Terms Of Service
1. Xgamble.io
XGamble.io (the "Website") is owned and operated by Gosu Company Limited ("XGamble", "we" or "us"), a BRITISH VIRGIN ISLANDS (BVI) BUSINESS COMPANY incorporated in 2024.
2. General
2.1. These Terms of Service govern your use of the Website and any associated services (the "Services"). They constitute a legally binding agreement between you and us and you should read them in their entirety before you use the Website or the Services. Your continued use of the Website or the Services constitutes acceptance by you of these Terms of Service; if you do not agree to them, you should not continue using the Website or the Services.
2.2. We may make amendments to these Terms of Service at any time. We will take appropriate steps to bring any material changes to your attention (e.g. by notification at login), but it is your responsibility to ensure that you agree with any changes made to these Terms of Service and you should continue to check for any updates on a regular basis. By continuing to use the Website or any Services after any such amendment to the Terms of Service you will be deemed to have accepted and agreed to be bound by such amendments, updates and/or modifications. If you do not agree to the changes, then you must not continue to use the Services.
2.3. These Terms of Service may be published in several languages. In the case of any discrepancy between the English language version of these Terms of Service and versions published in any other languages, the English language version shall prevail.
2.4. Any games or sports betting markets made available on the Website as part of the Services may also be subject to their own rules, to which you should also refer when participating. The provisions of these Terms of Service shall prevail in the event of any conflict with any such rules.
3. XGamble Account registration
3.1. In order for you to be able to place bets via the Website, you must first register for an account ("XGamble Account"). As part of the XGamble Account registration process, you will be required to provide your date of birth and a valid email address and choose a username and password for your XGamble Account. You must enter all mandatory information requested in the registration form. It is your sole responsibility to ensure that the information you provide is true, complete and correct. We may reject your requested username if we deem it to be offensive or inappropriate.
3.2. You may not register for a XGamble Account if:
You are under 18 years old or under the legal age of majority for gambling in the jurisdiction in which you are located;
You are residing or located in jurisdictions from which gambling or your use of the Services is not permitted. It is your responsibility to ensure that your use of our Services is lawful; or
You provide misleading information or try to register for a XGamble Account through third parties. You are prohibited from selling, transferring or acquiring XGamble Accounts to or from other XGamble users.
3.3. You are fully and solely responsible for the security of your login details and other sensitive information, including passwords and cryptocurrency wallets and associated private keys. We are not liable for any loss or damage arising from abuse or misuse of your XGamble Account by third parties due to your disclosure, whether intentional, accidental, active or passive, of any such information to any third party.
3.4. You are permitted to have only one XGamble Account. If you attempt to open more than one XGamble Account, any and all such accounts may be blocked, suspended or closed, and any sums credited to those accounts will be frozen and may be deducted. If you realize that you have opened more than one registered XGamble Account you must notify us immediately by email at [email protected].
3.5. If at any time after registration of your XGamble Account you become aware of any errors or incorrect information relating to your XGamble Account, you must inform us as soon as you possible by email at [email protected].
4. Know-your-customer ("KYC")
4.1. We reserve the right, at any time, to ask you for KYC documentation if we deem it necessary in order to determine your identity, location or age, or for any other purpose. We reserve the right to restrict your ability to access any or all Services or to make payments or withdrawals until your identity has been determined to our satisfaction, at our sole discretion.
4.2. We reserve the right to disclose your information to third parties as appropriate to comply with any legal process or as otherwise permitted under our privacy policy, and by using any Service, you acknowledge and consent to the possibility of such disclosure. Please refer to XGamble's AML Policy for more information.
5. Conditions of use
5.1. As a condition of your use of the Services, you represent, warrant, covenant and agree that:
You are the older of (i) 18 years of age and (ii) the legal age determined by any laws applicable to you regarding your use of the Website and the Services;
You have full capacity to enter into a legally binding agreement with us and you are not restricted by any form of limited legal capacity;
Your use of the Services is at your sole option, discretion and risk;
You are fully aware that there is a risk of losing funds when using the Website and the Services and you agree that we bear no responsibility to you for any such loss;
You acknowledge that the funds in your XGamble Account are consumed instantly when playing games and that we do not provide refunds;
You accept and acknowledge that the prevailing market value of cryptocurrencies can change dramatically;
You have not been diagnosed or classified as a compulsive or problem gambler;
You are not currently self-excluded from any gambling site or gambling premises, and you will inform us immediately if you enter into a self-exclusion agreement with any gambling provider;
You are accessing the Website from a jurisdiction in which it is legal to do so, and will not use our Services while located in any jurisdiction that prohibits the placing and/or accepting of bets online and/or playing casino and/or live games or which otherwise prohibits access to or use of the Services;
All information that you provide to us during the term of validity of these Terms of Service is true, correct and complete, and that you will immediately notify us if any such information changes;
You participate in the XGamble games strictly in your personal and non-professional capacity and for recreational and entertainment purposes only;
You participate in XGamble games on your own behalf and not on behalf of any other person;
You will not use or access the Website or Services for any purpose that is (1) illegal under any law applicable to you or (2) prohibited by or in breach of these Terms of Service.
