Stake Casino’s T&Cs are fair and well-crafted. However, we believe they are biased towards the casino, and if a player violates one or more rules, Stake is unlikely to change its decision. We appreciate that in some cases, account closure does not mean losing funds, as Stake will allow withdrawals. We do not recommend playing at Stake while you are traveling.

1. Terms and Service

Terms and Conditions

1. STAKE.COM

1.1 Stake.com is owned and operated by Medium Rare, N.V. (hereinafter “Stake”, “We” or “Us”), a company with head office at Korporaalweg 10, Willemstad, Curaçao. Stake is licensed and regulated by the Government of Curaçao under the gaming license 8048/JAZ issued to Antillephone. Some credit card payment processing are handled by its wholly owned subsidiary, Medium Rare Limited.

2. IMPORTANT NOTICE

2.1 By registering on www.stake.com (the “Website”), you enter into a contract with Medium Rare N.V., and agree to be bound by (i) these Terms and Conditions; (ii) our Privacy Policy; (iii) our Cookies Policy and (iv) the rules applicable to our betting or gaming products as further referenced in these Terms and Conditions (“Terms and Conditions” or “Agreement”), and the betting and/or gaming specific rules, and are deemed to have accepted and understood all the terms.

2.2 Please read this Agreement carefully to make sure you fully understand its content. If you have any doubts as to your rights and obligations resulting from the acceptance of this Agreement, please consult a legal advisor in your jurisdiction before further using the Website(s) and accessing its content. If you do not accept the terms, do not use, visit or access any part (including, but not limited to, sub-domains, source code and/or website APIs, whether visible or not) of the Website.

3. GENERAL

3.1 When registering on www.stake.com You (“You”, “Your”, Yourself” or the “Player” interchangeably) enter into an agreement with Stake.

3.2 This Agreement should be read by You in its entirety prior to your use of Stake’s service or products. Please note that the Agreement constitutes a legally binding agreement between you and Stake.

3.3 These Terms and Conditions come into force as soon as you complete the registration process, which includes checking the box accepting these Terms and Conditions and successfully creating an account. By using any part of the Website following account creation, you agree to these Terms and Conditions applying to the use of the Website.

3.4 We are entitled to make amendments to these Terms and Conditions at any time and without advanced notice. If we make such amendments, we may take appropriate steps to bring such changes to your attention (such as by email or placing a notice on a prominent position on the Website, together with the amended terms and conditions) but it shall be your sole responsibility to check for any amendments, updates and/or modifications. Your continued use of the website services after any such amendment to the Terms and Conditions will be deemed as your acceptance and agreement to be bound by such amendments, updates and/or modifications.

3.5 The terms of this Terms and Conditions shall prevail in the event of any conflict between the terms of this Terms and Conditions and of any of the game rules or other documents referred to in this Terms and Conditions.

3.6 These Terms and Conditions may be published in several languages for informational purposes and ease of access by players. The English version is the only legal basis of the relationship between you and us and in the case of any discrepancy with respect to a translation of any kind, the English version of these Terms and Conditions shall prevail.

4. STAKE ACCOUNT

Registration

4.1 In order for you to be able to place bets on stake.com, you must first personally register an account with us (“Stake Account”).

4.2 For a person to be registered as a player with Stake and use the Website, that person must submit an application for registration and opening of a Stake account. The application for the opening of the Stake Account must be submitted personally, and will require You to provide a set of personal information, namely e-mail, full name, date of birth, address, etc.

4.3 Where the information stipulated in 4.2. is not provided and/or is not deemed to be complete, accurate or up-to-date at any point in time, Stake reserves the right to suspend the Stake Account registration and treat any subsequent potentially accepted deposits to the Player’s Stake Account as invalid (and any winnings arising from such deposit as void). Where a Stake Account is suspended, You should contact customer support at [email protected].

4.4 All applicants must be 18 or such other legal age of majority as determined by any laws which are applicable to you, whichever age is greater or older. Stake reserves the right to ask for proof of age from any Player and suspend their Stake Account until satisfactory documentation is provided. Stake takes its responsibilities in respect of under age and responsible gambling very seriously.

4.5 Stake will not accept registration from individuals:

a) Under 18 years old or under the legal age of majority or gambling in their jurisdiction;

b) Residing in jurisdictions from where it is illegal or gambling is not permitted. Stake is not able to verify the legality of the Service in each jurisdiction and it is the User’s responsibility to ensure that their use of the Service is lawful;

c) Provide misleading information or try to pass by third parties.

4.6 Stake reserves the right to refuse any application for a Stake Account, at its sole discretion.

Know Your Customer

4.7 You represent and warrant that any information provided by You on Your application form is true, updated and correct.

4.8 Stake reserves the right, at any time, to ask for any KYC documentation it deems necessary to determine the identity and location of a Player. Stake reserves the right to restrict the Service, payment or withdrawal until identity is sufficiently determined, or for any other reason in Stake’s sole discretion. Stake also reserves the right to disclose a Player’s information as appropriate to comply with legal process or as otherwise permitted by the privacy policy of Stake (owner and operator of Stake), and by using the Service, you acknowledge and consent to the possibility of such disclosure.

Multiple Accounts

4.9 Only one Stake Account per Player is allowed. Should You attempt or successfully open more than one Stake Account, under Your own name or under any other name, or should You attempt or succeed in using the Website by means of any other person’s Stake Account, Stake will be entitled to immediately close all Your Stake Account(s), retain all monies in such Stake Accounts and ban You from future use of the Website.

4.10 Should Stake have reason to believe that You have registered and/or used more than one Stake Account, or colluded with one or more other individuals using a number of different Stake Accounts, Stake shall be entitled to deem such accounts as constituting multiple Stake Accounts, and suspend or close all such Stake Accounts. Stake will also be entitled to retain the funds till the Player proves that he did not attempt to create multiple accounts.

4.11 If you notice that you have more than one registered Stake Account you must notify us immediately. Failure to do so may lead to your Stake Account being blocked and the funds retained.

User Responsibility

4.12 It is your sole and exclusive responsibility to ensure that your login details are kept securely. You must not disclose your login details to anyone.

4.13 We are not liable or responsible for any abuse or misuse of your Stake Account by third parties due to your disclosure, whether intentional, accidental, active or passive, of your login details to any third party.

4.14 You are prohibited from selling, transferring or acquiring Stake Accounts to or from other Players.

4.15 You will inform us as soon as you become aware of any errors with respect to your account or any calculations with respect to any bet you have placed. We reserve the right to declare null and void any bets that are subject to such an error.

4.16 You are responsible for all activities that occur under your account.

Security Features

4.17 We recommend that you enable two-factor authentication to enhance the security of your account.

4.18 We may provide other security measures from time to time, and we encourage you to use them.

Suspension and Closure by Stake

4.19 Stake shall be entitled to close or suspend Your Stake Account if:

a) Stake considers that You are using or have used the Website in a fraudulent or collusive manner or for illegal and/or unlawful or improper purposes;

b) Stake considers that You are using or have used the Website in an unfair manner, have deliberately cheated or taken unfair advantage of Stake or any of its customers or if Your Stake Account is being used for the benefit of a third party;

c) Stake is requested to do so by the police, any regulatory authority or court or if Stake is unable to verify Your identity, profession or source of funds as is expressly required by the applicable regulations;

d) You are in breach of these Terms and Conditions, the applicable regulations or the fair use of our services, or Stake has concerns that You are a compulsive problem gambler without being self-excluded;

e) Stake considers that any of the events referred to in (a) to (e) above may have occurred or are likely to occur.

4.20 If Stake closes or suspends Your Stake Account for any of the reasons referred to in 4.19, You shall, to the extent permitted by applicable laws, be liable for any and all claims, direct losses, liabilities, damages, costs and expenses incurred or suffered by Stake (together, the “Claims”) arising therefrom and shall, to the extent permitted by applicable laws, indemnify and hold Stake harmless on demand for such Claims.

4.21 In the circumstances referred to in 4.19, Stake shall also be entitled to void any bets placed by You following such actions by You or to withhold and/or retain any and all amounts which would otherwise have been paid or payable to you (including any winnings) to the extent permitted by law.

4.22 We reserve the right to suspend or terminate your account at any time, with or without notice, if we suspect that you account has been compromised or is being used in breach of our Terms of Service.

4.23 If Stake closes Your Stake Account it will inform You of the available means to withdraw the remaining balance on Your Stake Account.

Our Liability

4.24 We take no responsibility for any loss or damage that you may suffer as a result of unauthorised access to your account.

4.25 We take no responsibility for any loss or damage that you may suffer as a result of your failure to keep your login secure and private.

