Responsible Gameplay Policy

Responsible Gameplay Policy

Introduction

Oakridge Interactive LLC (“Eazy6,” the “Company”) is committed to operating its platform in a secure, fair, and socially responsible way. Our aim is to promote responsible gameplay among players, employees, and stakeholders. Responsible gameplay encompasses the processes, tools, and resources that allow players to have a fair and safe experience with the Company, while helping protect them from problem play and unhealthy play patterns. Eazy6 is committed to complying with applicable laws and platform requirements and to maintaining controls that support contest integrity, account security, and player wellbeing.

Scope: Two Contest Modes. This Policy applies to both (a) Free-to-Play Contests, which do not require an entry fee and do not award anything of monetary value, and (b) Paid Contests (also referred to as “Paid DFS Contests”), which are peer-to-peer, pool-based, skill-based daily fantasy sports contests offered only in eligible U.S. jurisdictions, only to users who have completed identity verification, and in which users pay a cash entry fee for the opportunity to win cash prizes. Sections of this Policy that apply only to Paid Contests are clearly marked as such. Money-related player-safety tools — including deposit and wagering limits, cool-off periods, and self-exclusion — apply only to Paid Contests.

As part of this Policy, Eazy6 will:

  • Comply with applicable laws and platform requirements relating to responsible gameplay and user protection;

  • Inform players and prospective players about the help and assistance they can access should they experience signs of problem play or unhealthy play patterns;

  • Make all reasonable efforts to avoid marketing to minors, as defined by applicable law and platform standards;

  • Ensure that marketing and advertising efforts are responsible and contain any relevant player-safety information required by applicable law and platform standards; and

  • For Paid Contests, make available responsible-play tools (limits, cool-off, and self-exclusion) and problem-gambling resources, as described in this Policy.

1. Registration and Verification

1.1 Prohibition of Underage Players

  • Participation by an underage player is prohibited. Before a player can complete registration and begin play in the App, the player must accept Eazy6’s Terms of Service and affirm that he or she is at least eighteen (18) years of age, or such higher minimum age as may be required by the law of the state in which the player is located, particularly for Paid Contests.

  • Eazy6 checks the name, date of birth, and location of an individual at registration. For Paid Contests, age is further verified as part of identity verification conducted by the Company’s Identity Verification Provider before the first deposit, first Paid Contest entry, or first withdrawal (whichever occurs first).

  • If a player is confirmed to be a minor, Eazy6 will undertake the steps required to block that player’s access, close the account, and reverse or refund any affected transactions, consistent with applicable law.

1.2 Single Account per Player

  • Eazy6 allows each player to register and maintain only one active account. There are no exceptions.

  • Duplicate accounts are flagged and closed by the Company. This process supports the Company’s fraud, security, and anti-money-laundering responsibilities, and prevents players from circumventing account restrictions, responsible-play limits, cool-off periods, or self-exclusion applied to their original account.

  • The Company monitors for potential duplicate accounts using signals including duplicate email addresses, mobile numbers, device identifiers, payment-method identifiers, shared IP addresses, name and address matches, and identity-verification matches. On detection, a soft lock may be applied and Customer Support will address the issue with the player.

1.3 Identity Verification (Paid Contests)

For Paid Contests, each player must complete identity verification through the Company’s Identity Verification Provider before making the player’s first deposit, entering the player’s first Paid Contest, or initiating the player’s first withdrawal. Verification includes document authentication, biometric/facial matching, liveness detection, age verification, and sanctions/PEP screening. Players who fail or decline to complete verification are not permitted to participate in Paid Contests.

2. Monetization and Rewards

2.1 Free-to-Play Contests

Free-to-Play Contests are offered for entertainment purposes only and do not award cash, gift cards, or anything else of monetary value. In-app points, standings, and leaderboard positions for Free-to-Play Contests have no cash or monetary value and may not be sold, transferred, exchanged, or redeemed.

2.2 Paid Contests

In Paid Contests, players pay a cash entry fee for the opportunity to win cash prizes distributed from a peer-to-peer prize pool. The structure of each Paid Contest — including the entry fee, the platform fee covering the operations of the platform, the number of tiers and allocation percentages, the minimum qualifying threshold, and the possibility that no entry meets the minimum qualifying threshold (in which case no payouts are made) — is disclosed on the contest page before entry, as described in the Terms of Service. Players are encouraged to play responsibly and within their means, and to use the responsible-play tools described in Section 3.

3. Responsible Play Tools (Paid Contests Only)

Eazy6 provides self-directed responsible-play tools within the App to help players manage their participation in Paid Contests. These tools are available to all Paid Contest players and may be configured at any time from the player’s account settings.

