General Terms and Conditions

Interpretation

In the Customer Agreement:

(a) Headings and underlining are for convenience only and do not affect the construction of the Customer Agreement.

(b) Where a word or phrase is given a defined meaning in the Customer Agreement, any other grammatical form in respect of such word or phrase shall, unless the context indicates otherwise, have a corresponding meaning.

(c) A provision of the Customer Agreement will not be interpreted against a party because the party prepared or was responsible for the preparation of the provision, or because the party’s legal representative prepared the provision.

(d) any provision in a definition is a substantive provision imposing rights or obligations on any party, notwithstanding that it is only in Section ‎2, effect shall be given to it as if it were a substantive provision in the body of the Customer Agreement.

(e) Unless specified expressly to the contrary, all references to currency or “$” refers to US dollars.

(f) A reference to a statute or regulation includes amendments thereto.

(g) A reference to time is to time in Delaware i.e. EST/EDT.

(h) A reference to a person includes a reference to an individual, a partnership, a company, a joint venture, government body, government department, and any other legal entity.

(i) The words “includes”, “including” and similar expressions are not words of limitation.

Definitions

In the General Terms and Conditions, the following expressions shall have the respective meanings assigned to them, unless otherwise defined:

Account refers to the account registered with us through the Platform, regardless of whether it is considered an Inactive Account.

Alternative Payment Method refers to the method you use to receive cash redeemed from Redeemable Diamonds, excluding the Payment Method.

Authorized Persons refers and includes each member of the Company Group, and each of their respective officers, directors, employees, agents, suppliers, contractors, service providers, licensees, partners, successors and assigns, and each of the foregoing successors and assigns.

Company, we, our or us refers to RAFFLEFY LIMITED, with an address at 205 Christodoulou Chatzipavlou, Louloupis Court, 2nd Floor, Office 201 Limassol, Cyprus 3036.

Company Group refers to the Company, any company that, whether directly or indirectly, controls, is controlled by, or under common control with the Company, where "control" (including, with correlative meanings, the terms "controlling", "controlled by" and "under common control with") means the power to manage or direct the affairs of the person in question, whether by ownership of voting securities, by contract or otherwise, and any of the foregoing's exclusive suppliers.

Content refers to any material including any text, graphics, user interfaces, visual interfaces, images, trademarks, logos, sounds, music, artwork, source code and other materials used, presented or made available as part of the Games and/or Platform. Content includes Gold Coins, Diamonds, RUM, Extra Diamonds Spins and any other virtual currency used on the Platform.

Customer Agreement has the meaning ascribed to it in the preambles.

Customer Support refers to our user support function, contactable at [email protected].

Dispute shall have the meaning given to it in Section ‎‎19.

Diamonds refers to the virtual coins that enable participation in Diamonds Game Play, which is offered in a sweepstakes-style format.

Diamonds Game Play refers to the Games which are played with Diamonds.

Error refers to any malfunctions, data loss, downtime, delays, interruption or technical disturbances or any other disruption in the Platform, Games or Content.

Force Majeure Event refers to an event beyond the reasonable control of the Company including without limitation, non-performance by suppliers or subcontractors, acts of God, acts of government, fire, flood or storm damage, earthquakes or other natural disaster, labor disputes, trade disputes, explosion, strikes, industrial action, lockouts, war, riot, pandemic or epidemic.

Extra Diamonds Spins refers to virtual gameplay entries granted to Users for use in designated Diamonds Game Play, which is offered in a sweepstakes-style format.

Games refers to the games made available through the Platform from time to time.

General Terms and Conditions refer to these general terms and conditions, as updated from time to time.

Gold Coins refers to the virtual coins that enable participation in Gold Coins Game Play.

Gold Coins Game Play refers to the Games which are played with Gold Coins.

Improvement Suggestion shall have the meaning ascribed to it in Section 8.2 of these General Terms and Conditions.

Inactive Account shall have the meaning given to it in Section ‎‎5.1

Incorporated Policies has the meaning ascribed to it in the preambles.

Intellectual Property Rights refers to all past, present, and future rights of the following types, which may exist or be created under the laws of any jurisdiction in the world: (i) rights associated with works of authorship, including exclusive exploitation rights, copyrights, moral rights, and mask work rights; (ii) trademarks, service marks, trade dress, logos, trade names, domain names, URLs and corporate names, together with all translations, adaptations, derivations, and combinations thereof and including all goodwill associated therewith, and all applications, registrations, and renewals in connection therewith; (iii) trade secret rights; (iv) patent rights (including patent applications and disclosures); (v) other proprietary rights in intellectual property of every kind and nature; and (vi) rights in or relating to registrations, renewals, extensions, combinations, divisions, and reissues of, and applications for, any of the rights referred to in (i) through (v) of this paragraph.

JAMS has the meaning ascribed to it in Section ‎19.5 of these General Terms and Conditions.

JAMS Mass Rules has the meaning ascribed to it in Section ‎19.8of these Terms and Conditions.

JAMS Optional Arbitration Appeal Procedures refers to the appeal procedure set by JAMS that is then in place at the time of the appeal.

JAMS Rules and Procedures has the meaning ascribed to it in Section ‎19.5 of these General Terms and Conditions.

License refers to the license granted to you under Section 8.3 of these General Terms and Conditions.

Modifications has the meaning ascribed to it in Section 8.1.1 of these General Terms and Conditions.

Moral Rights refers to an author’s right of attribution and integrity under the Visual Artists Rights Act (VARA), 17 U.S. Code § 106A or other analogous statutory right anywhere in the world.

Notice of Dispute has the meaning ascribed to it in Section 19.1.

Participate refers to access or use any of the Platform, Content, or any Game for any purpose. Participation has a corresponding meaning.

Payment Method refers to the accepted payment method used to purchase Gold Coins and to receive cash redeemed from Redeemable Diamonds.

Personality Rights has the meaning ascribed to it in Section 8.4.

Platform refers to the website located at www.bigpirate.com and all of its subdomains, subpages and successor sites thereof and the application which links to these General Terms and Conditions through which the Services are provided.

Prizes refers to any prizes granted to you through your use of Redeemable Diamonds in accordance with the Customer Agreement.

Promotion has the meaning ascribed to it in Section ‎15.1.

Redeemable Diamonds refers to virtual coins granted upon winning Diamonds Game Play, which may be redeemed for Prizes.

Registered Customer means an individual who has successfully registered an Account on the Platform, whether the Account is then active or not.

Restricted Jurisdictions refer to:

1. Any jurisdiction outside of the United States.

2. In the United States, the following states: California, Connecticut, Idaho, Louisiana, Michigan, Montana, Nevada, New Jersey, New York, Tennessee, and Washington.

3. In the United States, any Indian land.

Services means the Games and any other services made available through the Platform.

Special Terms have the meaning ascribed to it in the preambles.

Taxes have the meaning ascribed to it in Section ‎12.10.

Third-Party Sites have the meaning ascribed to it in Section ‎16.1.

Threshold has the meaning ascribed to it in Section ‎12.13.

User, you or your refers to any person who Participates, including Registered Customers.

User Generated Content refers to the content, which is submitted, communicated shared, transmitted, posted, uploaded, or otherwise made available through the Platform (by way of example only, profile information, communications with other Users, with our Customer Support, whether privately or publicly, music, text, graphics, software, video clips, photographs, public messages, ideas, and comments) by Users and includes also any content (such as words, images, videos and/or audio) that Users opt to post, publish, input or upload to any social media page controlled by us or on our behalf.

Virtual Assets refers collectively to the various forms of virtual currency or gameplay entries available on the Platform, currently comprising Gold Coins, Diamonds, Redeemable Diamonds, Rum, and Extra Diamonds Spins.

Modification of the Customer Agreement; Modifications of the Platform, Service and Content

3.1 From time to time, we reserve the right to modify the Customer Agreement or any part thereof, including these General Terms and Conditions, by posting an amended version on the Platform and any such change shall come into effect and be binding upon you immediately.

3.2 It is your responsibility to ensure that you are aware of the correct, current terms and conditions of the Customer Agreement, including these General Terms and Conditions, and we advise you to check for updates on a regular basis.

3.3 If we update the Customer Agreement, including these General Terms and Conditions, in any way that would limit your then current rights, or which is to your detriment, or that otherwise may impact on your rights or obligations under the Customer Agreement, we will notify you when you next visit the Platform and you will be required to re-confirm your acceptance of the Customer Agreement. If, at any time, you do not accept the updated Customer Agreement, then you must cease using the Platform.

3.4 In general, if you do not agree with the amended version of the Customer Agreement or part thereof (as applicable), you must stop using the Platform, or any part thereof and you must terminate your Account in accordance with Section ‎7 (Termination and Suspension of Your Account).

3.5 We may at any time add, modify, remove, discontinue or suspend the Platform, Services or Content or any part thereof with immediate effect and without notice to you. In no event will the Company be liable to you for any loss, damage or liability suffered by you which results from any addition, modification, removal or suspension of the Platform, Services or Content or any part thereof and for the avoidance of doubt you will have no claims with respect to such addition, modification, removal or suspension.

Eligibility Criteria

4.1 In order to register an Account, access the Platform, use the Content, and play the Games, you must:

(a) be a natural person who is physically located in the United States and you are not located in or resident of any of the Restricted Jurisdictions;

(b) be able to form legally binding contracts under applicable law;

(c) be at least 21 years of age or the age of majority in the jurisdiction in which you normally reside, whichever is higher;

(d) not be listed on any U.S. Government list of prohibited or restricted parties;

(e) not be listed on any relevant PEP or sanctions lists;

(f) have a registered Account on the Platform, which is not a Dormant Account and is not closed, suspended or otherwise restricted;

(g) have no more than one (1) Account on the Platform; and

(h) comply with the remaining conditions listed in this Section ‎‎4.

