TERMS & CONDITIONS OF USE

NATURAL8.COM

Last updated: 2021.01.16

END USER LICENCE AGREEMENT (“EULA”) FOR RUN GOOD N.V.: IMPORTANT – PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE PROCEEDING TO USE OUR SERVICES, AND/OR DOWNLOADING OUR SOFTWARE, AS YOUR AGREEMENT TO THEM CONSTITUTES A LEGALLY BINDING AGREEMENT. IT IS YOUR SOLE RESPONSIBILITY TO PERIODICALLY REVIEW THIS EULA AND YOUR CONTINUED USE OF THE SITE, AND ASSOCIATED SERVICES, CONSTITUTES YOUR ONGOING ACCEPTANCE OF THE TERMS CONTAINED HEREINAFTER.

Introduction

The following terms and conditions as updated by us from time to time and made available here (these “Conditions”) shall govern the relationship between “You” (“Your” also refers to You throughout this EULA) and Run Good N.V. and/or its group companies (together referred to in these Conditions as “we”, “us” or “our”) in relation to all use of software licensed by us to You, directly or indirectly, and Your play on game client downloaded from natural8.com (“Natural8”).

Natural8 is operated by Run Good N.V., reg #150149 of 9 Abraham de Veerstraat, Willemstad, Curacao. Natural8 is governed solely by the laws and courts of Curacao exclusively without exception.

Whether You use Natural8 and/or You are playing any game thereon (“Game(s)”) means that You accept these Conditions which are legally binding. If You do not agree to accept and be bound by the terms please do not open an account or continue to use the website or participate in the Games. These Conditions set forth the legally binding terms and conditions which are applicable to Your use of the Game or Natural8, however, accessed and/or used, whether via personal computers, mobile devices or otherwise. Please be reminded that these Conditions constitute an agreement between You and us and define the rights and responsibilities that You and we have with respect to the Games and Natural8. You represent and warrant that You have the right, authority and capacity to accept these Conditions and to abide by them and that You have fully read and understood these Conditions without any impairment in judgment.

By visiting, registering on natural8.com (“Website”) and/or continuing to use the Services You agree to be, and are, bound by:

these Conditions; and by accepting these Conditions You also accept our;

Privacy Policy;

Withdrawal Policy;

Cookie Policy (which sets out how we use personal information which You supply to us);

Security & Ecology Policy;

the House Rules; and

all such other of our terms and conditions, game rules, rules or policies as they relate to any applicable Game, promotions, bonuses, special offers or any other aspect of Your use of the Website from time to time.

In the event of any inconsistency between these Conditions and the House Rules, then, to the extent of the inconsistency, these terms and conditions shall prevail.

CHANGES TO THE TERMS AND CONDITIONS

1.1 We may need to change the Conditions for a number of reasons, including for commercial reasons, to comply with new laws or regulations or for customer service reasons. The most up-to-date terms and conditions can be accessed here, and the date on which they came into force is noted.

1.2 Where We wish to make substantial changes to the Terms and Conditions, we will give You as much prior notice of such changes as is reasonably practicable via one of the following methods:

Email (to the email address You have previously supplied us with, if any);

A message in your mailbox of game client;

A notice on the Website.

1.3 Where we make changes to the Conditions which we wish to notify You of directly, we will do so by such a method of notification as we may, in our discretion, deem to be appropriate.

1.4 We may, at our discretion, invite You to accept the new Conditions by clicking on “yes” or “I accept”, checking a ‘tick box’ or any other similar method of confirmation by You. If You provide us with any such confirmation, or if you continue to use the Services and/or Your Account after notification under this paragraph 1 (Changes To The Terms And Conditions), You shall, from such time, be deemed to have accepted, and be bound by, the new Conditions (including any additions, removals, substitutions). If any change is unacceptable to You, You may either cease using the Services and/or close Your Account by following the steps in paragraph 2.6 below.

1.5 It remains Your responsibility to periodically check these Conditions to ensure you continue to agree with them each time You use the Website and the Services.

ACCOUNT OPENING AND SECURITY

2.1 In order to register, open an account and participate in the Games, You represent and warrant that:

You are at least 18 years of age and meet the minimum age requirement in Your local jurisdiction to contract with us, use the Website and participate in the Games;

You are not an employee/contractor of (i) the Company or (ii) any of the Company's group company;

You will abide at all times by these Conditions and any other agreements between You and us;

You are legally able to enter into contracts;

You have not been excluded or are not currently self-excluded from gambling;

You have not previously had your account closed by us for any reason;

You acknowledge that it is your responsibility to ensure that You understand and fully comply with any laws or regulations applicable in your own country or state.

2.2 If You do not meet the eligibility requirements set out above You are not authorised to use the Website. We reserve the right to suspend and/or close any accounts of any purported customer that does not meet the eligibility requirements and void any bets made via such accounts.

2.3 You are only permitted to open one account. If You have more than one account, You must immediately inform us. Furthermore, only one account for each IP/Household is allowed. If You open more than one account, any winnings on either account will be forfeited and all accounts may be closed. If we find there more than one account registered for Your household (“Duplicate Account”), we reserve the right to block or close any or all accounts of that household. All transactions made from the Duplicate Account will be made void.

2.4 Any returns, winnings or bonuses which You have gained or accrued during such time as the Duplicate Account was active will be forfeited by You and may be reclaimed by us, and You will return to us on demand any such funds which have been withdrawn from the Duplicate Account plus an admin fee will also be applied.

2.5 You must maintain Your account and keep Your details up-to-date.

2.6 If You wish to close Your account You must send a request to do so to [email protected] or use the permanent exclusion feature within the application. By closing Your Account, You will also forfeit any promotional bonuses, prizes or benefits which You may have acquired. In the event of closure of Your Account because of gambling addiction or if Your account has been closed due to fraud You acknowledge that You are prohibited from opening a new account.

2.7 The Company will not be liable if You manage to open a new account, for such action nor for any direct or indirect consequential damages.

2.8 The Company shall have the right to close, at any time, a new account opened in breach of the requirement stated herein.

2.9 You are required to enter all mandatory information requested by us. We shall not be liable for incorrect entries, including but not limited to data input error.

2.10 You must not open an Account if You are located in a jurisdiction in which applying for or opening an Account and/or using our Services is unlawful or contrary to any applicable regulation “Prohibited Jurisdiction”. It is Your responsibility to ensure that this is not the case. We reserve the right to immediately suspend Your Account if we discover that Your Account has been opened, or is being used, from a Prohibited Jurisdiction. We reserve the right to request proof of age documentation from any customer at any time.

2.11 We do not accept players who reside in the following countries and jurisdictions: Afghanistan, Åland Islands, Algeria, American Samoa, Angola, Australia, Armenia, Azerbaijan, Bahrain, Belarus, Belgium, Belize, Bonaire, Saint Eustatius and Saba, Bosnia and Herzegovina, Bulgaria, Colombia, Cuba, Curaçao, Czech Republic, Denmark, Eritrea, Estonia, Ethiopia, France, French Guiana, Georgia, Germany, Great Britain (UK), Greece, Guadeloupe, Iran, Ireland, Isle of Man, Israel, Italy, Kazakhstan, Kyrgystan, Latvia, Liberia, Malta, Marshall Islands, Martinique, Mauritania, Mayotte, Moldova, Mongolia, Netherlands, Netherlands Antilles, Norfolk Island, North Korea, Oman, Palestinian Territory Occupied, Philippines, Poland, Portugal, Reunion, Romania, Russia, Rwanda, S. Georgia and S. Sandwich Isls., Saint Martin (French part), Seychelles, Slovakia, Somalia, South Korea, Spain, Sudan, Sweden, Switzerland, Tajikistan, Turkmenistan, Ukraine, United States of America (USA), Uzbekistan, Virgin Islands (British), Virgin Islands (U.S.), Yemen, Zimbabwe, Canada, Kuwait, Liberia, Malaysia, Saint Eustatius and Saba, Singapore, and Tunisia. As a rule, if a potential player cannot find his/her country of residence in the list of countries available during the registration process, this means that Natural8 will not be able to accept him/her as a player, therefore this person will not be able to access the products and services of the Natural8.

2.12 We may suspend or terminate Your Account immediately at our absolute discretion if You breach any of Your obligations under these Conditions. We reserve the right to claim any remaining balance in Your Account as well as the right to claim damages caused by the breach.

