Terms and Conditions

Part A — Core Terms, Platform Architecture & User Relationship

1. Introduction and Legal Effect

These Terms of Service, together with all schedules, appendices, rules, disclosures, policies, and notices expressly incorporated by reference (collectively, the "Terms"), govern all access to and use of the online platform operated under the domain www.packy.gg including any affiliated websites, subdomains, applications, software, interfaces, or services now existing or made available in the future (collectively, the "Platform").

The Platform is operated by Pokewin Entertainment Ltd, a private limited liability company incorporated under the laws of the Republic of Cyprus (the "Company", "we", "us", or "our").

By accessing, browsing, registering on, or using the Platform in any manner whatsoever, you acknowledge that you have read, understood, and agree to be legally bound by these Terms. If you do not agree to these Terms, you must immediately discontinue all use of the Platform.

These Terms constitute a legally binding agreement between you and the Company.

2. Definitions and Interpretation

For the purposes of these Terms:

"User", "you", or "your" means any individual who accesses or uses the Platform, whether registered or not.

"Account" means a registered user account created on the Platform.

"Virtual Units" means any virtual credits, tokens, coins, cash, XP, points, levels, or similar units used within the Platform.

"Packy Coins" means Virtual Units received by a user in connection with a purchase, deposit, or other paid transaction on the Platform. Packy Coins are intended solely for entertainment use on the Platform, have no cash value, are not redeemable, and do not themselves constitute rewards, prizes, or withdrawable value.

"Packy Cash" means promotional Virtual Units that may be granted by the Platform, including in connection with purchases, deposits, bonuses, promotions, rewards, giveaways, competitions, leaderboard prizes, cashback, rakeback, challenges, or other promotional activities. Packy Cash may be eligible for rewards, prizes, redemptions, or promotional benefits only where expressly permitted by the Platform and subject to these Terms.

"Sweepstakes" means any promotional activity offering the possibility of receiving a reward without requiring a purchase.

"AMOE" means an Alternative Method of Entry that is free of charge.

"Packs" means digital containers or mechanisms that provide randomized digital items or outcomes within the Platform.

"Restricted Jurisdiction" means any country, state, territory, or region listed in Schedule A (Restricted Jurisdictions), together with any other jurisdiction designated as restricted or prohibited by the Company from time to time.

"Promotional Reward" means any rakeback, cashback, race prize, leaderboard prize, reload bonus, balance reward, deposit bonus, challenge prize, or other promotional benefit made available on the Platform.

"Promotional Value" means a notional value assigned by the Company for prize administration, redemption, and user-interface purposes only, which does not constitute money, cash, stored value, or a right to receive monetary payment.

"Payment Processor" means any third-party payment service provider, payment facilitator, acquiring bank, card network, or digital wallet provider through which payments on the Platform are processed.

Headings are for convenience only and do not affect interpretation.

The singular includes the plural and vice versa.

3. Nature of the Platform — Foundational Disclosure

The Platform is a promotional entertainment platform.

It does not offer:

• gambling,
• betting,
• wagering,
• casino games,
• lotteries.

The Platform may include chance-based promotional mechanics, including randomized digital item distributions, packs, cases, challenges, or similar features.

These mechanics are provided solely for entertainment and promotional purposes and do not constitute gambling where no purchase is required and where free methods of entry are available.

No element of the Platform requires a purchase, payment, or financial commitment in order to participate.

No purchase increases the chances of receiving a promotional reward.

Participation on the Platform is strictly voluntary and for entertainment purposes only.

This section is fundamental to the classification of the Platform and shall be interpreted broadly in favour of non-gambling characterisation.

4. No Financial or Custodial Relationship

Nothing in these Terms shall be construed as creating any form of:

• partnership,
• joint venture,
• agency,
• fiduciary duty,
• employment relationship,
• trust relationship,
• custodial relationship,
• banking relationship.

Users do not deposit funds with the Company in any custodial, banking, stored-value, or financial account sense.

Any use of the word "deposit" on the Platform refers only to a user-initiated purchase or balance-loading transaction for entertainment Virtual Units and does not mean that the Company holds money or assets on behalf of the user.

The Company does not hold funds, money, or assets on behalf of users.

Any interaction with the Platform does not constitute the opening of an account, wallet, bank account, stored-value account, payment account, or financial instrument of any kind.

5. User Acknowledgements and Assumptions

By using the Platform, you expressly acknowledge, represent, and agree that:

• Access to the Platform is a privilege, not a right;
• You participate entirely at your own risk;
• You have no expectation of profit, income, or financial return;
• Virtual Units are not money, property, or assets;
• Packy Coins and Packy Cash are Virtual Units only;
• You do not acquire ownership rights in any Virtual Units;
• Packy Coins are not redeemable and do not constitute rewards or prizes;
• Packy Cash may be eligible for promotional rewards only where expressly permitted by the Platform and subject to review;
• Promotional Rewards are time-limited and expire if not claimed within the applicable claim window (see Section 47);
• The Company may modify, restrict, or terminate access at any time;
• You have reviewed and accepted these Terms voluntarily.

These acknowledgements are material and relied upon by the Company.

6. Eligibility Requirements

6.1 Age

You must be at least eighteen (18) years of age, or the legal age of majority in your jurisdiction if higher, to access or use the Platform.

Certain jurisdictions may require users to be twenty-one (21) years of age or older.

The Company reserves the right to impose higher age thresholds at its discretion.

Users who do not meet the applicable age requirement must not access or use the Platform.

6.2 Geographic Eligibility

The Platform is void where prohibited by law.

You are solely responsible for determining whether your access to or participation on the Platform is lawful in your jurisdiction.

The Company makes no representations or warranties regarding legality in any specific location.