4.2 You warrant and represent that:

(a) you will only access and use the Platform and play the Games for personal and recreational purposes, and not on behalf of or for the benefit of any third party;

(b) you will provide us with information that is correct, accurate, complete, up to date and not misleading, and you will promptly notify us if there are any changes to the information you have provided to us to maintain its correctness, accuracy and completeness;

(c) when purchasing applicable Virtual Assets (such as Gold Coins) that are offered for purchase on the Platform, you will only use a Payment Method that is owned by you and held in your name, and that is not a business or corporate financial account, and you will not use any funds that have been obtained as a result of, or that are otherwise tainted by, illegal activity;

(d) you shall not, nor shall you attempt to, sell, transfer, or exchange for value any Virtual Assets or your Account to any third party.

(e) your access to and use of the Platform, as well as your participation in the Games, shall at all times comply with applicable laws.

(f) you will not access or use the Platform or play any Game in connection with any fraud, collusion or any other illegal activity; and

(g) you understand that a breach of this Section ‎4 shall constitute a material breach of the Customer Agreement and, in certain circumstances, may also amount to fraud or another criminal offence subject to prosecution.

4.3 You can register a new Account here, if you do not already have an Account on the Platform.

4.4 Any employee, officer, director and former employee, officer and director (less than three years since such person ceased to be an employee, officer or director, as applicable) of the Company or any of member of the Company Group, any of their respective advertising agencies, service providers or consultants or any other entity or individual involved with the design, production, execution or distribution of the Platform, Services, Content, or part thereof and their immediate family (spouse, parents, siblings and children, whether the relationship is by birth, marriage or adoption) and household members (persons who share the same residence at for least three months of the year), are not eligible to access the Platform, register an Account, use the Content, Services, and play the Games.

4.5 You acknowledge and agree that we are unable to provide you with any legal advice or assurances and that registering an Account and using the Platform and play of the Games is lawful in the jurisdiction that you are located in. It is solely your responsibility to ensure that at all times you comply with the laws which apply to you.

Registration and Management of Account

Single Customer Account

5.1 To access and use the Services, you must first create an Account. You are permitted to have only one Account, which includes any Inactive Account. We retain the right to decline Account registration or to deactivate an existing Account at our sole discretion - this includes situations where we suspect the Account is not registered under your actual name. Additionally, we may impose restrictions on the number of Accounts that can be created, such as limiting one Account per device, IP address, payment method, or similar identifiers.

5.2 If you create or attempt to create more than one Account on the Platform, we may suspend or permanently close any or all of those Accounts and take further action as outlined in these General Terms and Conditions. If you discover that you have unintentionally registered multiple Accounts, you must inform us in writing without delay.

Responsibility for your Customer Account

5.3 As part of the Account registration process, you are required to provide us with your email address, and choose a password, unless you register your Account using the Facebook®, Google® or Apple® login functionality, in which case you will be able to login to the Platform using your Facebook®, Google® or Apple® credentials and giving consent to the social platform to provide contact details to the Platform. Please note that the Company is not affiliated, associated, authorized, endorsed by, or in any way officially connected with Facebook®, Google®, or Apple®, or any of their subsidiaries or affiliates. The use of these login functionalities is provided solely for your convenience, and the Company assumes no responsibility or liability for the services, actions, or data handling practices of these third parties.

5.4 You are solely responsible for your Account, and all activities and transactions through your Account which includes without limitation any unauthorized use of your Account and any activity and transactions linked to your Account. To this end, you are solely responsible with respect to:

(a) ensuring your Account, Account password and any other access credentials are kept safe and secure;

(b) not sharing your Account, password or other login credentials for the Platform with any other person or permit any person access to them, nor do anything that could jeopardize the security of your Account; and

(c) any and all access and use of, or activity on, the Platform via your Account, including Game play or purchase of any applicable Virtual Assets (such as Gold Coins) that are offered for purchase on the Platform, will be considered by us as an activity carried out by you.

We shall assume that any communications received through your Account have been made by you. Furthermore, you agree that we are not responsible for any use of your Account by any third party.

5.5 If you suspect or become aware that your Account’s security may be at risk - such as through loss, theft, or unauthorized disclosure of your login credentials - you must notify Customer Support immediately. We are not responsible for any harm or loss resulting from your failure to safeguard this information.

5.6 Usernames that promote commercial interests or are considered offensive may not be used. We reserve the right to request that you change your username or to change it ourselves without prior notice.

5.7 You acknowledge that you do not hold any ownership rights, title, or proprietary interest in your Account.

Changes to your Account

5.8 When setting up your Account, you will be required to provide certain information as requested by us. You acknowledge that it is your sole responsibility to ensure that all details associated with your Account remain accurate, complete, and current at all times. For clarity, the name on your Account must exactly match the name on your official government-issued ID, and the address listed must correspond with both the proof of address you provide and the billing address linked to any Payment Method used on the Platform.

5.9 You are required to promptly inform Customer Support of any updates to your personal details, including your name, residential address, email, mobile number, or any other information we hold about you, so that your Account can be updated accordingly.

No Account transfers

5.10 You are not permitted to sell, exchange for value, or transfer your Account or any Virtual Assets to another party, including transferring them from your Account to someone else’s Account.

5.11 Accounts and Virtual Assets may only be obtained directly from us.

5.12 Any violation or attempted violation of Sections ‎5.10 or 4.11 may result in the immediate termination of your Account, without limiting any other rights or remedies available to us.

Dormant Accounts

5.13 In the event you have not used any Virtual Assets on the applicable Game play for 40 consecutive days, such Virtual Assets in your Account will be forfeited and retained by us, and if you haven’t logged in for 60 consecutive days we will deem your Account as an "inactive account" ("Inactive Account").

5.14 You agree that we may determine, in our sole discretion, whether to later reinstate any Virtual Assets that have been so revoked\forfeited. If we determine that your Account qualifies as Inactive Account, we reserve the right to remove any associated Virtual Assets. We will not be held liable for exercising this right. You also acknowledge that any decision to reinstate forfeited Virtual Assets will be made solely at our discretion.

5.15 We may, at our sole discretion, inform you that your Account is at risk of becoming or has already become an Inactive Account. However, we are under no obligation to provide such notice.

5.16 If your existing Account becomes an Inactive Account but has not been formally closed by us, you agree not to create a new Account.

Closure of Customer Accounts

5.17 You may request to close your Account by contacting Customer Support.

5.18 By closing your Account, you acknowledge and accept that any Virtual Assets linked to it will be forfeited. Whether these Virtual Assets are reinstated upon reopening the Account is entirely at our discretion. If you wish to reopen your Account, please reach out to Customer Support.

5.19 We reserve the right, at our sole discretion, to refuse the registration, suspension, closure, or reopening of any Account. This includes situations where we suspect the Account is not registered under your actual name. We may also impose limitations on your Account.

5.20 If we suspend or close your Account:

(a) due to any of the reasons outlined in Section 7.3 of these General Terms and Conditions, the consequences described in Section 7.5 will apply; and

(b) for any reason, your License will be considered terminated, unless and until we decide to reinstate or reactivate your Account.

Verification

6.1Compliance Checks

You acknowledge that we may, at any time - including but not limited to when you create an Account, acquire any applicable Virtual Assets (such as Gold Coins) that are offered for purchase on the Platform, or receive Diamonds or Redeemable Diamonds - carry out verification procedures as we consider appropriate or as required by applicable laws and regulations. These procedures may be conducted through third-party service providers and may include, without limitation:

• Identity verification
• Credit history and background screening
• Assessment of source of wealth
• Review of source of funds
• Screening for politically exposed persons (PEPs)
• Evaluation of payment methods and measures to prevent financial crime

6.2 Information and Documentation Requirements

You may be asked to supply specific information and documents upon request, which may include but are not limited to:

• Details regarding your current location and residency status
• Social security number
• Contact information such as phone number and email address
• Date of birth
• Government-issued identification numbers
• Financial documents such as bank statements or pay slips
• Proof of residential address
• Valid government-issued ID
• Photographs of you

6.3 Accuracy and Updates

You confirm that all information and documentation provided to us is accurate, complete, and truthful. You agree to promptly notify us of any changes to this information. Failure to provide accurate or complete information may result in suspension or termination of your account. In the event that we request any photographs from you, then such photographs: (i) must be a recent photograph of you (taken in the last six months); (ii) must be in color; (iii) must show a clear and focused image solely of your full face looking straight at the camera with a plain expression and your mouth closed; (iv) must show your eyes open and visible; (v) must not have hair in front of your eyes; (vi) must not have anything covering your face; (vii) must not have any shadows on your face or behind you; and (viii) must not in any way be amended or modified.

6.4 Account Suspension or Termination

Your account may be suspended or terminated while we complete verification checks to our satisfaction. If you fail to provide the requested documentation or information within 40 days of our request, or if the verification checks are not satisfactorily completed, we reserve the right to suspend, terminate, or otherwise restrict your account at our discretion.

Politically Exposed Persons

7.1 You should inform us immediately if you are, have been within the preceding twelve (12) months, or become a Politically Exposed Person or a family member of a Politically Exposed Person, as these are defined below. You must also provide us this information when asked by us to confirm whether you are a Politically Exposed Person or not. Please refer to this section for more information and applicable rules.