You will not collude with or assist, or attempt to collude with or assist, any third parties, or use any device, robot, spider, algorithm, software, routine or other method (or anything in the nature of the foregoing), in order to defraud us or interfere with the functioning or operational performance of the Website or the Services;
You will not use the Website or Services in any way which interferes or may interfere with other users, or make any attempt to gain an unfair advantage over other users, whether specifically prohibited by the applicable rules or not;
You will not disseminate any information which is unlawful, harassing, abusive, threatening, libelous, defamatory, obscene, indecent, inflammatory, racially or ethnically objectionable, pornographic or profane, or any material that could constitute or encourage conduct that would be considered a criminal offense or could give rise to civil liability;
In relation to deposits and withdrawals of funds into and from your XGamble Account (including cryptocurrencies and any other currencies that may be used from time to time), you will only use funds which have been legally obtained and which belong to you You will not use funds which originate from criminal or other illegal or unauthorized activities;
You acknowledge that we may take measures to detect and prevent unauthorized or illegal activity. These steps may include, but are not limited to, examination of your device properties, geolocation, detection of IP masking, and blockchain transaction analysis;
If you become aware of any suspicious activity relating to any of the games on the Website, you will report this to us immediately by contacting us by email at [email protected];
You acknowledge that we may suspend, block or close a XGamble Account and withhold funds if we deem it necessary to assist in the prevention of money laundering or other illegal activity;
You are fully and solely responsible for obtaining your own independent financial, accounting and tax advice, and for recording, reporting, paying and accounting to any relevant governmental or taxation authority for any tax or other levy that may be payable on any winnings or other sums that you receive from using the Services;
You will keep your username, password and cryptocurrency wallet private keys confidential and take appropriate steps to prevent unauthorized access or use;
You will immediately change your password and notify us if your username or password is compromised in any way;
You agree not to open more than one XGamble Account;
You acknowledge that we may modify or withdraw any of the Services at any time without prior notice to you; and
You acknowledge that we are not liable for any outages, slowness, capacity constraints or other deficiencies affecting the telecommunications networks or internet services required for you to access and use the Services.
5.2. We will be entitled to close or suspend your XGamble Account in the event of a breach of any of the above representations, warranties or covenants, or if we consider it likely that there has been or will be any such breach. We may also close or suspend your XGamble Account if asked to do so by the police, any regulatory authority or court or if we are unable to verify any of the KYC information provided by you.
6. No XGamble warranties
6.1. The Services are provided to you on an "as is" basis. We disclaim any and all warranties, expressed or implied, in connection with the Services. In particular, we provide you with no warranty or representation whatsoever regarding the Services’ quality, fitness for purpose, completeness, or accuracy, and we make no warranty that any Service will be uninterrupted, timely or error-free, or that any defects will be corrected. In particular, XGamble does not represent or warrant that the Website is or will be free from errors, bugs and other defects in its functioning, that access to the Services is or will be continuous, uninterrupted, timely, or secure, that the information made available via, contained on or used by the Website, including data feeds used for sports betting, is or will be accurate, reliable, complete, or current, or that the Website will be free from viruses or other harmful material. Information made available via, contained on or used by the Website may be inaccurate or incomplete or otherwise unreliable for a variety of reasons, for example as a result of software bugs, data feed interruptions, platform or server downtime, or other issues, and this may cause losses to you by affecting the functioning of the Services or the resolution of Markets.
6.2. XGamble may from time to time test new games and other features on the Website by introducing them in beta testing form ("Beta Features"). If you choose to use these Beta Features you do so on the understanding that (i) such features may be particularly unstable and prone to errors and bugs and other defects in functioning and (ii) XGamble will not be liable for any losses sustained as a result. Beta Features may need to be suspended, discontinued or modified at any time. Any winnings credited to your XGamble Account which relate to any technical or human error involving a Beta Feature may be deducted at XGamble’s sole discretion.
