Responsible Gaming Policy

Responsible Gaming Policy December 2021



1. Legal Notice

This Responsible Gaming Policy (the “Policy” or the “Responsible Gaming Policy”) may only be distributed pursuant to a confidentiality agreement between the recipient and Jump Clear, Inc. (“Jump Clear” or the “Company”). The recipient of this document may use it solely and exclusively to better understand Jump Clear’s Responsible Gaming Policy. This document may not be used for any other purpose and shall not be distributed or disclosed to any third party. Furthermore, the recipient will use all reasonably diligent means to protect against any unauthorized use, distribution, or disclosure of the Policy. The Company reserves the right to change this Policy and any of its contents from time to time without notice.


2. Purpose

Jump Clear, Inc. (“Jump Clear” or the “Company”) is committed to ensuring that its platform is operated in a secure, fair and socially responsible way and to endorse Responsible Gaming (“RG”) amongst its users, employees and stakeholders. Responsible Gaming encompasses the processes, tools and resources that allow users to have a fair and safe experience with the Company while protecting them from problem gambling issues. Jump Clear is committed to upholding the licensing objectives and compliance frameworks of the Company’s gaming regulators.

This Policy applies to all of Jump Clear’s personnel, who will:

◼ Comply with all applicable federal and state laws regarding Responsible Gaming and user protection.

◼ Provide easily accessible, clear, and meaningful information to users regarding Responsible Gaming tools and restrictions so that they can make informed choices about using Jump Clear’s platform and services.

◼ Inform users or prospective users about the help and assistance they can utilize should they experience any signs of problem gambling.

◼ Make all reasonable efforts to avoid marketing to minors, according to the definition of “minor” in each state.

◼ Make all reasonable efforts to avoid marketing to self-excluded users.

◼ Ensure marketing and advertising is responsible and contains the relevant Responsible Gaming information required by relevant regulations.

3. Scope

This Policy will apply to the full lifecycle of a user, as follows:

◼ During the creation and registration of a user’s monetary account with Jump Clear;

◼ During the activity and participation of a user in the paid-entry products on Jump Clear’s platform; and

◼ Following the limitation/restriction or closure of a user’s account

The above will be actioned on an ongoing basis to ensure the Company remains in compliance with any applicable laws or regulations.

◼ State specific regulation will be outlined in the Appendices at the end of this Policy.



4. Registration & Verification

4.1 Prohibition of Underage Users - Identification and Verification

◼ Before a user is able to complete registration and begin playing paid-entry games on the site, Jump Clear must ensure that the user is of legal age to do so.

◼ Participation in gambling by an underage user is prohibited.

◼ Jump Clear will check the name, age and address of an individual at registration.

◼ The age of the user will be verified using a reliable and independent source.

◼ In the event that a user is confirmed as a minor, Jump Clear will undertake the relevant steps as required to block that user’s access.

4.2 Duplicate Accounts

◼ Jump Clear will take all reasonable steps to ensure that a user is only able to register, open and maintain one active account.

◼ Any duplicate accounts will be flagged and closed by Jump Clear. This process allows the Company to comply with its fraud and security responsibilities, but it also allows Jump Clear to prevent users who may wish to circumvent any Responsible Gaming tools set on their initial account.

4.3 Credit to Users

◼ Jump Clear does not provide users with credit that would enable them to participate in paid-entry games with funds they do not have available.

4.4 Responsible Gaming Tools

◼ Jump Clear offers various tools that a user can set in order to better control their level of participation in paid-entry games and encourages users to use these tools in order to enjoy their time playing at Jump Clear. These levels can be set by the user in the platform at any time [e.g. either through our customer support or onsite].

◼ There are various Responsible Gaming tools that are available to a user including but not limited to:

o Deposit limits;

o Session Limits;

o Time outs

4.4.1 Deposit Limit

A deposit limit will limit the amount a user can deposit during a certain period of time (daily, weekly, or monthly). Once they have reached this sum they will not be able to make any new deposits until their limit has reset. Deposit limits may be reduced at any time, but increasing the deposit limit may only be done upon customer confirmation at the start of the following calendar period. Customers will receive a notification if they attempt to exceed the limit and the deposit will be prevented.

4.4.2 Reality Checks

This tool allows a user to select a time limit for the time spent on-site. When the time is reached, a pop up informs the user that this time has been reached.

4.4.3 Session Limit

This tools provides the user the ability to limit how many hours [or minutes] they can be logged into their account daily. Once they reach this limit, they will be automatically logged out. Session limits may be reduced at any time, but may be increased only at the start of the next calendar day.

