Terms & Conditions

Introduction

1.1 These Terms & Conditions govern access to and use of the website of Resolvo Curaçao N.V. and the alternative dispute resolution services provided by Resolvo Curaçao N.V. ("Resolvo", "we", "us", "our").

1.2 Resolvo is an independent alternative dispute resolution provider based in Curaçao.

1.3 Resolvo provides ADR services in accordance with the applicable Curaçao legal and regulatory framework, including the LOK, the applicable CGA framework, and its published complaint procedure.

1.4 By using our website or submitting a dispute to us, you agree to these Terms & Conditions.

1.5 If you do not agree, please do not use our website or services.

Definitions

2.1 For the purposes of these Terms & Conditions:

2.2 "Complaint" means a written expression of dissatisfaction by a player relating to an operator's services, decisions, terms, or conduct, indicating that the player is dissatisfied and seeks a response or resolution.

2.3 "Dispute" means a Complaint that has not been resolved to the player's satisfaction through the operator's internal complaints procedure and that is referred to Resolvo for ADR.

2.4 "Operator" means a gaming operator licensed by the Curaçao Gaming Authority and engaged with Resolvo as its ADR provider.

2.5 "Player" means the individual submitting a Dispute to Resolvo.

2.6 "CGA" means the Curaçao Gaming Authority.

2.7 "LOK" means the National Ordinance on Games of Chance (Landsverordening op de Kansspelen, P.B. 2024, no. 157).

2.8 "ADR Parameters" means any conditions applied by an Operator within the limits permitted by applicable law and regulation, such as a minimum claim value or provisions regarding whether an ADR outcome is binding on the player.

Scope of Services

3.1 Resolvo handles Disputes arising from Complaints that have first been submitted to the relevant Operator and have not been resolved to the player's satisfaction through the Operator's internal complaints procedure.

3.2 Resolvo only handles Disputes involving Operators that are CGA-licensed and have an active ADR arrangement with Resolvo.

3.5 Where an Operator has designated more than one ADR provider, the choice of ADR provider lies with the player.

Eligibility and Admissibility

4.1 Resolvo may open a case only where the applicable intake conditions are met.

4.2 These include that:

1. the Complaint has first been submitted to the Operator and the internal complaints procedure has been completed, or a final response has been issued;
2. the Dispute is not pending before a court or another ADR provider;
3. the Dispute has not already been decided by a CGA-certified ADR provider;
4. there is no conflict of interest preventing impartial handling;
5. the matter is not manifestly frivolous or vexatious; and
6. the matter falls within any applicable ADR Parameters.

4.3 A player may not seek to revive a Dispute that was previously terminated or declined by a CGA-accredited ADR provider, other than for conflict-of-interest reasons.

4.4 Resolvo may decline, suspend, or close a case where required information is not provided, where the matter falls outside scope, or where continuation would be inappropriate under the applicable framework.

4.5 Complaints involving responsible gaming, including self-exclusion, duty of care, or related player protection matters, are handled with priority and full seriousness irrespective of claim value.

4.6 Any minimum claim threshold applied by an Operator does not apply to such cases.

ADR Parameters

5.1 An Operator may publish ADR Parameters applicable to disputes concerning that Operator, provided those parameters are permitted under applicable law and regulation.

5.2 Such parameters may include a minimum claim threshold for escalation or provisions regarding whether an outcome is binding on the player.

5.3 Where relevant, the applicability and enforceability of such parameters will be assessed in light of the facts of the case and the governing legal and regulatory framework.

Submission of a Dispute

6.1 To submit a Dispute, the player must provide through the website, complaint portal, online form, or by email at least:

1. full name and residential address;
2. player account identification with the relevant Operator;
3. date of the original Complaint to the Operator and, where available, a copy of the Operator's final response;
4. a clear description of the disputed conduct and the outcome sought;
5. supporting documents and evidence; and
6. a declaration that the matter is not pending before a court or another ADR provider.

6.2 Disputes may be submitted in English, French, German, or Spanish, and in any additional language published by Resolvo from time to time.