VERIFICATION OF YOUR IDENTITY; ANTI-MONEY LAUNDERING REQUIREMENTS

3.1 You warrant that :

3.1.1 You are not Younger than 18 (eighteen) years old, or any legal age at which gambling or gaming activities under the law or jurisdiction that applies to You require (the “Legal Age”);

3.1.2 The details supplied when opening Your Account are correct; and

3.1.3 The money deposited is not derived by any activity which is illegal.

3.2 The Company complies with Curacao laws, regulations and guidelines for the prevention of money laundering and the funding of terrorism. Suspicious transactions shall be investigated by the Company and, if necessary, a suspicious transaction report will be made by the Company to the competent Authorities. In any such event, the Company is prohibited from informing any players or third parties involved, save in limited circumstances, that an investigation is being or may be carried out, or that information has been or may be transmitted to the competent Authorities. Furthermore, in the event of any suspicious transactions, the Company may suspend, block or close the account(s) of the relevant player(s) and withhold funds as may be required by law and/or by the competent Authorities.

3.3 All transactions made by players on our site are checked to prevent money laundering and all other illegal activity.

3.4 By agreeing to the terms, You authorise us to undertake verification checks as we may require ourselves or may be required by third parties (including, regulatory bodies) to confirm Your identity and contact details and to prevent money laundering (the “Checks”).

3.5 By regulation, we need to collect a copy of your identity document (ID) and a proof of address document before we can proceed with your withdrawal request. A satisfactory evidence of identity must be provided by You. The ID must be a current government-issued photo identification document, such as a passport or a driving license. As for the proof of address document, it must be a document that can prove your residential address, such as a bank statement, utility bill, or tax bill, and this document must be dated not more than 90 days from the date of submission.

3.6 In certain circumstances, we may have to contact You and ask You to provide further information to us directly in order to complete the Checks. If You do not or cannot provide us with such information then we may suspend Your Account until You have provided us with such information or permanently close Your Account.

3.7 Furthermore, if Your age is not successfully verified upon registration;

Your account will remain frozen;

no gambling will be permitted until age verification has been successfully completed;

If a customer is shown to be underage even after the completion of age verification, all transactions will be made void and related funds deposited will be returned within 5 working days.

3.8 Successful verification of your identity and/or Your Account does not overrule Section 12 in any way.

RISK

4.1 Participation in the Game is at Your discretion and risk. You understand that playing “real money” games is highly speculative in nature and therefore contains a degree of risk. You acknowledge that You are fully prepared financially to undertake such risks and to withstand any losses incorrectly and that You are able to sustain the total loss of any bets committed by You. You are entirely responsible for the information that You provide to us and we shall not be liable for incorrect entries made by You, including data input errors with respect to the bets on offer.

4.2 It is Your responsibility to ensure that all details of Your transactions on Natural8 are correct. You can access Your transaction history on the Website. Once a transaction has been confirmed by You (for example by clicking the enter tab) it cannot be cancelled.

4.3 We reserve the right to refuse the whole or part of any transaction requested by You at any time in our sole discretion. No transaction is accepted by us until we have confirmed to You that it has been accepted. If You do not receive a confirmation that Your transaction has been accepted, You should contact Customer Services.

YOUR NATURAL8 ACCOUNT

5.1 Only bets placed from Your account set up through the game client downloaded from natural8.com will be accepted for the Game and any winnings You make on the Game will be credited to Your account. You may facilitate all deposits and withdrawals by accessing the My Account page.

5.2 We reserve the right to refuse or limit (by setting minimum and maximum amounts which will be set out in the House Rules or on the Website) any bets and/or payouts at our sole discretion for any reason whatsoever. In circumstances a bet is deemed to be or is declared void by us at our discretion, any sum deducted from Your Account with respect to that bet shall be credited to Your account.

5.3 Bets shall only be valid if accepted by our server. Until accepted by our server, no communications from You shall be binding on us and all information displayed on Natural8 or the Website constitutes an invitation to play only. You agree that our records, in the absence of manifest error, shall be the final authority in determining the terms of any bets You place and the circumstances in which they were made.

5.4 Your Account is personal to You. You shall not allow others to use Your Account or to accept any prize or participate in any of the Games. Any person found to have violated this section be liable for all losses on the account but will not be entitled to collect any winnings.

5.5 You cannot transfer, sell, or pledge Your Account to another person. This prohibition includes the transfer of any assets of value of any kind, including but not limited to ownership of accounts, winnings, deposits, bets, rights and/or claims in connection with these assets, legal, commercial or otherwise. The prohibition on said transfers also includes however is not limited to the encumbrance, pledging, assigning, usufruct, trading, brokering, hypothecation and/or gifting in cooperation with a fiduciary or any other third party, company, natural or legal individual, foundation and/or association in any way shape or form.

5.6 It is Your responsibility to keep Your password private and secure and You are solely responsible for the security of Your account information and password. You are responsible for any unauthorized use of Your account and/or password. In the event that a third party places a bet, is thought to have placed a bet or makes a withdrawal from Your account, such bet or withdrawal shall be valid and liability for losses on Your account will lie with You, whether or not You were aware the third party misappropriated Your account and password information. Methods of misappropriation of Your account and password information includes but is not limited to hacking, viruses and malware present on your computer or device used to store or access your account and password information. Contact the Company immediately if your account and password information has been compromised.

5.7 While we make every effort to ensure that Your data is secure at all times, You likewise recognize that there are instances that may damage, corrupt, delete or in any way alter Your data that are beyond our control. However, we shall ensure that adequate security mechanisms designed to protect Personal Data will be used to prevent Personal Data from being stolen, misused or abused, and to prevent Personal Data breaches.

5.8 It is vital that You ensure that as much as possible Your personal information relating to You is kept up-to-date. We reserve the right to suspend or terminate Your Account if we suspect this information to be inaccurate. We will process information about You in accordance with Your Privacy Policy and our Cookie Policy.

5.9 The Company and any third parties it contracts with in relation to the provision of the Services will hold information with respect to Your identity, including but not limited to Your name, address and payment details, in accordance with our Privacy Policy and Cookie Policy. We rely on this information in entering into this agreement with You. You agree to indemnify us and hold us harmless against any costs, claims, damages, and expenses arising in connection with any falsehood or inaccuracy contained in the information You provide to us.

CUSTOMER FUND PROTECTION

6.1 Any funds You deposit with the Company will be held in a segregated bank account in the name of the Company (“Designated Account”) in accordance with the regulations relating to customers’ money. This means that all such funds are protected and in the case of insolvency properly due funds can be paid to the customer.

6.2 The Company keeps a sum of money equivalent to its liabilities to customers in the Designated Account which is solely used to hold the players’ balance. This Designated Account shall not be used for any operational purpose, and the balance of the Designated Account shall be audited by third-party auditors to confirm that it matches with the player’s total balance to meet any withdrawal request.

6.3 Monies held in Your account shall not attract any interest.

RESTRICTIONS

7.1 You agree to refrain from using Natural8 or our Website:

in excess of, or beyond, the agreed purpose;

to distribute, sell, license, provide or otherwise make any services available to third parties without our consent;

to store or transmit material or information that is infringing, libellous, defamatory, obscene, fraudulent, false or contrary to the ownership or intellectual property rights of any other person or otherwise harmful, unlawful or tortious, or in violation of any third party privacy rights;

in any way that is in violation of any applicable law, rule or regulation; or

to transmit viruses, malware, or other malicious code.

7.2 It is prohibited to modify, reverse-engineer, or otherwise manipulate, interfere with or disrupt any of our software used in the Website and/or Games. To ensure the integrity of the Website and Games, we reserve the right at any time in our sole discretion to block users from certain IP addresses from accessing the same tables or tournaments.

7.3 We may, at our sole discretion and without any requirement to give reasons, exclude any customer from our Services generally and/or from receiving selected promotions and offers introduced by us from time to time.

7.4 We reserve the right to suspend, discontinue, modify, remove, or add to the Website and/or any Games in Natural8 at our discretion with immediate effect and without any obligation to provide You with notice.

DEPOSITS

8.1 You can make deposits via payment methods provided in the cashier page, which includes credit cards, debit cards, various alternative payment options and bitcoins.

8.2 If You wish to participate in betting or gaming using the Website, You must deposit money into Your Account which You can then use to place bets or play games. We reserve the right to undertake KYC checks on player deposits for the purpose of regulatory compliance.

8.3 There are minimum deposit requirements per deposit method. Details for minimum deposits per deposit method are explained on the cashier page.

8.4 Deposits to the player Account are made by transfer of money to the Company’s account by way of the payment methods stated on the Website. The Company reserves the right to change the accepted method of payment at its sole discretion. The Company further reserves the right to accept certain methods of payment only subject to the fulfilment of certain conditions. The Company does not warrant that all methods of payment are available at all times.

