Skin Joker is an innovative online casino created for those seeking both excitement and top-tier entertainment. From the very beginning, we’ve focused on delivering a diverse range of games, secure payment options, and a user-friendly interface. Our mission is to blend a passion for gaming with fair play and transparent principles, ensuring every player can fully immerse themselves in thrilling gameplay without worrying about safety or data protection.

At Skin Joker, we continuously expand our library by partnering with leading game providers, offering the latest titles and compelling experiences. We pride ourselves on regulatory compliance, reliable support, and maintaining a seamless platform, whether you’re new to online gaming or a seasoned player. Here, winning goes hand in hand with genuine fun, and every spin holds the potential for a truly unforgettable moment. Join us at Skin Joker, where the thrill of the game takes center stage.

Welcome to our online casino! Before you immerse yourself in the thrill of spinning reels, shooting for multipliers, or testing your luck on the wheel, please read the following guidelines:

1. General Conduct

   • All games operate under strict fair-play standards with certified Random Number Generator (RNG) systems or provably fair mechanisms.
   • Players must comply with our Terms and Conditions to ensure a safe and equitable gaming experience.

2. Slots

   • Spin the reels in pursuit of matching symbols along active paylines.
   • Additional features like wilds, scatters, and bonus rounds can boost your winnings.
   • Always review each game’s paytable for details on symbols and payouts.

3. Table Games

   • Classic favorites (like Blackjack, Roulette, and Baccarat) follow traditional casino rules.
   • Stick to the minimum and maximum bet limits displayed at each table.
   • Some games allow side bets or special wagers; read the on-screen rules to learn about any extra features.

4. Crash Games

   • A multiplier increases in real time until it “crashes.”
   • Cash out before the crash to secure your winnings.
   • Use caution and strategy when deciding when to exit the game.

5. Wheel Games

   • Predict where the wheel will land by placing bets on segments, numbers, or colors.
   • Each wheel segment has its own payout ratio.
   • Thoroughly read the instructions for each variant to understand special rules.

6. Live Dealer Games

   • Interact with professional dealers via real-time video stream.
   • Chat features allow communication but maintain respectful conduct at all times.
   • Game flow and payouts mirror traditional, land-based casino standards.

7. Responsible Play

   • Keep track of your spending and playing time.
   • Use our responsible gaming tools (e.g., deposit limits, time-out options) if needed.
   • Seek assistance if you suspect problematic gambling habits.

Following these rules will help maintain a fun, fair environment for everyone. Enjoy your time here, and good luck!

Version 2.0 Effective date: 21 April 2025

Document Status & Integration

This Policy is a binding schedule to the Terms & Conditions and must be read alongside the Privacy Policy, AML/KYC Policy and Game Fairness & Integrity Statement. Where terminology overlaps, definitions in the Terms & Conditions prevail.

1. Objectives

1. Protect Players from gambling-related harm by embedding preventive measures, early-warning detection and rapid intervention.
2. Deter Under-Age & Vulnerable Access through rigorous age-verification, parental-control guidance and marketing discipline.
3. Foster an Informed Environment in which gambling is positioned strictly as leisure, never as income generation or investment.
4. Align with International Best Practice including:
   • UK Gambling Commission (LCCP — Social Responsibility Code 17);
   • Malta Gaming Authority RG Directive 2021-012;
   • European Committee for Standardisation (CEN) Workshop Agreement CWA 16259;
   • FATF risk-based approach to VASPs for crypto-related red-flags.

2. Key Definitions

3. Corporate Governance & Responsibilities

4. Under-Age & Vulnerable Player Safeguards

1. Age Verification:
   • Automated Tier 1 screening (DOB, IP, device fingerprint, phone validation) at sign-up.
   • Documentary Tier 2 checks (photo ID + proof of address) mandatory before first withdrawal.
2. Parental Controls:
   • Prominent footer links to Net Nanny, Qustodio, Norton Family, OpenDNS FamilyShield.
   • Advice sheet “Keeping Kids Safe Online” available for download.
3. Voluntary Vulnerability Flag:
   • Players may self-declare mental-health or addiction concerns; the account is then subject to mandatory cooler period and weekly contact.

5. Player-Protection Toolkit (Extended Features)

Implementation SLA: 15 minutes from confirmed request (via UI, chat or e-mail).

6. Risk-Monitoring & Automated Interventions

All events feed into a Player RG Score (0–100). Score ≥ 65 triggers mandatory loss limits; score ≥ 80 forces self-exclusion recommendation.

7. Crypto-Specific Harm-Reduction Measures

• Volatility Disclaimer
  Deposit panels display real-time USD conversion plus 24 h price change.
• ‘Crypto ≠ Investing’ Banner
  Rotating banner reminds Players that “Gambling winnings are not investments. Cryptocurrency values may fall.”
• Mixer / Privacy-Coin Ban
  Deposits from mixers, tumblers or privacy-focused coins are rejected—reducing high-risk anonymity loops.

