version 2.0. – January 2026
This Player Complaints & Dispute Resolution Policy (the “Policy”) is issued by MUCHGAMING B.V., a company registered in Curaçao, with business address at Korporaalweg 10, Willemstad, Curaçao (hereinafter: “we”, “us”, “our”, “Company”). The Company operates the online gaming brand Crypto.Games and is governed by Curaçao law, including the applicable licensing and regulatory framework for online games of chance. The Company operates under licence number OGL/2024/1336/1047 (the “Licence”) and any applicable regulations, licence conditions, and guidance issued by the competent Curaçao gaming authority (collectively, the “Applicable Framework”).
1.1. Our commitment. We believe players and users must be able to provide feedback and raise concerns about our services in a simple, fair, and transparent way. This includes complaints about account matters, game outcomes, payments/withdrawals, bonuses, technical issues, responsible gaming measures, and other service-related topics.
1.2. Purpose of this Policy. This Policy:
1.3. Principles. We handle complaints:
1.4. Governance & ownership. The Company maintains internal procedures and tools to log, track, and resolve complaints. The Chief Compliance Officer (CCO) is responsible for overseeing the implementation of this Policy, regular reporting (as required), and ensuring controls and training are in place. The Policy is reviewed at least annually and updated when required by the Applicable Framework or material business changes.
1.5. Relationship to other policies. This Policy operates alongside our Terms & Conditions, Responsible Gaming policy, AML/KYC policies, Privacy policy, and any other internal procedures governing our operations. If there is a conflict, mandatory provisions of the Applicable Framework prevail.
For the purposes of this Policy, the following terms have the meanings set out below:
ADR means Alternative Dispute Resolution, i.e., an independent out-of-court dispute resolution process.
ADR Provider means an independent dispute resolution entity certified/recognised for this purpose under the Curaçao online gaming regulatory framework and referenced in this Policy and/or our Terms & Conditions.
Applicable Framework means the Company’s Curaçao licence, applicable Curaçao laws and regulations for online games of chance, and any binding licence conditions/instructions applicable to complaints/ADR.
Business Day means a day other than Saturday, Sunday, or a public holiday in Curaçao.
Case Owner means the Company employee responsible for investigating, coordinating, and concluding a specific Complaint, including preparing the written outcome (this may be a Complaints Officer/Complaints Manager and/or the Chief Compliance Officer, depending on escalation level and complexity).
Complainant means the person submitting a Complaint (typically the Player; in limited cases, a “User” who is directly affected by the matter).
Complaint means a written expression of dissatisfaction directed to the Company regarding the provision of our services (including account matters, game outcomes, bonuses, payments/withdrawals, technical issues, or responsible gaming measures), submitted via the Official Complaint Submission Form or other “official” channel designated in this Policy.
Complaint File means the internal record for a Complaint, including the Complaint itself, communications, evidence, investigation steps, and the written outcome.
Complaint Management System means the Company’s IT/back-office system used to register, track, manage, and archive Complaints and Complaint Files (including allocation of a unique reference number).
Complaints Function means the Company’s oversight function responsible for governance of complaint handling (including escalation and reporting), led by the Chief Compliance Officer (and/or other designated responsible function, such as DPO, where relevant).
Dispute means a Complaint that remains unresolved to the Complainant’s satisfaction after the Company’s Final Determination, and which is escalated to internal review and/or ADR and/or the competent court.
Final Determination means the Company’s written final response on the merits of a Complaint, including reasons and next-step information (internal escalation and/or ADR options).
Official Complaint Submission Form means the Company’s designated complaint form (online and/or downloadable) that captures the minimum information needed to process a Complaint and triggers registration in the Complaint Management System.
Player means a natural person who holds an account with the Company and uses (or has attempted to use) the Company’s gaming services.
Responsible Gaming Complaint means a Complaint relating to responsible gaming measures (e.g., self-exclusion/cooling-off, time or deposit limits, vulnerable-player treatment, or alleged failures in applying requested restrictions).
