FAIR PLAY POLICY

This Fair Play Policy (“Policy”), which forms an integral part of the terms and conditions that govern the use of LINKSMIND (“Platform”), is intended to ensure that all games played on the Platform adhere to high standards of fairness, competition, skill, and sportsmanship. Accordingly, the policy sets out mandatory standards of conduct that are expected from users of the platform (“users” or “you”) and discloses, without limitation, specific measures implemented to ensure the aforesaid standards on the platform.

LINKSMIND EDUCORP PRIVATE LIMITED (hereafter, “LINKSMIND”, or “We” or “Us” or “Our”) reserves the right to take necessary actions, determined at its sole discretion, to enforce this Policy on all Games occurring on the Platform, and hence Users are advised to read this Policy carefully before playing a Game on the Platform.

Fair Play Violations

1.1 A Fair Play Violation (“Fair Play Violation”) means any activity of a user that violates this Policy, and includes:

• Activity that uses unfair means to manipulate the outcome of a Game on the Platform, irrespective of whether this is in favour of the user adopting such means.
• Activity that is fraudulent, illegal, suspicious or unfair, as determined by LINKSMIND in its sole discretion.
• Activity that is intended solely to transfer funds from one person to another person, or between distinct sources, thereby amounting to money transferring.
• Activity that involves collusion between two or more players to achieve a result during a Game, thereby amounting to syndicate playing.
• Activity that falls under the Prohibited Conduct set out in clause 2 below.

1.2 By registering on and using the Platform, Users agree that they will not indulge in any Fair Play Violation, by any means. Any User found guilty of a Fair Play Violation shall be subject to the consequences set out in clause 3 below.

2. Prohibited Conduct

2.1 The following conduct is expressly prohibited on the Platform:

• Multiple Accounts: Use of multiple accounts to play the same Cash Game or at the same table, as may be applicable.
• Impersonation: Impersonating any person or entity or misrepresenting your affiliation with any person or entity.
• Unauthorized Access: Accessing the LINKSMIND account of other Users without their permission.
• Misuse of Funds: Misrepresenting the source or identity of funds.
• Intentional Loss: Intentionally losing a particular round during a Cash Game in order to deliberately transfer winnings to another User.
• Cheating Tools: Use of unauthorized components, creation or use of cheats, exploits, bots, hacks, or any third-party software designed to modify, intercept, decrypt, or mine the Platform in any manner.
• Unlawful Content: Dissemination or uploading of spam, unlawful content, or any unauthorized communication to other players on the Platform, or employees of LINKSMIND EDUCORP PRIVATE LIMITED.
• Money Laundering: Use of the Platform as a means of money transfer between persons or separate accounts, or any conduct that may amount to money laundering or other unlawful activities under Indian law.
• Abusive Remark: Uploading any content to the Platform, or registering a user ID, which is racist, casteist, profane, vulgar, offensive, or unlawful in any manner.

2.2 Users must ensure that all KYC documentation submitted to Us is accurate and valid, and the submission of any false, forged, or other fraudulent documentation shall invite immediate termination of the User account, along with related legal action.

2.3 All communication must be strictly pertaining to matters related to the Platform, and Users found to be indulging in offensive or unlawful communication with any person on the Platform may be terminated and barred from accessing the Platform. The following types of communication are specifically prohibited:

• Vulgar or abusive language, racist remarks, offensive comments about religion or caste.
• Solicitation in any form by any player via the chat, begging, pestering, and causing nuisance of any sort.
• Discussion regarding the purchase or sale of Chips, or solicitation for the same.
• Flooding of chat window with recurring messages, or any sort of persistent or constant unwanted communication.
• Advertising or promotional activity, or attempt to promote products or services of third-parties.
• Malicious or defamatory content about the Platform or any of its other users.
• Revelation of personal details like email address, contact numbers, postal address, etc.

3. CONSEQUENCES OF FAIR PLAY VIOLATIONS

3.1 All games on the Platform are monitored for Fair Play Violations, and detection of a Fair Play Violation may lead to the immediate termination of the User accounts involved, including freezing the funds therein, until the matter is resolved.

3.2 Users found engaging in Fair Play Violation may be permanently barred from accessing the Platform, their accounts blocked, and any funds therein frozen in accordance with this Policy. This includes the Users who profited from the Fair Play Violation, and Users who aided or colluded in committing the Fair Play Violation.

