Player Complaints Policy

Version 2.0 · Effective 1 June 2026 · CGA Licence OGL/2024/139/0125

Our Commitment

At Trickless N.V., we are committed to providing a fair and transparent gaming experience. This policy sets out the structured process we follow to receive, handle, and resolve player complaints in accordance with the Curaçao Gaming Authority (CGA) Player Complaints Policy Guideline and the Landsverordening op de kansspelen (LOK).

1. Your Right to Complain

You have the right to make a complaint regarding any part of your relationship with the Company, or any incident related to your participation in a game of chance. This includes, but is not limited to:

• Deposit or withdrawal issues
• Bonus terms and conditions
• Account closures or restrictions
• Alleged errors or unfairness in game outcomes
• Responsible gaming issues
• Treatment of player balances
• KYC and verification
• Data protection
• Technical or software issues
• AML concerns
• Issues involving minors
• Fraudulent games or practices
• Licence or regulation concerns
• Unfair terms and conditions

Only you, as the registered player, may lodge a complaint. In accordance with Article 1.3(c) of the LOK, you may not sell, donate, rent out, lease, pawn, or pledge any of your claims against the Company. Complaints submitted on behalf of a player by a third party will not be accepted, except where the third party is a legally authorised representative.

2. When and How to Submit a Complaint

Time Limit

You may lodge a complaint free of charge at any time up to six (6) months of the settlement of the bet or the incident giving rise to the complaint.

• Peer-to-peer (P2P) and ante-post fixed odds betting: the six-month period begins after the bet settlement or conclusion of the specific event, not the date the wager was placed.
• In-running (live) sports betting: you may still submit a complaint within six months. However, prompt action is strongly advised, as investigation may depend on time-sensitive data.

How to Submit

Complaints can be raised via email: [email protected]. Your complaint should include at minimum:

• Your name, address, and place of residence
• Your account number (if applicable)
• Date of the complaint and date of the disputed event
• Description of the conduct being disputed, using predetermined category topics where applicable

The Company may request reasonable supporting documentation. Any such request will be limited to what is reasonably necessary in the context of the complaint.

3. How We Handle Your Complaint

The process and timeline applied to your complaint depends on whether it relates to responsible gaming or to any other matter.

3.1 Responsible Gaming-Related Complaints (Priority Track)

Complaints are categorised as responsible gaming-related whenever they concern the targeting of Vulnerable Players, or the availability or timely implementation of self-exclusion or cooling-off and their mandated consequences. These complaints are prioritised due to their potential impact on player well-being.

1. Within 2 days of receiving the complaint, we will confirm receipt in writing, explain how the complaint will be processed, and provide notice of the average resolution timeline.
2. Resolution target: we will use our best efforts to resolve responsible gaming complaints within 5 business days from the day of confirmation.
3. Extension: if more time is needed, you will be informed of the delay, which will not exceed a further 2 weeks. Where a delay results from slow response from you, the resolution period may be extended by no more than an additional 2 weeks.

3.2 All Other Complaints

1. Within 1 week of receiving the complaint, we will confirm receipt in writing, explain how the complaint will be processed, and provide notice of the average resolution timeline.
2. Resolution target: we will assess and respond to your complaint within 4 weeks.
3. Extension: if necessary due to complexity or lack of information, this period may be extended once by an additional 4 weeks, with prior written notice to you.

3.3 Use of AI in Complaint Handling

The Company may use AI tools to support the complaints process, subject to the following safeguards:

1. Once a complaint is identified as responsible gaming-related, all communication with you will be conducted by a human, not AI.
2. Complaints that can reasonably be considered complex will be handled by a human, not AI.
3. AI-assisted records are monitored to ensure recommendations are reasonable and consistent across players with like-for-like complaints.

4. Final Determination

You will always receive the final determination of your complaint in writing. This response will be one of the following:

1. A reasoned final assessment of the outcome or resolution of your complaint, with supporting evidence where necessary or applicable.
2. Detailed reasons for not handling the complaint. If additional information is reasonably required, we will request it within the initial response period. If you do not provide it within that period, the complaint may be rejected.
3. If you remain unsatisfied and raise a further complaint to that effect, you will be informed of your right to escalate the matter to an independent ADR entity.

5. Escalation and Alternative Dispute Resolution (ADR)

As a condition of our CGA licence under the LOK, the Company provides independent Alternative Dispute Resolution (ADR) services to players, free of charge — the Company bears all costs of the ADR process. Full details of our ADR process and provider are published in our Terms and Conditions.

• Escalating to ADR: If your complaint cannot be resolved internally, you are entitled to escalate it to our ADR provider, free of charge, after receiving our Final Response, or if we fail to issue one within the applicable timeframe.
• One attempt only: Once an ADR process has been completed, it cannot be recommenced by you or the Company with a different ADR entity.
• Dropped processes: If you withdraw from an ADR process that has already begun, you will not have the right to resurface that dispute at a later date.
• Your right to legal action: Except where mutually agreed under the specific terms of ADR, the Company will not restrict your right to take legal action.

6. The Role of the Curaçao Gaming Authority (CGA)

The CGA supervises the Company's gaming licence (OGL/2024/139/0125). Please note:

1. The CGA will not resolve or make decisions on individual player complaints regarding gambling-related transactions on the Company's website(s).
2. Unless deemed to be inadequately handled, decisions made by the Company and/or its ADR provider will not be subject to review or being overturned by the CGA.
3. Notwithstanding the above, the Company will not restrict your ability to contact the CGA directly regarding matters including malpractice, breach of licence conditions, or whistleblowing.
4. While the CGA does not mediate in individual disputes, it uses complaint information to support its supervisory and enforcement actions.

You may submit a complaint or concern directly to the CGA via the CGA Portal at www.gaming-curacao.com.

7. Our Reporting Obligations to the CGA

The Company submits reports to the CGA on 15 January and 15 June each year, covering complaints submitted since the previous reporting period (first reports due January 2026). Each report summarises:

• Total number of complaints made
• Total number of settled complaints (upheld and rejected)
• Number of pending or unresolved complaints
• Number of complaints by category
• Number of complaints referred to ADR
• Number and detail of complaints for which a player has taken legal action

The Company ensures transparency and compliance with ADR decisions and regulatory updates. Our ADR provider maintains its own reporting requirements in accordance with the Alternative Dispute Resolution policy issued by the CGA.

8. Record Keeping

We maintain a complete log of all complaints received, including the date of receipt, nature of the complaint, all correspondence, stage reached, and outcome. Records of unresolved complaints, and complaints escalated to ADR or legal proceedings, are retained for the lesser of five (5) years or the relevant period stipulated by data protection law, statute of limitations, or other applicable laws or guidelines.

The CGA reserves the right to request access, at any time, to records of complaints received and any disputes pending resolution; such records are always kept readily available.

9. Confidentiality and Fair Treatment

We treat all complaints with strict confidentiality and handle your personal data in accordance with our Privacy Policy and applicable data protection legislation. Trickless N.V. will not discriminate against, penalise, or disadvantage any player for having submitted a complaint in good faith.

This policy is reviewed annually, or upon material changes to CGA licence conditions or the Landsverordening op de kansspelen (LOK).

Contact Us

• Complaints: [email protected]
• Compliance: [email protected]
• CGA Portal: www.gaming-curacao.com

Trickless N.V.
Zuikertuintjeweg Z/N, Curaçao
Licence No. OGL/2024/139/0125 — Curaçao Gaming Authority
[email protected]

Last reviewed: June 2026 · Version 2.0 · This policy is subject to change in line with applicable regulations.