3.1 Deposit Limits

Players may set self-imposed deposit limits on a daily, weekly, and monthly basis. Once a deposit limit is in effect:

  • Deposits that would cause the player to exceed the applicable limit within the applicable period are blocked in the App; and

  • Requests to decrease an existing limit take effect immediately; requests to increase or remove a limit take effect only after a cooling period of at least twenty-four (24) hours, during which the existing (lower) limit continues to apply.

3.2 Entry-Fee and Wagering Limits

Players may set self-imposed limits on total entry fees across Paid Contests on a daily, weekly, and monthly basis. Once an entry-fee limit is in effect:

  • Entries that would cause the player to exceed the applicable limit within the applicable period are blocked in the App; and

  • Requests to decrease an existing limit take effect immediately; requests to increase or remove a limit take effect only after a cooling period of at least twenty-four (24) hours, during which the existing (lower) limit continues to apply.

3.3 Cool-Off Periods

Players may voluntarily activate a cool-off period during which Paid Contest participation is paused. Cool-off durations available are:

  • Twenty-four (24) hours;

  • Seventy-two (72) hours;

  • Seven (7) days; and

  • Thirty (30) days.

During a cool-off period, the player cannot make deposits or enter Paid Contests. The player may continue to access the App for non-wagering purposes and may initiate withdrawals of existing cash wallet balances. Cool-off periods cannot be shortened or cancelled once activated.

3.4 Self-Exclusion

Players may voluntarily enroll in self-exclusion to cease Paid Contest participation for a fixed term or permanently. Self-exclusion durations available are: 

  • Six (6) months;

  • One (1) year;

  • Five (5) years; and

  • Permanent (irrevocable).

Self-exclusion is account-wide and, where technically feasible, applies across all Company properties and contest modes. During the self-exclusion period: 

  • The player’s account is closed or restricted to prevent deposits and Paid Contest entries;

  • Cash wallet balances remaining at the time of enrollment are returned to the player’s verified payment method(s), subject to identity-verification, anti-fraud, and chargeback controls;

  • The player will not receive marketing communications promoting Paid Contests;

  • Self-exclusion cannot be shortened or cancelled during the elected term; permanent self-exclusion is irrevocable; and

  • The Company will take reasonable steps to prevent the self-excluded player from opening a new account under the same or different identifying information during the exclusion period.

At the end of a fixed-term self-exclusion (other than permanent), the player must affirmatively request reinstatement and complete re-verification before the account is restored. The Company reserves the right to decline reinstatement where warranted by the Company’s risk and compliance review.

4. Responsible Gameplay Information and Problem-Gambling Resources

Eazy6 ensures that relevant responsible-gameplay and problem-gambling information is clearly accessible to players in the App, on the Company’s website, and in qualifying marketing communications. These resources are provided by reputable organizations with expertise in supporting individuals experiencing problem play or related concerns, and their families.

4.1 National Resources

  • National Council on Problem Gambling (NCPG) – 1-800-GAMBLER (1-800-426-2537) or text 800GAM. Available 24 hours a day, 7 days a week, and provides confidential help and referrals for problem gambling.

  • SAMHSA National Helpline – 1-800-662-HELP (1-800-662-4357). Free, confidential, 24/7 treatment referral and information service (in English and Spanish) operated by the U.S. Substance Abuse and Mental Health Services Administration for individuals and families facing mental and/or substance use disorders, which frequently co-occur with problem gambling.

4.2 State-Specific Resources

In addition to the national resources listed above, state-specific problem-gambling helplines, treatment resources, and regulatory information are maintained within the Eazy6 App and on the Company’s website for each Eligible Jurisdiction in which Paid Contests are offered. This list is updated from time to time as the Company’s operating footprint and state-level resources change; updates to state-specific resources will not by themselves require an amendment to this Policy.

4.3 Placement and Prominence

Eazy6 communicates the location of these resources in a manner that allows a player to easily identify them, including in-App settings screens, the Company’s website, deposit and withdrawal flows for Paid Contests, self-exclusion enrollment flows, and, where required by law or platform standards, in marketing and advertising materials that reference Paid Contests. At a minimum, responsible-gameplay information includes the name and toll-free number of at least one reputable source where players can receive assistance.