4.4.4 Spending Limits

This will limit the amount a user can spend during a certain period (daily, weekly, or monthly). The user will be able to wager up to the amount they have chosen. Spending limits may be reduced at any time, but may be increased only at the start of the next applicable calendar period.

4.4.5 Loss Limits

A loss limit will limit the possible amount of net losses a user can make based on bets minus wins during a certain period (daily, weekly, monthly). When a user has reached this sum, they will not be able to place any new bets until their limit has reset.

4.4.6 Time Out

The user can choose to a short time frame to take a break for (72 hours, 7 days, or 30 days), during this time they will be unable to access their account. The account will reopen automatically after the chosen period.

These tools, where applicable, are in a clear, prominent and easily accessible position for the users to see.

4.5 Self-Exclusion / Restriction

Self-exclusion is a tool for users who are experiencing issues with problem gaming. During the time the user is self-excluded, they will not be able to play any paid-entry games and will not receive any marketing communication from the Company for paid-entry products.

Whether a third party can self-exclude a user is state specific and can be found in the relevant Appendix at the end of this Policy.

During the self-exclusion period, Jump Clear will do everything possible to prevent the user from opening new accounts. The Company will have reasonable controls and guarantees in place to ensure that while the user is excluded, they cannot access the Company’s website(s) and will not receive advertising material about games.

However, Jump Clear is not liable to the user or any third party if they continue to play on the Company website(s), if any advertising material is sent inadvertently to the user, and if they continue to bet on other sites from any party or establishments. Additionally, Jump Clear agrees that we have no responsibility of any kind if the user continues to play through additional accounts in which any of the registration details have changed (which would also include if the customer opens an account with substantially the same information, even if they enter in the record differently).

4.6 Responsible Gaming Information

Jump Clear ensures that all relevant Responsible Gaming and related information is easily accessible to users during their lifetime. This information contains details of organizations and bodies that provide help and assistance to a user and affected third parties should someone have problems limiting their involvement in monetary contests.

In providing and directing users to these sources for assistance, Jump Clear assists the user and any affected third party in getting help from independent reputable sources.

4.7 User Activity Monitoring

User activity will be monitored for behavior that may indicate a possible responsible gaming issue. If such issues are identified, Jump Clear may contact the user to determine whether responsible gaming concerns are warranted and whether further actions (including account restrictions) are appropriate. Activity monitored may include, but is not limited to:

◼ Time played;

◼ Number of payment methods used;

◼ Changes to user-imposed deposit limits;

◼ Changes to user-imposed loss limits;

◼ Changes to wager limits;

◼ Canceled withdrawal requests; and

◼ Number or frequency of time-out requests.

5. Advertising

5.1 Prohibitions on Advertising to Minors

Jump Clear will not market exclusively or primarily to minors, according to the definition of minor in each state and/or as specifically defined in any rules or regulations relating to pay-to-play gaming products in any jurisdiction. In order to ensure that Jump Clear’s marketing does not target minors, the Company will:

◼ Require all partner media outlets, websites, or other entities to agree to take all reasonable measures to not target minors on behalf of Jump Clear;

◼ Make all reasonable efforts to ensure that advertising networks do not place Jump Clear material on any websites that are aimed exclusively or primarily at minors;

◼ Not use any search engine optimization terms that target exclusively or primarily minors;

◼ Require that individuals or other entities speaking on behalf of Jump Clear on television, radio, or online outlets understand and acknowledge this aspect of the Jump Clear Marketing Policy; and

◼ Ensure that in-person promotional events are staffed by individuals that understand and acknowledge the Jump Clear Marketing Policy.

4.85.2 Prohibitions on Marketing to Self-Excluded Users

Jump Clear will automatically prevent self-excluded users, third party-excluded users, or users otherwise barred from participating in Jump Clear paid-entry contests from receiving marketing or direct contact relating to paid-entry products via the following methods:

◼ Email

◼ Mail

◼ App push

◼ Calls / Texts

6. Socially Responsible Marketing

Jump Clear will ensure that marketing communications do not suggest that gaming is a solution to financial concerns, an alternative to employment, or a way to achieve financial security. Jump Clear will make information about responsible play available to users clearly and conspicuously on its website and mobile applications.

Jump Clear will communicate the location of such resources where a user could easily identify it in each advertisement, landing page, or other location referencing pay-to-play games. The responsible play information will include the name and toll-free number of at least one reputable source where individuals who have problems limiting their involvement in monetary contests can receive assistance.

