SECURITY & ECOLOGY AGREEMENT

TABLE OF CONTENTS

0. INTRO

1. ECOLOGY

2. PREDATORY BEHAVIOR

3. COLLUSION

4.BUMHUNTING

5.CHIP-DUMPING

6.USE OF ARTIFICIAL INTELLIGENCE

7.EXTERNAL ASSISTANCE PROGRAMS

8.MULTI-ACCOUNTING

9. USE OF PROXIES AND VPNs

10. RATHOLING

11. CIRCUMVENTION

12. OFFENSIVE CHAT

13. OFFENSIVE PLAYER PROFILE

14. RESIDENTIAL COUNTRY

15. PRIVACY POLICY

16. MISCELLANEOUS

17. PENALTIES

18. ACCOUNT SHARING

0. INTRO

All mentions of GGNetwork henceforth shall refer to the property owned and controlled by GGN Global Limited. The Security and Ecology Agreement (the ‘Agreement’) as upheld by the GGNetwork Security Team ( “The Security Team”) should be read by you, the End User (the “User”) prior to the use of any GGNetwork related software.

1. ECOLOGY

1.1. GGNetwork’s ethos is that a healthy and safe player ecology is paramount to providing enjoyable poker games. To this end, we have implemented several security measures in order to foster and maintain a healthy ecology and to ensure that GGNetwork players 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 available to be taken by GGNetwork for the purposes of protecting the poker ecology.

1.2. The SEA may be subject to revision, without prior notice, at any time.

2. PREDATORY BEHAVIOR

2.1. Predatory Behavior is defined as User activities focused primarily on engaging in unethical advantages and tactics to exploit other players in order to gain unfair profit. These include, but are not limited to; bum-hunting, collusion, use of artificial intelligence, rat-holing, grimming, hit and running, buttoning and other unethical actions (mostly deemed unethical by general consensus of the poker community). GGNetwork's promise to its Users is to provide a safe, fun, and enjoyable poker environment. Predatory Behavior is in direct conflict with our promise, and as such, The Security Team adopts a strict zero-tolerance policy.

2.2. As The Security Team reviews on a case-by-case scenario based on the gravity of the suspected offence, The Security Team reserves the right, at its sole discretion, to suspend Users suspected of Predatory Behavior from the Network for a period of no more than 60 (sixty) days, pending the conclusion of an investigation into the User’s activities.

2.3. Should a User be in breach of Predatory Behavior, an outline of penalties The Security Team reserves is listed in Point 17 below.

3. COLLUSION

3.1. Collusion is the behavior in which 2 or more Users establish a partnership to gain an unfair advantage of other Users at the same cash game table or same tournament. The Security Team’s general rules regarding Collusion are (but not limited to):

1) User hands must be played independently, in their own best interests

2) User must not have a partnership to gain an advantage against other users

3) User must refrain from “Soft-Play”; the act of intentionally playing hands in a non-aggressive manner against a certain scope of User (friend, backer or another person of interest) as they would not against an unknown User. The only exception to Rule 3 is the “In The Money (ITM)” bubble and multi-handed situations past the money bubble in which one or more Users is all-in.

4) User must not ‘Chip Dump’; Chip Dumping is the act of intentionally transferring funds (or tournament chips) through the manipulation of gameplay.

5) User must not share hole card information with another User under any circumstances.

3.2. 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.

3.3. Should the Security Team conclude that a User or Users has attempted or committed Collusion, the potential actions we reserve are listed in Point 17.

3.4. Where we find conclusive evidence of Collusion, any related confiscated funds will be distributed (at the Security Team’s judgment) to affected users as evenly as possible.

4. BUMHUNTING

4.1. Bumhunting is defined as the act of deliberately targeting one subset of (usually weaker) players while avoiding giving action to another subset of (usually stronger) players.

4.2. Should a User be suspected of engaging in Bumhunting, GGNetwork reserves the right, at its sole discretion, to suspend the User from the Network for up to 60 (sixty) days, pending the conclusion of an investigation into the User’s activities.

4.3. Following the conclusion of the investigation, potential actions the GGNetwork Security Team reserves are listed in Point 17.

4.4. Where we find clear evidence of Bumhunting, any related confiscated funds will be distributed (at the Security Team’s judgment) to affected users as evenly as possible.

5. CHIP-DUMPING

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

5.2. Should a User be suspected of engaging in chip-dumping, The Security Team reserves the right, at its sole discretion and without notice to suspend the offending User from the Network for up to 60 days, pending the conclusion of an investigation into the User’s activities.

5.3. Following the conclusion of the investigation, potential actions the GGNetwork Security Team reserves are listed in Point 17.

