Privacy Policy

Last Updated: May 2026

1. Introduction

Luxx Life (Pty) Ltd (“Luxx Life”, “we”, “us”, or “our”) is a registered Social Lottery Manager appointed by the National Lotteries Commission (“NLC”) under the Lotteries Act, 57 of 1997 (“the Act”). In this capacity, Luxx Life provides administrative and operational services to registered Non-Profit Organisations (“NPOs”) who are the licensed operators of draw-based social lottery raffles conducted on the Luxx Life platform.

Luxx Life is committed to protecting the personal information of all participants in accordance with:

• The Protection of Personal Information Act, 4 of 2013 (“POPIA”)
• The Consumer Protection Act, 68 of 2008 (“CPA”)
• The Lotteries Act, 57 of 1997, and regulations promulgated thereunder
• Any applicable directions or guidelines issued by the NLC

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you:

• Visit www.luxxlife.co.za (the “Website”)
• Create a participant account
• Purchase raffle entries in draw-based social lottery raffles
• Participate in raffles conducted on behalf of NPO operators
• Interact with our services or contact us

By using our Website and services, you agree to the practices described in this Privacy Policy.

2. Responsible Party

The responsible party for the processing of your personal information is:

• Luxx Life (Pty) Ltd
• Johannesburg, Sandton, 2196
• Email: hello@luxxlife.co.za

Luxx Life determines the purpose and means of processing personal information in its capacity as Social Lottery Manager on behalf of NPO operators. Individual NPOs, as the licensed operators of their respective social lottery raffles, may separately process personal information in accordance with their own privacy obligations under applicable law.

3. Nature of Social Lottery Raffles

Luxx Life operates exclusively as a Social Lottery Manager providing administrative services to NPOs that are registered and licensed under the Lotteries Act, 57 of 1997. All draw-based social lottery raffles are conducted by the relevant NPO as the licensed operator. Luxx Life does not operate social lottery raffles independently.

All raffles facilitated through the Luxx Life platform are:

• Draw-based social lottery raffles constituting games of chance
• Conducted on behalf of, and under the name of, the relevant NPO operator
• Subject to the rules, conditions, and approvals issued by the NLC
• Open only to natural persons aged 18 years or older who are residents of the Republic of South Africa

Winners are determined solely by random draw. No element of skill, judgment, or ability is involved in the determination of winners.

Personal information is processed to administer draw-based raffles lawfully, transparently, and in accordance with the Lotteries Act and POPIA.

4. Personal Information We Collect

We may collect and process the following categories of personal information:

4.1 Information You Provide Directly

• Full name
• South African ID number or date of birth (for age and identity verification)
• Email address
• Mobile number
• Residential address
• Billing details
• Raffle entry records
• Communications with customer support

4.2 Payment Information

Payment card information is processed securely by third-party payment processors. Luxx Life does not store full card numbers. Limited transaction confirmation records are retained for compliance and audit purposes as required under the CPA and the Lotteries Act.

4.3 Technical Information

• IP address
• Device and browser information
• Operating system
• Website usage data
• Cookies and tracking data

4.4 Raffle and Account Data

• Reffle entries purchased
• Participation history per raffle
• Random draw results
• Winner verification records
• Prize fulfilment documentation

5. How We Use Your Personal Information

We process personal information for the following lawful purposes:

5.1 To Provide Raffle Administration Services

• Registering and managing your participant account
• Processing raffle entries and payments
• Administering draw-based raffles on behalf of NPO operators
• Conducting and recording random draws
• Facilitating prize delivery in collaboration with the relevant NPO operator

5.2 Eligibility Verification and Regulatory Compliance

We process identity, age, and residency information to verify participant eligibility in accordance with:

• The Lotteries Act, 57 of 1997, and NLC requirements
• The raffle terms and conditions of the relevant NPO operator
• The Consumer Protection Act, 68 of 2008

Identity documentation may be requested prior to prize fulfilment in order to verify the identity and eligibility of a winner.

5.3 Fraud Detection and Prevention

We may process personal information for the purposes of:

• Fraud detection and prevention
• Identity and eligibility verification
• Detection of duplicate account or entries
• Risk monitoring
• Preventing abuse of raffle processes
• Investigating suspicious activity

We reserve the right to disqualify participants found to be in breach of applicable raffle terms and conditions or the Lotteries Act.

5.4 Communication

We may contact you to:

• Confirm raffle entries
• Provide account updates
• Notify winners. of draw-based raffles
• Respond to enquiries
• Send marketing communications regarding social lottery raffles (where you have provided consent or as permitted by applicable law)

5.5 Legal and Regulatory Compliance

We may process and retain personal information to:

• Comply with the Lotteries Act, POPIA, and all applicable South African law
• Maintain draw and raffle records for NLC audit and reporting purposes
• Respond to lawful requests from the NLC, Information Regulator, or other competent authorities
• Protect our legal rights and those of the NPO operators

6. Lawful Basis for Processing (POPIA)

We process personal information under one or more of the following lawful grounds as contemplated in POPIA:

• Your consent
• Performance of a contract (raffle entry, prize award, and account services)
• Compliance with legal obligations 
• (including the Lotteries Act and NLC requirements)
• Legitimate interests of Luxx Life or the relevant NPO operator (including fraud prevention and service integrity)

Where processing is based on consent, you may withdraw such consent at any time by contacting us at hello@luxxlife.co.za. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

7. Direct Marketing

We may send you marketing communications regarding social lottery raffles conducted on behalf of NPO operators if:

• You have opted in to receive such communications; or
• You are an existing participant and have not opted out.

