Terms of Service

1.0 :: ACCEPTANCE_OF_TERMS

These Terms of Service (“Terms”) constitute a legally binding agreement between you (“User”, “you”, or “your”) and Minilotto Ltd. (“Minilotto”, “we”, “our”, or “us”) governing your access to and use of the Minilotto online lottery platform, including the player-facing website, wallet services, and all related features and applications (collectively, the “Platform”).

By registering an account, purchasing tokens, or otherwise accessing the Platform, you confirm that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, and any additional rules or notices published on the Platform. If you do not agree to these Terms, you must not use the Platform.

Minilotto operates under a valid licence issued by the Betting Control and Licensing Board of Zambia (BCLB) pursuant to the Lotteries Act (Chapter 163 of the Laws of Zambia) and the Betting Control Act (Chapter 164 of the Laws of Zambia). All operations are subject to the conditions of that licence and all applicable Zambian law.

2.0 :: ELIGIBILITY

To register and use the Platform, you must meet all of the following requirements:

• You are at least 18 years of age, as required by the Lotteries Act and applicable Zambian gambling regulations
• You hold a valid Zambian National Registration Card (NRC), which you must provide accurately at registration
• You are physically located in the Republic of Zambia at the time of participation
• You are not a current employee, director, contractor, or close family member of an employee or director of Minilotto Ltd.
• You have not been excluded from gambling under any self-exclusion programme or regulatory order
• You are legally competent to enter into a binding contract under Zambian law

We reserve the right to request documentary proof of eligibility at any time. Providing false information to circumvent eligibility requirements is a serious breach of these Terms and may be reported to the relevant authorities.

3.0 :: ACCOUNT_REGISTRATION

To access the Platform you must register an account by providing your full legal name, mobile phone number (MSISDN), email address, NRC number, and a secure password. You are responsible for ensuring that all information provided is accurate, current, and complete.

Each individual may hold only one account. Creating duplicate or multiple accounts is strictly prohibited and will result in the immediate suspension of all associated accounts and forfeiture of any balances held.

Your MSISDN serves as your unique account identifier and primary login credential. You are solely responsible for maintaining the confidentiality of your password. You must notify us immediately at support@minilotto.com if you suspect any unauthorised access to your account.

Minilotto will never contact you to request your password. We recommend enabling strong, unique passwords and logging out of shared devices after each session. Your active session is secured by a time-limited authentication token that expires automatically after 30 minutes of inactivity.

4.0 :: TOKENS_AND_WALLET

4.1 Tokens

Participation in Minilotto games requires the use of in-platform tokens. Tokens have no monetary value outside of the Platform, cannot be transferred between accounts, and cannot be redeemed for cash unless the Platform explicitly offers a withdrawal feature. Tokens are a platform credit used solely to purchase lottery game slots.

4.2 Purchasing Tokens

Tokens may be purchased using MTN Mobile Money. By initiating a token purchase, you authorise Minilotto and its payment processing partner (MTN Zambia) to debit the specified amount from your mobile money wallet. All purchases are subject to the minimum and maximum limits displayed on the Platform at the time of purchase.

4.3 Transaction Finality

All confirmed wallet transactions — including token credits from purchases and token debits from game entries — are recorded in an immutable, ACID-compliant ledger and are final and non-reversible once committed. You should verify all transaction details before confirming any purchase or game entry. In the event of a failed or disputed payment, please contact our support team with the relevant transaction reference.

4.4 Administrative Credits

In limited circumstances (such as the resolution of a verified platform error or dispute), Minilotto may credit your wallet manually. All such credits are subject to an internal two-person authorisation process — no single employee may unilaterally credit an account. All manual credits are logged in our audit system.

4.5 Referral Bonuses

You may earn token bonuses by referring new users to the Platform using your unique referral code. Referral bonuses are credited automatically upon the referred user’s successful registration and first transaction. Referral bonus amounts are set by Minilotto and may change at any time with notice. Abuse of the referral programme — including creating fake accounts to generate bonuses — will result in account termination and forfeiture of all accumulated tokens.

5.0 :: GAME_PARTICIPATION

5.1 How Games Work

Each Minilotto game consists of a fixed number of available slots, each priced at a set token value displayed before purchase. You may purchase one or more available slot numbers within a single game. Once all slots in a game are filled, or upon the scheduled game end date, a winner is selected from the occupied slots by the Minilotto system. The winner receives the prize associated with that game.

