The Platform and it's intended uses
Our platform offers games in two separate formats: (i) a standard, social casino format (the “Standard Play”) which offers gameplay via “eCredit Games” and (ii) a sweepstakes-based promotional format (“Promotional Play”) which offers gameplay via “Sweepstakes Games” to players. The eCredit Games offer a virtual prize – eCredits (also referred to as “Gold Coins”) that cannot be redeemed in any manner and can solely be used for gameplay in the eCredit Games. eCredits, used for entry in eCredit Games, may be purchased from the company using the kiosk. eCredits can also be obtained through other promotional methods (e.g., a sign-up bonus). The Sweepstakes Games offer a prize, known as the Redeemable Sweeps Coins, that have a real money redemption value. Players can obtain Sweeps Coins only through free promotional methods including a free, alternative mode of entry. Sweeps Coins, used for entry in Sweepstakes Games, may never be purchased from the company or otherwise. One can choose to either play with eCredits in the eCredit Games or with Sweeps Coins in the Sweepstakes Games, but there is no interconnection between the two formats.
Generally, gambling laws require three elements to be considered illegal gambling: consideration, chance, and prize. In eCredit Games, players pay money to obtain eCredits, so there is consideration. The eCredit Games are games of chance because the outcome is determined by a random number generator. Thus, the key question is whether there is a “prize.” In the eCredit Games, a user may win and must play with virtual coins that (1) have no secondary market value; and (2) can only be used to obtain additional game play. There are no redemptions for “real world” prizes. Given these circumstances, the element of prize – which is essential to a finding of gambling – is absent with regard to the eCredit Games under most laws. Thus, in the absence of prize, the games should not be considered illegal gambling under most laws.
As applied to the Sweepstakes Games, this analysis produces a similar result, though with the element of consideration missing, instead of an absent prize element. Although the Sweepstakes Games contain both chance and a prize (because the prize is Redeemable Sweeps Coins that can be redeemed for real money), they do not have “consideration” because users cannot pay to enter or participate in the Sweepstakes Games. Rather, all entries to the Sweepstakes Games are made either through one of the promotional means (e.g., via a daily bonus obtained by logging into the platform or free social media contests) or through a free, alternative mode of entry through which players can receive additional Sweeps Coins. In addition, players can obtain Sweeps Coins as a free bonus incidental to some purchases of eCredits. Under all circumstances, the player does not provide consideration to obtain the Sweeps Coins, but rather obtains them for free. In the absence of consideration, the Sweepstakes Games generally should not be considered illegal gambling under most laws.
Notice regarding connectivity
Scope and Purpose
This notice applies to all kiosk devices operated or made available by this organization. It is intended to fully and transparently inform users, operators, regulators, and any other interested parties of the nature and strict limitations of any internet or network connectivity present on such kiosk devices. This disclosure is provided to eliminate any ambiguity regarding whether kiosk data can be accessed, retrieved, monitored, or transmitted to any remote party.
Internet Connectivity: Permitted Uses Only
A kiosk device may be connected to the internet. However, this connection is strictly limited in scope and function. The sole permitted uses of any such internet connection are:
- (a) Delivery of authorized system software updates;
- (b) Installation of security patches and bug fixes; and
- (c) General maintenance and operational integrity functions.
No data pertaining to sweepstakes mechanics, game logic, award or prize structures, player activity, or device performance is transmitted, exchanged, or otherwise made available through this connection at any time.
Prohibition on Remote Data Access
The kiosk device does not contain, support, or enable any mechanism — whether hardware-based, software-based, or network-based — that would permit a remote user, third party, or external system to access the following categories of information:
- (a) Sweepstakes mechanics, algorithms, routines, or logic;
- (b) Award schedules, prize tables, payout configurations, or outcome data;
- (c) Performance metrics, uptime statistics, or operational logs;
- (d) Player activity records, session data, or usage patterns; and
- (e) Any other data generated by or stored on the kiosk device.
No Remote Monitoring or Retrieval
There is no functionality, interface, protocol, or pathway — including but not limited to remote desktop access, telemetry services, cloud synchronization, application programming interfaces (APIs), or diagnostic tools — through which any remote user could retrieve, observe, monitor, or interact with data stored on or generated by the kiosk device. This prohibition applies equally to authorized personnel, system administrators, and third-party vendors, except as expressly required for the limited connectivity purposes described in Section 2.
No Pertinent Data Exchange
For the avoidance of doubt, the internet connection described herein does not facilitate, and is expressly prohibited from facilitating, the exchange of any pertinent device data. "Pertinent data" means any information that relates to or reveals the configuration, performance, award state, activity history, or operational status of the kiosk device. All data communicated through the permitted internet connection is limited strictly to update packages, patch files, and system-level maintenance signals, none of which contain or expose user-facing or game-related information.
Compliance and Acknowledgment
This disclosure is provided in accordance with applicable regulations governing the transparency of kiosk and sweepstakes device operations. Any party relying on this device, or making regulatory or compliance determinations with respect to it, is hereby placed on full notice of the connectivity limitations described above. Operators are responsible for ensuring that device configuration at all times conforms to the restrictions set forth in this notice.
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