Terms

Terms and Conditions

UPDATED AS OF JULY 10, 2026.

Super Geeks LLC, its officers, directors, employees, contractors and affiliates (collectively, the “Company”, “us”, “our” or “we”), is the provider of the Exclusive Gaming Platforms, which include www.exclusivegaming.net, and any associated websites, mobile apps, or web pages available through external sites, third-party platforms or third party providers, such as through a Facebook page, Instagram, Snapchat, or X, in combination with any operations, content, products and services we provide or made available through any of the foregoing (collectively, the “Web Sites/Applications”). Please note, if accessing any one or more of the Web Sites/Applications through external sites, third party platforms or third party providers, you are also bound by all terms and conditions set forth in the policies of such external sites or third party platforms or third party providers.

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE ACCESSING, USING OR BROWSING THE WEB SITES/APPLICATIONS. ACCESSING, USING OR PARTICIPATING IN THE SERVICES OFFERED BY THE WEB SITES/APPLICATIONS, CONSTITUTES ACCEPTANCE OF OUR POLICIES, INCLUDING THESE TERMS OF USE.

THESE GENERAL TERMS OF USE FORM A BINDING AGREEMENT BETWEEN YOU AND THE COMPANY AND GOVERN YOUR USE OF OUR WEB SITES/APPLICATIONS, INCLUDING OUR GAMES IN ANY WAY. FOR THE AVOIDANCE OF DOUBT, WHILE SOME GAMES MAY BEAR RESEMBLANCE TO SLOT-MACHINES OR OTHER GAMES FOUND IN REAL-WORLD CASINOS, THE GAMES IN NO WAY OFFER REAL MONEY GAMBLING OPPORTUNITIES. NO REAL MONEY IS REQUIRED TO PLAY ANY GAMES ON THE WEB SITES/APPLICATIONS AND ALL SERVICES PROVIDED BY THE WEB SITES/APPLICATIONS ARE INTENDED FOR ENTERTAINMENT PURPOSES ONLY. THE SERVICES OFFERED BY THE WEB SITES/APPLICATIONS INCLUDE SOCIAL GAMES AND SWEEPSTAKES GAMES USED TO PROMOTE THE SOCIAL GAMES. NO PURCHASE IS NECESSARY TO ENTER AND PLAY GAMES IN ANY SWEEPSTAKES GAMES OFFERED BY THE WEB SITES/APPLICATIONS (“SWEEPS PLAY”).

FURTHERMORE, THESE TERMS OF USE EXPRESSLY INCORPORATE AND ARE INSEPARABLY LINKED TO OUR POLICIES, INCLUDING OUR PRIVACY POLICY, OFFICIAL SWEEPSTAKES RULES, LEGAL NOTICES, AND RESPONSIBLE GAMING POLICY.

THE WEB SITES/APPLICATIONS ARE ONLY AVAILABLE TO PARTICIPANTS IN THE UNITED STATES EXCLUDING THOSE IN CALIFORNIA, CONNECTICUT, DELAWARE, IDAHO, INDIANA, LOUISIANA, MAINE, MICHIGAN, MONTANA, NEVADA, NEW JERSEY, NEW YORK, TENNESSEE, UTAH AND WASHINGTON (THE “EXCLUDED TERRITORY”). SWEEPS PLAY IS ONLY AVAILABLE TO PARTICIPANTS IN THE UNITED STATES (EXCLUDING THE EXCLUDED TERRITORY). CHECK OUR OFFICIAL SWEEPSTAKES RULES TO DETERMINE YOUR ELIGIBILITY. THE COMPANY RESERVES THE RIGHT TO MAKE CHANGES TO THE EXCLUDED TERRITORY AT ANY TIME, WITHOUT NOTICE. YOU AGREE THE COMPANY SHALL NOT BE LIABLE FOR ANY DAMAGES RESULTING FROM A CHANGE TO THE EXCLUDED TERRITORY. PARTICIPATION IS VOID IN THE EXCLUDED TERRITORY AND WHERE PROHIBITED BY LAW.

IMPORTANT INFORMATION ABOUT BINDING AND FINAL ARBITRATION

THESE TERMS OF USE CONTAIN A MANDATORY ARBITRATION PROVISION IN THE SECTION TITLED “DISPUTE RESOLUTION BY BINDING ARBITRATION AGREEMENT,” WHICH SAYS THAT YOU AND THE COMPANY AGREE TO RESOLVE DISPUTES SOLELY THROUGH FINAL AND BINDING ARBITRATION ON AN INDIVIDUAL AND NOT CLASS-WIDE OR CONSOLIDATED BASIS. AMONG OTHER THINGS, THIS MEANS YOU WAIVE THE RIGHT TO RESOLVE DISPUTES IN COURT OR BEFORE A JURY. THESE TERMS OF USE ALSO CONTAIN A LIMITATION ON THE TIME PERIOD YOU HAVE A RIGHT TO BRING A CLAIM AGAINST THE COMPANY AFTER THE RELEVANT EVENTS HAVE OCCURRED.

YOU HAVE THE RIGHT TO OPT OUT OF ARBITRATION. SEE THE SECTION TITLED “DISPUTE RESOLUTION BY BINDING ARBITRATION AGREEMENT” BELOW FOR INSTRUCTIONS ON HOW TO OPT OUT.

The following governs your access and use of our Web Sites/Applications, including both of our entertainment platforms, including our Social Games platform and the Promotional Games sweeps play platform, all information, games, accounts, multimedia, comments, and other information and/or any other content (collectively, “Content”) available on or through our Web Sites/Applications, as engaged by you or other users.

BY ELECTRONICALLY ACCESSING THE WEB SITES/APPLICATIONS, CREATING A USER ACCOUNT ON WEB SITES/APPLICATIONS AND/OR ENGAGING IN ANY OF THE INFORMATIONAL, INTERACTIVE MULTIMEDIA SERVICES OR ENTERTAINMENT PROVIDED BY OR THROUGH THE WEB SITES/APPLICATIONS AND/OR THE WEB SITES/APPLICATIONS, YOU AGREE:

YOU HAVE READ AND UNDERSTAND ALL OF THE TERMS OF USE AND LEGAL NOTICES CONTAINED HEREIN; AND

YOU AGREE TO BE BOUND BY ALL OF OUR POLICIES, INCLUDING THESE TERMS OF USE, AND OUR OFFICIAL SWEEPSTAKES RULES, PRIVACY POLICY, RESPONSIBLE GAMING POLICY AND LEGAL NOTICES; AND

YOU ARE AT LEAST LEGAL AGE IN YOUR JURISDICTION (IN MOST REGIONS ATLEAST 21 YEARS OLD) AT TIME OF ACCESS OR REGISTRATION.

IF YOU ARE NOT WILLING TO BE OR CANNOT BE BOUND BY ALL OF THE TERMS AND CONDITIONS CONTAINED HEREIN, INCLUDING WITHOUT LIMITATION THE PRECEDING ACKNOWLEDGEMENT, THEN DO NOT ACCESS, BROWSE OR USE WEB SITES/APPLICATIONS OR ANY OF THE CONTENT. MOREOVER, WEB SITES/APPLICATIONS DOES NOT AND WILL NOT GRANT YOU ANY RIGHT OR LICENSE TO ACCESS, BROWSE OR USE WEB SITES/APPLICATIONS INCLUDING THE CONTENT WITHOUT YOUR WILLINGNESS AND ABILITY TO BE BOUND BY ALL OF THE TERMS AND CONDITIONS CONTAINED HEREIN, INCLUDING WITHOUT LIMITATION THE PRECEDING AGREEMENT AND ACKNOWLEDGEMENT.

We reserve the right, in our sole discretion, to revise or modify these Terms of Use at any time. Users are responsible for reviewing our Terms of Use periodically. Your continued accessing the Web Sites/Applications or any informational or interactive media services by or through the Company after a change or modification of the Terms of Use will constitute your acceptance of the revised Terms of Use. The date of the most recent Terms of Use will be posted at the top of this document.

PLEASE NOTE THAT THE SERVICE IS INTENDED FOR AMUSEMENT AND ENTERTAINMENT ONLY. THE SERVICE IS NOT A LOTTERY OR GAMBLING ACTIVITY AND YOU ACKNOWLEDGE THAT THE COMPANY DOES NOT PROVIDE YOU WITH ANY PRIZES OF MONETARY VALUE UNLESS IT IS RELATED TO THE SWEEPS PLAY.

GENERAL PERMISSIONS AND RESTRICTIONS:

The Company hereby grants you permission to access and use the Web Sites/Applications as set forth herein, provided that:

You agree not to alter or modify any part of Web Sites/Applications, except as provided for herein.
You agree not to access Content through any technology or means other than the authorized webpages and/or applications designated by the Company, or other explicitly authorized means the Company may designate in writing.
You agree not to use the Web Sites/Applications for any commercial use without the prior written authorization of the Company. Prohibited commercial uses include any of the following actions taken without the Company’s express approval:

sale of access to the Web Sites/Applications or its related services on another website;
use of the Web Sites/Applications or its related services for the primary purpose of gaining advertising or subscription revenue;
the sale of advertising, on the Web Sites/Applications or any Third-Party Website, targeted to the Web Sites/Applications or any of the Content; and
any use of Web Sites/Applications or its related services that the Company finds, in its sole discretion, to use Content with the effect of competing with or displacing the market for the Web Sites/Applications.

Prohibited commercial uses do not include any use that the Company expressly authorizes in writing.
Where expressly allowed by the Company, if you use any Content on another website, you must include a prominent text link back to the Web Sites/Applications on the pages where the Content is utilized. In such an instance you may not modify, build upon, or block any portion of the utilized Content.
You agree not to use or launch any automated system, including without limitation, “robots,” “spiders,” or “offline readers,” that accesses the Web Sites/Applications in any manner. Notwithstanding the foregoing, the Company grants the operators of public search engines permission to use spiders to copy materials from the site for the sole purpose of and solely to the extent necessary for creating publicly available searchable indices of the materials, but not caches or archives of such materials. The Company reserves the right to revoke these exceptions either generally or in specific cases.
You agree not to collect or harvest any personally identifiable information, including user account names, from the Web Sites/Applications, nor to use the communication systems provided by the Company (e.g. comments, messaging, etc.) for any commercial solicitation purposes.
You will otherwise comply with the Terms and Conditions contained herein, and all applicable local, national, and international laws and regulations.
The Company reserves the right to discontinue any aspect of the Web Sites/Applications at any time.

LICENSE:

You agree by accessing, browsing or otherwise using the Web Sites/Applications and the Content are and remain the sole property of the Company or third-party providers, as applicable. Except as expressly permitted by the Company in writing, you agree that your license to access, browse and/or use this content is limited solely to a personal, revocable, nonexclusive, non-transferable license to (i) access and view the the Web Sites/Applications and the Content, and (ii) upload and store any Content for your non-commercial use (with the exception of any fiscal or monetary reward provided by the Web Sites/Applications and not for resale or distribution to anyone else. You also agree that, with respect to any copy of the Content that you are permitted to upload, download, store and/or record/print, you will reproduce and include all copyright and other proprietary notices included in such Content.
Unless otherwise provided in writing by the Company, no license provided herein authorizes you to copy, reproduce, modify, adapt, translate, distribute, transmit, download, upload, post, sell, rent, license, transfer, publicly perform, publicly display, mirror, frame, scrape, extract, wrap, create derivative works of, reverse engineer, use in a manner prohibited by applicable laws or regulations, decompile or disassemble any aspect of the Web Sites/Applications or any of the content, in whole or in part, in any form or by any means, whether manual or automatic.
It is a user’s responsibility to ensure that their participation and use of the Web Sites/Applications is lawful in their jurisdiction. Any user who is knowingly in breach of any sections of these Terms of Service, including sections 1, 2 or 3, or makes any attempt to circumvent this restriction, for example, by using a VPN, proxy or similar service that masks or manipulates the identification of your real location, or by otherwise providing false or misleading information regarding your location or place of residence, or by participating from an Excluded Territory or through a third party or on behalf of a third party located in an Excluded Territory, is in breach of these Terms of Use, which constitutes a potentially actionable contractual breach, among other things, and we further caution that you may be committing fraud and may be subject to criminal prosecution.

ADDITIONAL USER RESTRICTIONS:

In addition to the general restrictions above, the following restrictions and conditions apply specifically to your use of Content on the Web Sites/Applications.

The Content on the Web Sites/Applications, including without limitation, the Games, text, software, scripts, graphics, photos, sounds, music, videos, interactive features and the like, and the trademarks, service marks and logos contained therein, are owned by or licensed to the Company or one of its business partners, subject to copyright and other intellectual property rights under the law. Content on the Web Sites/Applications is provided to you AS IS for your information and personal use only and may not be downloaded, copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, or otherwise exploited for any other purposes whatsoever, unless provided for herein. The Company reserves all rights not expressly granted in and to the Company and the Content.
To the extent user comments are permitted, such comments are made available to you for your information and personal use solely as intended through the normal functionality of the Web Sites/Applications. User comments are made available “as is”, and may not be used, copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, downloaded, or otherwise exploited in any manner not intended by the normal functionality of the Web Sites/Applications or otherwise as prohibited herein.
You may access Content and other content only as permitted herein. The Company reserves all rights not expressly granted in and to the Content and the Web Sites/Applications.
You agree to not engage in the use, copying, or distribution of any of the Content other than expressly permitted herein, including any use, copying, or distribution of materials of third parties obtained through the Web Sites/Applications for any commercial purposes.
You agree not to circumvent, disable or otherwise interfere with security-related features of the Web Sites/Applications or features that prevent or restrict use or copying of any Content or enforce limitations on use of the Web Sites/Applications or the Content therein.
You understand that when using the Web Sites/Applications, you may be exposed to content from a variety of sources, and that the Company is not responsible for the accuracy, usefulness, safety, or intellectual property rights of or relating to such Third-Party content.
You further understand and acknowledge that you may be exposed to third party content that is inaccurate, offensive, indecent, or objectionable, and you agree to waive, and hereby do waive, any legal or equitable rights or remedies you have or may have against the Company with respect thereto, and agree to indemnify and hold the Company, and/or licensors, harmless to the fullest extent allowed by law regarding all matters arising from your use of the site.

APPLE DISCLAIMERS: Users acknowledge and agree that this Agreement is solely between you and the Company only, and not with Apple, Inc. (“Apple”). Users further acknowledge and agree that, with respect to the iOS version of the Web Sites/Applications:

Apple and its subsidiaries are Third-Party beneficiaries under this Agreement and that, upon your acceptance of this Agreement, Apple will have the right (and will be deemed to have accepted the right) to enforce the terms and conditions of this Agreement against you as a third-party beneficiary thereof.
Apple has no responsibility for the Web Sites/Applications or any included Content.
In the event of any failure of the Web Sites/Applications to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the Web Sites/Applications to you (if any). To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the Web Sites/Applications, and any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty.
Apple is not responsible for addressing any of your claims or those of any third-party relating to the Web Sites/Applications or your possession and/or use of the Web Sites/Applications, including, without limitation: (i) maintenance and support; (ii) product liability claims; (iii) any claim that the Web Sites/Applications failed to conform to any applicable legal or regulatory requirement; and (iv) claims arising under consumer protection or similar legislation.
In the event of any Third-Party claim that the Web Sites/Applications or your possession and use of the Web Sites/Applications infringes that third-party’s intellectual property rights, Apple will not have any responsibility for the investigation, defense, settlement, and discharge of such claim.

GOOGLE DISCLAIMERS: Users acknowledge and agree that this Agreement is solely between you and the Company only, and not with Google, Inc. (“Google”) Users further acknowledge and agree that, with respect to the Android version of the Web Sites/Applications:

Google and its subsidiaries are Third-Party beneficiaries under this Agreement and that, upon your acceptance of this Agreement, Google will have the right (and will be deemed to have accepted the right) to enforce the terms and conditions of this Agreement against you as a third-party beneficiary thereof.
Google has no responsibility for the Web Sites/Applications or any included Content.
In the event of any failure of the Web Sites/Applications to conform to any applicable warranty, you may notify Google, and Google will refund the purchase price for the Web Sites/Applications to you (if any). To the maximum extent permitted by applicable law, Google will have no other warranty obligation whatsoever with respect to the Web Sites/Applications, and any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty.
Google is not responsible for addressing any of your claims or those of any third-party relating to the Web Sites/Applications or your possession and/or use of the Web Sites/Applications, including, without limitation: (i) maintenance and support; (ii) product liability claims; (iii) any claim that the Web Sites/Applications failed to conform to any applicable legal or regulatory requirement; and (iv) claims arising under consumer protection or similar legislation.
In the event of any Third-Party claim that the Web Sites/Applications or your possession and use of the Web Sites/Applications infringes that third-party’s intellectual property rights, Google will not have any responsibility for the investigation, defense, settlement, and discharge of such claim.
Your use of the Web Sites/Applications must comply with Google’s then-current Android Market Terms of Service.

THIRD-PARTY WEBSITES, LINKS AND GAMES:

The Web Sites/Applications may contain links to Third Party Websites that are not owned or controlled by the Company. The Company has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any Third-Party Websites. In addition, the Company will not and cannot censor or edit the content of any Third-Party Website. By using the Web Sites/Applications, you expressly relieve the Company from any and all liability arising from your use of any Third-Party Website.
You additionally acknowledge that some of the Third-Party Websites accessible through the Web Sites/Applications may be fraudulent in nature in an effort to reveal personal information such as passwords, account information, and credit card information. These fraudulent sites may offer the chance to win or purchase virtual currency allegedly used by the Web Sites/Applications, such as Gold Coins, at lower prices. You agree that the Company will not be liable for any actions you take at the request of these Third-Party Websites. THE COMPANY IS THE ONLY ENTITY AUTHORIZED TO OFFER VIRTUAL CURRENCY FOR USE ON OR THROUGH THE WEB SITES/APPLICATIONS, INCLUDING GOLD COINS AND SWEEPS COINS. NO OTHER THIRD-PARTY ENTITY IS AUTHORIZED TO DO SO. Any such offer shall be deemed fraudulent and no virtual currency obtained through such methods will be honored by the Company.
All third party websites are bound by their own Terms and Conditions outlined by that third party.
Games displaying a third party identification are solely and exclusively owned by that third party, including all intellectual property rights in or to the online software relating to such third party game.
You will not have any recourse against listed suppliers of games or any member of their respective company groups in relation to any of their respective Games and any recourse you may have in connection with the software connected to any of their respective Games is limited to the Company.

USER ACCOUNT:

In order to access some features of the Web Sites/Applications, you may have to create a User Account either directly or through one of the Company’s third party providers or external sites (e.g. Facebook, Inc.), which may also work with the Web Sites/Applications. You agree never to use another’s User Account without permission. When creating your User Account, you must provide accurate and complete information. If you wish to update your address, email, phone number, or other contact information, you may contact customer support at the email below. The name you provide when registering your User Account must match that on your government-issued ID. If you provide any information that is untrue, inaccurate, not current, or incomplete, or the Company has reasonable grounds to suspect that such information is untrue, inaccurate, not current, or incomplete, the Company reserves the right to suspend or terminate your User Account immediately and refuse any and all current or future use of the Web Sites/Applications, and declare any Prizes or Virtual Currency won invalid.
If your User Account is created via your Facebook account, you are allowing the Company to access your Facebook account information. If you access the Web Sites/Applications from Facebook, you shall comply with the terms of service of Facebook as well as these Terms.
You are solely responsible for the activity that occurs on your User Account, and you must keep your password secure. You must notify the Company immediately of any breach of security or unauthorized use of your User Account. Although the Company is not liable for any of your losses caused by any unauthorized use of your User Account, you shall be liable for those losses due to such unauthorized use.
Any information collected by the Company, including through the Web Sites/Applications or other means will be held subject to our Privacy Policy.
SINGLE ACCOUNT: You are allowed to register one (1) User Account, including any Inactive Accounts you may have, on the Platform. Should you attempt to open more than one (1) User Account, all open User Accounts in your name will be immediately suspended or closed. This includes the use of representatives, relatives, associates, affiliates, related parties, connected persons, and/or third parties operating on your behalf. You must notify the Company if you believe you have more than one User Account, whether they are all active or not.
Suspected Fraud and/or Abuse will result in your User Account being closed and your winnings will be removed, solely at the discretion of the Company. The Company reserves the right to cancel any bonuses, and may remove any winnings or Virtual Currency from your User Account if there is suspicion of fraud or abuse. Fraud or abuse includes, but is not limited to:

Delaying game rounds in any game, including free spins and bonus features, to a later time when you have no playing requirements;
Leaving large sums of Virtual Currency on the table and returning to the game after bonus play has been completed;
Playing games with bonus Virtual Currency to build up in-game value, lose the bonus Virtual Currency, and then redeem on the built-up value if in Sweeps Play; and
Using strategies that take advantage of any software bug or failure.

