Estonia's newest EMTA-licensed sportsbook

1. Introduction and general terms

1.1. Agreement: These terms of use (the "Terms") govern the contractual relationship between the user (hereinafter the "Player", "User" or "You") and Luckybet.ee SIA (hereinafter the "Operator", "we"). By creating an account and/or using the gambling services, you confirm that you have read, understood and agreed to these Terms, the privacy terms and the rules of the specific games.

1.2. Applicable law and jurisdiction: These Terms are governed by the law of the Republic of Latvia. All claims or disputes relating to these Terms or to the services provided by the Operator fall within the competence of the Latvian courts.

1.3. Estonian licence: The Operator holds an activity licence and an operating licence issued by the Estonian Tax and Customs Board (EMTA), which grant the right to organise remote gambling. The Operator acts in full compliance with the Gambling Act and the Money Laundering and Terrorist Financing Prevention Act.

1.4. Player eligibility:

• The User must be at least 21 (twenty-one) years of age to participate in games of chance.
• The User must be at least 18 (eighteen) years of age to participate in toto, i.e. sports betting.
• The User must have the legal capacity to enter into a binding agreement.
• The User must not be entered in the Estonian register of persons with a gambling restriction (HAMPI) and must not be under a valid self-exclusion, whether imposed by the Operator, another gambling operator or through a national self-exclusion system.

2. Acceptance of the Terms and their amendment

2.1. Player confirmation and obligations: By completing the registration process and/or accessing the website, the Player unambiguously confirms that:

• The Player has fully read, understood and agreed to these Terms.
• The Player agrees to comply with and is bound by these Terms, the privacy terms and all applicable game rules and internal regulations.
• The Player understands that a breach of these Terms may result in the suspension or closure of the Player's account and the confiscation of winnings.

2.2. Right to amend the Terms: The Operator reserves the right to amend, supplement, update or otherwise adjust these Terms at any time for commercial, legal or regulatory reasons, including to comply with the requirements of the Estonian Tax and Customs Board or in connection with changes to the Gambling Act.

2.3. Notification of changes: The Operator notifies Players of material changes to the Terms by publishing the updated version of the Terms on the website. In the case of material changes that significantly affect the Player's rights or obligations, the Operator endeavours to notify the Player before the changes take effect, by email or through a notice published on the website.

2.4. Player's obligation to review the Terms: It is the Player's sole responsibility to review the Terms periodically, and in particular before each gaming session or login, in order to be aware of the current version of the Terms.

2.5. Binding effect: All amendments to the Terms take effect immediately upon their publication on the website. Continued use of the services after the publication of the updated Terms constitutes the Player's express confirmation of and agreement to the amended Terms. If the Player does not agree to the changes, their sole remedy is to cease using the services and close their account.

3. Account management

3.1. Player participation in games

The Player may begin gambling as follows:

• 3.1.1. Registers and completes KYC identification: via Smart-ID, Mobiil-ID, bank link or, where necessary, by manual identification (Section 4).
• 3.1.2. After identity verification, the Player can log in to their account.
• 3.1.3. The system checks the Player against the HAMPI list.
• 3.1.4. The Player makes a deposit using any available payment method.
• 3.1.5. After the funds are received, the Player may choose any available casino or sports betting product.
• 3.1.6. The Player selects a game, sets the bet and participates in accordance with the rules of the specific game.

3.2. Registration and account creation

3.2.1. One-account principle: The Player is permitted to register and use only one (1) account with the Operator. If the Operator discovers that the Player holds multiple accounts, the Operator reserves the right to suspend or close all duplicate accounts and to treat the funds on those accounts as void.

3.2.2. Provision of data: The Player confirms and warrants that all data provided upon registration and throughout the validity of the account is true, complete, accurate and up to date. This includes, among other things, the Player's full name, personal identification code (or an equivalent identifier), residential address, date of birth, email address and contact details.

