1. General Introduction and definitions
1.1. All products are operated by FreeLabs Inc. Curacao (from herein referred to as “The Company”). A company operating under sublicense #8048/JAZ2019-XXX issued by Antillephone N.V., regulated by the Central Government of the Netherlands Antilles.
1.2. “T&Cs” are the terms & conditions constituting and governing the contractual relationship, as stated herein, and which the parties, as stated herein, hereby agree upon.
1.3. “The Platform” is the collection of games, services, products, and goods that The Company makes available through various digital and physical channels
1.4. “The Application” refers to the proprietary mobile and/or desktop and/or web application software developed by The Company which is designed to provide monitored and regulated access to The Platform
1.5. A "Client" is an individual, with The Application downloaded on his/her mobile or other device, and/or having an account, therefore, a contractual relationship with the company.
1.6. An "Account" is an account held by a Client, for bona fide transactions, with a strict aim to establish a normal commercial relationship with the company and with the purpose of conducting betting and other gaming and gambling transactions as well as other games and services that are available on The Platform.
1.7. The "Governing Authorities" are the authorities of Curacao. The "Governing Law" is the law of Curacao.
1.8. "Force Majeure" refers to any occurrence or condition beyond one's reasonable control which leads to a delay or default in the performance to the affected party's contractual obligation and shall, for the purposes of the T&Cs, include Acts of God, Government restrictions (including the denial or cancellation of any necessary license where such denial or cancellation is made through no fault of the affected party), wars, insurrections and/or any other cause beyond the reasonable control of the party whose performance is affected.
1.9. All trademarks, service marks and trade names as well as images, graphics, text, concepts or methodologies (collectively the “Intellectual Assets”) found on the Website, The Application and the material contained therein are the exclusive property of The Company and/or The Company suppliers and partners. The Client is not entitled to exploit or otherwise use any Intellectual Asset for whatever purpose, except for what is allowed by law.
1.10. "Mining" is defined by users permitting The Company to use the CPU power of the device(s) they own and/or control to perform cryptocurrency mining activity, by installing or activating The Application on said device(s).
1.11. "Free" is defined by the fact that gameplay is not paid for by subscriptions, or cash deposits, but through the process of Mining.
1.12. "Bolts" are the in-game credits. Users use Bolts to play games, bid for prizes in auctions and win jackpots. Users obtain Bolts through Mining, promotional awards, or through games.
1.13. The “Prize Auction” is a digital auction made available on the platform weekly or bi-weekly for users to browse through prizes that they can bid on using their Bolts.
1.14. An “Auction Prize” is a product, service, cash-equivalent, or voucher that the Customer has won through their participation in an auction using the Bolts in their account.
1.15. “Gambling Games” refers to electronic games that require a license for distribution as defined by the Curacao e-Gaming Licensing Authority
1.16. “Casino” refers to the specific user interface within The Application that provides access to Gambling Games
1.17. “Casino Games Providers” refers to authorized Gambling Games vendors that are contracted by The Company via a commercial agreement for rights to access and distribute electronic gaming content
2. The meaning of Free, Mining and the Bolt credit
2.1. The Company defines Free as the policy of:
2.1.1. Not accepting cash deposits for game wagers in any form (i.e. credit-card, bank transfer, crypto-currency transfer, etc)
2.1.2. Prohibiting any attempt to deposit cash with The Company for game wagering purposes, or for increasing the number of Bolts in a Customer account
2.2. Bolts are credits that can be used on The Platform for gameplay, auctions, and other activities as made available by The Application as defined in section 3 and section 4
2.3. Bolts can only be generated by the Customer through Mining, or awarded through winnings by playing games, taking part in promotions on the Platform, or by other non-cash deposit associated means
