Security & Ecology Agreement

GGPoker SECURITY AND ECOLOGY AGREEMENT (“SEA”)

Table Of Contents

0. INTRO
​1. ECOLOGY
​2. PREDATORY BEHAVIOR
​3. COLLUSION
​4. BUMHUNTING
​5. CHIP-DUMPING
​6. USE OF ARTIFICIAL INTELLIGENCE
​7. EXTERNAL ASSISTANCE PROGRAMS
​8. MULTI-ACCOUNTING
​9. USE OF PROXIES AND VPNs
​10. RATHOLING
​11. CIRCUMVENTION
​12. OFFENSIVE CHAT
​13. OFFENSIVE PLAYER PROFILE
​14. RESIDENTIAL COUNTRY
​15. PRIVACY POLICY
​16. MISCELLANEOUS
​17. ACTIONS FOR BREACH
​18. ACCOUNT SHARING

0. INTRO
The Security and Ecology Agreement (the ‘SEA’) as upheld by the GGPoker Security Team (“The Security Team”) should be read by you, the End User (the “User”), prior to playing on GGPoker and the GGPoker Network (“Network”). Your decision and acceptance to play on GGPoker is a confirmation of your acceptance of the terms of the SEA.

1. ECOLOGY
1.1. GGPoker’s ethos is that a healthy and safe player-ecology is paramount to providing enjoyable poker games. To this end, we have implemented several security measures in order to foster and maintain a healthy ecology and to ensure that GGPoker players are provided with a safe and secure environment. The items outlined below state what is being monitored, how it is being monitored, and any potential actions available to be taken by GGPoker for the purposes of protecting the poker ecology.
​1.2. The SEA may be subject to revision and variation, without prior notice to the User, at any time. All Users are expected to read the SEA prior to playing on GGPoker.

2. PREDATORY BEHAVIOR
2.1. Predatory Behavior is defined as User activities focused primarily on engaging in unethical advantages and tactics to exploit other players in order to gain unfair profit. These include, but are not limited to; bum hunting, collusion, use of artificial intelligence, ratholing, grimming, hit and running, buttoning and other unethical actions (mostly deemed unethical by general consensus of the poker community). GGPoker’s promise to its Users is to provide a safe, fun, and enjoyable poker environment. Predatory Behavior is in direct conflict with our promise, and as such, The Security Team adopts a strict zero-tolerance policy to it.
2.2. As The Security Team reviews on a case-by-case scenario based on the gravity of the suspected offence, The Security Team reserves the right, at its sole discretion, to suspend Users suspected of Predatory Behavior from the Network for a period of no more than 60 (sixty) days, pending the conclusion of an investigation into the User’s activities.
2.3. Should a User be in breach of Predatory Behavior, GGPoker shall have a right to apply such actions as is set out in Section 17 below.

3. COLLUSION
3.1. Collusion is the behavior in which two or more Users establish a partnership to gain an unfair advantage over other Users at the same cash game table or same tournament. The Security Team’s general rules regarding collusion are (but not limited to):
1) User hands must be played independently, in their own best interests;
2) User must not have a partnership to gain an advantage over other Users;
3) User must refrain from “Soft-Play” i.e. the act of intentionally playing hands in a non-aggressive manner against another User who is either a friend, backer or another person of interest. The only exception to this Rule 3 is the “In The Money (ITM)” bubble and multi-handed situations past the money bubble in which one or more Users is all-in;
4) User must not “Chip Dump” i.e. the act of intentionally transferring funds (or tournament chips) through the manipulation of gameplay.
5) User must not share hole-card information with another User under any circumstances.
3.2. The Security Team employs sophisticated industry-leading tools to detect suspicious actions deemed as collusion. Our tools monitor an assortment of data, such as hand history, betting patterns, and User gameplay. We also look at various other sources of information as part of our investigations.
3.3. Should the Security Team conclude that a User or other Users has/have attempted or committed collusion, the Security Team reserves the right to implement the actions stipulated in Section 17.
3.4. Where we find conclusive evidence of collusion, any related confiscated funds will be distributed (at the Security Team’s judgment) to affected Users as evenly as possible.

