Responsible Gaming Policy

1) Purpose & Scope

This Responsible Gaming Policy ("Policy") explains how Axis Platforms, Inc. supports responsible gaming as a software provider, and sets the minimum responsible gaming standards every Operator must meet when using the Platform. It supplements our Terms of Service, which require Operators to put responsible gambling measures in place.

This Policy applies to every Operator Platform and to every product offered on one, including casino games and prediction markets.

2) Definitions

• Company, Axis, we, us: Axis Platforms, Inc.
• Platform: The software, templates, dashboards, APIs, and infrastructure Axis provides to Operators.
• Operator: A business that uses the Platform to launch and run an Operator Platform (a "Customer" under our Terms of Service).
• Operator Platform: An online gaming, betting, prediction-market, or related site or application that an Operator runs using the Platform.
• End User: A player, customer, or visitor of an Operator Platform.
• Self-Exclusion: An End User's request to be blocked from gambling on an Operator Platform for a set period or permanently.
• Cooling-Off Period: A short, voluntary break from gambling, typically lasting from 24 hours to 6 weeks.
• Limits: Controls that cap how much an End User can deposit, wager, or lose, or how long they can play, over a set period.
• Reality Check: A notice that shows an End User how long they have been playing and how much they have won or lost in the current session.
• Minor: A person under 18 years of age, or under the minimum legal gambling age where they are located, whichever is higher.

3) Our Role

• Technology Provider Only: Axis provides the software Operators use to run their Operator Platforms. Axis does not offer gambling to the public, does not accept wagers, and is not a party to any game, bet, or market position. Axis is not the house under any circumstances.
• Operator Responsibility: Each Operator is solely responsible for its Operator Platform, including its games, markets, odds, settlements, payouts, End User funds, and marketing, and for meeting the responsible gaming requirements of its licenses and of applicable law.
• Axis Review: Axis may review payouts, games, markets, and responsible gaming practices on any Operator Platform. Any review is at Axis's discretion, is not an approval, and does not transfer responsibility from the Operator to Axis.

4) Our Commitments

As a software provider, Axis will:

• Build responsible gaming controls into the Platform and make them available to every Operator.
• Avoid building features that are designed to encourage excessive or compulsive gambling, or that make it harder for End Users to set limits, take a break, or self-exclude.
• Require every Operator to meet the standards in this Policy as a condition of using the Platform.
• Act when we learn that an Operator is not meeting those standards.
• Review and improve this Policy and the Platform's controls over time.

5) Platform Controls

The Platform includes controls that each Operator configures for its Operator Platform, including:

• Limits: Deposit, wager, and loss limits.
• Identity & Age Verification: Configurable identity verification (KYC) levels, and the information required at each level.
• Country Restrictions: Blocking of access from the countries the Operator selects.
• Risk Monitoring: Fraud rules, alerts, and End User risk scores that can help identify unusual or harmful patterns of play.
• Audit Trails: Records of sensitive administrative actions, such as manual balance adjustments.

The controls available to an Operator may vary with its configuration and integrations. Where a control required by an Operator's licenses or by applicable law is not available on the Platform, the Operator must provide it through an integration or other means before offering real-money play where that control is required.

6) Operator Standards

Every Operator must, at a minimum:

• Licensing: Hold every license required in each jurisdiction where its Operator Platform is available, and follow the responsible gaming conditions of those licenses.
• Responsible Gaming Policy: Publish its own responsible gaming policy, and display it and links to help resources prominently on its Operator Platform.
• Age & Identity Verification: Confirm that an End User is not a Minor before allowing real-money play, and verify identity as required by law and its licenses.
• Self-Exclusion & Cooling-Off: Offer self-exclusion and cooling-off periods that End Users can activate easily, and honor them as described in Self-Exclusion.
• Limits: Let End Users set deposit and loss limits, and wager or time limits where required. A request to lower a limit must take effect immediately. A request to raise or remove a limit must take effect only after a waiting period of at least 24 hours.
• Account History & Reality Checks: Give End Users access to their account activity, including deposits, withdrawals, wins, and losses, and provide reality checks where required.
• Clear Information: Display accurate odds, game rules, market rules and resolution sources, payout information, and bonus terms in plain language.
• Fair Games & Markets: Make sure games are tested or certified where required, and that markets are settled correctly under their published rules.
• Payouts: Pay winnings and process withdrawals promptly under its terms, and never delay or withhold funds to encourage further play.
• Monitoring & Intervention: Watch for signs of harm and act on them, as described in Identifying & Responding to Harm.
• Responsible Marketing: Meet the standards in Advertising & Promotions.
• Staff Training: Train staff who deal with End Users or their accounts to recognize signs of harm and respond appropriately.
• Complaints: Maintain a fair, accessible process for handling End User complaints.
• Cooperation: Provide the information Axis reasonably requests to review compliance with this Policy.