5.2 Slot Availability

Slot availability is displayed in real time. Once a slot is purchased by any user, it is no longer available. Minilotto does not guarantee the availability of any specific slot. Purchased slots are non-transferable and cannot be exchanged between games or users.

5.3 Winner Selection

The winning slot for each completed game is determined by Minilotto’s platform in accordance with our licence conditions under the Lotteries Act. The outcome is logged in our audit system and is final. Winners will be notified via the Platform and may also be contacted via their registered MSISDN or email address.

5.4 Game Cancellations and Refunds

Minilotto reserves the right to cancel any game in exceptional circumstances, including platform technical failure, regulatory direction, or insufficient slot sales by the scheduled end date. In the event of a cancellation, all tokens spent on slots within the cancelled game will be refunded to the participating users’ wallets. No further compensation is payable in respect of a cancelled game.

6.0 :: PROHIBITED_CONDUCT

You must not, and by using the Platform you agree not to:

• Register more than one account or register on behalf of another person without their knowledge
• Provide false, misleading, or incomplete identity information including name, MSISDN, or NRC number
• Attempt to manipulate, reverse-engineer, exploit, or disrupt the Platform, its game mechanics, or its underlying infrastructure
• Use automated scripts, bots, or any programmatic means to interact with the Platform
• Attempt to access the accounts, data, or wallets of other users
• Use the Platform in connection with money laundering, terrorist financing, or any other criminal activity
• Participate in any collusion, syndicate arrangement, or scheme designed to manipulate game outcomes or gain an unfair advantage
• Attempt to circumvent our rate-limiting, authentication, or security controls
• Use the Platform if you have been previously banned or excluded from Minilotto or from any other gambling service under a regulatory exclusion order
• Engage in any conduct that violates these Terms, the Lotteries Act, or any other applicable Zambian law

Violations of this section may result in immediate account suspension, forfeiture of wallet balance, reporting to the relevant regulatory and law enforcement authorities, and civil or criminal proceedings.

7.0 :: AML_AND_KYC_OBLIGATIONS

Minilotto is subject to the Anti-Money Laundering and Combating the Financing of Terrorism Act (AMLA) of Zambia and the conditions of our gambling licence. To comply with these obligations, we are required to verify your identity using your NRC number and mobile number, monitor transactions for suspicious activity, and report certain transactions to the Financial Intelligence Centre (FIC) of Zambia.

We may, at any time, request additional documentation to verify your identity, source of funds, or the legitimacy of your account activity. Failure to provide requested documentation within a reasonable timeframe may result in suspension of your account and funds pending investigation.

By using the Platform you consent to Minilotto conducting such checks and sharing relevant information with the FIC, the Betting Control and Licensing Board of Zambia (BCLB), and other authorities as required by law. This is not optional — it is a legal requirement of our operating licence.

8.0 :: RESPONSIBLE_GAMBLING

Minilotto is committed to promoting responsible gambling in accordance with our obligations under the Lotteries Act and our gaming licence. Gambling should be an enjoyable recreational activity; it is not a means to generate income or resolve financial difficulties.

You are solely responsible for your gambling behaviour. By using the Platform, you agree not to gamble with funds you cannot afford to lose, and to seek help if gambling is causing harm to you or others. If you wish to set account limits or request a period of exclusion, please contact us at support@minilotto.com.

Minilotto reserves the right to impose limits, cooling-off periods, or permanent exclusions on any account where we have reasonable grounds to believe the user may be experiencing gambling-related harm. Such interventions are carried out in accordance with our licence conditions and cannot be waived by the user during the designated period.

9.0 :: INTELLECTUAL_PROPERTY

All content, software, graphics, trademarks, game designs, and materials on the Platform are the exclusive property of Minilotto Ltd. or its licensors and are protected by applicable intellectual property laws. Nothing in these Terms grants you any right, title, or interest in or to any Platform content or intellectual property.

You are granted a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform solely for your personal, non-commercial participation in games, subject to these Terms. Any other use — including reproducing, distributing, or creating derivative works — is strictly prohibited without prior written consent from Minilotto.

10.0 :: PRIVACY_AND_DATA

Your use of the Platform is also governed by our Privacy Policy, which is incorporated into these Terms by reference. The Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights in relation to it. By using the Platform, you acknowledge that you have read and accept our Privacy Policy.