3.2.3. Updating data: The Player must notify the Operator without delay and update their account data if changes occur in the personal data provided. Failure to comply with this requirement may result in the temporary suspension of the account. The real-money balance on the account is refunded to the Player in accordance with Section 5 (Deposits and withdrawals). The Operator reserves the right to temporarily suspend withdrawals until the required data is updated, especially where outdated data prevents mandatory KYC/AML checks.

3.2.4. Refusal to open an account: The Operator reserves the right to refuse to open an account or to close an existing account at its own discretion, provided that this right is not exercised in a discriminatory manner. At the Player's request, the Operator is obliged to provide the reasons for refusing to open the account or closing the account. All contractual obligations already incurred are fulfilled in accordance with these Terms and applicable legislation.

3.3. Account security

3.3.1. Confidentiality: The Player is solely responsible for the confidentiality and security of their account data, including the username, the identity verification tool (e.g. Smart-ID, Mobiil-ID) and the password. The Player must not disclose this data to any third party.

3.3.2. Responsibility for account activity: The Player is fully responsible for all activities, transactions and consequences that occur through their account, regardless of whether the activity was authorised by the Player or not. Any unauthorised use of the account is at the Player's own risk, and the Operator is not liable for losses arising from such use.

3.3.3. Notification of security breaches: The Player is obliged to notify the Operator without delay if they suspect unauthorised use of their account or any other security breach.

3.3.4. Account inactivity: If an account has been inactive for 12 (twelve) consecutive months (i.e. no deposits, withdrawals or bets), it is deemed an inactive account. The Operator reserves the right to apply an administration fee of 10 euros per month to inactive accounts or to close them, provided that the Player has been appropriately notified in advance and the action complies with Estonian regulatory requirements. If the Player's account balance reaches zero, the administration fee is no longer charged and the account is closed.

3.4. Permitted username policy

3.4.1. Prohibited content: When registering an account, the Player agrees not to choose a username that the Operator, at its sole discretion, considers to be:

• offensive, vulgar or obscene;
• defamatory, abusive or hostile;
• racially, ethnically or religiously inappropriate;
• politically sensitive or provocative;
• promoting unlawful activities or violence;
• misleading or impersonating another user or an employee of the Operator.

3.4.2. Enforcement and sanctions: The Operator reserves the right to review and take measures against any username that breaches this policy, regardless of whether the breach is detected by the Operator or reported through another Player's complaint. Upon confirmation of a breach, the Operator may, at its discretion:

• issue the Player an official warning;
• require the immediate change of the username;
• suspend or permanently close the Player's account and confiscate the associated winnings, in particular in the case of serious or repeated breaches.

3.5. Account closure by the Player

3.5.1. Right to close the account: The Player has the right to close their account at any time. The account closure request must be submitted to the Operator's customer support by email from the Player's registered email address or via the account closure function provided for this purpose on the website.

3.5.2. Processing: The Operator processes the account closure request and confirms the account closure within a reasonable time, but no later than within 5 business days. After the closure request is confirmed, the Player can no longer access the account.

3.5.3. Settlement of funds: Upon receipt of a valid account closure request, the Operator refunds the Player the real-money balance on the account, provided that:

• all funds have been received and released;
• all mandatory KYC/AML procedures (Section 4) have been successfully completed;
• all bonus funds and related pending winnings are forfeited, unless otherwise provided by the specific bonus terms.

3.5.4. Difference from self-exclusion: Closing an account under this Section 3.5 differs from voluntary self-exclusion (Section 9.8). If the Player wishes to close the account due to concerns about their gambling behaviour, it is strongly recommended to initiate official self-exclusion in order to prevent the reopening of the account or the registration of new accounts.

3.6. Refusal to establish a customer relationship, account suspension and closure by the Operator

3.6.1. The Operator's right: The Operator reserves the right to refuse registration, suspend, restrict or permanently close the Player's account at its sole discretion, provided that such decisions are not made in a discriminatory manner, and to notify the Player of the relevant action, except where prohibited by law or a specific regulatory instruction.