6.3 Restricted Jurisdictions

The Company does not offer, and expressly declines to offer, the Platform or any services, features, purchases, promotions, sweepstakes, rewards, or redemptions to any person who is located in, resident in, incorporated in, or accessing the Platform from a Restricted Jurisdiction, or who is a citizen or resident of a comprehensively sanctioned jurisdiction, or who is the subject of applicable sanctions, in each case as set out in Schedule A (Restricted Jurisdictions) to these Terms.

The Company may designate additional countries, states, territories, or regions as restricted or prohibited at any time, with or without notice, and may amend Schedule A at its sole discretion.

You represent and warrant, on a continuing basis, that you are not located in, resident in, or accessing the Platform from a Restricted Jurisdiction and that you are not a sanctioned person. Any use of the Platform in breach of this representation constitutes a material breach of these Terms.

Where the Company determines, or reasonably suspects, that an Account is held by, controlled by, or accessed by a person in or from a Restricted Jurisdiction, or by a sanctioned person, the Company may immediately and without prior notice:

• freeze, suspend, restrict, or permanently terminate the Account;
• reject, void, forfeit, reverse, or cancel any entries, Virtual Units, Packy Coins, Packy Cash, Promotional Rewards, prizes, or redemption requests;
• withhold or cancel any pending redemption or fulfilment; and
• refuse any refund of purchases or deposits, save to the extent a refund is required by applicable law or is determined by the Company, at its sole discretion, to be appropriate.

No compensation is owed in respect of any action taken under this Section. The Company may retain records of, and report, such matters as required by applicable law, including sanctions regulations.

7. Geolocation and Circumvention Controls

The Platform uses technical, administrative, and automated measures to determine eligibility and location.

You agree that you shall not:

• use VPNs, proxies, or tunnelling services;
• falsify or conceal IP data;
• manipulate device identifiers;
• access the Platform on behalf of another person;
• attempt to bypass geographic or technical safeguards.

Any attempt to circumvent controls constitutes a material breach of these Terms and may result in immediate forfeiture and termination, including the enforcement measures described in Section 6.3 where the circumvention relates to a Restricted Jurisdiction.

8. Account Creation and Registration

Access to certain features of the Platform requires creation of an Account.

When creating an Account, you agree to:

• provide accurate, current, and complete information;
• maintain and update such information as necessary;
• keep login credentials confidential.

The Company may refuse registration or suspend an Account at its sole discretion.

9. One-Account Policy

Only one (1) Account is permitted per:

• individual,
• household,
• IP address,
• device,
• or any combination of the above.

The Company may treat multiple Accounts as associated based on behavioural, technical, or risk indicators.

Associated Accounts may be suspended or terminated collectively.

9.1 Approved Creator Exception

Notwithstanding the One-Account Policy, the Company may, in its sole discretion, permit approved creators, influencers, affiliates, ambassadors, content partners, testers, or similar promotional participants ("Approved Creators") to operate more than one Account where expressly authorised by the Company in writing.

Any such exception must be granted in advance and may be revoked, modified, suspended, or terminated by the Company at any time.

All Approved Creator Accounts remain subject to these Terms, including all eligibility requirements, verification procedures, geolocation controls, anti-abuse measures, compliance reviews, and enforcement actions.

The existence of multiple Accounts by an Approved Creator shall not constitute a violation of these Terms where valid written approval has been granted by the Company.

9.2 Unauthorised Multiple Accounts and Abuse

Except as expressly permitted under Section 9.1, users may not create, access, control, or benefit from more than one Account, whether directly or indirectly.

Users must not engage in any conduct designed to manipulate, exploit, circumvent, or abuse the Platform, its promotional systems, rewards programs, referral programs, bonus offers, competitions, giveaways, loyalty programs, challenges, or any other feature of the Services.

Prohibited conduct includes, without limitation:

• creating, operating, accessing, or benefiting from multiple unauthorised Accounts;
• repeated farming, harvesting, or accumulation of rewards, bonuses, entries, credits, Virtual Units, Packy Cash, prizes, or other benefits contrary to their intended purpose;
• stacking, combining, cycling, or otherwise exploiting free rewards, promotional offers, referral benefits, or incentives in a manner inconsistent with the spirit or intended operation of the Platform;
• using multiple individuals, devices, payment methods, households, IP addresses, technical workarounds, automation, scripts, or coordinated activity to obtain an unfair advantage;
• any abuse, circumvention, manipulation, fraudulent activity, or conduct intended to improperly increase eligibility for rewards, prizes, promotions, redemptions, challenge prizes, or benefits.

Where the Company determines, in its sole discretion, that a user has engaged in any such conduct, the Company may take any action it deems appropriate, including without limitation:

• suspension or termination of one or more Accounts;
• forfeiture, removal, adjustment, voiding, reversal, or recovery of Virtual Units, Packy Cash, entries, rewards, prizes, redemptions, or other benefits;
• removal, reduction, or cancellation of deposit bonuses, rakeback, cashback, and other Promotional Rewards, including any winnings or balances derived from them;
• cancellation of promotional eligibility;
• permanent exclusion from the Platform; and
• any other enforcement action reasonably necessary to protect the integrity of the Platform.

If the Company suspects that a user may be engaging in, or has engaged in, fraudulent, unlawful, improper, or abusive activity, including money laundering, reward farming, bonus abuse, promotional abuse, account circumvention, challenge abuse, or any conduct that violates these Terms, the Company may immediately deactivate access to the Website and Services and suspend or terminate the relevant Account(s).

Where an Account is suspended or terminated under this Section, the Company shall have no obligation to restore any Account, reverse any purchase, honour any redemption request, or award any prize, reward, challenge prize, or benefit associated with the Account.