3.1. Values. We are committed to delivering high-quality services and to handling player interactions, complaints, and disputes in a manner that is effective, efficient, fair, transparent, consistent, and timely.
3.2. Goals. The goal of this Policy is to set out a clear and practical framework for:
3.3. Objectives. The key objectives of this Policy are to ensure:
(a) Player-focused service delivery
(b) Supportive and effective complaint handling
(c) Business improvement and risk management
3.4. No retaliation. Players will not be mistreated for submitting a complaint. Submitting a complaint does not limit a player’s access to support channels and will not, by itself, result in account restrictions (except where needed for security, integrity of investigations, or compliance).
4.1. Who can submit a Complaint. This Policy applies to Complaints submitted by Players (account holders) and, where relevant, Users who can demonstrate they are directly affected by the matter complained of.
4.2. What this Policy covers. This Policy applies to Complaints relating to the Company’s services, including (without limitation):
4.3. What this Policy does not cover (exclusions). The following are generally outside the scope of this Policy (unless the Company decides otherwise in a particular case):
4.4. Third-party services and tools. Where a Complaint concerns a third-party service provider used in connection with our services (e.g., payment processors, KYC vendors), the Company remains the primary point of contact for the Player. We may need to liaise with the third party to investigate, but we will communicate the outcome to the Player in accordance with this Policy.
4.5. Multiple issues and linked Complaints. A Complaint may raise more than one issue. We may:
4.6. Abuse and bad faith. We may refuse to process a Complaint that is manifestly abusive (e.g., threats, harassment, spam) while still recording the incident and, where appropriate, offering a safe channel for legitimate concerns.
4.7. Priority treatment for responsible gaming matters. Complaints relating to responsible gaming (self-exclusion, limits, vulnerable players) are handled on an accelerated basis under this Policy and may be escalated immediately to the Complaints Function and/or senior management.
5.1. Player Interactions vs. Complaints. If you have a question, request, or general feedback that does not require a formal complaint outcome, please get in touch with Customer Support via Live Chat and/or email at [support email]. If you wish to submit a formal Complaint under this Policy, you must follow the process in Sections 5.2–5.7.
5.2. How to submit (official channels). Complaints must be submitted in writing , either:
5.3. Time limit (complaint window). You should submit your Complaint as soon as possible after the issue occurs. Unless mandatory law requires otherwise, Complaints should be submitted no later than six (6) months after the incident occurred or the relevant bet was settled (as applicable).
5.4. Minimum content requirements. To enable us to investigate properly, your Complaint must include at least:
5.5. Incomplete complaints/request for additional information.
(a) If your Complaint is incomplete or unclear, we may contact you to request additional written information or documents necessary to investigate and decide the Complaint.
(b) Unless we indicate otherwise, you must provide the requested information within five (5) Business Days of our request.
(c) If you do not provide the requested information within the deadline and we cannot reasonably proceed, the Company may close the Complaint without a determination on the merits (and will notify you accordingly).
5.6. Identity and security checks. Where a Complaint involves account security, payments/withdrawals, alleged fraud, or other sensitive matters, we may require reasonable steps to confirm that the Complainant is the account holder (or authorised representative) before disclosing account details or executing any corrective action.
5.7. Language. We will accept Complaints in English and/or the primary language of the relevant Crypto.Games website/domain, as made available via the Official Complaint Submission Form.
6.1. Receiving & registering a Complaint (logging).
(a) All Complaints received via the channels described in Section 5 are registered without undue delay in our Complaint Management System and assigned a unique reference number.
(b) Complaints submitted through the website (online form) are automatically integrated into the Complaint Management System.
(c) The Complaint record should include (at minimum) the following information (as applicable):
6.2. Acknowledgement of receipt.
(a) We acknowledge receipt in writing and provide the Complaint reference number.
(b) Where technically feasible, the Complaint Management System may send an automatic acknowledgement including the reference number.
