Security and Game Integrity Policy

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1. General terms:

1.1 Limitation of Liability:

LIMITATION OF LIABILITY: Under no circumstances, including negligence, shall WPN be liable for any special, incidental, indirect, or consequential damages whatsoever (including, without limitation, damages for loss of business profits, business interruption, loss of business information, or any other pecuniary loss) arising out of the use (or misuse) of the Software, the Games or your accessing the Site or the Servers, even if WPN had prior knowledge of the possibility of such damages.

For purposes of this Policy, the term WPN shall include the Winning Poker Network and each poker brand that operates under the WPN network.

1.2 Disclaimer:

1.2.1 While WPN makes every possible effort to ensure and enforce a fair environment for all our players, we accept no responsibility on third parties’ ill actions.
1.2.2 WPN commits to put in place a reasonable set of measures to prevent any form of cheating, and penalizes any player caught in violation of our security and game integrity policies.
1.2.3 WPN reserves the right to address unforeseen scenarios or situations not contemplated in the present policies as it sees fit.
1.2.4 Due to the nature of some of the described sections below WPN will comprehensively evaluate the reliability of any third-party accusation and source material received.
1.2.5 WPN reserves the right to adapt any of the described policies or outcomes to suit any legal grounds whenever the jurisdiction requires it.

1.3 WPN Decisions are final: By accepting our general terms and conditions you also accept that our Security and Game Integrity team investigation results, outcomes and penalties are final. You expressly agree and accept WPN alone to deem any account in violation of any of the present policies, and therefore you accept any such determination as final.

1.4 Confidentiality:

1.4.1 We commit to a strict personal privacy policy for all our players.
1.4.2 Player personal information is protected against unauthorized disclosure under the laws of the Republic of Costa Rica.

1.5 Penalties:

You accept and expressly acknowledge and agree that any penalty decision or determination lies within WPN’s sole and absolute discretion.

1.5.0 WPN’s sole discretion penalties may include but not limited to any of the following:
1.5.1 Soft warning: A player will be provided a written warning by email of his or her offending conduct, which must cease.
1.5.2 Heavy warning: A player will be provided a written warning by email of his or her offending conduct. In WPN’s sole discretion, these warnings are not progressive and WPN may immediately apply any penalties deemed appropriate.
1.5.3 Account temporary suspension: This penalty describes a limited timeout. During which the offending player shall be denied access to his or her account.
1.5.4 Expulsion from races or promotions: This penalty describes the loss to the offending player of any access or benefits under any rake race, leaderboard, loyalty or rakeback program and any other promotion offered now or in the future by WPN.
1.5.5 Re-payment of damage: WPN may demand as it sees fit that the offending user re-pay to WPN the damage cause to WPN or our player community.

1.5.7 Permanent ban allowing to withdraw their funds: This penalty describes a termination of an account where WPN determines in its sole discretion the right of the offending player to withdraw his or her remaining funds excluding unclaimed promotions, bonuses or loyalty rewards, plus provided that any affected players have been compensated in the amounts determined by WPN.

1.5.8 Permanent ban and confiscation of funds: This penalty describes a permanent loss of access to the player account and any funds held within WPN. This penalty shall apply across any sites operating on WPN Network.

1.5.9 Legal action: WPN reserves the right to pursue any legal or equitable actions in its sole discretion. By participating in games offered by WPN, each player shall expressly agree to jurisdiction over his or her player account under the laws of the Republic of Costa Rica. Each player expressly waives the application of any argument of forum non-convenience should WPN seek legal or equitable relief against the players account or account balance therein.

1.5.10 We reserve the right to apply any or a combination of the penalties described in this section as WPN sees fit.

Limitation of Liability.

LIMITATION OF LIABILITY WPN provides customers with services for which it collects rake and fees. WPN shall not be liable to compensate any player claiming to have been cheated, colluded against, or affected by playing against an Automated Player or bot beyond the rake and fees actually collected from the affected player.

