Affiliate Marketing Policy
for marketing and advertising in Ontario, Canada

Date: 2023/01/10

The defined terms in this Policy shall, unless set out inparagraph 1 below, have the meanings given to them in the Partner Agreement(amended only to the extent necessary for use in the context of the applicableAffiliate Terms and Conditions).

1. Definitions:

"Data Protection Legislation" means European Regulation(EU) 2016/679 and Directive 2002/58/EC and any legislation and/or regulationimplementing or made pursuant to them, or which amends, replaces, re-enacts orconsolidates any of them, and all other applicable laws relating to processingof personal data and privacy that may exist in any relevant jurisdiction;

"MIL" means Mobile IncorporatedLimited, registered in Malta under company number C 84149 whose registeredaddress is at Elite Business Centre, Treja ta' Box Box, Msida MSD 1840, Malta;Mobinc holds following license and certificate granting a right to providegabling services:

- Malta Gaming Authority license on Gaming servicesnumber MGA/B2C/818/2020; AND

- Alcohol and Gaming Commission of Ontario (AGCO) certificateof registration on online gambling services with number OPIG1241834.

"Self-Excluded Customer" means any individual that hasself-excluded from the Advertising Services (including via any overarchingnational self-exclusion scheme).

2. The Partner acknowledges andagrees that the Advertising Services are provided by MIL under its relevantgambling licences and/or approvals. Advertiser is the owner or licensor of thebrand under which the Advertising Services are operated, and is responsible forthe marketing and promotion of the Advertising Services.

3. The Partner shall notundertake any marketing or promotion of the Advertising Services unless anduntil the Advertiser has approved the websites on which the Partner intends tomarket and promote the Advertising Services (such approved websites being the"Sites").

4. The Partner shall ensure thatall marketing and promotion undertaken in respect of the Advertising Servicesby or on behalf of the Partner is undertaken in a socially responsible mannerand in accordance with all legal and regulatory requirements, including:

a. the Alcohol and GamingCommission of Ontario’s Marketing and Advertising (AGCO) at: https://www.agco.ca/lottery-and-gaming/guides/introduction-2 including in particular (butwithout limitation) the Marketing and Advertising sub-section containedin the Responsible Gambling section;

b. all applicable guidancepublished by the iGaming Ontario (iGO) on the website accessible at https://igamingontario.ca/ from time to time in relation to theadvertising and marketing of gambling;

c. all consumer protection laws;and

d. all applicable laws and regulationsrelated to gambling,

in each case as updated, amended,replaced or superseded from time to time.

5. The Partner shall not placeany links and/or use the Advertiser Brand alongside, in conjunction or inconnection with, and shall ensure that the Partner Sites do not contain:

a.    anyillegal or inappropriate content (including defamatory content or content whichcould incite religious hatred or prejudice on the basis of race, religion,gender, sexual orientation, age or disability); or

b.    anycontent which may harm the reputation of MIL and/or the Advertiser.

6. If the Partner uses any socialmedia platform to market and promote the Advertising Services, the Partnershall (and shall procure from any third party that provides such Services onbehalf of the Partner that it shall) fully comply with such social mediaplatform’s terms and conditions (as may be updated from time to time).

7. Without prejudice to paragraphs3 to 6 above, the Partner shall ensure that all marketing and promotion undertakenin respect of the Advertising Services by or on behalf of the Partner istargeted at the Territory only (including by reference to the language in whichit is available) and complies with such written guidelines and/or otherinstructions as may be provided to the Partner by Advertiser or MIL from timeto time in relation to the marketing and promotion for the AdvertisingServices.

8. The Partner shall immediatelycease any marketing activities on request by Advertiser and/or MIL ifAdvertiser and/or MIL considers that such marketing activities are in breach ofthe Agreement.

9. The Partner shall:

a. conduct itself, whenperforming its obligations and/or exercising its rights under the Agreement, asif it were bound by the same licence conditions and subject to the same codesof practice as MIL;

b. provide such information toAdvertiser and/or MIL as Advertiser and/or MIL may reasonably require in orderto enable it to comply with its information reporting and other obligationsowed to iGaming Ontario and/or any other relevant authority;

c. not do, omit to do or permitto be done, anything which may damage the reputation or goodwill of theAdvertiser, MIL, the Advertising Services or any other remote gambling servicesprovided by MIL; and

d. not do, omit to do or permitto be done, anything which may put any member of the Avertiser's and/or MIL'sgroup of companies in breach of applicable law or the licence conditions and/orcodes of practice attached to its gambling operating licence(s) from time totime.