3.6.2. Grounds for refusal, suspension or closure: The Operator may exercise the said right, among other things, in the following cases:

• Breach of the Terms: the Player breaches these Terms (e.g. holding multiple accounts, failing to update data).
• Breach of KYC/AML requirements: the Player fails to submit the required supporting documents (Section 4) in a timely manner, or the data provided is false, forged or unverifiable.
• Fraud and unfair play: the Operator has reasonable grounds to believe, or has specific evidence, that the Player is involved in Prohibited Activities, Fraud or unfair play (Section 12), including collusion, money laundering or the use of external aids.
• Regulatory requirement: the closure of the account is required by law, a state authority or a supervisory body (e.g. the Estonian Tax and Customs Board or the Financial Intelligence Unit).
• Security risk: the use of the account jeopardises the security of the service, the integrity of the games or the Operator's financial stability.
• Inactivity: the account has been deemed an inactive account (Section 3.3.4) and the Operator decides to close it.

3.6.3. Consequences: If the Operator closes an account due to a breach of these Terms, in particular in connection with fraud, unfair play or a breach of AML requirements (Section 12), the Operator reserves the right to confiscate the related winnings and withhold the deposits associated with the breach, and to notify the relevant authorities.

3.6.4. Funds upon account closure: If the Operator closes an account for administrative or security reasons unrelated to a breach by the Player, the remaining real-money balance is refunded to the Player in accordance with Section 5 (Deposits and withdrawals), provided that the appropriate compliance checks have been passed.

4. Player identification (know your customer – KYC/AML/CTF)

Under the Estonian Money Laundering and Terrorist Financing Prevention Act, the Operator has a legal obligation to identify each Player. Establishing identity is a mandatory precondition for opening an account, making deposits and processing withdrawals.

4.1. Initial identification upon registration

4.1.1. Mandatory data: Upon registration, the Player must provide accurate and complete personal data, including but not limited to: first and last name, personal identification code (Estonian personal code or, for non-residents, an equivalent identifier), date of birth, residential address and a valid email address.

4.1.2. Method of identification: In accordance with Estonian law, remote gambling operators must identify the Player using a reliable method. Identity verification may take place in one of the following ways:

• Mobiil-ID;
• Smart-ID;
• via bank link / internet bank (including, for the Pay and Play solution, by confirming the deposit);
• where necessary, KYC verification carried out manually.

4.2. Enhanced due diligence (EDD) and document verification

4.2.1. Mandatory documentation: The Operator reserves the right, at any time but in particular before processing the first withdrawal or where the total amount of transactions reaches 2,000 euros (or an equivalent amount), to request additional documents to confirm the Player's identity, the origin of funds and the residential address. This requirement is in line with the due diligence measures set out in the Estonian Money Laundering and Terrorist Financing Prevention Act.

4.2.2. Required documents: The required documents may include, among others, the following:

• Identity document: a clear and valid copy of a government-issued photo identity document (e.g. passport, ID card or driving licence).
• Proof of residential address: a copy of a recent utility bill or bank statement (issued within the last three months) showing the Player's name and residential address.
• Proof of payment method ownership: documentation confirming that the payment method used belongs to the Player (e.g. a copy of the front of a credit/debit card showing only the first six and last four digits, or a bank statement showing the account holder's name).

4.2.3. Failure to comply: If the Player fails to submit the required documents in a timely manner, or if the information provided proves to be false, misleading or unverifiable, the Operator reserves the right to suspend or close the Player's account and to suspend the payout of winnings pending further verification of the circumstances.

5. Deposits and withdrawals

5.1. Deposits

All payments must be made from an account belonging to the Player. The Operator does not offer credit or loans for gambling. Deposits can be made via the following payment methods:

• bank link payments;
• card payments (Visa/Mastercard);
• Trustly;
• Zimpler;
• Apple Pay / Google Pay;
• Pay and Play.