Acknowledgement, Procedure, and Outcome

7.1 Resolvo will acknowledge receipt of a submission within 7 calendar days, stating whether the case is admissible or whether additional information is required.

7.2 If requested information is not supplied within the specified time, Resolvo may decline the case.

7.3 Upon admissibility, Resolvo will inform the parties of the opening of the case and the next procedural steps.

7.4 Resolvo conducts an independent, impartial, and evidence-based assessment of each Dispute.

7.5 Both parties may submit further evidence within deadlines set by Resolvo.

7.6 Resolvo may ask targeted questions to obtain relevant facts and will apply the applicable legal and regulatory framework, including the LOK, CGA policies, and Curaçao civil law where relevant.

7.7 Differences in knowledge and resources between the player and the Operator may be considered and mitigated through accessible procedure design and plain-language communication.

7.9 The outcome will set out the findings, reasons, applicable rules, and any required actions for the parties.

7.10 The outcome is binding on the Operator in accordance with the applicable framework.

7.11 Whether the outcome is binding on the Player depends on the Operator's published ADR Parameters and any enforceable arrangements governing the dispute.

Confidentiality and Publication

8.1 ADR proceedings are confidential, subject to disclosure obligations arising under applicable law, regulation, or CGA requirements.

8.2 Resolvo may share information with the relevant Operator, the CGA, service providers acting on its behalf, or others where necessary for the ADR process or where legally required.

8.3 Resolvo may determine in a given case whether publication of an outcome, whether anonymised or otherwise, is permitted and under what conditions.

Independence and Impartiality

9.1 Resolvo acts independently and impartially in relation to both Operators and players.

9.2 Proceedings are conducted independently from the Operator and its players.

9.3 Conflict-of-interest considerations form part of admissibility and case handling.

Record-Keeping and Regulatory Cooperation

10.1 Cases are closed upon issuance of the final outcome or upon procedural decline, withdrawal, or closure on admissibility grounds.

10.2 Resolvo maintains confidential records of disputes for at least five years from case closure.

10.3 Resolvo cooperates with CGA monitoring and oversight, including the production of files upon request.

Website Use

11.1 Users must not engage in any activity that interferes with the operation or security of the website.

Limitation of Liability

12.1 Resolvo provides ADR services in good faith and in accordance with the applicable legal and regulatory framework.

12.2 Resolvo is not liable for the conduct of Operators, players, or third parties, nor for losses arising from matters outside the proper scope of its ADR role.

12.3 To the fullest extent permitted by applicable law, Resolvo excludes liability for indirect, consequential, incidental, or special loss or damage arising out of or in connection with the use of its website or services.

12.4 Nothing in these Terms & Conditions excludes or limits liability to the extent such exclusion or limitation is prohibited by applicable law.

Data Protection

13.1 Each party remains responsible for complying with applicable data protection law in relation to the personal data it processes.

13.2 Resolvo's handling of personal data in connection with the website and ADR services is further described in its Privacy Policy.

External Remedies and Regulatory Complaints

14.1 Resolvo does not replace judicial remedies.

14.2 Players retain the right to seek judicial recourse after ADR proceedings, unless limited by enforceable contractual arrangements to the extent permitted by law.

14.3 Resolvo does not determine regulatory complaints as such.

14.4 Where a player believes that an Operator has breached applicable regulation, the player may also contact the Curaçao Gaming Authority separately.

Governing Law and Jurisdiction

15.1 These Terms & Conditions, and any non-contractual obligations arising out of or in connection with them, are governed by the laws of Curaçao.

15.2 Any dispute relating to these Terms & Conditions shall be submitted to the competent courts of Curaçao.

Amendments

16.1 Resolvo may amend these Terms & Conditions from time to time.

16.2 The current version will be published on the website.

16.3 Continued use of the website or services after publication of an amended version constitutes acceptance of the revised Terms & Conditions.

Contact

17.1 For questions regarding these Terms & Conditions or our ADR services, please contact: