Please read this information carefully for your own benefit.

Grattiano is operated by 3-102-944465 SRL, a company registered in Costa Rica with company number 3-102-944465 and registered address at Provincia 01 San Jose, Canton 01 San Jose, Distrito Carmen, Barrio Escalante, Avenida Siete, Calle Veintinueve, Edificio Dos Mil Novecientos Diez, Costa Rica, which is licensed and regulated by the Tobique Gaming Commission to offer services under license number 0000175 in accordance with the Tobique Gaming Act 2023.

This Policy should be read together with the Terms and Conditions, the AML/KYC Policy and any other applicable player-facing policies made available on the Website.

Customer support team is available at [email protected]

We have designated a person within our organisation responsible for Responsible Gaming. Until a dedicated Responsible Gaming Officer is appointed, this role is fulfilled by our Compliance Officer. This person reports to our management team at least once every twelve (12) months on the effectiveness of this Policy and related operational procedures, and provides recommendations for improvement. Any material changes to this Policy are reported to the Commission.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions.

The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of these Terms and Conditions:

Account means a unique account created for You to access our Service or parts of our Service.

Website refers to Grattiano.

Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to 3-102-944465 SRL.

Service refers to the Website.

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Commission means the Tobique Gaming Commission.

Vulnerable Person means a person who: (a) is under eighteen (18) years of age; (b) has no, or insufficient, control over their gambling behaviour, because of which they are, or threaten to become, addicted to one or more games of chance and, as a result, may cause harm to themselves or to other people; (c) has been banned from playing any game of chance, either by force or at their own request; or (d) has been declared bankrupt.

AML/KYC Policy means our Anti-Money Laundering and Know-Your-Customer policy, available on the Website.

Responsible Gambling

Gambling means for the majority of our Users, entertainment, fun and excitement. But we also know that for some of our Users gambling has negative side effects. Pathological gambling has been recognized as a serious illness in medical science for many years.

Since day one, we have been aware of this issue and try our best to help. Under “Responsible Gambling” We understand multiple steps of measures, with which a gambling provider can help to lower the possibility of negative side effects appearing. In case they already appear we also try to take active steps against them.

The most important instrument against negative side effects from gambling are knowledge and education about the risks of gambling to support our Users self-control in order to make sure they do not suffer from negative side effects.

We maintain responsible gaming procedures and may apply responsible gaming measures, account reviews, player interactions, deposit limits, cooling-off, self-exclusion, operator-initiated restrictions or other measures where we consider this necessary or appropriate to protect Vulnerable Persons, promote responsible gaming, prevent gambling-related harm, or comply with applicable law, Commission requirements or regulatory instruction. We do not offer credit for wagering.

We monitor account activity and gambling patterns, including deposit and wagering frequency, repeated failed transactions, withdrawal cancellations, unusually extended play sessions, and frequent changes to Responsible Gaming tools, in order to identify Users who may be at risk. Where our staff or systems identify indicators of possible problem gambling, We follow an internal, documented process, which may include a direct conversation with the User, informing the User of available Responsible Gaming tools, applying deposit limits, temporarily suspending the Account, or, in cases of severe or persistent risk, permanently excluding the User.

Responsible Gaming measures will never be used as a pretext to delay or prevent legitimate withdrawals.

A clear link to this Responsible Gaming Section is available on the homepage of the Website and within your Account area. This Policy is also referenced in our Terms and Conditions. Responsible gaming information and tools, including deposit limits, cooling-off and self-exclusion, are available on the Website and may also be accessed or requested through Customer Support. Our Support is available via email or live chat at all times without any additional costs for you: email: [email protected]. Our Support will of course not give out any information about You without Your consent to anyone else. Customer Support will not disclose information about You to third parties, except where required or permitted under these Terms, this Policy, applicable law, Commission requirements or regulatory instruction, or where We consider such disclosure necessary or appropriate for AML/CFT/CPF, responsible gaming, safety, security, fraud-prevention, complaint-handling, dispute-resolution, enforcement or other compliance purposes, including but not limited to disclosures to the Tobique Gaming Commission, competent authorities, regulators, law-enforcement bodies or any other relevant persons or entities.

We make self-assessment information and responsible gaming resources available through the Website, including access to Your available gaming and deposit history for at least the last six months. Longer periods of transaction history may be requested from us and will be provided within 10 working days. You are encouraged to review Your gambling behaviour regularly and to use the available responsible gaming tools where appropriate.

You are encouraged to complete the Gamblers Anonymous 20-question self-assessment (available at https://gamblersanonymous.org/20-questions/) or the CAGE Questionnaire (Adapted for Gambling), which asks whether you have ever felt you should cut down on your gambling, felt annoyed by criticism of your gambling, felt guilty about your gambling, or needed to gamble as a morning “eye-opener” to recover from previous losses.

If your answers raise concerns, You should consider taking a break, using deposit limits, cooling-off or self-exclusion tools, or contacting Customer Support or independent responsible gambling support organisations for assistance.

You can also take a self-test at: https://www.begambleaware.org/gambling-problems/do-i-have-a-gambling-problem/, and find additional information about gambling addiction at: https://www.begambleaware.org/safer-gambling/

Helpful hints for responsible gambling at Grattiano:

Set yourself a deposit limit: You may set deposit limits through the available responsible gaming tools or by contacting Customer Support, as applicable, for daily, weekly or monthly periods. Once a limit is reached, You will not be able to deposit further funds until the relevant period resets. You may make a limit more restrictive at any time with immediate effect; a request to make a limit less restrictive is subject to a 24-hour waiting period before it takes effect. Before you start gambling think about how much you can afford to gamble with according to Your financial situation. Play with amounts which are for fun and for Your entertainment.

