Responsible Gaming

Our Commitment

We are committed to promoting responsible gambling and providing a safe and enjoyable environment for our players. Gambling should always be a form of entertainment — not a way to make money or solve financial problems.
We support measures that help prevent gambling-related harm and take reasonable measures to ensure that our platform is not accessible to minors or vulnerable individuals.

No Underage Gambling

Participation in gambling activities on this website is strictly prohibited for persons under the age of 18.
We use age verification tools and reserve the right to request proof of age at any time.
If we discover that a person under 18 has used our services, any winnings will be forfeited and any deposits will be refunded, subject to applicable law and our legal obligations.

Signs of Problem Gambling

Gambling may become a problem if it causes financial distress or affects your daily life. Ask yourself:

• Do you spend more than you can afford on gambling?
• Do you hide your gambling from others?
• Have you tried to stop gambling but couldn’t?
• Do you chase your losses or gamble to escape problems or a low mood?
• Have you borrowed money or sold things to gamble?

If you answered “yes” to any of these, you may be at risk.

Need Help?

If you or someone you know may have a gambling problem, we encourage you to seek help. The following independent organizations offer free and confidential support.
Important Notice. The list below is provided for informational purposes only and does not constitute a list of jurisdictions in which access to our gambling services is permitted. If your country is not listed below and you are seeking help or more information about responsible gambling, please feel free to contact our Customer Support team. We are here to help.

International Support

• BeGambleAware (https://www.begambleaware.org/)
  UK-based organization offering advice and support.
• Gambling Therapy (https://www.gamblingtherapy.org/)
  Provides multilingual help and online support worldwide.
• GamCare (https://www.gamcare.org.uk/)
  Helpline
• Gamblers Anonymous (https://www.gamblersanonymous.org/)
  Support groups worldwide for those affected by gambling.

Parental Controls

If you share your device with minors, consider using parental control software to block access to gambling sites:
 • Net Nanny (https://www.netnanny.com/)
 • Qustodio (https://www.qustodio.com/)
 • GamBlock (https://www.gamblock.com/)

Transparency and Compliance

We operate in line with the AML/CFT and Responsible Gambling obligations under our license, including screening customers for age, risk factors, and responsible play indicators.

Your safety is our priority.

1. Introduction

This Policy for safeguarding the responsible offering of Games of Chance (the “Policy”) has been adopted and implemented by the Operator according to the National Ordinance of the 20th of December 2024 Containing Rules concerning Games of Chance (National Ordinance on Games of Chance of Curacao) (the “LOK”) and the Responsible Gaming Policy for Licensed Operators (Version 1.0) adopted by Curacao Gaming Authority on the 17th of April, 2025) (the “Responsible Gaming Policy”).
The purpose of this Policy is to integrate Responsible Gaming principles into the Operator’s business model, ensuring that gambling remains an enjoyable form of entertainment rather than a source of harm. The Policy includes proactive steps and processes to protect Vulnerable Persons, promote responsible gambling along with mitigation or prevention of problem gambling behaviour. As a general principle no credit can be offered to players for the purpose of wagering.
This Policy is aimed to support that: a) players can play in a safe and secure environment; b) Games of Chance are fair and clear to players; c) reasonable measures are taken to prevent Vulnerable Persons from playing Games of Chance; d) players can limit or discontinue their playing of Games of Chance where such playing threatens to become an addiction for them. 
This Policy includes provisions to prevent Vulnerable Persons from playing Games of Chance, including: a) general information about gaming addiction made available to gamblers; b) Vulnerable Person identification procedures; c) measures in place to prevent excessive gaming or the threat of excessive gaming.

2. Definitions

In this Policy the capitalized terms have the following meanings: 

Curaçao Gaming Authority or CGA means Stichting Gaming Control Board (Gaming Control Board Foundation), formed by notarial deed of April 19, 1999, either under this name or under any adjusted name in the event of amendment of its articles of association.