5. YOUR WARRANTIES

5.1 Prior to your use of the Service and on an ongoing basis you represent, warrant, covenant and agree that:

Capacity

a) You are over 18 or such other legal age of majority as determined by any laws which are applicable to you, whichever age is greater;

b) 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;

c) You are not diagnosed or classified as a compulsive or problem gambler;

d) You are not currently self-excluded from any gambling site or gambling premises. You will inform Stake immediately if you enter into a self-exclusion agreement with any gambling provider.

Jurisdiction

e) You are accessing stake.com from a jurisdiction in which it is legal to do so;

f) You 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;

g) You accept and acknowledge that we reserve the right to detect and prevent the use of prohibited techniques, including but not limited to fraudulent transaction detection, automated registration and signup, gameplay and screen capture techniques. These steps may include, but are not limited to, examination of Players device properties, detection of geo-location and IP masking, transactions and blockchain analysis;

Funds & Tax

h) You are solely responsible for reporting and accounting for any taxes applicable to you under relevant laws for any winnings that you receive from us;

i) You are solely responsible for any applicable taxes which may be payable on cryptocurrency awarded to you through your using the Service;

j) There is a risk of losing cryptocurrency when using the Service and that Stake has no responsibility to you for any such loss;

k) You will not deposit funds which originate from criminal or other unauthorised activity;

l) You will not deposit funds using payment methods that do not belong to You;

m) All the funds deposited shall exclusively be used for Services available on the Website;

n) You will not withdraw or try to withdraw to a payment methods that do not belong to You;

o) You understand that by participating in the Services available on the Website, You take the risk of losing money deposited.

p) You accept and acknowledge that the value of cryptocurrency can change dramatically depending on the market value;

q) Stake shall not be treated as a financial institution;

Others

r) Your use of the Service is at your sole option, discretion and risk;

s) You will not conduct criminal activities through the Stake Account;

t) All information that you provide to us during the term of validity of this agreement is true, complete, correct, and that you shall immediately notify us of any change of such information;

u) You participate in the Games strictly in your personal and non-professional capacity and participate for recreational and entertainment purposes only;

v) You participate in the Games on your own behalf and not on the behalf of any other person;

w) You have only one account with us and agree to not to open any more accounts with us;

x) The telecommunications networks and Internet access services required for you to access and use the Service are entirely beyond the control of Stake and Stake shall have no liability whatsoever for any outages, slowness, capacity constraints or other deficiencies affecting the same;

y) You will not be involved in any fraudulent, collusive, fixing or other unlawful activity in relation to Your or any third parties’ participation in any of the games and/or services on the Website, and shall not use any software-assisted methods or techniques or hardware devices for Your participation in any of the games and/or services on the Website;

z) If you have access to non-public information related to an event or that can impact the outcome of an event or bet type, You will not bet on any event overseen by the relevant sport/event governing body;

aa) If You are an athlete, coach, manager, owner, referee, or anyone with sufficient authority to influence the outcome of an event You will not bet on any event overseen by the relevant sport or event of the governing body;

bb) If You are an owner (a person who is a direct or indirect legal or beneficial owner of 10 percent or greater) of a sport governing body or member team You will not bet on any event overseen by the sport governing body or any event in which a member team of that sport or event governing body participates;

cc) If You are involved in a sport or event You will not be involved in compiling betting odds for the competition in which You are involved.

5.2 In case of a breach of any of the representations, warrants or covenants mentioned in 5.1, Stake reserves the right to close or suspend Your Stake account at its own discretion and void any bets to the extent applicable by law.

6. STAKE WARRANTIES

6.1 Stake warrants that they will:

a) manage funds belonging to the Player in a secure and appropriate manner; and

b) manage personal information pertaining to the Player in accordance with applicable law, and in accordance with its Privacy Policy.

6.2 The software is provided “as is” without any warranties, conditions, undertakings or representations, express or implied, statutory or otherwise. Stake hereby excludes all implied terms, representations, conditions and warranties (including any of merchantability, merchantable quality, satisfactory quality and fitness for any particular purpose). Stake does not warrant that: (i) the Website and Services will meet Your requirements; (ii) the Website and Services will not infringe any third party’s intellectual property rights; (iii) the operation of the Website and Services will be error-free or uninterrupted; (iv) any defects in the Website and Services will be corrected; or (v) the Website or the servers are virus-free.

6.3 Stake can be contacted by email on [email protected] or on its live chat 24/7. The live chat is available when logged into Your Stake Account. In the event that Stake, in its sole discretion, deems that Your behaviour, via live chat, email, or otherwise, has been abusive or derogatory towards any of Stake’s or its Affiliates or third-party service provider’s employees, Stake shall have the right to block or terminate Your Stake Account.

7. DEPOSITS

7.1 You may participate in any Game only if you have sufficient funds on your Stake Account for such participation. For that purpose you shall use the payment methods available on the Website to deposit your funds. Stake will not give you any credit whatsoever for participation in any Game.

7.2 You must deposit funds to Your Stake Account using the payment methods available at www.stake.com.

7.3 You shall ensure that funds that You deposit into your Stake Account are not tainted with any illegality and, in particular, do not originate from any illegal activity or source.

7.4 To deposit funds into your Stake Account, you can transfer funds from crypto-wallets under your control or through any other payment methods available on stake.com. Deposits can only be made with your own funds.

7.5 You should only deposit money into Your account for the purpose of You using such money to place bets/wager on the Website. Stake is entitled to suspend or close Your account if we reasonably believe that You are depositing funds without any intention to place sporting and/or gaming wagers. In such circumstances we may also report this activity to relevant authorities.

7.6 You acknowledge and understand that funding Your Stake Account can only be funded by payment methods owned by You.

7.7 You further understand, agree and acknowledge that if Stake discovers, detects and/or identifies that You:

a) Funded/are funding Your Stake Account using third party payment methods; and/or

b) Funded/are funding Your Stake Account with funds that are tainted with illegality, such activity will be deemed as constituting a violation of the Terms of Service amounting to fraud, and by extension:

i) Stake reserves the right, at its own discretion, to suspend or close Your Stake Account; and

ii) Stake reserves the right, at its own discretion, to cancel, reverse or adjust any transactions and to forfeit funds deposited and/or winnings generated from the deposited funds.

7.8 Stake can set at its own discretion a minimum deposit amount. The minimum deposit amount can be changed at all time at Stake’s discretion and will be identified on the website. Please be aware that depending on the payment method used by You, additional fees might be charged by the payment providers.

7.9 The payment methods made available to you and the minimum and maximum deposit limit can be found in the wallet section on the Site. Applicable service fees may be applied and changed. Some payment methods may not be available in all countries.

7.10 Deposits are immediately processed and the updated balance is shown in the Stake Account instantly whenever a payment service provider is used. Stake does not take responsibility for any delays caused due to its payment system or due to delays caused by any third party. Note that:

a) some payment methods may include additional fees. In this case, the fee will be clearly visible for you in the cashier.

b) your bank or payment service provider may charge you additional fees for deposits of currency conversion according to their terms and conditions and your user agreement.

7.11 We reserve the right to use additional procedures and means to verify your identity when processing deposits into your Stake Account.

7.12 Funds cannot be transferred from your Stake Account to the Stake Account of another Player.

7.13 Stake can refuse any deposits at its own discretion. Users that have their accounts blocked, or suspended shall refrain from depositing at www.stake.com.

7.14 In the event that a player tries to deposit when his account is blocked or suspended, Stake will have the right to retain the funds.

8. WITHDRAWALS

8.1 Stake reserves the right to refuse any withdrawal by a Player from their Stake Account until:

a) the Player’s identity has been verified and Stake has confirmed the withdrawal is being made by a holder of the Stake Account;

b) the withdrawal is being transferred to an account of which the Player is a legal holder;

c) any additional information requested by Stake has been provided; and

d) the Player has complied with the minimum wager requirement for each deposit.

8.2 Stake reserves all rights to investigate Your account and gaming activity. If Stake reasonably suspects that Your account or gaming activity has violated these terms of service or applicable laws or regulations, it may, in its sole discretion, delay or decline further deposits, withdrawals and/or game play while it conducts its investigation. You acknowledge and accept that Stake may not be in a position to provide an explanation as to the nature of its investigation.

8.3 All withdrawals must be done through the same payment method chosen by you when placing a deposit, unless we decide otherwise or are unable to do so. If you deposit using a number of payment methods, we reserve the right to split your withdrawal across such payment methods and process each part through the respective payment method at our discretion and in accordance with anti-money laundering policies and regulation.

8.4 If we mistakenly credit your Stake Account with winnings that do not belong to you, whether due to a technical error in the pay-tables, or human error or otherwise, the amount will remain our property and will be deducted from your Stake Account. If you have withdrawn funds that do not belong to you prior to us becoming aware of the error, the mistakenly paid amount will (without prejudice to other remedies and actions that may be available at law) constitute a debt owed by you to us. In the event of an incorrect crediting, you are obliged to notify us immediately by email.