6. USE OF ARTIFICIAL INTELLIGENCE

6.1. GGNetwork's software package contains certain features designed to detect the use of automated programs that enable gameplay based on Artificial Intelligence. Use of such “bot” software programs is strictly prohibited.

6.2. GGNetwork's software may perform any or all of the following scans in order to detect the use of illicit automated programs and ensure that a “cheat-free” environment is maintained.

6.2.1. Scan all active software applications while our software is being used.

6.2.2. Scan all active processes while our software is being used.

6.2.3. Scan all activities for the potential use of artificial intelligence.

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

6.4. Should The Security Team conclude that a User has employed Artificial Intelligence, The Security Team reserves the right to apply penalties listed in Point 17.

7. 3rd PARTY TOOLS (EXTERNAL ASSISTANCE PROGRAMS)

7.1. GGNetwork does not permit the use of certain 3rd Party Tools (External Assistance Programs).

A 3rd Party Tool is prohibited if it:

1) 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 read the current game state is considered to a poker bot.

2) Data mines hands or private results (observing games without playing in order to build up a database of hand histories for future reference); the use of hands or private results acquired through data mining; the mass sharing of hands, private results or playing statistics for the purpose of analysis of opponents.

3) Is a Heads Up Display (HUD), a program that displays Users past tendencies and betting patterns

4) Is deemed by The Security Team to provide an unfair advantage against other users

5) Assists in automatic seating or game selection efficiency

6) Analyzes specific hand histories or user-defined situation using simulations, e.g) Range calculation, Nash equilibrium, ICM equity, Solvers.

7) Advises on actions to be taken in various poker situations, e.g) Hand Charts, Decision Trees.

A 3rd Party Tool is permitted if it:

1) Assists only in tiling/aligning of tables

2) Assists in the creation of Macros and Hotkey for gameplay efficiency that do 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 randomized amount between half and three-quarters of the pot is prohibited.

3) Is judged by The Security Team to have characteristics of prohibited 3rd Party Tools but is deemed inoperable in conjunction with the GGNetwork poker client.

7.2. Should The Security Team conclude that a User has employed 3rd Party Tools, The Security Team reserves the right to apply penalties listed in Point 17.

8. MULTI-ACCOUNTING

8.1. GGNetwork allows players to register accounts with multiple Operators. Each Operator will have their own set of multi-accounting policies.

8.2. GGNetwork enforces the overall policy that an individual may only register and participate in any single tournament from one of their accounts.

8.3. Should GGNetwork conclude that a player is in violation of 8.2, the following actions will be taken: said player will be disqualified from the tournament in-progress should the violation be detected in real-time, all funds held in said player's accounts shall be confiscated, said player will permanently be banned from playing on the Network.

9. USE OF PROXIES, VPNs, REMOTE DESKTOP AND VIRTUAL MACHINE

9.1. GGNetwork prohibits the use of Proxies and/or VPNs while our software is in use.

9.2 GGNetwork prohibits the use of remote desktop software and/or incoming remote desktop connection while our software is in use.

9.3. GGNetwork prohibits the use of our software running on a virtual machine.

​9.4. GGNetwork prohibits spoofing of IP Address or Mac Address, modifying them to impersonate other computer system or to hide the identity of the player.

9.5. Should GGNetwork conclude that player has violated 9.1 or 9.2 or 9.3 or 9.4, said player will be issued a warning.

9.6. In the event of repeated breaches of 9.1 or 9.2 or 9.3 or 9.4, The Security Team reserves the right to apply penalties listed in Point 17.

10. RATHOLING

10.1. 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.

10.2. Should a player be suspected of engaging in ratholing, said player will be issued a warning.

10.3. In the event of repeated breaches of 10.1, The Security Team reserves the right to apply penalties listed in Point 17.

11. CIRCUMVENTION

11.1. GGNetwork prohibits players from making fraudulent or unlawful use of the software.

11.2. GGNetwork prohibits players from breaking into, accessing or attempting to break into the software and/or the Network with malicious intent.

11.3. GGNetwork has developed and employs sophisticated proprietary technology intended to seek out and identify offending users.

11.4. Should The Security Team conclude that a User has violated these terms, The Security Team reserves the right to apply penalties listed in Point 17.

12. OFFENSIVE CHAT

12.1. GGNetwork expects players to follow the rules of common decency with respect to table chat.

12.2. Foul/Abusive Language: players found using foul and/or abusive language will be issued a warning, and have their chat removed for 7 days. Repeated offences from the same player may result in an extended suspension or a lifetime ban from the Network.