10. The Partner shall comply atall times with all Data Protection Legislation and must not do, or omit to do,and must ensure that its personnel and other representatives do not do or omitto do, anything that would cause (or may be reasonably expected to cause) theAdvertiser and/or MIL to be in breach of any provision of any Data ProtectionLegislation. Upon the Advertiser's reasonable written request, the Partnershall provide Advertiser with all co-operation and assistance reasonably requestedby the Advertiser to demonstrate that the Partner is complying with Data ProtectionLegislation. The Partner shall notify the Advertiser promptly upon becomingaware of any breach of direct marketing laws (including Data ProtectionLegislation) in relation to the Advertising Services.

11. The Partner shall not send anydirect marketing to any person unless such marketing has been approved inaccordance with the process set out in paragraph 12.

12. If the Partner wishes to sendany direct marketing to any person in relation to the Advertising Services(whether via email, direct messaging on social media, SMS or any push notification)it shall notify the Advertiser of its plans in respect of such direct marketingand Advertiser shall seek MIL's consent (which it may give or withhold in itssole discretion), on the Partner's behalf, in respect of such plans. If MILprovides its written consent to the Partner carrying out such marketing, theAdvertiser shall notify the Partner of the same and the Partner shall (andshall procure from any third party that provides such services on behalf of thePartner that it shall):

a. provide: (i) the relevant marketingmessages, links, use of the Advertiser Brand and/or any other promotionalcontent; and (ii) the intended recipient list, in each case to the Advertiser(for Advertiser to provide to MIL) at least two (2) weeks prior to the targetsend date in the format requested by MIL to enable MIL to approve (or notapprove, in its sole discretion) the same;

b. if MIL provides its approval(which will be notified to the Partner by Advertiser), only send such marketing(in the approved form) to its intended recipient list once MIL has providedprior written approval of the same on the day before the target send date. MILshall be entitled to require the Partner to remove any person from therecipient list for any reason, including but not limited to if MIL believesthat such person is a Self-Excluded Person. MIL shall not send any suchmarketing communication to any recipient if more than 24 hours have elapsedsince MIL's written approval of such recipient list;

c. include the Advertiser and MILon its marketing list and send all such marketing to the Advertiser and MILeach time it uses such marketing (using such contact details as shall be providedto the Partner by the Advertiser from time to time);

d. without prejudice to theforegoing, only send such messages to recipients who have willingly andexplicitly consented to receive marketing from the Partner in relation to the AdvertisingServices (and who have not withdrawn such consent), in accordance withapplicable Data Protection Legislation, such consent having been reaffirmed bythe recipient at least within the last year (and the Partner acknowledges thatMIL's approval of any recipient list shall not be confirmation that any suchrecipient has consented to receive such marketing);

e. clearly display a message ineach such communication to state who is sending such marketing communications(and confirm they are not being sent by MIL and/or Advertiser and/or theAdvertising Services);

f. clearly display an unsubscribefeature in each such communication clearly detailing methods of unsubscribingfrom the mailing list;

g. not send any promotional offersrelating to the Advertising Services to recipients under the age of 19;

h. comply at all times with allapplicable direct marketing laws and Data Protection Legislation; and

i. at least once every sixmonths, and in any event on MIL's and/or Advertiser's request, provide writtenevidence to Advertiser and MIL of its compliance with this paragraph 12.

13. The Advertiser shall keep andmaintain full, up to date and accurate original documents, books and recordsrelating to all its activities under the Agreement. The Partner shall provideto Advertiser on request such information as may be reasonably requested by Avertiserin order to assist or enable Advertiser and/or MIL to comply with applicable lawand/or to assess the Partner's compliance with the Agreement.

14. The Partner shall not conductdirect-to-consumer marketing, advertising, and player referral services tooperators or gaming sites that accept wagers from players in Ontario without anAGCO registration.

15. Without prejudice to any otherrights or remedies of the Advertiser, the Advertiser may terminate theAgreement immediately on written notice to the Partner if:

a. the Advertiser is required todo so by MIL for any reason;

b. the Partner breaches any ofparagraphs 3 to 14 of this Policy or has otherwise acted in a manner which isinconsistent with any of MIL's gambling licences and/or other approvals or anyrequirements, standards, instructions or conditions of any applicableregulatory authority (including iGaming Ontario);

16. The Partner acknowledges andagrees that, the greatest extent permitted by law, MIL shall have no liabilityto the Partner in relation to the Agreement or its subject matter. The Partnershall indemnify and hold harmless MIL against any loss, damage, liability, costor expense incurred or suffered by MIL as a result of any breach of theAgreement by the Partner.

