Legal

Digimatrix Legal Documentation Suite

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TABLE OF CONTENTS

1. Anti-Money Laundering (AML) Policy
2. Know-Your-Customer (KYC) Requirements
3. Responsible Gaming Policy
4. Cookie Policy
5. Affiliate Terms and Conditions
6. White-Label Agreement
7. Enterprise Partner Agreement
8. Copyright and DMCA Notice
9. Accessibility Statement
10. Incident Response and Data Breach Notification

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1. ANTI-MONEY LAUNDERING (AML) POLICY

Effective Date: November 2025

1.1 Overview

Digimatrix is committed to combating money laundering, terrorist financing, and other financial crimes. This AML Policy establishes comprehensive procedures to detect, prevent, and report suspicious activities in accordance with applicable anti-money laundering laws and regulations.

1.2 Regulatory Compliance

We comply with:

• Financial Action Task Force (FATF) Recommendations
• FinCEN (Financial Crimes Enforcement Network) regulations
• OFAC (Office of Foreign Assets Control) sanctions lists
• EU Anti-Money Laundering Directives
• Local and jurisdictional AML requirements

1.3 AML Program Requirements

Customer Due Diligence (CDD)

• Verify customer identity using government-issued documents
• Obtain beneficial ownership information
• Assess customer risk profile
• Document all verification attempts and results

Enhanced Due Diligence (EDD)

• Applied to high-risk customers, politically exposed persons (PEPs), and high-value accounts
• Additional verification layers and ongoing monitoring
• Enhanced documentation requirements

Ongoing Monitoring

• Continuous transaction monitoring for suspicious patterns
• Alert thresholds for unusual account activity
• Periodic customer profile reviews
• Escalation procedures for anomalies

1.4 Suspicious Activity Reporting (SAR)

• All suspected money laundering activities are reported to relevant authorities
• Reports filed within required timeframes (typically 30 days of detection)
• Suspicious transaction thresholds are established and enforced
• Red flags include: structuring deposits, unexplained wealth, rapid fund transfers

1.5 Restricted Jurisdictions and Sanctions Screening

• Screening against OFAC SDN (Specially Designated Nationals) lists
• Blocking transactions with sanctioned jurisdictions
• Regular updates to sanctions lists
• Denial of service to high-risk jurisdictions

1.6 Record Keeping

• Retention of customer identification records for minimum 5-7 years
• Documentation of all due diligence procedures
• Transaction records maintained for regulatory audit
• Audit trails for all system changes and manual overrides

1.7 Training and Compliance

• Annual AML training for all employees
• Designated AML Compliance Officer with authority and resources
• Staff procedures for reporting suspicious activities
• Disciplinary measures for policy violations

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2. KNOW-YOUR-CUSTOMER (KYC) REQUIREMENTS

Effective Date: November 2025

2.1 Purpose

KYC procedures establish the identity of customers to prevent fraud, money laundering, and terrorist financing, and to ensure regulatory compliance.

2.2 Customer Identification Program (CIP)

Initial Verification

• Full legal name
• Date of birth
• Residential address
• Government-issued ID (passport, driver’s license, national ID)
• Secondary verification document (utility bill, bank statement)

Documentation Requirements

• Clear photographic identification
• Proof of address (less than 3 months old)
• Verification of employment or income source (for high-value accounts)
• Beneficial ownership disclosure for business accounts

2.3 Risk-Based KYC Approach

Low-Risk Customers:

• Standard verification procedures
• Annual identity confirmation
• Basic transaction monitoring

Medium-Risk Customers:

• Enhanced verification requirements
• Source of funds documentation
• Quarterly monitoring and updates

High-Risk Customers:

• Comprehensive due diligence
• Senior management approval required
• Enhanced ongoing monitoring
• Possible service denial

2.4 Beneficial Ownership Identification

For business and corporate accounts:

• Identification of individuals with beneficial ownership (25%+ stake)
• Verification of decision-makers and authorized representatives
• Corporate registration verification
• Ultimate beneficial owner (UBO) identification

