Last Updated / Effective Date: August 1, 2026
License Status: Direct B2B Supplier License ·
Applicability: This policy applies exclusively to contracted B2B Resellers, Distributors, and Software Aggregators.
1. Purpose & Structural Scope
As a licensed business-to-business (B2B) provider of digital high-speed lottery software under the National Ordinance on Games of Chance (LOK) framework, NovaPlay (the "Company") does not interact with retail end-users, host consumer wallets, or run customer-facing gaming domains.
The purpose of this policy is to define the structured channels through which operational, technical, or commercial complaints may be submitted to the Company. This framework enforces a rigid downstream chain of triage across all distributors, aggregators, and downstream retail entities to protect the integrity of the core software distribution network.
2. Downstream Complaint Triaging Hierarchy
To ensure alignment with the Curaçao Gaming Authority (CGA) dispute resolution standards, all complaints must be filtered sequentially through the supply chain. Direct submissions to the Company by parties lacking a direct B2B contract will be rejected automatically.
Retail End-User → B2C Licensed Operator → Corporate Reseller → B2B Lottery Provider
End-User Level: End-users must file all complaints directly with their respective B2C Operator using the operator's official dispute resolution framework. To facilitate this, the Operator must make a complaint submission form available to the end-user that can be downloaded or uploaded by the end-user, which must include all details confirmed in the CGA Player Complaints Policy Guidelines. In compliance with the CGA framework, operators must reject any player complaint submitted more than six (6) months after the date of the event giving rise to the dispute.
Operator Level: The B2C Operator must attempt to resolve the issue internally or via their designated Alternative Dispute Resolution (ADR) provider. If the issue stems directly from core lottery game logic, calculation errors, or API outages, the Operator must escalate the issue to their contracted Reseller.
Reseller Level: The Reseller must validate the operator's technical report. If a systemic software bug, mathematical variance, or backend core defect is verified, the Reseller may file a formal B2B Technical Dispute Ticket with the Company.
3. B2B Reseller Escalation Requirements
When an authorized Reseller escalates a downstream operator or player-level technical issue to Us, the ticket must be accompanied by comprehensive data to facilitate an immediate forensic review. The ticket must include:
- Unique System Identifiers: The exact Round ID, Transaction Hash, and Session Token.
- Telemetry Data: The time-stamped API request/response logs between the Operator's Player Account Management (PAM) platform and our lottery server engine.
- Operator Context: The corporate name, active gaming license number, and domain URL of the downstream operator impacted.
- Impact Statement: A clear breakdown of the financial or operational variance caused by the reported issue.
4. Resolution SLA Timelines & Prioritisation
We classify and resolve validated Reseller tickets according to their systemic severity to maintain continuous business continuity:
- Priority 1: Critical Core Outages (Resolution: Within 4 Hours) — Total API failure, global lottery draw stagnation, or widespread game processing errors affecting multiple downstream operators.
- Priority 2: Game-Level Calculation Disputes (Resolution: Within 5 Business Days) — Discrepancies in RNG payout ratios, delayed prize settlement draws, or localised transaction mismatches.
- Priority 3: General Operational Queries (Resolution: Within 14 Business Days) — Non-breaking integration requests, front-end visual bugs, or standard commercial reporting variances.
5. Mandatory CGA Incident Portal Reporting
In accordance with Article 5.10 of the LOK framework, we maintain a direct compliance link to the official CGA Online Portal.
If a complaint escalated by a Reseller reveals a systemic security breach, severe financial irregularity, software manipulation, or unexpected critical platform exploit, our Compliance Officer is legally mandated to log an immediate notification via the CGA Incident Reporting Module within 24 hours. All technical logs and data payloads associated with the incident will be securely hosted and archived within an approved, registered data center infrastructure located physically in Curaçao to remain accessible for regulatory audit.
6. Prohibited Direct Retail Contact ("Tipping Off" & Legal Separation)
- No Direct Player Mediation: We will not communicate with, arbitrate for, or settle funds directly with retail players.
- Strict Anti-Tipping Off Rules: If a downstream complaint is flagged by our internal compliance team as a potential money laundering attempt or fraud ring under the National Ordinance on the Reporting of Unusual Transactions (NORUT/ LMOT), the Reseller and Operator will not be provided with details regarding any subsequent regulatory disclosures filed with the Financial Intelligence Unit (FIU) Curaçao via the goAML platform.
7. Contact Details for Authorised Corporate Resellers
Authorised compliance officers and technical directors of contracted Resellers may submit validated escalations directly to our dedicated B2B dispute terminal:
B2B Intake Portal: https://novaplay.tech
Dedicated Compliance Desk: compliance@nexawin.com