Any decision whether to award compensation to an affected player beyond rake and fees collected from such affected players shall be entirely discretionary on the part of WPN.

2. Compensation policies:

2.1.0 WPN compensation policies are subject to additional changes based on unforeseen situations. WPN in its sole discretion may evaluate and issue financial compensation to our players who are determined by WPN to have been affected by activity of Automated Players or Bots.

Each affected player who is provided such compensation shall receive an email notice of such account credit upon issuing of compensation. In the event that an affected player receives a credit based on WPN compensation policies, said player shall be bound by acceptance of said payment as full compensation for any injury, loss, etc, unless, within 24 hours, said player shall decline compensation as a satisfaction of any and all claims, by emailing refusal of compensation to [email protected]

2.2 Compensation may include, in WPN’s sole discretion, any of the following:

2.2.1 Funds redistribution: Redistribution of funds recovered from an offending player’s account, redistributed in a fair manner to affected players by the offending activities
2.2.2 Compensation: Distribution of funds that WPN at its sole discretion considers fair, whether or not was recovered from the offender’s account.
2.2.3 Compensations with cap: Distributions, in a limited amount that WPN at its sole discretion considers fair, whether or not they were recovered from the offender’s account.

2.3 Qualify for a compensation:

2.3.0 A player may qualify for a compensation only by meeting each of the following conditions:

2.3.1 The Player must have a WPN open active account.
2.3.2 The Player Account must be in good standings with WPN.
2.3.3 The Player Account must not have been found to have engaged in or be under a pending investigation from our security and game integrity team for any inappropriate activity. This includes Accounts which have been suspended pending further investigation.
2.3.4 Player Accounts under temporary or self-exclusion or responsible gambling protection do not qualify for a refund.
2.3.5 Accounts, which are under suspension, will not qualify for compensation.
2.3.6 Accounts created and played under former WPN affiliated skins will not be compensated.

2.4 Compensation logic by game type:

2.4.1 Multi-Table Tournaments (MTT`s)

Ladder Up Policy: In WPN’s sole discretion, an offending player, an Automated Player or Bot may be removed from the finished tournament list. Each player below the offending player’s finished spot is moved up one spot. If a player would receive more money in their new position, they will be awarded the difference between any prize awarded to the new spot less any prize awarded to their having finished play in their former spot.

2.4.2 Jackpot tournaments (JPT) Compensations that derive from JPT activity will be based on players’ overall win-loss whenever the offender player was involved, whether or not the offender player won the JPT, as it still influenced the overall outcome of each of the other players. Calculated as: Total JPT collected awards minus Total Buy-ins.

2.4.3 Cash Games, Heads Up SNG As a general policy, an innocent player affected by cheating, collusion or bot play may be compensated only if the player being considered for compensation has a net loss versus the offending player. i.e. a negative WIN-LOSS vs the offender player through time. For example, an innocent player who beats a given bot, and is a net winner, shall not be compensated for play against that given bot.

2.5 Compensation cap policies

2.5.1 WPN reserves the right at any time to increase the amount refunded up to a limit or cap per offending player. WPN reserves the right to increase the CAP amount whenever it considers it appropriate at WPN`s own discretion.

2.5.2 Cap based upon rake and fees paid by the affected player. WPN reserves the right to compensate affected users to a cap consisting on the rake and fees generated by the affected player, whenever the affected player faced a verified offender who is an Automated Player, Bot or cheater or engaged in collusion.

2.5.3 Generally, WPN will observe an aggregate cap of $25,000 USD per offending player or bot to be distributed among affected players whenever possible. In order to calculate the cap amount per player compensated, his portion will be multiplied by a ratio based on the $25,000 base cap or any new cap that WPN announces.

2.6 Transparent and verifiable policies:

2.6.0: WPN reserves the right at all times to publish relevant information regarding any banned account at any given time, including the offender account, players affected, and any funds credited based on our compensation policies. As provided in the Terms of Service, players identified as bots may be posted under this section as per WPN discretion. Under the Terms of Service, each player expressly consents to publication of screen names under this provision.