USER IDS AND PASSWORDS:

Access to certain areas of the Web Sites/Applications or the Content are limited by a user identifier (“User ID”) and password, which is selected and/or supplied as part of the registering process for a User Account with the Web Sites/Applications. By registering, you represent, warrant and covenant that:

You are of lawful age in your jurisdiction to access the Web Sites/Applications and Content, but in no case under 18 years of age;
You are using your actual identity;
You have provided only true, accurate, current, and complete information about yourself during the registration process; and
You will maintain and promptly update the information that you provide to keep it true, accurate, current and complete.

User ID’s on the Web Sites/Applications may not include: (i) References to breaking the law, including terrorism and child exploitation (ii) violence and/or threats (iii) hateful conduct (iv) harassment and sexual harassment (v) unauthorized sharing of private information (vi) impersonation (vii) glorification of natural or violent tragedies (viii) self-destructive behavior (ix) references to recreational drugs, hard drugs, and drug abuse, with exceptions for alcohol, tobacco, and marijuana (x) references to gaming addiction and gambling addition (xi) references to sexual acts, genitalia, or sexual fluids. Indefinite suspensions will be issued, at our sole discretion, for User ID’s that violate these Terms.
By logging onto the Web Sites/Applications using any password, you represent, warrant, and covenant that you are authorized to use such password and to engage in the activities that you conduct thereunder. You agree that you will be solely responsible for the maintenance and security of your User ID and password. You also agree that you will be solely responsible for any activities conducted on or through the Web Sites/Applications that occur through your User Account or with your User ID. Your User ID and password are unique to you, and you agree not to disclose or share your User ID and password with any other person or third-party.
In addition, you agree that you are entirely responsible for any and all activities which occur under your User Account or with your User ID whether or not you are the individual who undertakes such activities. This includes any unauthorized access and/or use of your User Account should you fail to sufficiently disconnect and/or log off the Web Sites/Applications and/or a public computer system. Accordingly, you absolve and release the Company from any claim of harm resulting from a third party undertaking the activities.
The Company reserves the right to deny or revoke access to the Web Sites/Applications, or any part thereof, at any time in our sole discretion, with or without cause. If we close your User Account pursuant to clause Section 25 of these Terms of Use, the consequences set out in section 25 shall apply. If we close your User Account for other reasons, we will make reasonable efforts to enable you to redeem any Prizes in your User Account, but any license to continued use, enjoyment or benefit of or from the Virtual Currency, including Gold Coins, and/or Sweeps Coins, will be terminated.
You may not transfer any Virtual Currency offered by the Company or obtained through the Web Sites/Applications, including the Gold Coins and Sweeps Coins between User Accounts, or from your User Account to that of another User or any other third party. Further, you may not receive any such Virtual Currency from other Users into your User Account. You may not offer any Virtual Currency to any other party. Any attempt to circumvent these prohibitions may be grounds for termination of your User Account, without prejudice to any other rights or remedies available to the Company.
The Company reserves the right to close, deactivate, or terminate your User Account if it deems, at its sole discretion, the User Account to be Dormant. A User Account will be deemed Dormant if there has been no login activity to the User Account for a period of sixty (60) consecutive days. Users will be sent warnings by the customer service team as a User nears the end of the sixty (60) day period of no login activity. If an account becomes Dormant, the Company will remit the balance of the redeemed value of Prizes in your User Account to you as may be required under applicable law.
In the event you wish to close your User Account, you may do so at any time by contacting customer support at the email below and submitting a request to do so. By closing your User Account, you agree to forfeit all continued access to and right to use, enjoy or benefit from any Virtual Currency or potential unredeemed prizes associated with your User Account. A closed User Account may be reopened by contacting support at the email below and requesting re-activation of your User Account. The Company will evaluate all such requests and re-open accounts at its sole discretion.

SITE MONITORING:

The Company may monitor or review any areas on the Web Sites/Applications where users upload Content, transmit or post Content or communicate with each other, or the like. However, the Company does not undertake to monitor or review every posting or communication, and disclaims any liability related to the content of any such postings and communications, whether or not arising under the laws of copyright, trademarks, libel, privacy, obscenity, offensive speech or otherwise. Any instances of posts or communications which violate these Terms are subject to indefinite suspension at our sole discretion.
While we may monitor the content of the communications from time to time, the Company does not endorse, support, sanction, encourage, verify, or necessarily agree with the comments, opinions, or statements posted. Any information or material placed online are solely the views and responsibility of those posting such statements, and do not necessarily represent the views of the Company.
The Company, in its sole discretion, reserves all rights to discontinue this service generally or to any user at any time.
The Company may disclose any records, electronic communications, information, materials, or other content of any kind (i) if the Company believes in good faith that the law or legal process requires it; (ii) if such disclosure is necessary or appropriate to operate the Web Sites/Applications; or (iii) to protect our rights or property or the rights or property of our users and business partners.

PUBLICITY, SUBMISSIONS AND MARKETING COMMUNICATIONS:

Except where prohibited by law, accessing and engaging the Web Sites/Applications constitutes each User’s consent to the Company’s and its agent’s use of Users’ name, likeness, photograph, voice, opinions and/or hometown and state/province/territory for promotional purposes in any media, worldwide, without further payments, notice or consideration.
A Submission to the Company or a post to any of its social media pages constitutes User’s consent to give the Company a royalty-free, irrevocable, perpetual, non-exclusive license to use such submission or post on a worldwide basis, and to incorporate it into other works, in any form, media or technology not known or later developed, including for promotional or marketing purposes. If requested, User will sign any documentation that may be required for the Company or its designees to make use of the non-exclusive rights User is granting to use the submission or post.
You consent to receive marketing communications from the Company in respect of its offerings by way of email, post, SMS and telephone notifications, any of which you may unsubscribe from at any time by contacting Customer Support.

LIVE CHAT SERVICES:

We may provide you with a Live Chat service to talk to our Customer Support representatives, or to talk to other Users. This may include use of our Facebook wall. It is your responsibility to use these services only for their intended purposes. You are not permitted to use our Live Chat services for illegal purposes.
Be careful what you post on any Live Chat service. We review and moderate chats and keep a log and record of statements. Your use of the Live Chat service should be for recreational and social purposes only.
Spamming on Live Chat is prohibited. You are prohibited from intimidating, harassing or abusing other Users or the Company employees and representatives.
You will not use any Live Chat service to engage in any form of harassment or offensive behavior, including but not limited to, threatening, derogatory, abusive or defamatory statements, or racist, sexually explicit, pornographic, obscene, or offensive language.
You will not use any Live Chat service to infringe the privacy rights, property rights, or any other rights of any person.
You will not submit any kind of material or information on any Live Chat service that is fraudulent or otherwise unlawful or violates any law.
You will not use any Live Chat service to distribute, promote or otherwise publish any material containing any solicitation for funds, advertising or solicitation for goods or services of other forums.
You will not use any Live Chat service to distribute, promote or otherwise publish any kind of malicious code or do anything else that might cause harm to the Platform or to other User’s systems in any way.
We reserve the right to monitor anything and everything submitted by you to any Live Chat service to ensure that it conforms to content guidelines that are monitored by us and subject to change from time to time.
If you breach any of the provisions relating to a Live Chat service, we may ban you from using that Live Chat service or all Live Chat services and/or suspend or close your User Account. If we close your User Account, we reserve the right to cancel or refuse to redeem any Prizes.
We reserve the right to remove any Live Chat service from the Platform if abused.
You agree to indemnify us against any damage arising out of your illegal, unlawful or inappropriate conduct or arising out of violation of the provisions of these Terms or any other rules on the Platform applying to the Live Chat service.
You will not collude in any way through the Live Chat service. Users are encouraged to report any suspicious behavior to Customer Support.

PATENTS PENDING:

The Company’s novel methodologies, technological improvements, and overall business methods (collectively “Patentable Subject Matter”) may be the subjects of pending patent application(s) in the United States and worldwide.

COPYRIGHTS:

The Web Sites/Applications and the Content contained and referenced therein are subject to copyrights owned by the Company and is for your informational and entertainment purposes only. Any reproduction, retransmission or other use is strictly prohibited, except as otherwise provided herein or in writing by the Company. Requests for permission to reproduce any of the prohibited Content should be addressed by writing to the Company at the email address below.

TRADEMARKS:

All trademarks, service marks, titles, domain names, logos, and company names (collectively ” Trademarks”) referred to on the Web Sites/Applications are trademarks, registered trademarks, service marks, domain names, logos, company names of or are otherwise the property of the Company or its affiliates or licensors. In countries where any of the Company’s trademarks, service marks, domain names, logos and company names are not registered, the Company claims other rights associated with unregistered trademarks, service marks, domain names, logos, and company names. Other product or company names referred to on the Web Sites/Applications may be trademarks of their respective owners.
The Company does not grant to you any rights under any of the Trademarks, and you agree that you may not use any of the Trademarks without permission from the owner of such Other Trademarks. With respect to the Other Trademarks owned by the Company, you may contact us by sending a letter to us at the email address below to request written permission to use the trademarks for purposes other than stated herein or for all other questions relating to the Web Sites/Applications.

OTHER INTELLECTUAL PROPERTY RIGHTS:

All right, title and interest in and to the Content, including without limitation the graphical display and arrangement of the Web Sites/Applications and the Content, and all intellectual property rights embodied therein, are the property of the Company or its licensors, suppliers or affiliates.
Without limiting the foregoing, with respect to the databases (“Databases”) used to store the Content, you agree and acknowledge that:

the Content, Databases and any other information contained therein shall remain valuable intellectual property owned by, or licensed to the Company, and that no proprietary rights are being transferred to you in such materials or in any of the Content contained therein;
You shall not, directly or indirectly, use any of the Content, Databases and any other information contained therein for any purposes other than your personal, non-commercial use;
You shall not, directly or indirectly, use the Content, Databases and any other information contained therein to compete directly or indirectly with the Company;
You shall not, directly or indirectly, use the Content, Databases and any other information contained therein to establish independent data files or otherwise amass statistical information thereof or therefrom.
You shall not, directly or indirectly, use the Content, Databases and any other information contained therein in violation of any applicable laws or regulations,
Misappropriation or misuse of the Content, Databases and any other information contained therein will cause serious irreparable damage to the Company and that in such event money damages may not constitute sufficient compensation to the Company; consequently; and
In the event of any misappropriation or misuse, the Company shall have the right to obtain injunctive relief in addition to any other legal or financial remedies to which the Company may be entitled.

In addition, you acknowledge that the Content, Databases and any other information contained therein are protected by law, including, but not limited to, United States and international copyright law and trademark law, as well as other state, federal, and international laws and regulations, including contract law, and laws pertaining to privacy and publicity.

NOTICE AND PROCEDURE FOR MAKING CLAIMS OF COPYRIGHT INFRINGEMENT:

The Company may, in appropriate circumstances and at its discretion, disable and/or terminate the accounts of users who infringe the intellectual property of others. If you believe that your copyright or the copyright of a person on whose behalf you are authorized to act has been infringed, please provide our Copyright Agent a written Notice containing the following information:

An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright or other intellectual property interest;
A description of the copyrighted work or other intellectual property that you claim has been infringed;
A description of where the material that you claim is infringing is located on the Service (e.g., web page link);
Your address, telephone number, and email address;
A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and
A statement by you, made under penalty of perjury, that the above information in your Notice is accurate and that you are the copyright or intellectual property owner or authorized to act on the copyright or intellectual property owner’s behalf.
Our Copyright Agent can be reached by mail to our contact address provided below, with attention to “Legal” or by sending an email to: support@exclusivegaming.net

NOTICE OF ENFORCEMENT:

The Company vigorously enforces its intellectual property rights to the fullest extent of the law. Accordingly, the Company may prosecute any unauthorized use or reproduction of any of the Content, Databases and any other information contained therein that violate the protection afforded by the United States and international copyright law and trademark law, and/or other state, federal, and international laws and regulations, including laws pertaining to contracts, and privacy and publicity.

GAMES:

All Games available to play on both the Social Games platform, which uses Virtual Currency such as Gold Coins, and the Promotional Games platform, which uses Sweeps Coins to provides Sweeps Play, possess their own rules and odds of winning. The individual rules and odds for each Game will be available to Users in the pay tables once the Game has been launched. It is the User’s responsibility to read the rules ahead of playing and familiarize themselves with all terms of play prior to playing each Game.
The Company reserves the right to declare any one play, spin, or other form of participation in a Game void, either partially or in full, if there is an error, mistake, misprint, or technical error on the pay table, win table, minimum or maximum stakes, odds, or software.
In the event of a difference or discrepancy between the result showing on a User’s screen and the result showing on the Web Sites/Applications software server, the result showing on the Web Sites/Applications software server shall be the governing result.
Sports Prediction Games – Should the Company offer Users the chance to play sports prediction games using one or multiple virtual currencies, then the following rules apply:

Customer cannot cancel picks once they are submitted.
For over/under picks, game overtime is included in the final score (unless otherwise specified in the app or sport-specific rules).
For half-time line picks, overtime is included as a part of the second half (unless otherwise specified in the app or sport-specific rules).
All minimums, maximums, and payout odds are subject to change without prior written notice.
Regarding suspended games, protest games, or overturned decisions, we follow Las Vegas gaming rules for picking purposes. Otherwise, we does not recognize suspended games, protests and overturned decisions for prediction purposes.
All sporting events must be played on the scheduled date, unless otherwise specified. If an event is postponed and/or rescheduled or there’s a change of venue, the event will automatically constitute ‘no action’, which means all virtual funds for that event will be refunded (unless sport-specific rules state otherwise). All parlays will be recalculated excluding that selection of the parlay (e.g. a 3-team parlay becomes a 2-team parlay). Individual tennis matches have no action if the match is not fully completed due to withdrawal/incapacity or disqualification. Note – This rule does not apply to Single Game Parlays (see General Rule #20).
All payouts are calculated on the odds in effect at the time of submitting the pick.
In the case of an obvious error on the posted line, scheduled time, or maximum Risk amount, any picks will be deemed ‘no action’, and all virtual funds will be credited or refunded accordingly. ‘Obvious error’ will be at our direction, supported by differences in market odds at the time the pick was submitted.
In the event of a settlement error or in-game score or stat correction, all picks will be corrected to the proper outcome. These corrections may result in a change to customer virtual funds balances, up to 7 days after the completion of the event.
Dates and start time of events shown are for guidance purposes only. Picks will be accepted up to the advertised start time. For any reason a pick is inadvertently accepted after an event or match has started, the selection(s) affected will be made void.
Game scores and times of in-play events are shown for display purposes only. We do not guarantee their accuracy and recommend checking with other sources instead of using them to inform decisions on placing picks. Picks will not be voided or refunded due to discrepancies or inconsistencies in the score display.
All futures picks are accepted as All In, Run or Not Run, Entered or Not Entered. Stakes are lost on a future pick if a selection does not take part. In the event of a tie where 3 or more competitors are offered in one prediction option, the payout will be divided by the number of players/competitors tied.
Overtime, quarters or extra innings are counted in the final score when making predictions on totals, moneyline and point spread unless otherwise specified, and with the exception of soccer lines including a price for a draw.
On half time picks, overtime is included as part of the second half.
All period and quarter picks placed are for that specific period or quarter only. All overtime picks placed will be for the full overtime, regardless of how many overtimes.
Other sports: All other contests that involve a scheduled length of play time or time limit must be played to their conclusion or have five minutes or less of scheduled playing time remaining when the contest concludes to be considered official for sports prediction purposes.
Straight pick is a single selection on a single event that carries a point spread, a total or a money line (or other market sides).
Parlay pick is a single prediction that links together two or more selections and is dependent on all of those selections winning together. In the event that one of these selections is a PUSH or NO ACTION, the Parlay will be settled at reduced odds based on the outcomes of the other selections (e.g. a 3-selection parlay becomes a 2-selection parlay).
Single Game Parlay is combination of selections within the same event. In the event that one of these selections is a PUSH or NO ACTION, the entire Single Game Parlay will result in a PUSH, regardless of whether the other selections win or lose.

Live Dealer Games – Should the Company offer Users the chance to play various casino games in a live dealer setting using one or multiple virtual currencies, then the following rules apply:

These Live Dealer Games involve events via the Web Sites/Applications where Users will be Playing against the house with other Users at the same time. The Live Dealer Games include favorites such as Roulette, Baccarat, Blackjack, Dragon Tiger, Casino Hold’em, Andar Bahar, Limitless Blackjack, Teen Patti and more. The Company reserves the right to add or remove Live Dealer Games as it sees fit. Individual Live Dealer Game rules and pay-outs will be available to the Users in the individual Live Dealer Game pay tables while playing the individual Live Dealer Game. It is the User’s responsibility to thoroughly review the rules of each Live Dealer Game.
Please note that the Company cannot control certain actions of those Users, who may be for example undertaking fraudulent activities such as colluding with other third parties or using unfair external factors or influences.
If you suspect a third party is colluding, cheating or undertaking a fraudulent activity, please let the Company know as soon as possible and provide as much information as possible such as Game Round ID, screenshots, video or any other identifying information such as action taken by the User, seat position or any other information related to the fraudulent claim.
The Company will take reasonable steps to prevent such unacceptable behavior, however, the Company will not be liable for any loss or damage which you may incur as a result of such third party collusion, fraud, cheating, or otherwise illegal activity. Users may leave a Live Dealer Game table at any time at their own discretion. Should the User elect to leave the table after playing their hand and after the play time locks, the results of the round will still reflect in the User’s Wallets.
Please note that in the case of Live Dealer games, you may not at any time be able to see or otherwise be provided with the most up-to-date information in relation to the Live Dealer Game, including for example (but without limitation), through delayed coverage, a slow internet connection or equipment, or other system flaws, faults, errors or service interruption. The Company shall not be liable for any delay in relaying up-to-date information related to the Live Dealer Game.
Interactions with Live Dealer: Users will be able to interact and directly communicate with the dealer while playing a Live Dealer Game. It is the User’s responsibility to act in an appropriate, friendly, and professional manner. Users may not belittle, attack, threaten, harass, insult or otherwise argue with the dealer or other Users. Any User found to have violated this term or be reported to the Company by the Live Dealer Game operator may be subject to account suspension, termination or a permanent ban from the Company.

VIRTUAL CURRENCY:

The Company may permit a Virtual Currency to be used for accessing and playing its Content and/or Games (“Virtual Currency”) through the Web Sites/Applications. Two (2) types of Virtual Currency will be available to Users on the Web Sites/Applications: Gold Coins (“GC”), which can only be used to play in casino-style games for entertainment purposes through the Social Games platform offered by the Web Sites/Applications; and Sweeps Coins (“SC”), which can only be used to play sweepstakes games or Sweeps Play on the Promotional Games platform offered by the Web Sites/Applications to promote the Company and the Social Games platform.
GC are used to play games in standard social gameplay on the Social Games platform. A User’s GC and GC balances are not transferable between the Social Game platform and the Promotional Game platform offering Sweeps Play platforms. GC are used to play games in standard social gameplay on the Social Games platform. GC have no real money value, are not redeemable for any government-issued currency, and are only intended to for Users playing games in the Web Sites/Applications including only the Social Game platform. GC may be obtained for free in various ways such as a daily bonus, a free allotment every 24 hours, by winning in the Social Games platform, by clicking Top Up in User’s Wallet when balance is lower than a preset amount, or other methods the Company may from time to time establish. GC may also be purchased from the Company through the Web Sites/Applications by using valid government-issued currency. By purchasing GC, you agree (1) such acquisition is valid and legal in your jurisdiction, and (2) once purchased, GC are not redeemable for any government-issued currency that is, such GC should be treated as a “good” or a license thereto, purchased as-is, with no returnable or redeemable value except within the entertaining Content provided by the Web Sites/Applications, or as otherwise expressly indicated by the Company.
GC have no real money value, are not redeemable for any government-issued currency, and are only intended to for Users playing games in the Web Sites/Applications including both the Social Game platform and the Promotional Games platform. GC may be obtained for free in various ways such as a daily bonus, a free allotment every 24 hours, by winning spins in the Social Games platform, by clicking Top Up in User’s Wallet when balance is lower than 1000 GC or other preset amount, or other methods the Company may from time to time establish. GC may also be purchased from the Company through the Web Sites/Applications by using valid government-issued currency. By purchasing GC, you agree (1) such acquisition is valid and legal in your jurisdiction, and (2) once purchased, XC are not redeemable for any government-issued currency that is, such XC should be treated as a “good” purchased as-is, with no returnable or redeemable value except within the entertaining Content provided by the Web Sites/Applications, or as otherwise expressly indicated by the Company.
SC are only available when Users elect to play games in Sweeps Play on the Promotional Games platform. SC are not available for purchase like GC are. SC may be obtained in a number of ways such as a daily allowance provided upon login, as a bonus to purchasing GC, or by submitting a Request Card pursuant to the Company’s Sweepstakes Rules, or other methods the Company may from time to time establish. See the Company’s Official Sweepstakes Rules for more information on how to collect, use, and redeem SC. NO PURCHASE IS NECESSARY TO OBTAIN SC.
It is the User’s responsibility to ensure each single play, round or spin using an amount virtual currency through the Web Sites/Applications reflects the amount of virtual currency a User actually intends to play. Unless otherwise contemplated in these Terms, the Company will not be responsible for a User’s negligence in playing a greater amount of virtual currency than they intended. This applies to all Games, including Live Dealer Games where a User may split their hand or double their play amount, the User must have the proper Virtual Currency balance available in order to do so.