5.2. Withdrawal requests

5.2.1. Submitting a request: Withdrawal requests must be submitted via the cashier system on the Operator's website.

5.2.2. Minimum and maximum limits:

• maximum daily withdrawal: three thousand euros;
• maximum weekly withdrawal: fifteen thousand euros;
• maximum monthly withdrawal: fifty thousand euros.

5.3. Compliance requirements and withdrawal conditions

5.3.1. Mandatory withdrawal channel: In accordance with Estonian legislation, the Operator must ensure that withdrawals (winnings) are made only to the same settlement account from which the Player made their deposit(s). Winnings may not be transferred to a third party's account.

5.3.2. Account verification: Withdrawal requests are subject to the Player identity verification (KYC) procedure in accordance with Section 4. The submission of identity verification documents is mandatory before the first withdrawal where the total amount of transactions reaches 2,000 euros, or at any other time at the Operator's discretion, in order to ensure compliance with anti-money-laundering rules.

5.3.3. Wagering requirements: If a withdrawal request is connected to bonus funds, all applicable wagering requirements and bonus conditions must be met before the withdrawal is processed.

5.3.4. AML checks: All transactions are subject to internal anti-money-laundering (AML) checks. If a transaction is considered suspicious, the Operator is legally obliged to report it to the Estonian Financial Intelligence Unit (RAB) and may suspend the withdrawal until the circumstances are clarified.

5.4. Processing times

5.4.1. Internal processing: The Operator makes reasonable efforts to process withdrawal requests within up to 5 (five) business days from the submission of the withdrawal request, except where additional identification and/or AML verification is required under these Terms or applicable law. This is subject to the Player's account not being under an ongoing investigation in connection with a breach of the Terms and all suspicions of fraud, unlawful or criminal activity having been resolved.

5.4.2. Third-party delays: Processing times may vary depending on the chosen withdrawal method and the internal procedures of the receiving bank or payment institution. The Operator is not liable for delays that occur in third-party payment systems.

6. General rules for casino games

6.1. The Operator offers games provided by certified software suppliers. The game rules are established by the game service provider and are available on the website within the relevant game before participating in the game (before placing a bet). By placing a bet, the Player confirms that they have read and approved the rules of the specific game.

6.2. The Operator reserves the right to amend, supplement, update or otherwise adjust the game rules at any time at its discretion. It is the Player's responsibility to review the current version of the game rules offered by the Operator before placing any bet.

6.3. The following information is displayed for each game:

• RTP (return-to-player percentage);
• game rules;
• payout tables;
• explanations of bonus rounds.

6.4. The randomness of game results is determined using certified random number generators (RNG – Random Number Generator).

6.5. The amount displayed in games with a progressive jackpot is an approximate visual indicator. The jackpot actually paid out is the amount registered on the game provider's server at the moment of winning.

6.6. The maximum win per single spin or game round in non-jackpot games is One hundred thousand euros, unless otherwise provided in the rules of the specific game.

6.7. In the event of display errors, only the results stored in the game provider's database are deemed valid.

6.8. If there is a suspicion of manipulation, technical failure or malicious interference, the Operator may suspend withdrawals until the investigation is completed.

7. General rules for sports betting (toto)

7.1. The sports betting terms form an integral part of these Terms. By agreeing to these Terms, the Player confirms that they are solely responsible for reviewing the sports betting rules before participating in sports betting.

7.2. The Operator reserves the right to amend, supplement, update or otherwise adjust the sports betting rules at any time at its discretion. It is the Player's responsibility to review the current version of the sports betting rules before participating in toto bets.

7.3. The detailed sports betting rules are available on the page of each event and comply with the result settlement principles commonly used in the gambling industry.

8. Bonuses

8.1. General principles and acceptance

8.1.1. Special conditions prevail: All bonus offers (including deposit bonuses, free spins and cashback) are subject to these general rules and to the specific bonus terms established for each individual campaign. In the event of a conflict, the specific bonus terms prevail.