7. Prohibited uses
7.1. The use of the Website or any of the Services for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, is prohibited. 7
.2. The Website and the Services are not offered to individuals or entities subject to United States, European Union, or other global sanctions or watchlists. By using the Website and the Services, you represent and warrant that you are not subject to such sanctions.
7.3. Persons located or resident in Australia, the British Virgin Islands, the Cayman Islands, Curaçao, Cyprus, the Netherlands, Portugal, Spain, the United Kingdom, the United States of America and any other location from which use of the Services is not permitted under applicable laws or regulations or where provision of the Services would require licensing or registration or which is embargoed by the United States of America, the European Union or the United Kingdom (the "Prohibited Jurisdictions") are not permitted to access the Website or the Services. These restrictions apply equally to residents and citizens of other jurisdictions while they are located in a Prohibited Jurisdiction.
7.4. Any attempt to conceal your true location through the use of a VPN, proxy, or similar service or through the provision of incorrect or misleading information about your place of residence or location will constitute a breach of these Terms of Service.
8. Deposits
8.1. You may only participate in a XGamble game if you have sufficient funds for such participation in your XGamble Account.
8.2. You may not deposit funds which originate from criminal or other unauthorized activity;
8.3. To deposit funds into your XGamble Account, you may transfer funds from a cryptocurrency wallet under your control or via any of the other payment methods that may be available from time to time on the Website. Deposits may only be made with your own funds.
8.4. We take no responsibility for any delays to deposits which may arise from or be associated with blockchain transaction times or the use of particular payment methods or which may be caused by any third party.
8.5. We reserve the right to use additional procedures and means to verify your identity when processing deposits into your XGamble Account.
8.6. Please note that the use of some payment methods may involve additional fees. Your bank or payment service provider may also charge you additional fees for making transfers or converting currencies.
8.7. We may refuse to credit any deposits at our own discretion. If your XGamble Account has been blocked or suspended, you must refrain from attempting to deposit funds into it. Should
you attempt to deposit funds when your XGamble Account is blocked or suspended, (i) you acknowledge and accept the risk that such deposited funds may be permanently lost, and (ii) if those deposited funds are not lost, we will have the right to retain them.
9. Withdrawals
9.1. Cryptocurrency withdrawals will be made to your stated cryptocurrency wallet address after you make a valid withdrawal request.
9.2. Withdrawals may be restricted if we detect suspicious, unauthorized or illegal activity relating to your XGamble Account.
9.3. If we mistakenly credit your XGamble Account with winnings or any other sums that do not belong to you, whether as a result of a technical error or human error or otherwise, such sums will remain our property and will be liable to be deducted from your XGamble Account. In the event of an incorrect credit to your XGamble Account, you are obliged to notify us immediately by email at [email protected] upon becoming aware of any such error. If you withdraw funds that do not belong to you before we become aware of such an error, those amounts credited to your XGamble Account in error will (without prejudice to other remedies and actions that may be available at law) constitute a debt owed by you to us.
9.4. If your XGamble Account has been closed, locked, blocked or excluded and you wish to recover funds held in it, please contact XGamble customer support at [email protected]. We reserve the right to refuse to reopen or unlock your XGamble Account or to allow withdrawals from it if we suspect that you are in breach of these Terms of Service or if we deem it necessary to do so for other reasons, and we may carry out additional KYC verification procedures and other checks for any withdrawal.
10. Bonuses
10.1. We may from time to time offer you bonuses and rewards, such as free spins, cashback, free bets, and extra money to play games with ("Bonuses"). Any such Bonuses will have their own sets of terms and conditions, to which you will need to agree in order to participate.
10.2. We reserve our right to remove any bonus from inactive accounts and accounts that we determine at our sole discretion to be intentionally exploiting a Bonus in bad faith.
10.3. We reserve the right to cancel all Bonuses that have not been claimed within the shorter of any applicable claiming period or 60 days, and to cancel any Bonus at our sole discretion.
11. Sports betting
11.1. XGamble may offer various sports betting markets from time to time ("Markets"), including pre-match and in-play Markets and single and multi bets. The availability of specific sports, events, or matches for betting is subject to change without prior notice.
11.2. Third party providers will provide information related to sports scores and analytics ("Third Party Content") for Markets. XGamble is not responsible for, does not endorse, and makes no representations or warranties concerning any of the Third Party Content made available on the Website. You rely upon such Third Party Content at your own risk.