2.6.1 WPN’s general policy is that any Account verified as a BOT will have its public screen name shared on the poker site, along with affected players public screen names and the amounts received as a compensation. Affected Players’ private personal information will not be shared and is protected under Costa Rica law from unauthorized disclosure.

2.6.2 WPN reserves the right to refrain from sharing information, coming from ongoing investigations, suspected or abandoned accounts in its sole discretion.

3. Collusion

3.0 Collusion is the action of teaming up with another player or players at the same table or in a multi-table event, or making any agreement with the intention to gain an unfair advantage over their opponents. This might include but is not limited to the following practices:

3.1 Hole-Card sharing: The act of sharing your hole card information with another player during play, under any circumstances.
3.2 Whipsawing: To bet and raise aggressively with the intention to trap another player.
3.3 Softplay: Playing hands in a non-aggressive way against other players.
3.4 Chip Dumping: Losing Chips intentionally to another user(s).

4. External assistance tools (“EAT”):

4.0 General definition: We recognize that there are many tools available to the general public designed to help educate players on how to play poker. As poker is a game of skill, we recognize the value in these resources. Still, some of these tools do not fall under this educational study category and can subsequently be used to create an unfair advantage.
As a result, we’ve developed a comprehensive list of both acceptable and prohibited tools for players who are logged onto the Winning Poker Network.

4.1 Acceptable tools:

4.1.0 Definition: Any third-party tool, piece of software, or source material, not developed by WPN, that allows players to improve their playing performance is considered acceptable provided it doesn’t pose any threat to the integrity of our games. These include:
4.1.1 Online study literature, training programs, or books that discuss complex strategies, provided they are educational only and are NOT used during any actual play. Actual playing decisions must ultimately be considered and executed by a human only.
4.1.2 Reference Material such as 2-dimensional, push-fold, preflop simple table-based starting hand charts that may orient players on what hands to play or not, in unopened pots.
4.1.3 Hand trackers and Heads Up Display (HUD) type tools that gather and display numeric-based stats. The stats displayed must be based solely on your own hand history collected through the games you have personally participated in, and such displays must not include information from a current hand in play.
4.1.4 Hotkey tools that enhance or abbreviate your actions through specific keyboard commands. Mathematical or arithmetical calculations of any sort must not be involved at the time when executing any hotkey action.
4.1.5 Leak trackers and bankroll management suites that allow users to manage and control their bankroll.
4.1.6 Tournament result websites that generate players statistics based on official tournament results that also adhere to the requests of players for self-exclusion from these lists.
4.1.7 Table arranger tools that tile up tables based on player preferences.
4.1.8 Tools that automatically generate notes based on your own hand history. These are known as note creators.

4.2 Prohibited tools:

Bots. What is prohibited is playing, using or benefiting from anyone’s play as an Automatic Player or Bot.

4.2.0 WPN and all sites which comprise the WPN network have offering players a fair playing environment and game integrity as the highest priority. Each poker site which comprises the WPN network has adopted a no-tolerance policy toward automated players or “bots” participating in any of the poker playing activities offered to real customers.

“Automated Players” or “Bots” are expressly prohibited from playing in any of the gaming offered by the WPN or any participating poker sites/brands.

Generally, any third-party tool, piece of software, or source material, not developed by WPN, that allows players to gain an unfair advantage poses a threat to the integrity of the live real persons playing WPN poker games.