8.1.2. Acceptance: By participating in any campaign or accepting a bonus, the User is deemed to have fully and unconditionally agreed to these general bonus terms.

8.1.3. Eligibility and restrictions: All bonus offers and/or campaigns are limited to one per person. Each of the Operator's bonus offers is valid only once per Player account, household, IP address (including shared computers, e.g. libraries or public internet points), email address, telephone number and payment account number, unless expressly provided otherwise in the specific bonus terms. If the Operator has reasonable grounds to suspect that a bonus or offer is being claimed more than once for the benefit of the same person or by a group of persons, the Operator has the right, in respect of the relevant customer or group of customers, to cancel the offer or all offers and/or to void the bets funded by the bonus or offer and remove the winnings obtained from those bets.

8.1.4. Changes and cancellation: The company reserves the right to amend, suspend or cancel any bonus offer or these general bonus terms at any time, including but not limited to in order to comply with legal requirements, due to regulatory obligations or in the event of a suspected breach of the rules.

8.2. Wagering requirements and locked funds

8.2.1. Wagering requirement: All deposit bonuses must be wagered at least 35 times before the winnings obtained from them can be withdrawn. Welcome bonuses must be wagered at least 35 times before the winnings obtained from them can be withdrawn.

8.2.2. Locked funds: Until the wagering requirements are fully met, the original deposit funds associated with the bonus and any possible winnings arising from them remain locked on the account and are not available for withdrawal.

8.2.3. Real money first: When a bonus is active, bets are always deducted first from the Player's real-money balance and only then from the bonus funds. Any attempt to abuse or circumvent this order (e.g. using real money only for low-risk sports bets and bonus funds for high-volatility casino games) is considered bonus abuse.

8.2.4. Effect of withdrawal: Submitting a withdrawal request for the deposit amount before the wagering requirements are met results in the immediate forfeiture of the active bonus and all associated winnings.

8.3. Game contribution and maximum bet

8.3.1. Slot game contribution: Bets placed on slot games count 100% towards meeting the bonus wagering requirements (except for the games listed below). Unless otherwise stated, sports bets with odds of at least 2.00 also count towards meeting the wagering requirement. Table games, crash games and live-dealer games do NOT count towards meeting the bonus wagering requirements.

8.3.2. Excluded games: Andar Bahar (Pragmatic Play), Live Casino.

8.3.3. Maximum bet rule: While an active bonus is in use, the permitted maximum bet is 5 euros, unless otherwise provided in the specific bonus terms. This includes all purchasable game features (e.g. respins or bonus rounds). Exceeding this limit gives the Operator the right to cancel the bonus and void all associated winnings.

8.4. Activation, validity period and winnings limits

8.4.1. Minimum deposit: A deposit of at least 10 euros is required to receive any deposit bonus.

8.4.2. Bonus activation: To activate a bonus, the Player must actively select the bonus or enter the bonus code upon registration or when making a deposit, in accordance with the instructions. If the deposit bonus is not activated, the Player must contact customer support before placing bets; otherwise the bonus cannot be added manually.

8.4.3. Validity period: All deposit bonuses are valid for 14 days from activation, unless otherwise provided in the specific bonus terms. If the wagering requirements are not met within the validity period, the bonus and all associated winnings are automatically removed.

8.4.4. Maximum winnings:

• for free bonuses or free spins without a deposit, the maximum payable win is 100 euros, unless otherwise provided in the specific bonus terms;
• for welcome bonuses and daily and weekly recurring bonuses, the maximum payable winnings amount is limited to 500 euros, unless otherwise provided in the specific bonus terms;
• for daily cashback, the maximum payable winnings amount is limited to 500 euros, unless otherwise provided in the specific bonus terms;
• for all other bonuses, the maximum payable win is 10,000 euros, unless otherwise provided in the specific bonus terms;
• all amounts exceeding the said limits are forfeited upon submission of the withdrawal request.