The Company may disclose relevant information to regulators, law enforcement agencies, payment providers, banks, card issuers, financial institutions, fraud prevention services, or other service providers where reasonably necessary for investigation, enforcement, compliance, or prevention of abuse. Users agree to cooperate fully with any investigation relating to such activity.

Users shall have no entitlement to compensation, reimbursement, or restoration of any Account, Virtual Units, Packy Coins, Packy Cash, rewards, prizes, or benefits removed pursuant to this Section.

9.3 Low-Risk Wagering and Promotional Abuse

Where rewards, bonuses, promotional credits, Packy Cash, entries, or similar benefits are provided subject to wagering, gameplay, participation, engagement, or usage requirements, users must engage in genuine and meaningful activity consistent with the intended purpose of the promotion.

The Company may determine, in its sole discretion, that activity constitutes low-risk wagering, token participation, hedging, minimal-risk play, artificial volume generation, wash activity, or other conduct primarily intended to satisfy promotional conditions without genuine participation.

Where such conduct is identified, the Company may:

• exclude relevant activity from wagering or participation calculations;
• void, adjust, remove, or recover associated rewards, bonuses, Packy Cash, entries, prizes, or benefits;
• remove, reduce, or cancel deposit bonuses and any balances or winnings derived from them;
• require additional verification or review;
• suspend or terminate promotional eligibility; and
• take any enforcement action available under these Terms.

The Company shall be the sole judge of whether activity constitutes genuine participation or prohibited low-risk wagering and promotional abuse.

10. Account Security and Responsibility

You are solely responsible for all activity occurring under your Account.

The Company is not responsible for unauthorised access resulting from your failure to safeguard credentials.

Accounts may not be:

• sold,
• transferred,
• assigned,
• licensed,
• shared.

Any attempted transfer is void.

11. Platform Availability and Modification

The Company reserves the right to:

• modify Platform features;
• add or remove games, challenges, promotions, or mechanics;
• change mechanics, limits, or rules;
• suspend or discontinue the Platform.

No compensation is owed for any modification or discontinuation.

12. Technical Limitations and Interruptions

The Platform may be subject to:

• maintenance;
• outages;
• latency;
• errors;
• interruptions.

The Company does not guarantee uninterrupted availability.

Technical issues do not create any entitlement, claim, or right.

13. Acceptance of Platform Risk

You acknowledge that use of the Platform involves inherent risks, including:

• technical failures;
• system errors;
• eligibility disputes;
• data transmission issues;
• balance display issues;
• challenge tracking issues.

You voluntarily assume all such risks to the maximum extent permitted by law.

Part B — Virtual Units, Balances, Economics, Abuse & Enforcement

14. Virtual Units — Legal Classification

All virtual credits, coins, cash, tokens, XP, points, levels, balances, or similar mechanisms used on the Platform, including Packy Coins and Packy Cash, are digital representations only.

Virtual Units:

• do not constitute currency, money, or cash equivalents;
• are not property, assets, securities, or financial instruments;
• do not represent stored value or a right of redemption;
• do not create a debt or obligation owed by the Company;
• may be revoked, adjusted, restricted, reweighted, or eliminated at any time.

Users receive only a revocable, limited licence to use Virtual Units within the Platform.

14.1 Packy Coins

Packy Coins are entertainment Virtual Units that may be received when a user makes a purchase, deposit, or other paid transaction on the Platform.

Packy Coins:

• are intended for entertainment use only;
• have no cash value;
• are not redeemable;
• do not constitute a prize, reward, or promotional payout;
• do not themselves create eligibility for redemption;
• may be subject to limits, restrictions, expiry, or adjustment.

When a user completes a purchase or deposit transaction, the Platform may credit the user with Packy Coins and may separately grant Packy Cash on top as a promotional bonus or incentive.

14.2 Packy Cash

Packy Cash is a promotional Virtual Unit that may be granted by the Platform in connection with purchases, deposits, promotions, bonuses, rewards, prizes, giveaways, cashback, rakeback, leaderboard activity, challenge activity, or other promotional features.

Only Packy Cash may be used as the source of rewards, prizes, redemptions, cashback, rakeback, leaderboard prizes, challenge prizes, or other promotional benefits, unless the Platform expressly states otherwise.

Packy Cash:

• cannot be purchased directly, and no mechanism exists for users to pay for Packy Cash;
• is promotional in nature;
• is not money or currency;
• does not constitute a deposit, stored value, or financial balance;
• is not owned by the user;
• may be subject to verification, eligibility checks, wagering or participation requirements, review, and compliance holds;
• may be reduced, cancelled, forfeited, frozen, or denied where required by these Terms or by Platform review.

The display of Packy Cash in an Account does not guarantee any reward, prize, redemption, payout, or benefit.

14.3 Displayed Dollar Values

The Platform may display balances, rewards, redemption values, prizes, or other informational metrics using the symbols "$", "USD", "Dollar", "Balance", "Value", or similar terminology.

Any such displayed value represents a Promotional Value assigned by the Company solely for entertainment, sweepstakes administration, reward allocation, redemption administration, and user-interface convenience purposes.

Users expressly acknowledge and agree that displayed values:

• do not constitute money, currency, legal tender, cash equivalents, deposits, stored value, electronic money, financial products, or financial instruments;
• do not represent funds held by the Company on behalf of any user;
• do not create a bank account, payment account, wallet, custodial relationship, or similar financial arrangement;
• do not constitute gambling winnings;
• do not create any right to receive cash or monetary consideration;
• may be modified, adjusted, replaced, suspended, or removed by the Company at any time.

For the avoidance of doubt, any dollar-denominated value displayed on the Platform represents only a Promotional Value and not an actual cash balance.