Specifically, WPN and sites on the Network prohibit
4.2.1 Poker bots or any other piece of software that might play poker without human intervention or otherwise gives advice on how to play in real time.
4.2.2 Software that provides a human player, current live game state information, such as pot odds and outs, or an absolute hand strength calculator.
4.2.3 Tools that offer real-time advice (RTA) on how to act at the table, (for example, tools known as push-this-button bots or advisor).
4.2.4 Programs capable of complex ICM, Nash Equilibrium, Expected Value (EV), Game Theory Optimal (GTO) based actions, which can be used in real time, i.e. making live play decisions, (i.e. advise on how to play the current hand.)
4.2.5 Auto or Semi-Auto chart retrieval software keyed to current live play.
4.2.6 Hole-card sharing tools. (Real time sharing of hole cards is a clear violation of universally accepted poker rules against collusion and constitutes cheating.) Further, WPN and its participating poker operators deem prohibited a practice of massively collecting, scraping or observing or sharing data-mined hands in which a player did not participate.
4.2.7 Hotkeys that include conditions based on the live scenario you face in play in real-time are prohibited.
4.2.8 Older but usable hand tracker versions and their HUDs with features non-compliant to our list of acceptable EAT specs from above.
4.2.9 Seating script software which may perform but are not limited to the following functions:

Reserving a seat
Securing a seat
Player nickname targeting
Player labeling
Collecting data on hands in which the user is not actively a participant

4.2.10 Tools that might modify or interfere the table layout by changing or overlapping our inhouse build graphics, as the WPN-provided layout is a tool by which WPN detects prohibited bot activity.

WPN reserves the right to determine in its sole discretion whether players are using or benefiting from any of the forbidden tools above, based on patterns consistent with such tool usage. All determinations by WPN shall be final. WPN reserves the right to address unforeseen scenarios or situations not contemplated in the present policies as it sees fit. WPN Decisions are final: By accepting our general terms and conditions you also accept that WPN determinations and decisions regarding our Security and Game Integrity investigation results, outcomes and penalties are final.

WPN shall maintain an ongoing, continual effort to prevent participation in its poker offerings by Automated Players or Bots. Additionally, due to the evolving nature of some of the described prohibited activity described above, and in reliance upon the value of crowd-sourcing and customers’ invaluable reporting and feedback, WPN will promptly evaluate the reliability of any third party suspicious activity and source material received from customers and reserves the right to adapt or modify any of the above described policies or outcomes.

5. Unethical behavior:

5.0 WPN reserves the right to deem some gameplay behavior as systematic predatory practices, which are unethical and detrimental to our poker community. Such predatory practices are strongly discouraged and players who engage in them may be penalized by WPN in its sole discretion, as listed in the 1.5 penalties section.
WPN considers the following predatory practices to be prohibited, including but not limited to the following:
5.1 Grimming: The practice to consistently play the small blind (SB) and skip the big blind (BB).
5.2 Ratholing: The practice of intentionally leaving a table and returning with a smaller amount of chips shortly after.
5.3 Bumhunting: The practice of over-targeting a certain player population, or a specific player.
5.4 Chat abuse: The practice of either disclosing hand in play information or suggestions, as well the verbal, offensive abuse.
5.5 Stalling: Deliberating delaying the action in a game to gain an advantage over your opponents on different tables from the same tournament
5.6 Table Camping: The practice to reserve, sit out or lock a seat for long periods of time.
5.7 Angle Shooting: Any behavior, action, or pattern not described already in the present policy that a user might exploit in their favor, disrupting the “spirit of the game”, to gain any sort of advantage, including but not limited to exploiting software bugs, deceiving or tricking other players. WPN reserves the right to deem other unforeseen scenarios as such.

6. Accurate and truthful information:

6.0 As per our general terms and conditions, our license is granted to the end-user who is obligated to provide accurate and truthful information at all times. That been said the following practices are strictly forbidden and might carry penalties whenever WPN confirms a violation:
6.1 Multi accounting: Create more than one account within the WPN network of sites
6.2 VPN-Proxy usage: With the intention or an effect of hiding your actual location and avoiding an accurate geolocation.
6.3 Account Sharing: The use of a given account by more than one person with or without consent.
6.4 Identity misrepresentation: Create an account on someone else’s behalf with or without their consent or allowing someone else to create an account on your behalf in a manner that misrepresents the true identity of the accountholder.
6.5 Ghosting: Handing off play of an account to allow another person to play on the account holder’s behalf. This activity is expressly prohibited and, in a tournament, context will result in the forfeiture and seizure of all funds in each player’s account, if any.
6.6 Fake profile information: Create an account that contains inaccurate or false information
6.7 KYC Refusal: Refuse to complete a “Know your Customer” (KYC) protocol whenever WPN requires it.
6.8 Penalties resulting on verified violation of this section are detailed in the 1.5 Penalties section