8.4.5. The verification period for each specific withdrawal case is up to 5 business days, except where there is a suspicion of fraud or a breach of AML requirements.

8.5. Bonus abuse and forfeiture

8.5.1. Definition of abuse: Bonuses are intended solely for genuine recreational players. Bonus abuse includes, among others but not limited to: creating multiple accounts, deferring game rounds or features until the wagering requirements are met, exploiting bonus mechanisms (e.g. building up a bonus feature and completing it with real money) or any attempt to manipulate campaign incentives.

8.5.2. Consequences: If the Operator establishes that the Player is a bonus abuser or has participated in fraudulent activities, the Operator reserves the right to:

• cancel all bonuses and their associated winnings;
• restrict the Player's further participation in campaigns;
• suspend or permanently close the Player's account.

8.5.3. KYC/AML requirements: At the Operator's request, the Player is obliged to submit valid identity verification documents (KYC) and AML documents (Section 4). Failure to submit the required documents results in the forfeiture of the bonus and all associated winnings.

8.6. Amendment and cancellation of bonuses

The Operator reserves the right to unilaterally extend or shorten, renew, cancel, reclaim or void any bonus offer. All bonus-related changes are published in the description of the relevant campaign. It is the Player's responsibility to be aware of these changes.

9. Responsible gambling

9.1. The Operator promotes safe and responsible gambling. Gambling is entertainment and must not be used to solve financial problems. The Operator offers extensive responsible gambling measures, including:

• daily, weekly and monthly deposit limits;
• daily, weekly and monthly loss limits;
• gaming session time limits;
• reality checks;
• self-exclusion for a period of 6–36 months via the Tax and Customs Board (HAMPI);
• online cooling-off options.

9.2. Deposit limits: The Player can set limits on the amount they can deposit over a specified period (daily, weekly or monthly). Deposit limits can be managed directly in the Player's account settings.

9.3. Reducing a limit: A reduction of a deposit limit takes effect immediately.

9.4. Increasing a limit: An increase of a deposit limit takes effect only after a 48-hour cooling-off period has elapsed, in order to prevent impulsive decisions.

9.5. Loss limits: The Player can set limits on the amount they can lose with real money over a specified period (daily, weekly or monthly). These limits are calculated on a net-loss basis, defined as the difference between the total bets and the total winnings for the selected period.

9.6. Time and session limits: The Player can set the maximum duration of their gaming sessions. When the set limit is reached, a corresponding notification is displayed.

9.7. Reality check: At predefined intervals, a mandatory pop-up window is displayed, informing the Player of the time elapsed, the amount of bets placed and the current balance, and giving the option to continue playing or to log out of the account.

9.8. Voluntary self-exclusion (Operator-based)

9.8.1. Requesting self-exclusion: Estonian residents can register self-exclusion in the HAMPI system via EMTA, the emta.ee portal or via Smart-ID/Mobiil-ID, as well as through customer support. If the Player wishes to take a break from gambling, they can request voluntary self-exclusion linked to the Operator's website. The relevant request must be submitted to customer support by email from the Player's registered email address or via the communication channel provided on the website, clearly stating the wish for self-exclusion and the desired period (e.g. 6 months, 1 year, 3 years).

9.8.2. Processing the request: Upon receipt of a valid request, the Operator processes the self-exclusion and closes the Player's access to the account within 24 hours of receiving the request.

9.8.3. Binding effect: Voluntary self-exclusion is a serious and binding commitment. After it is activated:

• the account cannot be reopened for any reason before the end of the chosen self-exclusion period;
• the Operator applies reasonable measures to prevent the Player from opening a new account on its website during the self-exclusion period;
• all remaining funds on the account are refunded to the Player in accordance with Section 5, provided that the compliance checks and AML requirements have been passed.

9.9. Warning: Gambling can be addictive. If you feel that gambling is becoming a problem, please seek help from professional support organisations.

