Responsible Gaming & Gambling Policy

Document Status & Integration

This Policy is a binding schedule to the Terms & Conditions and must be read alongside the Privacy Policy, AML/KYC Policy and Game Fairness & Integrity Statement. Where terminology overlaps, definitions in the Terms & Conditions prevail.

1. Objectives

Protect Players from gambling-related harm by embedding preventive measures, early-warning detection and rapid intervention.
Deter Under-Age & Vulnerable Access through rigorous age-verification, parental-control guidance and marketing discipline.
Foster an Informed Environment in which gambling is positioned strictly as leisure, never as income generation or investment.
Align with International Best Practice including:
- UK Gambling Commission (LCCP — Social Responsibility Code 17);
- Malta Gaming Authority RG Directive 2021-012;
- European Committee for Standardisation (CEN) Workshop Agreement CWA 16259;
- FATF risk-based approach to VASPs for crypto-related red-flags.

2. Key Definitions

Term	Meaning
Responsible Gambling (RG)	A comprehensive strategy ensuring gambling remains an enjoyable recreational activity without causing personal, social or financial harm.
Problem Gambling	Behaviour causing negative consequences for the gambler, others, or the community, often characterised by loss of control.
Self-Exclusion	A formal request by a Player to be prevented from accessing gambling services for a chosen duration.
Cooling-Off (“Time-Out”)	A short, fixed break (24 hours to 6 weeks) during which the account is inaccessible but not permanently closed.
RG Trigger Event	A data-point or pattern (e.g., rapid deposit escalation) that prompts a risk review.

3. Corporate Governance & Responsibilities

Role	Responsibility
Board of Directors	Approves RG strategy; receives quarterly RG risk reports.
Chief Compliance Officer (CCO)	Overall policy owner; escalates systemic RG breaches to the Board.
Responsible Gaming Manager (RGM)	Day-to-day administration, staff training, KPI monitoring, liaison with support vendors.
Customer-Support & Risk Staff	First-line detection, limit implementation, pastoral communication with Players.
External RG Auditor	Conducts annual gap-analysis, mystery-shopping and stress tests.

4. Under-Age & Vulnerable Player Safeguards

Age Verification:
- Automated Tier 1 screening (DOB, IP, device fingerprint, phone validation) at sign-up.
- Documentary Tier 2 checks (photo ID + proof of address) mandatory before first withdrawal.
Parental Controls:
- Prominent footer links to Net Nanny, Qustodio, Norton Family, OpenDNS FamilyShield.
- Advice sheet “Keeping Kids Safe Online” available for download.
Voluntary Vulnerability Flag:
- Players may self-declare mental-health or addiction concerns; the account is then subject to mandatory cooler period and weekly contact.

5. Player-Protection Toolkit (Extended Features)

Tool	Default	Granularity	Permanent/Adjustable	How to Activate
Deposit Limit	Off	Daily / Weekly / Monthly	Adjustable; 24 h cooling to increase	Account ➔ Limits
Loss Limit	Off	Daily / Weekly / Monthly	Adjustable; 24 h cooling	Account ➔ Limits
Single-Bet Cap	USD 5 eq. (bonus play)	Per spin/hand	Fixed while wagering bonus	Automatic
Session Duration	Off	30 min – 6 h	Adjustable; no cooling period	Gameplay header
Reality Check	60 min	15 / 30 / 60 min	Adjustable	Gameplay header
Time-Out	n/a	24 h – 6 w	Immediate & irreversible for term	Account ➔ Limits
Self-Exclusion	n/a	6 m / 1 y / 5 y / Permanent	Immediate & irreversible for term	Account ➔ Limits / Support
Withdrawal Lock	On	N/A	Fixed	Automatic
Session Budget Planner	Onboarding modal	Custom	Adjustable	Onboarding & Settings

Implementation SLA: 15 minutes from confirmed request (via UI, chat or e-mail).