PURCHASING VIRTUAL CURRENCY:

The payment instrument you use to purchase GC must be legally and beneficially owned by you and must be in your name. Should the Company learn that the name used to register your User Account is different from the name associated with your payment instrument, your User Account will be immediately suspended. In the event this happens to you, you must contact Customer Support at the email below to resolve the issue.
If one or more of your purchases is subject to a charge back request, your User Account will be suspended. In the event of any charge back on your User Account, the amount of the charge back will be a debt owed by you to us, and you must immediately submit payment for such purchases through an alternative payment instrument.
The Company reserves the right to request documents and information to verify your identity and the legal and beneficial ownership of the payment instrument you use to purchase GC.
You further agree that the Company, its Payment Administration Agent(s), and payment facilitators may store and keep your payment information (i.e. card number or token) on file to process any future purchases you may make. By accepting and agreeing to these Terms of Use, you authorize the Company, its Payment Administration Agent(s) and payment facilitators to store and keep your payment credentials in compliance with applicable payment processing regulations.
Except as provided by the Company, transfer or sale of Virtual Currency is strictly prohibited between users of the Web Sites/Applications for any government-backed currency value or otherwise.
All sales of Virtual Currency are final, unless at the Company’s sole and exclusive discretion a refund is deemed necessary for any reason suitable for the Company. Upon termination or suspension of your User Account, all Virtual Currency remaining in your account may be forfeited at the Company’s sole and exclusive discretion. The purchase of GC constitutes the purchase of a good as described above and a limited license that allows you to participate in Social Games offered by the Web Sites/Applications and is not the deposit of funds that may be withdrawn from at any point.
All uses of GC and SC that have been submitted for play and accepted are final and cannot be changed, withdrawn or canceled.
All Virtual Currency purchases shall be executed in USD or other currency designated by the Company and it is a User’s responsibility to ensure and confirm that their nominated bank account can accept and process transactions in USD or the Company-designated currency.
Users will be responsible for all foreign exchange transaction fees, charges, or other related costs they may incur in relation to payments made by the Company, including but not limited to any losses or costs arising from foreign exchange fluctuations.

VIRTUAL CURRENCY BALANCES:

Users may only participate in any Game if they possess the sufficient number of GC or SC (depending on mode of play) in their User Account to be eligible to participate. Under no circumstance will the Company extend a User any credit for the purchase of GC.
Once a User makes a GC Purchase, the funds will be drawn from the Users elected payment instrument as soon as practicable and the purchased GC and any ancillary gifted SC if they are included in the purchased GC package, will be added to the User’s Virtual Currency Wallets.
Users Virtual Currency balances will be displayed in their Virtual Currency Wallets (“VCW”). Each User will have two VCW’s on the Web Sites/Applications: On the Social Games platform, each User will have (1) a GC Wallet and (2) SC Wallet. Each User will also have two VCW’s on the Promotional Games platform: (1) a GC Wallet and (2) SC Wallet. On the Promotional Games platform, a User may click on their SC Wallet for a dropdown menu which will display their total SC balance, Redeemable SC balance, and Unplayed SC balance.
In the event a User runs out of GC and does not wish to purchase additional GC or wait for the next free allotment or bonus opportunity, a User will normally receive a preset replenishment amount of GC, either automatically or upon request. A User may also contact Customer Support to request more GC.
You agree that the Company has the absolute right to manage, regulate, control, modify and/or eliminate such Virtual Currencies as they see fit in their sole discretion, in any general or specific case, and that they will have no liability to you based on their exercise of such rights. You agree that you have no right or title in or to any such Virtual Currencies appearing or originating on the Web Sites/Applications.
The Company does not recognize any Virtual Currency transfers executed outside of the Web Sites/Applications or the purported sale, gift, or trade in the “real world” of anything related to the Web Sites/Applications. Accordingly, you may not sell Virtual Currency for “real world” money or otherwise exchange Virtual Currency for value outside of the Web Sites/Applications. Any attempt to do so is in violation of these Terms and will result in a ban from the Web Sites/Applications.

SWEEPS PLAY, BOOSTS AND PROMOTIONS:

All Promotions, including the Sweeps Play, Contests, Special Offers, and other Bonuses, are subject to these Terms of Use, the Official Sweepstakes Rules, and additional terms that may be published at the time of a Promotion. In the event of a conflict between these Terms of Use and the Official Sweepstakes Rules, Promotion-Specific Terms, Special-Offer Specific terms, the Official Sweepstakes Rules or Specific Terms will govern.
To access the Promotional Games platform offering Sweeps Play, a User must open the Social Games platform and click on the button next to their SC balance that says “Sweeps.” The User will then be redirected to the Promotional Games platform part of the Web Sites/Applications.
For more information regarding Sweeps Play, see the Official Sweepstakes Rules. The Company reserves the right, in its sole discretion, to withdraw or modify any such promotion (including their availability) without notice to you. If, in the reasonable opinion of the Company, we form the view that a User is abusing any promotion, to derive any advantage or gain for themselves or other User’s, including by way of Fraudulent Conduct, we may, at our sole discretion, withhold, deny or cancel any advantage, bonus, Prize, or award of SC as we see fit.
Should any prize or other item be delivered to a user, delivery shall be subject to the availability of such prize or item and the Company may determine the delivery method and the delivery address shall be the address used by the User to register the User Account. The Company is not responsible for any lost or damaged prize or item.

PAYMENT ADMINISTRATION AGENTS:

The Company in its sole discretion may appoint one or more Payment Administration Agent to accept payments, make payments, and facilitate the payment process from or to Users on behalf of the Web Sites/Applications.
Any Payment Administration Agent appointed by the Company will possess the same rights, power and privileges as the Company under these Terms of Use. Such appointed Payment Administration Agent will be entitled to exercise and enforce their rights, powers and privileges as the Company’s agent or in the Payment Administration Agent’s own name.
Under no circumstances will the Company be liable or responsible to any User for any loss, damage or other liability resulting or arising from the Payment Administration Agent’s negligence and/or acts which exceed the powers and authorities granted to it by the Company.

VERIFICATION CHECKS:

You acknowledge and agree that the Company shall be entitled to engage in any identification, credit or other verification checks as reasonably required or as required by applicable laws and regulations or by any regulatory authorities.
All requests for prize redemption will remain pending until all necessary verification checks have been completed to the sole satisfaction of the Company.
The Company may from time to time request certain information from you in order to properly complete a verification check, including but not limited to situations where cumulative or single prize redemption exceeds a cash value of $100 USD. This information might include, but is not limited to:

Photo Identification such as a Drivers License or State ID;
Proof of address: and/or
Proof of source of income such as a pay slip or bank statement.

In the event you fail to provide any documentation requested by the Company to help perform a verification check within thirty (30) days of the request, the Company is under no obligation to continue the verification process and may, in its sole discretion, close, restrict or suspend your User Account.
The Company may also use third-party service providers to assist in the identification and other verification checks using the information provided by Users.

CLOSURE OR SUSPENSION OF USER ACCOUNT:

Without limiting clause 8(e), we reserve the right, at our sole discretion, to suspend or close your User Account (notwithstanding any other provision contained in these Terms and Conditions) where we have reason to believe that you have engaged or are likely to engage in any of the following activities

you breached, or assisted another party to breach, any provision of these Terms of Use or the Official Sweepstakes Rules, or we have a reasonable ground to suspect such breach.
you have more than one User Account, including any Inactive Account, on any Platform.
the name registered on your User Account does not match the name on (i) your payment instrument used to make purchases of GC or (ii) the User Account to which you choose to redeem Prizes, or do not legally and beneficially own the payment instrument or User Account associated with your Prize Redemption.
your communication with us consists of harassment or offensive behavior, including (but not limited to) threatening, derogatory, abusive or defamatory statements, or racist, sexually explicit, pornographic, obscene or offensive language.
your User Account is deemed to be a Dormant Account under section 8(g).
you become bankrupt or insolvent.
you provide inaccurate, false, or misleading information.
your identity or source of wealth or source of funds (if requested) cannot be verified.
you attempt to use your User Account through a VPN, proxy or similar service that masks or manipulates the identification of your real location, or by otherwise providing false or misleading information regarding your citizenship, location or place of residence, or by playing Games using the Platform through a third party or on behalf of a third party.
you are not over 18 years of age or such higher minimum legal age of majority as stipulated in the jurisdiction of your residence.
you are located in an Excluded Territory or a jurisdiction where Participation is illegal.
you have allowed or permitted (whether intentionally or unintentionally) someone else to Participate using your User Account.
you have played in tandem with other User(s) as part of a club, group, etc., or played the Games in a coordinated manner with other User(s) involving the same (or materially the same) selections.
Where the Company and/or the Web Sites/Applications have received a “charge back”, claim or dispute and/or a “return” notification via your payment instrument.
you have failed our due diligence procedures, or are found to be colluding, cheating, money laundering or undertaking any kind of fraudulent activity.
It is determined by the Company that you have employed or made use of a system (including machines, computers, software or other automated systems such as bots) which give you an unfair advantage or automates your AMOE Sweepstakes Entries.
If the Company suspends or closes your User Account for any of the reasons referred to in this section 25 above, you will be liable for any and all claims, losses, liabilities, damages, costs and expenses incurred or suffered by the Company (together “Claims”) arising therefrom and you will indemnify and hold the Company harmless on demand for such Claim.
If we have reasonable grounds to believe that you have participated in any of the activities set out in this section 25 above then we reserve the right to withhold all or part of the balance or recover from your User Account any Prizes, the GC or SC that are attributable to any of the activities contemplated in this section 25. In such circumstances, your details may be passed on to any applicable regulatory authority, regulatory body or any other relevant external third parties.
The rights set out in section 25 are without prejudice to any other rights that we may have against you under these Terms of Use or otherwise. Any breach or suspected breach of the above-mentioned rules will result in the forfeiture of all prizes won.

DISCLAIMERS:

THE WEB SITES/APPLICATIONS AND THE CONTENT MAY INCLUDE TECHNICAL INACCURACIES AND/OR TYPOGRAPHICAL ERRORS. THE COMPANY MAY MAKE CHANGES OR IMPROVEMENTS AT ANY TIME WITHOUT NOTICE. THE WEB SITES/APPLICATIONS AND THE CONTENT ARE PROVIDED “AS IS” / “AS AVAILABLE” AND WITHOUT WARRANTIES OR CONDITIONS OF ANY KIND EITHER EXPRESSED OR IMPLIED. THE COMPANY DISCLAIMS, TO THE FULLEST EXTENT PERMITTED UNDER APPLICABLE LAW, ALL WARRANTIES AND CONDITIONS EXPRESSED OR IMPLIED, INCLUDING WITHOUT LIMITATION, WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT, AND ANY WARRANTIES CONCERNING THE AVAILABILITY, ACCURACY, RELIABILITY, COMPLETENESS, CURRENCY, QUALITY, PERFORMANCE OR SUITABILITY OF THIS SITE, THE CONTENT, OR ANY PRODUCTS, SERVICES OR RESULTS OBTAINED ON OR THROUGH THE WEB SITES/APPLICATIONS.
THE COMPANY DOES NOT REPRESENT OR WARRANT THE AVAILABILITY OF THE SITE, THAT THE WEB SITES/APPLICATIONS AND YOUR USE OF THE WEB SITES/APPLICATIONS WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THE WEB SITES/APPLICATIONS OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. THE COMPANY DOES NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OF OR THE RESULT OF THE USE OF THE WEB SITES/APPLICATIONS AND/OR THE CONTENT IN TERMS OF THEIR CORRECTNESS, ACCURACY, TIMELINESS, RELIABILITY, APPLICABILITY OR OTHERWISE. YOU (AND NOT THE COMPANY) ASSUME THE ENTIRE COST OF ALL NECESSARY SERVICING, REPAIR OR CORRECTION. THE ABOVE EXCLUSION MAY NOT APPLY TO YOU, TO THE EXTENT THAT APPLICABLE LAW MAY NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES. IN ADDITION TO THE FOREGOING, YOU AGREE THAT YOUR USE OF THE WEB SITES/APPLICATIONS AND THE CONTENT IS AT YOUR OWN SOLE RISK

LIMITATIONS ON LIABILITY:

THE COMPANY WILL NOT BE LIABLE FOR ANY DAMAGES OR INJURY, INCLUDING WITHOUT LIMITATION, DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES), CAUSED BY YOUR USE OF THE WEB SITES/APPLICATIONS AND THE CONTENT, INCLUDING BUT NOT LIMITED TO, ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OF TRANSMISSION, COMPUTER VIRUS, OR LINE FAILURE. THE COMPANY WILL NOT BE LIABLE FOR ANY DAMAGES OR INJURY, INCLUDING BUT NOT LIMITED TO, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, EXEMPLARY OR CONSEQUENTIAL DAMAGES (INCLUDING, BUT NOT LIMITED TO, LOST PROFITS AND DAMAGES THAT RESULT FROM INCONVENIENCE, DELAY, OR LOSS OF USE) THAT RESULT FROM THE USE OF, THE INABILITY TO USE, OR RELIANCE UPON, THE WEB SITES/APPLICATIONS AND THE CONTENT OR ANY PRODUCTS OR SERVICES OBTAINED ON OR THROUGH THE WEB SITES/APPLICATIONS, EVEN IF THERE IS NEGLIGENCE BY THE COMPANY OR BY ITS AUTHORIZED REPRESENTATIVE, OR AN AUTHORIZED REPRESENTATIVE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, OR ANY OF THE ABOVE. THE COMPANY’S TOTAL LIABILITY TO YOU FOR LOSSES, DAMAGES AND CAUSES OF ACTION WILL NOT BE GREATER THAN THE AMOUNT YOU PAID TO THE WEB SITES/APPLICATIONS, IF ANY, TO ACCESS THE WEB SITES/APPLICATIONS.
THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU TO THE EXTENT THAT APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR SUCH DAMAGES. THE ABOVE LIMITATIONS DO NOT RELEASE LIABILITY FOR INTENTIONAL MISCONDUCT, RECKLESSNESS, GROSS NEGLIGENCE, OR FRAUD.

INDEMNITY:

YOU AGREE TO INDEMNIFY, DEFEND AND HOLD HARMLESS THE COMPANY, THE COMPANY’S OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, CONTENT PROVIDERS, CUSTOMERS AND SUPPLIERS FROM AND AGAINST ANY AND ALL CLAIMS, PROCEEDINGS, DAMAGES, INJURIES, LIABILITIES, LOSSES, COSTS AND EXPENSES (INCLUDING REASONABLE ATTORNEYS’ FEES AND LITIGATION EXPENSES), RELATING TO OR ARISING FROM:

YOUR USE OF THE WEB SITES/APPLICATIONS AND ANY OF THE CONTENT, OR ANY PRODUCTS OR SERVICES OBTAINED ON OR THROUGH THE COMPANY;
ANY ARRANGEMENTS YOU MAKE BASED ON THE CONTENT OBTAINED ON OR THROUGH THE WEB SITES/APPLICATIONS;
ANY BREACH BY YOU OF THE TERMS CONTAINED HEREIN;
ANY ACTIVITY RELATED TO YOUR USER ACCOUNT (INCLUDING INFRINGEMENT OF THIRD PARTIES’ WORLDWIDE INTELLECTUAL PROPERTY RIGHTS OR NEGLIGENT OR WRONGFUL CONDUCT) BY YOU OR ANY OTHER PERSON ACCESSING THE WEB SITES/APPLICATIONS USING YOUR USER ACCOUNT;
ANY CIRCUMVENTION OR ATTEMPTED CIRCUMVENTION OR THESE TERMS OR ANY OTHER POLICY OF THE COMPANY; OR
ANY FRAUD COMMITTED WITH REGARD TO THE WEB SITES/APPLICATIONS.

The Company reserves the right, at your expense, to assume institute civil or criminal claims against you, report you to the relevant authorities, and to assume the exclusive defense and control of any matter for which you are required to indemnify the Company, and you agree to cooperate with the Company’s defense of these claims. The Company will use reasonable efforts to notify you of any such claim, action, or proceeding upon becoming aware of it. You agree that the provisions in this section will survive any termination of your User Account or the Web Sites/Applications.

RELEASE FOR FORCE MAJEURE:

You absolve and release the Company and our affiliates from any claim of harm resulting from any cause(s) over which we or they do not have direct control, including, but not limited to, failure of electronic or mechanical equipment or communication lines, telephone or other interconnect problems, computer viruses or other damaging code or data, unauthorized access, theft, operator errors, severe weather, earthquakes, natural disasters, strikes or other labor problems, pandemics, wars, or governmental restrictions.

TERM AND TERMINATION:

The Company reserves the right, at any time and for any reason, without notice to you, (i) to deny you access to the Web Sites/Applications and any of the Content; or (ii) to change, remove or discontinue any of the Content or services available on or through the Web Sites/Applications.
You may terminate this agreement at any time by providing prior notice to the Company and by destroying: (a) all of the Content obtained from the Web Sites/Applications, including, without limitation, permanently deleting all of the Content from any computer and/or media; (b) all related documentation and all copies and installations, if any. In addition, upon the Company’s request, you agree to certify in writing that all of the Content has been destroyed; and (c) permanently ceasing all use of the Web Sites/Applications. The warranty disclaimers, limitations and exclusions of liability, reservation and grant of property rights and other terms and conditions contained herein which by their nature are intended to survive will survive the termination or expiration of any license provided to you by the Company.

NOTICES:

Any legal notice, other document or communication required or permitted hereunder to the Company will be deemed to have been duly given only if in writing and delivered by certified U.S. mail, return receipt requested, postage prepaid, to the Company at the address below.
Notices to the Company shall be deemed delivered when actually received by the Company or its authorized representatives.
Any notice or other document or communication required or permitted hereunder to you will be sent to the e-mail address that you provide to the Company when you register a user account. Such notice will be deemed received by you the next business day after the email is sent. It is your responsibility to maintain an accurate, up-to-date e-mail address.
Should you elect to send or receive e-mail communications of any kind to or from the Company, you represent and warrant to the Company that your e-mail service has appropriate and adequate security systems necessary to prevent unauthorized access to outbound or inbound e-mail transmissions.
Any notices users provide to the Company that do not comply with this section shall have no legal effect.

COMPLIANCE WITH LAWS/CHOICE OF LAW:

Except as otherwise described, the Company is operated from within the United States of America and makes no representation that the Content are appropriate or available for use in other locations. If you use the Web Sites/Applications from other locations, you are responsible for compliance with applicable local laws including, without limitation, all export laws. Some of the Content may be subject to export controls imposed by the United States and may not be downloaded or otherwise exported or reexported: (a) into (or to a national or resident of) any country to which the U.S. has placed an embargo, including without limitation, Cuba, Iran, Iraq, Libya, North Korea, Syria, Russia or Yugoslavia; (b) to anyone in the US Treasury Department’s Specially Designated national list, or (c) to anyone on the US Commerce Department’s Table of Denial Orders. If you download or use the Content you represent and warrant that you are not located in, or under the control of, or a national or resident of any such country or on any such list.
Access, browsing and use of the Web Sites/Applications, the Content and the terms and conditions of the User Agreement are governed by U.S. federal law and/or the laws of Maryland, excluding any conflict of laws provisions that would refer to and apply the substantive laws of another jurisdiction.
Subject to the Dispute Resolution by Binding Arbitration Agreement Provision Below, these Terms of Use and the rights of the parties hereunder shall be governed and construed with the laws of Maryland, exclusive of conflict or choice of law rules. For the avoidance of doubt, the law of Maryland only governs the interpretation and enforcement of the Terms of Use. It does not displace any statutory claims or remedies that may exist under any state law.

DISPUTE RESOLUTION BY BINDING ARBITRATION AGREEMENT:

PLEASE READ THIS PROVISION CAREFULLY, BECAUSE IT REQUIRES YOU AND THE COMPANY TO ARBITRATE ALL PAST, PRESENT, AND FUTURE DISPUTES WITH THE COMPANY AND LIMITS THE MANNER IN WHICH YOU CAN SEEK RELIEF, SUBJECT TO THE TERMS AND OPT-OUT OPTION SET FORTH BELOW. THE OPTION TO OPT-OUT IS TIME-LIMITED AS YOU MUST OPT-OUT WITHIN 30 DAYS AND DESERVES YOUR IMMEDIATE ATTENTION. ARBITRATION PRECLUDES YOU FROM SUING IN COURT OR FROM HAVING A JURY TRIAL.
THESE PROVISIONS GENERALLY PRECLUDE YOU FROM BRINGING ANY CLASS, COLLECTIVE, OR REPRESENTATIVE ACTION AGAINST THE COMPANY. THEY ALSO PRECLUDE YOU FROM PARTICIPATING IN OR RECOVERING RELIEF UNDER ANY PAST, PENDING, OR FUTURE CLASS, COLLECTIVE, OR REPRESENTATIVE ACTION AGAINST THE COMPANY BY SOMEONE ELSE.
Scope of Arbitration Provision: Unless you opt out, you and the Company agree that any claim, controversy or dispute between you and the Company (the “parties”) arising out of or relating to your access to or use of any the Web Sites/Applications or to the Content will be resolved exclusively through final and binding arbitration, rather than in court or before a jury, regardless of whether such claim, controversy or dispute arose prior to, on, or subsequent to the date of your acceptance of these Terms of Use. This agreement to arbitrate (“Arbitration Agreement”) is intended to be broadly interpreted and, except as provided in the preceding sentence, includes any dispute, claim, or controversy between you and the Company arising out of or relating to any aspect of your relationship with the Company and/or the Web Sites/Applications or any conduct or failure to act on the part of the Company (including claims based on breach of contract, tort (for example, a negligence claim), violation of law or any claims based on any other theory) or any aspect of your access to or use of the Content.
Limitation on Period in which Claims May be Brought: YOU AND THE COMPANY AGREE THAT ANY CLAIMS, REGARDLESS OF FORM, ARISING OUT OF OR RELATING TO YOUR ACCESS TO OR USE OF ANY THE WEB SITES/APPLICATIONS OR TO THE CONTENT SHALL BE MADE BY FILING FOR ARBITRATION WITHIN ONE (1) YEAR FOLLOWING THE OCCURRENCE FIRST GIVING RISE TO THE CLAIM(S). If the provision in the previous sentence is held to be unenforceable, then any claim(s) against the Company must be made by filing for arbitration within the limitations period designated by the state or federal law underlying the claim(s). If any claim is not brought within the applicable period discussed above, it is permanently barred, and the parties cannot bring that claim in any manner or in any forum.
Costs of Arbitration: You agree to pay fifty percent (50%) of the filing, administrative and arbitrator fees associated with the arbitration, unless the arbitrator finds that either the substance of your claim or the relief sought was frivolous or brought for an improper purpose, in which case you agree to be responsible for and pay 100% of the costs. You will at all times be responsible for paying your own attorneys’ fees.
Arbitration Procedure: The provisions of this Section shall constitute your and the Company’s written agreement to arbitrate Disputes under the Arbitration Laws of the United States. You and the Company agree that the American Arbitration Association (“AAA”) will administer the arbitration under its Commercial Arbitration Rules and the Supplementary Procedures for Consumer Related Disputes in effect at the time arbitration is sought. Those rules are available at www.adr.org or by calling the American Arbitration Association at 1-800-778-7879. The parties acknowledge that these Terms of Use evidence a transaction involving interstate commerce. Notwithstanding any provision of the AAA Rules, any dispute over the formation, enforceability, validity or severability of any provision of this Section (“DISPUTE RESOLUTION BY BINDING ARBITRATION AGREEMENT”) shall be resolved by a court and not be a subject of the arbitration.
The arbitrator shall have no authority to amend or modify the terms of this Arbitration Agreement or to award punitive or exemplary damages, except as expressly authorized by law. The arbitration award may be enforced by judgment in any court of competent jurisdiction. Before, during, or after arbitration each party shall have the right, without awaiting the outcome of the arbitration, to seek interim injunctive relief from an appropriate court including but not limited to temporary restraining orders or preliminary injunctions. Seeking any such remedies shall not be deemed a waiver of either party’s right to compel arbitration.
The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve all disputes arising out of or relating to the interpretation, applicability, enforceability, or formation of these Terms, including, but not limited to any claim that all or any part of these Terms are void or voidable, or whether a claim is subject to arbitration. The arbitrator may award on an individual basis any relief that would be available pursuant to applicable law and will not have the power to award relief to, against or for the benefit of any person who is not a party to the proceeding. The arbitrator will make any award in writing but need not provide a statement of reasons unless requested by a party. The arbitrator’s decision shall be final and binding and may be entered as a judgment in any court of competent jurisdiction.
Prior to initiating arbitration, you must first send a written notice by certified mail to the Company at the contact address provided below. The arbitration notice must include the following at a minimum: (a) personal and/or account information sufficient enough to identify your user account, (b) a detailed description of your claim or dispute with the Company, and (c) the specific damages or other remedy or remedies that you are seeking. If your claim or dispute is not resolved with the Company within thirty days of the Company’s receipt of your arbitration notice that conforms with these requirements, then you may commence arbitration according to the requirements in these Terms.
Procedure to Opt Out of Arbitration Provision: WHETHER TO AGREE TO ARBITRATION IS AN IMPORTANT DECISION. IT IS YOUR DECISION TO MAKE AND YOU SHOULD NOT RELY SOLELY ON THE INFORMATION PROVIDED IN THESE TERMS OF USE, AS IT IS NOT INTENDED TO CONTAIN A COMPLETE EXPLANATION OF THE CONSEQUENCES OF ARBITRATION. YOU SHOULD TAKE REASONABLE STEPS TO CONDUCT FURTHER RESEARCH AND TO CONSULT WITH OTHERS (AT YOUR COST) REGARDING THE CONSEQUENCES OF YOUR DECISION.
If you do not agree to be subject to this arbitration agreement, you must opt out of this arbitration agreement within 30 days of entering this agreement, in the following specified manner: Send written notice via U.S. Mail, or by any nationally recognized delivery service (e.g., UPS, Federal Express, etc.) to Attn: Legal Department, to the email address provided below in the Contact section. You must send such Notice within thirty (30) days of your acceptance of these Terms of Use. You must include in it your name, address, and a clear statement that you do not wish to resolve disputes with the Company through arbitration. If you do not follow this procedure by your thirty (30) day deadline to do so, then you and the Company shall both be bound by the terms of this section entitled Dispute Resolution by Binding Arbitration Agreement.
Confidentiality: You and the Company shall maintain the confidential nature of the arbitration proceedings and the arbitration award, including the arbitration hearing, except as may be necessary to prepare for or conduct the arbitration hearing on the merits, or except as may be necessary in connection with a court application for a preliminary remedy, a judicial challenge to an award or its enforcement, or unless otherwise required by law or judicial decision.
If any portion of this section is determined by a court to be inapplicable or invalid, then the remainder shall still be given full force and effect.

WAIVER:

No delay or omission by the Company to exercise any right occurring upon any noncompliance on your part with respect to any of the terms and conditions contained herein will impair any such right or power or be construed to be a waiver thereof. Any waiver by the Company of any of the covenants, conditions or agreements to be performed by you will not be construed to be a waiver of any succeeding breach thereof or of any covenant, condition or agreement herein contained.

SEVERABILITY:

If any of the terms and conditions contained herein are adjudged invalid or unenforceable by a court of competent jurisdiction, the remaining portions will remain valid, enforceable, and in effect.

INDEPENDENT CONTRACTOR:

The Company is an independent contractor; nothing in this Agreement shall be construed to create a partnership, joint venture, or agency relationship between you and the Company.

TAXES:

The Company does not provide advice regarding legal and/or tax matters. Please contact your local legal and/or tax expert for information on how your play at the Web Sites/Applications may have such consequences. You are solely responsible for any taxes which apply to your use of the Web Sites/Applications.

CONTINUED USE DEEMED ACCEPTANCE:

The Company reserves the right, at its sole discretion, to change, alter, amend, add to, or otherwise modify its policies, including these Terms of Use, Sweepstakes Rules, Privacy Policy, Responsible Social Play Policy, and Legal Notices from time to time. Any amendments will be published on the Web Sites/Applications and such changes will be binding and effective immediately. After any such modification becomes effective, the Company will deem your continued use of the Web Sites/Applications or any of the Content to constitute your acceptance of and agreement to such modification. You agree it is your duty to read these Terms of Use and Legal Notices prior to using, accessing or browsing the Web Sites/Applications. Whenever we amend these Terms and Conditions in a way that would limit your current rights or which may be to your detriment, we will notify you upon your next visit to the Platform and you will be required to re-confirm your acceptance prior to playing any Games. If you do not agree to the amended Terms of Use, or other legal doc referenced above, you must stop using the Platform.

EMAIL ADDRESS AND CONTACT INFORMATION:

The Company may be reached by email at:
support@exclusivegaming.net
And/Or Customer Support at:
support@exclusivegaming.net
Our mailing address is:

145 West Ostend Street Suite# 600 Baltimore, MD 21230

CALIFORNIA NOTICE:

Under California Civil Code Section 1789.3, California consumers are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 N. Market Blvd., Suite N-112, Sacramento, California 95834, or by telephone at 1 (800) 952-5210.

ENTIRE AGREEMENT:

This constitutes the entire agreement between you and the Company with respect to your use of the Web Sites/Applications and the Content, and supersedes any and all prior understandings or agreements between you and the Company, whether written or oral. You acknowledge that, in providing you access to and use of the Web Sites/Applications and the Content, the Company has relied on your acceptance of this agreement.

Refund Policy

As a sweepstakes website, we do not offer refunds for entries or purchases. All transactions on our platform are considered final.

Responsible Social Gaming Policy

At Super Geeks LLC, we are committed to providing an enjoyable and responsible social gaming experience for all our users. Our Responsible Social Gaming Policy outlines our principles and guidelines to ensure a safe and fair environment:

Legal Compliance: We adhere strictly to all relevant laws and regulations governing social gaming, including but not limited to age restrictions and geographical limitations.

Player Protection: We prioritize the well-being of our players. We provide tools for self- exclusion and limits on spending to promote responsible gaming behavior.

Fair Play: We uphold fairness in all aspects of our games. Our systems are designed to ensure transparency and integrity, preventing any form of cheating or exploitation.

Privacy and Security: We protect our players’ personal information and gaming data with the highest standards of security and confidentiality.

Education and Awareness: We promote awareness of responsible gaming practices through educational materials and resources available to our players.

Support and Assistance: We provide access to support services for players who may need assistance with gaming-related issues.

Continuous Improvement: We regularly review and update our policies and procedures to adapt to evolving best practices and regulatory requirements.

By adhering to our Responsible Social Gaming Policy, we aim to foster a positive and enjoyable gaming experience while promoting responsible gaming behavior among our community of players.

If you or someone you know is struggling with gaming addiction, we encourage you to seek help and support.

Please consider contacting the following resources for assistance:

National Council on Problem Gambling (NCPG)

o Helpline: 1-800-522-4700
o Website: www.ncpgambling.org

Gamblers Anonymous

o Website: www.gamblersanonymous.org

Recognizing the signs of gaming addiction and seeking help early can make a significant difference. We are committed to providing a safe and enjoyable gaming environment, and encourage responsible gaming behavior at all times.

Date of Policy: July 30, 2024

KYC/AML Policy

BSA/AML/OFAC POLICY

Updated as of June 26, 2026

Internal AML Compliance Officer: Keith B.

Introduction

Objective

The primary goal of this BSA/AML/OFAC policy (referred to as the “AML policy” or “policy” herein) for Super Geeks LLC (the “Company”) is to establish a vigilant and responsive framework that proactively combats and mitigates the risks associated with money laundering and terrorist financing within the online gaming sector, and in particular, in connection with the operation of social gaming service via www.exclusivegaming.net. This policy is meticulously designed to align with the stringent requirements of United States federal laws, such as the Bank Secrecy Act (31 U.S.C. §§ 5311-5314, 5316-5332) and the PATRIOT Act (Pub.L. 107-56).

Key Objectives Include:

Risk Identification: Systematically identifying potential money laundering risks associated with customer activities.
Compliance Assurance: Ensuring rigorous compliance with all relevant legal and regulatory requirements.
Customer Due Diligence: Implementing thorough customer due diligence (CDD) measures to verify and authenticate customer identities.
Continuous Monitoring: Establishing ongoing transaction monitoring protocols to detect and report suspicious activities.
Staff Training & Awareness: Cultivating a culture of compliance through regular employee training and awareness programs.
Collaboration with Authorities: Maintaining an open and cooperative stance with regulatory bodies and law enforcement.
Data Protection & Privacy: Upholding the highest standards of data security and customer privacy in compliance with GDPR and U.S. privacy laws.
Adaptability & Review: Regularly reviewing and updating the policy to stay abreast of legal changes and emerging risks in the online gaming and financial sectors.

This comprehensive objective is crafted to not only meet but exceed the legal obligations imposed on online gaming entities, thereby fostering a secure and transparent operational environment at Company.

Scope

Applicability

This AML policy applies comprehensively to all dimensions of Company’s operations, encompassing various stakeholders, processes, and transactions.

Stakeholders

Employees: All levels of employees, including management, are required to adhere to this policy.
Contractors and Agents: External parties engaged in business with Company are also subject to this policy.
Customers: The policy guides customer interactions, emphasizing due diligence and transaction monitoring.

Processes

Customer Onboarding: Rigorous processes for customer identification and verification.
Transaction Processing: Monitoring and reporting of transactions as per the policy guidelines.
Reporting and Record Keeping: Adherence to legal requirements for documentation and reporting.

Transactions

All financial transactions, including deposits, withdrawals, and any other monetary movements, fall within the scope of this AML policy.

Geographical Reach

While primarily focused on complying with U.S. regulations, the policy also considers global anti-money laundering standards, especially in jurisdictions where Company operates or engages with customers.

Compliance and Review

Regular audits and reviews of AML practices to ensure ongoing compliance and adaptation to new regulations or emerging risks, including an annual review and audit. A purpose of the audit will be to identify any weaknesses or deficiencies in the Company’s risk management, monitoring, and reporting practices as they relate to BSA/AML/OFAC compliance. Each audit shall include a comprehensive review of the Company’s Policy and implementation thereof, including the Company’s policies, procedures, and controls related to the detection of money laundering, terrorist financing, and other financial crimes. The audit will also include a review of the Company’s transaction monitoring systems, sanctions screening processes, customer due diligence practices, and suspicious activity reporting. The auditor will also evaluate the effectiveness of the Company’s risk assessment framework, including its design, implementation, and review frequency, and test the accuracy of data that is used for financial crime detection and risk management purposes. The auditor will identify whether any deficiencies have been identified as part of each audit.

Implementation

The policy is implemented through a combination of internal controls, employee training, and the use of technology for monitoring and detection purposes.

This scope ensures a holistic approach to AML compliance, covering all aspects of Company’s operations, and reaffirms the Company’s commitment to maintaining the highest standards of integrity and regulatory adherence in all its activities.

Legal Framework

The Anti-Money Laundering (AML) policy of Company is grounded in a strong legal framework which encompasses US federal regulations. This framework is not only a foundation for compliance but also a guiding structure for our comprehensive AML strategy. The policy reflects our commitment to adhering to the highest standards of legal and regulatory requirements, ensuring vigilant monitoring, and robust reporting mechanisms. In this section, we explore the specific legal guidelines that shape our AML practices beginning with the rigorous standards set forth by US federal law.

US Guidelines

Bank Secrecy Act (BSA)

AML Program Requirement: The BSA necessitates that financial institutions, including online gaming businesses like Company, establish a comprehensive AML program. This program must include systematized policies, procedures, and controls to detect and report money laundering activities.
Record-Keeping and Reporting: Mandates the maintenance of detailed records for certain transactions and the filing of reports for transactions over $10,000, such as Currency Transaction Reports (CTR).
Suspicious Activity Reporting (SAR): Requires filing SARs for transactions that appear to be suspicious, regardless of the amount involved. This includes structured transactions that seem to avoid BSA reporting requirements.

PATRIOT Act

Enhanced Due Diligence (EDD): Focuses on performing EDD for customers involved in high-risk activities, including international transactions. This includes obtaining information about the purpose of an account, the source of funds, and monitoring account activity.
Customer Identification Program (CIP): Requires institutions to collect identifying information about their customers and verify their identities. This is essential for Company during customer onboarding.
Information Sharing under Section 314(a): Facilitates information sharing among financial institutions to identify and report activities that may involve terrorist acts or money laundering.

Other Relevant Regulations

FinCEN Requirements: Company must comply with the Financial Crimes Enforcement Network (FinCEN) regulations, including adhering to anti-money laundering standards and maintaining a culture of compliance within the organization.

S. Department of the Treasury, Office of Foreign Assets Control (OFAC) laws and regulations as well as applicable law regarding economic and trade sanctions in jurisdictions where the Company does business.

Recent Legal Changes in US Federal Guidelines

Overview

The financial and online gaming sectors are subject to continual legislative and regulatory changes. Company’s AML policy incorporates recent updates in US federal laws and guidelines to remain compliant and effective.

Key Changes

Bank Secrecy Act (BSA) Amendments: Recent amendments have expanded the definition of financial institutions and updated requirements for reporting and record-keeping.
Strengthening of PATRIOT Act Provisions: Enhancements in the PATRIOT Act have been made, particularly around customer due diligence and beneficial ownership.
FinCEN’s Updated Guidance: The Financial Crimes Enforcement Network regularly updates its guidance on AML practices, including new methodologies for detecting and reporting suspicious activities.

Adaptation and Compliance

Policy Review and Update: Company’s AML policy is regularly reviewed in light of these changes to ensure full compliance.
Employee Training: Employees are continuously educated on these changes to ensure they understand and can implement the updated practices effectively.

OFAC

OFAC maintains and publishes a list of people and organizations that are subject to sanction. OFAC also maintains tailored sanctions programs that apply to specific countries. The Company will not engage in transactions with individuals or entities on OFAC’s Specially Designated Nationals (SDN) List or other applicable sanctions programs. In certain instances, the country-based sanctions are broad enough that the country is regarded as “comprehensively sanctioned” and the Company is not allowed to conduct business with, or disburse funds to, people or organizations located in that country. Other jurisdictions where the Company may publish similar lists indicating people, organizations, and countries subject to sanctions. Those named by OFAC or other applicable jurisdictions, are together referred to as “Sanctions Targets.” The Company has implemented procedures for the screening of its users, suppliers, vendors, and other applicable business associates against applicable Sanction Target lists. The Company has a legal obligation to avoid doing business with or engaging in prohibited transactions with Sanctions Targets, and act as required by OFAC or other applicable regulations in the jurisdictions the Company does business. This may include freezing user accounts, blocking payments, and filing necessary reports with regulatory authorities. Compliance with this policy, OFAC, or other applicable sanctions is essential to protect the Company against criminal and civil penalties and to maintain the Company’s reputation and trust of our users, suppliers, vendors and business associates.

Customer Identity Verification

Company is committed to establishing a secure and trustworthy gaming environment. An integral part of this commitment is the rigorous verification of customer identities. This process is crucial in preventing fraud, money laundering, and other illicit activities. Our three-step verification process is designed to be thorough yet customer-friendly, ensuring compliance with legal requirements while safeguarding customer privacy and data.

Three-Step Verification Process Provided by Third Party

Step 1: Identity Collection

Data Collection: When a customer wants to create a new account, they provide personal data (name, date of birth, address, etc.) as part of the account opening process with the Company. This process may be facilitated using a third party identity verification service.
Document Submission for Verification: The customer is required to provide documents for verification, such as a passport, driver’s license, or ID card. The Company or third party system allows customers to upload these documents easily.
Document Verification Process: The Company or a third party provider then checks the authenticity of these documents, examining both their physical and digital features. This involves automated data extraction and comparison using methods like optical character recognition (OCR) and pattern recognition. The documents are analyzed to ensure they are genuine and not forged.

All new customers will be screened against OFAC’s updated SDN list and other relevant global sanctions lists via the Company or a third party provider. Any matches will result in account denial and escalation to the AML Compliance Officer.

Decision on Verification: If the verification is successful and the document is deemed authentic, the customer is considered legitimate. The Company’s or third party’s system provides real-time feedback during this process, ensuring high-quality document capture and efficient verification.

By integrating the identity collection step into the Company’s account setup, the Company can enhance its KYC process, ensuring compliance with AML regulations while providing a secure and user-friendly customer onboarding experience. This system is particularly beneficial for online platforms like the Company’s platform, where remote verification is crucial.