Games of Chance means any game in which one or more players, in exchange for the payment of money or monetary value, compete for prizes in the form of money or monetary value, and the outcome of which is determined either by chance only or by a combination of chance and players’ insight or skill, with no possibility for players to significantly influence the outcome, including sports betting and poker.
LOK is the National Ordinance on Games of Chance law of Curacao.

Marketing, promotion and advertising refer to all resources, messages and media that promote the Operator’s domain(s), brand(s), products, or services. This includes but is not limited to print and other media advertising content marketing, digital marketing, and social media campaigns.
Mandatory Requirements are the basic elements of the Policy.
Minor means any person under the age of 18.

Operator  means Progress Path Co N.V. (company number 164185, registered address Seru Loraweg 17C, Willemstad, Curaçao) which is licensed by the Curaçao Gaming Authority since 15/May/2026 to offer games of chance under
license number OGL/2024/1113/0517 in accordance with the National Ordinance on Games of Chance (LOK)

Vulnerable Person means a person who:
i. is under eighteen years of age;
ii. has no, or insufficient, control over his or her gambling behavior, because of which he or she is, or threatens to become, addicted to one or more Games of Chance and, as a result, may cause harm to himself or herself or to other people;
iii. has been banned from playing any Game of Chance either by force or at his or her own request;
iv. has been declared bankrupt, or has otherwise lost the control or disposal of all or part of his or her property.

Other capitalized terms not expressly defined herein are to be interpreted according to LOK, Responsible Gaming Policy, or general industry practice. 

3. Mandatory Requirements

This Policy includes the following mandatory Responsible Gaming elements for operational compliance with the CGA gaming license:

1.    Age verification (Section 4)
2.    Information accessibility (Section 5)
3.    Player self-assessments (Section 6)
4.    Behaviour tracking (Section 7)
5.    Consumer Advertising and Marketing (Section 11)
6.    Training of employees (Section 10)

The Operator commits to appointing a responsible person who fulfils the Responsible Gaming role. Unless/until there is a person dedicated to Responsible Gaming endeavours, the Compliance Officer is responsible for implementing and enforcing this Policy and whoever fulfils the role must provide a report to the Operator’s management team at least once every twelve (12) months as to the effectiveness of the Policy and related operational procedure. The report shall provide recommendations for management as to any proposed operational or policy enhancements. Any material changes to the Responsible Gaming policy will be reported to the CGA.

4. Prevention of underage gambling 

Age verification

According to Article 1.4(d) of the LOK, it is prohibited to allow a minor the opportunity to participate in Games of Chance.
The Operator undertakes to implement rigorous age verification processes to ensure that all participants are of legal gambling age.
During the account registration process, the Operator obligates to verify that the player is not a minor. This begins with self-attestation, where the player is required to enter their date of birth and confirm they are over 18 by selecting a designated checkbox and additional checks must be carried out to gain sufficient certainty that the individual is not a minor.
If at any point, notwithstanding the checks put in place, the Operator becomes aware that the player is a minor, the account will be closed immediately. The civil law implications of this action must be considered. These may include the obligation to refund all deposits made by the player and the forfeiture of any winnings. The Operator will clearly communicate the reason for the account closure to the minor.
Regardless of the above, proof of age document submission and checks are subject to the Operator’s  Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) and Customer due diligence (CDD) policies and should at a minimum include a government-issued valid ID check (such as a passport, national ID, or driver’s license) on reaching specified thresholds and in any case prior to first withdrawal.
Secondary verification methods such as electronic verification systems, payment validation, third party or government database checks, selfie verification, may be undertaken by the Operator at its own discretion, but do not supersede the government-issued document requirement.
The Operator will maintain records of all age verification processes and their outcomes. These records will be made available for regulatory review.

5. Self-Assessment 

Players can access their wagering and transaction history, including timestamps, in their account. Longer periods of transactions may be requested from the Operator and must be provided within 10 working days. 
Players are encouraged to regularly assess their gaming habits to determine whether their gambling remains within healthy limits by providing self-assessment tools that allow them to answer a series of questions designed to help identify potential problem gambling behaviours. These tools empower players to make informed decisions about their gambling activity.
The 20-question quiz test is available from Gamblers Anonymous published on its website https://gamblersanonymous.org/20-questions/  . 
Also, all players may use the scientifically recognized screening CAGE Questionnaire tool.