(c) The acknowledgement will be in plain language, confirm that we are investigating, and provide an initial expected timeline / next update target (normally within 7 days).
(d) The Complainant should use the reference number in all future correspondence regarding the Complaint.
6.3. Case ownership, triage, and prioritisation.
(a) Each Complaint is assigned to a Case Owner (Complaints Officer or Chief Compliance Officer, depending on complexity/escalation).
(b) Complaints involving responsible gaming, account security, payments/withdrawals, or potential legal/regulatory exposure may be prioritised and/or escalated immediately.
6.4. Information requests / incomplete Complaints.
(a) If a Complaint is incomplete or unclear, the Case Owner may request additional information/documents in writing.
(b) Unless we state otherwise, the Complainant should provide the requested information within five (5) Business Days.
(c) If the Complainant does not provide the requested information within the deadline and we cannot reasonably proceed, the Company may close/dismiss the Complaint (with written notice).
6.5. Investigation & resolution timelines (internal).
(a) Immediate resolution: Where possible, Complaints that can be resolved immediately will be communicated to the Complainant the same day.
(b) Standard timeline: We aim to issue a Final Determination within four (4) weeks from receipt of a complete Complaint.
(c) Extension: If the Complaint is complex, we may extend once (with reasons and a new deadline communicated in writing).
(d) Responsible gaming Complaints: We apply an accelerated handling track (acknowledgement and resolution as soon as reasonably possible, given the circumstances).
6.6. Escalation (internal).
(a) Complaints not resolved at the first handling stage, or complaints that are complex/high-risk, may be escalated to the Chief Compliance Officer for review and determination.
(b) The Chief Compliance Officer may escalate material issues to management and/or competent authorities, where appropriate.
6.7. Closing the Complaint.
(a) Once resolved (or dismissed/closed), the Case Owner updates the Complaint Management System with a “closed” status and a summary of actions taken.
(b) All resolved Complaints are logged as such in the Complaint Management System.
7.1. Written final response (always). A Player will always receive a Final Determination of their Complaint in writing.
7.2. When issued / timelines.
(a) Responsible Gaming Complaints: we use best efforts to resolve within five (5) Business Days. We confirm receipt within two (2) days and explain processing and expected timelines; any justified delay must be communicated and is limited as described in the applicable guidelines.
(b) All other Complaints: we assess and respond within four (4) weeks of receiving a complete Complaint. If necessary due to complexity or lack of information, this may be extended once by an additional four (4) weeks, with prior written notice to the Player.
7.3. Content of the Final Determination. The Final Determination will include, as applicable:
7.4. Outcomes (what you may receive). The Final Determination will be one of the following:
If additional information is reasonably required to address the Complaint fully, we will request it within the initial four-week period. If the Player does not provide the information required within that period, we may reject the Complaint.
7.5. Delivery channel. The Final Determination will be sent using the same communication channel the Player used to submit the Complaint (unless we agree otherwise or we reasonably need to use a different channel for security reasons).
7.6. Post-analysis and continuous improvement. The Compliance function reviews complaints-handling data on an ongoing basis to identify recurring or systemic issues and potential legal/operational risks, and to initiate corrective actions where appropriate.
8.1. When a Complaint becomes a “Dispute”. A Dispute is a Complaint that has not been resolved to the Player’s satisfaction through the Company’s internal complaints process (including the Final Determination).
8.2. Access to independent ADR (Alternative Dispute Resolution).
(a) If you remain dissatisfied after our Final Determination, you may escalate the Dispute to an independent ADR provider that is certified by the Curaçao Gaming Authority (CGA).
(b) Only ADR entities holding an official CGA certification (published on the official website) are permitted to handle Disputes on behalf of CGA B2C license holders.
(c) We will clearly inform Players in our Terms & Conditions which CGA-certified ADR provider(s) are available. If we offer multiple ADR options, only the Player may choose which ADR provider to use.
(d) Cost: ADR is provided free of charge to the Player. The Company will bear all costs of the ADR process.