3.3 In the event, We believe or suspect that you have been engaged in Fair Play Violation:

• We will notify you of such breach/attempt to breach.
• We shall have the right to investigate and monitor your LINKSMIND account and your gameplay for such period of time as in Our reasonable opinion may be needed to investigate such breach. The balance funds of users guilty of Fair Play Violations may be frozen for a period of up to 180 days. Such investigation will cover all the games that the concerned User has played since the time of registering on the Platform.
• In the event We, upon investigation, are of the view that your LINKSMIND Account is or has been engaged in Fair Play Violations, then to the extent of the amount which is involved in such Fair Play Violations, We may:
  • Forfeit the fund in Your LINKSMIND Account.
  • Repatriate the amount to the Generally Affected User or individuals who have been affected by the Fair Play Violation.
  • Levy a Fair Play violation fee of an amount up to ₹10,000 or 3 (three) times the add-cash amount paid by you for the game involving Fair Play Violation (whichever is higher) per instance. You agree that such fee is not a penalty but a reasonable cost to recover manpower, technology, and reputation damages suffered by the Platform. The fee may be debited from your LINKSMIND Account or legally recovered if the balance is insufficient. This fee may be in addition to any legal action taken by the Platform.

3.4 Where the review pursuant to a Fair Play Violation indicates any financial losses to a Genuinely Affected User, the amount of such loss, and further penalties that LINKSMIND may impose at its sole discretion, shall be recovered from the frozen funds of the concerned User. Where such funds do not cover the due amounts, LINKSMIND retains all rights to legally pursue available remedies to recover such amounts. Balance funds shall be released to the User in accordance with applicable law.

3.5 LINKSMIND reserves the right to review any game of any User at any point in time, and if any games are found to be in violation of this Policy, then strict penalty and actions will be taken as per this Policy. There is no time limitation on the detection and actioning of a Fair Play Violation on the Platform.

4. REDRESSAL FOR GENUINELY AFFECTED USERS

4.1 For the purpose of this Policy, a “Genuinely Affected User” shall mean a User who is subject to a direct monetary impact during a Cash Game on account of a Fair Play Violation by one or more of the other players in that Cash Game.

4.2 Genuinely Affected Users may, after review and confirmation by the LINKSMIND investigative team, be eligible for a refund of their add-cash amount for the affected Cash Game. Such refunds will be in accordance with the other policies governing the use of the Platform, including those relating to Game cancellation and refunds in Clause 6 below.

4.3 Genuinely Affected Users must report a Fair Play Violation within 72 (seventy-two) hours of the occurrence, via email to [email protected] or via the help section provided on the Platform. LINKSMIND’s internal team shall investigate the reported Cash Game and respond with the investigation within 72 hours. The necessary action for valid cases will be taken as per the Game cancellation and refund policy.

5. SECURITY MEASURES

5.1 LINKSMIND has implemented a 24×7 monitoring mechanism, involving a team of experts and proprietary technology, to review Cash Games played on the Platform for Fair Play Violations. However, we also rely on Users to report Fair Play Violations, in order to ensure swift redressal of such matters, and accordingly You are encouraged to contact Us if you suspect a Fair Play Violation during any Cash Game You participate in on the Platform.

5.2 LINKSMIND makes use of the Random Number Generator (RNG) algorithm in the game-play on the Platform, which has been accredited by a renowned testing lab (iTech Labs, which is IEC/ISO 17025 certified). Accordingly, international standards of randomisation are implemented on the Platform to ensure the fairness of each Cash Game, including seating, shuffling, etc.

5.3 LINKSMIND implements anti-collusion measures on the Platform which includes but are not limited to randomized seating at tables and anti-fraud algorithms.

5.4 Information about the playing cards is always encrypted, thereby preventing any third party from viewing the same.

5.5 Advanced techniques have been employed to assess whether two (2) or more players on the table are colluding during the Cash Game. In case the system detects any such Fair Play Violation happening on the table, an auto-alert is raised instantly.

5.6 An alert is automatically raised if there are any signs of Fair Play Violation.

6. GAME CANCELLATION AND REFUND POLICY

6.1 In the event a Rummy Cash Game is cancelled due to a technical error or any other reason solely attributable to the Platform, or on account of the detection of a Fair Play Violation, the following settlement policy shall be followed:

Points Rummy Cash Games:

• The add-cash amount paid by all Genuinely Affected Users shall be refunded.
• The add-cash amount paid by Users indulging in the Fair Play Violation shall be forfeited, and a Fair Play violation fee may be levied on such Users in accordance with this Policy.

Pool Rummy Cash Games, Deals Rummy Cash Games, and Tournament Games:

• The entry fee paid by all Genuinely Affected Users shall be refunded, including the rebuy amount if any.
• The entry fee and rebuy amount, if any, paid by Users indulging in the Fair Play Violation shall be forfeited, and a Fair Play violation fee may be levied on such Users in accordance with this Policy.

6.2 Refunds on account of such cancellations, where reviewed and confirmed by the LINKSMIND team in accordance with this Policy, will be made within 14 (fourteen) days of receipt of such request.