15. No Ownership; No Economic Expectation

Users acknowledge and agree that:

• Virtual Units are not owned by the user;
• Packy Coins and Packy Cash are not owned by the user;
• time, effort, payment, deposit activity, or gameplay activity does not create ownership rights;
• no expectation of profit, return, or appreciation exists;
• participation is not an investment of any kind.

The Company may alter Virtual Units, Packy Coins, Packy Cash, eligibility rules, challenge rules, and promotional mechanics regardless of user activity.

16. Prohibition on Transfer and Monetisation

Virtual Units, Packy Coins, and Packy Cash may not be:

• transferred between users;
• sold or exchanged;
• pledged or encumbered;
• used outside the Platform;
• used as collateral;
• converted into any third-party asset except where a redemption is expressly approved by the Platform.

Any attempt to monetise or transfer Virtual Units constitutes a material breach.

17. Platform Modes

17.1 Fun / Social Mode

Fun Tokens exist solely for entertainment.

Fun Tokens:

• have no value;
• cannot be redeemed;
• do not affect eligibility for promotions, rewards, prizes, or challenges.

17.2 Packy Coins Mode

Packy Coins are entertainment Virtual Units received in connection with a purchase, deposit, or paid transaction.

Packy Coins:

• are not redeemable;
• do not represent prizes or rewards;
• cannot be used as the source of cashback, rakeback, leaderboard prizes, challenge prizes, or redemptions;
• may be used only within supported Platform features.

17.3 Promotional Packy Cash Mode

Packy Cash is distributed through promotional mechanisms, including free entry mechanisms, bonuses, rewards, prizes, cashback, rakeback, leaderboard prizes, challenge prizes, or as an additional promotional amount granted on top of Packy Coins when a user completes a purchase or deposit.

Packy Cash:

• may be eligible for rewards or redemptions only where expressly permitted;
• may be subject to wagering, participation, verification, compliance, and anti-abuse review;
• may be frozen, reduced, cancelled, or forfeited under these Terms;
• does not increase odds because of payment;
• does not constitute money, property, or stored value.

17.4 Packs and Randomized Mechanics

Packs are entertainment features that provide randomized outcomes.

Users acknowledge that:

• outcomes are generated through algorithmic or probabilistic systems;
• results are not guaranteed;
• perceived value is subjective and may fluctuate;
• no expectation of profit or financial gain exists;
• displayed values are internal, promotional, and illustrative only.

The Company does not guarantee any specific outcome or value from Packs.

17.5 Demo Mode, Battle Mode, Borrowed Balance Mode, and Unsupported Modes

The Platform may offer demo mode, battle mode, borrowed balance mode, test modes, promotional display modes, or other unsupported modes.

Unless expressly stated otherwise by the Platform, activity in demo mode, battle mode, borrowed balance mode, or any unsupported mode does not qualify toward rewards, prizes, cashback, rakeback, VIP progression, leaderboard qualification, wagering requirements, redemption eligibility, or onsite challenge prizes.

18. Anti-Abuse Philosophy

The integrity of the Platform depends on genuine, human participation.

The Company applies behavioural analytics, technical tools, and manual review to detect abuse.

Abuse determinations are made at the sole discretion of the Company.

19. Prohibited Behaviour — Non-Exhaustive

Prohibited behaviour includes, without limitation:

• automated play or scripts;
• farming or grinding behaviour inconsistent with human play;
• coordinated or collusive activity;
• AMOE exploitation;
• creation of multiple or linked accounts;
• exploiting bugs or errors;
• reverse engineering or manipulation of mechanics;
• challenge abuse;
• balance source manipulation;
• deposit bonus abuse, including structured or artificial deposit patterns intended to farm bonuses;
• attempts to convert Packy Coins into Packy Cash through abuse, fraud, or exploitative behaviour.

20. Associated Accounts and Networks

Accounts may be deemed associated based on:

• IP overlap;
• device fingerprints;
• behavioural similarities;
• household indicators;
• timing and pattern analysis;
• payment or deposit indicators;
• challenge participation patterns.

Associated accounts may be penalised collectively.

21. Forfeiture and Retroactive Enforcement

Where abuse or violation is detected, the Company may:

• void Virtual Units retroactively;
• void, reduce, or freeze Packy Cash;
• remove, reduce, or cancel deposit bonuses and other Promotional Rewards, including balances or winnings derived from them;
• reverse prior redemptions;
• cancel challenge prizes;
• terminate accounts without notice;
• deny future access permanently.

No compensation is owed.

22. Platform Error Correction

Errors do not create entitlement.

The Company may correct:

• display errors;
• balance errors;
• Packy Coins errors;
• Packy Cash errors;
• outcome errors;
• challenge tracking errors;
• reward, bonus, and expiry calculation errors;
• system malfunctions.

Corrections may be made after values are displayed or communicated.

Marketing, Promotions, and Non-Reliance

All advertising, promotional materials, website content, screenshots, demonstrations, examples, and statements made by the Company or by third parties, including affiliates, partners, streamers, or influencers, are provided for illustrative and promotional purposes only.

You acknowledge and agree that:

• such materials do not constitute promises, guarantees, or representations of outcomes;
• influencer or affiliate statements reflect personal opinions and experiences only;
• you have not relied on any advertising, marketing, or promotional statements when deciding to use the Platform.

In the event of any inconsistency between marketing materials and these Terms, these Terms shall prevail.

Sole Discretion of the Company

All determinations relating to eligibility, compliance, abuse, redemption approval, account status, balance treatment, Packy Cash eligibility, challenge eligibility, Promotional Reward eligibility and expiry, and enforcement of these Terms shall be made by the Company in its sole and absolute discretion, including determinations made retroactively.

The Company is not required to provide explanations, evidence, or reasoning for any enforcement decision.