FIAT Withdrawals

8.5 You need to wager 100% of the value of your deposit in order to request a FIAT withdrawal.

8.6 Withdrawals from Stake Account are made through payments addressed to the Player or transferred to a bank account held in the name of the Player, as advised to Stake by the Player. Before processing any withdrawal, Stake reserves the right to perform enhanced due diligence where deemed necessary.

8.7 The minimum withdrawal amount will be identified on the website when performing a withdrawal.

8.8 If You have multiple withdrawals pending, Stake reserves the right to reject all withdrawals and request You to perform one withdrawal with the sum of all multiple withdrawals.

8.9 Stake will not charge You any fees on withdrawals. However, You are advised to check if the payment method You use imposes any additional charges. Stake will not be responsible for any commissions or processing fees charged to You by third parties such as Your bank as this is beyond our control.

Crypto Withdrawals

8.10 Crypto withdrawals will be made to your stated cryptocurrency wallet address when making a valid withdrawal request.

8.11 Stake reserves the right to carry out additional KYC verification procedures for any withdrawal. Players who wish to recover funds held in a closed, locked or excluded account, are advised to contact [email protected].

8.12 All transactions shall be checked in order to prevent money laundering. If a player becomes aware of any suspicious activity relating to any of the Games of the Website, s/he must report this to Stake immediately. Stake may suspend, block or close a Stake Account and withhold funds if requested to do so in accordance with the Prevention of Money Laundering Act or on any other legal basis requested by any state authority. You acknowledge that the funds in your account are consumed instantly when playing and we do not provide return of goods, refunds or retrospective cancellation of your account.

9. PLAYER FUNDS PROTECTION & CHARGEBACKS

9.1 Any funds You deposit with us in Your Stake Account, along with any winnings, are held for You in separate customer bank accounts / crypto wallet for the sole and specific purpose for You to place sports and gaming wagers and to settle any fees or charges that You might incur in connection with the use of our Services. This means Your funds are protected from being used for any other purpose.

9.2 If we incur any charge-backs, reversals or denial of payments or any loss suffered by Stake as a consequence thereof due to causes attributable to You in respect of Your Stake Account, we reserve the right to charge You for the relevant amounts incurred.

9.3 We may, at any time, offset any positive balance on Your account against any amounts owed by You to Stake.

10. PLACING BETS/WAGERS

10.1 You are allowed to place Your bets/wagers on the markets/products offered in the Website. Stake is not obliged to accept any bet/wager from You and bets/wagers will only be deemed as valid and finalised, and therefore as accepted by Stake, when You receive the confirmation from Stake of the acceptance of Your bet/wager.

10.2 Stake only accepts bets/wagers made online (including via mobile device). Bets/wagers are not accepted in any other form (post, email, fax, etc.) and where received will be invalid and void – win or lose.

10.3 It is Your responsibility to ensure details of the bets/wagers are correct. Once bets/wagers have been placed they may not be cancelled by You. Bets can only be changed by You using our Edit Bet feature, where this is available. Stake can only cancel or amend a bet/wager if the relevant event has been suspended or cancelled, if there was an obvious error on the relevant bet or its odds, if the bet is placed in breach of the Terms or if required to do so for legal or regulatory reasons.

10.4 Your funds will be allocated to bets/wagers in the order they are placed and will not be available for any other use. Stake reserves the right to void and/or reverse any transactions made after a bet/wager has been placed involving allocated funds, either at the time or retrospectively.

11. BET/WAGER CONFIRMATION

11.1 Bets/wagers will only be valid once You receive the confirmation of the acceptance of Your bet/wager. Bets/wagers placed with insufficient funds in Your account will be void.

11.2 A bet/wager that You request will only be valid once accepted by Stake. Each valid bet/wager will receive a unique transaction code. We shall not be liable for the settlement of any bets/wagers which are not issued with a unique transaction code. If You are unsure about the validity of a bet/wager, please check Your account history, or contact our Customer Support Team ([email protected]).

11.3 Should a dispute arise regarding the content of a bet, You and Stake agree that the Stake transaction log database of its internal control system will be the ultimate authority in such matters.

12. BONUS

12.1 Stake, at its sole discretion, might offer from time to time, a number of Bonuses and Promotions. For example, The Million Dollar Race, the 50 Billionth Bet Bonanza, Coupons, Reloads, and Rakeback.

Eligibility

12.2 Upon successful registration for a Stake Account, You may be eligible to receive Stake Promotions and Bonuses. By accepting this agreement and registering for a Stake Account on the Website, You are also acknowledging and accepting to be bound by the rules and regulations associated with any Promotions and Bonuses offered to You by Stake.

Bonus T&C

12.3 All promotions, bonuses, or special offers are subject to the express terms of any bonus offered on the Website(s) and promotion-specific terms and conditions, if applicable, and any bonus credited to Your account must be used in adherence with such terms and conditions. By accepting a promotion, bonus, or special offer available on the Website(s), You consent to the terms and conditions of such promotion, bonus, or special offer and acknowledge that wagers must always be placed with cash balances before bonus balances can be used to wager. We reserve the right to withdraw any promotion, bonus, or special offer at any time.

Activation & Expiry

12.4 By activating a Bonus or Promotion, You confirm that You also agree to the applicable terms and conditions.

12.5 No promotion, bonus, or special offer will be accepted or honoured by the Stake following the expiration date of the promotion, bonus, or special offer, unless Stake in its sole discretion chooses to do so for any particular customer, promotion, bonus, or special offer. Expiration dates will be set forth in the specific rules or terms and conditions of the particular promotion, bonus, or special offer. Furthermore, Stake reserves the right, in its sole discretion, to change or modify any policy with respect to the earning or expiration of bonuses.

12.6 Once forfeited or de-activated, the Bonus will no longer be available to You (and cannot be re-activated at any time thereafter). The amount of any Bonus Funds that have already been credited to your Stake Account Balance will remain available to You.

Bonus Abuse & Fraud

12.7 In the event that Stake believes a Player of the Service is abusing or attempting to abuse a bonus or other promotion or is likely to benefit through abuse or lack of good faith from a policy adopted by Stake, then Stake may, at its sole discretion, deny, withhold, or withdraw from any Player any bonus or promotion, or terminate that Player’s access to the Services, the Software, and/or lock that Player’s account, either temporarily or permanently.

12.8 You may only open one (1) account on the Website. The opening of multiple accounts on the Website for the purpose of accumulating bonuses, promotions, special offers, or otherwise, shall be considered abusive behaviour.

Stake Rights

12.9 Stake reserves the right to remove bonuses from all inactive accounts or accounts that are identified as “bonus abusers”.

12.10 Stake reserves the right to cancel all bonuses that have not been claimed within the claiming period or 60 days, the shorter of the two.

12.11 Stake reserves the right to cancel any bonus at its sole discretion.

13. AUTHORITY/TERMS OF SERVICE

13.1 You agree to the game rules described on the Stake.com website. Stake retains authority over the issuing, maintenance, and closing of the Service. The decision of Stake’s management, concerning any use of the Service, or dispute resolution, is final and shall not be open to review or appeal.

14. PROHIBITED USES

PERSONAL USE

14.1 The Service is intended solely for the User’s personal use. The User is only allowed to wager for his/her personal entertainment. Users may not create multiple accounts for the purpose of collusion, sports betting and/or abuse of service.

AML & SANCTIONS COMPLIANCE

14.2 Stake expressly prohibits and rejects the use of the Service for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various jurisdictions’ laws, regulations and norms. To that end, the Service is not offered to individuals or entities subject to United States, European Union, or other global sanctions or watch lists. By using the Service, you represent and warrant that you are not so subject.

JURISDICTIONS

14.3 Persons located in or reside in Afghanistan, Austria, Australia, Belarus, Belgium, Colombia, Côte d’Ivoire, Cuba, Curaçao, Czech Republic, Democratic Republic of the Congo, Denmark, France, Germany, Greece, Iran, Iraq, Israel, Italy, Liberia, Libya, Lithuania, Netherlands, North Korea, Ontario, Pakistan, Portugal, Serbia, Slovakia, South Sudan, Spain, Sudan, Syria, Sweden, Switzerland, United Kingdom, United States, Zimbabwe (the “Prohibited Jurisdictions”) are not permitted make use of the Service. For the avoidance of doubt, the foregoing restrictions on engaging in real-money play from Prohibited Jurisdictions applies equally to residents and citizens of other nations while located in a Prohibited Jurisdiction. Any attempt to circumvent the restrictions on play by any persons located in a Prohibited Jurisdiction or Restricted Jurisdiction, is a breach of this Agreement. An attempt at circumvention includes, but is not limited to, manipulating the information used by Stake to identify your location and providing Stake with false or misleading information regarding your location or place of residence.