8.5 We do not accept cash funds sent to us.

8.6 In relation to deposits and withdrawals of funds into and from Your Account, You shall only use such cards and other financial instruments that are valid and lawfully belong to You.

8.7 By depositing money, You agree not to make any charge-backs, reversal or otherwise cancel any deposits into Your Account, and agree to refund and compensate us for unpaid deposits.

WITHDRAWALS

9.1 There may be minimum and maximum limits on the amount that You can withdraw from Your Account, depending on the payment method used or limits applied to Your Account. Withdrawals may only be made to the card You have registered to Your Account and deposit funds with. Service charges may be charged by banks for withdrawals and will be deducted from Your Account at the time of withdrawal. Withdrawal made by cheque will be payable to You and not a third party and will be sent to You at the address registered with us.

9.2 All payments made into Your Account must have been confirmed as cleared, and none have been charged-back, reversed or otherwise cancelled prior to You withdrawing funds from Your Account.

9.3 Once we have approved Your withdrawal, You must give us sufficient information as to how the funds should be transferred to You. All withdrawals will be remitted only to the same Account from where the funds paid into Your Account originated unless proof was provided that the payment method has been lost or cancelled. We reserve the right to charge an administration fee amounting to our own costs (including the cost of the deposits) for withdrawals of funds that have not been put into play.

9.4 You are responsible for reporting Your winnings and losses to Your local tax or other authorities.

9.5 We reserve the right to request further information prior to any withdrawals.

HELD FUNDS

10.1 Held funds are part of Your total poker cash balance and relate to Your poker winnings in the previous 72 hours. Consequently, profits arising from poker sessions are not available immediately to withdraw, they are held in a customer’s poker wallet for a period of 72 hours. Despite these funds not being available for withdrawal they are available for use at the poker table.

10.2 In the case of a suspicious/collusive play taking place on Your Account or another player Account related to Yours in any way, You acknowledge that we reserve the right to block access to Natural8 by such Accounts and such amounts and suspend the use of withdrawal of funds for an indefinite period in order to carry out the necessary investigation and verify the details registered to the Account.

PROMOTIONS

11.1 We may, from time to time, offer bonuses and/or promotions that are governed by separate terms and conditions. Any bonuses credited to Your account must be used in adherence with such terms and conditions.

11.2 In the event and to the extent of a conflict between these Conditions and the bonus or promotion terms and conditions, the bonus or promotion-specific terms and conditions prevail.

11.3 If we believe that You are abusing or attempting to abuse a bonus or promotion, or are likely to personally benefit through the abuse of a bonus or promotion, we may deny, withhold or Withdraw from You any bonus or promotion at our sole discretion. We may also terminate Your access to our Website and/or Your Account. In such circumstances, we shall be under no obligation to refund to You any remaining balance amount showing in Your Account other than Your original deposit amount.

11.4 By participating in any Promotion of Natural8 ( the “Promotion”), You agree to cooperate in all advertising, marketing, publicity material and activities we may choose to utilize. You also agree, if requested, (a) to wear any Natural8-branded clothing or patches provided; and (b) to sign, if requested, an irrevocable release form allowing us to use your information with respect to the Promotion.

11.5 In any event sponsored by Natural8, You agree not to wear or expose third-party branding or advertising for any company which could be deemed as a Natural8 competitor. If you breach such a requirement, we reserve the right to revoke any prize awarded to you.

11.6 With respect to Your participation in any Promotion of Natural8, You confirm that the submitted materials will be Your own original work and such materials will not infringe on the intellectual property rights or other rights of any person or organization.

SUSPENSION, RESTRICTION OR TERMINATION OF YOUR ACCOUNT

12.1 Without restricting our ability to rely on other remedies that may be available to us, we may suspend or terminate Your Account or cancel any bets placed by You, remove any bonus monies in Your Account and/or take any other action we deem appropriate in our absolute discretion if:

You have been banned or prohibited from having an account by the Network;

You already have a Selective Mandatory Real Name (SMR) account on the Network;

We suspect You are acting in a manner that is detrimental to the conduct of our business; or

We are required to do so by law.

12.2 Your sole remedy in the event of termination of Your Account by us for any reason shall be the reimbursement of any undisputed Account balance You may then have, subject to You having complied with these Conditions to the fullest extent permitted by law. We shall have no further liability to You whatsoever.

12.3 Further restrictions that may apply to Your Account in the event of system, communications or technological errors or failures are set out in paragraphs 16 and 17 of these Conditions.

SECURITY CHECKS

13.1 We are committed to providing our customers with an enjoyable poker experience in a safe and secure environment, and we operate security procedures and checks to protect our customers and Natural8 from fraud and collusion. Any kind of BOT or Artificial Intelligence is strictly prohibited on Natural8. Occasionally, as part of this process, we will wish to make Checks on Accounts and plays in the Game(s) and this may result in the suspension of the use of Accounts whilst these checks are carried out, as well as requests for information from customers. We believe it is in the best interests of our customers and ourselves that we operate this process and it is a condition of participation that all our customers acknowledge this and cooperate with us in this respect.

13.2 Players can play on Natural8 only upon acceptance of the Security & Ecology Agreement. Security & Ecology Policy includes all the details of the security checks that we perform to make the environment safe and fair for all players.

PROHIBITED USES OF THE WEBSITE AND SERVICES

14.1 Cheating or Illegal Behaviour

The Game may only be used for lawful purposes and in a lawful manner. You agree to comply with all applicable laws, statutes, and regulations regarding the Game and any bets placed on or via the Game. All bets must be placed through the user interface provided on Natural8.

We reserve the right, in our sole discretion, to prohibit any player from participating in any and all Games of Natural8. We may, where situations warrant, freeze the chips, void bets, suspend or terminate the account of any player suspected of cheating in any form (which includes, without limitation, collusion or the exploitation of faults in software or the Website). We further reserve the right to restrict seating and/or to prohibit players from playing in a particular Game, including restricting two or more players from playing together at the same Game.

We reserve the right to void any bet inadvertently accepted after the time for placing bets has closed or where the event was resolved or at a stage where the player could have any indication of the outcome. In these circumstances, the original bet amount will be returned to the customer account.

14.2 Circumvention

We have developed and employ sophisticated proprietary technology intended to seek out and identify users making fraudulent or unlawful use of the Services or our Poker Software. You shall not break into, access or attempt to break into or access or otherwise circumvent our security measures. If we believe in our sole discretion, that You are in breach of this clause, we may terminate Your access to the Services immediately and/or have Your account blocked.

GAME RULES

15.1 The House Rules on the Website shall apply to Your participation in a Game. In particular, You are not permitted to make a bet in excess of the value of chips on the table at the beginning of a hand. You are permitted to acquire additional chips only between hands. If You run out of chips during a hand, You are considered “all- in”. You may not remove money from the table during a playing session. Taking money out of the Game and continuing to play is not allowed in a table bets format.

15.2 Players must refrain from “table talk” or “coffee-housing” or talking during a hand in a way that compromises an opponent’s hand. This applies if You are playing in the hand or watching the hand. Repeated abuse of this aspect of player behaviour will result in suspension or permanent restriction of play.

15.3 Abusive or offensive language or other behaviour considered inappropriate by us in the context of the Game will not be tolerated. Bad behaviour or offensive language identified by us or brought to our attention will be dealt with swiftly and may result in a suspension or loss of playing privileges or such other action as may be deemed necessary by us at our sole discretion.

15.4 You fully accept and agree that the random number generator software will determine all outcomes of the Games.

15.5 You acknowledge and agree that You shall not interfere, interrupt, and attempt to interrupt, or attempt to manipulate the operations of the Website or the normal play of any of the Games in Natural8. Failure to comply with the preceding may lead to Your exclusion from the Website and to criminal and civil investigations.

15.6 For detailed rules of games, You can check the rules in each game page or from the House Rules here.

SERVER CRASH

16.1 If You have chips at a table during a server crash, the Game will be cancelled and all of Your chips at the table and in play will be returned to Your Account. We, our affiliates, agents and licensors shall not be liable for any loss resulting from delays or interruptions to play due to failure, breakdown, malfunction, disconnection from or interruption of electronic or mechanical equipment, of telephone, internet connection or other communications facilities, or due to any denial of service (DDOS) attack or other malevolent external interferences with our site or any other causes over which we or they have no direct control.

16.2 In the event of systems, technological or communications failure or errors relating to the generation of any result, bet settlement or any other element of the Game or the Website, we will not be liable to You because of any such errors and we reserve the right to void all related bets and plays on the Game in question.

