Privacy policy.

Effective: 29 July 2026 Version 2.0 NDPA 2023 & Meta-aligned

Panenka AI is a WhatsApp-native betting assistant serving users across Africa. To do its job — placing bets on licensed bookmakers on your behalf, funding your bookmaker wallet when you ask, and replying to you on WhatsApp — it needs to handle some sensitive things: your phone number, your bookmaker logins, the messages you send us, and records of the bets and top-ups you instructed. This policy says, in plain English, what we collect, why we collect it, who we share it with, how long we keep it, and how you can make us delete it.

01The short version

We only collect what we need to place your bets, process your top-ups, and reply to you on WhatsApp. Phone number, profile name, the messages you send, your bookmaker logins (encrypted), records of bets we placed for you, and funding records for top-ups you confirmed.
We do not sell your data. Ever. There is no advertising business behind Panenka AI.
Your bookmaker password is encrypted at rest using AES-256-GCM and is only decrypted in memory when we need to log in to act on your instruction. We never display it back to you.
You control your data, in three granular steps. Send FORGET MY LOGIN to wipe stored bookmaker credentials, CLEAR CHAT to wipe your conversation history, or DELETE MY DATA to close your account and erase your personal data. You can also email privacy@usepanenka.com. We complete account deletions within 30 days.
Panenka AI is for adults only (18+) and is available only in our supported markets — currently Nigeria, Ghana, Kenya, Tanzania, Zambia, and South Africa — where your bookmaker operates.
We comply with the Nigeria Data Protection Act 2023 and the data protection laws of the other markets we serve, and we follow Meta's WhatsApp Business Platform data-handling requirements.

02Who we are

Panenka AI ("Panenka AI", "we", "us", "our") is operated by Panenka AI Technologies Ltd, a company registered in Nigeria, with its registered office in Lagos.

Under the Nigeria Data Protection Act 2023, we are the data controller for the personal data described in this policy. You can contact our data protection lead at privacy@usepanenka.com.

If you use Panenka AI from outside Nigeria, your local data protection law — for example Kenya's Data Protection Act 2019, Ghana's Data Protection Act 2012, South Africa's Protection of Personal Information Act (POPIA), Tanzania's Personal Data Protection Act 2022, or Zambia's Data Protection Act 2021 — may give you additional rights. We extend the rights described in this policy to every user, in every market we serve.

03What we collect

We collect three buckets of information. Nothing in here is collected silently — every item below corresponds to something you actively send us, to an instruction you give us, or to a message you receive from us.

From WhatsApp, when you message us

Data	Why we have it
Phone number (E.164)	Your account identifier. We cannot reply on WhatsApp without it.
WhatsApp profile name	To address you in replies (e.g. "Hi Tunde, your slip is locked in").
Message content (text)	To understand your request and place the correct bet. Panenka AI currently handles text messages; if you send us images, voice notes, or other media, the bot tells you it cannot read them and we do not process them.
Message metadata	Timestamps, message IDs, delivery/read status — used to reply correctly and debug failures.
Your country	You tell us your country at setup (we never infer it from your phone number). It sets your currency, timezone, and which bookmaker site we use for you.

From the betting flow itself

Data	Why we have it
Bookmaker username	To log into your bookmaker account on your behalf, only to carry out your instructions.
Bookmaker password (encrypted)	Same. Stored encrypted with AES-256-GCM, decrypted in memory only at the moment of use, never logged, never displayed back.
Bookmaker session tokens (encrypted)	So we stay logged in between your instructions without asking for your password again. Stored encrypted, expired and replaced regularly.
Booking codes & slip details	The selections, stake, and codes you ask us to place.
Bet history we placed for you	So we can tell you "we placed this for you on Saturday at 14:32" if you ask, and so settlement outcomes can be tracked and reported to you.
Funding & refund records	When you confirm a bookmaker top-up: the verified account holder name, amount, transfer reference, payment and credit status. Where a top-up fails and a refund is needed, the bank name, account number, and account holder name you give us for the refund.
Subscription & payment records	If you buy a Panenka AI plan: the plan, amount, currency, our payment reference, the payment's verified status and time, and your subscription's start and end dates. These are financial records — they survive account deletion in anonymised form so a payment always has an explanation on our side.
Saved-card renewal token	If you pay by card, our payment provider (Paystack) gives us a token that lets us charge that saved card for your next renewal — never your card number, which only Paystack sees. Bank-transfer and USSD payments create no token, and nothing renews by itself for them. Cancelling your subscription — or deleting your account — removes the token's ability to charge you.
Conversation history	The messages and steps of your chats with the bot, so the bot remembers context within and across conversations. Kept as described in How long we keep it, and clearable at any time with `CLEAR CHAT`.