2.5 Ongoing KYC Compliance

• Annual customer information updates
• Address verification
• Changes in account activity patterns reviewed
• Re-verification triggered by major life events or transactions

2.6 Politically Exposed Persons (PEPs)

• Screening against PEP databases
• Enhanced due diligence for PEPs and related parties
• Senior management approval for PEP accounts
• Enhanced monitoring of PEP transaction patterns

2.7 Layered Identity Verification

• Document verification (OCR technology)
• Biometric verification where applicable
• Address verification through third-party databases
• Credit bureau checks for additional verification

2.8 Data Privacy and Security

• KYC information protected under data protection regulations
• Secure storage with encryption
• Limited access on need-to-know basis
• Secure destruction after retention period expires

2.9 Customer Account Restrictions

Digimatrix may restrict or close accounts where:

• KYC verification cannot be completed satisfactorily
• Customer engages in suspicious activity patterns
• Customer is identified on sanctions lists
• Customer provides false or misleading information

2.10 Appeals and Dispute Process

• Customers may appeal account restrictions or closures
• Appeal process explained in writing
• Formal review by compliance team
• Decision provided within 30 days

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3. RESPONSIBLE GAMING POLICY

Effective Date: November 2025

3.1 Commitment Statement

Digimatrix is committed to promoting safe, fair, and entertaining gaming experiences while protecting vulnerable players from gambling-related harms.

3.2 Player Awareness and Education

• Clear disclosure of odds and RTP percentages
• Educational materials about gambling risks
• Problem gambling warning messages
• Links to support organizations and helplines

3.3 Spending Limits and Controls

Deposit Limits

• Daily deposit limits (minimum €/$/etc. customizable)
• Monthly deposit limits
• Player-set limits enforceable immediately
• No exceptions to deposit limits

Loss Limits

• Maximum loss allowances per day or month
• Players notified when approaching limits
• Automatic account suspension upon reaching limits

Betting Limits

• Maximum bet sizes per game
• Limits adjustable by player
• Enforced across all gaming sessions

Time Limits

• Session time reminders (30 min, 1 hr, 2 hr intervals)
• Mandatory break periods
• Countdown timers for session expiration

3.4 Self-Exclusion Program

Voluntary Exclusion Options

• Temporary self-exclusion (24 hours to 6 months)
• Permanent self-exclusion
• Multi-operator self-exclusion programs where available
• Irrevocable during exclusion period

Self-Exclusion Process

• Clear request procedures through account settings
• Immediate implementation (within 24 hours maximum)
• Confirmation email with exclusion details
• No promotional contact during exclusion

Self-Exclusion Termination

• Customers cannot reverse exclusions early
• Automatic reinstatement only after period expires
• Written notice required before reactivation

3.5 Account Cooling-Off Periods

• 24-hour cooling-off periods available on demand
• 5-day extended cooling-off periods for concerned players
• Mandatory cooling-off after large losses (where legally required)
• Account temporarily locked; no access or deposits during period

3.6 Reality Checks and Session Warnings

• Pop-up reminders showing session duration and money spent
• Automatic session interruptions at intervals
• Information about time and money spent displayed prominently
• Reality check frequency customizable by player

3.7 Early Warning System

• Automated detection of problem gaming indicators
• Metrics include: frequency of play, session duration, bet sizes, loss patterns
• Alerts to players showing concerning trends
• Encouragement to use responsible gaming tools

3.8 Vulnerable Population Protection

Age Verification

• Strict age verification at registration and deposit
• Re-verification of age for high-value accounts
• Blocking of underage account access

Financial Vulnerability

• Identification of players using unsecured credit
• Warnings about credit-funded gaming
• Self-exclusion encouragement for at-risk players

Problem Gambling Indicators

• Detection of rapid account depletion
• Recognition of chasing losses behavior
• Identification of failed deposit limit attempts