2.4. The act of mining is allowing a mobile phone or personal computer to complete mining on a network..
2.5. While the Customer may use electricity and CPU processing power as part of the Mining activity to generate Bolts, and incur costs in that process, the Customer agrees that Bolts do not represent any monetary value and can not demand any monetary compensation from The Company for any Bolts in their account
2.6. The Customer may not use Bolts for any purpose, by any means, other than by methods made available by the Platform as detailed in section 3 and section 4
2.7. For the avoidance of doubt, Free does not mean that the Customer is entitled to claim any products, services, goods, cash or items of monetary value from the Company without any exchange from the Customer to the Company; rather the Bolt credit is required as the medium of exchange between the Customer and the Company
3. Account Rules, Auctions and Withdrawals
3.1. An individual applying for registration warrants and represents that any information provided in its application form is true and correct. The Company will not register the individual and, where that individual has already been registered, The Company will cancel that individual's registration as a player if it becomes aware that individual has provided false information when registering as a player. Upon signing up for an account, the player will be requested for their full name, email, date of birth, residence address and phone number. This information must be real and verifiable upon creation of the account. IMPORTANT NOTICE: Date of birth can never be changed on an account. The phone number, and e-mail cannot be changed post account creation unless specially requested and user may have to undergo KYC a second time.
3.2. In order for the Client to request withdrawals, remove all initial limitations and have full rights in the promotions, the account must be verified. For the account to be verified, The Company will request for all of the following details:
3.2.1. Client’s government approved ID for age verification as players under eighteen (18) years of age are not accepted (via a driver’s license, voter registration ID, passport, or similar)
3.2.2. Proof of client’s place of residence as certain territories are not accepted (via a utility bill or similar proof of address)
3.2.3. Client’s valid e-mail address (cannot be the same as any existing Client’s email address) or phone number.
3.3. In the event the Client changes their place of residence, telephone number or any other element of his data, he/she is obliged to immediately inform the company, so the new data can be updated. Prize redemption will not be possible without all details being up to date and verifiable.
3.4. An individual applying for an Account acknowledges and accepts:
3.4.1. The “T&Cs” as currently published on the website, as well as any possible future changes. The Company reserves the right to make changes to these T&Cs at any time without notice. The Company will ensure that the customer is informed about such changes when the client next logs into their account by asking the customer to accept the revised Terms and Conditions. If the customer refuses consent, the client will be prohibited from using the Company’s service. These “T&Cs” shall be made readily available and accessible to players at all times;
3.4.2. Any regulatory provisions or other decisions made from time to time by the Governing Authorities;
3.4.3. The Company customer support may be available in several local languages. In any case of a dispute between a Client and the Company, only the English version shall prevail and be used;
3.4.4. As part of the registration process, the Client will have to choose which phone number and/or email address they wish to use for login into the Website. As login is secured through One Time Passwords (OTP), it is The Clients’ sole and exclusive responsibility to ensure that access to their email address and/or phone(s) are kept secure and not shared with others. The Client must not disclose their login details or OTP to anyone. The Company is not responsible for any abuse or misuse of your account by third parties due to a disclosure, whether intentional or accidental, whether active or passive, of the Client’s login details or OTP codes to any third party;
3.5. The Company reserves the right, at its own discretion and at all times, to:
3.5.1. Decline to open an Account and/or to close an existing Account informing the account holder, should the company believe the account contains false information, is not human-operated, has been opened by a person in a banned jurisdiction or any other reason that may put the Company, its directors or shareholders at legal, reputational, compliance, or any other kind of risk;
3.5.2. Decline to accept or limit mining submissions and therefore not issue the associated Bolt reward(s), without any explanation whatsoever;
3.5.3. Suspend Client’s account and/or cancel the participation of a Client in promotional activities, competitions or other services, whenever The Company is of the opinion that there are legitimate concerns that an account is, has been or may be used for illegal, fraudulent or dishonest practices. The client will be informed in writing through email or text message;
3.5.4. Where applicable, hold and manage funds belonging to Clients in accordance with generally accepted guidelines for cash management regarding such funds; this may include a Payment Service Provider being entrusted to hold funds in the name of and/or for the benefit of the Client;
3.5.5. Suspend and/or cancel the participation of the Client in the Services, and/or forfeit and/or confiscate credits available on his/her Client Account if the Client is found cheating, or if it is determined by the Company that the Client has employed or made use of a system (including machines, robots, computers, software or any other automated system) designed or suitable to defeat the Application and/or the Platform, and/or the software used to offer the Services. The client will be informed in writing through email or text message;
3.5.6. Suspend and close the client ́s account if the Company does not have interest in the Customer activity in its website, due to suspicious behavior or account inactivity. The Company would be entitled to terminate their services to the Client without providing compensation. The client will be informed in writing through email or text message.