14.4 The attempt to manipulate your real location through the use of VPN, proxy, or similar services or through the provision of incorrect or misleading information about your place of residence, with the intent to circumvent geo-blocking or jurisdiction restrictions, constitutes a breach of Clause 5 of this Terms of Service.

15. YOUR EQUIPMENT

15.1 Your computer equipment or mobile device and internet connection may affect the performance and/or operation of the Website. Stake does not guarantee that the Website will operate without faults or errors or that Stake services will be provided without interruption. Stake does not accept any liability for any failures or issues that arise due to Your equipment, internet connection or internet or telecommunication service provider (including, for example, if You are unable to place bets or wagers or to view or receive certain information in relation to particular events).

15.2 For customers using a mobile device for the placing of bets/wagers, please note that Stake will not be responsible for any damage to, or loss of data from the mobile device that the software is installed on, and will also not be responsible for any call, data or other charges incurred whilst using the software.

15.3 Due to limited display sizes on mobile devices, the mobile experience might differ slightly from other platforms. Differences might include, but are not limited to, the location of certain information on the platform and game names not being visible on all game pages.

16. FAIR USE

16.1 The Website and Services may only be used for recreational purposes by placing bets and wagers on events and/or gaming products.

16.2 You must not use the Website for the benefit of a third party or for any purpose which is illegal, defamatory, abusive or obscene, or which Stake considers discriminatory, fraudulent, dishonest or inappropriate. Stake may report to the authorities any activity which it considers to be suspicious and/or in breach of this paragraph.

16.3 If Stake has a reasonable suspicion that You are involved in fraudulent, dishonest or criminal acts, as set out under applicable laws, via or in connection with the Website or Services, Stake may seek criminal and contractual sanctions against You. Stake will withhold payment to any customer where any of these are suspected or where the payment is suspected to be for the benefit of a third party.

16.4 You shall indemnify and shall be liable to pay Stake, on demand, all costs, charges or losses sustained or incurred by us and our affiliates (including any direct, indirect or consequential losses, loss of profit and loss of reputation) in respect of all Claims arising directly or indirectly from Your fraudulent, dishonest or criminal acts while using the Website or Services

16.5 Furthermore, we reserve the right not to accept, process and/or honour bets/wagers where it would be forbidden, unlawful or illegal under applicable law or regulation to do so.

17. SOFTWARE AND TECHNOLOGY ISSUES

17.1 In order for You to use the Website and Services, You may need to download some software (for example, casino games that are made available via a flash player). Also, certain third party product providers may require You to agree to additional terms and conditions governing the use of their products that are available on or through the Website. If You do not accept those third party terms and conditions, do not use the relevant third party software. Stake does not accept any liability in respect of any third party software.

17.2 You are only permitted to use any and all software made available to You via the Website for the purpose of using the Website and Services and, save to the extent permitted by applicable law, for no other purposes whatsoever.

17.3 We hereby grant to You a personal, non-exclusive, non-transferable right to use the Website for the sole purpose of accessing and using the Services on the Website, in accordance with these Terms and Conditions. This right to use our Website and will be immediately terminated once Your user registration is cancelled for any reason, and specially, but not limited to, if You make use of that right with the aim of generating a parallel enterprise based in our Website or our products, or with the aim of making use of an automated service or software analysing, capturing or somehow using the information shown in our Website.

17.4 You are not permitted to:

a) install or load the software that forms part of the Website onto a server or other networked device or take other steps to make the software available via any form of “bulletin board”, online service or remote dial-in or network to any other person;

b) sub-license, assign, rent, lease, loan, transfer or copy (except as expressly provided elsewhere in these Terms and Conditions) Your right to use the Website, or the software that forms part of the Website, or make or distribute copies of same;

c) enter, access or attempt to enter or access or otherwise bypass Stake’s security system or interfere in any way (including but not limited to, robots or similar devices) with the products or the Website or attempt to make any modifications to the software and/or any features or components thereof;

d) copy or translate any user documentation provided ‘online’ or in electronic format.

e) In addition, except to the minimum extent permitted by applicable law in relation to computer programs, You are not permitted to: (i) translate, reverse engineer, decompile, disassemble, modify, create derivative works based on, or otherwise modify the Website; or (ii) reverse engineer, decompile, disassemble, modify, adapt, translate, make any attempt to discover the source code of the software that forms part of the Website or to create derivative works based on the whole or on any part of the Website.

17.5 You do not own the software that forms part of the Website. Such software is owned and is the exclusive property of Stake or a third party software provider company (any such third party provider, the “Software Provider”). Any software and accompanying documentation which have been licensed to Stake are proprietary products of the Software Provider and protected throughout the world by copyright law. Your use of the software does not give You ownership of any intellectual property rights in the software.

17.6 The software is provided “as is” without any warranties, conditions, undertakings or representations, express or implied, statutory or otherwise. Stake hereby excludes all implied terms, conditions and warranties, including any of merchantability, merchantable quality, satisfactory quality and fitness for any particular purpose, completeness or accuracy of the services or the software or infringement of applicable laws and regulations. Stake does not warrant or condition that: (i) the software will meet Your requirements; (ii) the software will not infringe any third party’s intellectual property rights; (iii) the operation of the software will be error free or uninterrupted; (iv) any defects in the software will be corrected; or (v) the software or the servers are virus-free.

17.7 In the event of communications or system errors occurring in connection with the settlement of accounts or other features or components of the software, neither Stake nor the Software Provider will have any liability to You or to any third party in respect of such errors. Stake reserves the right in the event of such errors to remove all relevant products from the Website and take any other action to correct such errors.

17.8 You hereby acknowledge that how You use the software is outside of Stake’s control. Accordingly, You install and/or use the software at Your own risk. Stake will not have any liability to You or to any third party in respect of Your receipt of and/or use of the software.

17.9 The software may include confidential information which is secret and valuable to the Software Provider and/or Stake. You are not entitled to use or disclose that confidential information other than strictly in accordance with these Terms and Conditions.

17.10 Stake shall not be liable if for any reason the Website is unavailable at any time or for any period. We reserve the right to make changes or corrections to or to alter, suspend or discontinue any aspect of the Website and the content or services or products available through it, including Your access to it.

17.11 You must not misuse the Website by introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. In particular, You must not access the Website without authority, interfere with, damage or disrupt the Website or any part of it, any equipment or network on which the Website is hosted, any software used in connection with the provision of the Website, or any equipment, software or website owned or used by a third party. You must not attack our Website via a denial-of-service attack. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect Your computer equipment, computer programs, data or other proprietary material arising due to Your use of the Website, software or to Your downloading of any material posted on it, or on any website linked to it.

18. THIRD PARTY CONTENT

18.1 Stake receives feeds, commentaries and content from a number of suppliers. Certain third party product providers may require You to agree to additional terms and conditions governing the use of their feeds, commentaries and content. If You do not accept the relevant third party terms and conditions, You agree to not use the relevant feeds, commentaries or content.

18.2 Stake does not accept any liability in respect of any third party feeds, commentaries and content.

18.3 Where the Website contains links to third party websites and resources, these links are provided for Your information only. Stake has no control over the content of these sites or resources, and accepts no liability for them or for any loss or damage that may arise from Your use of them. The inclusion of a link to a third party website does not constitute an endorsement of that third party’s website, product or services, if applicable.

19. ERRORS

19.1 Stake will not be liable in the event You try to or obtain an advantage from any errors in respect of bets or wagers on the Website if You were deliberately acting in bad-faith, including where: (i) there is an obvious error in the relevant odds, spreads, handicap, totals, cash-out; (ii) Stake continues to accept bets or wagers on closed or suspended markets; (iii) Stake incorrectly calculates or pays a settlement amount, including where a bet is Cashed Out for the full settlement amount, or a bet is made void incorrectly, where ‘Void if player does not start’ was selected at bet placement; or (iv) any error occurs in a random number generator or pay tables included, incorporated or used in any game or product.

20. BREACH

20.1 Without prejudice to any other rights, if a User breaches in whole or in part any provision contained herein, Stake reserves the right to take such action as it sees fit, including terminating this Agreement or any other agreement in place with the User and/or taking legal action against such User.

20.2 You agree to fully indemnify, defend and hold harmless Stake and its shareholders, directors, agents and employees from and against all claims, demands, liabilities, damages, losses, costs and expenses, including legal fees and any other charges whatsoever, howsoever caused, that may arise as a result of:

a) your breach of this Agreement, in whole or in part;

b) violation by you of any law or any third party rights; and

c) use by you of the Service.