7.2 A “Politically Exposed Person” or “PEP” means a natural person who is or has been entrusted with prominent public functions and includes his immediate family members or persons known to be close associates of such persons, but shall not include middle ranking or more junior officials. The term ‘“Politically Exposed Person” should be applied broadly and generally includes all persons who fulfil a prominent public function. This shall include those persons entrusted with prominent public function, i.e. other than as a middle-ranking or more junior official, including, but not limited to, the following:

• heads of state, heads of government, ministers and deputy or assistant ministers;
• members of parliament or of similar legislative bodies;
• members of the governing bodies of political parties;
• members of supreme courts, of constitutional courts or of other high-level judicial bodiesthe decisions of which are not subject to further appeal, except in exceptional circumstances;
• members of courts of auditors or of the boards of central banks;
• ambassadors, chargés d'affaires and high-ranking officers in the armed forces;
• members of the administrative, management or supervisory bodies of state-owned enterprises;
• directors, deputy directors and members of the board or equivalent function of an international organization;

Further, you should identify yourself as a PEP for a period of at least 12 months after the date on which you ceased to be entrusted with a public function.

A “family member of a PEP” includes, but is not limited to: a spouse of a PEP or partner of a PEP recognised by national law as equivalent to the spouse, children of a PEP and their spouses or partners, parents of a PEP.

A “close associate of a PEP” includes the following: an individual having joint beneficial ownership of a legal entity or a legal arrangement or any other close business relationship with a PEP; an individual who has sole beneficial ownership of a legal entity or a legal arrangement which is set up for the benefit of a PEP.

Termination and Suspension of Your Account

8.1 General Rights

The rights described in this Section are in addition to any other rights or remedies we may have under the Terms, the Customer Agreement, or applicable law.

You remain responsible for all activity conducted through your Account until it is formally terminated.

8.2 Termination by You

You may close your Account at any time by:

• Contacting Customer Support; or
• Initiating self-exclusion through the Platform, in accordance with our Responsible Social Gameplay Policy.

For more details, please refer to the Responsible Social Gameplay Policy.

8.3 Suspension or Termination by Us

Notwithstanding any other provision of these General Terms and Conditions, we reserve the right to suspend or terminate your Account at our sole discretion, including but not limited to the following circumstances:

• You breach, or we reasonably suspect you have breached, any provision of the General Terms and Conditions or the Customer Agreement;
• A chargeback is initiated on your Payment Method;
• We decide to discontinue the Services, either generally or specifically in relation to your Account;
• Any other grounds for termination or suspension as set out elsewhere in these General Terms and Conditions.

8.4 Consequences of Suspension

If your Account is suspended:

• You will be unable to access or use the Games, purchase any applicable Virtual Assets (such as Gold Coins) that are offered for purchase on the Platform, receive Diamonds, or otherwise use any of the Virtual Assets until the suspension is lifted at our discretion.
• We may still proceed to terminate your Account during the suspension period.

8.5 Consequences of Termination

Upon termination of your Account:

• All licenses granted to you under these General Terms and Conditions and Customer Agreement will immediately expire.
• You must cease all use of the Platform, its Content, and any associated Services or Virtual Assets.
• All Virtual Assets in your Account will be forfeited and retained by us.
• At our discretion, any unissued Prizes may be forfeited and retained.
• We may, at our discretion, retain any remaining balance in your Account.

Redemption of Redeemable Diamonds Post-Termination

• If your Account is terminated by you (Section 7.2) or by us due to discontinuation of Services specifically to you (Section 7.3), we may, at our discretion, allow you to redeem any unredeemed Redeemable Diamonds within 21 days of termination.
• This redemption is subject to the limitations and conditions as set out in the Sweep Rules, as well as the provisions of Section 12 of these General Terms and Conditions (Payment and Taxes).

8.6 Mutual Termination Effect

For clarity:

• Termination of your Account results in automatic termination of the Customer Agreement.
• Termination of the Customer Agreement results in automatic termination of your Account.

8.7 Survival of Terms

Termination of your Account does not affect any rights or remedies we may have under these General Terms and Conditions, the Customer Agreement, or applicable law. Any provisions that are intended to survive termination - either expressly or by their nature - shall remain in effect as long as necessary to fulfill their purpose.

Intellectual Property Rights; Restrictions and Licenses

9.1 Ownership and Restrictions

9.1.1. The Platform, Content, and Games are the exclusive property of the Company and are protected under applicable copyright laws, international treaties, and other intellectual property regulations. You acknowledge that all intellectual property rights related to the Platform, Content, and Games - including but not limited to software, trademarks, service marks, trade names, design elements, database rights, copyrights, visual layout, and overall presentation - along with any updates, enhancements, adaptations, or derivative works (“Modifications”), are and shall remain solely owned by the Company or its licensors. No rights are granted to you beyond those explicitly outlined in these General Terms and Conditions, particularly in Section ‎8.3, whether by implication, estoppel, or otherwise.

9.1.2. You agree not to:

• Copy, alter, or reproduce any part of the Platform, Content, or Games, including associated software and intellectual property, nor remove any copyright or trademark notices.
• Sell, lease, sublicense, assign, transfer, distribute, or otherwise dispose of the Platform, Content, or Games or any related software.
• Reverse engineer, decompile, disassemble, translate, or attempt to access the source code of any software used in connection with the Platform, Content, or Games.
• Share or make available the Platform, Content, or Games or related software to third parties via any network or other means.
• Use the Platform, Content, or Games in any way that violates applicable laws or regulations.

9.1.3. You must not take any action, directly or indirectly, that could challenge or undermine the Company’s (or its licensors’) ownership of the Platform, Content, Games, or any Modifications. All rights not expressly granted are reserved. Nothing in these General Terms and Conditions shall be interpreted as a transfer of intellectual property rights to you.

9.2 Improvement Suggestions

Any feedback, suggestions, or feature requests you or your personnel provide regarding the Platform or its components (“Improvement Suggestions”) shall become the sole property of the Company. You waive any claim to compensation or ownership and irrevocably assign all rights, including intellectual property rights, to the Company upon submission. This includes a waiver of any moral rights you may hold in such suggestions, allowing the Company and its authorized parties to use or modify them freely.

9.3 Limited License

Subject to your full compliance with the Customer Agreement, and for its duration, the Company grants you a personal, limited, revocable, non-exclusive, non-transferable, non-sublicensable license to use the Platform, Content, and Games - including any associated software - on a device you own or control. This license is strictly for personal, recreational, and entertainment use in connection with the Services.

9.4 Use of Personality Rights

By participating in Games or redeeming Prizes, and unless restricted by law, you grant the Company and any member of the Group Company a perpetual, worldwide, royalty-free, non-exclusive license to use your name, username, likeness, image, age, appearance, voice (including AI-generated voiceovers), opinions, and any content you generate (“Personality Rights”) in any format or medium now known or developed in the future. This license includes rights to display, perform, broadcast, reproduce, edit, adapt, and create derivative works for purposes such as marketing, promotion, product development, and distribution of the platform, games, coins, and prizes.

You release the Company and any member of the Group Company from any liability related to the use of your Personality Rights and waive any right to royalties or approval of the final materials. This release extends to the Company’s heirs, legal representatives, licensees, and assigns.

Game Rules and Game Terms

10.1 Game Rules

10.1.1. Individual Game Rules

Each Game available on the Platform is governed by its own specific rules, which are accessible directly through the Platform. It is your responsibility to review, understand, and comply with the rules of any Game you choose to play.

10.1.2. Void Participation

We reserve the right, at our sole discretion, to declare any participation in a Game void - either in whole or in part - if we identify any error, mistake, or technical fault.

10.1.3. Discrepancies in Results

In the event of any inconsistency between the result displayed on your device and the result recorded by our systems or those of the relevant third-party game provider, the latter shall prevail and be deemed the official outcome.

10.2 Gold Coins Usage and Terms

10.2.1. Use of Gold Coins

Gold Coins may only be used for Gold Coins Game Play. You must have a sufficient balance of Gold Coins in your Account to participate.

10.2.2. Ways to Receive Gold Coins

Gold Coins may be granted to you at our discretion through the following methods:

(1) purchase via the Platform’s Services,

(2) at regular intervals when logging into the Account, and

(3) from time-to-time via promotions. The number of Gold Coins awarded and any additional contest rules will be specified in the contest materials and\or Specific Terms applicable to such contest and are also subject to these General Terms and Conditions.

The Company may at its discretion also provide with a replenishment feature that allows Registered Customers to continue to play the Gold Coin Games even after their supply of Gold Coins is depleted. Thus, in such circumstances, Registered Customers may continue to play the Gold Coin Games without being required to purchase additional Gold Coins.

10.3 Gold Coins Terms of Purchase and Use

By purchasing or using Gold Coins, you acknowledge and agree to the following:

(a) You are purchasing a license to access Social Play; Gold Coins have no monetary value.

(b) Gold Coins are non-transferable and cannot be exchanged or redeemed for cash, other virtual currencies, or any item of value.

(c) All purchases and Prize redemptions are conducted in U.S. dollars. You are responsible for ensuring your Payment Method supports transactions in this currency.

(d) Upon purchase, the corresponding amount will be charged to your Payment Method. You are responsible for ensuring sufficient funds are available.

(e) We may impose minimum and maximum purchase limits, which can be modified at any time without prior notice.

(f) You are solely liable for any reversals, chargebacks, fees, penalties, or losses resulting from transactions made through your Account, whether authorized or not.

(g) Any third-party fees or charges incurred in connection with Gold Coin purchases are your responsibility.

(h) We do not offer credit facilities for purchasing Gold Coins.

(i) No purchase is required to participate in our Games. However, any purchase of Gold Coins is not considered a deposit and cannot be withdrawn.

(j) We reserve the right to modify, limit, expire, or remove Gold Coins at any time to comply with applicable laws, without liability to you.

(k) Except where required by law, all Gold Coin purchases are final and non-refundable. You may not transfer, sell, assign, or trade Gold Coins. Any attempt to do so is strictly prohibited and void.

(l) Refunds or credits may be issued at our sole discretion. A refund or credit granted in one instance does not obligate us to provide the same in future cases.

(m) In the event you have not used any Gold Coins on Gold Coins Game Play or any Sweep Coins on Sweep Coins Game Play for 40 consecutive days, Gold Coins in your Account will be forfeited and retained by us.

10.4 Loyalty Program

10.4.1. Description and Purpose

Rum is a virtual currency that may be available to Users from time to time as a loyalty program. It will be made available to Users for use exclusively in the Sweepstakes promotions. Rum is intended solely for entertainment and gamification purposes and may not be used in Gold Coins Game Play.

Rum cannot be purchased and is not linked to the amount entered or the outcome of any gameplay.

10.4.2. Restrictions and Limitations

• Rum has no monetary value and cannot be redeemed, exchanged, or transferred for cash, other virtual currencies, or any item of value.
• Rum is non-transferable between Users and may not be sold, traded, or gifted.
• Rum balances may be forfeited in accordance with inactivity provisions or upon termination of the Account.

10.4.3. Modification and Removal

We reserve the right to modify, suspend, or discontinue the availability or functionality of Rum at any time, without prior notice. We shall not be liable for any loss or damage resulting from such changes.

Submitting a Complaint

11.1 If you wish to raise a complaint, please contact our Customer Support. To ensure we can process your request efficiently, your message must include the following:

1. A clear and detailed description of your complaint or claim;

2. Your username and full name as registered in your Account;

3. The email address linked to your Account at the time of submission;

4. Any relevant details and supporting documentation, such as dates, times, and screenshots.

11.2 You also agree to provide any additional information or materials we may request in connection with your complaint or claim. Failure to supply the required information and documentation in a timely manner may delay our ability to assess and respond to your complaint or claim.

11.3 Subject to Section ‎‎2, our Customer Support team will review your submission and aim to issue a decision within thirty (30) days of receiving your complaint or claim.

11.4 All decisions made by us shall be considered final and binding, unless you choose to pursue the process outlined in Section ‎‎20 (Dispute Resolution and Arbitration Agreement).

Malfunctions, Errors, and Mistakes

12.1 You acknowledge and accept that:

(a) We are not liable for any Errors related to the Platform, including those occurring during gameplay or resulting from attempts to use the Platform or its Games in a manner inconsistent with our intended use;

(b) We are not responsible for any loss or damage incurred by you or any third party arising from use of the Platform or its content, including any inaccuracies or errors.

12.2 We reserve the right to declare any Game participation null and void, in whole or in part, if we determine that an Error, misprint, mistake, or technical issue has occurred in the Game rules or software. In such cases, we may revoke and deduct any Virtual Assets awarded to you, and you agree that these may be invalidated and removed from your Account.

12.3 You agree that we may, at our sole discretion, void your gameplay - either partially or entirely - if we identify any malfunction, Error, or improper operation of the Platform or Games. This includes issues related to pay-tables, win-tables, stakes, odds, or Game software. We may revoke any Virtual Assets awarded to you under such circumstances, and you agree that these may be invalidated and deducted from your Account.

12.4 In the event of a system Error or malfunction affecting the Platform, Services, or any Game, all gameplay resulting from such issues will be considered void. We may revoke and deduct any Virtual Assets awarded to you, and you agree that these may be invalidated and removed from your Account.

12.5 If there is a discrepancy between the results displayed on the Platform and those recorded in our back-end systems or the Game provider’s software, the latter shall be deemed accurate and will prevail.

12.6 If a Game fails to complete due to a system malfunction, we will make reasonable efforts to restore any lost Virtual Assets to your Account.

12.7 If your Virtual Assets or winning gameplay are confirmed by us to have been mistakenly deleted, lost, corrupted, or otherwise destroyed, your sole remedy will be the replacement of an equivalent amount of Virtual Assets.

12.8 If you are mistakenly awarded any Virtual Assets due to:

• Human or technical Error;
• Mistakes made by us or on our behalf;
• Bugs, defects, viruses, or other issues in the Platform, Services, or Content; or
• Games failing to operate according to their rules, then we are not obligated to honor such awards or Prizes. We may revoke and deduct any such items from your Account, and you agree that they may be invalidated and removed.

Removal of Games and Platform Changes

12.9 You acknowledge and agree that:

(a) We may update, add, or remove any Game or Content from the Platform at any time without prior notice;

(b) We may discontinue the availability of the Platform, any Game, or any Content in your jurisdiction at any time without prior notice;

(c) We are not liable for any loss or damage resulting from such updates, removals, suspensions, or discontinuations.

Payments and Taxes

Payment Methods

13.1 Any Payment Method or Alternative Payment Method you use must:

(a) Be registered solely in your name and legally belong to you;

(b) Be under your legal and beneficial ownership.

If we discover or reasonably suspect that the name on your Account differs from the name associated with your Payment Method, we reserve the right to suspend or terminate your Account immediately.

13.2 Funds used to purchase applicable Virtual Assets (such as Gold Coins) that are offered for sale on the Platform must not originate from any unlawful activity.

13.3 We may adjust the pricing of applicable Virtual Assets (such as Gold Coins) that are offered for sale on the Platform at our discretion. Additionally, we reserve the right to apply processing fees to purchases of such Virtual Assets or to payments made in connection with receiving Prizes.

13.4 All transactions involving the purchase of applicable Virtual Assets (such as Gold Coins) that are offered for sale on the Platform or the redemption of Redeemable Diamonds are conducted in U.S. Dollars. It is your responsibility to ensure that your payment method supports transactions in this currency.

13.5 We may appoint third-party payment processors or agents to handle payments on our behalf. We are not liable for any loss or damage resulting from the actions or omissions of these agents. You authorize us and any appointed payment processors to securely store your payment credentials (e.g., card number or token) for future transactions, in accordance with applicable payment regulations.

13.6 You are fully responsible for any chargebacks, reversals, claims, fees, penalties, or other losses incurred by us due to payments made through your Account, whether or not authorized by you. If any transaction is reversed or returned, the amount will be considered a debt owed to us and must be repaid immediately.

13.7 Unless required by law, all payments made to us are final and non-refundable. Refunds or credits may be issued at our sole discretion, and any such issuance does not obligate us to provide similar refunds or credits in the future.

13.8 You are responsible for any foreign exchange fees, charges, or related costs incurred in connection with payments to or from us, including losses due to currency fluctuations.

Taxes

13.9 You confirm that you are not subject to backup withholding by the IRS because:

(a) You are exempt from backup withholding;

(b) You have not been notified by the IRS that you are subject to backup withholding due to underreporting; or

(c) The IRS has informed you that backup withholding no longer applies.

13.10 All payments made by you to us, and your redemption of any Redeemable Diamonds for Prizes are exclusive of all taxes, duties, levies, charges and similar governmental assessments, including sales taxes, uses tax, value-added taxes, goods and services taxes, excise, business, service, and similar transactional taxes imposed by any jurisdiction and the interest and penalties thereon, excluding taxes based on our net income (collectively “Taxes”), which you solely shall be responsible to pay.

13.11 Payments made by us, including redemptions of Redeemable Diamonds for Prizes, are inclusive of applicable Taxes, which remain your responsibility. We reserve the right to charge you for such Taxes or apply a fee to offset them.

13.12 If we are legally required to withhold Taxes from any Prize payment, the withheld amount will be considered as paid to you. We may also charge you for any applicable Taxes or apply a fee to offset them.

13.13 If your total redemptions of Redeemable Diamonds reach or exceed $600 USD within a calendar year (the “Threshold”), we may temporarily suspend your ability to redeem until you complete and return a 1099-MISC form to our satisfaction. You may be asked to provide the last four digits or full Social Security Number, along with other necessary information, via email to our Customer Support, or through any other form or media provided or facilitated by the Company, including downloadable forms made available on the Platform. We may send the form to you by email, or through any other form or media provided or facilitated by the Company, including downloadable forms made available on the Platform, which must be completed and returned accurately.

We may also request additional documentation related to your redemptions exceeding the Threshold. Any information you provide may be shared with relevant tax authorities and service providers.

You are solely responsible for reporting and paying any applicable federal, state, or local taxes on Prizes and Redeemable Diamonds.

Nothing in this section limits our right to conduct verification checks as outlined in Section ‎6 (Verification), or to suspend or terminate your Account.

13.14 You acknowledge that we do not provide legal or tax advice. It is your sole responsibility to ensure that your use of the Platform, including participation in Games and redemption of Prizes, complies with the laws of your jurisdiction. If you require tax advice, please consult a qualified advisor.

13.15 No Financial Institution Status

We are not a financial institution, and you agree not to treat us as such. No interest will accrue on unredeemed Redeemable Diamonds. You are strictly prohibited from using the Services for arbitrage or currency exchange transactions. Any gains resulting from such prohibited activity may be forfeited and deducted from your balance without prior notice.

Prohibited Conduct: Fraud and Illegality

14.1 General Prohibition

You shall not engage in any fraudulent, unlawful, or prohibited activity in connection with your use of the Platform, including but not limited to its Content, Games, Services, Virtual Assets, or any associated Prizes.

14.2 Enforcement and Examples

Should we, in our sole discretion, determine or reasonably suspect that you have participated in or facilitated any fraudulent or illegal conduct, we reserve the right to suspend or permanently terminate your Account without prior notice. Illustrative examples of such conduct include, but are not limited to:

• Use of illicitly obtained funds;
• Submission of false, misleading, or manipulated information or documentation;
• Tampering with documents provided to us;
• Disruption of other users’ access to or enjoyment of the Services;
• Breach of terms applicable to any accepted Payment Method;
• Unauthorized access to or use of another user’s account;
• Actions that impair or interfere with the functionality or integrity of the Platform or Services;
• Circumvention of security protocols, including accessing the Platform after opting out of Services;
• Intentional disconnection from Games;
• Unauthorized scraping, indexing, framing, linking, or copying of Platform content;
• Commercial exploitation of the Platform or Services, including benchmarking or competitive analysis;
• Manipulation of Game timing or features to avoid play requirements;
• Cheating or collusion in any form;
• Hacking or unauthorized access to the Platform, Services, or Games;
• Exploitation of software bugs or malfunctions;
• Use of automated tools (e.g., bots) to access or interact with the Services;
• Strategic retention and re-entry into Games to exploit bonus features;
• Disruption of Service performance or integrity;
• Use of automated data collection tools (e.g., spiders, scrapers);
• Abuse of promotional offers or bonus systems;
• Violation of applicable laws or regulations;
• Use of IP masking techniques (e.g., VPNs) to misrepresent location;
• Evasion of geographic restrictions;
• Falsification of personal or payment information;
• Introduction of malicious software or unauthorized access to our or our service providers’ systems.

14.3 Additional Restrictions

You further agree not to, and shall not permit any third party to: (a) Access any account other than your own authorized Customer Account; (b) Upload or transmit content relating to any individual without their consent, or otherwise infringe upon the legal rights of any person or entity; (c) Initiate chargebacks for Gold Coin purchases made by you; (d) Use the Platform in violation of any applicable law, including data protection, intellectual property, and anti-spam legislation; (e) Infringe upon third-party Intellectual Property Rights, including unauthorized software use or distribution; (f) Share your Account credentials or allow unauthorized access to your Account; (g) Engage in conduct that is offensive, harassing, or otherwise unlawful under applicable workplace or harassment laws; (h) Offer or promote fraudulent goods or services; (i) Upload or disseminate content that is defamatory, obscene, abusive, discriminatory, or otherwise unlawful; (j) Conduct or attempt any security breach, including unauthorized access, denial-of-service attacks, or data corruption; (k) Monitor or intercept data transmissions without authorization; (l) Interfere with the availability or performance of the Platform for others; (m) Send unsolicited communications in violation of applicable anti-spam laws; (n) Use the Platform to harass others via messaging or email; (o) Reverse engineer, decompile, disassemble, or otherwise attempt to derive source code or create derivative works from the Platform or Games.

14.4 Monitoring and Reporting of Prohibited Conduct; Transaction Oversight and Cooperation

We maintain active oversight of all transactions conducted through the Platform to detect and prevent money laundering, financial crime, and other unlawful activities. Where we reasonably suspect any fraudulent, illegal, or improper conduct, we reserve the right to disclose your identity and relevant details to competent authorities, financial institutions (including banks, credit card issuers, and electronic payment providers), and other online service providers. You agree to fully cooperate with any investigation initiated by us or any such authority.

14.5 Account Suspension and Disclosure

In the event that we suspect you have breached the Customer Agreement or engaged in any fraudulent, unlawful, or otherwise prohibited activity in connection with the Platform or the Games, we may, at our sole discretion and without prior notice:

• Suspend, restrict, or permanently close your Customer Account;
• Decline to reverse or refund any applicable Virtual Assets (such as Gold Coins) purchases made prior to such action;
• Share relevant information concerning you and the suspected activity with regulatory bodies and/or law enforcement agencies.

14.6 Authority Notification and Investigation Support

We reserve the right to notify relevant governmental authorities, financial institutions, and online service providers of any suspected unlawful, fraudulent, or improper conduct associated with your use of the Platform. You are required to cooperate with us, as well as with any applicable regulatory or law enforcement authority, in connection with any inquiry or investigation into suspected fraudulent, unlawful, or prohibited activity.

14.7 Duty to Report

If you become aware of or suspect that any individual has engaged in unlawful, fraudulent, or improper conduct in relation to the Platform or the Games, you must promptly report such activity to us via Customer Support.

Responsible Social Gameplay

15.1 Commitment to Responsible Use

We are committed to fostering a secure, balanced, and responsible gaming environment for all users of the Platform. For further details on how we support responsible gameplay, please refer to our Responsible Social Gameplay Policy, which outlines available tools and resources to help you maintain a healthy relationship with the Platform.

15.2 Self-Exclusion and Purchase Limits

Our Responsible Social Gameplay Policy allows you, at any time, to:

• Request a temporary break from gameplay;
• Permanently close your Account through self-exclusion; and
• Set personal limits on the purchase of applicable Virtual Assets (such as Gold Coins) that are offered for purchase on the Platform.

These measures are designed to promote responsible use and mitigate the risk of excessive or harmful gameplay behavior.

15.3 Limitation of Liability

We shall not be held liable in the following circumstances:

• Where enforcement of our Responsible Social Gameplay Policy is hindered or rendered impracticable due to a Force Majeure Event; or
• Where you intentionally circumvent or attempt to bypass the security and protective measures implemented under the Policy, including continued use of the Platform or its content in contravention of such safeguards.

Promotions, Bonus Offers, and Special Offers

16.1 Applicability and Governing Terms

From time to time, we may make available various promotional offers, bonus-style incentives, or special offers (collectively, “Promotions”). All Promotions are subject to the terms and conditions set forth in the Customer Agreement, as well as any Specific Terms applicable to the relevant Promotion, which shall be made available to you at the time of the offer.

16.2 Right to Modify or Withdraw

You acknowledge and agree that we reserve the right, at our sole discretion, to modify or withdraw any Promotion at any time prior to your initial participation in such Promotion, without prior notice or liability.

16.3 Abuse and Misconduct

If we reasonably suspect that you have engaged in, or attempted to engage in, abuse or misuse of any Promotion, or have otherwise participated in fraudulent, unlawful, or improper conduct in connection with such offers, we may, without limitation and at our sole discretion:

• Deny, withhold, or revoke any Promotion;
• Rescind any promotional benefit or related policy applicable to you, either temporarily or permanently;
• Suspend or terminate your Customer Account.

Third-Party Sites and Advertising

17.1 External Links and Advertisements

The Platform, Services, and Platform Content may contain links to, or display advertisements for, websites, applications, products, services, or activities that are not owned, operated, or controlled by us (“Third-Party Sites”). These links and advertisements are provided solely for your convenience.

17.2 No Endorsement or Liability

The inclusion of any link or advertisement does not constitute an endorsement, sponsorship, or recommendation by us of the Third-Party Site or its content, products, services, or activities. We expressly disclaim any responsibility or liability for any content, offerings, or representations made by such Third-Party Sites.

17.3 Use at Your Own Risk

Your access to and use of any Third-Party Site is entirely at your own risk and is subject to the applicable terms and conditions and privacy policies of the Third-Party Site. We do not guarantee the accuracy, safety, legality, or reliability of any Third-Party Site or its content.

17.4 No Responsibility for Third-Party Conduct

You acknowledge and agree that:

• We are not responsible for the privacy practices, content, or security of any Third-Party Site;
• Clicking on links to Third-Party Sites may result in the collection or sharing of your personal data by third parties;
• Any concerns, complaints, or disputes regarding Third-Party Sites or advertisements should be directed to the relevant third party;
• We strongly encourage you to review the terms of service and privacy policies of any Third-Party Site before engaging with it.

17.5 No Relationship or Authorization

The presence of a link or advertisement does not imply any affiliation, partnership, or relationship between us and the Third-Party Site. We do not authorize any third party to offer or distribute Virtual Assets. You acknowledge and agree that:

• Certain Third-Party Sites may falsely claim to offer Virtual Assets;
• Any such offers should be considered fraudulent;
• We are not responsible for any Virtual Assets not directly offered or distributed by us.

Disclaimer of Warranties

18.1 Platform Provided “As Is”

To the fullest extent permitted by applicable law, the Platform, including without limitation the Services, Games, Content, any of the Virtual Assets, Prizes, and any other features, functionalities, or virtual items made available through the Platform, are provided on an “as is” and “as available” basis. We do not make, and expressly disclaim, any representations or warranties of any kind, whether express, implied, statutory, or otherwise, including but not limited to:

• The accuracy, completeness, reliability, or currency of the Platform, including without limitation the Services, Games, Content, any of the Virtual Assets, Prizes, and any other features, functionalities, or virtual items made available through the Platform;
• The uninterrupted or error-free operation of the Platform or Services or any part thereof;
• The availability, quality, or suitability of the Games or Services or any part thereof;
• The merchantability, fitness for a particular purpose, or non-infringement of the Platform, including without limitation the Services, Games, Content, any of the Virtual Assets, Prizes, and any other features, functionalities, or virtual items made available through the Platform;
• The security of the Platform or that it will be free from viruses, malware, or other harmful components.