7. Game play conflict of interest:

7.0 Different financial agreements might come across for poker players on a regular basis, such as trading, staking, funds swapping, bankroll sharing among others, however some of these common practices might lead to unethical ones that might affect the overall poker community. At any moment WPN reserves the right to confirm any of the following agreements that ultimately create a conflict of interest for our community members:

7.1 Staking fraudulent users: Users staking a later detected or verified fraudulent users shall be penalized in WPN’s sole discretion
7.2 P2P fraud: Whenever a Player 2 Player transfer relates to some sort of fraud, all users involved in the P2P activity shall be subject to penalty and forfeiture of funds.
7.3 Profit Sharing: Any profit-sharing agreement related to verified fraudulent activity shall be treated as participating in the underlying fraudulent activity and subject to penalty as WPN deems appropriate.
7.4 Non-aggression external agreements: Any agreements between players or groups of players to exploit any element unrelated to hands in play, that might include but not limited to schedule agreements, unstated or implied non-aggression patterns by simply avoiding or denying action.
7.5 Rake race agreements: Any agreement to modify their playing pace or activity to take some advantage in any rake race or weekly, monthly or seasonal leaderboards competitions.
7.6 Affiliate fraud: Any attempt to unlawfully boost affiliate commissions by any means, by violating the WPN affiliate program terms and conditions
7.7 Bonus clearance fraud: Any attempt to unlawfully release any promotion granted by WPN
7.8 User solicitation: Any request by any player to break any of our T&C in any form
7.9 Intimidation: Any form of threat and harassment to influence or force a player to take an action against our terms and conditions.
7.10 Penalties resulting on verified violation of this section are detailed in the 1.5 Penalties section

8. Financial Fraud:

WPN, and the poker sites on its Network are merchants who provide gaming services to customers. WPN customers are expressly forbidden any use or attempted use of any financial transactions for anything other than to fund gaming play.

WPN and the poker sites on the Network are NOT offering any money service or money transmittal services to any persons accessing any of the Network poker sites, cashier functions or other activities. WPN is NOT a financial exchange provider, all financial transactions are expressly limited to the deposit of funds to support gaming activity or the withdrawal of funds from a player’s account balance.

8.0 WPN does NOT offer customers any banking, financial services, money services or money transmittal services. Any attempt to use WPN’s cashier functions to facilitate any sort of money service or money transfer transactions may result in closure of the offending customer’s account and freezing or forfeiture of any balances therein.

Prohibited use of the WPN Network or poker sites thereon may include, but are not limited to:

8.1 Disputed transactions: Chargebacks of credit card deposits. Any attempt to initiate a chargeback claim with any payment provider, without first contacting WPN to attempt to prove the chargeback grounds and resolve the dispute shall be considered a prohibited activity. The same policy applies to any e-wallets or ACH or bank transfer transaction that results in a non-honored transaction. Any attempt to use WPN deposit, cashout or P2P transfers as a de facto money transmitter intermediary to move funds from one payment service to another is expressly prohibited. The sole permitted purpose of any transactions is limited to funding or cashing out an account balance to enable use of gaming services offered by WPN as a merchant.

8.2 Identity misrepresentation: Uses financial information of anyone not the WPN or site accountholder, with or without authorization of the person whose information is used, is prohibited. Only one player per account is allowed and that player’s information alone may be used to establish his/her identity. Staking agreements are a part of the poker economy and have been expressly approved by various gaming regulators. If a permitted staking arrangement is made between an account holder and a third party, all financial transactions nevertheless must be made by the accountholder. Funding or settlement of staking arrangements shall remain between the parties to such an arrangement and WPN shall not be a party thereto.