11.3. Third Party Providers may provide specific rules for resolution of Markets, to which you should refer when participating in them.
11.4. Markets will only be settled following official confirmation of the outcome or otherwise at XGamble’s sole discretion. If the outcome of a Market cannot be verified officially, we reserve the right to void it. If coverage of a match is abandoned or interrupted but the match proceeds normally, the relevant Markets will be settled according to the relevant results as officially reported.
11.5. If a match deviates significantly from the generally accepted format or rules, XGamble reserves the right to void any relevant Market.
11.6. If a match is not completed or not played (e.g. through disqualification, interruption, withdrawal, changes in draws, etc.), all undecided Markets will be void. However if the outcome of the Market has already been determined then the Market will be settled accordingly.
11.7. If the outcome of a Market was already known or decided before the placing of a bet, the bet will be void and any winnings may be withheld or deducted and wager amounts returned.
11.8. Betting may be voided in the case of any incorrectly displayed or calculated prices.
11.9. Bets are void on postponed, canceled, or abandoned Matches. Matches which have their start date altered well in advance to accommodate live TV, or to ease fixture congestion will not be classed as postponed. An abandonment is where a match is halted before the completion of the allocated match time and not played out to conclusion on the same day. Markets which have already been determined at the time of abandonment, such as ‘First Team to Score’, will stand. The Market must be fully determined for bets to stand.
11.10. If a Market is incorrectly settled, XGamble reserves the right to correct it at any time.
11.11. For prop bets, the following terminology applies:
"Player must play": applies to all pre-match player prop markets across NBA, NHL, NFL, CBB, and CFB and all in-play player prop markets across MLB, NBA and NFL.
"Player must start": all prematch MLB player prop markets (pitcher and batter markets) are "Player must start". Bench player markets are not available for pre-match betting. NHL goalie markets are "Goalie Must Start".
11.12. The following rules apply to prop bets:
XGamble reserves the right to void bets placed on known outcomes or known results.
Settlements are sourced from the official league data in the box scores: nfl.com, nba.com, mlb.com, and nhl.com.
Bets are void on postponed, canceled, or abandoned matches.
11.13. "Cash Out" is a feature that offers the customer the opportunity to take a return on a bet placed before the bet has reached its conclusion. To Cash Out (where available), click on the Cash Out button next to your bet. The Cash Out amount will then be credited to your account. Once you have chosen to Cash Out, your bet will be deemed concluded and will be unaffected by the final outcome of the relevant event.
11.14. The following also applies to the Cash Out feature:
Cash Out will not be available on certain Markets and events.
A time delay is applied on every Cash Out.
Cash Out will not be available if the event and/or Market you have placed a bet on is suspended.
A Cash Out attempt may not be successful if a Market or event is suspended or odds change during the time delay period applied after Cash Out is attempted.
Where Cash Out is available on a pre-match event, if we do not cover the event live then Cash Out will be unavailable once the event starts.
Your Cash Out value will differ depending on how your selection is performing and may be higher or lower than your original stake.
XGamble reserves the right to reverse the settlement of a Cash Out on any bet that has been settled in error.
XGamble will not be responsible in the event that Cash Out is unavailable because of technical issues. Any bets will be settled as normal based on the final result.
XGamble reserves the right to remove a customer’s ability to use the Cash Out feature, or to nullify any use of such feature, in the event of misuse or any other breaches of these Terms of Service.
11.15. A "Maximum Win Limit" will apply to bets on XGamble. The Maximum Win Limit is the maximum total amount that XGamble will credit to an individual customer’s XGamble Account in relation to any and all bets placed on (i) a single event or selection or (ii) a single Market or related Markets.
11.16. The Maximum Win Limit is equal to US$500,000, or its equivalent in the currencies in which the relevant bets are placed, calculated at the time each applicable Market is settled.
11.17. If a customer attempts to circumvent any Maximum Win Limits, whether through the use of multiple XGamble Accounts or through other means, it will constitute a breach of these Terms of Service. In those circumstances, XGamble may take such action as it sees fit, including canceling the relevant bets or adjusting or withholding winnings.
11.18. For the avoidance of doubt, the Maximum Win Limit does not impact XGamble’s discretion not to accept a bet or to limit the size of the stake it is willing to accept for a bet, nor does it impact XGamble’s ability to rely on and enforce these Terms of Service or any other applicable terms.