8.3. ADR provider details.
Current CGA-certified ADR provider(s) for Crypto.Games:eCOGRA (https://ecogra.org/alternative-dispute-resolution/)
8.4. Sharing the Complaint File with ADR. Upon written request by the ADR Provider, we will provide the relevant Complaint File and supporting information without undue delay (and, as a rule, within 2 Business Days) subject to lawful confidentiality, privacy, and security constraints.
8.5. ADR scope, refusal grounds & “no ADR shopping”. The ADR Provider may refuse to accept or continue a Dispute in certain cases, including where:
8.6. ADR decision timeframe. The ADR process is expected to take no more than 90 days from initial referral to completion.
8.7. Effect of ADR outcome (binding nature). The CGA expects that the outcome of the ADR process is binding on operators. Any further parameters (e.g., whether an ADR outcome is also binding on the Player, minimum claim value thresholds) must be proportionate and consistent with applicable law; disputes concerning responsible gaming measures must be addressed with full seriousness regardless of monetary value.
8.8. Role of the CGA (important notice). The CGA does not handle individual disputes between players and operators and cannot act as a civil court or order compensation. However, players may contact the CGA to report suspected breaches of the LOK/licence conditions and other compliance concerns.
8.9. Courts / legal action. If a Dispute is not resolved through the complaints process and/or ADR, either party may refer the matter to the competent courts, subject to applicable law and any mandatory rights that cannot be waived.
9.1. Complaint File (what we keep). For each Complaint, we create and maintain a Complaint File in the Complaint Management System. The Complaint File must include the information recorded upon receipt (see Section 6.1) and, at a minimum:
(a) a unique reference number;
(b) a copy of the Player’s Complaint submission (including attachments);
(c) a copy of the acknowledgement of receipt sent to the Player;
(d) investigation notes and results of the complaint-handling process, including supporting documents and internal approvals (as applicable); and
(e) a copy of the Final Determination (and any internal escalation outcome, if applicable).
9.2. Internal complaints register.
(a) The Company keeps a record of all Complaint Files in an internal complaints register maintained through the Complaint Management System.
(b) The register is managed under the responsibility of the Chief Compliance Officer (or other designated Complaints Function lead).
(c) Each Complaint File is marked “closed” and transferred into the register/closed-archive once the complaint settlement process is concluded (including where closed without determination due to lack of information).
9.3. Retention period. Records of complaints (Complaint Files and the register) are retained for ten (10) years, unless applicable law, licence conditions, regulatory instructions, or a legal hold require a longer retention period.
9.4. Confidentiality, access control & security.
(a) Complaint Files are treated as confidential and are accessible only to authorised personnel on a need-to-know basis.
(b) Access rights in the Complaint Management System must be role-based (e.g., Case Owners access only their assigned cases; the CCO has oversight access).
(c) The Company applies appropriate technical and organisational measures to protect Complaint Files (including secure storage, audit logs, and controlled export/sharing).
9.5. Transfers to ADR / authorities. Where a Dispute is escalated to ADR, we will share the relevant Complaint File with the ADR Provider upon legitimate request and in line with Section 8 (including the 2 Business Day target, unless a lawful restriction applies).
9.6. Monitoring & reporting. The Chief Compliance Officer performs ongoing review and analysis of complaint data to identify recurring or systemic issues and potential legal/operational risks, and to initiate corrective actions and management reporting as appropriate.
10.1. Customer Support (Stage 0 support). Customer Support:
10.2. Complaints Officer (Level 1 / Case Owner). The Complaints Officer acts as Case Owner for Level 1 Complaints and is responsible for coordinating the complaint handling process, including:
10.3. Multiple Complaints Officers (case allocation). Where more than one Complaint Officer exists:
10.4. Escalation proposal. A Complaints Officer may propose escalation of a Level 1 Complaint to Level 2 where:
10.5. Chief Compliance Officer (“CCO”) (oversight + Level 2 / Case Owner). The CCO is ultimately responsible for the complaints function and:
10.6. Escalation beyond compliance/authorities. Where appropriate, the CCO may escalate specific Complaints to:
10.7. ADR Provider (external dispute stage). Where a Dispute proceeds to ADR under Section 8, the ADR Provider:
10.8. All employees (duty to cooperate). All employees who are asked to support a Complaint investigation must cooperate promptly, provide relevant information, and preserve relevant records, subject to confidentiality and data protection requirements.