21. LIMITATIONS AND LIABILITY

21.1 Under no circumstances, including negligence, shall Stake be liable for any special, incidental, direct, indirect or consequential damages whatsoever (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 Service even if Stake had prior knowledge of the possibility of such damages.

21.2 Nothing in this Agreement shall exclude or limit Stake’s liability for death or personal injury resulting from its negligence.

22. INTELLECTUAL PROPERTY

22.1 Stake and its licensors are the sole holders of all rights in and to the Service and code, structure and organisation, 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 the Service in a manner prohibited by applicable laws or regulations (each of the above is an “Unauthorised Use”). Stake reserves any and all rights implied or otherwise, which are not expressly granted to the User hereunder and retain all rights, title and interest in and to the Service. 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 shall notify Stake immediately upon becoming aware of the commission by any person of any Unauthorised Use and shall provide Stake with reasonable assistance with any investigations it conducts in light of the information provided by you in this respect.

22.2 The term “Stake”, its domain names and any other trade marks, or service marks used by Stake as part of the Service (the “Trade Marks”), are solely owned by Stake. 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 Content”) belongs to Stake and is protected by copyright and/or other intellectual property or other rights. You hereby acknowledge that by using the Service, you obtain no rights in the Site Content and/or the Trade Marks, or any part thereof. Under no circumstances may you use the Site Content and/or the Trade Marks without Stake’s prior written consent. Additionally, you agree not to do anything that will harm or potentially harm the rights, including the intellectual property rights of Stake.

23. DISPUTES

23.1 If a User wishes to make a complaint, please contact Stake’s customer service team at [email protected]. Should any dispute not be resolved to your satisfaction you may pursue remedies in the governing law jurisdiction set forth below.

24. AMENDMENT

24.1 Stake reserves the right to update or modify this Agreement or any part thereof at any time or otherwise change the Service without notice and you will be bound by such amended Agreement upon posting. Therefore, we encourage you check the terms and conditions contained in the version of the Agreement in force at such time. Your continued use of the Service shall be deemed to attest to your agreement to any amendments to the Agreement.

25. GOVERNING LAW

25.1 The Agreement and any matters relating hereto shall be governed by, and construed in accordance with, the laws of Curaçao. You irrevocably agree that, subject as provided below, the courts of Curaçao shall have exclusive jurisdiction in relation to any claim, dispute or difference concerning the Agreement and any matter arising therefrom and irrevocably waive any right that it may have 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. Nothing in this clause shall limit the right of Stake to take proceedings against you in any other court of competent jurisdiction, nor shall the taking of proceedings in any one or more jurisdictions preclude the taking of proceedings in any other jurisdictions, whether concurrently or not, to the extent permitted by the law of such other jurisdiction.

26. SEVERABILITY

26.1 If a provision of this Agreement 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 hereof or the validity or enforceability in other jurisdictions of that or any other provision hereof.

27. ASSIGNMENT

27.1 Stake reserves the right to assign this agreement, in whole or in part, at any time without notice. The User may not assign any of his/her rights or obligations under this Agreement.

28. MISCELLANEOUS

28.1 No waiver by Stake of any breach of any provision of this Agreement (including the failure of Stake to require strict and literal performance of or compliance with any provision of this Agreement) 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 this Agreement.

28.2 Nothing in this Agreement shall create or confer any rights or other benefits in favour of any third parties not party to this Agreement.

28.3 Nothing in this Agreement shall create or be deemed to create a partnership, agency, trust arrangement, fiduciary relationship or joint venture between you and Stake.

28.4 Stake may assign, transfer, charge, sub-license, or deal in any other manner with this Agreement, or sub-contract any of its rights and obligations under this Agreement, to any other party.

28.5 This Agreement constitutes the entire understanding and agreement between you and Stake regarding the Service and supersedes any prior agreement, understanding, or arrangement between you and Stake.

29. COMPLAINTS

29.1 If you have a complaint to make regarding our services, you may contact our customer support via Live Chat or by email ([email protected]). We will endeavour to resolve the matter promptly.

2. Wager Requirements

A wager requirement defines the multiplier in which the sum of your deposit and bonus will need to be turned over. Since the majority of our games have between a 3.5% to 4.5% house edge, we’ve set our wager requirement at a 4% edge.

This means that if users play a 1% edged game, it will complete at a 4x slower rate. Thus, the wager requirement would be accumulating at a ratio of $0.25 for every $1 wagered. Conversely, the higher the house edge of the game being played, the less wager required to complete the rollover.

While having a wager requirement active, the user’s account will be locked until they meet the requirement set, or alternatively they lose their entire balance (in their relative bonus currency) and have no remaining active bets.

Users can check the progress of their wager requirement here.

While having an active wager requirement, users are not allowed to wager on certain games. The list of games are as follows:

3 Oaks Gaming

• All games

Belatra

• 7 Days The Spanish Armada
• Full Moon Magic
• Richy Hog
• Zombie Town

BGaming

• Candy Monsta
• God of Wealth Hold And Win
• Hit The Route
• Johnny Cash
• Journey Flirt
• Maneki 88 Gold
• Mice & Magic Wonder Spin
• Road 2 Riches
• WBC Ring of Riches
• Wild Heart

Big Time Gaming

• Lil Devil
• Royal Mint

Blueprint

• Bankin’ More Bacon
• Bounty Hunter: Unchained
• Cash Strike
• Fat Stacks Miami Cash
• Funky Buddha
• Gold Strike
• King Kong Cash
• King Kong Cash Even Bigger Bananas Megaways
• Madame of Mystic Manor
• Rise of Atlantis
• The G.O.A.T

Bombay Live

• Bollywood Stars

Booming Games

• Billy Bob Boom
• Butterfly Charms
• Fortune & Finery
• Money Inc
• Red Hot Volcano
• Treasure Vault

ELK Studios

• Birthday!
• Bloopers
• Ecuador Gold
• Electric Sam
• Kaiju
• Lake’s Five
• Miss Wildfire
• Poltava
• Sam on the Beach

Endorphina

• Football Superstar
• Golden Ox
• Jade Coins
• Joker Ra: Sunrise
• Lord of the Seas
• Lucky Streak X
• Ninja
• Oriental Dragon

Evolution

• Auto-Roulette
• Bac Bo
• Stock Market
• VIP Roulette

Fantasma Games

• 24 Star Dream
• Fortune Llama
• Miss Rainbow
• Prometheus: Titan Of Fire
• Shadow Summoner Elementals

GameArt

• Angry Dragons
• Fate’s Fury
• Pirate’s Pearl Megaways
• Safari Gems
• Wild Marmalade

Games Global

• 11 Enchanting Relics
• 1st Of The Irish
• 3 Lucky Rainbows
• 9 Skulls of Gold
• Africa X UP
• African Legends
• Age of Conquest
• Agnes Mission: Wild Lab
• Akiva: Claws of Power
• Amazing Link Apollo
• Amazing Link Bounty
• Amazing Link Hades
• Amazon Kingdom
• Amazon: Lost Gold
• Amber Sterling’s Mystic Shrine
• Ark of Ra
• Augustus
• Avalon
• Bling Bling Penguin
• Bolt X Up
• Book of Oz
• Buffalo on Fire!
• Bust The Mansion
• Captain Wild
• Chronicles of Olympus X UP
• Crazy Digginz: It’s All Mine!
• Diamond King Gold
• Diamond King Jackpots
• Diamond Sands
• Dr. Wildshock: Mad Loot Lab
• Fiona’s Christmas Fortune
• Fire and Roses Joker
• Fish ‘Em Up
• Fishin’ Christmas Pots Of Gold
• Fishin’ Pots of Gold: Gold Blitz
• Fishing Floats of Cash
• Gallo Gold Bruno’s Megaways
• God of Fire
• Gustav Minebuster
• Immortal Romance
• Immortal Romance Mega Moolah
• Lucky Clucks
• Lucky Leprechaun Clusters
• Lucky Twins Link&Win
• Mustang Riches
• Oink Farm
• Outlaw Saloon
• Peaky Pigs
• Pile ‘Em Up
• Piles of Presents
• Pirates Quest
• Retro Reels – Extreme Heat
• Scarab Kingdom
• Sisters of Oz WOWPOT
• Squealin’ Riches
• Starlite Fruits Mega Moolah
• Super 30 Stars
• The Finer Reels of Life
• Thunderstruck
• Thunderstruck II
• Thunderstruck Stormchaser
• Ticket to Riches
• Treasures Of Kilauea
• Triple Irish
• Trojan Kingdom
• Unusual Suspects
• Viking Queen
• Vikings Journey
• Wild Catch
• Wild Link Frenzy
• Wild Orient
• Witch Feature