From the technical infrastructure

Data	Why we have it
Server logs (IP, request paths, status codes)	For debugging, security monitoring, and abuse prevention. Phone numbers are masked in application logs.
Approximate device info from WhatsApp metadata	Provided by WhatsApp; used for compatibility (e.g. sending an interactive message format your client supports).
Aggregated, anonymous usage stats	Counts of messages handled, error rates. No personal identifiers.

What we do not collect

We do not collect your card details (card and bank payments are handled directly by licensed payment providers), your contacts list, your precise location, or any data from other apps on your phone. We do not read messages you send to anyone other than us. We do not use third-party advertising trackers on this website.

04How we use it

We use your data only for the following purposes:

To run the bot. Receive your message, understand your intent, place your bet on the bookmaker, process your confirmed top-up, send you the receipt.
To reply to support questions. If you ask "where's my receipt?" we look up your recent activity and answer.
To send transactional WhatsApp messages. Slip confirmations, expired-session notices, win/loss outcomes, funding status updates, one-time security codes. These are utility and authentication messages — never marketing — unless you've explicitly opted in.
To improve the service. Find and fix bugs, measure error rates, and improve our intent extraction using conversation data with direct identifiers (phone numbers, profile names) removed. We do not use your raw conversations to train third-party AI models.
To prevent fraud and abuse. Detect attempted account takeovers, multi-account abuse, and fraudulent betting or funding patterns.
To comply with the law. Including applicable gaming regulation in the markets we serve, tax law, anti-money-laundering obligations, and lawful requests from courts or regulators.

We will not use your data for any purpose materially different from the ones above without first asking your consent.

05Legal basis (NDPA 2023 and equivalents)

We rely on the following legal bases:

Performance of a contract. We process your phone number, your bookmaker credentials, your bet instructions, and your funding instructions because that is how we deliver the service you signed up for.
Legitimate interests. We process logs and aggregated usage data to keep the service running, secure, and free of fraud — interests that we believe do not override your rights.
Consent. We rely on your explicit consent for any optional marketing messages (e.g. price-drop alerts) and for storing your bookmaker password long-term so you don't have to re-enter it.
Legal obligation. Where regulators or courts in the markets we serve require us to retain or disclose information — including gaming and tax record-keeping.

You can withdraw consent at any time: reply STOP on WhatsApp (mutes marketing), FORGET MY LOGIN (deletes stored bookmaker credentials), CLEAR CHAT (clears conversation history), or DELETE MY DATA (closes your account).

06Who we share with

We share data only with the parties below, only for the reasons listed, and only the data they need to do their job.

Recipient	What we share	Why
Meta (WhatsApp)	Your phone number, profile, message content	WhatsApp is the channel itself. Meta processes the messages between you and us as part of running the platform. Their handling is governed by the WhatsApp Privacy Policy.
Your bookmakers (e.g. SportyBet, Bet9ja)	Your bookmaker username, password, and the specific action you asked us to perform	To log in and place the bet, load the code, or read the slip. We share only the credentials of the bookmaker you connected, only at the moment of carrying out your instruction. The bookmaker's own privacy policy applies to what they do with your account.
Licensed payment providers (currently Paystack and Kuda, for Naira top-ups)	The verified account name, top-up amount, transfer reference, and transaction status — and, for refunds, the bank account details you provide	To collect a funding transfer you confirmed, credit the bookmaker wallet you selected, and refund or escalate a failed credit.
Anthropic (AI provider)	Your message text (with phone number redacted)	We use Claude to extract intent from natural-language messages ("show me Chelsea matches"). Anthropic's privacy policy applies. Your text is not used to train their models under our enterprise terms.
Hosting provider	Application data and logs on encrypted infrastructure	Our servers run on a VPS in a third-party data centre. They store the bytes; credentials are additionally encrypted at the application layer.
Regulators / law enforcement	Whatever a valid legal request demands	Only on receipt of a lawful order. We will tell you if we receive one unless legally prohibited.

What we do not share

We do not sell, rent, or trade your data with advertisers, data brokers, marketing firms, or any third party not listed above. We do not share your data with any bookmaker other than the one you connected, and only for the actions you instructed. There is no advertising business behind Panenka AI.

07Your bookmaker credentials

This is the most sensitive thing we hold, and we treat it accordingly.