8. Educational Resources

SkinJoker curates a multilingual Help Centre with:

• Budget-planning worksheets;
• Videos on house edge & RTP;
• Articles on recognising problem gambling;
• A 20-question Self-Diagnosis Test adapted from the Canadian Problem Gambling Index (CPGI). Test results are stored locally on the device, not on our servers, to protect privacy.

9. Marketing, Bonuses & Affiliate Controls

1. Opt-In Only
   Marketing e-mails/SMS/push require explicit consent (double opt-in).
2. Content Standards
   No “risk-free”, “income” or “debt-solution” claims; mandatory “18+ | Play Responsibly” footer.
3. Bonus Clarity
   Wagering multiplier, expiry, max bet and game weighting stated with ≥ 11-pt font, no asterisks.
4. Affiliate Monitoring
   RG compliance clause in all affiliate contracts; quarterly review of partner content; zero-tolerance for misleading or under-age targeting—breach results in claw-back and programme expulsion.

10. Staff Competence & Culture

• Induction Training
  8-hour RG module covering addiction psychology, communication skills, suicide-prevention protocols.
• Annual Refresher
  4-hour update; pass mark 85 %.
• RG Champions
  Each shift has a trained champion authorised to impose emergency limits without managerial approval.
• Mental-Health Support for Staff
  Confidential counselling, recognising vicarious trauma from regular exposure to distressed players.

11. Data Protection & Confidentiality

• RG data (limits, exclusions, chat notes) is stored in a segregated schema, encrypted (AES-256) and access-restricted to RG personnel.
• Retention: 5 years after account closure or end of exclusion, whichever is later (aligned to EU AMLD 6 & Hong Kong AMLO).
• Disclosure: Only to the Player, authorised staff, or statutory authorities under lawful request. No RG data is used for marketing profiling.

12. Policy Review, Metrics & Continuous Improvement

Policy undergoes full review annually or immediately after a material RG incident. Revised versions are posted in the RG footer link and communicated via in-site message.

13. Complaints & Escalation

1. Front-Line
   Live chat or e-mail to rg@skinjoker.com (response ≤ 1 h).
2. RGM Review
   Formal resolution within 14 days; written outcome sent to Player.
3. Independent Mediation
   If unsatisfied, Player may request mediation by a certified addiction counsellor jointly appointed (costs borne by SkinJoker).

14. Contact Points

24 / 7 / 365 Assistance

• Live Chat (icon bottom-right)
• rg@skinjoker.com (dedicated RG desk)
• +852 5803 8760 (Hong Kong, English)

Remember
Gambling should be fun, not a financial plan.
If you ever feel pressure, pause, set limits, or walk away. Help is always available.

Version 1.0 Effective date: 21 April 2025

These General Rules

These General Rules apply to every visitor and registered player (“Player,” “you”) of the skinjoker.com cryptocurrency-gaming platform (“Site”) operated by SkinJoker Tech Ltd. (“SkinJoker,” “Company,” “we,” “us,” “our”). They complement—yet do not replace—the legally binding Terms & Conditions, Privacy Policy, AML/KYC Policy, Responsible-Gaming Policy and Game Fairness & Integrity Statement. If a conflict arises, the Terms & Conditions prevail.

1 Scope and Acceptance

By accessing, browsing or using any feature of the Site you confirm that you have read, understood and agree to abide by these General Rules in full. If you disagree with a rule, cease use immediately.

2 Eligibility and Jurisdiction

1. Age – You must be 18 years of age or older (or the legal age of majority in your jurisdiction) to open or use an account.
2. Restricted Territories – Players located in, or ordinarily resident in, any country listed in Schedule A (see §15) are strictly prohibited from accessing the Site, even via VPN, proxy, TOR or similar tools.
3. Self-Assessment – You are solely responsible for ensuring that unlicensed online gambling is lawful in your location before depositing funds or placing wagers.

3 Account Creation and Security

1. Single-Account Rule – Only one account per natural person is allowed. Duplicate accounts will be merged; bonuses and linked winnings may be voided.
2. True Data – All registration details must be accurate and kept current. False or misleading information is grounds for suspension.
3. Credential Duty – Maintain the confidentiality of your username, password and two-factor authentication (2FA) credentials. All actions taken under your login are deemed yours.
4. KYC/AML – Documentary identity verification is mandatory before any withdrawal or when cumulative deposits/withdrawals reach the crypto-equivalent of EUR 2,000 in a 24-hour period.

4 Deposits, Withdrawals and Wallet Rules

All transactions must originate from, and be paid to, wallets controlled by you. Deposits routed through mixing/tumbling services or privacy-enhanced coins will be refused and may trigger an AML review.

5 Gameplay Conduct

1. Fair Play – Use of bots, scripts, collusion, exploitation of software errors, or any external aid that manipulates game outcome or speed is forbidden.
2. Game Integrity – All results are generated by certified RNGs or provably-fair algorithms. Disputes are resolved using the recorded server outcome.
3. Malfunctions – In the event of a manifest error or malfunction, affected wagers may be voided and the stake returned at management’s discretion.