11.1. Fairness and neutrality. Complaints are handled fairly, objectively, and in good faith. Decisions are based on relevant facts, available evidence, the applicable rules (Terms, game rules, promotion terms), and the Applicable Framework.
11.2. No undue barriers / free of charge. Submitting and processing a Complaint under this Policy is free of charge for the Player. We do not impose unnecessary procedural barriers, and we keep requests for information proportionate to what is needed to resolve the matter.
11.3. Independence and conflicts of interest.
(a) The Company ensures that complaint handling is performed independently from the operational area that is the subject of the complaint, to the extent reasonably possible.
(b) Conflict rule: a person must not act as Case Owner where they were directly involved in the events being complained about or where a conflict of interest exists (or could reasonably be perceived).
(c) Where a conflict is identified, the Complaint must be reassigned to another Case Owner and/or escalated to the CCO.
11.4. Consistency. Complaints are handled consistently across similar scenarios. Where a departure from prior outcomes is justified (e.g., different evidence, new information, rule changes), the reasons must be recorded in the Complaint File.
11.5. Transparency and communication. We communicate in clear language, provide reasons for outcomes, and set realistic timelines and updates (including extension notices where applicable).
11.6. Confidentiality and data protection.
(a) Complaints and Complaint Files are confidential and are shared internally only on a need-to-know basis.
(b) We apply appropriate measures to safeguard personal data, account data, and security-sensitive information.
(c) Where we cannot disclose certain information (e.g., security/integrity measures, third-party confidential data, ongoing investigations), we will explain this in general terms where feasible.
11.7. Complaint trend analysis and remediation. The CCO reviews complaint trends and root causes, may initiate corrective actions (process improvements, training, control changes, product/UX adjustments), and escalates systemic issues to management.
11.8. Training and awareness. Relevant personnel receive training on: (i) identifying a Complaint, (ii) intake requirements, (iii) evidence handling, (iv) timelines, (v) RG escalation, and (vi) ADR handover procedures.
11.9. Quality assurance. The Company may conduct periodic sampling and review of closed Complaint Files to verify adherence to this Policy, the quality of reasoning, timelines, and completeness of records.
12.1. Overview. Our complaints management process follows a staged approach designed to resolve issues as early as possible, while ensuring an independent escalation path where needed. The end-to-end process contains five functional steps:
12.2. Stages (what the Player experiences).
12.3. Levels (how we allocate internally).
12.4. No skipping internal steps (general rule). Players cannot bypass the internal process by submitting directly to internal Level 2 and must complete the Company’s internal handling before external escalation to ADR (unless mandatory law requires otherwise).
13.1. General rule. We aim to resolve complaints as quickly as reasonably possible. Where we cannot resolve immediately, we will keep the Player informed and provide a written outcome within the timeframes below.
13.2. Acknowledgement of receipt.
(a) All Complaints: we acknowledge receipt in writing and provide a reference number (normally within one (1) week of receipt).
(b) Responsible Gaming Complaints: we acknowledge receipt within two (2) days.
13.3. Resolution timeframes (Final Determination).
(a) Immediate resolutions: where possible, issues that can be verified and corrected quickly (e.g., simple bonus clarification, obvious UI error, simple account question) may be resolved the same day.
(b) Standard Complaints: we aim to issue a Final Determination within four (4) weeks from receipt of a complete Complaint.
(c) Complex cases / extension: if a Complaint is complex (e.g., multiple transactions, technical integrity review, third-party confirmation), we may extend the deadline once by up to four (4) additional weeks. We will notify the Player in writing before the original deadline expires, explaining the reasons and the new expected date.