7. Training

Various levels of responsible gaming training are provided to employees and other stakeholders of the Company depending on the role of the employee / stakeholder. These are continually reviewed to ensure they are up to date with the latest regulatory changes, trends and best practices.

Training materials include but are not limited to the following information:

◼ What the policies and procedures are in Jump Clear including what Responsible Gaming tools are available and how these can be activated.

◼ Spotting the markers of harm i.e.: identification

◼ Assistance to a user who may be at risk of harm or be a compulsive gambler.


8. Periodic Review

Jump Clear will conduct a review of its Responsible Gaming Policy annually or sooner if required. Any material changes to the Policy will be reviewed and approved by the Compliance Officer or their designee.

9. Record Retention

Jump Clear will maintain all documentation related to its Responsible Gaming Policy per the Company’s Data Retention policy in conjunction with state specific regulatory stipulations. This will include user history and transactions as well as marketing and advertising material.

10. Supporting Documents

Appendices outlining state specific regulations for Responsible Gaming

11. REVISION HISTORY

REVISIONDATEAUTHORDESCRIPTION1.0MichaelInitial Release



◼ Appendix A - Colorado

◼ Legal age to gamble:

o 21 years of age.

◼ Record retention:

o Daily records of the Company’s operations shall be kept and maintained for at least three years.

o These records will sufficiently detail all financial transactions to ensure compliance with the state’s requirements.

◼ Self-Exclusion:

o A user may request placement on the list of self-excluded persons for a period of one, five, or ten-years, or may request a lifetime ban.



◼ Appendix B – New Jersey

◼ Legal age to gamble:

o 18 years of age.

◼ Record retention:

o Records of the following items are maintained for at least 7 years:

­ The date and time the fantasy sports activity started and ended;

­ Prize structure used;

­ Participants that entered the fantasy sports activity;

­ Selections each game participant made for his or her team;

­ Total number of points earned by each participant's team;

­ Total amount of entry fees paid;

­ Results, including the points earned by the winning participant or participants;

­ Total amount of participants' winnings; and

­ Total amount of cash or cash equivalents awarded to participants.

­ Participant account information, which includes:

● A unique participant identification;

● Participant identity details, which include the participant's legal name, age, and address;

● Any self-restrictions;

● Any previous accounts; and

● The date and location from which the participant account was registered.

◼ Responsible Gaming tools

o In New Jersey, Jump Clear offers its users the ability to utilize the following Responsible Gaming tools:

­ Spend limits;

­ Deposit limits;

­ Session limits.


◼ Appendix C – New York

◼ Legal age to gamble:

o 18 years of age.

◼ Record retention:

o Relevant user information / records will be kept for at least 5 years.

◼ Refund process for confirmed underage users:

o Jump Clear will refund the deposit if it is confirmed that a user is a minor.

o This refund must be credited back to the user no more than 2 days following positive confirmation of age.

o The deposit will be refunded whether or not the minor has engaged in or attempted to engage in a contest.

o This refund may be offset by any prizes already awarded.

o If after investigation it is concluded the minor fraudulently misrepresented their age, and in the event that this minor was due a prize, this prize will not be awarded and will be paid out to / presented to the next user in the immediate position following the underage user.

◼ Self-Exclusion:

o In order for a user to voluntarily exclude themselves in the state of New York from daily fantasy sports activities, the following is to be completed:

­ The ‘Request for Voluntary Self-Exclusion from All Gaming Facilities and Entities Licensed, Permitted or Registered by the New York State Gaming Commission’ form.

­ The notarized form, with photograph, per instructions, should be mailed to:

New York State Gaming Commission

Director of Education & Community Relations

PO Box 7500

Schenectady, New York 12301-7500

◼ Responsible Gaming:

o For the state of New York, reputable resources and information related to responsible gaming information should be made available, free of charge, to users from this state e.g., the OASAS HOPE line – 1-877-8-HOPENY.

◼ Appendix D – Massachusetts

◼ Legal age to gamble:

o 18 years of age.

◼ Record retention:

o Relevant user information / records will be kept for at least 10 years.

◼ Refund process for confirmed underage users:

o Jump Clear will refund the deposit if it is confirmed that a user is a minor.

o The deposit will be refunded whether or not the minor has engaged in or attempted to engage in a contest.

o This refund may be offset by any prizes already awarded.

o If after investigation it is concluded the minor fraudulently misrepresented their age, and in the event that this minor was due a prize, this prize will not be awarded and will be paid out to / presented to the next user in the immediate position following the underage user.