17. The Partner acknowledges andagrees that MIL may enforce the terms of the Agreement against the Partner asif it were a party to the Agreement.

18. This Policy may beamended unilaterally at any time by the Advertiser.

19. The Partner is obliged tokeep up to date and comply with any changes to this Policy, the Alcohol anGaming Commission of Ontario (AGCO) rules and regulation of iGaming Ontario(iGO). The AGCO’s rules can be found attached to this Policy and also via thefollowing link: https://www.agco.ca/marketing-and-advertising.

AGCO Marketing and Advertising

2.03 Advertising, marketing materials and communications shall nottarget high-risk, underage or self-excluded persons to participate in lotteryschemes, shall not include underage individuals, and shall not knowingly becommunicated or sent to high-risk players.

Requirements – At aminimum, materials and communications shall not:

1. Be based on themes, or use language, intended to appeal primarily to minors.
2. Appear on billboards or other outdoor displays that are directly adjacent to schools or other primarily youth-oriented locations. 
3. Contain cartoon figures, symbols, role models, and/or celebrity/entertainer endorsers whose primary appeal is to minors.
4. Use individuals who are, or appear to be, minors to promote gaming.
5. Appear in media and venues, including on websites, and in digital or online media, directed primarily to minors, or where most of the audience is reasonably expected to be minors.
6. Exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of all potentially high-risk persons, or otherwise extoll the virtues of gaming.
7. Entice or attract potentially high-risk players. Instead, precautions shall be in place to limit marketing communications to all known high-risk players.

Guidance: Where cartoons are used, they may not primarily appealto minors.

2.04 Marketing, including advertising and promotions, shall be truthful, shall not misleadplayers or misrepresent products.

Requirements – At aminimum, materials and communications shall not:

1. Imply that playing a lottery scheme is required in order to fulfill family or social obligations or solve personal problems.
2. Promote playing a lottery scheme as an alternative to employment, as a financial investment, or as a requirement for financial security
3. Contain endorsements by well-known personalities that suggest that playing lottery schemes has contributed to their success.
4. Encourage play as a means of recovering past gaming or other financial losses.
5. Be designed so as to make false promises or present winning as the probable outcome.
6. Imply that chances of winning increase:

   a. The longer one plays;

   b. The more one spends; or

   c. Suggest that skill can influence the outcome (for games where skill is not a factor);

7. Portray, suggest, condone or encourage gaming behaviour that is socially irresponsible or could lead to financial, social or emotional harm.
8. Suggest that gaming can provide an escape from personal or professional problems.
9. Portray gaming as indispensable or as taking priority in life; for example, over family, friends or professional or educational commitments,
10. Suggest that gaming can enhance personal qualities, for example, that it can improve self-image or self-esteem, or is a way to gain control, superiority, recognition or admiration,
11. Suggest peer pressure to gamble nor disparage abstention,
12. Link gaming to seduction, sexual success or enhanced attractiveness,
13. Portray gaming in a context of toughness or link it to resilience or irresponsible play, or
14. Suggest gaming is a rite of passage.
15. Offer a product or promotion that is not reasonably attainable without incurring substantial losses.

2.05 Advertising and marketing materials that communicate gamblinginducements, bonuses and credits are prohibited, except on an operator’s gamingsite and through direct advertising and marketing, after receiving activeplayer consent.

Guidance:

• This standard does not prohibit the use of inducements, bonuses and credits.
• This standard prohibits all public advertising, including targeted advertising and algorithm-based ads.
• Direct marketing and advertising includes but is not limited to: direct messaging via social media, emails, texts, and phone calls.

2.06 Permitted advertising and marketing materials thatcommunicate gambling inducements, bonuses and credits must, at a minimum:

1. Disclose all material conditions and limitations of the offer at its first presentation on the gaming site, with all other conditions and limitations no more than one click away.
2. Not be described as free unless the inducement, bonus or credit is free. If the player has to risk or lose their own money or if there are conditions attached to their own money, the offer must disclose those terms and may not be described as free.
3. Not be described as risk-free if the player needs to incur any loss or risk their own money to use or withdraw winnings from the risk-free bet.

2.07 Players must be provided an opt-in process whereby theyactively consent to receiving any direct advertising and marketing ofinducements, bonuses and credits, and must be provided a method to withdrawtheir consent at any time, where such marketing and advertising materialsare available.

Guidance: direct marketing and advertising includes but is not limited to:direct messaging via social media, emails, texts, and phone calls.