Part C — Redemption, Verification & Compliance

23. No Automatic Right to Redemption

The presence of Virtual Units, Packy Coins, or Packy Cash does not guarantee redemption.

Packy Coins are not redeemable.

Packy Cash may be eligible for redemption only where expressly permitted by the Platform and only after all applicable requirements, reviews, and verifications are satisfied.

Redemption is conditional, discretionary, and subject to review.

24. Redemption Controls

The Company may impose:

• minimum and maximum thresholds;
• daily, weekly, or monthly caps;
• staggered fulfilment;
• cooling-off periods;
• balance source restrictions;
• Packy Cash eligibility restrictions.

Controls may change without notice.

25. Compliance Holds and Investigations

Accounts, Virtual Units, Packy Cash, challenge prizes, rewards, or redemption requests may be placed on hold during:

• fraud reviews;
• AML reviews;
• eligibility checks;
• abuse investigations;
• challenge abuse reviews;
• balance source reviews.

There is no guaranteed timeline for completion.

26. Verification and KYC

The Company operates a risk-based identity verification and anti-money laundering programme. Verification may be required at any time, including before or after redemption requests, challenge prize claims, promotional awards, or other reward-related activity, and wherever necessary for fraud prevention, Payment Processor requirements, legal obligations, or internal risk assessment.

Without limiting the foregoing, the Company may, at its sole discretion, require identity verification in connection with any fiat deposit or purchase (including by credit card, debit card, Apple Pay, Google Pay, or Cash App Pay), whether before or after the transaction is processed. Verification may become mandatory once users reach the deposit or withdrawal thresholds published in the Company's Anti-Money Laundering Policy, which is available at packy.gg/aml and forms part of these Terms.

Verification is conducted through one or more independent third-party identity verification providers appointed by the Company from time to time (currently including Sumsub). Accounts funded exclusively with cryptocurrency are not, as a matter of routine, subject to identity verification; verification will be requested on such accounts where suspicious activity, elevated risk indicators, or legal or Payment Processor requirements arise.

Verification may include:

• government ID;
• proof of address;
• biometric (liveness) checks;
• device verification;
• proof of ownership of the payment method used;
• tax documentation;
• source of funds or source of balance review.

All deposits and purchases must be made using payment methods owned by the Account holder. The use of third-party payment methods is prohibited unless expressly authorised by the Company, and the Company may require evidence of payment method ownership at any time. You confirm that all funds used on the Platform originate from legitimate sources and that every payment method you use belongs to you or is otherwise lawfully authorised.

Failure to complete required verification, refusal to cooperate, or submission of false or misleading information may result in account restrictions, suspension, refusal of deposits, withholding of redemptions, forfeiture, account closure, or reporting to relevant authorities or Payment Processors where required by law.

Where verification is required in connection with a fiat deposit or purchase and is not completed to the Company's satisfaction, or where the Company otherwise determines at its sole discretion that it does not wish to accept a fiat transaction, the Company may decline or reverse the transaction and refund the corresponding amount to the original payment method (refund to source), in which case any Virtual Units, Packy Coins, Packy Cash, bonuses, or benefits credited in connection with that transaction may be voided and removed. A refund to source under this Section is a compliance measure and does not constitute an admission of any obligation or liability.

27. Tax Responsibility and Reporting

You are solely responsible for all taxes, duties, levies, or similar charges arising from participation on the Platform or receipt of any promotional reward, prize, redemption, Packy Cash benefit, or challenge prize.

Where required by applicable law, including United States tax law, the Company reserves the right to:

• require submission of tax documentation, including IRS Forms W-9 or W-8BEN;
• withhold amounts from any reward;
• report transactions or reward values to tax authorities;
• delay, suspend, or cancel any redemption, reward, or challenge prize pending tax compliance.

Failure or refusal to provide required tax documentation within the timeframe specified by the Company may result in denial or forfeiture of the reward, without compensation.

Part D — Official Sweepstakes Rules & US Legal Protections

28. Sweepstakes Overview

The Platform offers promotional sweepstakes.

NO PURCHASE NECESSARY.

A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING.

FREE METHODS OF ENTRY ARE AVAILABLE AND PROVIDE THE SAME ODDS OF WINNING AS ANY OTHER METHOD OF ENTRY.

Sponsor and Administrator: Pokewin Entertainment Ltd (HE 491188), Themistokli Dervi 48, 3rd Floor, Office 306, 1065 Nicosia, Cyprus.

Displayed dollar values throughout the Platform represent Promotional Values only (see Section 14.3). Such values do not constitute cash balances, deposits, stored value, gambling winnings, or a right to receive money.

The Platform does not operate a marketplace for real-world trading of digital items. Any perceived value is internal and non-transferable.

Users acknowledge that any displayed value, pricing, or indication of worth is purely informational or illustrative and does not represent real-world redeemable value.

29. Eligibility for Sweepstakes

Sweepstakes are open only to eligible individuals located in permitted jurisdictions. Sweepstakes are void in all Restricted Jurisdictions listed in Schedule A and wherever otherwise prohibited by law.

Employees, contractors, affiliates, and immediate family members may be excluded.

30. Entry Methods

Entries may be obtained via:

• promotional distributions;
• giveaways;
• free AMOE mechanisms;
• Packy Cash promotional distributions;
• other methods disclosed on the Platform.

Equal treatment of entries. Entries obtained through a free AMOE receive the same odds of winning, participate in the same prize pools, are subject to the same deadlines and entry frequencies, and are subject to no greater redemption or prize-claiming restrictions than entries obtained through any other method. Instructions for the free AMOE are disclosed on the Platform, and the Company processes all valid AMOE submissions promptly.

The Company electronically logs AMOE submissions and retains such records for a minimum of three (3) years.