18.2 No Guarantee of Access or Functionality

We do not guarantee that the Platform, Services, Content or Games will be available at all times or in all locations, or that access will be uninterrupted or secure. We may suspend, withdraw, or restrict access to any part of the Platform at any time, without notice, for maintenance, upgrades, legal compliance, or other reasons.

18.3 User Responsibility and Risk

You acknowledge and agree that your use of the Platform, Services, Content and Games is entirely at your own risk. You are solely responsible for ensuring that your use of the Platform complies with all applicable laws, regulations, and third-party terms, including those relating to internet access, data usage, and local gaming restrictions.

Indemnity, Additional Disclaimers, and Limitation of Liability

19.1 Indemnification

You agree to indemnify, defend, and hold harmless the Authorized Persons from and against any and all claims, liabilities, losses, damages, costs, and expenses (including reasonable legal fees) arising out of or related to:

(a) your access to or use of the Platform or any component thereof;

(b) the devices or systems you use to engage with the Platform;

(c) your acquisition or use of any of the Virtual Assets;

(d) any breach by you of the Customer Agreement; or

(e) any infringement or violation by you of Company’s or its licensors’ intellectual property rights.

19.2 Assumption of Risk

You acknowledge and accept that your use of the Platform is entirely at your own risk.

19.3 Exclusion of Damages

To the maximum extent permitted by applicable law, in no event shall any of the Authorized Persons be liable to you for any indirect, incidental, consequential, special, exemplary, or punitive damages - including, without limitation, loss of profits, business opportunities, revenue, data, goodwill, or legal fees - arising out of or related to:

• your use of or inability to use the Platform, its Content, or Prizes;
• any act or omission by Company;
• the conduct or content of any third party on or through the Platform, including defamatory, offensive, or unlawful behavior;
• unauthorized access to or alteration of your data or communications; or
• any other matter connected to the Platform, Services, Games, Content, or Prizes.

This exclusion applies regardless of the legal theory asserted, whether in contract, tort (including negligence), statute, or otherwise, and even if Company was advised of or should have foreseen the possibility of such damages.

19.4 Cap on Liability

Subject to applicable law, the total aggregate liability of the Company and each of the Authorized Persons under the Customer Agreement shall not exceed the monetary value of applicable Virtual Assets purchased by you within the thirty (30) days immediately preceding the date of your first claim. If no such purchase was made during that period, your sole and exclusive remedy shall be to terminate your account and discontinue use of the Platform.

19.5 Time Limitation on Claims

To the fullest extent permitted by law, any claim or cause of action arising out of or related to your use of the Platform or the Customer Agreement must be initiated within one (1) year from the date the claim or cause of action first arose.

19.6 Reasonableness of Terms

You acknowledge that the indemnity and limitation of liability provisions in this Section are reasonable and necessary to protect the legitimate interests of the Company and the Authorized Persons, and that you have reviewed and accepted these terms as part of your agreement to be bound by the Customer Agreement.

19.7 Additional Disclaimers

Any disclaimers presented within the Platform or its content are incorporated herein by reference. Where such disclaimers impose stricter limitations on your use of the Platform or content, those stricter limitations shall prevail.

19.8 Jurisdictional Exceptions

If any portion of this Section is deemed unenforceable under applicable law, it shall apply to the maximum extent permitted by such law.

19.9 Waiver of Similar Rights – Non-California Residents

You waive any rights under similar statutes or common law principles similar to California Civil Code Section 1542 which may be applicable in your jurisdiction.

19.10 Survival

This Section shall survive the termination or expiration of the Customer Agreement.

Dispute Resolution and Arbitration Agreement

PLEASE READ THE FOLLOWING SECTION CAREFULLY BECAUSE IT REQUIRES YOU AND US TO ARBITRATE CERTAIN DISPUTES AND CLAIMS ON AN INDIVIDUAL BASIS AND LIMITS THE MANNER IN WHICH YOU AND WE CAN SEEK RELIEF FROM THE OTHER.

By agreeing to these General Terms and Conditions, you and we agree that any and all past, present and future disputes, claims or causes of action between you and us arising out of or relating to the Customer Agreement, the Platform, the formation of the Customer Agreement, our relationship or any other dispute between you and us or any of our licensors, distributors, suppliers or agents (including but not limited to any application store or platform from which the Platform is accessed or downloaded), and whether arising prior to or after your agreement to this section, (collectively, “Dispute(s)”) will be governed by the procedure outlined below. You and we further agree that, except solely as set out in Section ‎20.8below, any arbitration pursuant to this Section ‎20shall not proceed as a class, group, mass or representative action.

20.1 The agreement to arbitrate contained in this Section ‎20, its scope and enforcement shall be governed by the Federal Arbitration Act.

Informal Dispute Resolution

Informal Dispute Resolution

20.2 We are committed to providing a positive experience on our Platform. As such, the parties shall first attempt to resolve any Dispute informally for at least 45 days before initiating arbitration. The informal negotiations begin upon the sending of a properly addressed written notice from one party to the other ("Notice of Dispute"). The Notice of Dispute must:

(a) include the full name and contact information of the complaining party;

(b) include additional information to identify the complaining party and the relevant User’s Account(s), including email address(es) used to establish your Account(s);

(c) describe the nature and basis of the Dispute; and

(d) set forth the specific relief sought.

We will send our Notice of Dispute to your postal or email address. Any Notice of Dispute to Company shall be sent to [email protected]. If a Dispute is not resolved within forty-five (45) days after the Notice of Dispute is sent, you or we may initiate formal action as described below. The amount of any settlement offer made by any party may not be disclosed to the arbitrator until after the arbitrator has determined the amount of the award, if any, to which either party is entitled.

We Both Agree to Arbitrate

20.3 By agreeing to these General Terms and Conditions, you and Company each and both agree to resolve any Disputes – including any Dispute concerning the enforceability, validity, scope or severability of this agreement to arbitrate – through final and binding arbitration as discussed herein, except as set forth under “Exceptions to Agreement To Arbitrate” below.

Opt Out of Arbitration Agreement

20.4 You may decline this agreement to arbitrate by notifying us at [email protected] within thirty (30) days of first accepting these General Terms and Conditions, with the subject line “ARBITRATION OPT-OUT” and stating that you decline this arbitration agreement. You must include your name, email address and postal address and you must personally hand-sign and date your notice. You can attach the notice to your email as a PDF, photograph or by any other means that clearly displays the required information and demonstrates that you have complied with these requirements. By opting out of the agreement to arbitrate, you will not be prohibited from accessing or using the Platform, but you and we will not be able to invoke the mutual agreement to arbitrate to resolve Disputes under the terms otherwise provided herein. For avoidance of doubt, in the event you exercise your right to opt out of the agreement to arbitrate, Section 19.1 and those limitations and restrictions applicable to litigation that are set out in Section ‎20.9 (and the judicial forum selection provision set out in Section ‎21.12) shall continue to apply to you. In addition, if you opt out of this agreement to arbitrate and at the time of your receipt of these General Terms and Conditions you were bound by an existing agreement to arbitrate disputes arising out of or related to your use of or access to the Platform, that existing arbitration agreement will remain in full force and effect. In other words, if you are bound by an agreement to arbitrate at the time you opt out of this one, that prior agreement to arbitrate will continue to apply to you. The remainder of these General Terms and Conditions (aside from any opted-out provisions of this Section 19) shall supersede the prior version.

Arbitration Procedures and Fees

20.5 You and Company agree that JAMS (www.jamsadr.com) (“JAMS”) will administer the arbitration under its Comprehensive Arbitration Rules and Procedures in effect at the time the arbitration is sought (“JAMS Rules and Procedures”). Those rules are available at http://www.jamsadr.com. Except as provided in Section 19.8 (Mass Arbitration), the arbitration will proceed on an individual basis and will be handled by a sole arbitrator in accordance with those rules; provided that the parties shall be presented with a list of five potential arbitrators and shall rank those potential arbitrators in order of preference. JAMS shall select the arbitrator with the highest combined preference (e.g. if both parties select a potential arbitrator as their top preference, that arbitrator will be selected). Any arbitration will be held in Virginia, or, at either party’s election, will be conducted telephonically or via other remote electronic means. The payment of any arbitration fees will be governed by the JAMS Rules and Procedures, and the arbitrator shall be authorized to award any remedies, including injunctive relief, that would be available to you in an individual lawsuit and that are not waivable under applicable law.

20.6 All arbitration proceedings and resulting awards conducted pursuant to Section 20 shall be confidential. Any such award may not be disclosed to third parties other than to a party's legal, accounting or financial advisors (each of whom shall be subject to that same confidentiality obligation) except (i) by either party in support of its pursuit or defense of its legal rights or obligations in another litigation or arbitration (whether involving the same or different parties), (ii) to the extent disclosed in connection with a petition or motion to confirm, enforce or recognize the award or (iii) otherwise as required or permitted by applicable law.