◼ Self-Exclusion (third-party):

o A third-party can request the self-exclusion of a user only if they can provide documentary evidence of sole or joint financial responsibility, for the source of any funds deposited with Jump Clear, for gameplay, including:

­ Proof that the requestor is jointly obligated on the credit or debit card associated with the users’ account;

­ Proof of legal dependency of the user on the requestor under state or federal law; and

­ Proof of the existence of a court order that makes the requestor wholly or partially obligated for the debts of the person for whom exclusion is requested.

o An exclusion can also be provided for, in situations in which the requestor can establish the existence of a court order requiring the user to pay unmet child support obligations.

◼ Responsible Gaming:

o Deposit Limits – automatic and set by Jump Clear:

­ A user cannot deposit more than $1,000 per month.

­ In the event that the user wishes to increase this limit, Jump Clear will conduct an affordability check.

­ This limit will be re-evaluated annually.

­ If an annual re-evaluation is not performed, this limit will revert to $1,000 per month.

o Responsible Gaming tools:

­ Jump Clear offers its users in Massachusetts the ability to utilize the following Responsible Gaming tools:

● Spend limits;

● Session limits;

● Reality checks;

● Time-out

­ Should the user wish to change any of these limits set, they can only do so 90 days after the initial limit being set.


















◼ Appendix E – Pennsylvania

◼ Legal age to gamble:

o 21 years of age.

◼ Self-Exclusion

o Users may select a period to self-exclude in years, with one year being the minimum.

o A user may request placement on the list of self-excluded persons and agree that, during any period of voluntary exclusion, they may not collect any winnings nor recover any losses resulting from any fantasy contest activity.

o This list is private and not open to public inspection. This list may be disclosed to affiliated licensed gaming entities or licensed operators in the Commonwealth or other jurisdictions for the limited purpos e of assisting in the proper administration of responsible programs operated by affiliated licensed gaming entities or licensed operators.

◼ Responsible Gaming:

o Responsible Gaming tools:

­ Jump Clear will provide users with the ability to set deposit limits.

o Responsible Gaming information:

­ The responsible gaming and the compulsive and problem information will be conspicuously posted at fantasy contest registration points and provide the toll-free telephone number to participants.

­ The toll-free telephone number and the compulsive and problem play notice shall be approved by the board, in consultation with the Department of Drug and Alcohol Programs or a successor agency.

◼ Advertising

o Advertisements must contain a gambling assistance message that is similar to one of the following:

­ If you or someone you know has a gambling problem, help is available. Call (toll free telephone number).

­ Gambling Problem? Please call (toll free telephone number).

­ Gambling Problem? Call (toll free telephone number).

o The complete text of the gambling assistance message and the font to be used for the statement, if it has not been previously approved, shall be submitted to the Director of OCPG for approval utilizing the process as outlined below:

­ For signs, direct mail marketing materials, posters and other print advertisements, the height of the font used for the gambling assistance message must be the greater of:

● The same size as the majority of the text used in the sign, direct mail marketing material, poster or other print advertisement.

● Two percent of the height or width, whichever is greater, of the sign, direct mail marketing material, poster or other print advertisement.

­ For billboards, the height of the font used for the gambling assistance message must be at least 5% of the height or width, whichever is greater, of the face of the billboard.

­ For video and television, the gambling assistance message must be visible for either:

● The entire time the video or television advertisement is displayed. The height of the font used for the gambling assistance message must be at least 2% of the height or width, whichever is greater, of the image that will be displayed.

● From the first time a table game, table game device, slot machine, associated equipment or casino name is displayed or verbally referenced, and on a dedicated screen shot visible for at least the last 3 seconds of the video or television advertisement. If the licensee elects to utilize this option, the height of the font used for the gambling assistance message displayed must conform to:

▪ During the advertisement must be at least 2% of the height or width, whichever is greater, of the image that will be displayed.

▪ On the dedicated screen shot must be at least 8% of the height or width, whichever is greater, of the image that will be displayed.

­ For web sites, including social media sites:

● The gambling assistance message must be posted on each webpage or profile page.

● On a gaming related advertisement, posted on the webpage or profile page.

● The height of the font used for the gambling assistance message must be at least the same size as the majority of the text used in the webpage or profile page.

● For advertisements posted on the webpage or profile page, the height of the font used for the gaming assistance message must comply with paragraph (1).