Golden Hero

• Mimi and Magic Staff
• Monster Domination

Hacksaw Gaming

• Stick’Em

Jade Rabbit

• Steam Spin

NetEnt

• Codex of Fortune
• Cursed Treasure
• Dead or Alive
• Lost Relics 2
• Jack Hammer 3
• Jingle Bells Bonanza
• Rainforest Gold
• Rome: The Golden Age
• Pirate’s Party
• Serengeti Kings
• Street Fighter 2
• The Wish Master Megaways

OneTouch

• Flexing Dragons
• Reel Fruitz Frenzy
• Steam Vault
• Tiki Terror
• Wacky Wildlife
• Wealthy Sharks

PG Soft

• Dragon Hatch
• Dragon Hatch 2
• Fortune Dragon
• Fortune Rabbit
• Fortune Tiger
• Fortune Mouse
• Fortune Ox

PlaynGo

• 3 Clown Monty 215 Crystal Roses: A Tale of Love
• Baker’s Treat
• Cat Wilde and The Incan Quest
• Chambers of Ancients
• Eye of the Kraken
• Gerard’s Gambit
• Golden Legend
• Happy Halloween
• Hugo 2
• Love is in the Fair
• Mahjong 88
• Moon Princess
• Moon Princess 100
• Moon Princess Power of Love
• Multifruit 81
• Pearls of India
• Pimped
• Rage to Riches
• Royal Masquerade
• Sea Hunter
• Tower Quest
• Viking Runecraft

PopiPlay

• Slotham City
• Wild Wild Bank
• Guns and Dragons

Pragmatic Play

• 3 Kingdoms – Battle of Red Cliffs
• Asgard
• Candy Jar Clusters
• Cash Elevator
• Ding Dong Christmas Bells
• Dragon Kingdom
• Jade Butterfly
• Jungle Gorilla
• Spaceman
• Pinup Girls
• Snakes and Ladders Megadice
• The Champions
• Wheel O’Gold
• Wild Depths

Push Gaming

• Hearts Highway
• Jammin Jars 2
• Mad Cars
• Shamrock Saints
• Tiki Tumble
• Wild Swarm
• Wild Swarm 2

Quickspin

• Brawlers Bar Cash Collect
• Crown of Valor
• Skulls Up!

Red Rake Gaming

• Boomerang Jack’s Lost Mines
• Captain Wild
• Gustav Minebuster
• Million Christmas
• Super 30 Stars
• Triple Irish

Red Tiger

• 10,001 Nights Megaways
• Bounty Raid 2
• Dragon’s Clusterbuster
• Dragon’s Fire Infinireels
• Dragon’s Luck Megaways
• Dragon’s Mirror
• Dynamite Riches
• Dynamite Riches Megaways
• Get the Gold Infinireels
• Gonzo’s Quest Megaways
• London Tube
• Play with the Devil
• Reptizillions Power Reels
• Siren’s Riches
• Spin Town
• Spooky Carnival
• The Wild Kiss
• Zaida’s Fortune
• Zeus Lightning Power Reels

Relax Gaming

• 5 Monsters
• Book of 99
• Christmas Santa
• Deep Descent
• Frequent Flyer
• Golden Calaveras
• Great Pigsby Megaways
• Hellcatraz
• Not Now Norman
• Orca’s Wild Bonanza Extenda Edition
• Phoenix Up Cash
• The Wild Drifter
• Tiki Bonanza
• Titan Strike
• Towering Pays Egypt
• Treasure Pirates
• Valkyrie Wild Storm
• Wild Donuts

Spinomenal

• 1 Reel Baba Yaga
• 1 Reel Beauty
• 1 Reel Buffalo
• 1 Reel – Caribbean Treasure
• 1 Reel: Cash Vault
• 1 Reel Demi Gods II
• 1 Reel Demi Gods III
• 1 Reel Demi Gods IV
• 1 Reel Egypt
• 1 Reel Elves
• 1 Reel Fruits
• 1 Reel Golden Piggy
• 1 Reel Halloween
• 1 Reel Hawaiian Bliss
• 1 Reel Joker
• 1 Reel Majestic King
• 1 Reel Mammoth
• 1 Reel Monkey
• 1 Reel Panther
• 1 Reel Patrick
• 1 Reel Reef
• 1 Reel Shamrock
• 1 Reel Thanksgiving
• 1 Reel Wolf Fang
• 1 Reel Xmas
• Aztec Spell
• Aztec Spell – 10 Lines
• Beer Collection – 20 Lines
• Beer Collection – 30 Lines
• Book Of Demi Gods III
• Book Of Rebirth
• Book of The Divine
• Colossus Fruits
• Comic Craze
• Demi Gods III
• Egyptian Rebirth II
• Egyptian Rebirth II 10 Line
• Fruits Collection – 10 Lines
• Gangster’s Gold
• Goddess Of Lotus
• Goddess Of Lotus- 10 Lines
• Magical Amazon
• Penny Fruits Xtreme
• Queen Of Fire
• Spinning Beers
• Story of the Samurai
• Story of the Samurai – 10 Lines

Stake Originals

• Dice
• Crash
• Dragon Tower
• Limbo
• Hilo
• Slide
• Mines
• Blackjack

Thunderkick

• 12 Bolts of Thunder
• 1429 Uncharted Seas
• Beat the Beast: Quetzalcoatl’s Trial
• Not Enough Kittens
• Raven’s Eye
• Rocket Fellas Inc
• The Rift

Truelab

• Aztec Legend
• Crypts of Fortune
• Day and Night
• Victoria Wild
• Victoria Wild Deluxe

Wazdan

• All games

3. Anti-Money Laundering, Anti-Terrorist Financing statement

1. Company Business Model

Medium Rare N.V. (“Stake” or the “Company”) is a company incorporated under Curaçao Law that was established in 2017 and operates the online casino www.stake.com under the licence n.º 1668/JAZ. Stake presently supports users in more than 169 countries globally.

As part of its global operations, Stake has established compliance measures commensurate with its services and products that are reasonably designed to deter and detect illicit activity on its platform. Such measures include onboarding and compliance screenings of its customers and transaction action-based controls.

2. Company Policy Statement

Stake is not a financial institution within the meaning of applicable law of Curaçao and is accordingly not directly subject to the statutes and regulations applicable to certain financial institutions, money transfer, or virtual asset service providers. However, in accordance with the 2016 Regulations for Anti-Money Laundering and Combating the Financing of Terrorism (“AML/CFT”) applicable for the Curaçao jurisdiction as provided by the Curaçao Gaming Control Board, Stake expressly prohibits and rejects the use of Stake products for any form of illicit activity, including money laundering, terrorist financing or trade sanctions violations, consistent with various national anti-money laundering (“AML”) laws, regulations and norms. Stake continues to monitor norm setting parameters promulgated by the Financial Action Task Force (“FATF”) and certain gaming trade groups in addition to the Curaçao Gaming Control Board and will take necessary action as it deems appropriate to reflect changes in law.

Stake’s intention is to follow global best practices in guarding against Stake products being used to facilitate such activities. Those best practices include:

• Adoption of a written policy, and procedures and controls, reasonably designed to guard against money laundering, terrorist financing and trade sanctions violations;
• Where appropriate, designation of a compliance officer to oversee the implementation of the policy, procedures and controls;
• Provision of related education and training to relevant personnel; and
• Independent reviews, monitoring and maintenance of the policy, procedures and controls.

3. Definitions

The following defined terms are widely used in the industry:

Money Laundering: The process of making illegally-gained proceeds appear legal. This process is generally broken down into three steps: placement, layering and integration.

Placement: The process of placing unlawful proceeds into traditional financial institutions, through deposits or other avenues.

Layering: The process of separating proceeds of criminal activity from their origin through the use of layers of complex financial transactions, such as converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds or purchasing assets.

Integration: Using apparently legitimate transactions to disguise the illicit proceeds, allowing the laundered funds to be distributed back to the criminal; integrating the now clean money back into normal use.

Suspicious Activity: Activity conducted by a user or non-user using the institution where there are indications that the persons engaging in the transaction may be doing so for fraudulent or illegal purposes.

Sanctions: Sanctions are activities conducted by the international community to prohibit or constrain activities of the target of the sanctions.For example, they are used:

• To encourage a change in behaviour for a target country or regime;
• To apply pressure on a target country to comply with set objectives;
• As an enforcement tool when international peace and security has been threatened and diplomatic efforts have failed; or
• To prevent and suppress the financing of terrorists or terrorist acts.

4. Governance and Oversight

Stake has appointed a Chief Compliance Officer (“CCO”) that is responsible for coordinating the implementation of the AML Policy and policy program. The Chief Compliance Officer’s duties also include developing AML initiatives, work with other stakeholders to revising the AML policy, assessing new regulatory requirements and investigate potentially suspicious or unusual activity. Stake also provides AML training to all of its employees on a regular basis.

