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Stake Poker Security & Ecology Policy

1. General

a. This Stake Poker Security & Ecology Policy (“SEP”) must be read in conjunction with the Stake.com Terms and Conditions and Card Room Rules, which together constitute a binding agreement (“Agreement”) between you (“User”) and Medium Rare N.V (“Stake”).

b. In case of any inconsistency between this SEP, the Terms and Conditions, the Card Room Rules, or any other rules applicable to Stake Poker, the resolution will follow this order of precedence: the Stake Poker Terms and Conditions; the Card Room Rules; this SEP; and any other rules applicable to Stake Poker.

c. This SEP is applicable to all poker games (excluding casino games) made accessible by Stake to the User on the Stake Poker page, collectively referred to as “Poker Games” or “Poker Game”, as applicable.

d. In this Agreement, words in the singular include the plural and vice versa.

e. Unless otherwise defined in this SEP, capitalized terms shall have the meanings given to them in the Terms and Conditions.

f. By playing any Poker Game the User:

(i) agrees to comply with the Terms and Conditions, the Card Room Rules, this SEP, and any other rules applicable to Stake Poker;

(ii) acknowledges that any breach of this Agreement may result in your Stake account being removed, restricted or suspended;

(iii) agrees to be bound by the decisions of Stake relating to or arising from the Poker Games, which are final and determinative; and

(iv) acknowledges that this SEP is designed to create and maintain a healthy ecology within Stake Poker, intended to provide a safe, fair and enjoyable playing environment for all Users, and based on the spirit of fair, safe and lawful competition.

2. Enforcement measures by Stake

a. To maintain a safe and fair environment, Stake utilizes server-side monitoring technologies, which may include services provided by its platform providers, and other internal processes, to detect and investigate Prohibited Activities and Behaviors or Prohibited Use of Auxiliary Tools or Services. This may include, but is not limited to, fraudulent transaction detection, automated registration and signup, detection of geo-location and IP masking, transactions and blockchain analysis.

b. In addition to the rights available to it under the Agreement, Stake may:

(i) given reasonable grounds to believe that a User is involved in any form of Prohibited Activities and Behaviors or Prohibited Use of Auxiliary Tools or Services, block and conduct a security check on any account at any time, even during gameplay, which may result in, but is not limited to, restricted access to the User’s account, cashiers, gameplay or rewards; and

(ii) following a thorough investigation into that User, based on accumulated information, data and evidence, and confirmation of any form of Prohibited Activities and Behaviors or Prohibited Use of Auxiliary Tools or Services, levy one or more penalties at its absolute discretion and as available to it depending on the applicable regulations in the applicable jurisdiction.

c. The penalties that Stake may levy for confirmed Prohibited Activities and Behaviors or Prohibited Use of Auxiliary Tools or Services by the User may include one or more of the following:

(i) issuing a written warning to the User;

(ii) restricting the Stake products or product types that the User may access, including Stake Poker;

(iii) temporarily suspending or permanently refusing the User access to any Stake product or product types, including Stake Poker;

(iv) temporarily or permanently refusing the User access to Stake; (v) removing or reducing the User’s promotional rewards; and (vi) confiscating any amounts paid or payable to the User by engaging in any Prohibited Activities and Behaviors or Prohibited Use of Auxiliary Tools or Services, including for the purposes of compensating affected individuals.

d. Users agree to cooperate fully and promptly with any security investigation conducted by Stake relating to Prohibited Activities and Behaviors or Prohibited Use of Auxiliary Tools or Services.

3. Prohibited Activities and Behaviors

Stake monitors and prohibits the activities and behaviors specified in this section 3 (“Prohibited Activities and Behaviors”) in relation to Stake Poker.

a. (Use of real-time assistance) The use of any external assistance in Poker Games which provides a User with an unfair advantage over their opponents, influences their decision-making in real time, or allows them to play in a manner they otherwise would not be able to replicate, including, but not limited to, charts, software, apps, websites, physical and digital reference materials. b. (Use of bots) The use of any software, programs, websites, or apps that enable playing a Poker Game without User intervention or reduce the requirement of a User to make decisions and/or execute actions, including, but not limited to, artificial intelligence, fully and partially automated bots, or any other tools that automate decisions or actions. c. (Collusion) Conspiring with another User to gain an unfair advantage in a Poker Game, sharing information about a User’s hand in a particular Poker Game while that Poker Game is still in play, or intentionally playing a User’s hand in a particular Poker Game in a non-aggressive manner against an opponent.

d. (Multi-accounting) Intentionally creating and/or using multiple accounts, participating in any game using multiple accounts, or participating in any freerolls or promotions using multiple accounts simultaneously.

e. (Bum hunting) Intentionally seeking out less experienced Users or avoiding more experienced Users, screening for and engaging certain Users, choosing to participate in a Poker Game when only specific Users are present, or otherwise targeting specific Users, including, but not limited to, by leaving a Poker Game shortly after certain Users depart, and/or resuming a Poker Game when certain Users are present.

f. (Data mining / mass data analysis) Any act that results in accumulation of hand histories other than a User’s own hand history, including, but not limited to, by using any third party tools to import and/or convert hand histories, and granting direct or indirect access to a User’s own Stake Poker data, including hand histories and tournament results, to another User.

g. (Chip dumping) Intentionally losing chips to another User, or accepting chips that are intentionally forfeited by another User.

h. (Trespassing) If a User’s account is prohibited from accessing Stake Poker, using a new or pre-existing account to access Stake Poker.

i. (Account sharing) Sharing a User account, or credentials in respect of a User account, with another individual.

j. (Hit and running) Leaving a Poker Game shortly after winning a significant pot, consequently depriving opponents of a chance to recover their losses, in consideration of the size of the pot, the number of hands played post-winning the pot, and the frequency of such behavior.

k. (Hacking) Gaining unauthorised access to a User account, including by compromising digital devices or networks.

l. (Predatory behavior) Any act of exploiting unethical advantages or engaging in exploitative tactics over other Users to gain undeserved benefits including, but not limited to, grimming, buttoning, ratholing, and other actions that defy the spirit of fair competition or may otherwise be considered unethical.

m. (Circumvention) Any manipulation of Stake Poker to circumvent any applicable security measures including, but not limited to, exploiting or attempting to exploit software bugs or features we offer within Stake Poker for financial gain.

n. (Enhanced enforcement for VIP cash games and tournaments) To the extent that the User is participating in a VIP cash game or tournament, any financial relationships with other Users which may impact the relevant Poker Games, including, but not limited to, staking, swaps, profit-sharing, bankroll sharing or off-client deals.

4. Prohibited Use of Auxiliary Tools or Services

a. Stake monitors and strictly prohibits the use of the following (“Prohibited Use of Auxiliary Tools or Services”) in relation to Stake Poker:

(i) any auxiliary tools or services that may facilitate Prohibited Activities and Behaviors, including, but not limited to, bots, VPNs, proxy servers, tools that share hole card information, ICM calculators, solver-type software, dynamic range software, seating scripts, virtual machines, remote control software and any tool enabling real-time advice during a Poker Game; and

(ii) any tools or services that provide the User with an unfair advantage over opponents, or are otherwise in violation of the Agreement.

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