6 Bonuses and Promotions

• Default wagering requirement: 35 × (bonus + deposit for match offers).
• Expiry: 7 days after crediting unless stated otherwise.
• Maximum bet while wagering: USD 5 equivalent per spin/hand/round.
• Abuse (e.g., bonus stacking, hedge betting, multiple accounts) voids the promotion and associated winnings.

7 Chat and Community Behaviour

• Respectful language is mandatory; hate speech, harassment, threats or spam is prohibited.
• Advertising external websites, competing services or selling accounts/items is not allowed.
• Violations may lead to mute, chat ban or account suspension.

8 Responsible Gambling

• Set deposit, loss, wager and session limits or activate time-outs at any time via the Responsible-Gaming panel.
• Self-exclusion options: 6 months, 1 year, 5 years or permanent (irreversible for the chosen term).
• Withdrawals are locked – they cannot be cancelled once requested, to help prevent loss-chasing.
• Independent help lines (GamCare, Gambling Therapy, NCPG) are linked in the Site footer and reality-check pop-ups.

9 Anti-Money-Laundering (AML) Obligations

• SkinJoker monitors deposits, gameplay and withdrawals in real time.
• We may request source-of-funds/wealth documents and block or reverse transactions deemed suspicious.
• Suspicious Activity Reports may be filed with competent authorities without notice to you.

10 Software, Hardware and Intellectual Property

• All software is provided “as is.” Compatibility with your device is your responsibility.
• Intellectual-property rights in the Site and Games remain with SkinJoker or its licensors; you receive a personal, non-transferable right to use them for private entertainment only.

11 Data Protection and Cookies

Personal data is processed according to the Privacy Policy. Essential cookies are required for login and gameplay; non-essential cookies are controlled via consent-management.

12 Complaints and Dispute Resolution

1. Lodge complaints via support@skinjoker.com or live chat within 30 days of the event.
2. We acknowledge within 24 hours and aim to resolve within 14 days.
3. Unresolved disputes proceed to confidential arbitration in Hong Kong as outlined in the Terms & Conditions.

13 Breaches and Sanctions

• Minor breaches: warning, temporary suspension, removal of chat privileges or bonuses.
• Major breaches (fraud, collusion, AML violations): account termination, confiscation of funds, notification to authorities and permanent ban.

14 Updates and Amendments

SkinJoker may amend these General Rules at any time. Material changes are announced via e-mail or in-site message 7 days before they take effect. Continued use of the Site after the effective date constitutes acceptance.

15 Schedule A — Restricted Territories (Non-Exhaustive)

Australia; Curaçao; Czech Republic; France & Overseas Territories; Islamic Republic of Iran; Israel; Lithuania; the Netherlands & BES islands; North Korea; Singapore; Spain; Syrian Arab Republic; United Kingdom; United States of America & territories; any jurisdiction subject to comprehensive OFAC sanctions. SkinJoker may update this list at its discretion.

16 Support and Contact

• General & Account Support (24 / 7 / 365): support@skinjoker.com
• Responsible-Gaming Desk: rg@skinjoker.com
• Live Chat: Icon bottom-right on every page

Postal address:
SkinJoker Tech Ltd.
22/F, 2 International Finance Centre
8 Finance Street, Central, Hong Kong SAR, China

Play responsibly. 18 + only. Gambling is entertainment, not investment. Stop when the fun stops.

Last revised: 21 April 2025

Preamble

The present Terms & Conditions (the “Agreement”) govern the relationship between you (“Player”, “user”, “you” or “your”) and SkinJoker Tech Ltd., a company incorporated in Hong Kong SAR, China, under number 3098212, having its registered office at 22/F, 2 International Finance Centre, 8 Finance Street, Central, Hong Kong (“SkinJoker”, “Company”, “we”, “us”, “our”).

By clicking “Create Account”, depositing cryptocurrency, placing any wager, participating in any promotion or otherwise using the domain skinjoker.com (the “Site”) you confirm that you have read, understood and irrevocably accepted this Agreement in its entirety together with the:

• Privacy Policy (data protection and cookies);
• Responsible-Gambling Policy (self-exclusion tools and addiction safeguards);
• AML/KYC Policy (identity verification and source-of-funds requirements);
• Game Fairness & Integrity Statement; and
• any game-specific rules, bonus terms, tournament rules or additional conditions we publish from time to time.

If you disagree with, or cannot comply with, any provision, you must not open an account or otherwise use the Site.

1. Definitions

2. Legal Status & Disclaimer of Regulatory Oversight

2.1 SkinJoker currently does not hold a remote-gaming licence issued by any governmental or regulatory authority. We operate from an offshore location and voluntarily apply industry best practices for game integrity, AML/CFT and responsible gambling.

2.2 Accordingly, by using the Site you expressly acknowledge and accept that:

• no statutory deposit-guarantee or alternative dispute-resolution scheme applies;
• you have no recourse to a regulator for complaints; and
• you engage with the Site entirely at your own risk and subject to your own legal assessment of local laws.