5. Know Your Customer and Transaction Monitoring

Stake will apply appropriate user due diligence and ongoing monitoring measures required by law. Stake will endeavour to prevent users from engaging in illicit or otherwise unauthorised activity. Stake uses a combination of its software development and other service agreements, which are enforced through internal operational features to ensure that it complies with the applicable law.

Know Your Customer

A. Customer Due Diligence.

Stake has adopted a risk based CDD to enable Stake to understand the nature and purpose of the user relationship to the Stake platform in order to develop a customer risk profile. In order to do so, Stake collects certain documentary and non-documentary information at account-opening commensurate with the nature of the type account and services that Stake offers. Stake maintains different CDD for different accounts and services.

For instance, the CDD requires users go through Stake’s customer identification program (“CIP”). The CIP consists of procedures for:

• Collecting baseline (e.g., wallet address, email address) information at account creation through Stake’s user onboarding portal;
• Monitoring the risk profile associated with the underlying cryptocurrency wallet used to fund the user’s account;
• Maintaining records of the information used to identify the user; and
• Determining if a user appears on any list of known or suspected terrorists or terrorist organisations provided to the financial institutions based on the above information.

The above steps are operationalised using the following measures:

• Identity and Age Verification. A third-party service provider will support’s Stake’s ability to determine the legitimacy of the identification information other KYC materials or information provided and will confirm that the user is permissible. The service provider also will confirm that the user does not appear to be located in a comprehensively-sanctioned or otherwise prohibited jurisdiction and will search global sanctions lists to confirm that the user does not appear thereon using onboarding information such as wallet addresses.
• Customer Information. Stake will collect details on each user to form a reasonable belief that Stake knows the identity of its users commensurate with the user’s risk profile. For instance, Stake may collect such details as the wallet address, name, address, country, date of birth, or postal code (collectively, “KYC Information”). Stake will collect any of the above KYC Information prior to issuing a Stake funding address (e.g., QR code) to users. Stake does not presently allow users who are non-natural persons.Stake may, at its own description rely on the performance by another institution of some or all of the elements of our CIP.
• Geo-blocking for Prohibited Jurisdictions. Stake will require contractual client certifications that, through IP address-based geo-blocking, no gaming services will be offered in countries where such activity is not permitted.
• Geo-blocking for Sanctioned Jurisdictions. Stake also will require contractual client certifications that such users are not subject to United States, European Union, or other global sanctions or watch lists, including individuals or entities associated with the United States’ comprehensively sanctioned jurisdictions, Iran, Cuba, North Korea, Syria and the Crimean region of Ukraine. Stake will rely on various risk-based measures to verify these representations including as in the below-described know-your-user (“KYC”) measures and through IP address-based geo-blocking.
• Contractual Prohibitions on Users Onboarding from Prohibited Jurisdictions. Users are notified at onboarding that Stake does not offer services in restricted jurisdictions. Stake’s policy on restricting user activity stems from a combination of its risk, fraud prevention, and AML standards, as well as any assessments associated with the permissibility of its services in certain jurisdictions.

B. Enhanced Due Diligence and Ongoing Monitoring

Stake performs ongoing monitoring on its users in order to detect any behaviours or indicators that might raise suspicions in regard to money laundering and terrorism financing practices. For that purpose, Stake has implemented a set of red flag indicators that help it determine such behaviours and require further action from Stake in assessing the customer information.

Whenever one of those red flags is triggered, the user account will be suspended and Stake will pursue enhanced due diligence. Enhanced KYC diligence under this policy is deemed to include, but not limit to, the provision of:

• Full legal name;
• Country of citizenship;
• Permanent Address (which, for an individual, must be a residential or business street address, and for an entity, must be a principal place of business, local office or other physical location);
• Identification number (either a taxpayer identification number, or, if unavailable, a passport number and country of issuance, 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);
• Identification Document; and
• Source of Funds and Source of Wealth.

Stake may use third party service provider to verify any of the above information as determined to establish a reasonable basis to know the true identity of the user where the user’s activity warrants such action.

C. Acceptance Policy

Stake will not accept a and will block the users that:

• Do not provide the identification information requested by Stake;
• Provide fake identification documents;
• Try to use different means to deceive about their location;
• Are from restricted or prohibited jurisdictions; or
• Are subjected to United States, European Union, or other global sanctions or watch lists;
• Are gambling addicted or have mental health issues;
• Its source of funds are originated or exchanges in restricted jurisdictions;

Stake reserves the right to block and suspend player for any other reasons at its own description

Transactions Monitoring

Stake is firmly committed to complying with economic and trade sanctions programs imposed by jurisdictions in which the firm conducts business. For that purpose Stake established a transaction monitoring program with controls and processes to identify and detect any unusual activity in real time and in its ongoing monitoring.

Stake will conduct ongoing monitoring on a regular basis using rule-based systems developed in-house and others from third-party vendors to review user history and patterns of activity to detect and report any unusual activity as required and to develop and implement any additional controls or limits in its platform.

Stake implemented procedures addressing the following two key components of unusual or suspicious activity management:

• identification of unusual activity through methods of identification may include employee and customer identification, law enforcement inquiries, other referrals, or transaction and surveillance monitoring system reports; and
• alert management that focuses on processes used to investigate, evaluate and document identified unusual or potentially suspicious activity.

Stake will use the following processes to achieve both goals:

• Transaction Monitoring for Sanctioned or Prohibited Jurisdictions. Stake may in its reasonable discretion impose certain due diligence requests at user balance withdrawal. Stake presently conducts a mixture of manual and automated transaction monitoring processes to identify “red flag” behaviour. Where such red flag behaviour is identified, Stake may refuse to process any withdrawal attempts or collect additional information from the recipient. Stake will further endeavour to limit any attempted user account funding from prohibited jurisdictions (which are identified in the Stake user facing disclosures and updated from time to time internally) where the associated wallet address indicates that the user or the user’s funds are located in such a prohibited jurisdiction. For instance, Stake may prohibit a user from funding their Stake account using a known U.S. based exchange wallet as such assets indicate that the user is a U.S. person. Users will have the ability to rebut any suspension with additional information as part of Stake’s ongoing transaction monitoring and user due diligence standards.
• Screening for Sanctioned Parties. Prior to issuing a Stake funding address to a user, Stake will screen a user’s wallet address against applicable sanctions databases. Such screening measures will rely on third party blockchain forensics vendors such as Chainalysis. Stake will periodically re-screen wallet addresses against such databases.
• Identification of Unusual Activity. Stake will monitor account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to its business. Monitoring will be conducted running regular reports of unusual, high risk, or suspicious user activity.
• Anti-Mixing Measures.Stake will utilise software designed to detect other suspicious deposit or withdrawal patterns. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform.
• Chainalysis Review. Every single crypto deposit or withdrawal both indirect and direct will run through Chainalysis and reviewed for signs of fraud or suspicious behaviour. A user’s account will be suspended and reviewed upon alert of potential illicit behaviour. Sufficient proof of wealth may be requested from high-risk accounts. Stake may refuse to withdraw to certain “high-risk” addresses as determined in consultation with Chainalysis risk scoring.
• Withdrawal Threshold KYC. Additionally, and independently, every account, wherever or with whomever associated, will be suspended until adequate KYC diligence occurs once that account reaches a withdrawal threshold dependent on the accounts risk characterisation over the life of the account.