CASINO GAME DISCONNECTIONS

17.1 If you are disconnected in the middle of casino games (i.e. Blackjack, Baccarat, Roulette, CasinoPoker, RussianPoker, Sicbo, DragonTiger, Wheel of Fortune) simply log back into your account. You will be able to resume the disrupted game at the point at which you were disconnected. Your pending bet will be kept for 90 days, and your bet will be cancelled and returned to your balance if the game is not completed within 90 days from the disconnection.

INTELLECTUAL PROPERTY RIGHTS

18. These Conditions confer only the right to use Natural8, the Website, and the Games while these Conditions and applicable license(s) (if any) are in effect and they do not convey any rights of ownership in or to Natural8, the Website, Games or any of our intellectual property. All right, title and interest, including without limitation any copyright, patent, trade secret or other intellectual property right in the Website and Games will remain our sole property. Any services provided to You under these Conditions, and other data or materials that are prepared in the performance of such services hereunder, and all right, title and interest in the foregoing, will belong to us.

PUBLICITY OF TOURNAMENT RESULTS

19.1 By registering for a tournament at Natural8, You agree to allow us to use your play data within an online live stream, in online broadcasting, and any other future publicity that Natural8 may use after the completion of the tournament. All Natural8 tournaments are reported on in various online media and social media platforms with results published that include players’ Natural8 nicknames, finishing positions, played-hands and pay-outs in the events. However, we do not publicly use players’ real names or personal information unless we have written permission from the players to do so. Any final tables of tournaments, selected by Natural8, can be broadcasted on online media, such as the Twitch platform, with hole cards open with a delay of 1 (one) hour from the actual time of play.

19.2. For some specific tournaments, You need to consent that your real name will be published if you win any prize from such tournaments. If you do not want the publicity of your real name, you should not register for such tournaments in Natural8. For these specific tournaments, You will be prompted with a pop-up window during the tournament registration for release consent of your information and additional confirmation of your real name.

INDEMNIFICATION

20.1 You agree to hold harmless and indemnify us and our subsidiaries, affiliates, officers, agents and employees from and against any third party claim arising from or in any way related to Your breach of these Conditions, or Your violation of any law or the rights of a third party, or Your use of the Website and/or Games, including any liability or expense arising from all claims, losses, damages (actual or consequential), suits, judgments, litigation costs, and attorneys’ fees, of every kind and nature. Nothing in these Conditions shall be deemed to exclude or limit Your liability in respect of any indemnity given by You under these Conditions.

LIMITATION OF LIABILITY

21.1 We do not warrant that our operations shall be uninterrupted or error-free. We shall provide our Services on an “as is” and “as available” basis without warranty of any kind, whether expressed or implied, including, but not limited to the implied warranties of merchantability and fitness for a particular purpose. To the maximum extent permitted by law, we exclude all Conditions, warranties, representations or other terms which may apply to the Website and Game, whether express or implied.

21.2 Our maximum liability to You for any matter arising out of or in connection with Your use of the Website will be limited to the aggregate of the amount legitimately in Your account and the return of the amount of the stake of any disputed bet.

21.3 The Company (or any of its group companies officers, directors, employees, shareholders or agents) will take all the measures needed in order to protect the company against any of the following:

any direct, indirect, special, incidental, consequential loss or damages whether exemplary or punitive;

any loss of income;

any loss of direct or indirect profits;

any loss of goodwill;

any loss of contracts;

any loss of use of money;

any loss or damages arising from or connected in any way to business interruption; or

in any way whether in tort (including without limitation to negligence), contract or otherwise in connection with the Website in any way or in connection with the use, any inability to use or the results of the use of the Website including but not limited to loss or damages due to viruses that may infect Your computer equipment.

21.4 We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect Your computer or mobile equipment, computer programs, data or other proprietary material due to Your use of the Website or Games or to Your downloading of any content on it, or on any website linked to it.

21.5 We will not be liable for any loss or damage that You may suffer because of any act of God, power failure, trade or labour dispute, act, failure or omission of any government or authority, obstruction or failure of telecommunication services or networks, access delays or access interruption, data non-delivery or data misdelivery, the unauthorised use of Your security access details or any other delay or failure caused by a third party. In such an event we reserve the right to void any bet or cancel or suspend our services arising from such circumstances without incurring any liability. Furthermore, we will not be responsible for the failure of any equipment, wherever located or administered, or whether under our direct control or not, that may prevent the operation of our Website or prevent You from being able to contact us.

21.6 Nothing in these Conditions shall exclude our liability which we may have in respect of fraud or death or personal injury arising from our negligence.

THIRD-PARTY CONTENT

22. You expressly acknowledge and agree that we shall not be liable to You for the content of or use by You of any information or services offered by third parties or affiliates advertising, marketing, or otherwise posting content through the Website (whether directly or via links to or from other sites or resources) nor can we be said to endorse the content of such advertisements or information and we make no warranties with respect to such content.

DORMANT ACCOUNTS

23.1 For the purposes of these Conditions, a “Dormant Account” shall mean any customer account which, for a continuous period of 12 (twelve) months or more, has not either (a) had funds deposited in it; or (b) had funds withdrawn from it; or (c) had a bet placed from it; or (d) had a bet settled from it. In respect of such Dormant Accounts, we reserve the right to charge on the last day of each month a processing handling fee of £5 per month (or the remaining balance should the account balance be under £5) which will be deducted in arrears at any time within 10 (ten) working days of the subsequent month. These charges shall be payable in respect of any Dormant Account until such time as the account becomes active again or has a nil balance.

23.2 If Your account has been deemed a Dormant Account and has subsequently been dormant for an additional 12 (twelve) calendar months, Your account shall be deemed to be an “Abandoned Account” and closed, and the sum total of cash held in Your account at the time of closure will be donated to charity.

23.3 Any Personal Data retained in relation to Dormant Accounts will be deleted and disposed of when no longer needed.

RESPONSIBLE GAMING

24. We are committed to endorsing responsible gaming as a policy of customer care and social responsibility. We believe it is our responsibility to You, our customers, to ensure that You enjoy Your wagering experience on our site, while remaining fully aware of the social and financial harms associated with problem gambling. Check out our Responsible Gaming guide for more information.

24.1 Deposit Limits

After account registration, You can set Your own daily, weekly and monthly deposit limits at any time.

If You want to increase Your deposit limit, You must wait 24 hours, after which You must confirm the value increase, for immediate implementation. If You decline the increase, Your deposit limit will remain as the previously selected value. You can find more information about our responsible gaming guide here.

24.2 Self-exclusion

We want everyone to enjoy playing our Games. However, we do recognise that some customers would wish to restrict or even cease playing. We, therefore, provide a self-exclusion facility that allows customers to close their accounts for a temporary period from 1 hour or much longer period up to 5 years or permanently. You can select a self-exclusion period via the ‘Cashier’ dashboard. Alternatively, You may contact our Customer Service Support team directly by email to [email protected]

When choosing to self-exclude, You will not qualify to receive any bonuses or promotions we may offer during Your self-exclusion. Within two days of choosing to self-exclude, which You would have previously provided us with Your explicit consent to receive, You will also be excluded from any marketing material that we may send. No further marketing material will be sent until the self-exclusion period is over, and You have requested to return to the Website.

Once You choose to self-exclude, Your account will be closed for the duration of the selected period, and You will no longer have access to the Games. We will return Your remaining account balance in accordance with our Withdrawal Policy.

During a self-exclusion agreement, You must not attempt to gamble with us, and we cannot be responsible or liable for any subsequent consequences or losses (however caused) that You may suffer or incur if You continue gambling through additional accounts where You have altered any of Your registration details or You provide misleading, inaccurate or incomplete details or otherwise seek to circumvent the self-exclusion.

If You choose to reopen Your account once the self-exclusion period has ended, You will be required to contact the customer support team via [email protected] You will then be given a minimum 24 hour cooling off period before Your account is active. Whilst the 24 hour cooling off period is in place You will be given the option to cancel the reactivation.

We also wish to draw Your attention to the existence of software preventing an individual computer from accessing gambling websites or services, such as: www.cyberpatrol.com or www.gamblock.com. If You require any further information or assistance regarding our functionality, please contact [email protected]

You can always find more information about responsible gaming here.

CUSTOMER COMPLAINTS

25.1 Should there be any claim or dispute relating to bet(s) on Natural8, please contact us at [email protected] and the complaint will be assigned to a customer support representative.