3.5.7. Limit each customer’s winnings to a maximum of Euro14,000 equivalent per day and cancel any extra winnings that customer might generate through his play.
3.5.8. Hold or charge any Payment method fees or expenses, from the Client’s account, for all the previous deposits and withdrawals, plus any administrative or legal costs the Client provoked for any reason due to customer activity on the platform, whenever The Company is of the opinion that there are legitimate concerns that an Account is, has been or may be used for illegal, fraudulent or dishonest practices.
3.5.9. In case of a possible refunding to the client in regard to the above-mentioned cases, the maximum refund is limited to the last deposit minus the deposit and withdrawal fees.
3.6. The Company does not accept clients:
3.6.1. Under the age of 18 years old to play on The Company’s gambling games;
3.6.2. Being residents of The United States of America, other U.S. territories, and France, The Netherlands, Saba, Statia, St. Maarten, Singapore, Aruba, Bonaire and Curaçao;
3.6.3. Being professional punters, betting syndicates, traders, professional athletes and players wagering for the sole scope to take advantage of “inside” information;
3.7. The company accepts no responsibility for any Betting Duties or taxes arisen by the local authorities of the client’s territory. Such duties or taxes are paid exclusively by the client. If the client refuses to pay such amounts, the company has no liability whatsoever.
3.8. Only one Account can be opened at a time per person, telephone number and email address. In the event that we suspect that:
3.8.1. A Client is opening multiple accounts (using same or similar names, address, telephone, e-mails, same or similar dynamic IP address, computers or other devices);
3.8.2. A Client is acting as a part of syndicate (using same or similar names, address, telephone, e-mails, same or similar IP address, computers or other devices, acting on same or similar pattern);
The company reserves the right to block the relevant Account(s) held by the Client or the Syndicate and report the incident(s) to the relevant Authorities. Following an internal investigation, The Company has the right to cancel bets, forfeit winnings, and deduct bonuses from all relevant accounts as these are tracked on our ledger. The Company also reserves the right to reallocate the Bolt credits awarded from Mining activity from the different superfluous Accounts to a single Account (original account) and to delete the remaining superfluous account(s). Any bonuses given to the superfluous Account(s) will not be transferred.
3.9. Should The Client want to permanently close their account on The Platform, they may email [email protected] and request permanent deletion of the said account. NOTE: Should the user then decide to reopen the account, he/she will need to register as a new user and provide new and updated KYC information.
3.10. Any legal claim or dispute arising under or in connection with the Contract shall be settled in accordance with the Governing Law of Curacao. In the event of a dispute, it is advisable that the Account Holder lodges a complaint with customer service using the contact details in the Website. Customer service will respond within 48 hours of the lodged complaint. The parties should do their utmost to reach an amicable settlement within a reasonable time and in no later than 10 days. The client may also lodge a complaint within 6 months to [email protected] The complaint must contain clear and unequivocal information about the complainant's identity and shall give all the relevant details that gave rise to the complaint.
3.11. The Company Website works by using cookies for the following purposes:
(a) To identify the Client's preferred language so it is automatically selected when the Client returns to Website;
(b) To ensure that bets placed by the Client are associated with the Client's betting coupon and account;
(c) To ensure that the Client receives any bonuses the Client is eligible for;
(d) For analysis of Website traffic so as to allow us to make suitable improvements. Please be aware that it is not possible to use the full functionality of the Website without cookies.