Step 2: Document Verification

Threshold-Triggered Verification: When a customer’s transaction or account activity reaches predefined thresholds, additional document verification is triggered. This could include scenarios like high-value deposits, withdrawals, or unusual transaction patterns.
Document Upload and Analysis: Customers upload supplementary documents such as utility bills or bank statements for address verification. These documents are analyzed for authenticity and consistency with the identity data provided in Step 1.
Advanced Authentication Techniques: The Company and/or its third party provider utilizes various techniques to authenticate these documents. This includes checking for security features (watermarks, holograms), conducting colorspace and edge analysis to detect alterations, and verifying the general data against expected standards (spelling, dates, etc.).
Cross-Reference and Consistency Check: The system cross-references the information from these additional documents against the initial identity documents and the data provided by the customer, ensuring consistency and authenticity.
Real-Time Feedback and Correction: Real-time feedback is provided during the upload process, guiding customers to submit clear and correctly formatted documents, thereby reducing the potential for errors and the need for re-submission.

This detailed approach in Step 2 leverages the Company’s and/or its third party provider’s advanced verification capabilities to enhance the accuracy and integrity of the customer verification process, ensuring compliance with AML regulations and mitigating risks associated with identity fraud.

Step 3: Electronic Verification

Comprehensive Database Checks: The Company and/or a third party provider performs extensive electronic verification by cross-referencing customer information against a wide range of public and private databases. This includes checking against global watchlists, sanctions lists, and databases of politically exposed persons (PEPs).
Sophisticated Analysis Tools: Utilizing advanced AI and machine learning algorithms, the Company and/or a third party provider analyzes customer data to detect any discrepancies, inconsistencies, or indications of fraudulent activity.
Compliance and Risk Assessment: This step is crucial for maintaining compliance with AML regulations and managing risk effectively. It helps ensure that the Company’s operations remain secure and trustworthy.
User-Friendly Interface and Process: The electronic verification process is integrated seamlessly into the customer journey, ensuring a smooth and user-friendly experience while maintaining high security and compliance standards.

Ongoing Monitoring and Alerts

The system is designed for continuous monitoring of customer activities. It flags any unusual patterns or changes in customer behavior that could indicate potential money laundering or other illicit activities. This includes regular reviews of transaction patterns and real-time alerts for activities that meet pre-defined red flags or thresholds. Any significant changes in risk levels will prompt further investigation or escalation to the AML Compliance Officer. Customer records will also be regularly reviewed and updated to ensure accuracy. Any discrepancies or changes in customer information will be addressed promptly. The Company reserves the right to identify and subject high-risk customers who may undergo periodic enhanced verification as part of ongoing monitoring efforts. Ongoing monitoring also includes regularly updating and rescreening against updated OFAC lists and other sanctions data. Enhanced due diligence will be applied to customers with potential ties to sanctioned regions or entities.

This detailed approach in Step 3 leverages the Company’s and/or a third party provider’s technology to provide thorough and ongoing verification of customer information, crucial for AML compliance and risk management.

Consent

Informed Consent

Explicit Permission: Customers are required to give explicit permission for the verification process and the use of their data. This consent is obtained through clear, understandable language, outlining the specific purposes for which the data will be used.
Documentation: Consent is documented and securely stored as part of the customer’s record. Company ensures easy access to this record for both internal compliance checks and customer review.
Revocation Option: Customers are informed of their right to revoke consent at any time, along with the implications of such revocation on the services they can access.

Risk Assessment

Risk assessment is a pivotal component of Company’s AML policy. This process involves systematically categorizing customers based on their risk profiles to implement appropriate measures for each category. It is a continuous and evolving process, adapting to changing customer behaviors, transaction patterns, and global risk landscapes. The objective is to effectively identify, assess, and manage the risks associated with money laundering and terrorist financing, ensuring that enhanced scrutiny is applied where risks are higher. This proactive risk assessment forms the basis for applying due diligence measures tailored to the risk level of each customer.

Risk Categorization

Initial Assessment: On customer onboarding, the Company conducts an initial risk assessment based on information provided during the sign-up process. This includes evaluating transaction patterns, geographic location, type of games played, and frequency of play.
Categorization Criteria:

Low Risk: Customers with regular, small-scale transactions, residing in low-risk countries (as per international AML standards), and showing consistent gaming behavior.
Medium Risk: Includes customers with larger or irregular transactions, residents of countries with higher AML risk profiles, or exhibiting occasional deviations in typical gaming patterns.
High Risk: Customers engaging in very high-value transactions, residing in high-risk jurisdictions, showing significant and uncharacteristic changes in gaming behavior, or previously flagged for suspicious activities.

Dynamic Reassessment: The risk category of a customer is not static and is reassessed regularly based on ongoing transaction monitoring and customer activity.
Technology Integration: Utilizing advanced analytics and AI tools to assist in identifying and categorizing risks dynamically.
Compliance Team Involvement: The compliance team regularly reviews risk categorization criteria and individual assessments to ensure accuracy and compliance with evolving AML regulations.

Enhanced Due Diligence (EDD)

Process Overview

For customers classified as high-risk, the Company implements an Enhanced Due Diligence (EDD) process. This rigorous procedure involves a deeper examination of the customer’s profile, activities, and the risk they may pose.

In-Depth Background Checks: Conduct comprehensive checks including a review of the customer’s financial history, public records, and any past involvement in suspicious activities.
Source of Wealth Verification: Assess the legitimacy of the customer’s source of income or wealth. This may involve scrutinizing financial statements, business records, or other relevant documentation.
Ongoing Monitoring: Maintain heightened surveillance on transactions and activities of high-risk customers. This includes monitoring for unusual patterns or changes in behavior that could indicate money laundering.
Senior Management Approval: Transactions or accounts involving high-risk customers often require approval from senior management, ensuring an additional layer of scrutiny.
Documentation and Record-Keeping: Detailed records of the EDD process, including findings and decisions, are meticulously maintained for future reference and regulatory compliance.
Regular Review and Updates: EDD procedures are regularly reviewed and updated to remain aligned with current best practices and regulatory changes.

Transaction Monitoring

Transaction monitoring is a crucial aspect of Company’s AML policy, designed to identify and manage the risks associated with money laundering and terrorism financing. Transactions are screened for names, addresses, and identifiers associated with OFAC-sanctioned individuals or jurisdictions using automated tools, such as those provided by ComplyAdvantage and Veriff. This proactive process involves constant surveillance of customer transactions to detect unusual or suspicious activities. The effectiveness of this system is pivotal in preventing and mitigating illicit activities within the platform. Through advanced technology and comprehensive procedures, Company ensures that all transactions are consistently monitored for anomalies, thus safeguarding the integrity of its operations.

System Implementation for Transaction Monitoring

Advanced Monitoring Software: Company employs sophisticated AI-based software for transaction monitoring. This software is capable of analyzing vast amounts of transaction data in real-time, identifying patterns and anomalies indicative of suspicious activities.
Customizable Parameters: The system is configured with parameters that reflect Company’s specific risk profile. These parameters are based on transaction sizes, frequency, customer risk categories, and other relevant factors.
Alert Generation: When a transaction or a series of transactions deviate from the established norm, the system automatically generates alerts. These alerts are then reviewed by the compliance team for further investigation.
Integration with Customer Profiles: The monitoring system is fully integrated with customer profiles, allowing for a more nuanced understanding of each customer’s typical transaction behavior.
Regular Updates and Maintenance: The system is regularly updated to incorporate the latest in AI and machine learning advancements, as well as to adapt to evolving patterns of financial crime.
Compliance Team Training: The compliance team receives ongoing training to effectively utilize the system, interpret its findings, and take appropriate action.

Thresholds & Limits in Transaction Monitoring

Setting Transaction Thresholds: Company establishes specific monetary thresholds for transactions. These thresholds are based on various factors such as transaction type, customer risk category, and historical data. Transactions that exceed these set limits are flagged for further review.
Dynamic Adjustment of Limits: The thresholds are not static; they are periodically reviewed and adjusted to reflect changing patterns in customer behavior and emerging trends in financial crime.
Transaction Review Process: Any transaction that exceeds these predefined limits undergoes a detailed review. This involves assessing the nature of the transaction, the involved parties, and the context to determine if it aligns with the customer’s typical activity profile.
Customized Limits for High-Risk Categories: For customers in higher risk categories, more stringent transaction limits are set, and their transactions are subjected to more frequent reviews.
Documentation and Reporting: All findings from the review of transactions exceeding thresholds are meticulously documented. If suspicious activity is detected, it is reported in accordance with regulatory requirements.

Reporting

Suspicious Activity Reports (SARs): Company follows strict protocols for filing SARs. When a transaction or pattern of transactions is identified as suspicious, it is reported to the relevant authorities in accordance with the Bank Secrecy Act and other applicable regulations.
Timely Submission: All SARs are filed within the stipulated time frame required by regulatory bodies to ensure compliance and timely intervention.
Detailed Documentation: Each report includes comprehensive details about the transaction, customer information, the nature of the suspicious activity, and any related investigation findings.
Internal Tracking: For internal monitoring and compliance, a record of all filed SARs and their outcomes is maintained.
Confidentiality: The process of reporting is handled with strict confidentiality to protect the integrity of the investigation and the privacy of the individuals involved.

AML Compliance Officer Role

The Company understands that the role of the AML Compliance Officer is critical in ensuring the effective implementation and oversight of the Anti-Money Laundering (AML) program. This position is key to maintaining the integrity of the Company’s financial transactions and adherence to AML regulations. The AML Compliance Officer assigned by the Company is set forth above. The AML Compliance Officer is responsible for developing, coordinating, and overseeing the internal policies and procedures designed to prevent, detect, and report money laundering and other illicit financial activities. This role involves a strategic combination of regulatory knowledge, operational oversight, and effective communication across various departments.

Responsibilities of the AML Compliance Officer:

Program Oversight: The AML Compliance Officer is tasked with the comprehensive management of Company’s AML program. This includes continuous evaluation and updating of AML strategies to align with evolving regulatory landscapes.
Policy Compliance: Ensuring that all business practices, transactions, and customer interactions are in strict compliance with AML policies and regulations.
Staff Training: Responsible for conducting regular AML training sessions for employees, ensuring that all staff members are aware of their responsibilities under AML regulations and are equipped to recognize and report suspicious activities.
Liaison with Regulatory Authorities: Acting as the primary contact for regulatory bodies, the AML Compliance Officer manages all communications and reporting with these authorities, ensuring that Company adheres to all regulatory requirements and responds promptly to regulatory inquiries or audits.
Continuous Improvement: Implementing a culture of continuous improvement within the AML framework by integrating feedback, monitoring program effectiveness, and making necessary adjustments.

Qualifications of the AML Compliance Officer:

Regulatory Expertise: Deep understanding of AML regulations and laws, including the Bank Secrecy Act and PATRIOT Act. Familiarity with global AML standards is also crucial.
Risk Management Experience: Proven track record in risk management, with the ability to identify, assess, and mitigate financial risks.
Strong Analytical Skills: Ability to analyze complex data and transaction patterns to identify potential money laundering activities.
Effective Communication: Excellent communication skills to effectively liaise with regulatory bodies, convey AML policies to staff, and report to senior management.
Leadership and Training: Experience in leading a team and conducting training sessions on AML compliance.

Employee Training

Employee training is a cornerstone of Company’s AML policy. Recognizing that informed and vigilant staff are essential in identifying and preventing money laundering activities, the Company is committed to providing comprehensive and ongoing training on AML regulations and practices. This training ensures that all employees, regardless of their role, understand the importance of AML compliance and are equipped with the knowledge and tools necessary to contribute to the Company’s efforts in combating financial crimes.

Regular Training

Comprehensive Training Sessions: the Company requires training for new employees and conducts regular AML training sessions for all employees. These sessions cover various aspects of AML compliance, including updates to the Company’s AML policy, emerging trends in money laundering, and new regulatory requirements.
Detection Techniques: Training focuses on equipping employees with the skills and techniques needed to detect signs of money laundering and other financial crimes. This includes recognizing suspicious transaction patterns and understanding customer behavior that may indicate risk.
Legal Requirements: The training program also emphasizes the legal obligations of employees and the Company under AML laws, ensuring a thorough understanding of regulatory compliance.
Interactive and Engaging Format: Training sessions are designed to be interactive, engaging, and tailored to different roles within the Company, ensuring relevance and effectiveness.
Regular Updates: Training content is regularly reviewed and updated to reflect the latest AML trends and changes in laws and regulations.

Record Keeping

Documentation of Training Sessions: the Company meticulously documents all AML training sessions. This includes details such as training content, date, duration, and the trainer’s name.
Employee Attendance Records: A record of employee attendance for each training session is maintained. This ensures accountability and helps in tracking the AML knowledge level across the organization.
Accessibility and Audit-Readiness: These records are kept in an organized and accessible manner to facilitate internal reviews and external audits.
Retention Period: Training records are retained for a specified period, in accordance with regulatory requirements, to demonstrate compliance with AML training mandates.

Data Security & Privacy

Data security and privacy are fundamental elements of the Company’s AML policy. Recognizing the sensitivity of customer data and the potential risks associated with its handling, the Company is committed to implementing stringent data security measures and upholding high standards of privacy. This commitment not only ensures compliance with regulations but also builds trust with customers and partners. The approach to data security and privacy is comprehensive, encompassing both technological safeguards and organizational protocols.

Protection Measures

Cybersecurity Infrastructure: Implementing advanced cybersecurity infrastructure, including firewalls, intrusion detection systems, and secure network architectures to protect customer data from unauthorized access.
Encryption Technologies: Utilizing strong encryption for data at rest and in transit, ensuring that sensitive information is safeguarded against interception and breaches.
Regular Security Audits: Conducting regular security audits to identify and address vulnerabilities, ensuring the integrity of the cybersecurity measures.
Access Controls: Implementing strict access controls to ensure that only authorized personnel have access to sensitive data, based on their role and necessity.
Employee Awareness: Training employees in cybersecurity best practices to prevent accidental breaches and to recognize potential cyber threats.

Privacy Compliance

Data Subject Rights: Upholding the rights of data subjects, including the right to access, rectify, erase, and object to data processing.
Data Protection Officer (DPO): Appointing a DPO to oversee compliance with privacy laws and act as a point of contact for regulatory authorities and data subjects.
Privacy Policy Transparency: Maintaining a transparent and easily accessible privacy policy, detailing how customer data is collected, used, and protected.
Consent and Opt-Out Options: Providing clear options for customers to give consent for data processing and the ability to opt-out or withdraw consent.

Cooperation with Authorities

Company recognizes the importance of cooperating with regulatory and law enforcement authorities in the fight against money laundering and terrorist financing. This cooperation is a key component of the Company’s AML policy, reflecting a commitment to legal compliance and the broader effort to maintain the integrity of the financial system. This section outlines the protocols and practices that facilitate effective collaboration with authorities, ensuring timely and efficient sharing of information and adherence to legal obligations.

Information Sharing (Revised with Legal Citations)

Compliance with BSA: In accordance with the Bank Secrecy Act (31 U.S.C. § 5318(g)), Company complies with requirements to report suspicious activities and share relevant information with federal authorities.
Adherence to the PATRIOT Act: Under the USA PATRIOT Act (Pub.L. 107–56), the Company adheres to enhanced information-sharing provisions to combat money laundering and terrorism financing.
Procedure and Record-Keeping: Maintains detailed records of all information shared, ensuring compliance with these legal frameworks while respecting customer privacy.

Audit and Inspection Readiness (Revised with Legal Citations)

Record Retention as per BSA: Consistent with the Bank Secrecy Act requirements, Company retains records, including SARs and relevant financial transactions, for a minimum of five years (31 CFR 1010.430).
Readiness for Audits: Ensures all relevant records are organized, up-to-date, and readily accessible for both internal audits and external regulatory inspections.

Policy Review and Updates

Regular reviews and updates of the AML policy are crucial for Company to stay aligned with evolving regulatory landscapes and emerging financial crime trends. This process ensures that the policy remains effective, relevant, and in strict compliance with US regulations. The review encompasses assessing the efficiency of current AML practices, updating procedures based on recent legal changes, and integrating technological advancements. This ongoing refinement process underscores the Company’s dedication to maintaining the highest standards of AML compliance.

Regular Review

Annual Review and Audit Schedule: Company conducts an annual review and audit of its AML policy to ensure it remains up-to-date with the latest legal requirements and best practices in the field of AML compliance.
Legal and Regulatory Updates: The review process includes an assessment of any changes in US AML laws and regulations, ensuring the policy aligns with current legal standards.
Best Practices Integration: The policy is also updated to reflect emerging best practices in AML compliance, incorporating insights from industry trends and technological advancements.
Stakeholder Involvement: The review process involves input from various stakeholders, including the compliance team, legal advisors, and senior management, to ensure a comprehensive and effective policy.

Feedback Mechanism

Establishing Feedback Channels: Company sets up dedicated channels for receiving feedback from both employees and customers regarding its AML policy and procedures.
Employee Feedback: Employees are encouraged to provide insights and suggestions based on their on-the-ground experience with AML practices, offering valuable perspectives for improvement.
Customer Feedback Collection: Customer feedback is gathered through surveys and direct communication channels, focusing on their experience with AML-related processes.
Review and Integration: All feedback is regularly reviewed by the AML compliance team, and actionable insights are integrated into the policy for continuous improvement.

Legal Precedents and Citations

This section provides a comprehensive overview of legal frameworks and cases shaping AML practices:

Bank Secrecy Act (BSA): Details the BSA’s requirements, focusing on SARs and CTRs, underpinning the AML compliance framework.
USA PATRIOT Act: Analyzes key provisions affecting AML, notably in customer identification and data sharing, enhancing the BSA’s framework.
Key Legal Cases:

United States v. The Bancorp Group, Inc.: Demonstrates consequences for inadequate AML programs.

Regulatory Guidance:

FinCEN Guidance FIN-2016-G003: Outlines customer due diligence, including beneficial owner identification.
Wolfsberg Group Guidance: Cited for industry-standard AML principles.

Glossary of Terms

Suspicious Activity Report (SAR): A document filed by financial institutions to report suspicious or potentially suspicious activity to regulatory authorities.
Customer Due Diligence (CDD): The process of collecting and analyzing information about a customer’s identity and risk profile.
Enhanced Due Diligence (EDD): Additional verification procedures for high-risk customers, including in-depth investigation into their background and source of funds.
Beneficial Ownership: Identifying the natural persons who ultimately own, control, or influence a customer, especially in corporate structures.
Politically Exposed Persons (PEPs): Individuals who hold a prominent public position or role, making them potentially higher risk for involvement in corruption.
Money Laundering: The process of concealing the origins of illegally obtained money, typically through a sequence of banking transfers or commercial transactions.
Bank Secrecy Act (BSA): U.S. legislation requiring financial institutions to assist government agencies in detecting and preventing money laundering.
USA PATRIOT Act: An act enhancing U.S. government’s abilities to deter and punish terrorist acts in the United States and around the world, including measures to prevent money laundering.
Financial Action Task Force (FATF): An intergovernmental organization that develops policies to combat money laundering and terrorism financing.
Know Your Customer (KYC): The process of a business verifying the identity of its clients and assessing their suitability, along with the potential risks of illegal intentions.
Currency Transaction Report (CTR): A report that U.S. financial institutions are required to file for transactions over $10,000.
Trade-Based Money Laundering (TBML): The process of disguising the proceeds of crime and moving value through the use of trade transactions.
Risk-Based Approach (RBA): An AML strategy that prioritizes resources towards the areas of highest risk.
Wire Transfer Regulations: Laws governing the transfer of funds through electronic means, especially across borders.
Sanctions Lists: Lists of individuals, organizations, and countries targeted by economic sanctions.
De-risking: The process where financial institutions limit their exposure by closing or restricting certain accounts.
Compliance Officer: An individual responsible for ensuring that an organization complies with relevant laws and regulations.
Financial Intelligence Unit (FIU): A central national agency responsible for receiving, analyzing, and transmitting disclosures on suspicious transactions.
Anti-Money Laundering (AML) Program: A set of procedures, laws, and regulations designed to prevent criminals from disguising illegally obtained funds as legitimate income.
Layering: In money laundering, the process of moving funds through various financial transactions to obscure their origin.

Policy Approval

Management Sign-off

Approval Process: The final draft of the AML policy is presented to senior management for review and approval. This process ensures that the policy aligns with the overall strategic objectives of Company and adheres to regulatory requirements.
Documentation of Approval: The approval by senior management is formally documented, signifying the endorsement and commitment of the Company’s leadership to the AML policy.
Authority and Responsibility: The sign-off by management not only authorizes the policy’s implementation but also underscores the responsibility of management in ensuring its effectiveness and adherence.

Super Geeks LLC ANTI-MONEY LAUNDERING POLICY

Introduction

Objective

The primary goal of the AML policy for Super Geeks Llc is to establish a vigilant and responsive framework that proactively combats and mitigates the risks associated with money laundering and terrorist financing within the online gaming sector. This policy is meticulously designed to align with the stringent requirements of both United States federal laws, such as the Bank Secrecy Act (31 U.S.C. §§ 5311-5314, 5316-5332) and the PATRIOT Act (Pub.L. 107-56), and the European Union’s Anti-Money Laundering Directives (EU 2015/849; EU 2018/843).

