Terms and Conditions for Property Draw Operations

1. Introduction

These Terms and Conditions govern the operation of the property draw known as "Who Wants to Be a Landlord" ("Property Draw") and the participation of all persons who purchase, receive, register, or otherwise participate in an eligible Property Draw entry ("Participant" or "Player").

By purchasing a ticket, registering an account, submitting an entry, or otherwise participating in the Property Draw, the Player confirms that they have read, understood, and accepted these Terms.

The Property Draw shall be conducted in accordance with all applicable laws, regulations, licence conditions, regulatory directives, and approved game rules applicable in the jurisdiction in which the Property Draw is offered.

2. Regulatory Compliance

• The Operator shall obtain and maintain all licences, permits, approvals, registrations, and authorisations required by the applicable regulatory authority before conducting the Property Draw.
• The Operator shall conduct the Property Draw fairly, transparently, securely, and in accordance with its approved rules and licence conditions.
• No game, draw, promotional scheme, prize structure, or material change to the Property Draw shall be introduced where regulatory approval is required unless such approval has first been obtained.
• Where applicable, the Operator shall maintain adequate accounting, security, internal-control, transaction-monitoring, and record-keeping systems.
• The Operator shall comply with lawful reporting, audit, tax, statutory contribution, and regulatory requirements.

3. Eligibility of Players

• Participation is restricted to persons who are 18 years of age or older, unless a different minimum age is expressly required by applicable law.
• The Operator may require proof of age and identity before allowing participation or paying a prize.
• Employees, directors, officers, agents, contractors, auditors, draw administrators, and other persons directly involved in operating or administering a particular draw may be prohibited from participating in that draw.
• The Operator may refuse or cancel an entry where it reasonably believes that the Player is underage, has provided false information, has breached these Terms, or is otherwise legally ineligible.

4. Registration and Player Information

• Where registration is required, each Player shall provide accurate, complete, and current information.
• A Player shall not create or operate an account using another person's identity or payment information without lawful authority.
• The Operator may conduct reasonable identity, age, fraud, anti-money-laundering, and other compliance checks required by law or its regulatory obligations.
• The Operator may suspend an account while a compliance, fraud, or identity investigation is being conducted.

5. Property Draw Entries and Tickets

• Each valid ticket or electronic entry shall constitute participation in the relevant Property Draw.
• A ticket is valid only if it has been legitimately issued or recorded through an authorised channel of the Operator.
• Lost, stolen, altered, counterfeit, duplicated, damaged, or fraudulently obtained tickets may be declared invalid.
• Unless otherwise stated in the specific game rules, tickets are non-transferable and non-refundable after the relevant draw or entry deadline.
• The Operator shall clearly publish the price of each entry, applicable taxes or charges, entry closing time, draw date, and applicable winning conditions.

6. Draws and Selection of Winners

• Draws shall be conducted according to the approved rules of the Property Draw.
• The Operator shall use reasonable procedures and appropriate technology to ensure that draws are conducted fairly, securely, and independently.
• Where required, draws may be witnessed, audited, certified, or supervised by an authorised independent person or regulatory representative.
• The winning numbers, entries, or selection criteria shall be determined in accordance with the published rules.
• The Operator shall not manipulate, predetermine, or unlawfully interfere with the outcome of a draw.
• In the event of a technical failure or circumstance affecting the integrity of a draw, the Operator may postpone, suspend, cancel, or repeat the draw where permitted by law and the applicable regulatory approval.

7. Prizes

• The star prize is an apartment.
• No Player is guaranteed to win a prize merely by purchasing a ticket or entering the Property Draw.
• A Player becomes entitled to a prize only after the Operator has verified that the winning entry is valid and that all applicable eligibility and claim requirements have been satisfied.
• The Operator may withhold or refuse payment of a prize where there is reasonable evidence of fraud, unlawful participation, ticket manipulation, identity fraud, duplicate claims, or another material breach of these Terms.
• Where a prize is subject to tax, statutory deduction, withholding, or other lawful charge, the applicable amount may be deducted before payment.

8. Prize Claims and Payment

The Operator may require a winner to provide:

• Valid government issued identification
• Proof of age
• The original or verifiable electronic ticket
• Proof of ownership of the winning account
• Any other information reasonably required for lawful verification

• Prizes shall be paid through approved payment channels and in accordance with applicable regulatory and financial-control requirements.
• The Operator shall not charge a winner an unlawful or undisclosed fee as a condition of receiving a legitimate prize.
• The Operator shall publish clear procedures for unclaimed prizes and shall deal with such prizes in accordance with applicable law and regulatory requirements.

9. Fraud, Cheating and Prohibited Conduct

Where fraud or other unlawful conduct is suspected, the Operator may suspend the relevant account or transaction and refer the matter to the appropriate authorities.

