GORILLA GAMEZ LLC
RESPONSIBLE GAMING POLICY
December 2025, V. 1.0
Introduction
Gorilla Gamez LLC (“Gorilla Gamez”, the “Company”) is committed to ensuring that its platform is operated in a secure, fair, and socially responsible way. Our aim is to endorse and encourage Responsible Gaming (“RG”) amongst its players, employees, and stakeholders. Responsible Gaming encompasses the processes, tools and resources that allow players to have a fair and safe experience with the Company, while protecting them from problem gaming issues. In addition, Gorilla Gamez is committed to upholding the licensing objectives and compliance frameworks of any gaming regulators that may regulate its activities now and in the future.
As part of this Policy, Gorilla Gamez will:
- Ensure compliance with all applicable federal and state laws regarding Responsible Gaming and consumer protection.
- Provide easily accessible, clear, and meaningful information to players regarding Responsible Gaming tools and restrictions so that they can make informed choices about using the Company’s platform and services.
- Inform players or prospective players about the help and assistance they can utilize should they experience any signs of problem gaming.
- Make all reasonable efforts to avoid marketing to minors as defined by each state in which Gorilla Gamez conducts business.
- Make reasonable efforts to avoid marketing to self-excluded players.
- Ensure that its marketing and advertising efforts are responsible and contain any relevant Responsible Gaming information required by each state in which Gorilla Gamez conducts business.
Registration & Verification
- Prohibition of Underage Players – Identification and Verification
- Participation in gaming by an underage player is prohibited.
- Before a player can complete registration and begin their play on the website, the player must accept Gorilla Gamez’s Terms & Conditions and affirm that he or she is at least 18 years of age, or such higher age as required by local law.
- Gorilla Gamez will check the name, age, and address of an individual at registration.
- If a player is confirmed to be a minor, Gorilla Gamez will undertake the relevant steps required to block that player’s registration and access.
- Duplicate Accounts
- Gorilla Gamez will ensure that a player is only able to register, fund, and maintain one active account.
- Any duplicate accounts will be flagged and closed by the Company. This process allows the Company to comply with its fraud and security responsibilities, but it also allows Gorilla Gamez to prevent players who may wish to circumvent any Responsible Gaming tools set on their initial account.
- The Company will monitor for any duplicate email addresses, IDs, or multiple accounts using the same IP. Once identified a temporary lock will be applied and Customer Support will address with the player until resolved.
Credit to Players
- Gorilla Gamez will not provide players with credit or loans.
Responsible Gaming Tools
- Gorilla Gamez wants our players to have an entertaining and fun experience on our website. We also want our players to play responsibly. To accomplish both goals we have established tools that a player can use to better control their level of gameplay.
- Gorilla Gamez will periodically review this policy to implement best practices to achieve a robust Responsible Gaming environment. Currently, Gorilla Gamez is developing the following Responsible Gaming tools that are described more fully below:
- Deposit limits
A deposit limit will limit the amount a player can deposit during a certain period (daily or monthly). Once they have reached this sum, they will not be able to make any new deposits until their limit has reset. Deposit limits may be reduced at any time but increasing the deposit limit may only be done upon customer confirmation at the start of the following period. Customers will receive a notification if they attempt to exceed the limit, and the deposit will be prevented. Gorilla Gamez has set the maximum daily deposit limit for all users at $5,000. Users will be able to set their own monthly deposit limit.
- Time outs
The player can choose to take a time out — a designated time frame to take a break (72 hours, 7 days, 14 days, 30 days, or 60 days). During this time, the player will only be able to withdraw funds from their account. The ability to enter contests and/or deposit additional funds will reopen automatically after the chosen period has expired.
Self-Exclusion / Restriction
Self-exclusion is a tool for players who are experiencing issues with problem gaming. During the time the player is self-excluded they will only be able to withdraw funds from their account. Gorilla Gamez will use reasonable efforts to ensure the player will not receive marketing communications from the Company during any period of self-exclusion.