3. Eligibility, Jurisdiction & Player Representations

3.1 You represent and warrant that each of the following statements is true at all material times:

1. You are at least 18 years old or have attained the age of legal majority in your jurisdiction;
2. You are not a resident, citizen or ordinarily located in a Restricted Territory;
3. You are not listed on any sanctions list (e.g., OFAC, EU Consolidated List, UN sanctions);
4. You have not previously been self-excluded or had an account closed by SkinJoker;
5. The funds you use derive from lawful sources and are free of any lien or encumbrance;
6. You are acting solely on your own behalf and not for any third party.

3.2 The Company reserves the unilateral right to refuse service, cancel wagers, or close accounts where it reasonably suspects non-compliance with the above representations.

4. Account Creation, Verification & Security

4.1 To open an Account you must provide a valid e-mail address, create a strong password and accept this Agreement.

4.2 KYC Tier 1: automated age, IP and device screening is completed immediately upon registration.
KYC Tier 2: prior to the first withdrawal or when cumulative deposits/withdrawals reach the crypto-equivalent of EUR 2,000 in any 24-hour period, you must upload:

• government-issued photo ID (passport, national ID card or driver’s licence);
• recent proof of address (utility bill or bank statement ≤ 3 months old); and
• a real-time selfie for biometric comparison.

4.3 One Account Rule. Each individual may hold only one Account. Duplicate Accounts will be consolidated; any Bonus Funds and associated winnings may be voided.

4.4 You must keep credentials confidential. You are solely responsible for any activity conducted via your Account, whether authorised or not. Compromised credentials must be reported to support@skinjoker.com without undue delay.

5. Deposits, Withdrawals & Wallet Management

5.1 Minimum deposit: crypto-equivalent of USD 10. Deposits are credited when the transaction achieves three (3) network confirmations.

5.2 Minimum withdrawal: crypto-equivalent of USD 20. Standard maximum withdrawal: USD 50,000 per 7-day rolling period. Higher limits may be granted to VIP tiers subject to Tier 3 verification.

5.3 Irreversibility. Blockchain transactions are non-reversible. Confirm the accuracy of the destination address before sending funds.

5.4 The Company maintains distinct cold-wallet storage for not less than 90 % of aggregate Player balances, with the remainder in a hot wallet for operational liquidity. Multi-signature protocols are enforced.

5.5 Withdrawals undergo risk analysis. The Company aims to approve requests within 15 minutes; however, security or compliance reviews may extend processing to a maximum of 24 hours.

5.6 The Company does not charge internal fees. Variable miner or network fees apply and are deducted automatically from the payout amount.

5.7 Reverse withdrawals are not permitted as a responsible-gaming safeguard.

6. Bonuses, Promotions & Wagering Requirements

6.1 Unless expressly waived, all Bonuses are subject to:

• 35× wagering requirement on Bonus Funds (bonus + deposit for match offers);
• 7-day expiry;
• USD 5 (crypto equiv.) maximum bet per spin/hand while wagering; and
• game-contribution weighting (e.g., slots 100 %, roulette 10 %, baccarat 0 %).

6.2 Bonus abuse—including but not limited to multi-accounting, hedge betting, “bonus hunting”, or low-risk wagering—renders the Bonus void at the Company’s discretion.

6.3 Promotional free spins have a default value of USD 0.10 (crypto equiv.) per spin unless stated otherwise.

6.4 Tournaments are scored according to the specific event rules (highest multiplier, total wagered, consecutive wins). In cases of a tie, precedence is given to the earliest time stamp.

7. Game Rules, Fairness & Technical Interruptions

7.1 Third-party Games: supplied by studios licensed in Malta, Gibraltar, Isle of Man, Estonia or equivalent and certified by independent test houses (GLI, iTech Labs, eCOGRA).

7.2 Proprietary Games: operate on provably fair algorithms. Verification tools (client seed, server seed, nonce) are accessible within the Game interface.

7.3 Disconnection Policy: if a Game round is recorded on the server, the outcome remains valid and will display upon reconnection. If no outcome is recorded, the stake is returned.

7.4 In the event of a manifest error, hardware failure or rogue RNG result outside statistical norms, the Company may void affected wagers and reinstate the pre-game balance.

8. Responsible-Gambling Measures

8.1 Self-service tools: Players may set deposit, loss, wager and session limits; enable hourly reality checks; impose a “time-out” (24 hours – 6 weeks); or activate self-exclusion (minimum 6 months, maximum permanent).

8.2 Self-exclusion is enforced across all Accounts held with the Company. Attempting to circumvent exclusion will result in immediate termination and forfeiture of any balance.

8.3 Contact details for accredited counselling bodies (GamCare, Gambling Therapy, NCPG) are provided in the footer and responsible-gaming pages.

9. Anti-Money-Laundering & Counter-Terrorist Financing (AML/CTF)

9.1 The Company adheres to Financial Action Task Force (“FATF”) recommendations and relevant Hong Kong AML legislation. Accordingly:

• transactional monitoring is performed in real time;
• deposits from mixers, tumblers or privacy-enhanced coins may be rejected;
• source-of-funds checks are triggered by large, rapid or unusual play patterns.

9.2 Suspicious Activity Reports (“SARs”) may be filed with competent authorities. You waive any right to be informed of such filings.