11.0 :: DISCLAIMERS

The Platform is provided on an “as is” and “as available” basis. To the fullest extent permitted by Zambian law, Minilotto makes no warranties, express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, or uninterrupted availability of the Platform.

We do not guarantee that the Platform will be free from errors, interruptions, or security vulnerabilities at all times. Planned and unplanned maintenance may temporarily affect availability. We will endeavour to notify users of planned downtime in advance where possible.

Game outcomes are determined by the Platform and are final. Minilotto does not guarantee any particular outcome or prize, and participating in any game does not guarantee a win. Gambling involves risk and you may lose the tokens you spend.

12.0 :: LIMITATION_OF_LIABILITY

To the maximum extent permitted under the laws of Zambia, Minilotto, its directors, employees, and agents shall not be liable for any indirect, incidental, special, or consequential loss or damage arising out of or in connection with your use of the Platform, including but not limited to loss of profits, loss of data, loss of tokens, or loss of opportunity.

Our total aggregate liability to you in connection with any claim under these Terms shall not exceed the total value of tokens held in your wallet at the time the claim arises, or ZMW 500, whichever is greater.

Nothing in these Terms limits liability for fraud, gross negligence, death or personal injury caused by negligence, or any other liability that cannot be excluded under applicable Zambian law.

13.0 :: SUSPENSION_AND_TERMINATION

13.1 By Minilotto

We reserve the right to suspend, restrict, or permanently close your account at any time if: you breach these Terms; we have reasonable grounds to suspect fraudulent, abusive, or criminal activity; we are required to do so by law or regulatory direction; or your account has been inactive for an extended period and has a zero token balance.

Where an account is suspended pending investigation, access to the wallet may be temporarily frozen. Where an account is permanently closed following a verified breach, any remaining token balance may be forfeited in accordance with our licence conditions.

13.2 By You

You may close your account at any time by contacting us at support@minilotto.com. Upon account closure, any remaining token balance will be handled in accordance with your instructions subject to identity verification, applicable law, and our AML obligations. Closure does not affect obligations or liabilities that arose before the closure date.

14.0 :: MODIFICATIONS_TO_TERMS

Minilotto reserves the right to update or amend these Terms at any time to reflect changes in our services, legal obligations, or regulatory requirements. Where changes are material, we will notify you by email or through a prominent notice on the Platform at least 14 days before the changes take effect.

Your continued use of the Platform after the updated Terms take effect constitutes your acceptance of the revised Terms. If you do not agree with any amendment, you must stop using the Platform before the effective date of the change. The current version of these Terms is always accessible on this page with the effective date noted at the top.

15.0 :: GOVERNING_LAW_AND_DISPUTES

These Terms are governed by and construed in accordance with the laws of the Republic of Zambia, including but not limited to the Lotteries Act (Chapter 163), the Betting Control Act (Chapter 164), the Prohibition and Prevention of Money Laundering Act No. 14 of 2001 (as amended), and the Data Protection Act No. 3 of 2021.

Any dispute arising out of or in connection with these Terms or your use of the Platform shall first be referred to our support team for informal resolution. If the dispute cannot be resolved informally within 30 days, it shall be subject to the exclusive jurisdiction of the courts of the Republic of Zambia.

If you have a complaint regarding any aspect of our service, you may also refer the matter to the Betting Control and Licensing Board of Zambia (BCLB), which oversees licensed gambling operations in Zambia.

16.0 :: GENERAL_PROVISIONS

Severability: If any provision of these Terms is found to be invalid or unenforceable under applicable law, that provision will be modified to the minimum extent necessary to make it enforceable, and the remaining provisions will continue in full force and effect.

Entire Agreement: These Terms, together with our Privacy Policy and any additional licence-specific conditions published on the Platform, constitute the entire agreement between you and Minilotto regarding your use of the Platform and supersede all prior agreements or understandings.

Waiver: Failure by Minilotto to enforce any provision of these Terms on any occasion shall not constitute a waiver of that provision or our right to enforce it in the future.

Assignment: You may not assign or transfer your rights or obligations under these Terms without our prior written consent. Minilotto may assign its rights and obligations, including in the event of a merger, acquisition, or business restructuring, with notice to you.

17.0 :: CONTACT_US

For questions about these Terms, account support, or to raise a complaint, please contact us: