Responsible Gaming Policy

Introduction

Aim Games, LLC (“Aim Games”, the “Company”) is committed to providing a platform that is operated in a secure, fair, and socially responsible way.  Our aim is to endorse and encourage Responsible Gaming (“RG”) amongst its players, employees, and stakeholders. Responsible Gaming encompasses the processes, tools and resources that allow players to have a fair and safe experience with the Company, while protecting them from problem gaming issues.  In addition, while the Company is not currently required to be licensed in any state, Aim Games is committed to upholding the licensing objectives and compliance frameworks of any future gaming regulators that may regulate its activities.

As part of this Policy, Aim Games will: 

• Operate in a manner that is compliant with with all applicable federal and state laws regarding Responsible Gaming and consumer protection. 

• Provide easily accessible, clear, and meaningful information to players regarding Responsible Gaming tools and restrictions so that they can make informed choices about using the Company’s platform and services. 

• Inform players or prospective players about the help and assistance they can utilize should they experience any signs of problem gaming.  

• Make all reasonable efforts to avoid marketing to minors as defined by each state in which Aim Games conducts business.  

• Make commercially reasonable efforts to avoid marketing to self-excluded players.

• Use responsible marketing and advertising efforts that contain any relevant Responsible Gaming information required by each jurisdiction in which Aim Games allows real money game play. 

1. Registration & Verification

   A Prohibition of Underage Players - Identification and Verification  

• Participation in real money gameplay by an underage player is prohibited.

• Before a player can complete registration and begin cash enable game play on the app, the player must accept Aim Games’ Terms of Service and affirm that he or she is at least 18 years of age. 

• Aim Games will do certain checks on the name and age of individual registration, and will do further checks when a player hits certain deposit and or withdrawal requirements.

• If a player is confirmed to be a minor, Aim Games will undertake the relevant steps required to block that player’s access.

B Duplicate Accounts

• Duplicate accounts are prohibited by the Aim Games Terms of Service, and Aim Games will make reasonable efforts to ensure that a player is only able to register, fund, and maintain one active account.  

• Duplicate accounts will be flagged and closed by the Company when they are known. This process allows the Company to comply with its fraud and security responsibilities, but it also allows Aim Games to prevent players who may wish to circumvent any Responsible Gaming tools set on their initial account.

2. Credit to Players

• Aim Games will not provide players with repayable credit or loans. 

3. Responsible Gaming Tools

• Aim Games wants our players to have an entertaining and fun experience on our app. We also want our players to play responsibly.  To accomplish both goals we have established tools that a player can use to better control their level of gameplay, including self exclusion.

4. Self-Exclusion / Restriction

Self-exclusion is a tool for players who are experiencing issues with problem gaming and if a player requests that we exclude their account, Aim Games will close the account and will restrict the player from opening a new account.  A player will be allowed to withdraw funds from their account before it is closed.  Aim Games will use commercially reasonable efforts to ensure the player will not receive marketing communications from the Company after self-exclusion. 

5. Responsible Gaming Information  

Aim Games will ensure that relevant Responsible Gaming and related information is easily accessible to players. This information contains details of organizations and bodies that provide help and assistance to problem gamers and their families. 

In providing and directing players to these sources for assistance, Aim Games aims to ensure that Players with a gaming problem will get help and assistance from a reputable source with expertise in this area.

6. Player Activity Monitoring

Player activity will be monitored for behavior that may indicate a possible concern or responsible gaming issue. If concerns are identified, Aim Games may contact the player to determine whether these concerns are warranted and whether further actions (including account restrictions) are appropriate.  Activity monitored may include, but is not limited to:

• Time played.

• Number of payment methods used.

• Cancelled withdrawal requests; and

• Number or frequency of time-out or self-exclusion requests.

7. Prohibitions on Advertising to Minors

Aim Games will not market exclusively or primarily to minors, according to the definition of minor in each state and/or as specifically defined in any rules or regulations relating to pay-to-play gaming products in any jurisdiction. To ensure that Aim Games’ marketing does not target minors, the Company will: 

• Require all partner media outlets, websites, or other entities to agree to take reasonable measures not to target minors on behalf of Aim Games; 

• Make reasonable efforts to ensure that advertising networks do not place Aim Games material on any websites that are aimed exclusively or primarily at minors; 

• Not use any search engine optimization terms that target exclusively or primarily minors; 

• Require that individuals or other entities speaking on behalf of Aim Games on television, radio, or online outlets understand and acknowledge this aspect of the Aim Games marketing policy; and

• Ensure that in-person promotional events, should the Company hold these in the future, are staffed by individuals who understand and acknowledge the Aim Games marketing policy.

8. Prohibitions on Marketing to Self-Excluded Players

Aim Games will automatically prevent self-excluded players, third party-excluded players, or players otherwise barred from participating in Aim Games contests from receiving marketing or direct contact via the following methods:

• Email

• Mail

• Calls / Texts 

9. Socially Responsible Marketing

Aim Games will use commercially reasonable efforts to ensure that marketing communications do not suggest that playing only skill based games are a solution to financial concerns, an alternative to employment, or a way to achieve financial security.  Aim Games will make information about responsible play available to consumers, clearly and conspicuously, on its website. 

10. Training

Various levels of responsible gaming training are provided to employees and other stakeholders of the Company, depending on the role of the employee/stakeholder with Aim Games. These are periodically reviewed to ensure they are up to date with the latest regulatory changes, trends, and best practices.

Training materials include but are not limited to the following information:

• Aim Games’ current policies and procedures with a description of Aim Games’ Responsible Gaming tools 

• Red flags that help identify players with potential gaming problems

• How to assist a player who may be at risk of harm or be a compulsive gambler.

11. Periodic Review

Aim Games will conduct a review of its Responsible Gaming Policy annually or sooner if required.  Any material changes to the Policy will be reviewed and approved by the Compliance Officer or their designee. 

12. Record Retention

Aim Games will maintain all documentation related to its Responsible Gaming Policy per the Company’s Data Retention Policy in conjunction with any state-specific regulatory requirements. This will include player history and transactions, as well as marketing and advertising material.