Encryption at rest. Your bookmaker password is encrypted using AES-256-GCM. The encryption key is injected into the application from the server environment and is never written to the database or to source code.
Decryption only in memory, only at use. We decrypt your password in process memory at the exact moment we are logging into the bookmaker on your behalf, and we discard the cleartext immediately after.
Never logged. Our server logs explicitly redact credential fields. If a debug log accidentally captured a credential, that is a security incident and we treat it as such.
Never displayed back to you. Even you, the account owner, cannot read your stored password back from us. If you forget it, reset it on the bookmaker's site and re-enter it with us.
Deletable on demand. Reply FORGET MY LOGIN on WhatsApp and we wipe your stored bookmaker credentials and session tokens within seconds. The rest of your account is unaffected.

If you only want Panenka AI to work with booking codes without a stored login, you do not have to give us a password at all — the load a code and stake flow can work from a code alone, while the browse and build a slip flows require a connected bookmaker account.

08WhatsApp & Meta data

Panenka AI is built on top of Meta's WhatsApp Business Platform. Some specifics that follow from that:

End-to-end encryption. WhatsApp encrypts messages in transit between your device and ours. Once a message reaches our server (decrypted), we process it under this policy.
Meta sees the metadata. Phone numbers, timestamps, message types, and delivery statuses are visible to Meta as the platform operator. We do not control that.
24-hour customer service window. Meta's policy lets us reply freely for 24 hours after your last inbound message. Outside that window, we can only send pre-approved template messages — typically slip confirmations, login codes, funding status, and outcome notices.
Marketing messages require opt-in. We will not send you promotional templates (e.g. "boosted odds on this match") unless you have explicitly opted in. Reply STOP at any time to mute these. Utility and authentication messages tied to bets you placed will continue, because they are part of the service you asked for.
Click-to-WhatsApp ads. If you arrived via a Facebook or Instagram ad, Meta may share with us the fact that you clicked from a specific ad campaign, so we know which campaign you came from.

09How long we keep it

Data	Retention
Your account & bookmaker credentials	For as long as your account is active. Credentials can be wiped at any time with `FORGET MY LOGIN`; everything is deleted within 30 days of an account deletion request.
Conversation history	180 days, then deleted unless tied to a bet still in dispute. You can clear it at any time by sending `CLEAR CHAT`.
Bets placed (receipts, codes)	5 years, to comply with gaming and tax record-keeping requirements in the markets we serve. On account deletion these records are anonymized — stripped of everything that identifies you — and the anonymous remainder is deleted at the end of the retention period.
Funding records (top-ups, refunds)	5 years, for financial record-keeping and anti-money-laundering obligations. Anonymized on account deletion in the same way as bet records; refund bank details are scrubbed, not retained.
Server logs	Up to 30 days, then rotated out.
Aggregated, anonymous metrics	Indefinitely (no personal data inside).
Backups	Encrypted backups are retained for up to 35 days. Deletion requests propagate through the next backup cycle.

10Your rights

Under the Nigeria Data Protection Act 2023 — and the equivalent laws of every market we serve — you have the following rights. We honor each one of them, free of charge, within 30 days of your request.

Right to access. Ask us for a copy of the personal data we hold about you.
Right to correction. Ask us to fix anything inaccurate.
Right to deletion. Ask us to delete your account and your data — see the next section for how.
Right to portability. Ask us to export your data in a machine-readable format (JSON).
Right to object. Object to processing based on legitimate interests, or to marketing.
Right to withdraw consent. Where we rely on consent (marketing, long-term credential storage), you can withdraw at any time.
Right to lodge a complaint. With the Nigeria Data Protection Commission, or with your local data protection authority, if you believe we have mishandled your data.

To exercise any of these, message the bot or email privacy@usepanenka.com from the phone number registered with your account. We may ask one verification question to confirm it is you.

11Deleting your data

You stay in control of your data at three levels, all available directly in the bot:

FORGET MY LOGIN — wipes your stored bookmaker credentials and session tokens within seconds. Your account, conversation history, and bet records are unaffected.
CLEAR CHAT — wipes your conversation history with the bot: past messages, conversation context, and personalisation memory. Your account, connected bookmakers, and bet records are unaffected. If you have a bet still awaiting settlement, we keep the minimum needed to settle and report it, then delete it.
DELETE MY DATA — closes your Panenka AI account entirely. The bot asks you to confirm once before anything is touched, because this cannot be undone.

You can also request deletion by email: send a message from the address on file (or the registered phone number, via WhatsApp) to privacy@usepanenka.com with the subject "Delete my data".