10. Communication and marketing

10.1. Use of email address and telephone number: By registering an account and agreeing to these Terms, the Player consents to the Operator using the email address and/or mobile telephone number provided by the Player for the following purposes:

• Important notifications: sending notices and messages relating to the operation of the account, security updates, changes to the Terms, mandatory KYC/AML requests, and confirmations of deposits and withdrawals. It is not possible to opt out of these important service messages.
• Marketing and promotional information: sending promotional emails, offers and information about the Operator's services, bonuses, new games and special offers ("marketing messages").

10.2. Marketing consent and opt-out

10.2.1. Giving consent (opt-in): The Player confirms that, by agreeing to these Terms, they give express consent to receive marketing messages, unless they have expressly withdrawn marketing consent during registration via the relevant option.

10.2.2. Right to opt out: The Player has the unconditional right to opt out of receiving marketing messages at any time. This can be done in the following ways:

• by clicking the "unsubscribe" link in the footer of any marketing email received;
• by changing the communication preferences in the Player's account settings on the website;
• by contacting customer support directly with a request to be removed from all marketing lists.

10.3. Compliance with the Estonian Advertising Act: All marketing messages sent by the Operator strictly comply with the requirements of the Estonian Advertising Act, in particular the principles of responsible gambling and the requirement that advertising must be clearly distinguishable as advertising.

11. Data protection and privacy

11.1. Consent to the processing of personal data: By creating an account and using the Operator's services, the Player gives express consent to the Operator collecting, storing and processing the Player's personal data, including but not limited to identity verification data (KYC documents), transaction history and communication data.

11.2. Purposes of data processing: The Player agrees that their personal data is processed for the following main purposes:

• to manage and service the Player's account;
• to fulfil obligations arising from legal, regulatory and licensing requirements, including anti-money-laundering (AML) and responsible gambling requirements in accordance with Estonian law;
• to process financial transactions and withdrawals;
• for business communication and marketing purposes (in accordance with Section 10).

11.3. Data retention period: In accordance with § 54 of the Estonian Gambling Act, the Organiser is legally obliged to retain data for at least five (5) years after the end of the customer relationship with the Player or the date of the last transaction.

11.4. Privacy terms: All collection, storage and use of personal data takes place strictly in accordance with the Operator's separate privacy terms document and the General Data Protection Regulation (GDPR). The Player confirms that they have read and agreed to the privacy terms. The privacy terms describe in detail the scope of data processing, the data retention periods and the Player's rights, including the right to access, rectify and delete data.

11.5. Data security: The Operator is committed to protecting the Player's personal data and applies appropriate technical and organisational measures to prevent unauthorised access to data, data loss or misuse.

12. Prohibited activities, fraud and unfair play

12.1. Prohibited conduct: The Player undertakes not to engage in any unlawful, fraudulent or malicious activity in connection with the use of the services. Prohibited activities include, among others but not limited to, the following:

• Fraudulent activity: providing false or misleading identity verification or transaction information.
• Collusion and unfair play: any attempt to influence game results, participate in collusion (arrangements with other players) or use system errors or vulnerabilities for personal gain.
• Bonus abuse: using campaigns or bonuses in a manner that conflicts with their specific terms.
• Use of technical aids: using software, bots, artificial intelligence (AI) or other external technical devices or aids intended to give the Player an unfair advantage or to automate play.
• Money laundering: using the Operator's services to transfer money for unlawful purposes or any activity that may be regarded as money laundering or terrorist financing.

12.2. Consequences of prohibited activity: If the Operator establishes, at its sole discretion and on the basis of reasonable evidence, that the Player has engaged in any prohibited activity:

12.2.1. Measures taken against the account: The Operator reserves the right to immediately suspend, terminate or permanently delete the Player's account without prior notice.

12.2.2. Forfeiture of funds and winnings: The Operator has the right to cancel or withhold winnings and bonuses associated with prohibited activity, fraud or unfair play. The Operator may suspend or restrict the funds on the Player's account until the investigation is completed. The Operator may use the funds on the Player's account to compensate for losses caused by the Player's conduct only where the amount of the losses is undisputed or where they have been established by a final court judgment or another legally binding decision.

