Cryptocurrency Policy

Cryptocurrency Policy

Lottorbit · Licensed by the Tobique Gaming Commission · Version 1.0

1. Introduction and Scope

1.1. Cryptocurrencies are not classified as fiat currency. However, because they can be used to place wagers with us, the Tobique Gaming Commission ("Commission") has issued guidelines governing the acceptance and processing of cryptocurrency transactions by its licensees, and this Cryptocurrency Policy ("Policy") sets out how Lottorbit ("we", "us", "the Company") complies with those guidelines.

1.2. The principal goal of this Policy is to ensure proper age and identity verification of every Customer using cryptocurrency, and to ensure that customer funds held in cryptocurrency are demonstrably safeguarded.

1.3. This Policy applies to every domain, sub-domain, alias, and mirror site operated by us that is approved to accept cryptocurrency. It applies in addition to, and does not replace, our Terms and Conditions, Privacy Policy, and Payment of Winnings Policy.

1.4. This Policy applies only if and to the extent that we offer cryptocurrency as a supported payment method. Where we do not, this Policy has no effect and all deposits and withdrawals are governed by our standard payment arrangements.

2. Regulatory Approval

2.1. Before offering cryptocurrency as a payment method on any domain, sub-domain, alias, or mirror site, we must obtain pre-approval in writing from Differentia Licensing Advisory Group ("DLAG") acknowledging and approving our use of cryptocurrency. We do not accept cryptocurrency on any site that has not received this approval.

2.2. The Commission may modify or amplify the requirements of this Policy at any time. Where it does so, we will be notified by email and will have thirty (30) days from that notification to bring our systems, procedures, and this Policy into compliance with the new standards.

3. No Conversion Between Cryptocurrency and Fiat Currency

3.1. We do not sell, buy, or exchange cryptocurrency for fiat currency, or fiat currency for cryptocurrency, at any time, in connection with your Account.

3.2. If you deposit using cryptocurrency, your deposit, all wagers placed with those funds, and any payout arising from them will remain in cryptocurrency throughout. We do not convert cryptocurrency balances to a fiat-denominated Account balance, and we do not pay out winnings generated from cryptocurrency wagers in fiat currency.

3.3. If you wish to deposit or withdraw in fiat currency, you must use one of our separate, non-cryptocurrency payment methods. Cryptocurrency and fiat funds are not interchangeable and are not combined within a single Account balance.

4. Identity and Age Verification

4.1. Before you may deposit, wager, or withdraw using cryptocurrency, we will collect and verify:

• proof of identity — a passport, voter's identity card, or driving licence;
• proof of address — an electricity or telephone bill, or a letter from your employer or a recognised public authority confirming your address;
• confirmation that you are over the age of 18; and
• a valid email address.

4.2. We will not process a cryptocurrency deposit, wager, or withdrawal until this verification has been satisfactorily completed.

5. Hardware KYC and Device Verification

5.1. We collect and store device and connection information ("hardware KYC") at every stage of your interaction with cryptocurrency features, including sign-up, login, deposits, and withdrawals. This includes, but is not limited to, your IP address, MAC address, and browser information.

5.2. We use this information to ensure that all wagering, deposits, and withdrawals associated with your Account are consistently made to and from the same user, identified by IP address and device/computer. Activity inconsistent with this — for example, deposits and withdrawals associated with different devices or locations without a satisfactory explanation — will be treated as higher-risk and may result in additional checks, or suspension of cryptocurrency features on your Account, pending review.

6. Proof of Balance

6.1. We make available to DLAG, on demand, proof that customer cryptocurrency funds have been deposited and are held as represented. This proof is provided using a Merkle Sum Tree or another method acceptable to DLAG.

7. Proof of Solvency

7.1. We provide DLAG with periodic (weekly or monthly, as directed) proof of solvency, demonstrating that we hold sufficient cryptocurrency funds to cover all outstanding bets and jackpots owed to customers.

7.2. Cryptocurrency funds belonging to customers are held in a separate account from our own corporate funds, and are not used for our own operating purposes.

8. Backup of KYC and Balance Data

8.1. All KYC information and balance data collected under this Policy is backed up in accordance with our agreed backup method, consistent with our Data Security obligations under the Code.

9. Display of Exchange Rate

9.1. We display the prevailing exchange rate between each supported cryptocurrency and a reference fiat currency on our homepage, sourced from a recognised rate provider (for example, bitcoinaverage.com or livecoinwatch.com for Bitcoin). This rate is displayed for your information only, since, as set out in Clause 3, we do not convert between cryptocurrency and fiat currency in connection with your Account.

10. Volatility Warning

10.1. The value of cryptocurrencies can change dramatically depending on market conditions. Because your deposits, wagers, and any winnings remain denominated in cryptocurrency at all times, the fiat-equivalent value of your Account balance may rise or fall significantly for reasons entirely unrelated to your gaming activity. We do not accept liability for changes in the fiat-equivalent value of your cryptocurrency holdings with us.

11. Domains, Sub-Domains, Aliases, and Mirror Sites

11.1. This Policy, and the DLAG approval described in Clause 2, applies individually to every domain, sub-domain, alias, and mirror site through which we offer cryptocurrency payment methods. We will not extend cryptocurrency acceptance to a new domain, sub-domain, alias, or mirror site without first obtaining the corresponding DLAG approval.

12. Changes to This Policy

12.1. We will notify you when we make significant changes to this Policy, and will notify the Commission of such changes within 24 hours together with the rationale for making them, consistent with our approach to changes to our Terms and Conditions.