11.19. Unless XGamble has specifically agreed otherwise, an individual customer’s maximum daily winnings are equal to US$500,000, or its equivalent in the currencies in which the relevant bets are placed, calculated at the time each applicable Market is settled.
12. Breach
12.1. Without prejudice to any other rights, if you breach in whole or in part any provision contained herein, we reserve the right to take such action as we see fit, including closing or suspending your XGamble Account and/or deducting funds from it, terminating our relationship with you under these Terms of Service or any other agreement and/or taking legal action against you.
12.2. You hereby fully indemnify, defend and hold harmless XGamble and its shareholders, directors, employees and agents from and against all costs, expenses, losses, damages, claims, demands and liabilities (including legal fees and any other charges) that may be incurred or suffered by XGamble or its shareholders, directors, employees and agents, arising in any way from (i) any breach by you of any part of these Terms of Service; (ii) any violation by you of any law or any third party rights; or (iii) your use of the Services.
13. Limitation of liability
13.1. Under no circumstances shall we be liable for any claims, proceedings, liabilities, costs, losses or special, incidental, direct, indirect or consequential damages (including, without limitation, damages for loss of business profits, business interruption, loss of business information, or any other pecuniary loss) arising out of the use or misuse of the Services. This limitation of liability applies (1) regardless of whether the alleged liability is based on contract, tort, strict liability, statutory liability or any other basis, (2) even in the case of our own negligence, and (3) even if we have been advised of the possibility of such liability.
13.2. The limitations of liability in these Terms of Service shall apply to the fullest extent permitted under applicable laws.
14. Intellectual property
14.1. We and our licensors are the sole holders of all rights in and to the Services and related code, structure and organization, including copyright, trade secrets, intellectual property and other rights. You may not, within the limits prescribed by applicable laws (a) copy, distribute, publish, reverse engineer, decompile, disassemble, modify, or translate the website, or (b) use any Service in a manner prohibited by applicable laws or regulations (each of the above is an "Unauthorized Use"). We reserve any and all rights implied or otherwise, which are not expressly granted to you hereunder and retain all rights, title and interest in and to the Services. You agree that you will be solely liable for any damage, costs or expenses arising out of or in connection with the commission by you of any Unauthorized Use. You will notify us immediately upon becoming aware of the commission by any person of any Unauthorized Use and will provide us with reasonable assistance with any investigations it conducts in light of the information provided by you in this respect.
14.2. The term "XGamble", its domain names and any other trademarks and service marks used by us as part of the Services (the "Trademarks"), are solely owned by us. In addition, all content on the Website, including, but not limited to, the images, pictures, graphics, photographs, animations, videos, music, audio and text (the "Site Contents") belongs to us and is protected by copyright and/or other intellectual property or other rights. You hereby acknowledge that by using the Services, you obtain no rights in the Site Contents and/or the Trademarks, or any part thereof. Under no circumstances may you use the Site Contents and/or the Trademarks without our prior written consent. You also agree not to do anything that would, or would be reasonably likely to, harm or potentially harm our rights, including our intellectual property rights.
15. Complaints
If you wish to make a complaint regarding the Services, you may contact our customer support team by email at [email protected].
16. Governing law and jurisdiction
16.1. These Terms of Service shall be governed by, and construed in accordance with, the laws of England & Wales.
16.2. The courts of England & Wales have exclusive jurisdiction to settle any dispute arising from or connected with these Terms of Service (including a dispute relating to their existence, validity or termination, or the consequences of their nullity, or any non-contractual obligation arising out of or in connection with them) and you irrevocably waive any right that you may otherwise have had to object to an action being brought in those courts, or to claim that the action has been brought in an inconvenient forum, or that those courts do not have jurisdiction.
16.3. You must bring any and all legal claims under these Terms of Service in your individual capacity and not as a claimant in or member of any purported class action, collective action, private attorney general action, or other representative proceeding. You agree to waive the right to demand a trial by jury, where applicable.
17. Severability
If any provision of these Terms of Service is or becomes illegal, invalid or unenforceable in any jurisdiction, that shall not affect the validity or enforceability in that jurisdiction of any other provision of these Terms of Service or the validity or enforceability in other jurisdictions of that or any other provision.18. Assignment
We reserve the right to assign our rights under these Terms of Service, in whole or in part, at any time without notice. You may not assign any of your rights or obligations under these Terms of Service.
19. Miscellaneous
19.1. No waiver by us of any breach of any provision of these Terms of Service shall in any way be construed as a waiver of any subsequent breach of such provision or of any breach of any other provision of these Terms of Service.