8.3 Player to player: WPN is a merchant that offers gaming services. Financial arrangements made by customers outside WPN will not be honored or enforced by WPN. No P2P transactions shall be permitted to either party to settle or resolve any agreements or liabilities related to any debts, promises, obligations or transfers between players, other than a one-way transfer of account balances related solely to funding the customer’s gaming activity or legal staking on WPN, as a merchant Any elements of a supposed transaction involving any third party entity, including accounts held other gaming sites, financial services providers, or the blockchain will not be permitted, facilitated, or enforced by WPN.

8.4 Cryptocurrency fraud: Any use of a cryptocurrency transfer that is determined to be fraudulent, including but not limited to double spending and clipboard hijacking, is expressly prohibited and fraudulent.

8.5 Multi Accounting: Customers are expressly prohibited from creating or acquiring or ghosting multiple accounts under the control of one person or group of persons acting in concert, regardless of the given identity of the various account holders.

8.6 Unforeseen events: WPN might take any action as it sees fit whenever a financial abuse occurred and was not expressly enumerated by the above financial fraud policies.

8.7 Penalties resulting on verified violation of this section are detailed in the 1.5 Penalties section

9 Policies enforcement:

9.0 User/You are required to ensure that any action and decision-making must be made by a human account holder through the software interface and is based on own knowledge of the game. WPN will take every step to determine if any user is receiving assistance during their decision-making process through prohibited tools or other actions that violate the present Security and Game Integrity policy.

9.1 You expressly agree and accept that WPN, from time to time, may implement security or game integrity measures to enforce its policies as it sees fit. Such measures might include but are not limited to:

9.2 Know your Customer (KYC) protocol: Requiring compliance by you with additional identity verification steps.

9.3 Personal Interview with You: By our security and game integrity staff in order to clarify any arisen concern.

9.4 Video session: Participation by you in a recorded or live-streamed video session while playing in our cardroom as WPN sees fit, which you expressively consent you will provide whenever WPN may require.

9.5 External Assistance Tools verification: You agree that WPN may take action by any means it sees fit to detect the presence of prohibited software or programs you may have installed or run while running WPN software. Any attempt to prevent this detection or verification shall be subject to penalty against you or your account.

9.6 Compatibility prevention: WPN frequently and comprehensively updates its software to detect and prevent player practices and tools expressively prohibited in the present policies. Any attempt to evade, block or interfere with this detection or prevention shall be subject to penalty against you or your account.

9.7 Service Denial: WPN reserves an absolute right to deny service to any player who utilizes programs or tools that WPN determines could create a conflict with its security and game integrity policy or interfere with provision by WPN of its poker services.

9.8 Human interaction verification: You expressly agree and accept that WPN may require you to successfully complete a human interaction challenge to ensure a human usage or play on your account.

9.9 Share activity restriction: WPN, at its sole discretion, reserves the right to prevent players from sharing a table, whether to prevent further violations to present policies or as part of its player protection efforts.

10 Disclaimer for External Assistance Tools (EAT)

10.1 WPN neither supports nor endorses the use of any external assistance tool (EAT). WPN does not authorize the use of WPN trademarks or logos, or the use of WPN images to promote any EAT.

10.2 WPN considers that usage of an EAT may provide an advantage to the end-user. In principle, such advantage might be deemed as “fair” or “unfair” by WPN at any time at its sole discretion, without prior notice. A combination of different EATs may provide a user an aggregate unfair advantage.

10.3 An EAT must refrain from displaying information in real time, related to the hand in play.

10.4 Every player MUST make their own observations and interpretations of the play scenario in their current hand. An EAT may not suggest strategy or automate actual play in real time or for a live hand.

10.5 An EAT must refrain from interfering with the regular WPN software performance, including blocking or replacing any software functionality or preventing our security verifications.

10.6 Any EAT to be used with any WPN play must not cause a violation of the present security and game integrity policies.”