10. Responsibilities of the Operator

The Operator shall:

• Operate the Property Draw in accordance with its licence and applicable law
• Provide clear information about the Property Draw and its rules
• Protect the integrity of the draw and ticketing systems
• Maintain appropriate records of entries, transactions, draws, winners, and prize payments
• Take reasonable measures to prevent fraud and unauthorised access
• Protect Players from misleading representations concerning their chances of winning
• Provide an accessible complaints procedure
• Implement responsible-gaming measures appropriate to the Property Draw
• Cooperate with lawful regulatory investigations and audits

11. Responsible Gambling

• Property Draw participation is a form of gambling and involves the risk of losing money.
• Players should participate only with money they can afford to lose.
• The Operator may introduce reasonable spending, deposit, account, participation, or self-exclusion controls where required by law or its responsible-gaming policy.
• Players may request information concerning available responsible-gambling and self-exclusion measures.

12. Advertising and Promotions

• All advertising shall be truthful, clear, and not materially misleading.
• Advertising shall comply with applicable regulatory requirements concerning age restrictions, responsible gambling, promotional claims, and consumer protection.
• No advertisement shall state or imply that a Player is guaranteed to win a prize.
• Promotional campaigns shall clearly state their eligibility requirements, duration, prizes, selection method, and material conditions.

13. Data Protection and Privacy

The Operator may collect and process personal information necessary to operate the Property Draw, verify identity and age, process payments, prevent fraud, comply with legal obligations, and administer prizes. Personal information shall be handled in accordance with applicable data-protection legislation and the Operator's Privacy Policy. The Operator shall take reasonable technical and organisational measures to protect Player information against unauthorised access, loss, alteration, disclosure, or misuse.

14. Suspension and Termination

The Operator may suspend or terminate a Player's participation where:

• The Player breaches these Terms
• The Player is found to be underage
• Fraud or unlawful activity is suspected
• Information supplied by the Player is materially false or misleading
• Suspension is required by a regulator, court, law-enforcement authority, or applicable law

The Operator may suspend a Property Draw where required for regulatory, technical, security, integrity, or other lawful reasons. Where a Property Draw is cancelled or suspended, the Operator shall deal with entries and prizes in accordance with applicable law, regulatory directions, and the approved rules of the Property Draw.

15. Technical Failures

The Operator shall take reasonable measures to maintain the availability, security, and integrity of its systems. The Operator shall not be responsible for failures outside its reasonable control, including telecommunications failures, power outages, natural disasters, cyber incidents, government actions, or other force-majeure events, subject to applicable law. Where a technical failure materially affects a draw or entry, the Operator shall take reasonable corrective measures and notify the regulator and affected Players where required.

16. Complaints and Dispute Resolution

Complaints should include the Player's name, ticket or transaction number, date of transaction, nature of the complaint, and supporting evidence. The Operator shall investigate complaints fairly and within a reasonable period. Where a dispute cannot be resolved internally, the parties may refer the matter to the relevant regulatory authority, mediation, arbitration, or a competent court as required or permitted by applicable law.

17. Changes to These Terms

The Operator may amend these Terms where reasonably necessary to comply with changes in law, regulation, technology, security requirements, or the operation of the Property Draw. Material amendments shall be communicated to Players through appropriate channels and, where required, submitted for regulatory approval before taking effect. No amendment shall unlawfully deprive a Player of a prize already validly won.

18. Limitation of Liability

19. Governing Law

These Terms shall be governed by the laws applicable to the Property Draw and the jurisdiction in which the Operator is licensed. The Operator shall comply with all applicable property draw, gaming, consumer-protection, taxation, anti-money-laundering, data-protection, advertising, and other relevant laws and regulatory directives.

20. Regulatory Authority

The Property Draw shall remain subject to the supervision, directives, inspection, audit, and enforcement powers of the competent regulatory authority. Where the Property Draw is operated in Nigeria under a National Lottery licence or applicable NLRC approval, the Operator shall comply with the applicable requirements of the National Lottery Regulatory Commission and the terms of its specific licence or permit.

21. Severability

If any provision of these Terms is determined to be invalid, unlawful, or unenforceable, that provision shall be modified or severed to the extent necessary, while the remaining provisions shall continue in effect to the extent permitted by law.

22. Entire Agreement

These Terms, together with the specific rules of each Property Draw game, applicable promotional rules, Privacy Policy, responsible-gaming policy, and the Operator's licence conditions, constitute the governing terms for participation in the Property Draw. Where there is a conflict between these Terms and a mandatory requirement of applicable law or a regulatory directive, the law or regulatory directive shall prevail.

23. Player Acceptance