Complaint Procedure

Introduction

1.1 This Complaint Procedure explains how a player may refer a dispute to Resolvo Curaçao N.V. for alternative dispute resolution.

1.2 Resolvo is an independent ADR provider operating within the Curaçao legal and regulatory framework, including the LOK, the applicable CGA framework, and this published procedure.

1.3 Resolvo assesses disputes independently, impartially, and on the basis of the evidence and the applicable legal and regulatory rules.

Before You Submit a Dispute

2.1 Resolvo handles only 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.

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

Eligibility and Admissibility

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

3.2 These include:

1. the Complaint has first been submitted to the Operator and the internal complaints process 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 previously been reviewed and decided by a CGA-certified ADR provider;
4. there is no conflict of interest preventing impartial handling;
5. the Dispute is not evidently frivolous or vexatious; and
6. the Dispute falls within any applicable ADR Parameters.

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

3.4 Resolvo may decline, suspend, or close a case where required information is not supplied, where the matter falls outside its scope, or where continuation of the ADR process would be inappropriate.

Responsible Gaming Matters

4.1 Complaints involving self-exclusion, duty of care, or related responsible gaming and player protection issues are treated as a priority category.

4.2 Operator-imposed minimum claim thresholds do not apply to such cases.

How to Submit a Dispute

5.1 To submit a Dispute, the player must provide:

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.

5.2 Disputes may be submitted through the Resolvo website, online form, complaint portal, or by email.

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

Acknowledgement and Case Opening

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

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

The ADR Process

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

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

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

7.4 Resolvo recognises that there may be differences in knowledge, resources, or access to information between a player and an Operator.

7.5 Procedural steps and communications may therefore be adapted to support accessibility, clarity, and fairness.

Outcome and Binding Effect

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

8.2 In accordance with the applicable framework, the outcome is binding on the Operator.

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

Confidentiality and Publication

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

9.2 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.

9.3 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

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

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

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

Record-Keeping and Regulatory Cooperation

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

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

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

External Remedies

12.1 ADR does not replace judicial remedies.

12.2 Players may seek judicial recourse after ADR proceedings, subject to any binding and enforceable contractual arrangements to the extent permitted by law.

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