10. Prohibited Practices

It is strictly forbidden to:

1. use bots, AI or scripts to gain an advantage;
2. collude with other Players;
3. manipulate or exploit software errors;
4. launder funds or facilitate illicit transactions;
5. access the Site via proxy, VPN, TOR or similar obfuscation tech;
6. threaten or harass staff or other Players;
7. distribute or post unlawful, defamatory or obscene material.

Violations may result in confiscation of funds, Account closure and notification to law-enforcement.

11. Intellectual Property & Third-Party Content

All Content is protected by copyright, trademark and other intellectual-property laws. You obtain no ownership rights. Third-party marks (e.g., game studios) remain the property of their respective owners.

12. Privacy & Cookies

Personal data is processed per the Privacy Policy, which forms an integral part of this Agreement. Essential cookies are required for Site functionality; non-essential cookies are controlled via consent management.

13. Taxation

SkinJoker does not withhold taxes. You are responsible for declaring and paying any tax due on winnings under the laws applicable to you.

14. Liability & Indemnification

14.1 The Site is provided “as is” without warranties of any kind. We do not warrant uninterrupted availability, error-free operation or future profitability.

14.2 To the maximum extent permitted by law, the Company’s aggregate liability shall not exceed the lesser of (i) the crypto equivalent of USD 10,000 or (ii) the net deposits made by you during the preceding six months.

14.3 You shall indemnify, defend and hold harmless the Company, its directors, employees, affiliates and suppliers against any claim arising from your breach of this Agreement, violation of law or misuse of the Site.

15. Suspension, Termination & Forfeiture of Funds

15.1 The Company may suspend or terminate your Account if:

• KYC/AML requirements are unmet;
• fraudulent, collusive or criminal activity is suspected;
• chargeback or crypto transaction reversal is initiated;
• you reside in or relocate to a Restricted Territory.

15.2 Legitimate balances, net of promotional funds and chargeback offsets, will be paid to you unless prohibited by law or a competent authority.

16. Complaints & Dispute Resolution

16.1 Internal procedure: contact support@skinjoker.com within 30 days of the incident. Provide username, date/time, Game ID and a detailed description.

16.2 We will acknowledge receipt within 24 hours, issue a case reference and aim to resolve within 14 days.

16.3 Arbitration: unresolved disputes shall be submitted to binding arbitration in Hong Kong under UNCITRAL Rules, seated in Hong Kong, language English. The arbitrator’s decision is final. Each party bears its own costs unless the arbitrator decides otherwise. Class or group actions are expressly waived.

17. Force Majeure

The Company is not liable for delay or failure to perform resulting from events beyond its reasonable control, including but not limited to act of God, war, civil unrest, pandemic, governmental action, power outage, telecommunications failure or blockchain network disruption. Time for performance is extended for the duration of such event.

18. Changes & Updates

We may modify this Agreement at any time. Material changes are announced via e-mail or in-site notification at least seven (7) days before they take effect. Your continued use after the effective date constitutes acceptance. If you disagree, you must close your Account before the new terms apply.

19. Assignment

SkinJoker may assign or novate its rights and obligations under this Agreement to any subsidiary, affiliate or successor without notice. You may not assign your rights or obligations.

20. Severability & Waiver

If any clause is found invalid or unenforceable, the remaining provisions remain in full force. No waiver by the Company of any breach shall be deemed a waiver of any subsequent breach.

21. Governing Law

This Agreement shall be governed by the substantive laws of the Hong Kong Special Administrative Region, excluding conflict-of-law principles.

22. Language

This Agreement is drafted in English. Translations may be provided for convenience. In case of discrepancy, the English version prevails.

23. Contact

SkinJoker Tech Ltd.
22/F, 2 International Finance Centre
8 Finance Street, Central, Hong Kong, SAR China
General Support (24 / 7 / 365): support@skinjoker.com
Data Protection Officer: dpo@skinjoker.com

Schedule A — Restricted Territories (Non-Exhaustive)

Australia; Curaçao; Czech Republic; France & Overseas Territories; Islamic Republic of Iran; Israel; Lithuania; Netherlands & BES Islands; North Korea; Singapore; Spain; Syrian Arab Republic; United Kingdom; United States of America (inc. Puerto Rico, Guam, U.S. Virgin Islands, American Samoa); any state subject to comprehensive OFAC sanctions.
The Company may amend this list at its discretion. Presence in or relocation to a Restricted Territory subjects the Account to immediate closure.

Play responsibly. 18 + only. If gambling ceases to be fun, take a break and seek help from a recognised support organisation.

Version 3.0 Approved by the Board: 21 April 2025

1. Purpose

This Policy sets out the comprehensive framework adopted by SkinJoker Tech Ltd. (“SkinJoker,” “Company,” “we,” “our”) to detect, deter and report money-laundering (ML), terrorism-financing (TF), sanctions evasion, fraud and any other illicit use of the cryptocurrency gaming platform skinjoker.com (the “Site”). The Policy supplements our Terms & Conditions, Privacy Policy, Responsible-Gaming Policy, Game Fairness & Integrity Statement and General Rules.

Although we operate without a state gambling licence, SkinJoker voluntarily aligns with:

• The Financial Action Task Force (FATF) Recommendations (updated February 2024);
• Hong Kong Anti-Money-Laundering & Counter-Terrorist-Financing Ordinance (Cap. 615);
• EU Sixth Anti-Money-Laundering Directive (AMLD 6);
• FinCEN guidance for convertible virtual-currency (CVC) providers;
• Joint Working Group IVMS 101 Travel-Rule Standard.

2. Scope & Application

Subject Entities

• All natural persons using the Site (“Players”).
• All SkinJoker directors, officers, employees and contractors (“Staff”).
• Third-party service providers performing AML/KYC functions (“Associated Parties”).

Covered Activities

• Cryptocurrency deposits, wagers, withdrawals, voucher redemptions and promotional credits.
• Player-to-Player (“P2P”) transfers (if enabled).
• Any other financial or value transfer activity facilitated by the Site.

3. Legal & Regulatory Framework (Key Provisions)

4. Governance & Organisational Structure

Escalation hierarchy and 24 / 7 contact tree are detailed in Internal SOP AML-001.

5. Risk-Based Methodology (Enterprise-Wide Risk Assessment, “EWRA”)

Reviewed annually and when triggering events occur.

6. Customer Due-Diligence Programme

6.1 CDD Tiers & Verification

Non-completion within 30 days ➔ account suspension + potential balance freeze pending review.

6.2 Beneficial-Ownership (Corporate Clients)

• Certificate of incorporation, shareholder register (> 25 % BO), director IDs.
• Corporate proof of address, business licence.
• Board resolution authorising account and designated signatory.

6.3 Politically Exposed Persons & Sanctions

• Real-time API screening on onboarding & every 4 h thereafter.
• PEPs permitted subject to Tier 3 EDD + deposit cap USD 10 000 eq./week.
• Positive sanctions result → immediate account lock, funds blocked, MLRO review.

6.4 Travel-Rule Compliance (Crypto Transfers ≥ USD 1 000 eq.)

• Originator & beneficiary data (IVMS 101) sent via CipherTrace Traveler to Travel-Rule-enabled VASP counterparties.
• If beneficiary VASP is non-compliant, withdrawal is routed via in-house Travel-Rule hold wallet pending manual review.

7. Cryptocurrency-Specific Controls

1. Blockchain Analytics – Chainalysis KYT risk scoring on every inbound/outbound transaction; score ≥ 75/100 auto-block.
2. Mixer / Privacy-Coin Ban – Deposits from Tornado Cash, Blender, CoinJoin clusters, Monero, Zcash-shielded rejected.
3. Wallet Management – Fresh deposit address (BIP-32) per transaction; hot-wallet cap = trailing 24-h average withdrawals; multi-sig cold wallets (3/5 quorum) with Hardware Security Modules.
4. Address Blacklist – Daily import of OFAC SDN, EU, UN, UK and HKMA crypto-wallet lists.
5. Volatility Risk Alert – Auto message if token price drops > 20 % 24-h asking Player to reconfirm withdrawal address.

8. Ongoing Monitoring & Transaction-Screening Programme

8.1 Automated Rule-Set (Sample)

8.2 Machine-Learning Module

• Gradient-boosting model (AUC 0.93) flags anomalous wager paths, chip-dumping & collusion rings; retrained monthly on labelled SAR outcomes.
• Features: session length, bet variance, token exchange rate correlation, time-zone irregularities.

9. Suspicious Activity Reporting (SAR)

“Tipping-off” is strictly prohibited (Cap. 405 §25).

10. Record-Keeping & Data Protection

Processing is lawful under Art. 6 (1)(c)(f) GDPR; data shared strictly on a “need-to-know” basis.

11. Training & Staff Competence

Training content reviewed by MLRO & HR; completion tracked in LMS.

12. Independent Audit & Assurance

• Auditor engaged under ISAE 3000 standard.
• Scope: EWRA validation, random 5 % CDD file check, SAR timeliness, system penetration & Travel-Rule test transfers.
• Report delivered to Board; remediation deadlines logged in ComplianceTracker GRC.

13. Breach Management & Enforcement

1. Minor Breach (documentation delay < 48 h) → formal reminder + 24 h cure period.
2. Material Breach (EDD refusal, high-risk wallet deposit) → account suspension, balance freeze, potential SAR.
3. Critical Breach (sanctions match, evidence of terrorist financing) → immediate freeze, SAR, permanent account termination, notice to law-enforcement.

Internal disciplinary procedures apply to Staff negligence or wilful non-compliance (up to dismissal).

14. Review, Change-Control & Version History

Policy reviewed annually or upon regulatory trigger (e.g., new FATF guidance). Change proposals logged in Compliance JIRA; Board approval required for material revisions.