3.9 Staff Training

• Annual responsible gaming training for all staff
• Recognition of problem gambling signs
• Procedures for assisting concerned players
• Customer service protocols for vulnerable players

3.10 Support Resources

• 24/7 access to problem gambling helplines
• Links to certified addiction counseling services
• Information about Gamblers Anonymous and similar organizations
• Free, confidential resources at point of contact

Partner Organizations

• National Council on Problem Gambling
• Gamblers Anonymous
• NCPG (National Center for Responsible Gaming)
• Local gambling addiction services

3.11 Grievance and Complaints

• Clear procedures for complaint submission
• Investigation of all responsible gaming complaints
• Response within 14 days
• Escalation procedures for unresolved issues

3.12 Continuous Improvement

• Regular review of responsible gaming measures
• Player feedback integration
• Updating of tools and resources
• Annual policy review and updates

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4. COOKIE POLICY

Effective Date: November 2025

4.1 What Are Cookies?

Cookies are small data files stored on your device that help us recognize you and enhance your experience. This policy explains how Digimatrix uses cookies and similar tracking technologies.

4.2 Types of Cookies We Use

Essential Cookies

• Authentication and login functionality
• Session maintenance
• Security and fraud prevention
• Cannot be disabled without losing service functionality

Performance Cookies

• Analytics and usage statistics
• Page load times and performance metrics
• Error tracking and diagnostics
• Aggregated data collection for improvement

Functionality Cookies

• Remembering user preferences and settings
• Language and regional settings
• Gaming preferences and customization
• Personalization of user experience

Marketing Cookies

• Tracking advertising performance
• Targeted advertising based on interests
• Remarketing campaigns
• Social media integration
• Behavioral targeting (only with consent)

Third-Party Cookies

• Analytics providers (Google Analytics, Mixpanel)
• Payment processors
• Advertising networks
• Social media platforms

4.3 Cookie Duration

• Session cookies: Deleted when browser closes
• Persistent cookies: Retained up to 24 months
• User-controlled cookies: Deleted upon preference change
• Required by law: Retained per regulatory requirements

4.4 Cookie Consent

• Explicit consent required for non-essential cookies
• Cookie consent banner displayed on first visit
• Users can accept all, reject all, or customize preferences
• Consent preferences stored and respected

4.5 Managing Cookies

Browser Settings

• Most browsers allow cookie management through settings
• Users can delete existing cookies
• Users can block future cookies
• Instructions available for all major browsers

Opt-Out Options

• Opt out of marketing cookies through preference center
• Opt out of analytics through provider settings
• Do Not Track (DNT) signals honored where applicable
• Cookie management dashboard available in account settings

4.6 Privacy and Security

• Cookies do not contain sensitive personal information
• Cookies are encrypted for security
• Payment information never stored in cookies
• Cross-domain cookie tracking disabled

4.7 Third-Party Cookie Privacy

• Third parties bound by data protection agreements
• Third parties prohibited from sharing cookie data
• Links to third-party privacy policies available
• Users can opt out of third-party tracking

4.8 Cookie Updates

• This policy updated as new technologies emerge
• Users notified of material cookie practice changes
• Historical versions available upon request

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5. AFFILIATE TERMS AND CONDITIONS

Effective Date: November 2025

5.1 Affiliate Program Overview

Digimatrix Affiliate Program allows partners to earn commissions by referring players to our platforms.