12.3. Racist Language: players found using racist language will be issued a warning, and have their chat removed for a month. A second offence will result in the permanent removal of said player's chat function.

12.4. Spamming: players found spamming other players about external websites, promotions or products will have their chat function removed permanently.

12.5. Begging: players found begging at the tables will be given a warning, and have their chat removed for a month. A second offence may result in the removal of said player's chat function.

12.6. Discussing Hands-in-play: players found discussing hands-in-play will have their chat function removed for a month. Repeated offences may result in the permanent removal of said player's chat function.

12.7. Should GGNetwork remove the chat function from a player's account, a message detailing the reason for the removal will be issued to said player.

12.8. In addition to the broad guidelines stated above, a common-sense policy should be used as to what is and is not considered to be appropriate chat. Inappropriate chat shall be handled and dealt with on a case-by-case basis.

13. OFFENSIVE PLAYER PROFILE

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

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

13.3. GGNetwork reserves the right, without prior notice, to suspend for up to 30 days or block any accounts with offensive nicknames.

14. RESIDENTIAL COUNTRY

GGNetwork, in its sole discretion, reserves the right to change a player's Residential Country (flag) to match their log-in information. In such cases, the Network will issue said player a message outlining the change.

 

15. PRIVACY POLICY

15.1. GGNetwork is committed to protecting players’ personal information. The Privacy Policy describes what information we collect, why we collect this information, and how we use the collected information.

15.2. We may automatically collect certain data and receive Personal Information which the players provide to us. We may also receive Personal Information from Operators, service providers, and from customer lists lawfully acquired from third-party vendors. We will have access to any information players provide to such vendors, service providers and third-party e-commerce services, and we will use the Personal Information as set out in this Privacy Policy. We take steps to ensure that our arrangements with third-party service providers and online vendors protect our player’s privacy.

15.3. We may disclose your Personal Information if required to do so by law, or for the reasons outlined below:

15.3.1. Comply with any legal process served on us, any of our sites or the Services or in circumstances where we are under a substantially similar legal obligation.

15.3.2. Protect and defend our rights or property.

15.3.3. If, in our reasonable judgment, it is necessary to enforce compliance with our internal policies to protect our company, customers, or others.

15.3.4. To a person who, in our reasonable judgment, is seeking the information as your agent.

15.3.5. Where sharing or disclosing your information is required in order to offer you products or services you desire.

15.3.6. To a third party or parties, where disclosure is required or permitted by law.

15.3.7. To any other entity that acquires all or a portion of our organization by merger, reorganization, operation of law, or a sale of some or all of our assets.

16. MISCELLANEOUS

16.1. Players determined to have violated multiple SEA rules may face actions in addition to those corresponding to each individual violation.

16.2. Warnings and penalties issued to a player will apply to all accounts, regardless of operator, attributable to said player.

16.3. In the event that a player avoids or fails to cooperate with our investigations, GGNetwork will have no choice but to rely on the findings of its investigation to draw conclusions, and administer penalties (as set out in Point 17).

16.4. GGNetwork reserves the right to refrain from revealing details about how Security investigations have been conducted, so as not to fall susceptible to future abuse and circumvention of our detection methods.

17. PENALTIES

17.1. It is The Security Team’s paramount objective to provide a safe and healthy poker environment and will always aim at educating Users initially. In cases where a serious breach (and continued breaches) occurs, a player’s account may be locked to allow for an investigation of the alleged breach. For the duration of the lock, the User account, login, gameplay, withdrawal, deposits or inter-wallet transfers may not be possible.

17.2. Penalties for confirmed breaches, based on the accumulated information available, may be one, or a combination of the following:

1) A warning

2) Temporary suspension of User’s account

3) Permanent ban of User’s account

4) Block of deposits/withdrawals/inter-wallet transfers

5) Seizure of funds to compensate victims of breach (loss of funds due to use of bots or other 3rd Party Programs, loss of funds due to collusion, loss of funds due to bumhunting). Seizure of funds may include funds not only in the User’s poker wallet, but overall wallet and pending withdrawals within the Brand.

17.3. The Security Team’s decision is final and reserves the right to determine whether or not a breach of the Security and Ecology Agreement has occurred.

18. ACCOUNT SHARING

18.1 GGNetwork prohibits account-sharing. Each account should solely be accessed by the player who registered it at all times

18.2 GGNetwork prohibits sharing sufficient volume of hands/results with anyone in order to analyze or hunt other players

18.3. Should The Security Team conclude that a user has involved in account sharing, The Security Team reserves the right to apply penalties listed in Point 17.

LAST UPDATE: 5 AUGUST 2019