25.2 An initial response will be sent to the customer within 24 hours for weekdays and within 72 hours for weekends.

25.3 If no subsequent/follow up contact is made by the customer within seven days, the complaint is considered resolved.

25.4 If subsequent/follow up contact is made by customer, the complaint is re-examined by the designated customer support representative within 24 hours for weekdays and within 72 hours for weekends, then either a second response is sent or the complaint is escalated to a customer support manager according to departmental procedures; and the customer support department continues to process customer complaints until they are successfully resolved or are deemed in dispute, according to departmental procedures.

25.5 Should a resolution not be reached or you are unhappy with the resolution we have come to, you may seek external resolution from Gaming Curacao.

GOVERNING LAW

26. The Conditions shall be governed by and interpreted in accordance with the laws of Curacao

MISCELLANEOUS

27.1 If, for any reason, a court of competent jurisdiction finds any provision of these Conditions, or portion thereof, unenforceable, invalid, or unlawful, then the remainder of these Conditions shall continue in full force and effect and will be read to give maximum effect to the intention of the parties as reflected by its plain language.

27.2 You agree that no venture, partnership, employment, or agency relationship exists between You and us as a result of these Conditions.

27.3 Our failure to exercise any rights under these Conditions shall not institute or be deemed a waiver or forfeiture of such right or waiver or forfeiture of such rights in the future.

27.4 These Conditions constitute the entire understanding between You and us relating to the use of the Game.

27.5 Online gambling debts are enforceable in Curacao.

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Disclaimer

We will not be held responsible in any circumstances for any loss or damage that may result from the use of the Services, Software or Website. We disclaim any warranty for the Services, Software or Website, which are provided on an ‘as is’ basis. We will endeavour to supply the Services, Software and Website to the highest possible standard and in a safe and secure manner, although we make no warranty that their supply will be uninterrupted or free from errors. Where any defect is notified to us we will make every effort to correct the defect in a timely manner. We will not be liable to you where any communication or system is impacted by a delay or failure. We reserve the right to suspend, remove or modify the Services, either temporarily or permanently, at our sole discretion and without any obligation to provide you with notice of such an action. We will not be liable for any loss incurred in this circumstance. It is your sole responsibility to ensure that you have the legal right to use the Services from within the jurisdiction that you reside or access them from. It is not our intention that anyone should use the Services from any jurisdiction where online gambling is illegal. The availability of the Services or Website in any jurisdiction should not be construed as an offer, solicitation or invitation by us to use the Services or Website. You acknowledge that your participation in the Services is at your sole decision and that you accept the full risk of using the Services. You further acknowledge that you do not find the Services or Website to be offensive, biased or indecent.

This Privacy Policy is effective from 16 January 2021

Natural8 is concerned with protecting the privacy of any Personal Data that you may choose to provide to us (“Personal Data”). Natural8 will ensure that the Processing of your Personal Data is compliant with the General Data Protection Regulation, (“GDPR”), (Regulation (EU) 2016/679). Accordingly, Natural8 issues this Policy to inform you of our use of your Personal Data.

This Policy applies to the Company and its directly or indirectly controlled wholly-owned subsidiaries conducting business within the European Union (EU) European Economic Area (EEA) or processing the Personal Data of Data Subjects within EU/EEA.

1. Introduction

1.1 This Privacy Policy sets out the way in which Natural8 (“we” or “us”), a company which is operated by Run Good N.V., reg #150149 of 9 Abraham de Veerstraat, Willemstad, Curacao collects, processes and retains Personal Data and ensures that the below steps are taken by us to protect such Personal Data.

1.2 By utilising our Services, you acknowledge that you have read, and agree to, the terms of this Privacy Policy and that you consent to the use by Natural8 of your Personal Data for the purposes set out in section 3 of this Privacy Policy. If you do not wish to provide your Personal Data on the basis set out in this Privacy Policy, you should not enter the relevant information on the Website or provide your Personal Data to us otherwise. However, if you do not provide your Personal Data, you may not be able to use all of the Services.

1.3 Capitalised terms not defined in this Privacy Policy shall be as defined in the Terms & Conditions.

This Privacy Policy is incorporated into, and forms part of, the Terms & Conditions.

1.4 Definitions:

The following terms “Anonymisation”, “Controller”, “Processor”, “Data Subject”, “Data Portability” “Personal Data”, “Processed/Processing”, “Pseudonymisation”, “Cross-Border processing of Personal Data”, “Supervisory Authority” used in this document shall have the same meaning as in the GDPR:

“You” means the player, the ‘Data Subject’ who is using the services of Natural8.

“Visitor” means an individual other than a user, who uses the public area, but has no access to the restricted areas of the Site or Service.

1.5 Principles:

This Policy is based on the following GDPR principles:

• The Processing of Personal Data shall take place in a lawful, fair and transparent way;
• The collection, processing and retention of Personal Data shall only be performed for specified, explicit and legitimate purposes and no further processing will take place which is incompatible with those purposes;
• The collecting and retaining of Personal Data shall be adequate, relevant and limited to what is necessary in relation to the purpose for which they are Processed;
• The Personal Data shall be accurate and where necessary, kept up to date;
• Every reasonable step shall be taken to ensure that Personal Data that is inaccurate having regard to the purposes for which they are Processed, are erased or rectified without delay;
• Personal Data shall be kept in a form which permits identification of the Data Subject for no longer than it is necessary for the purpose for which the Personal Data is processed;
• All Personal Data shall be kept confidential and stored in a manner that ensures appropriate security;
• Personal Data shall not be shared with third parties except when necessary in order for them to provide services upon agreement;
• Data Subjects shall have the right to request access to and rectification or erasure of Personal Data, or restriction of Processing, or to object to Processing as well as the right of Data Portability.

2. The Information we collect:

2.1 As part of providing you with the Services, we collect your Personal Data on registering an account. “Personal Data” means any information from which you can be personally identified or be identifiable, including but not limited to your name, surname, email address, home address, telephone number, mobile number, date of birth, government ID information, electronic location information and electronic device information – this covers passport/license, MAC address and IP address.

2.2 As part of providing you with the Services, we also collect information about the transactions you undertake, including details of payment cards used, details of the games you played and underlying gaming transactions.

3. How we will use your Personal Information

3.1 When providing our Services we ensure that we collect, retain and process your Personal Data in accordance with the GDPR. We will Process your Personal Data to enable us to:

3.1.1 Set-up, administer and manage your Account and records (including processing deposits and withdrawals);

3.1.2 Provide and personalise the Services (including allowing you to wager and play our games);

3.1.3 Receive and respond to your communications and requests;

3.1.4 Notify you about updates to the Software and/or the Services;

3.1.5 Ensure that we are able to fulfil our regulatory obligations regarding your Account, including by verifying the accuracy of any information you give us;

3.1.6 Comply with our obligations under Applicable Laws and to Regulators in jurisdictions where we are licensed (Isle of Man);

3.1.7 Investigate, and assist with the investigation of, suspected unlawful, fraudulent or other improper activity connected with the Services (including, where appropriate, dealing with requests from authorised entities/Authorities for the sharing of information);

3.1.8 Carry out market research campaigns;

3.1.9 Preparing statistics relating to the use of the Services by you and other customers;

3.1.10 Provide you with information about, and support for, the Services, including changes to the Services, technical updates and changes to the Terms & Conditions (including this Privacy Policy);

3.1.11 Provided that you “opt-in” and don’t “opt-out” from this option, keep you informed on offers and promotions in relation to our products and services;

3.1.12 Support any other purpose necessary for the performance of our contractual obligations or specifically stated at the time at which you provided your Personal Data. These are the “Purposes” for which we may collect your Personal Data.

3.1.13 In order to comply with all applicable regulations, we will supply some of your personal information to third parties (including financial institutions, age verification, and credit reference agencies). Credit reference agencies provide services for identity verification, credit risk and affordability checking, fraud prevention, anti-money laundering, and tracing. A record of the search and results will be retained, and the third party may use the information to assist other companies for verification purposes (legitimate purpose).

3.2 Your stored payment details will be used to facilitate future transactions initiated by you within the Natural8 Cashier.

3.3 If at any time you wish us to stop Processing your Personal Data for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us by [email protected]

3.4 To ensure a good quality of service we may monitor any communication you have with us whether in writing or by electronic mail (“recordings”). Any recordings remain the property of Natural8 and will be used only for the purposes listed above.

3.5 In the event that the purposes for Processing change, then we will notify you by a Privacy Notice whereby we will inform you of the changes and seek any additional consent that may be required.