3.12. The Company shall not accept a wager in Bolts from a Client unless an Account has been established in the name of the Client and there are adequate Bolts in the Account to cover the amount of the wager.
3.13. The Company does not accept cash deposits via credit card, bank transfer, crypto-currency transfer, or any other such means for use as wagers in games as detailed in section 2.
3.14. The Customer may use their Bolts to redeem goods, products or services via the auction provided by the Platform, such redemptions are referred to as Auction Prizes. The rules governing the auction and Auction Prizes are as follows:
3.14.1. The Company will present a list of products, goods, and/or services that an individual Customer is entitled to bid for. Note that the list of products, goods, and/or services may differ for each Customer on a basis that the Company deems fit – this may include factors such as, but not limited to, geographic location, account balance, account age, Customer age, and previous auction participation information;
3.14.2. The Customer acknowledges that the auction item availability algorithm is proprietary to The Company and accepts that it may vary from time to time;
3.14.3. Each auction item will, at minimum, have an item description, current bid price, and auction closing time;
3.14.4. The Customer that commits the highest value of Bolts to the bid item at the auction closing time is deemed to be the winner of that item and entitled to the Auction Prize;
3.14.5. The Customer acknowledges that winning an Auction Prize will result in exchange of their committed Bolt credits for the Auction Prize;
3.14.6. The decision of the Auction Prize winner is made by the system at auction closing time, and where a Customer disputes the system decision they may appeal to The Company for a review by completing the necessary appeal application at https://www.freeca.sh/appeals within 24 hours of the winner being declared. The customer accepts that:
188.8.131.52. Incomplete appeals applications will invalidate the appeal;
184.108.40.206. Following a review by the company, that all decisions made by The Company are considered final and may not be appealed again;
3.14.7. No Auction Prize will be disbursed/awarded without full KYC being completed as described in section 3.2. Additionally, if the Customer requests an Auction Prize to be sent to a prohibited jurisdiction, only committed Bolts will be returned; no Auction Prize will be disbursed/awarded.
3.14.8. For any disbursements or awards of Auction Prizes, The Company reserves the right to charge administrative costs, together with any commission due to third parties – if such costs are applicable they will be clearly indicated in the item description at the time of auction;
3.14.9. The Company will communicate to The Customer the timeline and process for Auction Prize disbursement within 72 hours of the Customer completing KYC and selecting the redemption method with associated details; where the Company is unable to confirm logistics within 72 hours for whatever reason, the Customer will be notified via email or text message by when The Company expects to be able to confirm;
3.14.10. In the event that the requested Auction Prize is no longer available, the Customer accepts that the Company will endeavor to provide an item of similar type or value;
3.14.11. The Customer accepts that under Force Majeure alternative redemption methods may need to apply, which may include the cancellation of the redemption and a refund of Bolt credits to the customer account
3.15. In the case of a problem gamblerThe Company will offer the user the option to self-exclude him/herself from the gambling games. This will require the user to register using their email/phone number and provide full KYC information to The Company. The user will then be blocked from gambling games for six months. Self-Exclusion requests will be processed immediately or within 72 hours. The user will still be allowed to mine and earn Bolts and use the Bolts in the auction and other digital services that the platform provides that are unequivocally not gambling related. After the six-month period has elapsed, if the user chooses, he/she will be able to request access to the gambling games after The Company receives a letter of acceptance from an immediate family member, and the family member’s KYC information. The user may also have to submit to The Company additional documentation that may be requested. Problem gamblers are encouraged to look into https://www.begambleaware.org. to safeguard themselves from other gambling sites.
4. Games, Casino Games, Lotteries and other entertainment
4.1. The Company will be offering the user a multitude of digital entertainment products including but not restricted to games of skill and games of chance, video content, avatar and profile personalization.
4.1.1. All Gambling Games offered on the Platform have had their Random Number Generator certified by an appropriate independent third party. Where the Company works with Casino Games Providers, fairness will be ensured through yearly certification checks.