15. Appendices

Appendix A — Glossary
(abridged: AML, CDD, EDD, FIU, HSM, IVMS 101, ML, PEP, SAR, TF, VASP)

Appendix B — Schedule A (Restricted Territories)
Australia; Curaçao; Czech Republic; France & DOM-TOM; Iran; Israel; Lithuania; Netherlands & BES; North Korea; Singapore; Spain; Syria; United Kingdom; United States & territories; any comprehensively sanctioned state.

Appendix C — Red-Flag Typology Matrix

(Full 60-indicator matrix available to authorized Staff in SOP AML-002.)

Contact (24 / 7 / 365)

Money-Laundering Reporting Officer
SkinJoker Tech Ltd.
22/F, 2 International Finance Centre, 8 Finance Street, Central, Hong Kong SAR, China
e-mail: aml@skinjoker.com (PGP key ID 0x98F1 A7C3)
Hotline: +852 5803 8761

Failure to comply with KYC requests or involvement in suspicious activity will result in account suspension, possible forfeiture of funds and notification to the competent authorities.
Play responsibly. 18 + only.

Last updated: 21 April 2025

1 Purpose of This Notice

This Cookie & Tracking Notice (“Notice”) explains how SkinJoker Tech Ltd. (“SkinJoker,” “we,” “our,” “us”) uses cookies, software development kits (“SDKs”), pixels and comparable technologies (collectively, “Cookies”) when you visit or interact with the website skinjoker.com and its sub-domains, mobile progressive-web application (PWA) and application-programming-interface endpoints (together, the “Site”).

It should be read together with our Privacy Policy, which describes in detail how we process personal data. Capitalised terms not defined here carry the meaning set out in our Privacy Policy or Terms & Conditions.

2 What Are Cookies?

Cookies are small text files stored on your device when you browse a website. They enable recognition of your browser, store preferences or collect usage statistics. We also employ other identifiers—such as HTML5 local-storage objects, device IDs, web beacons and JavaScript-based SDKs—which, for regulatory purposes (GDPR, UK GDPR, ePrivacy Directive, CCPA/CPRA), are treated like cookies.

3 Why We Use Cookies

* Under the EU ePrivacy regime, Strictly Necessary cookies do not require consent; all others do. For CCPA/CPRA, collection constitutes “sharing” or “sale” only where targeted advertising identifiers are involved—users may opt-out.

4 First-Party vs Third-Party Cookies

• First-Party Cookies are set directly by SkinJoker (e.g., sk_session, rg_prefs).
• Third-Party Cookies are set by service providers acting under contract. We impose contractual data-protection addenda (DPAs) and Standard Contractual Clauses (SCCs) when data is transferred outside the EEA/UK.

A complete, dynamically updated list is available in the Cookie Preferences Centre (link in footer).

5 Cookie Preferences & Withdrawal of Consent

When you first land on the Site, a banner explains our use of non-essential cookies and offers three options:

1. “Accept All” – enables all categories.
2. “Decline Non-Essential” – only strictly necessary & security cookies remain.
3. “Customise” – granular toggles for Functional, Analytics, Marketing categories.

You can change your settings anytime via Cookie Settings in the footer. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6 Browser & Device Controls

• Delete or block cookies in browser settings (Chrome, Firefox, Safari, Edge).
• Use browser add-ons such as Google Analytics Opt-out (GAO-O) or uBlock Origin.
• Reset advertising identifiers on Android/iOS (“Reset Advertising ID”).

Blocking certain cookies may degrade functionality (e.g., staying logged in, wallet address generation).

7 Other Tracking Technologies

• Web Beacons / Pixels
  1×1 gifs loaded from ad networks to record impressions.
• Local Storage
  Used to cache provably-fair seeds for offline validation; cleared when you clear browsing data.
• Software Development Kits (SDKs)
  Firebase Cloud Messaging for push notifications; Intercom SDK for in-app chat.
• Server-Side Logging
  TLS handshake meta-data, IP, user-agent, device fingerprint—stored in encrypted log buckets for 7 days, strictly for security diagnostics.

8 Do Not Track (DNT) & Global Privacy Control (GPC)

The Site currently honours GPC signals for California residents by treating them as an opt-out of cross-context advertising cookies. Traditional DNT headers are not universally supported and therefore not acted upon.

9 Data Sharing & International Transfers

Cookie-derived data may be transferred to the United States, Singapore or other jurisdictions where our vendors host servers. We rely on SCCs, vendor Binding Corporate Rules or adequacy decisions to safeguard such transfers (see Privacy Policy §8).

10 Data Retention

Cookie identifiers are stored no longer than listed in §4 or as required for legal or security purposes (e.g., AML audit logs). Aggregated, de-identified analytics data may be retained indefinitely.

11 Updates to This Notice

We may update this Notice to reflect changes in technology, legal requirements or business practices. Material changes are announced via the cookie banner and a prominent Site notice 7 days before taking effect. Continued use of the Site after the effective date constitutes acceptance.

12 Contact

Data Protection Officer
SkinJoker Tech Ltd.
22/F, 2 International Finance Centre, 8 Finance Street, Central, Hong Kong SAR, China
E-mail: dpo@skinjoker.com • Support (24 / 7 / 365): support@skinjoker.com

Play responsibly. 18 + only.