6. Risk-Monitoring & Automated Interventions

Trigger	Threshold	System Action	Human Follow-Up
Deposit Spike	200 % ↑ vs. 30-day average	Flag to Risk Engine	Tier 1 chat outreach within 60 min
Net Loss > USD 1,000 eq. in 24 h	—	Auto reality-check + loss-limit suggestion	Mandatory phone or chat call
Continuous Play	≥ 4 h without break	Auto log-out + cool-down pop-up	Offer session-time limit
Multiple Declined Deposits	3 × in 10 min	Account temp-lock 60 min	Source-of-funds query
Self-Harm Language	Any instance in chat/support	Immediate session termination	Escalate to RGM; welfare e-mail

All events feed into a Player RG Score (0–100). Score ≥ 65 triggers mandatory loss limits; score ≥ 80 forces self-exclusion recommendation.

7. Crypto-Specific Harm-Reduction Measures

Volatility Disclaimer
Deposit panels display real-time USD conversion plus 24 h price change.
‘Crypto ≠ Investing’ Banner
Rotating banner reminds Players that “Gambling winnings are not investments. Cryptocurrency values may fall.”
Mixer / Privacy-Coin Ban
Deposits from mixers, tumblers or privacy-focused coins are rejected—reducing high-risk anonymity loops.

8. Educational Resources

SkinJoker curates a multilingual Help Centre with:

Budget-planning worksheets;
Videos on house edge & RTP;
Articles on recognising problem gambling;
A 20-question Self-Diagnosis Test adapted from the Canadian Problem Gambling Index (CPGI). Test results are stored locally on the device, not on our servers, to protect privacy.

9. Marketing, Bonuses & Affiliate Controls

Opt-In Only
Marketing e-mails/SMS/push require explicit consent (double opt-in).
Content Standards
No “risk-free”, “income” or “debt-solution” claims; mandatory “18+ | Play Responsibly” footer.
Bonus Clarity
Wagering multiplier, expiry, max bet and game weighting stated with ≥ 11-pt font, no asterisks.
Affiliate Monitoring
RG compliance clause in all affiliate contracts; quarterly review of partner content; zero-tolerance for misleading or under-age targeting—breach results in claw-back and programme expulsion.

10. Staff Competence & Culture

Induction Training
8-hour RG module covering addiction psychology, communication skills, suicide-prevention protocols.
Annual Refresher
4-hour update; pass mark 85 %.
RG Champions
Each shift has a trained champion authorised to impose emergency limits without managerial approval.
Mental-Health Support for Staff
Confidential counselling, recognising vicarious trauma from regular exposure to distressed players.

11. Data Protection & Confidentiality

RG data (limits, exclusions, chat notes) is stored in a segregated schema, encrypted (AES-256) and access-restricted to RG personnel.
Retention: 5 years after account closure or end of exclusion, whichever is later (aligned to EU AMLD 6 & Hong Kong AMLO).
Disclosure: Only to the Player, authorised staff, or statutory authorities under lawful request. No RG data is used for marketing profiling.

12. Policy Review, Metrics & Continuous Improvement

KPI	Target	Reporting Frequency
Time to implement limit/exclusion	≤ 15 min	Monthly
% reality-check acknowledgements	≥ 90 %	Quarterly
Self-exclusion re-registration rate	≤ 8 %	Semi-annual
Staff training completion	100 %	Annual
External audit non-conformities	0 critical	Annual

Policy undergoes full review annually or immediately after a material RG incident. Revised versions are posted in the RG footer link and communicated via in-site message.

13. Complaints & Escalation

Front-Line
Live chat or e-mail to [email protected] (response ≤ 1 h).
RGM Review
Formal resolution within 14 days; written outcome sent to Player.
Independent Mediation
If unsatisfied, Player may request mediation by a certified addiction counsellor jointly appointed (costs borne by SkinJoker).

14. Contact Points

24 / 7 / 365 Assistance

Live Chat (icon bottom-right)
[email protected] (dedicated RG desk)
+852 5803 8760 (Hong Kong, English)

Remember
Gambling should be fun, not a financial plan.
If you ever feel pressure, pause, set limits, or walk away. Help is always available.