4. BUM HUNTING
4.1. Bum hunting is defined as the act of deliberately targeting one subset of (usually weaker) players while avoiding giving action to another subset of (usually stronger) players.
4.2. Should a User be suspected of engaging in bum hunting, GGPoker reserves the right, at its sole discretion, to suspend the User from the Network for up to 60 (sixty) days, pending the conclusion of an investigation into the User’s activities.
4.3. Following the conclusion of the investigation, the GGPoker Security Team reserves the right to implement the actions set out in Section 17.
4.4. Where we find clear evidence of bum hunting, any related confiscated funds will be distributed (at the Security Team’s judgment) to affected Users as evenly as possible.

5. CHIP-DUMPING
5.1. Chip-dumping is defined as the act of a User intentionally losing his/her chips to another User.
5.2. Should User be suspected of engaging in chip-dumping, The Security Team reserves the right, at its sole discretion and without notice to suspend the offending User from the Network for up to 60 days, pending the conclusion of an investigation into the User’s activities.
5.3. Following the conclusion of the investigation, the GGPoker Security Team reserves the right to implement the actions set out in Section 17.

6. USE OF ARTIFICIAL INTELLIGENCE
6.1. GGPoker’s software package contains certain features designed to detect the use of automated programs that enable gameplay based on Artificial Intelligence. Use of such “bot” software programs is strictly prohibited.
6.2. GGPoker’s software may perform any or all of the following scans in order to detect the use of illicit automated programs and ensure that a “cheat-free” environment is maintained:
6.2.1. Scan of all active software applications while our software is being used.
6.2.2. Scan of all active processes while our software is being used.
6.2.3. Scan of all activities for the potential use of artificial intelligence.
6.3. Should any of the aforementioned processes reveal a suspicious application or process, our software may scan the files associated with the suspicious application or process and compile a composite mesh (a profile that characterises the files associated with the application or process) to be matched against profiles for known illicit automated programs.
6.4. Should the Security Team conclude that a User has employed Artificial Intelligence, The Security Team reserves the right to implement the actions set out in Section 17.

​7. THIRD PARTY TOOLS (EXTERNAL ASSISTANCE PROGRAMS)
7.1. GGPoker does not permit the use of certain third party tools (External Assistance Programs).
7.1.1 A third party tool is prohibited if it:
plays without human intervention or reduces the requirement of a human to make decisions. A human must decide what action to take and the exact size of any bet or raise. Any tool or service which reads the current game state is considered to be a poker bot;
data mines: (i) hands or private results (observing games without playing in order to build up a database of hand histories for future reference) and (ii) the mass sharing of hands, private results or playing statistics for the purpose of analysis of opponents;
is a Heads-Up Display (HUD) i.e. a program that displays Users past tendencies and betting patterns;
is deemed by The Security Team to provide an unfair advantage over other Users;
assists in automatic seating or game selection efficiency;
analyses specific hand histories or User-defined situations using simulations, e.g. range calculation, nash equilibrium, ICM equity, solvers;
provides advice on actions to be taken in various poker situations, e.g. hand charts, decision trees.
7.1.2 A third party tool is permitted if it:
assists only in tiling/aligning of tables;
assists in the creation of macros and hotkey for gameplay efficiency that do not reduce the requirement of a User having to make a decision. The User must decide what action to take and the exact relative size of any bet or raise, with the macro or hotkey merely executing this decision. For example, a hotkey that bets half the pot is permitted. A hotkey that bets a randomised amount between half and three-quarters of the pot is prohibited;
is judged by the Security Team to have characteristics of prohibited third party tools but is deemed inoperable in conjunction with the GGPoker poker client;
7.2. Should the Security Team conclude that a User has employed third party tools, the Security Team reserves the right to implement the actions out in Section 17.