Version 2.0 Board approval date: 21 April 2025

1. Purpose & Policy Statement

SkinJoker Tech Ltd. (“SkinJoker,” “we,” “our”) is committed to providing a transparent, fair, and timely mechanism for resolving player complaints and disputes related to the cryptocurrency-based gaming services offered via skinjoker.com (the “Site”). This Procedure establishes a multi-stage complaint-handling system and an optional ADR pathway that—while not mandated by a state regulator—aligns with ISO 10002:2018 (Customer-Satisfaction Management), UKGC LCCP SR Code 6 best practice, and the EU ADR Directive 2013/11/EU.

2. Regulatory Context & Guiding Principles

Core Principles: Accessibility • Fairness • Confidentiality • Timeliness • Transparency • Non-Retaliation.

3. Scope & Applicability

* Out-of-scope items are routed to Feedback Management (CSR-004 SOP).

4. Definitions

See Appendix A for the full glossary; key terms include Complaint, Dispute, ADR, Working Day.

5. Roles & Responsibilities

6. Complaint Categories & Severity Matrix

Severity influences escalation priority but not outcome fairness.

7. How to File a Complaint

Mandatory data (use Template B – Complaint Form in Appendix):

1. Username & registered e-mail.
2. Transaction / Game ID(s).
3. Date & time (UTC).
4. Detailed narrative (≤ 1,000 words).
5. Supporting evidence links or attachments (max 10 MB).

Submission channels (monitored 24 / 7 / 365):

• E-mail: complaints@skinjoker.com
• Secure online form: skinjoker.com/complaints
• Live-chat: select “Complaint” from topic drop-down.
• Postal (last resort): Complaints Officer, 22/F, 2 IFC, 8 Finance Street, Central, Hong Kong.
• Voice calls are accepted but must be followed by written confirmation to preserve audit trail.

8. Data Requirements & Evidence Standards

• Blockchain proof
  Provide full TX hash; screenshots alone are insufficient.
• Game proof
  Use built-in “Copy Fairness Log” button; do not alter JSON.
• Video evidence
  MP4 < 50 MB; must include address bar & system clock.
• Document authenticity
  Metadata must match file creation date; altered PDFs may be rejected.

9. Internal Complaint-Handling Workflow

1. Acknowledgement – auto-ticket ID + human confirmation within 24 h.
2. Triage – assign severity; gather logs, server seeds, KYC notes.
3. Investigation – cross-departmental (Risk, RG, TechOps); Player updates every 48 h.
4. Draft Decision – CO summarises facts, policy references, remedy proposal.
5. Quality Review – HPP & CCO sign-off for High severity cases.
6. Outcome Notification – plain-language e-mail containing decision, supporting evidence, ADR info.
7. Closure – CRM ticket flagged “Resolved,” “Partially Resolved,” or “Rejected”; JSON export to Complaints Register (Appendix C).

10. Key Service-Level Objectives (SLOs)

11. Root-Cause Analysis (RCA) & Corrective Actions

RCA mandatory for High-severity upheld Complaints.

• Tools: 5 Whys, Fishbone (Ishikawa), Pareto charts.
• Corrective actions may include game provider patch request, staff re-training, KYC SOP revision, or UI content updates. RCA report stored in Confluence with JIRA ticket linkage.

12. Alternative Dispute-Resolution (ADR) Framework

12.1 ADR Provider Criteria

• ISO 17024 compliant staff competence.
• Data-protection measures (GDPR, PDPO).
• Decision publication policy respecting party anonymity.

SkinJoker has contracted with:

1. eCOGRA Mediation Service – informal document mediation (Level 1).
2. HKIAC – arbitration under UNCITRAL Rules, seat Hong Kong (Level 2).

12.2 Fees & Costs

13. Record-Keeping, Reporting & Oversight

Quarterly analytics are presented to the Board: volume, category distribution, RCA themes, corrective actions.

14. Abuse, Vexatious Conduct & Anti-Harassment Safeguards

• Warn Players using abusive language, issuing threats, or spamming.
• Suspend Complaint processing until respectful communication resumes.
• Terminate accounts where vexatious behaviour persists (≥ 3 frivolous Complaints closed as unfounded within 6 months).

15. Continuous Improvement & Annual Review

PDCA cycle applied:

1. Plan: Identify KPI gaps, regulatory changes.
2. Do: Implement updated SOPs, staff training.
3. Check: Audit sample files, verify SLOs.
4. Act: Board approves revisions, publishes Version update.

Annual third-party audit (ISO 10002 lead auditor) verifies framework adequacy.

16. Updates & Change-Control

Material revisions (e.g., different ADR provider, time-frames) are notified via e-mail and in-site banner 7 days prior. Version log maintained in Appendix D.

17. Contact Directory

Postal: SkinJoker Tech Ltd., FAO Complaints Officer, 22/F, 2 International Finance Centre, 8 Finance Street, Central, Hong Kong SAR.

Play responsibly. 18 + only.
If gambling ever stops being fun, please use our Responsible-Gaming tools or seek help from an accredited support organization.