Key Objectives Include:

Risk Identification: Systematically identifying potential money laundering risks associated with customer activities.
Compliance Assurance: Ensuring rigorous compliance with all relevant legal and regulatory requirements.
Customer Due Diligence: Implementing thorough customer due diligence (CDD) measures to verify and authenticate customer identities.
Continuous Monitoring: Establishing ongoing transaction monitoring protocols to detect and report suspicious activities.
Staff Training & Awareness: Cultivating a culture of compliance through regular employee training and awareness programs.
Collaboration with Authorities: Maintaining an open and cooperative stance with regulatory bodies and law enforcement.
Data Protection & Privacy: Upholding the highest standards of data security and customer privacy in compliance with GDPR and U.S. privacy laws.
Adaptability & Review: Regularly reviewing and updating the policy to stay abreast of legal changes and emerging risks in the online gaming and financial sectors.

Scope

Applicability

This AML policy applies comprehensively to all dimensions of Super Geeks Llc ‘s operations, encompassing various stakeholders, processes, and transactions.

Stakeholders

Employees: All levels of employees, including management, are required to adhere to this policy.
Contractors and Agents: External parties engaged in business with Super Geeks Llc are also subject to this policy.
Customers: The policy guides customer interactions, emphasizing due diligence and transaction monitoring.

Processes

Customer Onboarding: Rigorous processes for customer identification and verification.
Transaction Processing: Monitoring and reporting of transactions as per the policy guidelines.
Reporting and Record Keeping: Adherence to legal requirements for documentation and reporting.

Transactions

All financial transactions, including deposits, withdrawals, and any other monetary movements, fall within the scope of this AML policy.

Geographical Reach

While primarily focused on complying with U.S. and EU regulations, the policy also considers global anti-money laundering standards, especially in jurisdictions where Super Geeks Llc operates or engages with customers.

Compliance and Review

Regular audits and reviews of AML practices to ensure ongoing compliance and adaptation to new regulations or emerging risks.

Implementation

The policy is implemented through a combination of internal controls, employee training, and the use of technology for monitoring and detection purposes.

This scope ensures a holistic approach to AML compliance, covering all aspects of Super Geeks Llc’s operations, and reaffirms the company’s commitment to maintaining the highest standards of integrity and regulatory adherence in all its activities.

Legal Framework

The Anti-Money Laundering (AML) policy of Super Geeks Llc is grounded in a strong legal framework, encompassing both US federal regulations and EU directives. This framework is not only a foundation for compliance but also a guiding structure for our comprehensive AML strategy. The policy reflects our commitment to adhering to the highest standards of legal and regulatory requirements, ensuring vigilant monitoring, and robust reporting mechanisms. In this section, we explore the specific legal guidelines that shape our AML practices, beginning with the rigorous standards set forth by US federal law and followed by the equally stringent directives of the European Union.

US Guidelines

Bank Secrecy Act (BSA)

AML Program Requirement: The BSA necessitates that financial institutions, including online gaming businesses like Super Geeks Llc, establish a comprehensive AML program. This program must include systematized policies, procedures, and controls to detect and report money laundering activities.
Record-Keeping and Reporting: Mandates the maintenance of detailed records for certain transactions and the filing of reports for transactions over $10,000, such as Currency Transaction Reports (CTR).
Suspicious Activity Reporting (SAR): Requires filing SARs for transactions that appear to be suspicious, regardless of the amount involved. This includes structured transactions that seem to avoid BSA reporting requirements.

PATRIOT Act

Enhanced Due Diligence (EDD): Focuses on performing EDD for customers involved in high-risk activities, including international transactions. This includes obtaining information about the purpose of an account, the source of funds, and monitoring account activity.
Customer Identification Program (CIP): Requires institutions to collect identifying information about their customers and verify their identities. This is essential for Super Geeks Llc during customer onboarding.
Information Sharing under Section 314(a): Facilitates information sharing among financial institutions to identify and report activities that may involve terrorist acts or money laundering.

Other Relevant Regulations

FinCEN Requirements: Super Geeks Llc must comply with the Financial Crimes Enforcement Network (FinCEN) regulations, including adhering to anti-money laundering standards and maintaining a culture of compliance within the organization.

Recent Legal Changes in US Federal Guidelines

Overview

The financial and online gaming sectors are subject to continual legislative and regulatory changes. Super Geeks Llc ‘s AML policy incorporates recent updates in US federal laws and guidelines to remain compliant and effective.

Key Changes

Bank Secrecy Act (BSA) Amendments: Recent amendments have expanded the definition of financial institutions and updated requirements for reporting and record-keeping.
Strengthening of PATRIOT Act Provisions: Enhancements in the PATRIOT Act have been made, particularly around customer due diligence and beneficial ownership.
FinCEN’s Updated Guidance: The Financial Crimes Enforcement Network regularly updates its guidance on AML practices, including new methodologies for detecting and reporting suspicious activities.

Adaptation and Compliance

Policy Review and Update: Super Geeks Llc’s AML policy is regularly reviewed in light of these changes to ensure full compliance.
Employee Training: Employees are continuously educated on these changes to ensure they understand and can implement the updated practices effectively.

Customer Identity Verification

Super Geeks Llc is committed to establishing a secure and trustworthy gaming environment. An integral part of this commitment is the rigorous verification of customer identities. This process is crucial in preventing fraud, money laundering, and other illicit activities. Our three-step verification process is designed to be thorough yet customer-friendly, ensuring compliance with legal requirements while safeguarding customer privacy and data.

a. Three-Step Verification Process

Step 1: Identity Collection

Data Collection via EVS : When a customer wants to create a new account, they provide personal data (name, date of birth, address, etc.) as part of the account opening process on Super Geeks Llc. This process is facilitated using EVS’s identity verification service.
Document Submission for Verification: The customer is required to provide documents for verification, such as a passport, driver’s license, or ID card. EVS ‘s system allows customers to upload these documents easily.
Document Verification Process: EVS then checks the authenticity of these documents, examining both their physical and digital features. This involves automated data extraction and comparison using methods like optical character recognition (OCR) and pattern recognition. EVS’s system analyzes the documents to ensure they are genuine and not forged.
Decision on Verification: If the verification is successful and the document is deemed authentic, the customer is considered legitimate. EVS provides real-time feedback during this process, ensuring high-quality document capture and efficient verification.

By integrating EVS into the identity collection step, Super Geeks Llc can enhance its KYC process, ensuring compliance with AML regulations while providing a secure and user-friendly customer onboarding experience. This system is particularly beneficial for online platforms like Super Geeks Llc, where remote verification is crucial.

For more detailed information on EVS ‘s document verification process, you can visit their website: EVS Document Verification Process.

Step 2: Document Verification

Threshold-Triggered Verification: When a customer’s transaction or account activity reaches predefined thresholds, additional document verification is triggered. This could include scenarios like high-value deposits, withdrawals, or unusual transaction patterns.
Document Upload and Analysis: Customers upload supplementary documents such as utility bills or bank statements for address verification. EVS ‘s system analyzes these documents for authenticity and consistency with the identity data provided in Step 1.
Advanced Authentication Techniques: EVS utilizes various techniques to authenticate these documents. This includes checking for security features (watermarks, holograms), conducting colorspace and edge analysis to detect alterations, and verifying the general data against expected standards (spelling, dates, etc.).
Cross-Reference and Consistency Check: The system cross-references the information from these additional documents against the initial identity documents and the data provided by the customer, ensuring consistency and authenticity.
Real-Time Feedback and Correction: EVS provides real-time feedback during the upload process, guiding customers to submit clear and correctly formatted documents, thereby reducing the potential for errors and the need for re-submission.

This detailed approach in Step 2 leverages EVS ‘s advanced verification capabilities to enhance the accuracy and integrity of the customer verification process, ensuring compliance with AML regulations and mitigating risks associated with identity fraud.

For more specific details on EVS ‘s document verification process, you can refer to their explanation on their website: EVS Document Verification Process.

Step 3: Electronic Verification

Comprehensive Database Checks: EVS performs extensive electronic verification by cross-referencing customer information against a wide range of public and private databases. This includes checking against global watchlists, sanctions lists, and databases of politically exposed persons (PEPs).
Sophisticated Analysis Tools: Utilizing advanced AI and machine learning algorithms, EVS analyzes customer data to detect any discrepancies, inconsistencies, or indications of fraudulent activity.
Ongoing Monitoring and Alerts: The system is designed for continuous monitoring of customer activities. It flags any unusual patterns or changes in customer behavior that could indicate potential money laundering or other illicit activities.
Compliance and Risk Assessment: This step is crucial for maintaining compliance with AML regulations and managing risk effectively. It helps ensure that Super Geeks Llc ‘s operations remain secure and trustworthy.
User-Friendly Interface and Process: The electronic verification process is integrated seamlessly into the customer journey, ensuring a smooth and user-friendly experience while maintaining high security and compliance standards.

This detailed approach in Step 3 leverages EVS ‘s technology to provide thorough and ongoing verification of customer information, crucial for AML compliance and risk management.

For more specific details on EVS ‘s electronic verification capabilities, please refer to their services on their website: EVS Electronic Verification.

Consent

Informed Consent

Explicit Permission: Customers are required to give explicit permission for the verification process and the use of their data. This consent is obtained through clear, understandable language, outlining the specific purposes for which the data will be used.
Documentation: Consent is documented and securely stored as part of the customer’s record. Super Geeks Llc ensures easy access to this record for both internal compliance checks and customer review.
Revocation Option: Customers are informed of their right to revoke consent at any time, along with the implications of such revocation on the services they can access.

GDPR Compliance

Transparency: All data collection and processing activities are conducted transparently, with customers being fully informed about what data is collected, how it is used, and whom it is shared with.
Data Minimization: Super Geeks Llc adheres to the principle of data minimization, ensuring that only the necessary data for the verification and compliance process is collected.
Data Subject Rights: The policy upholds all the rights of data subjects under GDPR, including the right to access, the right to rectification, the right to erasure, and the right to data portability.
Security Measures: Implement robust security measures to protect customer data from unauthorized access, alteration, or destruction.
Regular Audits and Updates: Regularly review and update data protection measures to ensure ongoing compliance with GDPR. This detailed approach ensures that the consent process is thorough, respecting customers’ rights and adhering to the strict standards of GDPR.

For more information on GDPR compliance and best practices, you can refer to the official GDPR website: GDPR Compliance.

Risk Assessment

Risk assessment is a pivotal component of Super Geeks Llc ‘s AML policy. This process involves systematically categorizing customers based on their risk profiles to implement appropriate measures for each category. It is a continuous and evolving process, adapting to changing customer behaviors, transaction patterns, and global risk landscapes. The objective is to effectively identify, assess, and manage the risks associated with money laundering and terrorist financing, ensuring that enhanced scrutiny is applied where risks are higher. This proactive risk assessment forms the basis for applying due diligence measures tailored to the risk level of each customer.

a. Risk Categorization

Initial Assessment: On customer onboarding, Super Geeks Llc conducts an initial risk assessment based on information provided during the sign-up process. This includes evaluating transaction patterns, geographic location, type of games played, and frequency of play.
Categorization Criteria:
- Low Risk: Customers with regular, small-scale transactions, residing in low-risk countries (as per international AML standards), and showing consistent gaming behavior.
- Medium Risk: Includes customers with larger or irregular transactions, residents of countries with higher AML risk profiles, or exhibiting occasional deviations in typical gaming patterns.
- High Risk: Customers engaging in very high-value transactions, residing in high-risk jurisdictions, showing significant and uncharacteristic changes in gaming behavior, or previously flagged for suspicious activities.
Dynamic Reassessment: The risk category of a customer is not static and is reassessed regularly based on ongoing transaction monitoring and customer activity.
Technology Integration: Utilizing advanced analytics and AI tools to assist in identifying and categorizing risks dynamically.
Compliance Team Involvement: The compliance team regularly reviews risk categorization criteria and individual assessments to ensure accuracy and compliance with evolving AML regulations.

Enhanced Due Diligence (EDD)

Process Overview

For customers classified as high-risk, Super Geeks Llc implements an Enhanced Due Diligence (EDD) process. This rigorous procedure involves a deeper examination of the customer’s profile, activities, and the risk they may pose.

In-Depth Background Checks: Conduct comprehensive checks including a review of the customer’s financial history, public records, and any past involvement in suspicious activities.
Source of Wealth Verification: Assess the legitimacy of the customer’s source of income or wealth. This may involve scrutinizing financial statements, business records, or other relevant documentation.
Ongoing Monitoring: Maintain heightened surveillance on transactions and activities of high-risk customers. This includes monitoring for unusual patterns or changes in behavior that could indicate money laundering.
Senior Management Approval: Transactions or accounts involving high-risk customers often require approval from senior management, ensuring an additional layer of scrutiny.
Documentation and Record-Keeping: Detailed records of the EDD process, including findings and decisions, are meticulously maintained for future reference and regulatory compliance.
Regular Review and Updates: EDD procedures are regularly reviewed and updated to remain aligned with current best practices and regulatory changes.

Transaction Monitoring

Transaction monitoring is a crucial aspect of Super Geeks Llc ‘s AML policy, designed to identify and manage the risks associated with money laundering and terrorism financing. This proactive process involves constant surveillance of customer transactions to detect unusual or suspicious activities. The effectiveness of this system is pivotal in preventing and mitigating illicit activities within the platform. Through advanced technology and comprehensive procedures, Super Geeks Llc ensures that all transactions are consistently monitored for anomalies, thus safeguarding the integrity of its operations.

a. System Implementation for Transaction Monitoring

Advanced Monitoring Software: Super Geeks Llc employs sophisticated AI-based software for transaction monitoring. This software is capable of analyzing vast amounts of transaction data in real-time, identifying patterns and anomalies indicative of suspicious activities.
Customizable Parameters: The system is configured with parameters that reflect Super Geeks Llc ‘s specific risk profile. These parameters are based on transaction sizes, frequency, customer risk categories, and other relevant factors.
Alert Generation: When a transaction or a series of transactions deviate from the established norm, the system automatically generates alerts. These alerts are then reviewed by the compliance team for further investigation.
Integration with Customer Profiles: The monitoring system is fully integrated with customer profiles, allowing for a more nuanced understanding of each customer’s typical transaction behavior.
Regular Updates and Maintenance: The system is regularly updated to incorporate the latest in AI and machine learning advancements, as well as to adapt to evolving patterns of financial crime.
Compliance Team Training: The compliance team receives ongoing training to effectively utilize the system, interpret its findings, and take appropriate action.

Thresholds & Limits in Transaction Monitoring

Setting Transaction Thresholds: Super Geeks Llc establishes specific monetary thresholds for transactions. These thresholds are based on various factors such as transaction type, customer risk category, and historical data. Transactions that exceed these set limits are flagged for further review.
Dynamic Adjustment of Limits: The thresholds are not static; they are periodically reviewed and adjusted to reflect changing patterns in customer behavior and emerging trends in financial crime.
Transaction Review Process: Any transaction that exceeds these predefined limits undergoes a detailed review. This involves assessing the nature of the transaction, the involved parties, and the context to determine if it aligns with the customer’s typical activity profile.
Customized Limits for High-Risk Categories: For customers in higher risk categories, more stringent transaction limits are set, and their transactions are subjected to more frequent reviews.
Documentation and Reporting: All findings from the review of transactions exceeding thresholds are meticulously documented. If suspicious activity is detected, it is reported in accordance with regulatory requirements.

Reporting

Suspicious Activity Reports (SARs): Super Geeks Llc follows strict protocols for filing SARs. When a transaction or pattern of transactions is identified as suspicious, it is reported to the relevant authorities in accordance with the Bank Secrecy Act and other applicable regulations.
Timely Submission: All SARs are filed within the stipulated time frame required by regulatory bodies to ensure compliance and timely intervention.
Detailed Documentation: Each report includes comprehensive details about the transaction, customer information, the nature of the suspicious activity, and any related investigation findings.
Internal Tracking: For internal monitoring and compliance, a record of all filed SARs and their outcomes is maintained.
Confidentiality: The process of reporting is handled with strict confidentiality to protect the integrity of the investigation and the privacy of the individuals involved.

AML Compliance Officer Role

The role of the AML Compliance Officer at Super Geeks Llc is critical in ensuring the effective implementation and oversight of the Anti-Money Laundering (AML) program. This position is key to maintaining the integrity of the company’s financial transactions and adherence to AML regulations. The AML Compliance Officer is responsible for developing, coordinating, and overseeing the internal policies and procedures designed to prevent, detect, and report money laundering and other illicit financial activities. This role involves a strategic combination of regulatory knowledge, operational oversight, and effective communication across various departments.

Responsibilities of the AML Compliance Officer

Program Oversight: The AML Compliance Officer is tasked with the comprehensive management of Super Geeks Llc ‘s AML program. This includes continuous evaluation and updating of AML strategies to align with evolving regulatory landscapes.
Policy Compliance: Ensuring that all business practices, transactions, and customer interactions are in strict compliance with AML policies and regulations.
Staff Training: Responsible for conducting regular AML training sessions for employees, ensuring that all staff members are aware of their responsibilities under AML regulations and are equipped to recognize and report suspicious activities.
Liaison with Regulatory Authorities: Acting as the primary contact for regulatory bodies, the AML Compliance Officer manages all communications and reporting with these authorities, ensuring that Super Geeks Llc adheres to all regulatory requirements and responds promptly to regulatory inquiries or audits.
Continuous Improvement: Implementing a culture of continuous improvement within the AML framework by integrating feedback, monitoring program effectiveness, and making necessary adjustments.

Qualifications of the AML Compliance Officer

Regulatory Expertise: Deep understanding of AML regulations and laws, including the Bank Secrecy Act, PATRIOT Act, and relevant EU directives. Familiarity with global AML standards is also crucial.
Risk Management Experience: Proven track record in risk management, with the ability to identify, assess, and mitigate financial risks.
Strong Analytical Skills: Ability to analyze complex data and transaction patterns to identify potential money laundering activities.
Effective Communication: Excellent communication skills to effectively liaise with regulatory bodies, convey AML policies to staff, and report to senior management.
Leadership and Training: Experience in leading a team and conducting training sessions on AML compliance.

Employee Training

Employee training is a cornerstone of Super Geeks Llc’s AML policy. Recognizing that informed and vigilant staff are essential in identifying and preventing money laundering activities, the company is committed to providing comprehensive and ongoing training on AML regulations and practices. This training ensures that all employees, regardless of their role, understand the importance of AML compliance and are equipped with the knowledge and tools necessary to contribute to the company’s efforts in combating financial crimes.

a. Regular Training

Comprehensive Training Sessions: Super Geeks Llc conducts regular AML training sessions for all employees. These sessions cover various aspects of AML compliance, including updates to the company’s AML policy, emerging trends in money laundering, and new regulatory requirements.
Detection Techniques: Training focuses on equipping employees with the skills and techniques needed to detect signs of money laundering and other financial crimes. This includes recognizing suspicious transaction patterns and understanding customer behavior that may indicate risk.
Legal Requirements: The training program also emphasizes the legal obligations of employees and the company under AML laws, ensuring a thorough understanding of regulatory compliance.
Interactive and Engaging Format: Training sessions are designed to be interactive, engaging, and tailored to different roles within the company, ensuring relevance and effectiveness.
Regular Updates: Training content is regularly reviewed and updated to reflect the latest AML trends and changes in laws and regulations.

b. Record Keeping

Documentation of Training Sessions: Super Geeks Llc meticulously documents all AML training sessions. This includes details such as training content, date, duration, and the trainer’s name.
Employee Attendance Records: A record of employee attendance for each training session is maintained. This ensures accountability and helps in tracking the AML knowledge level across the organization.
Accessibility and Audit-Readiness: These records are kept in an organized and accessible manner to facilitate internal reviews and external audits.
Retention Period: Training records are retained for a specified period, in accordance with regulatory requirements, to demonstrate compliance with AML training mandates.

Data Security & Privacy

Data security and privacy are fundamental elements of Super Geeks Llc ‘s AML policy. Recognizing the sensitivity of customer data and the potential risks associated with its handling, the company is committed to implementing stringent data security measures and upholding high standards of privacy. This commitment not only ensures compliance with regulations like GDPR but also builds trust with customers and partners. The approach to data security and privacy is comprehensive, encompassing both technological safeguards and organizational protocols.

a. Protection Measures

Cybersecurity Infrastructure: Implementing advanced cybersecurity infrastructure, including firewalls, intrusion detection systems, and secure network architectures to protect customer data from unauthorized access.
Encryption Technologies: Utilizing strong encryption for data at rest and in transit, ensuring that sensitive information is safeguarded against interception and breaches.
Regular Security Audits: Conducting regular security audits to identify and address vulnerabilities, ensuring the integrity of the cybersecurity measures.
Access Controls: Implementing strict access controls to ensure that only authorized personnel have access to sensitive data, based on their role and necessity.
Employee Awareness: Training employees in cybersecurity best practices to prevent accidental breaches and to recognize potential cyber threats.

b. Privacy Compliance

GDPR Adherence: Ensuring all data collection and processing activities comply with the General Data Protection Regulation, respecting the privacy and rights of EU citizens.
Data Subject Rights: Upholding the rights of data subjects, including the right to access, rectify, erase, and object to data processing.
Data Protection Officer (DPO): Appointing a DPO to oversee compliance with privacy laws and act as a point of contact for regulatory authorities and data subjects.
Privacy Policy Transparency: Maintaining a transparent and easily accessible privacy policy, detailing how customer data is collected, used, and protected.
Consent and Opt-Out Options: Providing clear options for customers to give consent for data processing and the ability to opt-out or withdraw consent.