8. MULTI-ACCOUNTING
8.1. GGPoker prohibits Users from opening multiple accounts on GGPoker.
8.2. In any circumstances, GGPoker strictly prohibits that Users register or participate in any single tournament from multiple accounts. Furthermore, Users are prohibited from playing with two or more accounts at any poker tables, including but not limited to, Cash Games, Spin&Gold, and any other games offered by GGPoker, simultaneously.
8.3. Should GGPoker conclude that a User is in violation of Section 8.2, the following actions will be taken: said User will be disqualified from the tournament in-progress should the violation be detected in real-time, all funds held in said User’s accounts shall be confiscated, said Users will permanently be banned from playing on the Network.
8.4. Should GGPoker conclude that a User has created a new account on any Network skin, in order to circumvent any previous warnings from Network Security, all funds held in said User’s accounts shall be confiscated, said User’s will permanently be banned from playing on the Network.

9. USE OF PROXIES, VPNs, REMOTE DESKTOP AND VIRTUAL MACHINE
9.1. GGPoker strictly prohibits the use of proxies, VPN and remote desktops from prohibited/restricted countries, while our software is in use.
9.2. Should GGPoker determine that 9.1. is in violation, we may restrict players’ use of proxies, VPN and remote desktops, pending the outcome of our investigations. Should players fail to cooperate with our investigations, their accounts may be blocked.
9.3. Should GGPoker determine that players have engaged in fraud, collusion, or any other violations to our Security & Ecology Agreement, while using a proxy, VPN or remote desktop, their accounts may be blocked and funds may be confiscated without prior warning.

10. RATHOLING
10.1. Ratholing includes, without limitation, incidents where a User plays short-stacked and upon hitting a certain chip threshold, the offending User intentionally leaves the table, and immediately sits with a lesser stack at a new table of the same limit.
10.2. Should a User be suspected of engaging in ratholing, said User will be issued a warning.
10.3. In the event of repeated breaches of 10.1, the Security Team reserves the right to apply the actions set out in Section 17.

11. CIRCUMVENTION
11.1. GGPoker prohibits players from making fraudulent or unlawful use of the software.
11.2. GGPoker prohibits players from breaking into, accessing or attempting to break into the software and/or the Network with malicious intent.
11.3. GGPoker prohibits players from exploiting or attempting to exploit software bugs within the client for personal/mutual gain.
11.4. GGPoker has developed and employs sophisticated proprietary technology intended to seek out and identify offending Users.
11.5. Should the Security Team conclude that a User has violated these terms, the Security Team reserves the right to apply the actions set out in Section 17.

12. OFFENSIVE CHAT
12.1. GGPoker expects Users to follow the rules of common decency with respect to table chat.
12.2. Foul/Abusive Language: Users found using foul and/or abusive language will be issued a warning, and have their chat removed for seven (7) days. Repeated offences from the same User may result in an extended suspension or a lifetime ban from the Network.
12.3. Racist Language: Users found using racist language will be issued a warning, and have their chat removed for a month. A second offence will result in the permanent removal of said User’s chat function.
12.4. Spamming: Users found spamming other Users about external websites, promotions or products will have their chat function removed permanently.
12.5. Begging: Users found begging at the tables will be given a warning, and have their chat removed for a month. A second offence may result in the removal of said User’s chat function.
12.6. Discussing Hands-in-play: Users found discussing hands-in-play will have their chat function removed for a month. Repeated offences may result in the permanent removal of said User’s chat function.
12.7. Should GGPoker remove the chat function from a User’s account, a message detailing the reason for the removal will be issued to said User.
12.8. In addition to the broad rules stated above, a common-sense policy should be used as to what is and is not considered to be appropriate chat. Inappropriate chat shall be handled and dealt with on a case-by-case basis.

13. OFFENSIVE USER PROFILE
13.1 Users should not have player profiles, i.e. nicknames and avatars, that are offensive to other Users. A common-sense policy should be used to determine what is deemed to be offensive. Examples are player profiles with political, racial, or sexual implications, those that contain insults, or expletives, and celebrity impersonations.
13.2. GGPoker reserves the right, without prior notice, to replace any avatars it deems to be offensive.
13.3. GGPoker reserves the right, without prior notice, to suspend for up to thirty (30) days or block any accounts with offensive nicknames.

14. RESIDENTIAL COUNTRY
GGPoker, in its sole discretion, reserves the right to change a User’s residential country (flag) to match their log-in information. In such cases, GGPoker will issue said User a message outlining the change.