Proceedings Requiring Three Arbitrators

20.7 Notwithstanding anything to the contrary in Section ‎‎20.5, if either party either seeks a monetary award in excess of five hundred thousand dollars ($500,000) or seeks an equitable form of relief that would significantly impact other Users, in each case as reasonably determined by either party, the parties agree that such arbitration will proceed on an individual basis but will be handled by a panel of three (3) arbitrators and take place pursuant to the JAMS Rules and Procedures. Each party shall select one neutral arbitrator, with the third neutral arbitrator selected in accordance with the JAMS Rules and Procedures. That third arbitrator shall serve as chair of the arbitral panel and must be a retired judge with experience arbitrating or mediating disputes. In the event of disagreement as to whether the threshold for a three-arbitrator panel has been met, the sole arbitrator appointed in accordance with this Section ‎‎20.7 shall make that determination. If the arbitrator determines a three-person panel is appropriate, the arbitrator may – if selected by either party or through the JAMS selection process – participate in the arbitral panel. You and we agree that any award issued by a three-arbitrator panel may be appealed in accordance with the JAMS Optional Arbitration Appeal Procedures at either party’s election.

Mass Arbitration

20.8 To increase efficiency of resolution, in the event 25 or more similar arbitration demands against Company (including members of the Company Group), presented by or with the assistance of the same law firm or organization or group of law firms or organizations acting together, are submitted to JAMS, the JAMS Mass Arbitration Procedures and Guidelines (“JAMS Mass Rules”) shall apply. In such event, the JAMS Process Administrator (as described in the JAMS Mass Rules) shall have the authority to implement the procedures set forth in the JAMS Mass Rules, including the authority to batch together individual arbitration demands into a single coordinated proceeding. Arbitrators and the JAMS Process Administrator appointed in accordance with this Section ‎20.8 must be retired judges with experience arbitrating or mediating disputes. All provisions of this Section 19 that are not in conflict with the JAMS Mass Rules, including the appointment process for the arbitrators, shall continue to apply.

Waiver of Class Action and Collective Arbitration

20.9 TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW (AND EXCEPT AS EXPRESSLY PROVIDED IN SECTION ‎19.8), NEITHER YOU NOR COMPANY SHALL BE ENTITLED:

(a) TO CONSOLIDATE, COORDINATE OR JOIN ANY DISPUTES BY OR AGAINST OTHER INDIVIDUALS OR ENTITIES;

(b) TO PARTICIPATE IN ANY GROUP, CLASS, MASS OR COLLECTIVE ARBITRATION;

(c) TO ARBITRATE OR LITIGATE ANY DISPUTE IN A REPRESENTATIVE CAPACITY, INCLUDING AS A REPRESENTATIVE MEMBER OF A CLASS;

(d) TO ARBITRATE OR LITIGATE ANY DISPUTE IN A PRIVATE ATTORNEY GENERAL CAPACITY; OR

(e) OTHERWISE TO SEEK RECOVERY OF LOSSES OR DAMAGES (WHETHER FOR YOURSELF OR OTHERS) INCURRED BY A THIRD PARTY,

IN CONNECTION WITH ANY DISPUTE (AS DEFINED ABOVE), ANY AND ALL SUCH RIGHTS ARE HEREBY EXPRESSLY AND UNCONDITIONALLY WAIVED. ANY CHALLENGE TO THE VALIDITY OR ENFORCEABILITY OF THIS SECTION ‎20.9 SHALL BE DETERMINED EXCLUSIVELY BY THE ARBITRATOR. NOTWITHSTANDING ANYTHING TO THE CONTRARY SET FORTH IN THESE GENERAL TERMS AND CONDITIONS, IN THE EVENT ALL OR ANY PORTION OF SECTIONS ‎20.7, ‎20.8OR ‎20.9 OF THIS SECTION ‎20 IS FOUND TO BE INVALID OR LESS THAN FULLY ENFORCEABLE IN A PARTICULAR DISPUTE, THEN THE PARTIES’ AGREEMENT TO ARBITRATE (BUT NOT THOSE LIMITATIONS AND RESTRICTIONS APPLICABLE TO LITIGATION THAT ARE SET OUT IN SECTIONS 20.1 AND 20.9) MAY BE DEEMED VOID AND AS HAVING NO EFFECT FOR PURPOSES OF THAT DISPUTE, UPON EITHER PARTY'S ELECTION.

Exceptions to Agreement to Arbitrate for Temporary Relief

20.10 NOTWITHSTANDING THE OTHER PROVISIONS OF THIS SECTION ‎20, EITHER YOU OR COMPANY MAY BRING AN ACTION IN A COURT AUTHORIZED BY SECTION 10.12 FOR TEMPORARY INJUNCTIVE RELIEF UNTIL AN ARBITRATOR HAS BEEN EMPANELED AND CAN DETERMINE WHETHER TO CONTINUE, TERMINATE OR MODIFY SUCH RELIEF.

Miscellaneous

21.1 Force Majeure

We shall not be held liable for any failure or delay in fulfilling our obligations under this Customer Agreement where such failure or delay results from circumstances beyond our reasonable control. These include, but are not limited to: acts of God; governmental actions; fire, flood, storm, earthquake, or other natural disasters; labor or trade disputes; strikes, lockouts, or industrial actions; war, riot, civil unrest; pandemics or epidemics; or failure by suppliers or subcontractors to perform.

21.2 Relationship of the Parties

Nothing in this Customer Agreement shall be construed to create any partnership, joint venture, agency, or other form of association between the parties. Neither party shall have authority to bind the other, make representations on behalf of the other, or assume any obligation for the other, whether express or implied.

21.3 Entire Agreement

This Customer Agreement - including these General Terms and Conditions, our Privacy Policy, Responsible Social Play Policy, Sweepstakes Rules, and any applicable Special Terms - constitutes the entire agreement between you and us regarding your access to and use of the Platform. It supersedes all prior written or oral agreements, representations, or understandings.

21.4 Amendments

We reserve the right to modify this Customer Agreement, including these General Terms and Conditions, at any time. Any updated version will be published on the Platform and shall become effective immediately upon posting.

21.5 Notification of Changes

If any update to this Customer Agreement materially affects your rights or obligations, we will notify you upon your next visit to the Platform. You will be required to re-confirm your acceptance of the revised terms. If you do not accept the updated Customer Agreement, you must discontinue use of the Platform.

21.6 Waiver

Any waiver of a breach or default under this Customer Agreement must be in writing and signed by the waiving party. Such waiver shall not be deemed a waiver of any subsequent breach or default.

21.7 Severability

If any provision of this Customer Agreement is found to be invalid or unenforceable by a court of competent jurisdiction, that provision shall be severed, and the remainder of the Agreement shall remain in full force and effect to the maximum extent permitted by law.

21.8 Notices

All notices under this Customer Agreement must be in writing and sent via email:

(a) To you, at the email address registered to your Customer Account;

(b) To us, at [email protected], including the information specified in Section 10.1 of these General Terms and Conditions. Notices shall be deemed received at 9:00 AM on the next business day following transmission, unless an automated failure notice is received, in which case the notice shall be deemed not delivered.

21.9 Assignment by You

You may not assign, transfer, or novate your rights or obligations under this Customer Agreement without our prior written consent.

21.10 Assignment by Us

We may assign, transfer, or novate our rights and/or obligations under this Customer Agreement to any third party without your consent, including in connection with a merger, acquisition, change of control, or sale of assets.

21.11 Governing Law

This Customer Agreement, and any matters relating to your access or use of the Platform, shall be governed by and construed in accordance with the laws of the State of Virginia, USA, excluding its conflict of laws principles. The United Nations Convention on Contracts for the International Sale of Goods shall not apply.

21.12 Jurisdiction and Dispute Resolution

Subject to Section ‎20, the parties agree that the courts located in Virginia, USA shall have exclusive jurisdiction over any disputes arising out of or in connection with this Customer Agreement or the use of the Platform. Notwithstanding the foregoing, either party may seek to compel arbitration or enforce an arbitral award in any court of competent jurisdiction. EACH PARTY HEREBY WAIVES, TO THE MAXIMUM EXTENT PERMITTED BY LAW, ANY RIGHT TO A TRIAL BY JURY IN ANY LEGAL PROCEEDING ARISING OUT OF OR RELATING TO THIS AGREEMENT OR THE PLATFORM.

21.13 Inconsistency

In the event of any inconsistency between this Customer Agreement and other information or documents provided by us (including via Customer Support), the terms of this Customer Agreement shall prevail.

Where there is a conflict between this Customer Agreement and any applicable Special Terms, the Special Terms shall govern.

Subject to the above, if any conflict arises between these General Terms and Conditions, Sweepstakes Rules, Privacy Policy, and Responsible Social Play Policy, these General Terms and Conditions shall govern solely to the extent necessary to resolve the conflict, unless expressly stated otherwise.

Welcome Package – Terms & Conditions

22.1 Eligibility

The Welcome Packages are available to new players only who are legally eligible to participate in sweepstakes promotions under applicable U.S. laws. The package is limited to one per player, household, IP address, device, email address, and payment method.

22.2 Package Description

The Welcome Package may include Gold for entertainment gameplay and free Diamonds, Rum and Claw Machine Credits issued at no cost. The exact amounts are displayed in the Coin Store at the time of the package.

22.3 One-Time Use

These Welcome Packages are strictly limited to one purchase per player. Any attempt to claim the package more than once, including through multiple accounts or identities, may result in disqualification and account restriction.

22.4 Playthrough Requirement

Free Diamonds issued as part of the Welcome Packages are subject to a one-time (1x) playthrough requirement. All Diamonds must be played at least once before any winnings derived from those Diamonds become eligible for redemption.

22.5 Gameplay & Redemption

Gameplay using Gold and Diamonds is subject to standard game rules and platform limitations. Any potential prize redemption requires full account verification and compliance with all applicable sweepstakes rules and platform terms.