4.1.2. Gambling Games may include but are not restricted to:
5. Content may be provided by Casino Games Providers as well as proprietary content from The Company itself.
5.1. As mentioned in 3.14 problem gamblers will have the option to self-exclude themselves from the Casino and Gambling Games but nonetheless maintain access to The Company’s other content.
5.2. Access to content will otherwise be available to users immediately upon registration unless there is a scheduled or emergency maintenance of The Platform. In the case of a scheduled maintenance, The Company aims to inform users if services are hindered at least 24 hours before. In the case of an emergency maintenance situation The Company will inform users as soon as possible or within 48 hours of the work being carried out.
5.3. The Company will make best efforts to ensure availability of The Platform, however the Company makes no guarantee that the Customer will be able to access The Platform to play games, place bets, perform Mining, or request redemptions, and can not be held liable for interruptions to service.
6. Games General Rules
6.1. All bets placed on the Gambling Games are placed respectively on the servers of 3rd party providers depending on the provider of the game in which the bet is placed. The Company is licensed by the Casino Games Providers to represent, promote, and market the Gambling Games. The Company receives, holds and pays funds in relation to an Account holder for the purpose of transactions and settlements with the Casino Games Providers.
6.2. All Gambling Games are highly trustworthy and verified from authorities to prevent any potential hacking action. However, technology loopholes that The Company has no control of may be taken advantage of by specific users. Irregular winnings or betting patterns will be investigated, and The Company reserves the right to confiscate any winnings made under such pattern. Users are not allowed to deposit Bolts from ill-gotten means.
6.3. If bonus rules are misspelled or omitted by any client who takes advantage by acting in a fraudulent attitude alone or as a syndicate, The Company reserves the right to confiscate any winnings made under such pattern.
6.4. The user hereby agrees that in case the Customer wins a jackpot of EUR 5,000 or higher (or the equivalent to any other currency) in relation to any Gambling Game offered by The Company in The Platform, the winnings may be awarded once the Casino Games Provider verifies and accepts it within a 1 month time frame.
6.5. The Company has insured Jackpots with the Casino Games Providers therefore all winnings are paid through the global pools. For the avoidance of any misunderstanding, the Client will receive the winnings once the Casino Games Provider has transferred the relevant funds to The Company within 1 month of the win.
6.6. Standard Promotional Terms
6.7. The terms contained in this document (Standard Promotional Terms) apply to all promotional offers available through the Website, the Application and the Platform (each a Promotion) and, together with any applicable specific promotional terms, which may also be referred to as "Key Terms", set out on the individual web landing page, and/or application screen, for the relevant Promotion (Specific Promotional Terms), form a legal agreement between the user and The Company and can only be amended with consent. By participating in any Promotion, the user is accepting and agreeing to be bound by the Rules.
6.8. In the event of any conflict or inconsistency between these Standard Promotional Terms and the Specific Promotional Terms, the Specific Promotional Terms shall prevail, followed by these Standard Promotional Terms, but only to the extent necessary to resolve such conflict or inconsistency.
6.9. Unless otherwise indicated, participation in each Promotion is limited to one per person, family, household, address or organization to whom The Company sends the Promotion. The Company reserves the right to restrict participation in certain Promotions to players who fulfill specific selection criteria. Where a Promotion permits multiple participants, The Company reserves the right, in its sole discretion, to limit the number of participants.
6.10. In the event that a user uses Bolts in respect of which the user has received a Bonus, without having met any applicable release requirements, usage restrictions or general eligibility criteria, the user shall forfeit the entire sum of the Bonus and any winnings resulting from this Bonus, The Company shall be entitled to deduct this from the user’s Account.
6.11. In the event that The Company deems that an irregular playing pattern has taken place, The Company reserves the right to prevent the user from using Account funds and/or withhold any of the user’s winnings derived from the user’s use of the bonus.
6.12. Any disruption to the system platform due to force majeure is out of the company’s hands to predict or repair, customer must agree not to hold the company liable
6.13. Player domain and game servers are in Curacao.