19.2. Nothing in these Terms of Service shall create or confer any rights or other benefits in favor of any third parties.
19.3. Nothing in these Terms of Service shall create or be deemed to create a partnership, agency, trust arrangement, fiduciary relationship or joint venture between you and us.
19.4. These Terms of Service constitute the entire understanding and agreement between you and us regarding the Services and supersede any prior agreement, understanding, or arrangement between you and us.
Version 1.4
Apr 2024
Privacy Policy
1. Introduction
This is the Privacy Policy of Gosu Company Limited ("XGamble", or "us"), a BRITISH VIRGIN ISLANDS (BVI) BUSINESS COMPANY incorporated in 2024 which operates the online casino www.xgamble.io.
Protecting your personal data is extremely important to us. This Privacy Policy describes how we at XGamble collect, use and protect the information and data you provide us with, in order to manage our relationship with you. We will process any personal information you provide us with, or that we otherwise have relating to you, in the manner set out in this Privacy Policy.
2. Collection, storage and use of Personal Data
The collection, storage and use of your personal information begins when you provide us with your information.
To register an account with us, you will need to share certain personal information, such as your name, email address, home address, telephone number, and date of birth. In addition, as you begin to enjoy using our services from www.xgamble.io, we will collect other types of information, which may include your IP address and browser type; your device information; your betting, payment and other account transactions; chat transcripts, email correspondence, and potentially phone calls recorded for training purposes. We shall only process your personal data when there is a genuine reason to do so, and that reason must be one of the following:
When fulfilling a contract we have with you
Where we have a legal obligation
Where you have consented to the processing
When it is in our legitimate interest
When it is in the public interest
When it is in your vital interests
If we do use legitimate interests as a reason to process your Personal Data, we will tell you that we are doing so, what our legitimate interests are, and provide you with a method to raise any questions or objections you may have. However, compelling grounds for processing such information may override your right to object.
3. Data security
You acknowledge that no data transmission over the Internet is totally secure. Accordingly, we do not guarantee or warrant the security of any information which you transmit to us. However, once we receive your personal data, we will take reasonable steps to protect it from misuse, loss, unauthorized access, modification and disclosure.
Each XGamble customer’s information is stored securely. Access rights to this data have been strictly limited to those employees and partners who need the information to perform their jobs. The transfer of all such information is done using appropriate encryption, and the databases containing the information are located in secure environments within password-protected databases.
4. Correction, retention and deletion of Personal Datay
You can ask us to correct any incorrect personal information about you that we process by sending an email to [email protected].
We will keep your data for as long as you are a customer of ours. If you are no longer a customer, we will keep your data for the minimum length of time required to comply with the purposes set out in this policy and relevant legal or regulatory obligations. Your Personal Data may be kept longer if we cannot delete it for technical reasons.
You can request the deletion of your personal data by sending an email to [email protected]. Please note that we may not be able to comply with your request at the time it is made if we are subject to a legal obligation to continue to store your data or because of technical limitations.
5. Marketing
All of our marketing communications, whether by email or SMS, will include instructions on how to opt out of receiving such marketing or promotional communication. Consent to this processing can be revoked, in whole or in part, at any time by contacting customer service and letting us know what type of marketing communications you wish to receive, or not. If you wish to completely remove your consent to marketing activities, your personal data will be removed from all of our marketing processes.
Where we have appropriate consent or a lawful basis, some of your personal data will be processed by our external marketing partners to enable us to communicate with all of our customers, either by phone or by email. This may include email and SMS delivery platform providers, prize or giveaway providers, etc. The intent of these communications is to send you marketing material that we hope will be of interest to you about our promotions, new games, offers, prizes, events, etc. You will not receive marketing from third-party sites.
6. Contacting us
If you have any concerns, or would like more detail about how we process your Personal Data, you can contact us at [email protected]. You have the right to request a copy of the personal information we hold about you.
AML Policy
1. Introduction
Gosu Company Limited ("XGamble" or the "Company") is a BRITISH VIRGIN ISLANDS (BVI) BUSINESS COMPANY incorporated in Feb 2024. It operates the online casino www.xgamble.io.
This policy (the "AML Policy'') sets out XGamble’s approach to preventing and countering Money Laundering ("ML") and Terrorist Financing (''TF"). In developing this policy, XGamble has considered all current Anti-Money Laundering (''AML") and Countering the Financing of Terrorism ("CFT") obligations required under BVI law, as well as best practice guidance issued for the gaming sector. This policy has been created utilizing guidance issued by the BVI Gaming Control Board.
XGamble acknowledges that its products and services are at risk from individuals or groups seeking to launder criminal proceeds or facilitate funds designated for the financing of terrorism. As such, XGamble is committed to fostering and promoting a compliance culture throughout the company which highlights the importance of preventing ML and TF.
2. Policy Statement and Objectives
XGamble prohibits the use of its products and services for any form of illicit activity, including ML, TF and sanctions violations, and is committed to following global best practices in guarding against such use. Those best practices include:
Adopting a written policy, and procedures and controls, reasonably designed to guard against ML, TF and sanctions violations;
Designating a compliance officer to oversee the implementation of the policy, procedures and controls;
Providing appropriate education and training to relevant personnel; and
Conducting independent reviews, monitoring and maintenance of the policy, procedures and controls.
The objectives of this AML Policy are to set out the main procedures, systems, and controls XGamble has implemented to follow the above best practices, and in particular to prevent and detect ML and TF.
3. Chief Compliance Officer
XGamble has appointed a Chief Compliance Officer ("CCO"), who is responsible for coordinating the implementation of the AML Policy. The CCO’s duties also include developing AML initiatives, working with other stakeholders to revise the AML policy, assessing new regulatory requirements and investigating and reporting potentially suspicious or unusual activity.
The CCO has an independent and direct reporting line to the Board, and will act on his/her own authority. The CCO will be authorized to submit suspicious transaction reports ("STRs") to the Financial Intelligence Unit of BVI (the "FIU") without requiring approval to do so.
4. Responsibility of Employees, Directors and Officers
All of XGamble’s employees, directors and officers, regardless of their position, are required to comply with this policy, and have a duty to be aware of the need to prevent ML and TF. Should they have reason to believe or suspect that any transaction, or potential transaction, could involve the proceeds of criminal conduct, they must report this to the CCO without delay. Failure to do so may result in disciplinary action.
As the business grows and the number of employees increases, XGamble will ensure that employees are trained to identify and report suspicious activity. XGamble will provide AML training to its employees on a regular basis.
5. Know-Your-Customer Measures and Transaction Monitoring
XGamble recognises the risks it faces of being used for ML and TF and has implemented controls, policies and procedures which are proportionate and targeted to those risks. XGamble applies appropriate know-your-customer ("KYC") and ongoing monitoring measures to further the objectives of this AML Policy and as required by law.
5.1. KYC Measures
XGamble has adopted risk-based Customer Due Diligence ("CDD") processes to enable it to develop a customer risk profile. These processes involve collecting certain information on customers at the onboarding stage and also monitoring customer activity. XGamble’s CDD includes the following measures:
Collecting Customer Information. XGamble will collect details on each customer to form a reasonable belief that it knows the identity of its customers. XGamble may collect such details as a customer’s wallet address, name, address, country, date of birth, or postal code (collectively, "KYC Information"). XGamble will collect any of the above KYC Information before issuing a XGamble funding address (e.g., QR code) to customers. XGamble does not presently allow customers who are non-natural persons. XGamble may utilize a third-party service provider to help it to determine the validity of the information provided by customers.
Excluding and Geoblocking Prohibited Jurisdictions. Customers are notified at onboarding that XGamble does not offer services in jurisdictions where such services are not permitted to be offered ("Prohibited Jurisdictions"), and requires customers to declare that they are not located in a Prohibited Jurisdiction. XGamble has implemented IP address-based geo-blocking of identified Prohibited Jurisdictions.
Excluding and Geoblocking Sanctioned Jurisdictions. Customers are notified at onboarding that XGamble does not offer services in jurisdictions subject to United States, European Union, or other global sanctions or watch lists, including Iran, Cuba, North Korea, Syria and the Crimean region of Ukraine ("Sanctioned Jurisdictions"), and requires customers to declare that they are not located in a Sanctioned Jurisdiction are not personally subject to international sanctions. XGamble has implemented IP address-based geo-blocking of identified Sanctioned Jurisdictions.
Screening for Sanctioned Parties. Before issuing a XGamble funding address to a customer, XGamble will screen a customer’s wallet address against applicable sanctions databases. Such screening measures rely on third-party blockchain forensics vendors such as Chainalysis.