4. Disclosing your Personal Information

4.1 Except as described in this Policy, we will not intentionally disclose the Personal Data that we collect and/or retain on the Service to third parties without your prior explicit consent. We may disclose Personal Data to third parties in the following circumstances:

• Any company within our Group (including to its employees and subcontractors) which assists us in providing the Services or which otherwise has a need to know such information;
• Any third party which assists us in providing the Services, including (but not limited to) payment processors and marketing service providers;
• Any third party which can assist us in verifying the accuracy of your Personal Data, including financial institutions and credit reference agencies (a record of the search may be retained by such third party. Security use/plan to use will fall under this category for ID and Document checks;
• Any third party who assists us in monitoring use of the Services, including the detection and prevention of fraud and collusion;
• Any contractors or other advisers auditing any of our business Processes or who have the need to access such information for the purpose of advising us;
• Any law enforcement body which may have any reasonable requirement to access your Personal Data;
• Other online gaming sites, banks, credit card companies, and appropriate agencies, where you are found to have cheated or attempted to defraud us or any other user of our services;
• Any regulatory body or authorised entity which may have any reasonable requirement to access your Personal Data; and
• Any potential purchaser of Natural8 or any investors in it or in any company within our Group (including in the event of insolvency).

4.2 We shall keep the Data Subjects informed and ensure that these trusted partners and/or third parties will abide with the mandatory data protection measures. During such data transmission we shall take all appropriate organizational, technical and legal protection measures. Any Personal Data transfers outside the EU/EEA will follow procedure as described in section 12.

4.3 The Company gives its customers the possibility to make use of “chat rooms” where players are able to communicate with each other. Whilst we will ensure that the players follow the terms as set in the “chat room policy”, we will not be responsible for any data breaches that might arise from the use of our chat rooms. Therefore, you accept responsibility and under no circumstance shall we be held responsible for any damages that might arise from any breach of data.

4.4 If at any time you wish us to stop Processing your Personal Data for the above purposes, then you must contact us and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed. You may contact us [email protected]

5. Data Subject Rights

5.1 We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. Your principal rights under the GDPR are:

• the right for information;
• the right to access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to object to processing;
• the right to data portability;
• the right to complain to a supervisory authority; and
• the right to withdraw consent.

5.2 If you wish to access or amend any other Personal Data we hold about you, or to request that we delete any Personal Data about you, you may contact us by email: [email protected] We will acknowledge your request within seventy-two (72) hours and handle it promptly. Natural8 will respond to these requests within a month, with a possibility to extend this period for particularly complex requests in accordance with Applicable Law. We will retain your information for as long as your account is active, as needed to provide you services, or to comply with our legal obligations, resolve disputes and enforce our agreements as described in section 13.

5.3 You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page on the ‘My Account’ tab in the Cashier. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. Where appropriate and possible we shall apply Anonymisation or Pseudonymisation to Personal Data to reduce the risks to the Data Subjects.

5.4 You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some or all of the features and functionality of the Service.

5.5 At any time, you may object to the Processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.

5.6 In accordance with Applicable Law, we reserve the right to withhold disclosing Personal Data if such disclosing would adversely affect the rights and freedoms of others.

5.7 You have the right to Data Portability, whereby You as Data Subject may request to receive all Personal Data retained by us free of charge in a structured, commonly used and machine-readable format. However, we reserve the right to charge a fee for complying with such requests if they are deemed manifestly unfounded or excessive. The Company may charge a reasonable administrative-cost fee if further copies are requested. We shall keep records including a ‘log’ of these requests.

5.8 When we receive requests to dispose of Personal Data records by Data Subjects, We shall ensure that these requests are handled within a reasonable time frame. We shall keep records including a ‘log’ of these requests.

5.9 We shall also strive in obtaining adequate disposal mechanisms to ensure no Personal Data is leaked outside of the organisation.

5.10 Should we fail in abiding with the required data protection obligations, you shall have the right of complaint to your Supervisory Authority.

6. Contacting us

6.1 For full details about Natural8 Group members and where they operate please contact us on [email protected]

6.2 If at any time you believe that we have not adhered to this Privacy Policy, please contact us [email protected] and we will seek to promptly determine and correct the problem.

7. Advertising and use of Cookies

7.1 Cookies are pieces of information that a website transfers to your computer’s hard disc for record keeping purposes. Cookies can make the web more useful by storing information about your preferences on particular sites, thus enabling website owners to provide more useful features for their users. They contain no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies or inform you when they are set.

7.2 Information on how to disable cookies can be obtained by referring to either your Operating Systems Manual or your Browser Guide, or by contacting your Internet Service Provider. However, given that Natural8 may sometimes use cookies, you may not be able to take full advantage of our Website if you do disable them.

7.3 Our Online poker service uses session cookies to establish and maintain your session with us. With cookies enabled, you shouldn’t notice any difference to the service. Natural8 requires your web browser to accept a session cookie before you can log on or register for the service. Session cookies only exist until you close down your web browser, as opposed to permanent cookies which your browser stores until they expire. If you browser is set to disable cookies, you may restrict your access to Natural8.

7.4 Natural8 web pages may contain electronic images, known as web beacons or spotlight tags. These enable Natural8 to count users who have visited certain pages on our website. Web beacons and spotlight tags are not used by us to access your personal information, they are simply a tool we use to analyse which web pages customers view, in an aggregated manner.”

7.5 If you object to cookies or want to delete any cookies that are already stored on your computer, you should follow the instructions for deleting existing cookies and disabling future cookies on your web browser or equivalent software. Further information is available at www.aboutcookies.org. Please note that by deleting or disabling cookies you may not be able to access certain areas or features of the Website.

7.6 As part of the Website’s operation, and for our own statistical analysis of site traffic, our Website automatically logs internet IP addresses. We do not log any email address of visitors to the Website. Our advertising system logs IP addresses to supply more accurate advertising features, such as language-specific banners.

7.7 While the Website may contain links to websites operated by parties other than us, we are not responsible for the privacy practices or content of such websites.

8. Minors and Children’s Privacy

8.1 Protecting the privacy of minors is especially important. Our Service is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at [email protected] and request that we delete your child’s Personal Data from our systems.

9. Security

9.1 We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. Natural8 has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services Processing Personal Data, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

9.2 Your winnings and cash-outs are kept strictly confidential, and winnings information is stored in secure operating environments. We do not provide winnings information to any third party unless such information is required to be disclosed by law, regulation or a similar governmental authority.

9.3 No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, however, we shall ensure that adequate security mechanisms designed to protect Personal Data will be used to prevent Personal Data from being stolen, misused or abused, and to prevent Personal Data breaches.. If you believe your Personal Data has been compromised, please contact us [email protected]

10. Data Breach

10.1 When we learn of a suspected or actual Personal Data breach, We shall perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is any risk to the rights and freedoms of Data Subjects, we will notify the relevant Supervisory Authorities without undue delay and, when possible, within 72 hours.

10.2 In the event that a Personal Data breach is likely to result in a high risk to the rights and freedoms of the Data Subject, the DPO must ensure that all affected Data Subjects are informed of the breach without undue delay.

11. Privacy Settings

11.1 Although we may allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users with whom you may choose to share your information. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons. We have taken the necessary steps to protect as much as possible your Personal Data in transit by utilising HTTPS on our Website and TLS 1.2 (a strong protocol), ECDHE_RSA with P-256 (a strong key exchange), and AES_256_GCM (a strong cipher).

12. Data Retention

12.1 Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

12.2 We only retain the Personal Data collected from you for as long as your account is active or otherwise for a limited period of time as long as we need it to fulfil the purposes for which we have initially collected it, unless otherwise required by law.

12.3 Retention periods may vary from a few months in relation to enquiries to over ten years to comply with our legal obligations and in line with our Data Retention Policy, resolve disputes, and enforce our agreements or in order to protect your vital interests or the vital interests of another natural person.

12.4 For payment processing information, Your payment details will be stored for a maximum of eight years. If you wish to remove your saved payment details at any point, this can be facilitated via the Natural8 Cashier.

12.5 We shall ensure that all employees, agents, contractors, sub-contractors, suppliers and any other third party will abide by the retention periods set by us and will be appropriately trained to do so.

13. International Transfers

13.1 Natural8 forms part of a group of companies and the Personal Data you provide to us may be transferred to and stored in countries outside of the European Union (EU), or European Economic Area (EEA) as we use suppliers and Processors which are based outside of the EU/EEA, or use servers based outside of the EU/EEA as in the case of NSUS Group in Canada. Personal Data may also be Processed by staff operating outside the EU/EEA who work for Natural8. A transfer of your Personal Data may happen if any of our servers are located in a country outside of the EU/EEA or one of our service providers is located in a country outside of the EU/EEA. If we transfer or store your Personal Data outside the EU/EEA in this manner, we will take steps with the aim of ensuring that your privacy rights continue to be protected, as outlined in this Privacy Policy and in accordance with the GDPR and other applicable laws.