Cooperation with Authorities

Super Geeks Llc recognizes the importance of cooperating with regulatory and law enforcement authorities in the fight against money laundering and terrorist financing. This cooperation is a key component of the company’s AML policy, reflecting a commitment to legal compliance and the broader effort to maintain the integrity of the financial system. This section outlines the protocols and practices that facilitate effective collaboration with authorities, ensuring timely and efficient sharing of information and adherence to legal obligations.

a. Information Sharing (Revised with Legal Citations)

Compliance with BSA: In accordance with the Bank Secrecy Act (31 U.S.C. § 5318(g)), Super Geeks Llc complies with requirements to report suspicious activities and share relevant information with federal authorities.
Adherence to the PATRIOT Act: Under the USA PATRIOT Act (Pub.L. 107–56), the company adheres to enhanced information-sharing provisions to combat money laundering and terrorism financing.
EU Directives Compliance: Following the European Union’s Fourth (EU 2015/849) and Fifth (EU 2018/843) Anti-Money Laundering Directives, the policy includes cooperation with EU member state authorities in AML matters.
Procedure and Record-Keeping: Maintains detailed records of all information shared, ensuring compliance with these legal frameworks while respecting customer privacy.

b. Audit and Inspection Readiness (Revised with Legal Citations)

Record Retention as per BSA: Consistent with the Bank Secrecy Act requirements, Super Geeks Llc retains records, including SARs and relevant financial transactions, for a minimum of five years (31 CFR 1010.430).
EU AML Directive Compliance: In line with the EU’s Anti-Money Laundering Directives, records are maintained for at least five years, ensuring readiness for audits and inspections as required (EU 2015/849; EU 2018/843).
Readiness for Audits: Ensures all relevant records are organized, up-to-date, and readily accessible for both internal audits and external regulatory inspections.

Policy Review and Updates

Regular reviews and updates of the AML policy are crucial for Super Geeks Llc to stay aligned with evolving regulatory landscapes and emerging financial crime trends. This process ensures that the policy remains effective, relevant, and in strict compliance with both US and EU regulations. The review encompasses assessing the efficiency of current AML practices, updating procedures based on recent legal changes, and integrating technological advancements. This ongoing refinement process underscores the company’s dedication to maintaining the highest standards of AML compliance.

a. Regular Review

Annual Review Schedule: Super Geeks Llc conducts an annual review of its AML policy to ensure it remains up-to-date with the latest legal requirements and best practices in the field of AML compliance.
Legal and Regulatory Updates: The review process includes an assessment of any changes in US and EU AML laws and regulations, ensuring the policy aligns with current legal standards.
Best Practices Integration: The policy is also updated to reflect emerging best practices in AML compliance, incorporating insights from industry trends and technological advancements.
Stakeholder Involvement: The review process involves input from various stakeholders, including the compliance team, legal advisors, and senior management, to ensure a comprehensive and effective policy.

b. Feedback Mechanism

Establishing Feedback Channels: Super Geeks Llc sets up dedicated channels for receiving feedback from both employees and customers regarding its AML policy and procedures.
Employee Feedback: Employees are encouraged to provide insights and suggestions based on their on-the-ground experience with AML practices, offering valuable perspectives for improvement.
Customer Feedback Collection: Customer feedback is gathered through surveys and direct communication channels, focusing on their experience with AML-related processes.
Review and Integration: All feedback is regularly reviewed by the AML compliance team, and actionable insights are integrated into the policy for continuous improvement.

Appendices

The appendices of Super Geeks Llc’s AML policy serve as a comprehensive repository of supplementary information, providing detailed references, legal citations, and additional resources. These appendices are crucial for enhancing the understanding of the AML policy, offering clarity and depth to the procedures and regulations discussed within the main document. They include relevant legal cases, regulatory guidelines, a glossary of AML terms, and other pertinent materials that support the effective implementation and ongoing management of the AML program.

a. Legal Precedents and Citations

This section provides a comprehensive overview of legal frameworks and cases shaping AML practices:

Bank Secrecy Act (BSA): Details the BSA’s requirements, focusing on SARs and CTRs, underpinning the AML compliance framework.
USA PATRIOT Act: Analyzes key provisions affecting AML, notably in customer identification and data sharing, enhancing the BSA’s framework.
EU Anti-Money Laundering Directives: Summarizes the directives, emphasizing due diligence and reporting obligations within the EU jurisdiction.
Key Legal Cases: ◦ _United States v. The Bancorp Group, Inc.: Demonstrates consequences for inadequate AML programs. ◦ _Case C-212/11 Jyske Finans A/S (European Court of Justice): Interprets the EU’s Third AML Directive on customer verification.
Regulatory Guidance: ◦ _FinCEN Guidance FIN-2016-G003: Outlines customer due diligence, including beneficial owner identification. ◦ _Wolfsberg Group Guidance: Cited for industry-standard AML principles.

b. Glossary of Terms

Suspicious Activity Report (SAR): A document filed by financial institutions to report suspicious or potentially suspicious activity to regulatory authorities.
Customer Due Diligence (CDD): The process of collecting and analyzing information about a customer’s identity and risk profile.
Enhanced Due Diligence (EDD): Additional verification procedures for high-risk customers, including in-depth investigation into their background and source of funds.
Beneficial Ownership: Identifying the natural persons who ultimately own, control, or influence a customer, especially in corporate structures.
Politically Exposed Persons (PEPs): Individuals who hold a prominent public position or role, making them potentially higher risk for involvement in corruption.
Money Laundering: The process of concealing the origins of illegally obtained money, typically through a sequence of banking transfers or commercial transactions.
Bank Secrecy Act (BSA): U.S. legislation requiring financial institutions to assist government agencies in detecting and preventing money laundering.
USA PATRIOT Act: An act enhancing U.S. government’s abilities to deter and punish terrorist acts in the United States and around the world, including measures to prevent money laundering.
Financial Action Task Force (FATF): An intergovernmental organization that develops policies to combat money laundering and terrorism financing.
Know Your Customer (KYC): The process of a business verifying the identity of its clients and assessing their suitability, along with the potential risks of illegal intentions.
Currency Transaction Report (CTR): A report that U.S. financial institutions are required to file for transactions over $10,000.
Trade-Based Money Laundering (TBML): The process of disguising the proceeds of crime and moving value through the use of trade transactions.
Risk-Based Approach (RBA): An AML strategy that prioritizes resources towards the areas of highest risk.
Wire Transfer Regulations: Laws governing the transfer of funds through electronic means, especially across borders.
Sanctions Lists: Lists of individuals, organizations, and countries targeted by economic sanctions.
De-risking: The process where financial institutions limit their exposure by closing or restricting certain accounts.
Compliance Officer: An individual responsible for ensuring that an organization complies with relevant laws and regulations.
Financial Intelligence Unit (FIU): A central national agency responsible for receiving, analyzing, and transmitting disclosures on suspicious transactions.
Anti-Money Laundering (AML) Program: A set of procedures, laws, and regulations designed to prevent criminals from disguising illegally obtained funds as legitimate income.
Layering: In money laundering, the process of moving funds through various financial transactions to obscure their origin.

Policy Approval Management Sign-off

Approval Process: The final draft of the AML policy is presented to senior management for review and approval. This process ensures that the policy aligns with the overall strategic objectives of Super Geeks Llc and adheres to regulatory requirements.
Documentation of Approval: The approval by senior management is formally documented, signifying the endorsement and commitment of the company’s leadership to the AML policy.
Authority and Responsibility: The sign-off by management not only authorizes the policy’s implementation but also underscores the responsibility of management in ensuring its effectiveness and adherence.

Audit / Fraud Policy

All payments, deposits, redemptions, and withdrawals are subject to verification. Participants may be required to provide valid, government-issued identification and/or supporting documentation to confirm their payment method, full legal name, date of birth, and residential address.

If any account information submitted by a Participant does not match the Participant’s personal identifying information, the Participant will be required to provide supporting documentation substantiating the use of such information, along with a written explanation detailing the reason for the discrepancy.

If verification documents do not match the information provided on the account, or if legitimate documentation is not submitted within SEVEN (7) DAYS of your request, the account will be suspended. In such cases, all balances, winnings, credits, or funds associated with the account will be deemed forfeited and shall not be refunded.

All determinations regarding verification, discrepancies, documentation sufficiency, and account status shall be made at the sole discretion of the Administrator, and such decisions shall be considered FINAL AND BINDING.

By participating, you acknowledge and agree to these terms as a condition of entry and continued account use.

Sweepstakes Rules

Updated as of June 27, 2026

NO PURCHASE NECESSARY TO ENTER OR WIN. YOU HAVE NOT YET WON. A PURCHASE WILL NOT IMPROVE YOUR CHANCE OF WINNING. BY ENTERING, YOU AGREE TO THESE OFFICIAL RULES, WHICH CONSTITUTES A CONTRACT BETWEEN YOU AND THE COMPANY, SO READ THEM CAREFULLY BEFORE ENTERING. WITHOUT LIMITATION, THIS CONTRACT INCLUDES INDEMNITIES FROM YOU AND A LIMITATION OF YOUR RIGHTS AND REMEDIES.

PARTICIPATION IS VOID WHERE PROHIBITED OR RESTRICTED BY LAW. MUST BE OF MAJORITY AGE IN YOUR JURISDICTION TO PARTICIPATE, BUT IN NO CASE UNDER EIGHTEEN (18) YEARS OLD.

PLEASE READ ALL TERMS AND CONDITIONS OF THESE RULES CAREFULLY. THESE RULES SUBJECT YOU TO OUR POLICIES, INCLUDING OUR TERMS OF USE AND DECISIONS, WHICH CONTAIN AN AGREEMENT TO RESOLVE DISPUTES BY ARBITRATION ON AN INDIVIDUAL BASIS AND WAIVER OF CLASS ACTION CLAUSE.

To promote its brand and its sales services offered through its Web Sites/Applications, the Company also offers various games (“Promotional Games”) to eligible users including sweepstakes games. Entries into the sweepstakes games offered by the Company through the Promotional Games portion or platform of its Web Sites/Applications com are made through the use of “Sweeps Coins” (“SC”). Promotional Games using SC, referred to as “Sweeps Games” herein, are subject to these Sweepstakes Rules and the Terms of Use. Participating in Sweeps Games offered through the Promotional Game platform using SC offers a chance for eligible users to win additional SC which may be redeemable for real prizes and real cash (referred to as “Sweeps Play”).

These Sweepstakes Rules are to be read in conjunction with the Company’s other policies, including its Terms of Use, and are not meant as a replacement of any other policy. Terms which are defined in the Terms of Use have the same meaning in these Sweepstakes Rules.

Additionally, the Company’s Privacy Policy applies to these Sweepstakes Rules and any information provided by a user pursuant to these Sweepstakes Rules will be subject to the terms of the Privacy Policy.

SPONSOR/PROMOTER: The Sole Sponsor/Promoter of Sweeps Play is the Company.

THE COMPANY IS NOT AFFILIATED WITH OR SPONSORED BY APPLE, INC., GOOGLE, META, OR ANY OTHER PARTY UNLESS SPECIFICALLY STATED IN WRITING.

ELIGIBILITY TO PLAY IN SWEEPS PLAY:

Sweeps Play is open only to legal residents (individuals who are the majority age in their Jurisdiction, but in no case under the age of eighteen (18)) of the fifty (50) United States excluding users located in the states of California, Connecticut, Delaware, Idaho, Indiana, Louisiana, Maine, Michigan, Montana, Nevada, New Jersey, New York, Oklahoma, Tennessee, Utah, and Washington (the “Excluded Territory”), unless otherwise stated in these Sweepstakes Rules. THE EXCLUDED TERRITORY IS DEFINED HEREIN AS OF THE DATE SHOWN ABOVE. THE COMPANY RESERVES THE RIGHT TO MAKE CHANGES TO THE EXCLUDED TERRITORY AT ANY TIME, WITHOUT NOTICE. YOU AGREE THE COMPANY SHALL NOT BE LIABLE FOR ANY DAMAGES RESULTING FROM A CHANGE TO THE EXCLUDED TERRITORY.
PARTICIPATION IS VOID IN THE EXCLUDED TERRITORY AND WHERE PROHIBITED BY LAW.
Employees of the Company and its respective parents, subsidiaries, divisions, affiliates, suppliers, distributors, and advertising, promotional, and judging agencies, including the administrator of this Sweepstakes if any, and each of their respective officers, directors, and employees, and the immediate family members (spouses, parents, step-parents, legal guardians, children, step-children, siblings and step-siblings and their spouses) and household members of each (whether or not related), are not eligible to participate or win.
Sweeps Play is subject to all applicable Federal, State, Provincial, Territorial, and Local Laws and Regulations. It is the sole responsibility of the Participant to determine whether their participation in the Sweepstakes is legal and compliant with all regulations in the State or Province where they reside.
Participation in Sweeps Play constitutes the User’s full and unconditional agreement to these Sweepstakes Rules, Privacy Policy and all the Company other policies, Terms of Use, and decisions, which are final and binding in all matters related to the Sweepstakes.
Winning a Prize is contingent upon fulfilling all requirements set out in these Sweepstakes Rules and all other Company policies, Terms of Use and decisions.
In the event of a dispute as to the ownership of any SC, the authorized account holder of the email address used to register the User Account will be deemed to be the User. The “authorized account holder” is the person assigned the email address by an internet access provider, online service provider or other organization responsible for assigning email addresses for the domain associated with the submitted address.
The Company’s decisions as to the administration and operation of Sweeps Play are final and binding.

HOW TO ENTER/PARTICIPATE IN PROMOTIONAL GAMES SWEEPS PLAY:

To participate in Sweeps Play, Users must create a User Account (as explained below), and collect SC while playing Promotional Games using SC.
To access the Sweeps Platform, a User must click on a button to be redirected to the Promotional Games.
When Users play games in Sweeps Play, they will play games using SC for the chance to win further SC, which will be redeemable for real prizes and/or real cash. SC may be obtained in numerous ways described below. NO PURCHASE OR PAYMENT OF ANY KIND IS REQUIRED TO OBTAIN SWEEPS COINS. A PURCHASE DOES NOT INCREASE YOUR CHANCES OF WINNING.
Users may obtain SC in the following ways:

By Logging on to the Web Sites/Applications: A User will be awarded a set amount of free SC the first time they Log on to their User Account each day. To create a User Account, Users may visit the Web Sites/Applications and follow the required steps. User Accounts are free to create. Only one (1) User Account is allowed per User.
As a Bonus to purchasing items available for sale through the Web Sites/Applications. The amount of SC awarded may vary based on the purchase price and amount of items purchased and this information will be displayed to the Users as they make their purchase.
ALTERNATIVE MODE OF ENTRY – Sending a Request Card by Post: Users may receive SC by sending a standard postcard or blank piece of paper made to size (“Request Card”) which must be 4” x 6”, unfolded and placed inside a stamped #10 envelope addressed in handwriting, to the following address and satisfying the requirements set out below, including a unique Mail-In Request Code described below:

ATTENTION: Sweeps Coin Request

Super Geeks LLC

145 W. Ostend St.
Suite 600
Baltimore, MD
21230

Users Must:

Legibly handwrite the following on the outer envelope:

On the outside of the envelope, the User must write the following in the following order:

On the Front Top left of the envelope:

Their return address;

On the Back Mid-Center (not top) of the envelope:

Their unique Mail-In Request Code generated to their user account in the format displayed on the screen. Any other format will be invalid. (instructions on how to obtain the Mail-In Request Code are below)

Legibly handwrite the following, in landscape layout, on only one side of the Request Card inserted inside the envelope IN THE FOLLOWING ORDER:

On the top left of the card:

Their full name as shown on their User Account
The email address registered to their User Account.
Their unique Mail-In Request Code generated to their User Account while logged on to in the following format: XXXXXX-XXXXXX-XXXXXXXXX. Any other format will be invalid. (Instructions on how to obtain the Mail-In Request Code are below).
The return/residential address on their Government ID associated with their User Account.

On the top right of the card:

The date on which the letter was prepared by the User.

Additionally on the front side of the Request Card, the User must then write the following statement below the above information:

“I wish to receive Sweeps Coins to participate in Sweeps Play through www.exclusivegaming.net.”

FOR THE AVOIDANCE OF DOUBT, COMBINED REQUESTS SENT VIA PACKAGE OR PARCEL DO NOT MEET THE REQUIREMENTS SET OUT ABOVE AND ARE INVALID.

Mail-In Request Code: In order for a Request Card to be processed and deemed valid, it must possess a unique Mail-In Request Code. To obtain a Mail-In Request Code, the User must be logged in to their User Account. Once logged in the User must select to the link that says “My Account” or “Profile”. On the “My Account” or “Profile” tab the User will be able to select the button “Get Mail-In Code.” A unique code will then be generated in a reasonable amount of time. The User must write this code on the outer envelope (as described above) in the following format: XXXXXX-XXXXXX-XXXXXXXXX. The purpose of the Mail-In Request Code is to assist the Company with the efficient, effective, and timely processing of a User’s Request Card. A POSTAL REQUEST CARD MAY ONLY BE USED ONCE and may only be used by the User whose User Account was used to generate the Mail-In Request Code. Any person suspected by the Company to have either directly or indirectly provided a Mail-In Request Code to another User may, in the Company’s sole discretion, be disqualified from Sweeps Play and may risk suspension or termination of their User Account. MAIL-IN REQUEST CODES ARE VALID FOR 60 DAYS AFTER THEY ARE GENERATED.
There is a limit of one request per outer envelope. For each Request Card a User submits in accordance with the above requirement, the User will receive up to five (5) SC. The SC will be randomly generated by the system between one (1) SC to five (5) SC. The SC will be added to the Participant’s User Account within a reasonable amount of time after being received by the Company in the mail.
A User must ensure that their handwriting is legible. If the User’s handwriting is not legible, as determined in our sole discretion the Request will be void and the SC will not be added to the User’s User Account. Additionally, all required information must be written in one color of ink (Black ink is recommended). The use of multiple colors will result in disqualification of the Request Card. Failure to comply with any of the requirements set out in this section 3(f) will result in disqualification of that particular Request Card.
The request must only be made by the User. The name written on the Request Card must match the name associated with the User Account in question. If the name provided to the Company upon registration of the User Account is different from the name on the Request Card, the Request Card will be deemed invalid and the User must submit a request to change the name associated with their User Account.
Tampering with the entry process or the operation of Sweeps Play, including but not limited to the use of any device to automate the SC entry process or to unfairly assist the User with meeting the handwritten requirement, is prohibited and any Request Cards deemed by the Company, in its sole discretion, to have been submitted in this manner will be void. Any User caught tampering with the AMOE Request Card process, outsourcing the drafting of Request Cards, or manipulating Request Card entries will result in disqualification of their Request Cards and User Account suspension.
In the event a dispute regarding the identity of the User who actually submitted a request or whether a request satisfies the requirements set out above cannot be resolved to the Company’s satisfaction, the affected Request Card will be deemed ineligible.
The Company is not responsible for lost, late, incomplete, invalid, unintelligible or misdirected SC requests or allocations.
The Company reserves the right to add other methods or alter the above methods of obtaining SC from time to time. The Company will allow for a Grace Period for those Request Cards already in the mail but not received by the Company before any update to these Official Sweepstakes Rules. All dates will be cross-referenced to the date written on the Request Card and postage. If it is determined that the User has tampered with the initial date written on the Request Card or with the postage date, the Request Card will be disqualified. Any Request Card received after the Grace Period expires will be reviewed in accordance with the updated Sweepstakes Rules.
Please note the following rules regarding AMOE Request Card submissions, which if not followed, could result in the suspension or blocking of your User Account:

Information regarding the status of pending Request Cards will not be available until the review, approval, and crediting of Request Cards is complete.
The Company will be unable to provide updates on the status of Request Cards until the review period is complete.
All qualifying and approved Request Cards will be credited to the User Accounts which meet the AMOE Request Card requirements described in these Official Sweepstakes Rules.
The Company is only able to comment and advise on approved and credited Request Cards and is unable to provide information on non-qualifying and disqualified Request Cards.
The Company will only be able to advise on questions related to Request Card format if the User provides a picture or copy of their Request Card. No template Request Card will be provided.
Disqualified Request Cards will not be reconsidered, all decisions related to Request Card approval are final and no reconsiderations will be allowed.
Any missing Request Cards or Request Cards that do not reach the Company will not qualify for approval.