5.2 Eligibility

• Must be 18 years or older
• Compliance with all applicable laws
• No competing affiliate relationships without approval
• Acceptance of Digimatrix affiliate standards

5.3 Commission Structure

• Revenue share model: [X]% of player net gaming revenue
• CPA (Cost Per Acquisition) model: Fixed fee per depositing player
• Hybrid models available for high-performing affiliates
• Commission tiers based on monthly volume

5.4 Payment Terms

• Commissions calculated monthly
• Payment processed within 15 business days
• Minimum payout threshold: [Insert Amount]
• Payments via bank transfer, payment processor, or agreed method

5.5 Promotional Guidelines

• Use only approved Digimatrix marketing materials
• No misleading or false advertising
• No paid search on Digimatrix brand terms without approval
• Compliance with FTC disclosure requirements

5.6 Prohibited Affiliate Practices

• No spam or unsolicited communications
• No trademark bidding without authorization
• No mobile app store manipulation
• No trademark infringement
• No fraudulent or invalid traffic
• No incentivized player recruitment without disclosure

5.7 Player Quality Standards

• Players must be legitimate users
• No bot-generated or fake player traffic
• Players must meet KYC requirements
• Players must comply with Digimatrix Terms and Conditions

5.8 Clawback and Chargeback Policy

• Fraudulent commissions subject to clawback
• Commissions reversed for disputed transactions
• Player refunds result in commission reversal
• Account closure results in pending commission forfeiture

5.9 Affiliate Account Management

• Dedicated affiliate dashboard
• Real-time tracking and reporting
• Marketing material access
• Support contact availability

5.10 Termination

• Either party may terminate with 30 days notice
• Immediate termination for policy violations
• Outstanding commissions paid upon valid termination
• Non-compete clause: [X] months post-termination

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6. WHITE-LABEL AGREEMENT

Effective Date: November 2025

6.1 White-Label Service Description

Digimatrix provides customizable gaming platform infrastructure to partners for operation under their own branding.

6.2 License Grant

• Non-exclusive license to use Digimatrix platform technology
• License limited to Partner’s specified domain and branding
• License terminable for cause or upon agreement
• All intellectual property remains Digimatrix property

6.3 Platform Customization

• Branding customization (logos, colors, themes)
• Game selection and availability
• Custom domain and white-label URL
• API integration capabilities

6.4 Technical Support

• 24/7 technical support for platform operation
• Regular system maintenance windows
• Uptime SLA: [X]% availability guarantee
• Emergency response protocols for critical issues

6.5 Regulatory Responsibility

• Partner responsible for obtaining gaming licenses
• Partner liable for regulatory compliance in their jurisdiction
• Digimatrix provides compliance infrastructure and documentation
• Partner indemnifies Digimatrix for regulatory violations

6.6 Revenue Share

• Revenue sharing model: [X]% to Partner, [X]% to Digimatrix
• Monthly accounting and settlement
• Minimum monthly guarantee: [Insert Amount]
• Bonus structures for performance milestones

6.7 Payment Processing

• Digimatrix provides payment processor integration
• Partner responsible for merchant account compliance
• KYC and AML screening performed by Digimatrix
• Chargebacks and disputes handled per agreement

6.8 Player Data and Privacy

• Partner controls player account data
• Digimatrix retains operational and analytical data
• Data sharing agreements govern information exchange
• Privacy policy compliance required from Partner

6.9 Term and Termination

• Initial term: [X] years
• Automatic renewal unless terminated
• Either party may terminate with [X] days notice
• Termination for cause: immediate effect
• Player data return and transition procedures

6.10 Performance Metrics

• Monthly reporting on player metrics
• Gaming revenue tracking and reconciliation
• Player retention and engagement analytics
• Problem gaming report submission

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7. ENTERPRISE PARTNER AGREEMENT

Effective Date: November 2025

7.1 Partnership Overview

Digimatrix partners with enterprises to provide scalable gaming infrastructure and enterprise ecosystem solutions.