12.2.3. Notification of authorities: In accordance with Estonian and European Union law (including AML/CTF legislation), the Operator is legally obliged to report suspicious and/or fraudulent activities to the Estonian Financial Intelligence Unit (RAB), the Estonian Tax and Customs Board (EMTA) and other relevant supervisory, law enforcement or state authorities. The Player agrees that the Operator is not obliged to notify the Player of such reports.

12.2.4. Legal measures: The Operator reserves the right to initiate or request the commencement of civil and criminal proceedings against a Player connected to prohibited activity, by reporting the matter to the competent law enforcement authorities. This includes claiming compensation for losses and legal costs through the relevant courts to the fullest extent permitted by law.

13. Limitation of liability

13.1. No warranties: The Operator provides the services and makes the website available on an "as is" and "as available" basis. The Operator gives no warranties or representations, whether express or implied, including as to the satisfactory quality of the service, fitness for a particular purpose, completeness or accuracy.

13.2. Service interruptions: The Operator is not liable for any damage or losses incurred by the Player arising, among other things, from:

• delays, failures, interruptions or work stoppages of the server, website or game software;
• errors or deficiencies in the website content, except where such errors are caused by the Operator's gross negligence or intent to mislead;
• force majeure circumstances, including war, natural disasters, power outages and labour disputes.

13.3. Technical errors: The Operator is not liable for technical failures, hardware or software malfunctions, or the interruption or loss of network connection that may occur on the Player's side, including circumstances that interrupt play or cause the loss of data or winnings.

13.4. Third-party liability: The Operator is not liable for damage or losses caused by the actions of third parties, including malfunctions or failures of payment service providers, telecommunications networks or internet service providers.

13.5. Exclusion of indirect damages: The Operator is not liable for any indirect, special, incidental, punitive or consequential damage or loss (including but not limited to lost profits, loss of data or loss of business opportunity) arising from the Player's use of the services, regardless of whether the Operator has been notified of the possibility of such damages.

14. Intellectual property

14.1. Ownership of content: The Player acknowledges and agrees that the website, all of its content, graphics, photographs, designs, software, computer code, music, sound, video, the overall design and user experience of the website, trademarks, trade names and logos (collectively "intellectual property objects") belong to the Operator or its licensors and are protected by copyright and intellectual property legislation.

14.2. Limited licence to the Player: The Operator grants the Player a limited, non-exclusive, non-transferable and non-sublicensable licence to access and use the intellectual property objects solely for the personal and non-commercial use of the gambling services offered on the website, in accordance with these Terms.

14.3. Restrictions: The Player is under no circumstances permitted, without the Operator's prior written consent, to copy, reproduce, distribute, publish, display, translate, modify, use for commercial purposes or create derivative works from any intellectual property object.

14.4. Use of trademarks: The Player undertakes not to use the Operator's trademarks, logos or trade names in any way, including in connection with products or services that the Operator does not offer, or in a manner that may cause confusion among customers or damage the Operator's reputation.

15. Claims and dispute resolution

15.1. If the Player has complaints relating to game results, technical problems or settlement, they have the right to submit a written claim within 15 days of the relevant game taking place.

15.2. Claims must be submitted to the following contact details:

15.3. The Operator reviews the submitted claim and provides the Player with a written response within 15 days.

15.4. Customer support is open Monday to Friday from 10:00 to 17:00.

15.5. If, for any reason, the Player is not satisfied with the resolution provided by the Operator for the complaint, the Player has the right to submit a complaint to an independent arbitration body or to the relevant supervisory and licensing authority — the Tax and Customs Board (EMTA), which handles both the issuing of licences and supervision (email: [email protected]).

16. Language

16.1. These Terms are drawn up in Estonian, English and Russian. In the event of discrepancies between the translations, the Estonian version prevails.