5.2. Ongoing Monitoring
XGamble performs ongoing monitoring of its customers in order to detect any behavior or circumstances that might indicate ML or TF activity, sanctions breaches or other illicit activity. XGamble has implemented a range of processes to help it achieve this goal:
Transaction Monitoring for Sanctioned or Prohibited Jurisdictions. XGamble presently conducts a mixture of manual and automated transaction monitoring processes to identify "red flag" behavior. Where such red flag behavior is identified, XGamble may refuse to process any withdrawal attempts or require additional information from the customer. XGamble will further endeavor to limit any attempted customer account funding from Prohibited Jurisdictions where the associated wallet address indicates that the customer or the customer’s funds are located in such a Prohibited Jurisdiction. For instance, XGamble may prohibit a customer from funding their XGamble account using a known U.S.-based exchange wallet, as this may indicate that the customer is a U.S. person. Customers will have the ability to rebut any suspension with additional information as part of XGamble’s ongoing transaction monitoring and customer due diligence standards.
Transaction Monitoring for Sanctioned Parties. XGamble will periodically re-screen customers’ wallet addresses against applicable sanctions databases.
Identification of Unusual Activity. XGamble will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and any other red flags. Monitoring will be conducted running regular reports of unusual, high-risk, or suspicious customer activity.
Anti-Mixing Measures. XGamble does not allow the use of anonymity-enhancing technologies such as mixers, tumblers, or certain coins and tokens. Where XGamble becomes aware that an anonymity-enhancing technology is being used on the XGamble platform, XGamble will disallow such use. XGamble may also take steps to address suspicious deposit or withdrawal patterns; such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk.
Chainalysis Review. Each crypto deposit and withdrawal will be run through Chainalysis and reviewed for signs of fraud or suspicious behavior. A customer’s account will be suspended and reviewed upon alert of potential illicit behavior. Sufficient proof of wealth may be requested from high-risk accounts. XGamble may refuse to withdraw to certain "high-risk" addresses as determined in consultation with Chainalysis risk scoring.
Withdrawal Threshold KYC. Additionally, and independently, any account’s withdrawal function may be suspended until adequate due diligence has been carried out once that account has reached a withdrawal threshold dependent on the account’s risk characterisation over the life of the account, assessed according to XGamble’s sole discretion.
Ban Evasion Detection. XGamble will utilize third-party service providers to detect the use by one customer of multiple accounts, in breach of XGamble’s terms of service. XGamble further prohibits peer-to-peer account transfers within the XGamble platform infrastructure. Any attempts to circumvent this restriction will be treated as a red flag.
Time Zone Monitoring. XGamble has implemented time zone controls which check customers’ device location information against restricted jurisdictions to determine whether they are trying to use software to mask their true location.
Vendor Management. XGamble will periodically assess the strength of its key third-party service providers to determine whether additional services are needed, the third-party service provider is not performing in accordance with its contractual obligations, or if other remedial action is necessary for XGamble to comply with this AML Policy. XGamble may request information from any third-party service provider as part of its vendor review process.
Compliance Innovation. In addition to vendor management, XGamble will continuously monitor any non-documentary compliance mechanisms to determine whether their use on the XGamble platform would be viable. XGamble may run test or trial mechanisms on a limited basis with such compliance vendors to determine their effectiveness. Blockchain-native compliance tools may include fraud prevention services, on-chain KYC providers, and other tools designed to reflect the technological features associated with blockchain platforms.
5.3. Enhanced Due Diligence
Whenever a red flag is triggered, the relevant customer’s account will be suspended and XGamble will perform enhanced due diligence ("EDD"). EDD may include, but is not limited to, requiring customers to provide their:
Full legal name;
Country of citizenship;
Permanent address (which must be a residential or business street address);
Identification number (a passport number and country of issuance, a taxpayer identification number, an alien identification card number or number and country of issuance of another government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard);
Government-issued identification document (e.g. a passport); and
Source of funds and source of wealth.
XGamble may use third-party service providers to verify any of the above information.
5.4. Blocking of Customers
XGamble will not onboard / will block or suspend customers who:
Do not provide the identification information requested by XGamble;
Provide fake identification documents;
Adopt measures to conceal their true location;
Are from restricted or prohibited jurisdictions;
Are subjected to United States, European Union, or other global sanctions or watch lists;
Are addicted to gambling or have mental health issues; or
Deposit funds which originate from exchanges in restricted jurisdictions.
In addition, XGamble reserves the right to block and suspend players for any other reason at its sole discretion.
6. Reporting
If a customer is identified as being on a sanctions list, or linked to ML or TF or other criminal activities, XGamble will make an appropriate report to the FIU.