14. Data Protection Officer/Representative

14.1 Our data protection representative who is responsible for matters relating to privacy and data protection at Natural8 can be reached at: [email protected]

14.2 In accordance with the applicable legal regulations governing the protection of Personal Data, each request/inquiry will be resolved without undue delay and at the latest within 30 days of receipt.

14.3 When contacting and posting such requests, we will invest reasonable efforts to confirm your identity and to prevent unauthorized Personal Data processing.

15. Accountability

15.1 We shall be responsible for and be able to demonstrate compliance with the principles outlined above.

15.2 Natural8 shall perform Data Protection Impact Assessment (DPIA) periodically and/or for any changes to data Processing Activity according to the Data Protection Impact Assessment Guidelines.

16. Governing Law

16.1 This Policy is intended to comply with the laws and regulations in the place of establishment and of the country in which the Company operates. In the event of any conflict between this Policy and applicable laws and regulations, the latter shall prevail.

17. Changes to this Privacy Policy

17.1 As the Company evolves, there may be the need to update this Policy to keep pace with changes to the website, software, services, business, and Applicable Laws. We will, however, always maintain our commitment to respect the Data Subject’s privacy. We will ensure that we will notify the Data Subjects with any material changes under this Policy by email (the most recent email provided by the Data Subject) or post any other revisions to this Policy along with their effective date, in an easy-to-find area of the website.

Validity

This document was updated on 16 January 2021 and is effective from that date.

Contact: Data Protection Officer

Email: [email protected]

Company Address: 9 Abraham de Veerstraat, Willemstad, Curacao

Table Of Contents

PREAMBLE

1. OVERVIEW
2. ACTIONS FOR BREACH OF NATURAL8 SEP

BREACHES

3. USE OF BOTS
4. USE OF REAL-TIME ASSISTANCE (RTA)
5. CIRCUMVENTION
6. ACCOUNT SHARING
7. GHOSTING
8. TRESPASSING
9. ENHANCED ENFORCEMENT OF VIP GAMES
10. COLLUSION
11. PREDATORY BEHAVIOUR
12. BUM HUNTING
13. CHIP-DUMPING
14. MULTI ACCOUNTING
15. USE OF VPN/PROXY & REMOTE DESKTOP
16. THIRD-PARTY TOOLS
17. RATHOLING
18. USER SOLICITATION
19. OFFENSIVE USER PROFILE

PREAMBLE

1. OVERVIEW

1.1. The Security and Ecology Policy (the "SEP") as maintained and operated by the Natural8 Security Team (“The Security Team”) should be read by you, the End User (the “User”), prior to playing on Natural8 and the GGNetwork (“Network”). Your decision and acceptance to play on Natural8 is a confirmation of your acceptance of the terms of the SEP.

1.2.Natural8’s ethos is that a healthy and safe User ecology is paramount to providing enjoyable poker games. To this end, we have implemented several security measures to foster and maintain a healthy ecology and ensure that Natural8 Users are provided with a safe and secure environment. The items outlined below state what is being monitored, how it is being monitored, and any potential actions taken by Natural8.

1.3. We reserve the right to make immaterial changes to the SEP. If we make any material changes to SEP, we will give you as much prior notice of such changes as is reasonably practicable but, in any event, you will be notified of material changes before they come into effect. Material changes will be communicated to you via email with a summary of the material changes to these Conditions. You will also receive a pop-up message when you login, directing you to review the completely updated SEP. After reviewing the updated terms and conditions, you will be prompted to “Agree” to the updated SEP to continue to use our services. Your continued use of the services after being notified of the material changes, and after indicating your acceptance of the updated SEP, will be considered by us to be your acceptance of the changes. If you do not agree to the material changes, then you will not be able to continue to use the services.

2. ACTIONS FOR BREACH OF NATURAL8 SEP

2.1. The Security Team’s paramount objective is to provide a safe and healthy poker environment and will always aim to educate Users at the outset. In cases where a serious breach (and continued breaches) occurs, your account may be locked to allow for an investigation of the alleged breach. For the lock’s duration, access to your account, login, gameplay, withdrawal, deposits, or inter-wallet transfers may be restricted.

2.2. Actions that can be taken against Users for confirmed breaches, based on the accumulated information available to us, are as follows:

a) WARNING: A written notice;

b) REWARD REMOVAL: Removal/reduction of your promotional rewards;

c) SUSPENSION: Temporary suspension of your account;

d) ACCOUNT CLOSURE: Permanent closure of your account;

e) PERMANENT BAN: Permanent ban from Natural8;

f) CONFISCATION: Seizure of funds to compensate victims of any prohibited/fraudulent activities (loss of funds due to use of bots or other Third Party Tools, loss of funds due to collusion, loss of funds owing to bum hunting). Seizure of funds may not only include funds in your poker wallet but in your main wallet as well as any pending withdrawals.

2.3. Regarding the results of any investigations, The Security Team’s decisions are final. The Security Team reserves the right to determine whether or not a breach of the SEP has occurred. By agreeing to our SEP, you hereby accept The Security Team’s said right of decision and determination.

BREACHES

3. USE OF BOTS

3.1. A bot plays without human intervention or reduces the requirement of a human to make decisions. A human must decide what action to take and the exact size of any bet or raise. Any tool or service which reads the current game state and gives a User aid on decisions is strictly prohibited.

3.2. Natural8’s software package contains certain features designed to detect the use of automated programs that enable gameplay based on Artificial Intelligence.

3.3. Natural8’s software may perform any or all of the following scans to detect the use of illicit automated programs and ensure that a “cheat-free” environment is maintained:

a) Scan of all active software applications while our software is being used.

b) Scan of all active processes while our software is being used.

c) Scan of all activities for the potential use of Artificial Intelligence.

3.4. Should any of the aforementioned processes reveal a suspicious application or process; our software may scan the files associated with the questionable application or process and compile a composite mesh (a profile that characterises the files associated with the application or process) to be matched against profiles for known illicit automated programs.

3.5. Actions taken for breaches: PERMANENT BAN and/or CONFISCATION

4. USE OF REAL-TIME ASSISTANCE (RTA)

4.1. Any decision made at the poker table must be made solely by you. Humans must decide what action to take and the exact size of any bet or raise.

4.2. Use of any software and/or reference materials that provides advice and/or has an influence on your decision-making in real-time is strictly prohibited.

4.3. Prohibited software includes, but is not limited to, GTO solvers, range calculators, and ICM analyzers.

4.4. Prohibited reference materials are solutions from simulations, e.g., GTO charts, range calculation, ICM equity, decision trees, nash equilibrium, or push/fold charts.

4.5 The following reference material is allowed: a basic pre-flop chart that defines starting hands to play from each starting position. If reading materials contain stack size, relative positions, or any User-defined situations then they are not permitted.

4.6. Actions taken for breaches: PERMANENT BAN and/or CONFISCATION

5. CIRCUMVENTION

5.1. Natural8 prohibits Users from making fraudulent or unlawful use of their software.

5.2. Natural8 prohibits Users from breaking into, accessing, or attempting to break into the software and/or Network with malicious intent.

5.3. Natural8 prohibits Users from exploiting or attempting to exploit software bugs within the client for personal/mutual gain.

5.4. Natural8 has developed and employs sophisticated proprietary technology intended to seek out and identify offending Users.

5.5. Actions taken for breaches: PERMANENT BAN and/or CONFISCATION

6. ACCOUNT SHARING

6.1. Natural8 prohibits sharing accounts. Each account should solely be accessed by the User who registered it at all times.

6.2. Natural8 prohibits sharing a sufficient volume of hands/results with anyone in order to analyse or hunt other Users.

6.3. Natural8 prohibits sharing accounts as it affects the integrity of leaderboards and promotions.

6.4. Actions taken for breaches: REWARD REMOVAL and/or PERMANENT BAN, CONFISCATION

7. GHOSTING

7.1. Users are strictly prohibited from playing on behalf of someone else or allowing someone else to play on their account.

7.2. The use of software to share hole card information with other individuals in real-time is strictly prohibited. Further discussed in section 15. Use of VPN, Proxy & Remote Desktop

7.3. Actions taken for breaches: PERMANENT BAN and/or CONFISCATION

8. TRESPASSING

8.1. Natural8 strictly prohibits Users previously banned from any GGNetwork skin from returning on any account on any GGNetwork skin.