(d) Responsible Gaming Complaints: we use best efforts to resolve within five (5) Business Days (or sooner where possible).
13.4. Requests for information (stopping the clock).
(a) If we request additional information/documents under this Policy, the resolution timeline runs from the date the Complaint becomes complete.
(b) If the Player does not provide requested information within the stated deadline, we may close the Complaint without a determination on the merits (and notify the Player accordingly).
13.5. Status updates. For complaints that cannot be resolved promptly, we aim to provide at least one meaningful status update (e.g., “investigating”, “awaiting third-party confirmation”, “integrity review ongoing”) within seven (7) days of acknowledgement, and thereafter as reasonably needed until closure.
13.6. Prioritisation. The following categories may be prioritised and/or fast-tracked:
13.7. Internal escalation timing. Where the Player requests internal review (or the Case Owner escalates), we aim to confirm escalation and assign the Level 2 Case Owner within five (5) Business Days, and to proceed without undue delay.
13.8. ADR escalation timing. A Player may escalate to ADR once a Final Determination is issued (or earlier only where mandatory law requires). The ADR Provider’s procedures processinggovern ADR Provider’s timeframes; we will cooperate and provide the Complaint File promptly as described in this Policy.
14.1. Official complaint channels. Players may submit Complaints via the channels set out in Section 5, including by completing the Official Complaint Submission Form (online and/or downloadable) and/or by email to the Company’s designated complaints address.
14.2. Primary contact details:
14.3. Same-channel rule for responses. The Company will, as a rule, send the acknowledgement and the Final Determination using the same communication channel the Player used when submitting the Complaint, unless a different channel is necessary for security reasons or is agreed with the Player.
14.4. Plain-language communications. We communicate in a clear, plain-language manner that is reasonably understandable to players, including in automated acknowledgements and status updates.
14.5. Reference number usage. Players should quote the complaint reference number in all future communications relating to the same Complaint/Dispute to enable efficient handling and retrieval.
14.6. Website publication. This Policy (and the complaint submission form/process) is published in a publicly available section of the Company’s website to ensure transparency and accessibility.
15.1. Approval and ownership. This Policy is an internal control document approved by the Company’s management and overseen by the Chief Compliance Officer.
15.2. Review cycle. This Policy is reviewed at least annually and updated as required to ensure ongoing compliance with applicable laws, licence conditions, and business operations.
15.3. Material changes. Where updates materially affect Player rights or procedures (e.g., complaint channels, ADR Provider details, timelines), we will publish the updated version on the website and update cross-references in the Terms & Conditions.
15.4. Version control.
Version: 2.0
Effective date: 17 January 2026
Replaces: The legacy dispute resolution policy versioned “v1.0 – May 2020” (where applicable).
15.5. Contact for questions about this Policy. For questions about this Policy, please contact [email protected]
________________________________________________________________________
Select category (tick one):
_______________________________________________________________________________ _______________________________________________________________________________
_______________________________________________________________________________
Tick what you attach:
List attachments (file names): ____________________ 2) ____________________ 3) ____________________
Declaration
By submitting this form, I confirm that:
Signature (if applicable): __________________________
Full name: __________________________
Date: ____ / ____ / ______
________________________________________________________________________________
If you submit on behalf of the Player, attach written authorisation (POA/authorisation letter).
Briefly describe the issue and include key facts (amounts, bet IDs/round IDs, transaction hashes/IDs, dates, what happened).
Dispute summary:
__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Explain why you disagree with the Company’s Final Determination (e.g., incorrect application of rules, missing facts, technical evidence, payment status).
Grounds:
State what you want the ADR Provider to decide (e.g., pay withdrawal, correct settlement, bonus adjustment, refund, account action).
Requested remedy:
Select the ADR Provider from the CGA-certified list (as referenced in our Terms / Complaints Policy).
Full name: ____________________________
Signature (if applicable): ____________________________