7.2 Scope of Services

• Platform development and customization
• Infrastructure hosting and support
• Player acquisition and retention tools
• Analytics and business intelligence
• Compliance and regulatory support

7.3 Service Levels

• Platform availability: [X]% uptime SLA
• Response times for support requests: [X] hours
• Deployment of updates and enhancements
• Quarterly business reviews and performance analysis

7.4 Data and Reporting

• Custom reporting dashboards
• Real-time analytics and metrics
• Monthly performance reports
• Quarterly strategic reviews

7.5 Fees and Payments

• Monthly platform licensing fee
• Per-player fees based on active users
• Custom development fees for enhancements
• Annual true-up and reconciliation

7.6 Intellectual Property

• Partner retains ownership of brand and content
• Digimatrix retains platform technology IP
• Custom developments owned by Digimatrix
• Licensing of third-party technologies

7.7 Confidentiality

• Mutual confidentiality obligations
• Competitive information protection
• Restricted access to sensitive data
• Term extends beyond agreement termination

7.8 Compliance and Risk

• Partner responsible for regulatory licenses
• Partner complies with all gaming regulations
• Digimatrix provides compliance infrastructure
• Risk allocation and insurance requirements

7.9 Termination and Transition

• Term: [X] years with renewal options
• Termination for cause: immediate
• Termination for convenience: [X] days notice
• Data transition and player account management
• Transition support period: [X] days

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8. COPYRIGHT AND DMCA NOTICE

Effective Date: November 2025

8.1 Copyright Notice

All content on Digimatrix platforms, including software, graphics, games, designs, text, and images, is protected by copyright and other intellectual property laws.

© 2025 Digimatrix. All rights reserved.

8.2 Intellectual Property Rights

• Digimatrix owns or licenses all platform content
• Unauthorized reproduction or distribution prohibited
• No reverse engineering or decompilation
• No derivative works without permission

8.3 DMCA Compliance

Digimatrix complies with the Digital Millennium Copyright Act (DMCA) and similar laws in other jurisdictions.

Notice and Takedown Procedures

• Copyright holders may submit DMCA takedown notices
• Notice must include specific infringing content identification
• Notices must be submitted to our Copyright Agent
• Digimatrix acts expeditiously upon valid notices

Copyright Agent Contact

DMCA Agent: Digimatrix Copyright Department Email: copyright@digimatrix.com Address: [Insert Address] Phone: [Insert Phone]

8.4 Counter-Notification Process

Users may submit counter-notices if they believe content was removed in error:

• Counter-notice must identify the removed content
• User certifies content removal was mistaken
• Counter-notice signed under penalty of perjury
• Processing occurs within 10-14 business days

8.5 Repeat Infringement Policy

• Users with multiple DMCA violations may have accounts terminated
• Repeat infringers permanently banned from platforms
• Digimatrix retains evidence of violations
• Legal action may be pursued for flagrant infringement

8.6 Fair Use

• Limited reproductions for personal, non-commercial use permitted
• Educational use and criticism protected under fair use
• Research and commentary exceptions apply
• Transformative works evaluated case-by-case

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9. ACCESSIBILITY STATEMENT

Effective Date: November 2025

9.1 Commitment to Accessibility

Digimatrix is committed to ensuring digital accessibility and usability for all users, including those with disabilities.

9.2 Web Content Accessibility Guidelines (WCAG)

• Compliance with WCAG 2.1 Level AA standards
• Regular accessibility audits and testing
• Third-party accessibility assessments
• Ongoing improvements and updates

9.3 Accessibility Features

Visual Accessibility

• High-contrast color options
• Adjustable text sizes
• Screen reader compatibility
• Alt text for images
• Readable fonts and sufficient spacing

Motor and Navigation

• Full keyboard navigation
• Voice control compatibility
• Large clickable target areas
• Keyboard shortcuts for common functions

Cognitive Accessibility

• Clear, simple language
• Consistent navigation and layout
• Helpful error messages
• Time extensions for tasks

Audio Accessibility

• Video captions and transcripts
• Audio descriptions for important content
• Adjustable audio volume controls
• Visual indicators for sound alerts

9.4 Assistive Technology Compatibility

• Screen reader optimization (NVDA, JAWS)
• Voice control support
• Mobile accessibility features
• Browser plugin compatibility

9.5 Accessibility Support

• Accessibility feedback email: accessibility@digimatrix.com
• Alternative access methods available
• Dedicated support for accessibility issues
• Remediation timeline for identified issues

