Last Updated / Effective Date: August 1, 2026
1. Introduction & Scope of Operations
As a business-to-business (B2B) gaming content developer and software aggregator, NovaPlay is dedicated to fostering a safe, sustainable, and transparent digital gaming environment. Our B2B infrastructure solutions are aligned with the regulatory standards monitored by the Curaçao Gaming Authority (CGA) under the National Ordinance on Games of Chance (LOK). NovaPlay supplies games under a seamless-wallet model and does not hold player identity, KYC records, deposit history, limit settings or exclusion registers. Oversight of the distribution chain is accordingly performed at the operator and integration layer, not at the player layer. In accordance with the CGA’s updated compliance frameworks, we architect our gaming engines to support the prevention of gambling-related harm and help protect vulnerable persons at this structural level.
Because our business model operates strictly within a B2B supply chain, we do not maintain a direct retail relationship with end-user players, handle player registrations, or host player account metrics. Our software is distributed exclusively to direct corporate clients ("Resellers"), who subsequently license our content to downstream online Operators. Consequently, our responsible gaming compliance strategy is executed through two primary pillars: advanced technical game engineering and strict downstream contractual enforcement.
2. Technical Architecture & Embedded Player Protection Tools
We integrate player protection protocols directly into our code base. Our proprietary gaming software is engineered to seamlessly communicate with the player-protection and responsible gaming modules operated by downstream platforms. Our API infrastructure natively supports, processes, and respects player-protection parameters, including:
- Reality Checks and Session Alerts: Our games support real-time interval notification webhooks. These trigger in-game pop-up displays showing play duration and financial win/loss tallies, prompting players to confirm they wish to continue playing before proceeding.
- Dynamic Limit Configurations: Our systems recognize and immediately enforce daily, weekly, or monthly deposit, spending, session time, and loss limits established by the player on the operator's interface.
- Self-Exclusion Execution: Our game servers respond immediately to self-exclusion blocks relayed by the platform. When a player activates an exclusion period (ranging from temporary cool-off periods to permanent lifetime bans), our API immediately terminates the active game state and rejects subsequent game-loading requests from that unique token.
3. Downstream "Chain of Trust" & Contractual Mandates
To maintain the compliance profile of our software throughout its distribution lifecycle, we operate a strict "Chain of Trust" framework. We contractually mandate that all direct corporate Resellers enforce robust responsible gaming protocols within their downstream networks as a condition of utilising our software feeds.
- Operator Vetting & Digital Seals: Resellers are contractually obligated to verify that downstream Operators possess valid operational licensing from a recognised and competent gaming authority (including, but not limited to, the Curaçao Gaming Authority or other applicable sovereign regulators).
- Responsible Gaming Interfaces: Resellers must ensure that all downstream Operators deploy explicit, easily accessible, and localized Responsible Gaming sections. For operators running under Curaçao jurisdiction, this must include the mandatory CGA Digital Green Seal and direct links to certified support groups, while operators in other jurisdictions must display the equivalent statutory compliance badges and player-protection links mandated by their respective local regulators.
- Age Verification Controls: Resellers must ensure that downstream Operators maintain rigid, multi-stage identity verification checks to permanently prevent minors (under 18) and vulnerable persons from accessing our gaming content in accordance with the scope of the applicable Responsible Gaming Policy of CGA.
Self-Exclusion and Regulatory Prohibitions: Resellers must ensure that downstream Operators implement comprehensive self-exclusion mechanisms, ensuring that the applicable scope, terms, and conditions comply with all requirements arising from the LOK and CGA Policies. Downstream Operators must strictly observe all statutory prohibitions provided by the CGA Responsible Gaming Policy. - Fair Marketing Standards: Resellers must contractually restrict their partner networks from utilizing predatory marketing, misleading promotional bonus text, or advertising campaigns that exploit vulnerable or self-excluded individuals, all in accordance with the scope of the applicable Responsible Gaming Policy of CGA.
- Credit or Mediation: Resellers must ensure that downstream Operators do not engage in granting credit to players or mediate in this, or any related financing transactions, in accordance with the strict prohibitions of the LOK.
4. Monitoring, Onboarding, & Integration Audit Rights
Access to the game feed is authenticated per operator against credentials issued only following registration and approval, with declared brands, domains and permitted jurisdictions recorded at the point of onboarding. Resellers and aggregators are required to obtain prior written approval for onward distribution, to notify NovaPlay of each downstream operator before launch, to flow down responsible-gaming obligations, and to report responsible-gaming incidents to NovaPlay. Primary responsibility for monitoring the distribution chain rests with the Reseller.
NovaPlay retains integration telemetry that does not depend on player identity, including operator and brand identifiers, launch origin domain, session geolocation, player-identifier stability, wallet response and decline codes, and session duration. This data is queryable and is used to investigate indications of non-compliance. NovaPlay additionally acts upon regulator notifications, player complaints escalated to it, reseller reports, certification findings and periodic verification checks of downstream brands.
5. Enforcement & Action on Non-Compliance
If a Reseller fails to adequately monitor their distribution chain, or if a downstream Operator is discovered systematically bypassing player-protection boundaries, we will take immediate corrective action.
For the purposes of this clause, bypassing player-protection boundaries means:
- Operation on an undeclared brand or domain
- Operation into a jurisdiction outside the approved scope
- Onward distribution without approval
- Suppression or modification of responsible-gaming elements presented within the games
- Integration behavior inconsistent with an operative player-protection layer at the operator
Where non-compliance is established, NovaPlay suspends supply by revoking operator credentials and disabling the launch endpoint. Suspension can be applied at brand, operator or reseller level, and can be restricted by jurisdiction, permitting either localised or network-wide withdrawal of the game feed. Suspension is authorised by the Risk Manager and executed by the Risk Team without undue delay following the decision.
6. Institutional Training & Compliance Readiness
In accordance with CGA operational expectations, all internal game developers, account managers, and executive staff undergo mandatory annual training regarding local responsible gaming standards, problem gambling indicator detection, and ethical software development. We update our internal training criteria to ensure our software architecture adapts to evolving international gaming benchmarks and CGA mandates.