15. PRIVACY POLICY
15.1. GGPoker is committed to protecting Users’ personal information. The Privacy Policy describes what information we collect, why we collect this information, and how we use the collected information.
15.2. We may automatically collect certain data and receive Personal Information which the User provides to us. We may also receive Personal Information from operators and service providers. We will have access to any information which User provides to such vendors, service providers and third-party e-commerce services, and we will use the Personal Information as set out in this Privacy Policy. We take steps to ensure that our arrangements with third-party service providers and online vendors protect our User’s privacy.
15.3. We may disclose your Personal Information if required to do so by law, or for the reasons outlined below:
15.3.1. To comply with any legal process served on us, any of our sites or the Services or in circumstances where we are under a substantially similar legal obligation.
15.3.2. To protect and defend our rights or property.
15.3.3. If, in our reasonable judgment, it is necessary to enforce compliance with our internal policies to protect our company, customers, or others.
15.3.4. Where sharing or disclosing your information is required in order to offer you products or services you desire, provided that User has given us his/her consent to do so.
15.4. We may disclose your information to the following:
15.4.1. To a third party or parties, where disclosure is required or permitted by law.
15.4.2. To any other entity that acquires all or a portion of our organisation by merger, reorganisation, operation of law, or a sale of some or all of our assets.
15.5. GGpoker considers any attempts to solicit personal information as a threat to our Users, and strictly prohibits such behavior. Should GGPoker determine that solicitation of personal information has occurred, we reserve the right to immediately suspend the offending accounts for further investigation, permanently ban the offending accounts, and in severe cases, take legal actions against these accounts.

16. MISCELLANEOUS
16.1. Users determined to have violated multiple SEA rules may face actions in addition to those corresponding to each individual violation.
16.2. Warnings and penalties issued to a User will apply to all accounts, regardless of operator, attributable to said User.
16.3. In the event that a User avoids or fails to cooperate with our investigations, GGPoker will have no choice but to rely on the findings of its investigation to draw conclusions, and administer penalties (as set out in Point 17).
16.4. GGPoker reserves the right to refrain from revealing details about how security investigations have been conducted, so as not to fall susceptible to future abuse and circumvention of our detection methods.
16.5 GGPoker shall ensure a high standard of regulatory compliance in relation to preventing its services from being associated with crime and disorder. GGPoker shall implement appropriate safeguards to minimise the risk of its gaming platform being used to launder money, assisting in the financing of terrorism or being victim of a crime. GGPoker shall ensure that management and staff are aware of their obligations at law and procedures that must be followed.

17. ACTIONS FOR BREACH OF THE SEA
17.1. It is the Security Team’s paramount objective to provide a safe and healthy poker environment and will always aim at educating Users at the outset. In cases where a serious breach (and continued breaches) occurs, a player’s account may be locked to allow for an investigation of the alleged breach. For the duration of the lock, the User account, login, gameplay, withdrawal, deposits or inter-wallet transfers may not be possible.
17.2. Measures which can be taken against Users for confirmed breaches, based on the accumulated information available, may be one, or a combination of the following:
a) A written warning;
b) Temporary suspension of User’s account;
c) Permanent ban of User’s account;
d) Block of deposits/withdrawals/inter-wallet transfers;
e) Seizure of funds to compensate victims of breach (loss of funds due to use of bots or other 3rd Party Programs, loss of funds due to collusion, loss of funds due to bumhunting). Seizure of funds may include funds not only in the User’s poker wallet, but overall wallet and pending withdrawals within GGPoker.
f) Removal/reduction of player/promotional rewards;
17.3. The Security Team’s decision is final and The Security Team reserves the right to determine whether or not a breach of the SEA has occurred. User accepts the Security Team’s said right of decision and determination.

18. ACCOUNT SHARING
18.1 GGPoker prohibits account-sharing. Each account should solely be accessed by the User who registered it at all times.
18.2 GGPoker prohibits sharing sufficient volume of hands/results with anyone in order to analyse or hunt other Users.
18.3. Should the Security Team conclude that a User was/is involved in account sharing, the Security Team reserves the right to apply the actions set out in Section 17.