The Company may limit, reject, or void entries (including AMOE entries) to prevent abuse, including bulk, automated, scripted, or duplicative submissions.

31. Odds of Winning

Odds depend on the number of eligible entries and the mechanics of the specific promotion.

Odds are never affected by payment. Purchasing does not improve any participant's chances of winning, and free entrants compete on identical terms with all other entrants.

32. Winner Determination and Verification

Potential winners are subject to verification.

No participant is a winner until verification is complete.

Failure to comply results in forfeiture.

33. Prize Substitution, Limits and Fulfilment

Prizes may be substituted for items of equal or greater promotional value.

Delays may occur for compliance or logistical reasons.

Jurisdictional prize limits. In Florida (and in any other jurisdiction imposing equivalent requirements), the maximum redemption value of any prize won on any one spin, play, or entry is five thousand US dollars (USD 5,000). Any prize valued in excess of USD 5,000 will be reduced to a maximum value of USD 5,000, and no amount above that limit will be allocated or paid. The Company may impose equivalent limits in other jurisdictions where required to avoid registration, bonding, or similar regulatory obligations.

The Company maintains records of winner determinations, prize awards, and sweepstakes administration in accordance with applicable law.

34. Publicity Release

Where permitted by law, participants grant the Company the right to use:

• username;
• non-identifying likeness;
• prize information;
• general location.

Such use may be for promotional and compliance purposes without additional compensation.

35. Release of Claims

Participants release the Company from all claims arising from:

• participation;
• eligibility determinations;
• verification outcomes;
• redemption delays;
• technical issues;
• administrative decisions;
• Packy Cash treatment;
• Promotional Reward expiry;
• challenge prize determinations.

36. Assumption of Risk

Participants assume all risks associated with participation.

37. Disclaimer of Warranties

The Platform is provided "AS IS" and "AS AVAILABLE".

No warranties are made regarding outcomes, availability, balances, Packy Coins, Packy Cash, rewards, redemptions, or challenge prizes.

38. Limitation of Liability

To the maximum extent permitted by law:

• the Company shall not be liable for indirect or consequential damages;
• total liability shall be capped at the greater of EUR 100 or rewards received in the prior 12 months.

39. Indemnification

Users agree to indemnify the Company from all claims arising from violations or abuse.

40. Binding Arbitration

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS.

To the fullest extent permitted by applicable law, any dispute, claim, or controversy arising out of or relating to these Terms, the Platform, any Virtual Units, Packy Coins, Packy Cash, Sweepstakes, rewards, redemptions, challenge prizes, or the relationship between you and the Company (each, a "Dispute") shall be resolved exclusively through final and binding arbitration, and not in a court of law.

This arbitration agreement is governed by the United States Federal Arbitration Act, 9 U.S.C. §§ 1–16, and evidences a transaction involving interstate commerce.

Arbitration shall be conducted on an individual basis only and not as a class, collective, consolidated, or representative action.

The arbitration shall be administered by the American Arbitration Association, AAA, in accordance with its Consumer Arbitration Rules then in effect, unless the parties mutually agree otherwise.

Unless otherwise required by law, the seat of arbitration shall be New York, New York, USA, and arbitration proceedings shall be conducted in English.

The arbitrator shall have exclusive authority to resolve any Dispute, including issues relating to the interpretation, applicability, enforceability, or formation of this arbitration agreement.

Judgment on the arbitral award may be entered in any court of competent jurisdiction.

This arbitration provision shall survive termination of your Account and/or these Terms.

Opt-Out Right

You may opt out of this arbitration agreement by sending written notice to the Company within thirty (30) days of creating your Account.

Your notice must include your full name, registered email address, and a clear statement of intent to opt out of arbitration.

Failure to opt out within this period constitutes acceptance.

41. Class Action Waiver

To the maximum extent permitted by law, you agree that:

• you may bring Disputes against the Company only in your individual capacity;
• you waive any right to participate in a class action, collective action, representative action, or private attorney general action.

If any portion of this waiver is found unenforceable, the arbitration agreement shall nevertheless remain in full force and effect.

42. Governing Law

Cyprus law applies, subject to mandatory consumer protections.

U.S. arbitration law applies where required.

43. Severability, Waiver & Entire Agreement

Invalid provisions do not affect the remainder.

Failure to enforce is not a waiver.

These Terms constitute the entire agreement.

44. Intellectual Property Disclaimer

Any references to third-party brands, characters, or assets are used for descriptive or illustrative purposes only.

The Platform is not affiliated with, endorsed by, or sponsored by any third-party intellectual property owner.

Users acknowledge that all Platform mechanics operate independently of any such third-party entities.

Without limiting the foregoing, the Platform is an independent platform and is not affiliated with, endorsed by, sponsored by, or connected to The Pokemon Company, Nintendo, Creatures Inc., GAME FREAK, or any of their subsidiaries or affiliates. Pokemon names, characters, images, logos, and trademarks are the intellectual property of their respective owners and are used for descriptive and thematic purposes only. The Platform is not an official Pokemon product or service.

45. Source of Funds, Balance Sources, and Wagering Eligibility

The Platform reserves the right, at its sole discretion, to determine whether and to what extent activity generated from specific balance sources counts toward rewards, promotions, VIP progression, leaderboard qualification, wagering requirements, cashback, rakeback, challenge qualification, redemption eligibility, or any other incentive program.

Balances or Virtual Units originating from bonuses, promotional credits, Packy Cash grants, cashback, leaderboard prizes, rewards, challenge prizes, airdrops, affiliate commissions, refunded amounts, or any other non-purchased or non-deposited funds may be excluded from, or assigned a reduced weighting toward, such calculations.

Packy Coins are not redeemable and cannot be used as the source of rewards, prizes, cashback, rakeback, leaderboard prizes, challenge prizes, or redemptions.