You may unsubscribe at any time via:

• The unsubscribe link included in marketing emails; or
• Emailing hello@luxxlife.co.za

We do not sell or disclose personal information to third parties for their own marketing purposes.

8. Sharing of Personal Information

We do not sell or rent your personal information.

We may share information with the following categories of recipients:

8.1 NPO Operators

Third-party service providers engaged by Luxx Life to assist with:

• Payment processing
• Website hosting and cloud services
• IT support and security
• SMS and email distribution
• Fraud monitoring
• Prize logistics and fulfilment

All third-party service providers are contractually required to safeguard personal information in accordance with POPIA and to process it only for the purposes for which it was shared.

8.2 Legal and Regulatory Authorities

We may disclose personal information where required by law, court order, or a lawful directive from the NLC, Information Regulator, or other competent regulatory authority.

8.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, personal information may be transferred to the relevant successor entity, subject to equivalent protections.

9. Cross-Border Transfers

Some service providers may store or process personal information outside the Republic of South Africa. Where personal information is transferred internationally, Luxx Life ensures that:

• The recipient country or organisation provides a comparable level of data protection; or
• Appropriate contractual safeguards (including data processing agreements) are in place; or
• You have provided informed consent to the transfer.

10. Retention of Personal Information

We retain personal information only for as long as necessary to:

• Fulfil the purpose for which it was collected
• Comply with legal and regulatory obligations, including the Lotteries Act and NLC record-keeping requirements
• Maintain draw and raffle records for audit purposes
• Prevent fraud and resolve disputes

Draw records, raffle transaction records, and winner verification documentation may be retained for such periods as required under the Lotteries Act, the CPA, and applicable NLC directions. When personal information is no longer required, it will be securely deleted or de-identified in accordance with POPIA.

11. Security Safeguards

Luxx Life implements appropriate technical and organisational security measures, including:

• Secure hosting environments
• SSL-encrypted transactions
• Access control and role-based permissions
• Confidentiality agreements with staff and service providers
• Ongoing security monitoring

While we take all reasonable steps to protect personal information, no system or transmission method can be guaranteed to be completely secure.

12. Mandatory and Voluntary Information

Certain categories of personal information are required to participate in social lottery raffles, including:

• Identity and age verification information
• Payment and billing details
• South African residency confirmation

Failure to provide required information may result in the inability to process a raffle entry, disqualification, or the inability to award a prize. Where information is voluntary, this will be indicated at the time of collection.

13. Winner Determination

All winners of draw-based social lottery raffles facilitated through the Luxx Life platform are determined by a random draw process. Winner determination is not based on skill, judgment, or automated profiling of participants.

The random draw process is conducted in accordance with the terms and conditions of the relevant NPO operator’s raffle and the requirements of the NLC. Draw results are recorded and retained for regulatory audit purposes.

14. Winner Announcements and Publicity

Luxx Life and the relevant NPO operator may be required to announce draw-based raffle winners in accordance with the Lotteries Act and NLC requirements. Such announcements may include a winner’s first name and town of residence, where required for transparency and regulatory compliance.

Any additional use of a winner’s personal information for publicity purposes — including photographs, video recordings, testimonials, or other identifiable content — will only be undertaken with the winner’s prior written consent. Participation in any such publicity activity is entirely voluntary and will not affect entitlement to a prize.

Consent for publicity use may be withdrawn at any time prior to publication by contacting hello@luxxlife.co.za.

15. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Maintain Website functionality and session management
• Analyse traffic and usage patterns
• Enhance the participant experience

You may manage or disable cookies through your browser settings. Please note that disabling certain cookies may limit Website functionality. Where required by applicable law, we will obtain your consent before placing non-essential cookies.

16. Children’s Privacy

Our services are strictly limited to individuals aged 18 years or older, in accordance with the Lotteries Act, 57 of 1997. We do not knowingly collect personal information from persons under the age of 18. If we become aware that personal information has been collected from a minor, such information will be deleted without delay.

17. Data Breach Notification

In the event of a security compromise that poses a real risk of harm to participants, Luxx Life will:

• Notify the Information Regulator as required under POPIA; and
• Notify affected individuals in a manner and within the timeframes prescribed by POPIA.

18. Your Rights Under POPIA

In accordance with POPIA, you have the right to:

• Request access to your personal information held by Luxx Life
• Request the correction or updating of inaccurate personal information
• Request the deletion of your personal information (where legally permissible)
• Object to the processing of your personal information
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Information Regulator
• Lodge a complaint with the Information Regulator

Requests relating to your personal information may be directed to: Email hello@luxxlife.co.za

Proof of identity may be required before we are able to process your request.

19. Complaints

If you believe that Luxx Life has processed your personal information in an unlawful manner, you may lodge a complaint with:

The Information Regulator (South Africa)
Website: https://www.justice.gov.za/inforeg/
Email: complaints.IR@justice.gov.za

Complaints relating to the conduct of social lottery raffles may be directed to the National Lotteries Commission where appropriate.

We encourage participants to contact Luxx Life in the first instance so that we may have the opportunity to resolve any concern directly.

20. Changes to This Privacy Policy

Luxx Life may update this Privacy Policy from time to time to reflect changes in our practices, the requirements of the NLC, or applicable legislation. Updated versions will be published on our Website with a revised “Last Updated” date.

Continued use of our Website and services following publication of an updated Privacy Policy constitutes acceptance of the revised terms. Where changes are material, we will endeavour to notify registered participants by email.