8.2. Actions taken for breaches: CONFISCATION

9. Enhanced Enforcement of VIP Cash Games and Tournaments

9.1. Users involved in any of the following financial relationships are strictly prohibited from playing at the same VIP cash game tables as their associates: staking, swaps, profit-sharing, or any bankroll sharing agreement.

9.2. Real Name players and players that have been requested to provide personal documents for Real Name conversion are strictly prohibited from creating and/or playing on any new accounts, and creating and/or playing on any pre-existing accounts other than their Real Name accounts, on any GGNetwork skin.

9.3. Users are strictly prohibited from making deals, including off-client deals, at the Final Table of select tournaments, including the Super MILLION$ High Roller.

9.4. Actions taken for breaches: 30-DAY SUSPENSION and/or PERMANENT BAN, CONFISCATION

10. COLLUSION

10.1. Collusion is the behavior in which two or more Users establish a partnership to gain an unfair advantage over other Users at the same cash game table or same tournament. The Security Team’s general rules regarding collusion are (but not limited to) as below:

a) Users’ hands must be played independently, in their own best interests.

b) Users must not have a partnership to gain an advantage over other Users.

c) Users must refrain from “Soft-Play” i.e. the act of intentionally playing hands in a non-aggressive manner against another user who is either a friend, backer, or another person of interest. The only exception to this rule is the “In The Money (ITM)” bubble and multi-handed situations past the money bubble in which one or more Users is all-in.

d) Users must not share hole-card information with another User under any circumstances.

10.2. The Security Team employs sophisticated industry-leading tools to detect suspicious actions deemed as collusion. Our tools monitor an assortment of data, such as hand history, betting patterns, and User gameplay. We also look at various other sources of information as part of our investigations.

10.3. Actions taken for minor breaches: WARNING or TEMPORARY BAN

10.4. Actions taken for repeat/major breaches: PERMANENT BAN and/or CONFISCATION

11. PREDATORY BEHAVIOUR

11.1. Predatory Behaviour is defined as User activities focused primarily on engaging in unethical advantages and tactics to exploit other Users in order to gain unfair profit.

11.2. Predatory Behaviour includes, but is not limited to; bum hunting, collusion, use of Artificial Intelligence, ratholing, grimming, hit-and-running, buttoning, and other unethical actions (mostly deemed unethical by general consensus of the poker community).

11.3. Natural8’s promise to its Users is to provide a safe, fun, and enjoyable poker environment. Predatory Behaviour is in direct conflict with our promise, and as such, The Security Team adopts a strict zero-tolerance policy to it.

11.4. Actions taken for initial breaches: WARNING or TEMPORARY BAN

11.5. Actions taken for repeat breaches: PERMANENT BAN and/or CONFISCATION

12. BUM HUNTING

12.1. Bum hunting is defined as the act of deliberately targeting one subset of (usually weaker) Users while avoiding giving action to another subset of (usually stronger) Users.

12.2. Bum hunting includes targeting a User by either intentionally sitting out at a table or observing Cash Game tables and only participating when the preferred User joins. Users are expected to be seated for the purpose of playing.

12.3. Bum hunting also includes the act of purposely targeting a User by following the targeted User’s activity. This can include being on standby in the lobby until a preferred User enters a game and then following them into the game and playing only until said User leaves.

12.4. While it is acceptable to be seated and occasionally deny action in certain circumstances, giving action to certain players while denying action to other players when you are starting tables is strictly prohibited.

12.5. Queueing, the act of intentionally seeking to avoid playing against specific players in blind registration games, such as Spin & Gold, is strictly prohibited.

12.6. Actions taken for initial breaches: WARNING or TEMPORARY BAN

12.7. Actions taken for repeat breaches: REWARD REMOVAL, PERMANENT BAN and/or CONFISCATION

13. CHIP-DUMPING

13.1. Chip-dumping is defined as the act of a User intentionally losing his/her chips to another User.

13.2. Actions taken for minor breaches: WARNING or TEMPORARY BAN

13.3. Actions taken for repeat/major breaches: PERMANENT BAN and/or CONFISCATION

14. MULTI ACCOUNTING

14.1. Natural8 prohibits Users from intentionally opening/using multiple accounts on the same GGNetwork skin.

14.2. Natural8 prohibits any User from intentionally opening an account if the User has been banned from GGNetwork.

14.3. Natural8 prohibits any User from intentionally opening an account if the User already has a Selective Mandatory Real Name (SMR) account on any GGNetwork skin.

14.4. Natural8 prohibits Users from playing from multiple accounts simultaneously and playing on the same table for Cash Games, Spin & Gold, or the same player pool for any other games offered.

14.5. Natural8 prohibits Users from playing from multiple accounts in the same tournament.

14.6. Natural8 prohibits Users from registering for the same tournament multiple times to take advantage of freerolls or promotions.

14.7. If a User accidentally creates a multi-account, we will close all newly created accounts and move funds to the original account.

14.8. Actions may still be taken against Users that successfully verify their Natural8 account(s).

14.9. Actions taken for breaches: ACCOUNT CLOSURE and/or PERMANENT BAN

15. USE OF VPN, PROXY & REMOTE DESKTOP

15.1. Natural8 prohibits the use of VPN/PROXY, remote desktops, or any alternative methods used to mask one’s actual location and/or identity in order to play from a prohibited region or engage in other breaches of our SEP

15.2. Should we determine that Users are accessing Natural8 from prohibited countries, we may restrict their use of VPN/Proxy, or suspend the account and request Proof of Presence (“POP”).

15.3. Natural8 also strictly prohibits the use of remote desktop and screen-sharing software while accessing the Natural8 client, as they can be used to facilitate breaches of our SEP, including playing from prohibited countries, ghosting, multi-accounting, RTA, and botting.

15.4 Actions taken for minor breaches: WARNING or TEMPORARY BAN

15.5 Actions taken for repeat/major breaches: PERMANENT BAN and/or CONFISCATION

​16. THIRD-PARTY TOOLS

16.1. Natural8 does not permit the use of certain third-party tools.

16.2. A third-party tool is prohibited if it,

 a) data mines,

(i) hands or private results (observing games without playing in order to build up a database of hand histories for future reference), and

(ii) the mass sharing of hands, private results, or playing statistics for the purpose of analysis of opponents

 b) is a Heads-Up Display (HUD) i.e. a program that displays Users’ past tendencies and betting patterns,

 c) assists in automatic seating or game-selection efficiency, and/or

 d) is deemed by The Security Team to provide an unfair advantage over other Users.

16.3. A third-party tool is permitted if it,

 a) assists only in the tiling/aligning of tables,

 b) assists in the creation of macros and hotkeys for gameplay efficiency that does not reduce the requirement of a User having to make a decision. The User must decide what action to take and the exact relative size of any bet or raise, with the macro or hotkey merely executing this decision. For example, a hotkey that bets half the pot is permitted. A hotkey that bets a randomised amount between half and three-quarters of the pot is prohibited, and/or

 c) is judged by The Security Team to have characteristics of prohibited third-party tools but is deemed inoperable in conjunction with the Natural8 client.

16.4. Actions taken for minor breaches: WARNING or TEMPORARY BAN

16.5. Actions taken for major/repeat breaches: PERMANENT BAN

17. RATHOLING

17.1. Ratholing includes, without limitation, incidents where a User plays short-stacked and upon hitting a certain chip threshold, the offending User intentionally leaves the table and immediately sits with a lesser stack at a new table of the same limit.

17.2. Actions taken for breaches: WARNING or TEMPORARY BAN

18. USER SOLICITATION

18.1. Natural8 considers any attempts to solicit personal information as a threat to our Users, and strictly prohibits such behaviour. Should Natural8 determine that solicitation of personal information has occurred, we reserve the right to immediately suspend the offending accounts for further investigation, permanently ban the offending accounts, and in severe cases, take legal actions against these accounts.

18.2. Actions taken for initial breach: WARNING or TEMPORARY CHAT BAN

18.3. Actions taken for repeat breaches: PERMANENT CHAT BAN or PERMANENT BAN

19. OFFENSIVE USER PROFILE

19.1. Users should not have User profiles, i.e. nicknames and avatars, that are offensive to other Users. A common-sense policy should be used to determine what is deemed to be offensive. Examples are User profiles with political, racial, or sexual implications, those that contain insults or expletives, and celebrity impersonations.

19.2. Natural8 reserves the right, without prior notice, to replace any avatars it deems to be offensive.

19.3. Natural8 reserves the right, without prior notice, to reset any Nicknames it deems necessary.

19.4. Users that continuously update offensive user profiles can lose access to these functions.

19.5. Actions taken for breaches: WARNING or TEMPORARY BAN