5. Player Activity Monitoring and Intervention

Player activity is monitored for behavior that may indicate a possible concern or responsible-gameplay issue. The Company reviews behavioral signals across both Free-to-Play and Paid Contests, and integrates those signals with the fraud, integrity, and anti-money-laundering controls described in the AML, Sanctions & KYC Compliance Policy. Signals monitored may include, but are not limited to:

  • Time of day, frequency, and duration of play sessions;

  • Significant increases in play time or repeated extended sessions;

  • Rapid escalation in deposit frequency, deposit amount, or entry-fee size (Paid Contests);

  • Repeated failed deposit attempts, chargebacks, or payment reversals (Paid Contests);

  • Frequent requests to adjust responsible-play limits;

  • Play continuing after substantial losses (loss-chasing behavior) (Paid Contests);

  • Repeated attempts to circumvent account restrictions, cool-off periods, self-exclusion, or identity-verification controls;

  • Communications with Customer Support indicating distress, financial hardship, or problem-play concerns; and

  • Information received from the Payment Services Provider, Identity Verification Provider, or other reliable third party suggesting heightened risk to player wellbeing.

When concerns are identified, Eazy6 may contact the player to discuss the observations, provide problem-gambling resources, recommend or prompt use of responsible-play tools (limits, cool-off, or self-exclusion), temporarily restrict the account pending review, or, in appropriate circumstances, close the account. Automated risk signals are not used to make decisions producing legal or similarly significant effects without human review where required by law.

6. Prohibited Advertising to Minors

Eazy6 will not market exclusively or primarily to minors, as defined by applicable law and platform standards. To ensure that Eazy6 marketing does not target minors, the Company will:

  • Require partner media outlets and other entities to take reasonable measures not to target minors on behalf of Eazy6;

  • Make reasonable efforts to ensure that advertising networks do not place Eazy6 material in digital channels aimed exclusively or primarily at minors;

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

  • Require that individuals or entities speaking on behalf of Eazy6 on television, radio, or online outlets understand and acknowledge this aspect of the Company’s 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 Company’s marketing policy.

7. Responsible Marketing

Eazy6 ensures that marketing communications do not suggest that our contests or skill-based contests are a solution to financial concerns, an alternative to employment, or a way to achieve financial security. Eazy6 makes responsible-gameplay information clearly and conspicuously available to consumers in the App and on the Company’s website. For Paid Contests, marketing communications will, where required by law or platform standards, include reference to at least one problem-gambling helpline (for example, 1-800-GAMBLER) and the applicable minimum age requirement.

The Company will not make affirmative claims about odds or expected returns that are not accurate and substantiated, and will not use imagery, language, or inducements that target minors, vulnerable individuals, or self-excluded players.

8. Employees, Contractors, and Sports Insiders

Employees, contractors, directors, and officers of the Company, as well as their household members, are prohibited from entering Paid Contests on the Eazy6 platform. Players with access to non-public information material to the outcome of Paid Contests — including, without limitation, players, coaches, referees, league officials, team staff, sports data employees, and scorers associated with the underlying real-world events — are likewise prohibited from entering Paid Contests. These restrictions are additional to the broader prohibited-conduct obligations set forth in the Terms of Service.

9. Training

Responsible-gameplay training is provided to employees, contractors, and other stakeholders of the Company on a risk-based and role-appropriate basis, including:

  • Baseline responsible-gameplay training for all employees on an annual basis;

  • Role-specific training for Customer Support, trust-and-safety, compliance, payment-operations, and marketing personnel, covering how to recognize and respond to responsible-gameplay concerns;

  • At-hire training for new employees before they are assigned to roles involving player-facing communication, account administration, or compliance escalations; and

  • Ad-hoc training when policies, procedures, responsible-play tools, or applicable laws materially change.

Training materials cover, at a minimum: Eazy6’s current policies and procedures related to responsible gameplay, account security, and support escalation; red flags that help identify potential unhealthy play patterns; how to assist a player who may be at risk of harm or experiencing compulsive play; responsible-play tools available in the App and how to help a player enroll; and confidentiality obligations regarding player communications and records. 

10. Periodic Review

Eazy6 will conduct a review of this Responsible Gameplay Policy no less frequently than annually, and sooner if material changes to the Services, regulatory environment, or platform standards warrant. Material changes to the Policy will be reviewed and approved by the Company’s designated policy owner (or their designee) and logged in the revision history below.

11. Record Retention

Eazy6 maintains all documentation related to this Responsible Gameplay Policy in accordance with the Company’s data retention practices and applicable legal requirements. Retained records include: responsible-play tool configurations and changes (limit settings, cool-off, self-exclusion enrollments and reinstatements); player history and play activity; Customer Support contacts and resolutions related to responsible gameplay; marketing and advertising materials; and training completion records. Minimum retention periods align with the Company’s AML, Sanctions & KYC Compliance Policy (five years) and applicable state laws, and may be extended for legal holds or ongoing investigations.


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