Players can set their self-exclusion period for 6 months, 1 year, 2 years, 5 years, or permanently.
Responsible Gaming Information
Gorilla Gamez will ensure that relevant Responsible Gaming and related information is easily accessible to players. This information contains details of organizations and bodies that provide help and assistance to problem gamblers and their families.
In providing and directing players to these sources for assistance, Gorilla Gamez aims to ensure that Players with a gaming problem will get help and assistance from a reputable source with expertise in this area.
Player Activity Monitoring
Player activity will be monitored for behavior that may indicate a possible concern or responsible gaming issue. If concerns are identified, Gorilla Gamez may contact the player to determine whether these concerns are warranted and whether further actions (including account restrictions) are appropriate. Activity monitored may include, but is not limited to:
- Time played.
- Number of payment methods used.
- Changes to player-imposed deposit limits.
- Cancelled withdrawal requests; and
- Number or frequency of time-out or self-exclusion requests.
Prohibitions on Advertising to Minors
Gorilla Gamez will not market exclusively or primarily to minors, according to the definition of minor in each state and/or as specifically defined in any rules or regulations relating to pay-to-play gaming products in any jurisdiction. To ensure that Gorilla Gamez’s marketing does not target minors, the Company will:
- Require all partner media outlets, websites, or other entities to agree to take reasonable measures not to target minors on behalf of Gorilla Gamez;
- Make reasonable efforts to ensure that advertising networks do not place Gorilla Gamez material on any websites that are aimed exclusively or primarily at minors;
- Not use any search engine optimization terms that target exclusively or primarily minors;
- Require that individuals or other entities speaking on behalf of Gorilla Gamez on television, radio, or online outlets understand and acknowledge this aspect of the Gorilla Gamez marketing policy; and
- Ensure that in-person promotional events, should the Company hold these in the future, are staffed by individuals who understand and acknowledge the Gorilla Gamez marketing policy.
Prohibitions on Marketing to Self-Excluded Players
Gorilla Gamez will automatically prevent self-excluded players, third party-excluded players, or players otherwise barred from participating in Gorilla Gamez contests from receiving marketing or direct contact via the following methods:
- App push
- Calls / Texts
Socially Responsible Marketing
Gorilla Gamez will ensure that marketing communications do not suggest that our contests are a solution to financial concerns, an alternative to employment, or a way to achieve financial security. Gorilla Gamez will make information about responsible play available to consumers, clearly and conspicuously, on its website and mobile applications.
Gorilla Gamez will communicate the location of such resources, where a player could easily identify it in each advertisement, landing page, or other location referencing pay-to-play games. The responsible play information will include the name and toll-free number of at least one reputable source where problem gamers can receive assistance.
Training
Various levels of responsible gaming training are provided to employees and other stakeholders of the Company, depending on the role of the employee/stakeholder with Gorilla Gamez. These are periodically reviewed to ensure they are up to date with the latest regulatory changes, trends, and best practices.
Training materials include but are not limited to the following information:
- Gorilla Gamez’s current policies and procedures with a description of Gorilla Gamez’s Responsible Gaming tools
- Red flags that help identify potential problem gaming
- How to assist a player who may be at risk of harm or be a compulsive gambler.
Periodic Review
Gorilla Gamez will conduct a review of its Responsible Gaming Policy annually or sooner if required. Any material changes to the Policy will be reviewed and approved by the Compliance Officer or their designee.
Record Retention
Gorilla Gamez will maintain all documentation related to its Responsible Gaming Policy per the Company’s Data Retention Policy in conjunction with any state-specific regulatory requirements. This will include player history and transactions, as well as marketing and advertising material.
Document Version & Approval History
| Version ID | Approval Date | Reviewer Name/Title | Approver Name/Title | Revision Notes |
| V1.0 | Document Creation | |||