Do not try to win back a loss at every cost: Try to not take too huge risks to win back what You lost before at any cost. Play for Entertainment and not to earn money.

Set yourself a time limit: Set yourself a time limit and do not break it. Keep in mind gambling should stay in balance with your other hobbies and not be Your only hobby.

Play smart: It is smarter to not play, when You are extremely stressed, depressed or under too much pressure. Also do not play when you are under the influence of medications, drugs or alcohol.

Take breaks: You should take breaks when You notice, that You get tired or can’t concentrate anymore.

Only one account: To make it easier to have an overview how much time and money You spend on gambling it is highly advised to not create more than one Account per Person.

You may request a temporary cooling-off period through the available responsible gaming tools, for a duration of 24 hours, 7 days, 1 month or 3 months. During a cooling-off period, access to gambling activity is restricted for the selected period, while account administration and withdrawals may continue, subject to these Terms, AML/KYC checks and applicable law. You may also choose to opt out of marketing communications for the duration of the cooling-off period.

Cooling-off restrictions take effect immediately once selected. Your Account is automatically reactivated once the selected period ends, and no further action is required from You. We will not question Your decision, offer bonuses or promotions to encourage You to continue playing, or delay or complicate the activation process.

Age Verification

We verify Your age and identity during account registration, requiring self-attestation of your date of birth and confirmation, via a designated checkbox, that You are over 18. Further checks, including a government-issued ID check, are carried out on reaching specified thresholds and in any case prior to your first withdrawal, in accordance with our KYC and AML policies. We may also verify Your age and identity at any other time where required or considered appropriate. If We become aware that You are underage or otherwise not permitted to use the Service, Your Account will be closed immediately: any deposits You have made will be refunded to You, any winnings will be forfeited, and We will clearly communicate to You the reason for the closure.

To use our Service, You have to be 18 years or older. To avoid abuse, keep Your login data safe from any minors near You.

Principally we recommend a filter program to avoid minors, especially children, to access any content on the internet, which is not healthy for them.

For parents and guardians, we recommend safeguarding usernames, passwords and payment details when sharing devices with minors. Third-party software that helps restrict access to gambling websites specifically is also available, for example: BetBlocker (betblocker.org), GamBlock (gamblock.com) and Gamban (gamban.com).

In case You are diagnosed with a gambling addiction or try to stay away from gambling for a different reason, we want to assist you to stay away from anything, that does nothing good for you. “Self-Exclusion” means, that You exclude yourself, out of Your own choice, from all gambling services across all Accounts, brands and domains operated under our licence.

You may initiate and complete the self-exclusion process fully online through the available responsible gaming tools, without needing to contact Customer Support or obtain our approval, for a period of 1 year, 3 years, 5 years, 10 years, or for life, with a minimum period of one (1) year. Only in exceptional cases may You request self-exclusion by email or chat, in which case the selected option will be enabled within 24 hours.

Please keep in mind that once applied, Self-Exclusion is irreversible and irrevocable for the applicable exclusion period and will not be undone for Your own protection. After the self-exclusion period ends, You must submit a written request (by email or chat) to reactivate Your Account; We will not initiate contact to prompt Your return during or after the exclusion period.

Customer support: [email protected]

During Self-Exclusion, You must not create or use another Account or attempt to circumvent the exclusion. We may use reasonable measures to identify duplicate accounts and may close, restrict or block accounts, block known payment methods where appropriate, cancel access, withhold winnings, void related activity, stop direct marketing and take any other action available under the Terms, applicable law, AML/CFT/CPF requirements, Commission requirements or regulatory instruction. Every attempt to create a new Account during Self-Exclusion is a violation of these Terms and may result in the permanent ban of Your original Account.

We may exclude You from the Service as a high-risk intervention measure where You display problematic gambling behaviour or engage or attempt to engage in criminal activity through the Website. We will not exclude You solely on the basis of the amount of Your winnings. Operator-initiated exclusions are documented, and records are retained for at least five (5) years and may be requested by the Commission at any time.

Our marketing and advertising will not target Vulnerable Persons, will not portray gambling as a way to achieve financial success or solve financial difficulties, will not suggest that skill can influence the outcome of games based purely on chance, will not portray gambling as a substitute for financial, emotional or mental well-being, and will not associate gambling with alcohol, drugs, or other harmful behaviours. Our marketing materials do not feature minors and will not contain sexually explicit content. Bonuses and promotions are communicated with clear terms and are not used to encourage excessive gambling. All advertising includes a visible responsible gaming message. Any third party engaged to promote the Website, including affiliates, sponsorships or influencers, is made aware of this Policy and required to adhere to it.

Our customer support and Responsible Gaming staff are trained to recognise signs of gambling distress, to conduct sensitive and structured conversations with Users who may be at risk, and to direct Users to the appropriate Responsible Gaming tools and support resources described in this Policy.

In accordance with Commission requirements, the footer of the Website’s homepage and app displays: a clear indication that under-age gambling is prohibited; the name and registered address of 3-102-944465 SRL; our Commission license number; a statement confirming Commission regulatory oversight; a link to this Responsible Gaming Section; our Commission digital seal; and direct links to gambling addiction support resources, including Gamcare, Gamblers Anonymous and Gambleaware.