A Users’ SC balance will be available to them on the app screen in their SC Wallet on the Web Sites/Applications. These coins are only to be used to play games Sweeps Games. The amount of SC to be allocated to Users can be changed at any time by the Company in its sole discretion.
A User will be able to see both their total, un-played, and redeemable SC balance by clicking their SC Wallet while on the Promotional Games platform. Only SC earned while playing Sweeps Games may be redeemed for prizes or cash.
Use of any automated or other system(s) to participate, to acquire SC, or win prizes is prohibited and will result in disqualification from playing games on the Web Sites/Applications. To opt-out, a User need only not visit the Promotional Games platform of the Web Sites/Applications.
SC are only valid for sixty (60) days from the date a User last logged on to their User Account. In the event that a User does not log onto his/her User Account for sixty (60) consecutive days, all accrued SC shall automatically expire and the User Account will be deemed dormant.
In the event of a dispute as to any registration of a User Account, the authorized account holder of the email address used to register the User Account will be deemed to be the participating Account. The “authorized account holder” is the natural person assigned the email address by an internet access provider, online service provider or other organization responsible for assigning email addresses for the domain associated with the submitted address.
SC may be forfeited if a User’s User Account is deactivated for any reason at the Company’s sole discretion, or for any other reason also at the Company’s sole discretion.

HOW TO WIN PRIZES WITH SWEEPS COINS AND SELECTION OF WINNERS:

To win Prizes in Sweeps Games, a User must accumulate SC by playing Sweeps Games.
All SC uses will be withdrawn from the User’s un-played SC balance in their SC Wallet. SC must be played a minimum of one (1) time to be eligible for redemption.
All SC won while playing games will be added to the User’s redeemable SC balance.
In the event that a User uses SC but their unplayed SC balance is insufficient to cover the minimum amount required for play, the additional SC needed to reach the minimum will be withdrawn from the User’s redeemable SC balance. In the event that there is a technical issue, the game outcome will be voided and all funds will be returned to the User in their unplayed SC balance.
A User may elect to submit a Redemption Request for cash by selecting the “cash out” option. Any verified payment options will appear for the User to select how they would like to receive their redemption of cash in the event it is approved by the Company.
FOR PURPOSES OF REDEMPTION ONLY. 1 SC will be redeemable for $1. SC possesses no real monetary value until a Redemption Request has been approved and processed by the Company. There is no guarantee that a Redemption Request will be granted. Approval of Redemption Requests is at the sole discretion of the Company.
The odds of winning a certain number of SC will be available to Users in each individual game’s Pay Table and Rules.
The Company reserves the right to change the prize win rates and odds of any game on the Web Sites/Applications. It is a User’s responsibility to check the rules of each game they play to see the odds of winning SC while playing that particular game.

VERIFICATION AND CONFIRMATION OF POTENTIAL WINNERS AND NOTIFICATION OF WINNING:

Potential Sweeps Game winners are subject to verification by the Company and the decisions of the Company are final and binding in all matters related to the Sweeps Games. A User is not a winner of any prize, even if the online screen indicates they are, unless and until the User’s eligibility has been verified and the User has fully complied with these Official Sweepstakes Rules and been notified that verification is complete. The Company will not accept screenshots or other purported evidence of winning in lieu of its validation process
Potential prize winners must comply with these Official Sweepstakes Rules and WINNING IS CONTINGENT UPON FULFILLING THIS REQUIREMENT.
A potential prize winner may be required to sign and return an affidavit to the Company, an affidavit/declaration of eligibility, and liability/publicity release (except where prohibited) in order to claim his/her prize (if applicable).
If a potential winner cannot be contacted, fails to comply with section 5 if requested) within the required time period, or fails to comply with these Official Sweepstakes Rules, or if the prize or prize notification is returned as undeliverable, that potential winner forfeits the prize.
In the event that a potential winner of a Sweeps Game prize is disqualified for any reason, the Company may, in its sole discretion, put the prize back into Sweeps Games.
Users will be able to check prize eligibility by hitting redeem and comparing their total redeemable SC to the available prize values.

PRIZES AND REDEMPTION OF PRIZES:

Prizes may only be obtained by redeeming redeemable SC earned while playing Sweeps Games.
By redeeming a prize on the Web Sites/Applications, Users agree to be bound by all the Company’s rules, regulations, and Terms of Service. The Company is not responsible for any delays in receiving a gift card prize or other disputes which may arise once a User has redeemed a prize.
To be eligible to receive a Prize:

A User must be an eligible User in accordance with these Sweepstakes Rules; and
The User’s details must match those of the User’s User Account.

For security reasons and for the prevention of money laundering, the Company will only authorize a redemption of prizes to a bank or bank account held in the User’s name. If you provide account details which relate to a bank account held jointly between you and another person, you acknowledge and accept that any prizes will be paid into that joint account, and they may require you to supply additional documentation relating to the person who jointly holds the bank account with you so that we may identify and verify the joint account holder.
The Company is not responsible for any taxes or fees associated with a winning prize. Users are responsible for all applicable taxes and fees associated with prize receipt and/or redemption. A User’s total annual winnings will be made available upon request.
The Company can only process one prize Redemption Request at a time with minimum time between requests once every forty-eight (48) hours. The Company will process Redemption Requests as soon as practicable (review periods may be a minimum of seventy two (72) hours). Reviews are conducted Monday-Friday during business hours (9am-5pm EST). Any Redemption Request received on a Saturday, Sunday, or holiday will be reviewed accordingly at a minimum of on the next business day. Redemption Requests will be actioned in the order that they are approved, not in the order they are received. Redemption methods vary in processing times and may take up to ten (10) business days to process and reflect in a User’s User Account depending on the Redemption method selected by the User.
The Company is not responsible for any foreign exchange transaction fees, charges or related costs may be incurred as a result of, or in relation to, a prize redemption, including but not limited to any losses or additional costs arising from foreign exchange fluctuations.
SC are not transferable and no substitution will be made except as provided herein at the Company’s sole discretion. The Company reserves the right to substitute the listed prize of equal or greater value for any reason owing to circumstances outside the Company’s reasonable control. SC are not to be offered for sale, substitution, or transfer in any manner, SCs may only be used for play in Sweeps Games.
Prize winners will be notified in accordance with Section 5 of these rules.
Users who elect to redeem SC for cash will receive a check or alternate pickup location (if available) up to at least ten (10) days after their redemption is approved. Users who elect to redeem their SC through Skrill will receive their redemption instantly upon approval by the Company.
For Users who reside and/or access Sweeps Games in the State of Florida or the State of New York, the maximum amount a prize may be redeemed is limited to $5,000 USD per game outcome or per play round. Any amounts in excess of $5,000 USD will not be eligible for redemption. Additionally, the Company reserves the right to limit total daily redemptions to a maximum daily redeemable amount in any or all States.
It is the User’s responsibility to:

Ensure your bank information is correct and that they will accept and process payments from the Company; and
Ensure all information you provide such as your legal name, address, age, and contact information is accurate and complete.

ENTRY CONDITIONS AND RELEASE:

By Participating, each User agrees to:

Comply with and be bound by:

All Company policies and Terms of Use;
These Official Sweepstakes Rules; and
The decisions of the Company which are binding and final;

Release and hold harmless the Company and its parent, subsidiary, and affiliated companies, the prize suppliers and any other organizations responsible for sponsoring, fulfilling, administering, advertising, or promoting Sweeps Games, and all of their respective past and present officers, directors, employees, agents and representatives (collectively “the Released Parties”) from and against any and all claims, expenses, and liability, including but not limited to negligence and damages of any kind to persons and property, including but not limited to invasion of privacy (under appropriation, intrusion, public disclosure of private facts, false light in the public eye or other legal theory), defamation, slander, libel, violation of publicity, infringement of trademark, copyright or other intellectual property rights, property damage, or death or personal injury arising out of or relating to an entry, creation of an entry or submission of an entry, participation in Sweeps Games, acceptance or use or misuse of prizes (including travel or activity related thereto) and/or broadcast, exploitation or use of entry; and
Indemnify, defend, and hold harmless the Company from and against any and all claims, expenses, and liabilities (including reasonable attorneys/legal fees) arising out of or relating to a User’s participation in Sweeps Games and/or User’s acceptance, use or misuse of prizes.

LIMITATION OF LIABILITY:

Insofar as permitted by law in the respective territories, the Company assumes no responsibility for:

Any incorrect or inaccurate entry information, whether caused by a User, printing error, or for any faulty or failed electronic data transmissions;
Any unauthorized access to, or theft, destruction, or alteration of entries at any point in the operation of games played in Sweeps Play;
Any technical malfunction, failure, error, omission, interruption, deletion, defect, delay in operation or communication line failure, regardless of cause, with regard to any equipment, systems, networks, lines, satellites, servers, camera, computers or providers utilized in any respect of the operation of Sweeps Play;
Inaccessibility or unavailability of any network or wireless service, the Internet or website or any combination thereof.
Suspended or discontinued internet, wireless, or landline phone services; or
Any injury or damage to User’s or to any other person’s computer or mobile device which may be related to or resulting from any attempt to participate in games played in Sweeps Play or download of any materials related to Sweeps Play.

The Company reserves the right at its sole discretion to cancel, terminate, modify, or suspend Sweeps Play in whole or in part. In such an event, the Company shall immediately suspend all drawings and prize awards, and the Company reserves the right to award any remaining prizes in a manner deemed fair and equitable by the Company. The Company and Released Parties shall not have any further liability to any participant in connection with Sweeps Play.
If for any reason a User’s SC are confirmed to have been erroneously deleted, lost, or otherwise destroyed or corrupted, User’s sole remedy is replacement by SC of an equivalent amount of SC

PUBLICITY AND SUBMISSIONS:

Except where prohibited by law, participation in Sweeps Play constitutes each User’s consent to the Company’s and its agent’s use of Users’ name, likeness, photograph, voice, opinions and/or hometown and state/province/territory for promotional purposes in any media, worldwide, without further payments, notice or consideration.
A Submission to the Company, whether through the Web Sites/Applications or a post to any of its social media pages constitutes User’s consent to give the Company a royalty-free, irrevocable, perpetual, non-exclusive license to use such submission or post on a worldwide basis, and to incorporate it into other works, in any form, media or technology not known or later developed, including for promotional or marketing purposes. If requested, User will sign any documentation that may be required for the Company or its designees to make use of the non-exclusive rights User is granting to use the submission or post.

SWEEPS BOOSTS AND REWARDS:

The Company offers Users the opportunity to participate in various Boosts and Rewards Programs. All Boosts and Rewards Programs are governed by these Official Sweepstakes Rules and all Company policies, Terms of Use and decisions. All decisions related to Boosts and Rewards will be decided by the Company in its sole decision and such decisions will be considered final and binding.

GENERAL CONDITIONS:

The Company reserves the right to cancel, suspend and/or modify any games or rules while playing games in Sweeps Play or these Official Sweepstakes Rules, or any part thereof, with immediate effect owing to circumstances outside its reasonable control and only where circumstances it made unavoidable if any fraud, technical failures or any other factor beyond the Company’s reasonable control impairs the integrity or proper functioning of Sweeps Play, as determined by the Company.
The Company reserves the right in its sole discretion to disqualify any individual it finds to be tampering with the entry process or the operation of Sweeps Play or to be acting in violation of these Official Sweepstakes Rules or any other promotion or in an unsportsmanlike or disruptive manner. Such User’s SCs will be deemed invalid.
Any attempt by any person to deliberately undermine the legitimate operation of Sweeps Play may be in violation of criminal and civil law and, should such an attempt be made, the Company reserves the right to terminate such individual’s use of the services and seek damages from any such person to the fullest extent permitted by Law. The Company’s failure to enforce any term of these Official Sweepstakes Rules shall not constitute a waiver of that provision. Such User’s SCs will be deemed invalid.
In all other cases, the Company reserves the right to cancel, suspend and/or modify Sweeps Play. Any notice regarding cancellation, suspension and/or modification will be sent to the email address associated with your User Account.
In the event of modifying Sweeps Play, a User’s continued enrollment and/or participation in Sweeps Play constitutes acceptance of the modified terms.

GOVERNING LAWS AND DISPUTES:

These Official Sweepstakes Rules shall be governed and interpreted in accordance with the laws of Maryland.
If you have any complaints about Sweeps Play, you must contact Customer Support in the first instance or by writing to the Company via customer support by submitting an online support form, by email at legal@exclusivegaming.net within fourteen (14) days of any incident or issue. We will use all our efforts to resolve the reported matter promptly.
All disputes shall be governed by the Dispute Resolution by Binding Arbitration Agreement clause in the Terms of Use, including the enumerated Waiver of Class Actions. Also, see Below.
For your protection and to ensure the best possible service to you by the Company, telephone conversations and other relevant communication between you and the Company may be recorded and/or monitored.
The Company will not tolerate derogatory, abusive, or violent behavior or statements that are threatening, vulgar, defamatory, or otherwise offensive. Should you behave in such a manner towards the Company’s employees or other Users (as determined in the Company’s sole discretion), the Company reserves the right to suspend and/or close your account, disqualify you from Sweeps Play participation, and stop all communication and/or replies from the Company, and/or take further measures as may be deemed appropriate, including reporting to relevant local authorities and law enforcement agencies.

WINNER’S LIST:

To obtain a copy of a legally-required winner’s list for Sweeps Play, send an email to legal@exclusivegaming.net.

DISPUTE RESOLUTION BY BINDING ARBITRATION AGREEMENT:

PLEASE READ THIS PROVISION CAREFULLY, BECAUSE IT REQUIRES YOU AND THE COMPANY TO ARBITRATE ALL PAST, PRESENT, AND FUTURE DISPUTES WITH THE COMPANY AND LIMITS THE MANNER IN WHICH YOU CAN SEEK RELIEF, SUBJECT TO THE TERMS AND OPT-OUT OPTION SET FORTH BELOW. THE OPTION TO OPT-OUT IS TIME-LIMITED AS YOU MUST OPT-OUT WITHIN 30 DAYS AND DESERVES YOUR IMMEDIATE ATTENTION. ARBITRATION PRECLUDES YOU FROM SUING IN COURT OR FROM HAVING A JURY TRIAL.
THESE PROVISIONS GENERALLY PRECLUDE YOU FROM BRINGING ANY CLASS, COLLECTIVE, OR REPRESENTATIVE ACTION AGAINST THE COMPANY. THEY ALSO PRECLUDE YOU FROM PARTICIPATING IN OR RECOVERING RELIEF UNDER ANY PAST, PENDING, OR FUTURE CLASS, COLLECTIVE, OR REPRESENTATIVE ACTION AGAINST THE COMPANY BY SOMEONE ELSE.
Scope of Arbitration Provision: Unless you opt out, you and the Company agree that any claim, controversy or dispute between you and the Company (the “parties”) arising out of or relating to your access to or use of any of the Web Sites/Applications or Content will be resolved exclusively through final and binding arbitration, rather than in court or before a jury, regardless of whether such claim, controversy or dispute arose prior to, on, or subsequent to the date of your acceptance of the Company’s policies including these rules and its Terms of Use. This agreement to arbitrate (“Arbitration Agreement”) is intended to be broadly interpreted and, except as provided in the preceding sentence, includes any dispute, claim, or controversy between you and the Company arising out of or relating to any aspect of your relationship with the Company or any conduct or failure to act on the part of the Company (including claims based on breach of contract, tort (for example, a negligence claim), violation of law or any claims based on any other theory) or any aspect of your access to or use of the Content.
Limitation on Period in which Claims May be Brought: YOU AND THE COMPANY AGREE THAT ANY CLAIMS, REGARDLESS OF FORM, ARISING OUT OF OR RELATING TO YOUR ACCESS TO OR USE OF ANY THE COMPANY’S WEB SITES/APPLICATIONS OR TO THE CONTENT SHALL BE MADE BY FILING FOR ARBITRATION WITHIN ONE (1) YEAR FOLLOWING THE OCCURRENCE FIRST GIVING RISE TO THE CLAIM(S). If the provision in the previous sentence is held to be unenforceable, then any claim(s) against the Company must be made by filing for arbitration within the limitations period designated by the state or federal law underlying the claim(s). If any claim is not brought within the applicable period discussed above, it is permanently barred, and the parties cannot bring that claim in any manner or in any forum.
Costs of Arbitration: If the value of your claim does not exceed $10,000, the Company will pay for the reasonable filing, administrative and arbitrator fees associated with the arbitration in the event such fees exceed $200, unless the arbitrator finds that either the substance of your claim or the relief sought was frivolous or brought for an improper purpose. In addition, if you are able to demonstrate that the costs of arbitration will be prohibitive as compared to the costs of litigation, the Company will pay as much of your filing and hearing fees in connection with the arbitration as the arbitrator deems necessary to prevent the arbitration from being cost-prohibitive. You will still be responsible for paying your own attorneys’ fees.
Arbitration Procedure: The provisions of this Section shall constitute your and the Company’s written agreement to arbitrate all Disputes, and you and the Company agree that the American Arbitration Association (“AAA”) will administer the arbitration under its Commercial Arbitration Rules and the Supplementary Procedures for Consumer Related Disputes in effect at the time arbitration is sought. Those rules are available at www.adr.org or by calling the American Arbitration Association at 1-800-778-7879. The parties acknowledge that the Company’s policies including these rules and its Terms of Use evidence a transaction involving interstate commerce. Notwithstanding any provision of the AAA Rules, any dispute over the formation, enforceability, validity or severability of any provision of this Section (“DISPUTE RESOLUTION BY BINDING ARBITRATION AGREEMENT”) shall be resolved by a court and not be a subject of the arbitration.
The arbitrator shall have no authority to amend or modify the terms of this Arbitration Agreement or to award punitive or exemplary damages, except as expressly authorized by law. The arbitration award may be enforced by judgment in any court of competent jurisdiction. Before, during, or after arbitration each party shall have the right, without awaiting the outcome of the arbitration, to seek interim injunctive relief from an appropriate court including but not limited to temporary restraining orders or preliminary injunctions. Seeking any such remedies shall not be deemed a waiver of either party’s right to compel arbitration.
The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve all disputes arising out of or relating to the interpretation, applicability, enforceability, or formation of these Terms, including, but not limited to any claim that all or any part of these Terms are void or voidable, or whether a claim is subject to arbitration. The arbitrator may award on an individual basis any relief that would be available pursuant to applicable law and will not have the power to award relief to, against or for the benefit of any person who is not a party to the proceeding. The arbitrator will make any award in writing but need not provide a statement of reasons unless requested by a party. The arbitrator’s decision shall be final and binding and may be entered as a judgment in any court of competent jurisdiction.
Prior to initiating arbitration, you must first send a written notice by email to the Company at legal@exclusivegaming.net. The arbitration notice must include the following at a minimum: (a) personal and/or account information sufficient enough to identify your user account, (b) a detailed description of your claim or dispute with the Company, and (c) the specific damages or other remedy or remedies that you are seeking. If your claim or dispute is not resolved with the Company within thirty days of the Company’s receipt of your arbitration notice that conforms with these requirements, then you may commence arbitration according to the requirements in these Terms.
Procedure to Opt Out of Arbitration Provision: WHETHER TO AGREE TO ARBITRATION IS AN IMPORTANT DECISION. IT IS YOUR DECISION TO MAKE AND YOU SHOULD NOT RELY SOLELY ON THE INFORMATION PROVIDED IN THESE RULES AND THE COMPANY’S POLICIES INCLUDING ITS TERMS OF USE, AS IT IS NOT INTENDED TO CONTAIN A COMPLETE EXPLANATION OF THE CONSEQUENCES OF ARBITRATION. YOU SHOULD TAKE REASONABLE STEPS TO CONDUCT FURTHER RESEARCH AND TO CONSULT WITH OTHERS (AT YOUR COST) REGARDING THE CONSEQUENCES OF YOUR DECISION.
You will be subject to the Company’s policies, including these rules and the Terms of Use at all times. However, if you do not agree to be subject to this arbitration agreement, you must opt out of this arbitration agreement within 30 days of entering this agreement, in the following specified manner: Send written electronic Notice via email to legal@exclusivegaming.net. You must send such Notice within thirty (30) days of your acceptance of the Company’s Terms of Use. You must include in it your name, address, and a clear statement that you do not wish to resolve disputes with the Company through arbitration. If you do not follow this procedure by your thirty (30) day deadline to do so, then you and the Company shall both be bound by the terms of this section entitled Dispute Resolution by Binding Arbitration Agreement.

USER’S PERSONAL INFORMATION:

Information collected from Users is subject to the Company‘s Privacy Policy.

QUESTIONS:

If you have questions, you may contact us at info@exclusivegaming.net.

Have questions?

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