Players are encouraged to answer the following questions honestly:

C – Cut Down: Have you ever felt you should cut down on your gambling?

A – Annoyed: Have people annoyed you by criticizing your gambling habits?

G – Guilty: Have you ever felt guilty about your gambling?

E – Eye-Opener: Have you ever had a morning "eye-opener" to steady your nerves or recover from gambling losses?

Interpreting the Results
•    0 Yes Answers: Low risk for gambling problems.
•    1 Yes Answer: Moderate risk; further assessment may be needed.
•    2 or More Yes Answers: High risk; further evaluation and intervention are strongly recommended.
Any player who recognizes problematic gambling behaviours through self-assessment should explore the available responsible gambling tools.
 

6. Procedures for Player Identification and Intervention

The Operator will have a structured and documented process for responding to identified indicators of problem gambling. This process must include the following components:
Player Profiling and Risk Assessment
•    A risk-based approach will be adopted to determine the appropriate level of monitoring and intervention.
•    All Responsible Gaming interactions—whether initiated by the player or the Operator—will be recorded in the Player Account Management (PAM) system, along with the indicators of concern and any actions taken.

Responsible Gaming Interventions
•    Players identified as exhibiting at-risk behaviour will be informed of the Responsible Gaming tools available, such as deposit limits, cooling off, and self-exclusion options.
•    The Operator will follow a clear escalation protocol where appropriate, which may include:
o    Temporarily suspending the account pending further assessment.
o    Permanently excluding the player in cases of severe or persistent risk.

•    Under no circumstances will the Operator use Responsible Gaming measures as a pretext to prevent or delay legitimate player withdrawals. 

7. Training and Staff Readiness 

The Operator undertakes to train customer service and Responsible Gaming staff to manage player interactions professionally and effectively.
Training will cover:
-    Recognizing signs of gambling distress (e.g., agitation, aggression, or financial desperation).
-    Conducting sensitive and structured conversations with at-risk players.
-    Directing players to appropriate support resources and Responsible Gaming tools.

8. Consumer Advertising and Marketing

The Operator undertakes not to engage in irresponsible advertising.
•    No Targeting of Vulnerable Groups – Marketing including visual content must not directly target Vulnerable Persons.
•    No Portrayal of Gambling as an Investment – Advertising must not promote gambling to achieve financial success or solve financial difficulties.
•    No Misrepresentation of Skill vs. Chance – Marketing must not suggest that skill can influence the outcome of games that are purely based on chance.
•    No Emotional Manipulation – Advertising must not portray gambling as a substitute for financial, emotional, or mental well-being.
•    Marketing materials must not feature minors or depict them engaging with gambling content.
•    No Explicit content – Adverts, messaging or any communications must not contain any overt sexual or pornographic imagery or suggestion.
•    No Encouragement of Unrelated Harmful Behaviours – There must be no linkage between gambling and smoking, drug use, alcohol consumption, seduction, or enhanced attractiveness.
•    Bonus Conditions:
- Bonuses and promotions must be communicated transparently with clear terms and conditions.
- Operators must not use bonuses to encourage excessive gambling.
•    Third Party Involvement: 
-    The Operator is responsible for materials provided to affiliates, representatives, sponsorships, ambassadors social media influencers, including wordings and visual representations, where the influencers actions and/or statements are paid placement or advertisement.
-    The operator must make any contracted third-party aware of their Responsible Gaming policy and require them to adhere to it.

•    Responsible Gaming Messaging – All advertising must include a clearly visible responsible gaming message or slogan.

9. Internet Filtering Tools

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Person, the Operator undertakes to initiate direct contact. This communication must advise the player to review the Responsible Gaming area and consider using the available tools and support services.