7) Protection of Minors

• Minors must not be allowed to register, deposit, or gamble on any Operator Platform.
• Operators must verify an End User's age before the End User can deposit or gamble, and must promptly close any account found to belong to a Minor and handle its wagers and balance as required by applicable law.
• Advertising must not be directed at Minors, use content that particularly appeals to Minors, or appear in media aimed mainly at Minors.
• Operators should give End Users information about parental control and filtering tools that can block access to gambling sites.

8) Self-Exclusion

When an End User self-excludes, the Operator must:

• Block new deposits and wagers immediately, and close or suspend the account for the full exclusion period.
• Return any remaining withdrawable balance under its terms and applicable law.
• Stop all marketing to the End User promptly, including marketing sent by affiliates.
• Take reasonable steps to stop the End User from opening a new account during the exclusion period.
• Not allow the self-exclusion to be reversed before the exclusion period ends.
• After the exclusion period ends, reopen the account only if the End User actively asks, and only after a waiting period of at least 24 hours.

Operators must offer self-exclusion periods of at least 6 months, along with longer and permanent options, and must honor any national or regulator-run self-exclusion scheme that applies to them. Self-exclusion records are kept even after an account is closed, as described in our Data Retention & Deletion Policy.

9) Identifying & Responding to Harm

Operators must monitor End User activity for signs of harm, such as:

• Rapid increases in how much or how often an End User deposits.
• Chasing losses, including repeated deposits soon after losing.
• Repeated attempts to raise limits, or to deposit after reaching a limit.
• Cancelling withdrawals in order to keep gambling.
• Gambling for unusually long periods, or at unusual times such as overnight.
• Repeated failed deposit attempts, or use of many different payment methods.
• Messages to support or chat that suggest distress or loss of control.

When these signs appear, the Operator must take proportionate action, such as contacting the End User, sharing help resources, applying limits, pausing promotions, or suspending the account. Operators may use the Platform's risk monitoring tools to help, but they remain responsible for identifying harm and acting on it.

10) Advertising & Promotions

Operators must make sure that all of their advertising, bonuses, and promotions, including those run by affiliates:

• Are lawful, accurate, and not misleading, with significant terms stated clearly.
• Are not directed at Minors, self-excluded End Users, or End Users who have opted out of marketing.
• Do not suggest that gambling is a way to earn income, solve financial problems, or achieve personal or social success.
• Do not encourage End Users to chase losses or to gamble more than they intended.
• Include a responsible gaming message and a link to help resources where appropriate.

11) Review & Enforcement

• Axis may review any Operator Platform for compliance with this Policy at any time, including its configuration, marketing, End User complaints, payouts, games, and markets, and may request information from the Operator.
• If Axis finds that an Operator is not meeting this Policy, Axis may require the Operator to fix the issue within a set time, restrict Platform features, or suspend or terminate the Operator's access under our Terms of Service.
• Axis may share information with regulators or law enforcement where required by law.
• The absence of a review or of action by Axis does not mean that an Operator is compliant.

12) Help & Support

If you are an End User and want to set a limit, take a break, or self-exclude, please contact the Operator of the site you use. Axis does not manage End User accounts. If you contact Axis, we will direct you to the right Operator.

If gambling is causing harm to you or someone you know, free and confidential help is available:

• United States: National Problem Gambling Helpline, 1-800-GAMBLER (1-800-426-2537), provided by the National Council on Problem Gambling.
• United Kingdom: National Gambling Helpline, 0808 8020 133, provided by GamCare.
• International: Gambling Therapy offers free online support in several languages at gamblingtherapy.org.
• Peer Support: Gamblers Anonymous meetings are held around the world. Find one at gamblersanonymous.org.

13) Disclaimer

14) Changes to This Policy

We may update this Policy from time to time by posting a revised version on this page with a new effective date. We will notify Operators of material changes by email or through the Platform.

15) Contact

For questions about this Policy, email support@axis.inc with "Responsible Gaming" in the subject line. If you are an End User, please contact the Operator of the site you use.