Only Packy Cash may be eligible as the source of rewards, prizes, cashback, rakeback, leaderboard prizes, challenge prizes, or redemptions, and only where expressly permitted by the Platform and subject to these Terms.

The Platform may modify the eligibility, weighting, or treatment of wagering activity, gameplay activity, challenge activity, or promotional activity derived from any balance source at any time without prior notice.

46. Onsite Challenge Prize Eligibility

To be eligible to claim any prize, reward, or payout from onsite challenges, including but not limited to "Hit Card" and "Upgrader" challenges, each qualifying play, bet, wager, or activity must be completed using Packy Cash in raw, non-borrowed balance mode.

Wagers, plays, or activity placed using Packy Coins, demo mode, battle mode, borrowed balance mode, test mode, or any other unsupported mode shall not qualify toward onsite challenge completion, onsite challenge progression, or onsite challenge prize claims.

For the Upgrader challenge, only qualifying activity completed with Packy Cash in raw, non-borrowed balance mode shall count toward challenge completion or prize eligibility.

Any reward, prize, payout, cashback, rakeback, leaderboard prize, or challenge prize connected to an onsite challenge may only be awarded from Packy Cash and remains subject to verification, compliance review, eligibility review, abuse review, and these Terms.

The Platform reserves the right, at its sole discretion, to review, withhold, freeze, reduce, cancel, or deny any onsite challenge prize where it detects or reasonably suspects:

• abuse;
• fraud;
• manipulation;
• exploitation of challenge mechanics;
• coordinated activity;
• balance source abuse;
• low-risk wagering;
• borrowed balance abuse;
• demo mode abuse;
• battle mode abuse;
• any other conduct intended to gain an unfair advantage.

The Platform's determination regarding onsite challenge eligibility, qualifying activity, balance source treatment, prize approval, prize denial, or abuse shall be final and binding to the maximum extent permitted by law.

47. Promotional Reward Expiry and Claim Windows

All Promotional Rewards are time-limited, discretionary, promotional benefits. A Promotional Reward that is not claimed within its applicable claim window expires automatically and is forfeited in full, without notice, compensation, restoration, or substitute benefit.

Unless expressly stated otherwise for a specific promotion, the following claim windows apply, in each case measured from the time the relevant reward becomes available to claim in the user's Account:

• Rakeback — daily: must be claimed within three (3) days;
• Rakeback — weekly: must be claimed within three (3) days;
• Rakeback — monthly: must be claimed within three (3) days;
• Race prizes: must be claimed within three (3) days of the conclusion of the relevant race;
• Leaderboard prizes: must be claimed within five (5) days of the conclusion of the relevant leaderboard period;
• Reload bonuses and balance rewards: must be claimed within three (3) days.

Instant rakeback claims. Where the Platform offers an instant claim option, users may elect to claim accrued rakeback immediately, in which case the claimable amount is seventy percent (70%) of the accrued value. By electing an instant claim, the user irrevocably waives the remaining thirty percent (30%), which is forfeited without compensation. Waiting for the scheduled daily, weekly, or monthly payout does not guarantee any particular amount, and all rakeback remains subject to these Terms.

The Company may amend, extend, shorten, suspend, or withdraw any claim window, expiry period, or reward mechanic at any time, with or without notice. Expired Promotional Rewards will not be restored, re-credited, or compensated under any circumstances, including where a user was unable to claim due to account restriction, verification review, technical issues, or absence from the Platform. All Promotional Rewards remain subject to verification, compliance review, anti-abuse review, balance source rules, and every other provision of these Terms, both before and after being claimed.

48. Deposit Bonuses

The Platform may, at its sole discretion, offer promotional deposit bonuses granted as Packy Cash in connection with qualifying purchases or deposits.

Unless expressly stated otherwise for a specific promotion:

• the maximum deposit bonus is five percent (5%) of the qualifying deposit amount;
• deposit bonuses are capped at twenty US dollars (USD 20) (or its equivalent) per rolling six (6) hour period; and
• deposit bonuses are capped at eighty US dollars (USD 80) (or its equivalent) per rolling twenty-four (24) hour period.

Deposit bonuses are discretionary promotional benefits, not entitlements. The Company may modify, reduce, cap, suspend, withhold, or discontinue deposit bonuses, whether generally, for specific promotions, or for individual users, at any time, with or without notice and without compensation.

Without limiting the foregoing, the Company may remove, reverse, void, or recover any deposit bonus, together with any Packy Cash, balances, winnings, rewards, or benefits derived directly or indirectly from it, where the Company determines or reasonably suspects, at its sole discretion:

• fraudulent activity of any kind;
• abusive wagering behaviour, including low-risk wagering, hedging, wash activity, or artificial volume generation (Section 9.3);
• bonus farming, structuring of deposits, or coordinated or multi-account activity (Sections 9.2 and 20);
• any other breach of these Terms.

Deposit bonuses are granted as Packy Cash and remain subject to all provisions of these Terms applicable to Packy Cash, including wagering or participation requirements, balance source rules (Section 45), expiry (Section 47), verification, and compliance review.

49. Payments, Billing and Payment Processing

49.1 Accepted Payment Methods

The Platform may accept payment through credit cards, debit cards, Apple Pay, Google Pay, Cash App Pay, cryptocurrency, and such other payment methods as the Company makes available from time to time. The Company may add, remove, restrict, or condition any payment method at any time, generally or for individual users, without notice or compensation.

Every payment on the Platform is a purchase of entertainment Virtual Units (Section 4). No payment constitutes a deposit of funds, the creation of stored value, or the opening of a financial account of any kind.

49.2 Payment Processors

Payments are processed by one or more independent third-party Payment Processors. The Company does not itself receive, store, or process full payment card numbers.