We complete account deletions within 30 days. What deletion means for each kind of data:

Deleted: your account record and phone number, stored bookmaker credentials and sessions, conversation history, notification preferences, and watch/alert subscriptions.
Anonymized, then retained: records of bets we placed for you and funding records may be kept for up to 5 years to comply with gaming, tax, and anti-money-laundering record-keeping. Before retention they are stripped of everything that identifies you — your user reference, phone number, names, and refund bank details are scrubbed — and the remaining anonymous ledger is isolated, access-restricted, and never used for any product purpose. If you delete your account while a self-exclusion is active, we also keep a one-way scrambled fingerprint (a cryptographic hash) of your phone number — never the number itself — until the exclusion expires, so the break you asked for still holds if you rejoin before it ends.

Deleting your Panenka AI account does not delete your bookmaker accounts (SportyBet, Bet9ja). To close those, contact each bookmaker directly. Full details are on our data deletion page.

Meta App Review note

If you are Meta's review team verifying our data deletion contact for the WhatsApp Business Platform: this section and our data deletion page are the canonical user-facing data deletion mechanism. The address privacy@usepanenka.com is monitored for deletion requests and we respond within 30 days as required.

12Security

We take security seriously because we have to — bookmaker credentials are not data we get to leak.

Encryption in transit. All HTTP traffic to and from our servers is HTTPS only, TLS 1.2+, with HSTS enabled. WhatsApp traffic is end-to-end encrypted on top.
Encryption at rest. Bookmaker credentials and session tokens are AES-256-GCM encrypted at the application layer, with keys injected from the server environment and never stored in the database or source code.
Least privilege. Production database access is restricted to a small number of named operators. Staff tooling that can display user data is read-only and masks phone numbers by default.
Logging discipline. Application logs explicitly redact credentials, OTPs, full phone numbers, and bookmaker session tokens.
Backups. Encrypted, retention capped at 35 days, restoration drilled.
Incident response. If we discover a breach affecting your data we will notify you within 72 hours, and notify the relevant data protection authority as required by law.

No system is perfectly secure. If you believe you have found a vulnerability in Panenka AI, please email security@usepanenka.com — we appreciate responsible disclosure.

1318+ only

Panenka AI is for adults only. By using the service, you confirm you are at least 18 years old and physically located in one of our supported markets — currently Nigeria, Ghana, Kenya, Tanzania, Zambia, and South Africa. Gaming law in every market we serve, and Meta's WhatsApp Business policy, both require this.

We do not knowingly collect data from anyone under 18. If we learn that a user is under 18, we delete their account and data immediately. When we ban an under-18 account we keep only the phone number and the ban reason — the minimum marker that stops the account being re-created — and everything else is wiped. Parents or guardians who believe a minor has used the service should contact privacy@usepanenka.com and we will act within 24 hours.

If you or someone close to you is struggling with gambling, free confidential help is available: in Nigeria, contact Gamble Alert (gamblealert.org) on +234 705 889 0073 or +234 705 889 0074 (toll-free); in South Africa, the National Responsible Gambling Programme (responsiblegambling.org.za) on 0800 006 008 (toll-free, 24/7); anywhere else, Gamblers Anonymous (gamblersanonymous.org) or your local gambling support line. You can also send SELF-EXCLUDE to the bot to suspend your own access for a period you choose.

14International transfers

Your data is stored on servers operated by our hosting provider, which may be located outside your country. Where we transfer data internationally — for example, to Meta's data centres or to Anthropic's API endpoints — we rely on the receiving party's adequate-protection commitments and on the contractual safeguards required by applicable data protection law.

We do not transfer data to jurisdictions that lack reasonable data protection law without your explicit consent or another lawful basis.

15Cookies on this site

This website (usepanenka.com) does not set advertising or tracking cookies. We do not embed Facebook Pixel, Google Analytics, or third-party ad trackers. The only state we set in your browser is what is necessary for the page to function (for example, remembering whether you chose dark or light mode).

The WhatsApp bot itself does not use cookies — it is a messaging service, not a website.

16Changes to this policy

We may update this policy as the service evolves or as the law changes. When we do, we will:

Update the "Effective" date at the top.
Increment the version number.
For any change that materially affects your rights, send a notice on WhatsApp and require you to acknowledge the new policy before continuing to use the service.

The current version of this policy is always at usepanenka.com/privacy.html.

17Contact us

For any privacy question, request, or complaint:

Email our data protection lead: privacy@usepanenka.com
Security disclosures: security@usepanenka.com
General: hello@usepanenka.com
WhatsApp: send HELP to the bot
Post: Panenka AI Technologies Ltd, Lagos, Nigeria

If we do not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Nigeria Data Protection Commission or with your local data protection authority.