws and regulatory requirements governing gambling and gaming operations and to promote consumer confidence and player protection.

This Policy applies to:

●      All customers and players of KBET

●      All gambling products and services offered by KBET (whether online and/or retail)

●      All employees, agents, and third-party service providers involved in customer interactions

2. Regulatory Framework

This Policy is aligned with and developed in accordance with the applicable State Government laws governing gaming and betting operations, together with the license conditions, regulations, directives, and guidelines issued by the relevant State Government regulatory authority (the “Regulator”), as may be amended from time to time.

In particular, KBET ensures compliance with requirements relating to:

●      Player protection and fair gaming

●      Transparent, accessible, and effective complaints and dispute resolution mechanisms

●      Proper record keeping and regulatory reporting

●      Responsible gambling and consumer safeguards

This Policy also takes into account other applicable Nigerian laws and regulations, including consumer protection legislation and data protection requirements.

3. Definitions

Complaint: Any expression of dissatisfaction by a customer relating to KBET’s products, services, conduct, systems, or decisions.

Dispute: A complaint that remains unresolved after initial review or where the customer challenges the outcome of a complaint.

Customer: Any individual who uses or attempts to use KBET’s gambling services.

4. Guiding Principles

KBET is committed to handling complaints and disputes in accordance with the following principles:

●      Fairness and impartiality

●      Transparency and accountability

●      Confidentiality and data protection

●      Timely and proportionate resolution

Accessibility and ease of communication for all customers

5.  How to Lodge a Complaint

Customers may submit complaints through any of the following channels:

●      Email: [email protected]

●      Customer Support Portal / Live Chat

●      Telephone: +2342017001698

●      Written correspondence addressed to KBET’s registered office

Where possible, complaints should include:

●      Customer name and registered account details

●      A clear description of the complaint

●      Relevant dates, transactions, or reference numbers

●      Any supporting documentation or evidence

The absence of complete information will not prevent a complaint from being accepted or reviewed. Submitting or pursuing a complaint under this Policy will not incur any fee or charge to the customer.

KBET will take reasonable steps to assist customers who require additional support in submitting a complaint, including customers with accessibility needs or limited ability to access digital communication channels.

6. Complaint Handling Process

KBET’s complaint handling process is designed to meet State Government standards requiring licensed operators to maintain clear, accessible, and effective mechanisms for resolving customer complaints fairly and promptly.

6.1.  Acknowledgement

●      All complaints will be acknowledged within 48 hours of receipt.

●      The acknowledgement will confirm receipt of the complaint and provide an indicative timeline for resolution.

6.2.  Investigation

●      Complaints will be reviewed objectively by the Customer Support Team and, where necessary, escalated to the Compliance Team.

●      Additional information may be requested from the customer to support the investigation.

●      KBET may review transaction logs, betting records, system data, communications, and relevant internal policies.

6.3.  Resolution

●     KBET aims to resolve complaints within 14 business days of receipt.

●    Where additional time is required due to the complexity of the complaint, the customer will be informed of the reason for the delay and provided with periodic updates.

●     The outcome of the complaint will be communicated clearly and in plain language.

●     Customers have the right to request written reasons for KBET’s decision

7. Dispute Resolution and Escalation

This escalation framework complies with State Government laws requiring licensed operators to provide customers with access to both internal and external dispute resolution mechanisms.

7.1.  Internal Escalation

If a customer is dissatisfied with the initial resolution, they may request escalation of the matter to KBET’s designated Senior Management Officer.

●      Requests for escalation must be submitted within 14 days of receiving the resolution.

●      The escalation review will be conducted independently of the initial decision, where practicable.

7.2.  External Dispute Resolution

Where a dispute remains unresolved after internal escalation, the customer may escalate the matter to:

●      The State Government or any other competent regulatory authority

●      Any legally recognised Alternative Dispute Resolution (ADR) mechanism in Nigeria

●      The Nigerian courts of competent jurisdiction

8. Responsible Gambling Considerations

In line with State Government requirements on player protection and responsible gambling:

●      Complaints relating to responsible gambling, self-exclusion, underage gambling, or player protection will be prioritised.

●      Such complaints will be handled by appropriately trained personnel.

●      KBET will take immediate remedial action where a breach of responsible gambling obligations is identified.

9. Record Keeping and Reporting

All complaints and disputes will be recorded in a secure complaint register in accordance with State Government requirements. Records will include the nature of each complaint, actions taken, applicable timelines, and final outcomes.

Complaint records will be retained for the minimum period required under applicable regulatory and data protection requirements and will be made available for inspection by the State Government upon request. KBET will submit complaints-related information to the State Government when required, including periodic or ad-hoc regulatory reports. Complaint data may also be used for internal reporting, trend analysis, and continuous improvement of services.

10. Confidentiality and Data Protection

All complaints will be handled confidentially. Personal data will be processed in accordance with applicable data protection laws, including the Nigeria Data Protection Act (NDPA) 2023, and KBET’s internal data protection policies

11. Staff Training and Awareness

Employees responsible for handling complaints and disputes will receive appropriate training to ensure effective, fair, and compliant complaint resolution. This Policy will be made available to staff and customers via KBET’s website or upon request.

12. Governance

This Policy is approved by senior management and will be reviewed periodically, and at least annually, to ensure ongoing compliance with applicable laws, licence conditions, and regulatory expectations.