You acknowledge that Payment Processors, card networks, digital wallet providers, and acquiring banks act independently of the Company and may, at their own discretion, decline, delay, hold, flag, reverse, or refuse any transaction, impose their own verification or security requirements, or suspend processing generally. The Company is not responsible for, and has no control over, such determinations.

Transactions made through Apple Pay, Google Pay, or Cash App Pay are additionally subject to the terms, conditions, and privacy policies of the respective wallet provider. Apple, Google, and Block, Inc. (Cash App) are not sponsors of, and are not affiliated with, the Platform or any Sweepstakes.

49.3 Payment Authorization and Verification

By submitting a payment, you represent and warrant that you are the lawful holder of the payment method used, that you are authorised to use it, and that sufficient funds or credit are available. The Company and its Payment Processors may carry out payment verification measures at any time, including card issuer verification, address or CVV verification, 3-D Secure or equivalent strong customer authentication, device and velocity checks, and requests for proof of payment method ownership. A transaction may be declined, held, or reversed where verification is not completed to the satisfaction of the Company or its Payment Processors.

An authorization hold may be placed on your payment method when a transaction is initiated. An authorization hold is not a completed charge; the hold may remain visible on your statement for several days depending on your card issuer, and the Company has no control over the timing of its release.

49.4 Failed, Reversed, Duplicate and Incorrect Payments

Where a payment fails, is declined, or is reversed, any Virtual Units, Packy Coins, Packy Cash, bonuses, entries, or benefits credited in reliance on that payment may be immediately voided, removed, or recovered, including from winnings or balances derived from them.

Where a duplicate charge or an incorrect charge amount occurs due to a processing error, the Company will, upon verification, refund the duplicate or excess amount to the original payment method in accordance with the Refund Policy. Errors do not create any entitlement beyond correction of the error (Section 22).

49.5 Chargebacks and Payment Disputes

If you believe a charge is incorrect or unauthorised, you must contact [email protected] before initiating a chargeback or payment dispute, so the matter can be reviewed and, where justified, refunded directly.

Initiating a chargeback or payment dispute in respect of a delivered purchase, without first contacting the Company, or where the underlying transaction was authorised, constitutes a material breach of these Terms. In such cases the Company may immediately:

• suspend or terminate the Account and any associated Accounts;
• void, forfeit, or recover Virtual Units, Packy Coins, Packy Cash, Promotional Rewards, entries, prizes, and any balances or winnings derived from the disputed transaction;
• withhold pending redemptions pending resolution of the dispute;
• recover from any Account balance an amount corresponding to the disputed transaction and any associated fees; and
• share relevant transaction, device, and account information with Payment Processors, card issuers, banks, and fraud prevention services for the purpose of contesting the dispute and preventing fraud.

Nothing in this Section limits any right you may have under applicable law or card scheme rules to dispute a genuinely unauthorised transaction.

49.6 Payment Fraud and Stolen Payment Methods

The use of stolen, counterfeit, or unauthorised payment methods, the use of another person's payment method without lawful authority, and any other form of payment fraud are strictly prohibited and constitute a material breach of these Terms. Where the Company detects or reasonably suspects payment fraud, it may immediately freeze or terminate the relevant Account(s), void all associated Virtual Units, Promotional Rewards, and redemptions, refund transactions to the original payment method, and report the matter to Payment Processors, financial institutions, and law enforcement authorities. The Company cooperates fully with card issuers and law enforcement in the investigation of payment fraud.

49.7 Refunds to Original Payment Method

Any refund the Company issues, whether under the Refund Policy, as a compliance measure (Section 26), or otherwise at its discretion, will be made only to the original payment method used for the relevant transaction. The Company does not make refunds to a different card, account, wallet, or person, except where the original payment method no longer exists and applicable law requires an alternative.

49.8 Processing Delays and Provider Outages

Payment processing times depend on Payment Processors, card issuers, banks, and network conditions. The Company is not liable for delays, outages, downtime, or failures of any Payment Processor, card network, digital wallet, banking system, or cryptocurrency network, and such events do not create any entitlement, claim, or right against the Company. Where a payment method or Payment Processor becomes unavailable, the Company may suspend the affected payment functionality without notice or compensation.

49.9 Fees, Currency and Taxes

Your card issuer, bank, or wallet provider may impose its own fees, including foreign transaction or currency conversion fees, which are your sole responsibility. Prices may be displayed in USD or other currencies; the amount charged may vary with exchange rates and issuer practices. All applicable taxes on purchases are your responsibility except where the Company is required to collect them.

Schedule A — Restricted Jurisdictions

The Company does not offer the Platform or any services to persons located in, resident in, or accessing the Platform from the following jurisdictions. This Schedule may be amended by the Company at any time without notice.

United States — Restricted States

• Washington
• Nevada
• Michigan
• Idaho
• New Jersey
• Montana
• Connecticut
• California
• New York

Sanctioned or Embargoed Jurisdictions (including sanctioned regions and persons)

• Afghanistan
• Belarus
• Cuba
• Iran
• North Korea
• Russia
• Syria
• Venezuela (sanctioned regions and persons)
• Crimea region
• Donetsk region
• Luhansk region
• Sevastopol region

High-Risk Jurisdictions

• Myanmar
• Yemen
• Sudan
• South Sudan
• Democratic Republic of the Congo
• Haiti
• Somalia
• Lebanon

In addition, the Platform is not available to any person listed on any applicable sanctions or watchlist administered by the European Union, United Nations, OFAC, HM Treasury, or any other competent authority, regardless of location.

Accounts, entries, Virtual Units, Promotional Rewards, or redemptions connected to a Restricted Jurisdiction are subject to the enforcement measures set out in Section 6.3.

Last Updated: 22 July 2026