9.6 Known Limitations

• Third-party content may not meet accessibility standards
• Certain game features may have limited accessibility options
• Mobile app accessibility varies by device and OS
• Legacy content being gradually updated

9.7 Accessibility Roadmap

• Regular accessibility improvements scheduled
• User feedback incorporated into development
• Quarterly accessibility reviews
• Annual third-party accessibility audits

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10. INCIDENT RESPONSE AND DATA BREACH NOTIFICATION

Effective Date: November 2025

10.1 Incident Response Framework

Digimatrix maintains comprehensive incident response procedures to address security breaches, data loss, and other security incidents.

10.2 Incident Classification

Critical Incidents

• Unauthorized access to customer payment data
• Large-scale data breaches affecting 1000+ users
• Loss of service availability (>4 hours)
• Ransomware or malware infection

High-Priority Incidents

• Unauthorized access to personal information
• Service disruption (1-4 hours)
• Suspected insider threats
• Database vulnerabilities

Medium-Priority Incidents

• Unsuccessful intrusion attempts detected
• Minor data exposure (<100 users)
• Service degradation
• Third-party vendor incidents

10.3 Incident Detection

• 24/7 security monitoring systems
• Intrusion detection systems (IDS)
• User report mechanisms
• Third-party notifications
• Automated alerts and escalation

10.4 Incident Response Team

• Chief Information Security Officer (CISO)
• Incident Response Coordinator
• Legal and Compliance Team
• Technical Investigation Team
• Communications and PR Team

10.5 Investigation and Containment

• Immediate incident investigation upon notification
• Containment measures to prevent spread
• Forensic analysis and evidence preservation
• Root cause analysis
• Investigation report generation

10.6 Breach Notification Requirements

Notification Timeline

• Without unreasonable delay
• Minimum 30 days of breach discovery (varies by jurisdiction)
• If notification would compromise law enforcement investigation: after consultation with authorities

Notification Content

• Nature of personal information breached
• Estimated number of affected individuals
• Steps taken to mitigate harm
• Contact information for further questions
• Credit monitoring offers where applicable

Notification Methods

• Email to last known email address
• Postal mail for physical addresses
• Public notice for large-scale breaches
• Notification to regulatory authorities where required

10.7 Regulatory Notifications

• Notification to relevant data protection authorities
• Notification to gaming regulators
• Notification to financial regulators
• Notification to law enforcement if criminal activity

10.8 User Support and Remediation

• Free credit monitoring (if applicable)
• Identity theft protection services
• Extended monitoring (minimum 2 years)
• Dedicated support hotline
• FAQ and resource guides

10.9 Transparency and Communication

• Public disclosure of significant breaches
• Regular updates to affected users
• Cooperation with law enforcement
• Media inquiry response procedures

10.10 Post-Incident Review

• Lessons learned documentation
• Remediation action plan
• System improvements implementation
• Policy and procedure updates
• Training and awareness updates

10.11 Insurance and Financial Protection

• Cyber liability insurance coverage
• Third-party liability coverage
• Professional indemnity insurance
• Business interruption insurance

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ADDITIONAL LEGAL RESOURCES

Key Documents Referenced

• Master Service Agreement
• Service Level Agreements (SLAs)
• Data Processing Agreements (DPAs)
• Risk Management Framework
• Compliance Calendar

Support and Escalation

Legal Inquiries: Email: legal@digimatrix.com Phone: [Insert Phone] Portal: [Insert Legal Portal URL]

Compliance Questions: Email: compliance@digimatrix.com Phone: [Insert Phone]

Data Protection Officer: Email: dpo@digimatrix.com

Incident Reporting: Email: incidents@digimatrix.com Phone: [Insert Emergency Number]

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Digimatrix — Creating Platforms For Digital Play

These legal documents are provided for informational purposes and should be reviewed by qualified legal counsel in your jurisdiction. Last Updated: November 2025