22.6 Abuse & Fraud Prevention

We reserve the right to withhold or revoke the Welcome Packages and any associated benefits if abuse, fraud, manipulation, or violation of these Terms is detected or reasonably suspected.

22.7 General Terms Apply

The Welcome Package is subject to the platform’s General Terms & Conditions, Sweepstakes Rules, Privacy Policy, and Responsible Play guidelines.

Annex 1. Wheel of Gold Game

1.1 Overview

Wheel of Gold is a free-to-play social entertainment feature available to all registered participants who are eligible for promotions

No purchase is ever necessary to play or win. Wheel of Gold is always free to enter.

Participants must be 21+ to participate.Void where prohibited by law.

Participants use Spins (Attempts) to play a virtual prize wheel and receive guaranteed rewards

Rewards include Gold only.

Feature classification: Non-pay-to-win promotional gamification feature using virtual currency with no monetary value, fully compliant with sweepstakes/social-casino requirements.

1.2 Obtaining Spins (Attempts)

Participants earn Spins through non-monetary gameplay only, as follows:

Earn 1 Spin for every 100,000 Gold (GC) played on eligible social casino games.

Additional rules:

• A maximum of 10 stored Spins may be held. Additional Spins will not be issued if the balance is full.

• Spins cannot be bought, sold, transferred, or exchanged.

• Gold (GC) have no monetary value and cannot be redeemed for cash or anything of value.

• Spins may also be granted during free promotional giveaways.

• Spins do not represent real money or real-world items.

• Attempts may be removed during maintenance or promotional resets.

1.3 Wheel Spin Mechanics

• Each Wheel of Gold Spin consumes 1 Spin

• Spins must be triggered manually using the “Spin” button — no autoplay or batching.

• Participants may use up to 3 Spins per day, regardless of stored Spins.

• Stored Spins remain available for future use unless removed during resets

• Spin balances are shown before and after each spin.

• Reward results are shown immediately via animation or pop-up

Wheel of Gold offers only non-monetary entertainment rewards.

1.4 Available Rewards

The Wheel may award the following:

Gold (GC)

• Used only for Gold Game Play.

• Have no monetary value.

• Cannot be withdrawn, exchanged, or transferred.

• Are intended solely for entertainment purposes within the platform.

• Do not represent the opportunity to win real money or real prizes.

No other reward types are available.

1.5 Reward Table with Probabilities

1.6 Game Controls and Conditions

• To play, participants must first earn Spins by wagering Gold (non-monetary virtual currency).

• 100,000 GC wagered = 1 Spin.

• All spins are manual; no auto-spins or bulk spins.

• Spins are consumed individually and displayed before/after each spin.

• Rewards are shown immediately after each spin.

• Spins do not expire unless removed during scheduled resets or maintenance.

• Wheel of Gold is a social entertainment feature only — not gambling.

• Participation is subject to all platform Terms & Conditions and applicable laws.

Annex 2. Big Pirate

2.1 Big Pirate is available to all registered participants who are eligible for promotions. No purchase ever necessary to play or win. Big Pirate is always free to enter. Participants must be 21+ to participate. Void where prohibited by law.

2.2 Big Pirate is a free to play Social Casino where participants build islands, take part in raids and attacks, and earn rewards, including Diamonds. The goal is to build as many islands as possible and win prizes along the way.

2.3 Participants begin with a starter kit that includes Rum. Rum is essential for spinning Big Pirate, as well as for raiding and attacking.

2.4 Earning: participants can earn Rum by:

• Creating an account, get 2 free Rum. First-time participants only.

• Coin Store Purchases. Select bundles offers can be purchased and include free Rum.

• Playing Slot games and earning Rum as you play with Diamonds. Get 1 Rum for every 10 Diamonds played through in the casino.

• Complete Milestones. Play the in-game slot (Big Pirate) and fill the Milestone bar. Each spin may land a Milestone symbol. The more you collect the closer you’ll get to unlocking bonus loot, including Rum. Milestones reset every 24 hours, login daily to continue progress.

• Winning prizes in the Tournaments and Challenges.

• Free Promotions and Giveaways (ie Holidays, events, etc.)

2.5 Spinning: In Big Pirate, participants use collected Rum to spin at our gamification features to earn in-game rewards such as Free Spins, Gold, Diamonds, Coins, unlock combos, and advance through the game. The more Rum earned by aforementioned mechanics (see 4) or by playing our social style games, the more spins participants get to move forward in the game.

2.6 Building and upgrading Islands: participants unlock, build objects, and upgrade islands as they play. Coins are used for upgrades. Once all upgrades on an island are completed, additional in-game rewards are unlocked, allowing a participant to move forward to the next island. Completing islands gives participants the possibility to earn more rewards and continue progress through the game.

2.7 Gameplay Combos: Big Pirate offers several key combos when playing, including Skull Coins combo: Collect Coins to build and upgrade islands. Attack Combo: Allows participants to plunder other Pprticipants’ islands. Shield Combo: Protects your island from attacks. Raid Combo: Engage in playful raids to loot other participants’ treasure chests and collect virtual Coins.

2.8 Raids, Attacks, and Tournaments: Landing a 3-symbol Raid Combo lets participants simulate a raid and collect virtual Coins from other participants’ treasure chests, with outcomes based on their in-game performance. Landing a 3-symbol Attack Combo allows participants to plunder parts of another participant’s Island and claim virtual rewards. If a participant has a Shield, it protects their Island from that attack but the shield is lost. Participants can also join 48-hour Tournaments to earn points by spinning, raiding, and attacking. The more points collected, the higher the participant climbs on the leaderboard, unlocking additional in-game rewards.

2.9 Milestones and Rewards Calendar: In Milestones, participants can earn additional rewards by collecting special symbols when spinning the Slot and completing the Milestones bar. Spins are available through accumulating Rum, either through means as per point 4, or via a free alternative methods (AMOE), such as requesting for top-ups from through the live chat.

The Rewards Calendar offers daily prizes, which can be attained after claiming a free entry or through optional bundle purchases. No purchase ever necessary to play or win. Big Pirate is always free to enter. Participants must be 21+ to participate. Void where prohibited by law.

2.10 Rewards and playthrough requirements: Big Pirate offers a chance to win a main prize of up to 6,000 Diamonds. Diamond prizes will be awarded immediately. A 1x playthrough requirement must be met in the Casino before the Diamonds are eligible for redemption. For Free Spins rewards, the following conditions apply: Free Spins: Winning from Free Spins in Diamonds has a required playthrough of 1x before being eligible for redemption, with a maximum prize of 100 Diamonds per Free Spins reward.

2.11 Standard Terms and Conditions apply.

Annex 3. Claw Machine

3.1 The Claw Machine is available to all registered participants who are eligible for promotions

3.2 The Claw Machine is a real online claw machine. A participant can purchase Claw Machine credits, which allows them to start playing. Participants can then control the claw to grab a toy, which is equivalent to a prize like Rum. Once all conditions are met, participants can claim these prizes directly in their account.

3.3 Each try at the Claw Machine gives participants 25 seconds to grab a toy.

3.4 Each toy caught in the Claw Machine gives a reward. The available toys and their bonus amounts are:

• Plum: 30 Free Spins, Diamond winnings from these Free Spins will be added to the participant balance and will be subject to a 1 time playing requirement before being available for redemption.

• Banana: 20 Free Spins, Diamond winnings from these Free Spins will be added to the participant balance and will be subject to a 1 time playing requirement before being available for redemption.

• Strawberry: 10 Free Spins, Diamond winnings from these Free Spins will be added to the participant balance and will be subject to a 1 time playing requirement before being available for redemption.

• Clover (Lucky leaf): 1 Diamond which need to be played 1 time to be available for redemption.

• Diamond: 2 Diamonds which need to be played 1 time to be available for redemption.

• If a participant wins more than one toy, only one randomly selected prize will be given.

3.5 The maximum amount of Diamonds which can be won from awarded free spins will be 100, any amount exceeding that will be voided.

3.6 The requirements for redemption must be met within 10 days of receiving the award. If the requirements aren’t met in time, the reward and any winnings will be cancelled.

3.7 Standart Terms and Conditions apply.

Annex 4. Reward Market

4.1 In the Reward Market a participant can exchange Rum for Rewards like Free Spins on which are applied the following conditions:

4.1.1 Rewards:

• After exchanging Rum for the respective rewards, a participant will have 10 days to play the Diamond winnings 1 time before being eligible for redemption.

• The maximum amount which can be redeemed from the rewards received from the Reward Market will be equal to 5 times the initial reward amount. For example: the maximum amount to be redeemed from a 15 Diamonds reward will be 75 Diamonds.

• The rewards is only valid in the Social Casino section. It can not be used in other areas like the Social Live Casino.

4.1.2 Free Spins:

• The winnings from the free spins will be added, and will require a 1 time play to be eligible for redemption.

• A participant will have 10 days to play the amount 1 time.

• The maximum amount which can be redeemed from the reward will be 100 Diamonds, any amount exceeding that will be voided.

4.1.3 Claw Machine:

• Credits to play the Claw Machine can be purchased for Rum from the Reward Market. Please see there Terms and Conditions in the Annexes.

4.2 A participant can accumulate Rum for use in the Reward Market by:

• Logging in Daily.

• Receiving Free Rum from purchasing Bundles.

• 1 Rum for every 10 Diamonds played in the Social Casino will be awarded..

• Or as prizes from the BigPirate game

• Requesting Rum from an AMOE (like asking our Support team)

4.3 General Terms and Conditions apply.