Game Lounge: Compliance through legal support

XY Legal Solutions (XYLS) and Game Lounge started their successful partnership through the Keurmerk Verantwoorde Affiliates (KVA, English: Quality Mark Responsible Affiliates). Game Lounge is a leading company within the iGaming affiliate space, offering their services across the globe for a range of operators. Naturally, this requires knowledge of, and strict compliance within different jurisdictions. Therefore, Game Lounge and XYLS started intensifying their partnership by signing a Legal Service Agreement. This agreement would guarantee quick and accessible legal support.

As Game Lounge is active in various jurisdictions, legal requirements differ significantly. It is for this reason that Game Lounge requested a method for making these requirements insightful in a clear and comprehensive manner. This resulted in multiple ‘Affiliate Market Guidelines’, which give clear information on the do’s and don’ts within specific markets. These markets include:

• Germany;
• The Netherlands;
• The United Kingdom;
• Sweden;
• Spain;
• Switzerland;
• And, Denmark.

These guidelines elaborate on numerous different topics. Game Lounge can alter these guidelines as they see fit per country as well. This greatly increases the value of the information, as there is simply no one-size-fits-all solution for every guideline. These guidelines offer a clear structure throughout, while still providing specific guidance.

Specific examples will be given for each market on what can or cannot be done concerning affiliation. This means that we will provide a list of what to do or not to do on an affiliate website, along with clear examples. These will, of course, be tailored according to Game Lounges´ needs, taking into consideration any differences in their affiliation business per market. An example from the Affiliate Guideline for Germany is given below, specifically about the ‘Careful and balanced design of expressions´, entirely based on German legislation and where possible, legal cases:

“Article 5 paragraph 3 of the GlüStV states that it is not allowed to make any advertisements for virtual slots, online poker and online casino games on the internet between 6.00 AM and 9.00 PM (this is also the case for live streaming, posting videos and further). The final deliberation on the GlüStV indicates that any form of advertising online gambling between these times is not allowed, but this does not apply to already given information. As such an affiliate may post new content outside of these times, but may not place any new advertisements activities for online gambling between 6.00 AM and 9.00 PM.

It is important to not give the impression that gambling is a substitution for financial problems and a solution for personal problems. The affiliate can take a few points into account when advertising gambling:

• Indicate that gambling is done for fun, not for the monetary gain;
• Avoid indicating that gambling is a way of life and/or can substitute working;
• Clearly state that responsible gambling behaviour is important/desired;
• Clearly state that excessive participation in gambling is not desired.”

Another example is for the prevention of deception, whereby concrete examples of texts have been given, for example:

“Do:

With this strategy you have something to hold on to. You can orient yourself to this and perhaps even prevent yourself from coming out negative. Games of chance always remain a matter of chance, but with this strategy you create a guideline for yourself.

Do not:

With this strategy you have something to hold on to. You can orientate yourself to this and make sure you don’t come out negative. Games of chance always remain a matter of chance, but with this strategy you can never come out negative.”

“Do:

Please note that a strategy has no direct influence on your chances of winning. It does help you to play consciously but is mainly there for a fun playing experience. Whether you win depends entirely on your luck!

Do not:

This strategy has a direct influence on your chances of winning. It helps you to play consciously and ensures that you win big. Why leave your winning to your luck, when this strategy guarantees winning!”

These are just some of the examples given in the guidelines. The total collection of examples gives a thorough view of all the do’s and don’ts when it comes to content.

The complete report can be quite extensive, reason being the (amount of) topics that are incorporated. We use our own designer in drafting these guidelines. They will design the guideline as if it was an internal document, using Game Lounges´ logo and characteristics specific to their own internal documents. The style of writing will also be as if it was an internal document. The result will be a clear internal document (PDF), containing all the needed information for Game Lounge to perform its affiliate services in a compliant manner. This will also save them the manpower they would otherwise need to allocate to research the full legislation on iGaming affiliation, allowing them to focus on their core business.

The Legal Service Agreement provides Game Lounge with the option to request legal advice at all times. Thanks to our ‘low threshold’ approach, our team of professional legal consultants will quickly and easily address any requests for assistance. This will allow Game Lounge to receive quick and accurate legal advice, whenever they require. With our multidisciplinary team, we offer advice on a range of topics, including iGaming, GDPR and contract law. We provide a specifically tailored approach for each request, which can vary from comprehensive reports to answering the question via chat or videocall.

Below you will find a very positive review on how Game Lounge has found our cooperation so far:

Are you interested in the compliance through legal support as described above? Please contact us, as our consultants will explain more.