D. Other Ongoing Monitoring Controls

Additionally to the above mentioned controlling procedures, Stake has also implemented the following procedures to complement its know your customer and ongoing monitoring procedures:

• Ban Evasion Detection. In addition, Stake will utilise third-party service provider software designed to detect the use by one user of multiple accounts. This software relies on detection of links between the same devices used to access multiple accounts. Such instances will be dealt with on a case-by-case basis, depending on the perceived level of risk. In such instances, a user may be required to explain their methodology and purpose for using the platform. Stake accounts are funded by users using local (non-custodial) or hosted (custodial) wallets. In addition to a Chainalysis screening, Stake monitors user activity within the Stake platform and any withdrawals must meet Stake’s and its third-party service provider’s verification processes. Stake further prohibits peer-to-peer account transfers within the Stake platform infrastructure. Any attempts to circumvent this restriction will be treated as a red flag.
• Time Zone Monitoring. Stake has implemented time zone controls that detects the users device information and crosses it with restricted jurisdiction to understand if they are trying to use geo location software to hide the jurisdictions where they are connecting from.
• Products and Services Review. Stake will establish additional procedures to avoid facilitating user attempts to exploit the Stake platform. Stake has a robust set of user-facing terms that users attest to in order to utilise the Stake platform. Stake will establish certain additional safeguards to mitigate against the risk of such misuse. For instance, Stake may establish policies or procedures for limiting which user assets can be onboarded to the Stake platform. Stake lists the assets that are available for use on the Stake platform. Stake does not allow the use of anonymity enhancing technologies such as mixers, tumblers, or certain coins and tokens. Where Stake becomes aware that an anonymity enhancing technology is being used on the Stake platform, Stake will disallow such use.
• Vendor Management. Stake works with reputable third-party service providers as part of its compliance infrastructure. Stake will periodically assess the strength of its key third party service providers to determine if additional services are needed, the third-party service provider is not performing consistent with its contractual obligations, or if other remedial action is necessary for Stake to comply with this policy. Stake may request information from any third-party service provider as part of its vendor review process.
• Compliance Innovation. In addition to vendor management, Stake will continuously monitor any non documentary compliance mechanisms to determine their viability for the Stake program. Stake may run test or trial programs on a limited basis with such compliance vendors to determine the effectiveness of such programs. Blockchain native compliance tools include fraud prevention services, on-chain KYC providers, and other tools designed to reflect the technological features associated with blockchain platforms.

6. Education and Training

Stake, with the assistance of its legal counsel and under the oversight of its CCO, may provide employees AML, anti-terrorist financing and trade sanctions compliance training on a periodic basis, as deemed appropriate.

7. Reporting

Stake is obliged to report any unusual or suspicious transactions, in accordance with the National Ordinance. Customers that are identified as being on a sanctions list, linked to money laundering or terrorism financing or other criminal activities will be reported as suspicious activity to the regulator.

4. Privacy Policy

This is the privacy policy of Medium Rare N.V. (owner and operator of Stake.) This Privacy Policy sets out how Stake.com will manage your personal information which we collect as a result of your membership of Stake, your use of our websites located at https://stake.com and any pages or websites under the ‘Stake’ brand including any mobile phone or tablet applications that are owned and/or operated by us or whenever we otherwise deal with you. We are committed to ensuring that the personal information we collect about you is protected and is used, stored and disclosed in accordance with the Privacy Act and this Privacy Policy.

1. Website Use

In using the website, you agree to be bound by the terms of this Privacy Policy. Stake.com may review the Privacy Policy periodically and reserves the right to change the Privacy Policy at any time at its discretion by posting such changes on the website. Changes will be effective immediately when posted on the website. Your continued use of the website following posting will constitute your acceptance of those changes. This Privacy Policy will not apply to websites which are linked to the website and over which Stake.com has no control.

2. Personal Information

The kinds of Personal Information that Stake.com may collect from you is:

• Name
• Email Address
• Personally Submitted Preferences
• Date of Birth
• Country of Citizenship
• Physical Address
• Identification Number
• Government Issued Identification
• Location Data
• Device Information
• IP Address

The Company collects, or may collect, such information through methods including:

• Data input during account registration processes
• Communications with Customers

3. Collection Purposes

Stake.com will collect your Personal Information only by lawful and fair means and not in an intrusive way to operate its business as a licensed online wagering bookmaker for the following purposes:

• For know-your-customer (KYC) identity verification.
• If you wish to subscribe to Stake.com’s marketing communications.
• To process your application to become a Member of Stake.com or any managed subdomains.
• To provide and improve services to you as a Member.
• To identify you as a Member and authenticate your identity for security purposes and to comply with our legal obligations.
• To maintain your Member account.
• To upgrade and enhance your experience within the website or over the telephone, or to tailor or develop information, services or products to suit your needs which may include market research and conducting promotions.
• To tell you about our products or services that we think may be of interest to you by communicating with you via email, SMS or telephone.
• To create aggregate data about Members through demographic profiling, statistical analysis of the database to provide to potential and existing stakeholders, and to allow for more efficient operation of Stake.com’s business.
• To respond to your questions, comments, or requests.
• To determine Members’ liability to pay goods and services tax and other taxes where applicable.
• To comply with Stake.com’s contractual, legal, and statutory obligations.
• For taking appropriate action if Stake.com has reason to suspect that unlawful activity or misconduct of a serious nature has been, is being or may be engaged in that relates to our functions and activities.
• To establish, exercise or defend any legal claims.
• To manage job applications.

If you do not provide Stake.com with the Personal Information we request, we may be unable to process your application to become a Member, provide you with our services or respond to your enquiry or complaint.

By using Stake.com, becoming a Member or otherwise choosing to provide Stake.com with Personal Information you consent to Stake.com collecting, using, processing and potentially disclosing your Personal Information for the above purposes and on the bases described in this Privacy Policy.

4. Direct Marketing and Opting Out

From time to time we may use your Personal Information to inform you about our products or services or about promotional activities which Stake.com believes may be of interest or of benefit to you. We may do this via email, SMS, telephone or mail. If you no longer wish to receive marketing or promotional material from Stake.com at all or in any particular form, you may contact us at any time by email to [email protected] with your request with which we will comply as soon as is practical.

From time to time we may contact you in relation to the management and administration of your Stake.com account. These communications can be via any of the modes of contact recorded when registering as a Member. Such communication does not affect your opt-in or opt-out status for direct marketing communications.

5. Management of your Personal Information

Stake.com will take all reasonable steps to ensure that the Personal Information which it collects, uses or discloses is correct and is stored in a secure environment which is accessed only by authorised persons. We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Stake.com will destroy or permanently de-identify the Personal Information we hold when it is no longer required for any purpose permitted under the APPs including our legal or operational obligations.

6. Security of Personal Information

You acknowledge that no data transmission over the Internet is totally secure. Accordingly, Stake.com does not guarantee or warrant the security of any information which you transmit to it. Any information which you transmit to Stake.com is transmitted at your own risk. However, once Stake.com receives your transmission, Stake.com will take reasonable steps to protect your Personal Information from misuse, loss and unauthorized access, modification and disclosure including by using password protected systems and databases and Secure Socket Layer (SSL) technology. By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.

Stake.com’s employees, agents and contractors are required to maintain the confidentiality of Members’ Personal Information and trading behavior. Information posted on bulletin boards or communicated within a social media environment (for example, Facebook, Twitter, Chat Rooms) becomes public information. Stake.com cannot guarantee the security of this type of disclosed information.

We take seriously the responsibility to exclude children from access to our services. We will not accept their information for the purposes of opening a wagering account. It is however, ultimately the responsibility of parents or guardians to monitor their children’s Internet activities including where appropriate by using Internet screening software.

Remember to always log out of your account when you have completed your time on the website. This is particularly important if you share a computer with another person. You are responsible for the security of and access to your own computer, mobile device or any other handset used to access the website.

Ultimately, you are solely responsible for maintaining the secrecy of your username, password and any account information. Please be careful whenever using the Internet and our website.

7. Access to Personal Information

You may access the Personal Information collected by Stake.com by following the “Settings” link on the website or by contacting us on [email protected]. We will give you access to your Personal Information in the manner requested if that is possible and within a reasonable period. If we refuse your request or cannot give you access in the manner you have requested, we will do what we can to meet your requirements by other means. We may not be required to give you access to your Personal Information in certain circumstances which are set out in the APPs including where it may have an unreasonable impact on another individual’s privacy. If we refuse access for such reasons, we will advise you in writing of the refusal and our reasons and the complaint mechanisms available to you.

8. Delete Personal Data

You can request to have your personal data deleted if Stake.com no longer have a legal reason to continue to process or store it. Please note that this right is not guaranteed – in the sense that Stake.com do not have the ability to comply with your request if it is subject to a legal obligation to store your data. You can request the deletion of your personal data by sending an email to [email protected].

9. Contact Details

If you have any queries, requests for access or correction or complaints relating to the handling of your personal information, please contact us by email at [email protected] or by the site customer support chat function.

10. International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

11. Legal Basis for Processing

For purposes of the EU General Data Protection Regulation, Stake.com’s processing of your personal information is supported by the following lawful bases:

• Performance of a Contract: Stake.com needs to process your personal information to perform our contract with you or our Customer.
• Legitimate Interest: Stake.com processes your personal information to further our legitimate interests but only where our interests are not overridden by your interests or fundamental rights and freedoms.
• Consent: In some cases, Stake.com also relies on your consent to process your personal information.
• Compliance with Legal Obligations: Stake.com may process your personal information to comply with our legal obligations.

12. Supervisor Authority

If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

13. Updates to this Privacy Policy

As noted, Stake.com may review, change and update this Privacy Policy from time to time reflect our current practices and obligations. We will publish our current Privacy Policy on our website at https://stake.com and the changes will take effect at the time of publishing. You should review this privacy policy regularly and remain familiar with its terms.