Contracts and legal obligations

1) Contract map in iGaming

B2C: User Agreement, Privacy Policy, Bonus Rules, Payment Policy/CCP, RG Policy.
B2B: Licensing agreements with game studios, PSP/KYC providers, anti-fraud services, data hosters.
White-label/Co-brand: IP/data distribution, brand guide, content rights and marketing.
Affiliates/Media: Advertising Standards (18 +/RG/short terms), pre-clearance, reporting, and payouts.
API/SDK: Terms of Use, rate limits, version/depletion, rights to Derived Data.
Partnerships/sponsorships: IP/image rights, "morals clause," 18 + zoning, make-good.
Infrastructure/outsourcing: SLA for uptime/support, security (ISO/SOC), audit.

2) Mandatory sections of any professional contract

1. Subject and scope: clear description of services/licenses, geo and channels.
2. Period and stages: phases, control points, acceptance criteria, transition to maintenance.
3. Responsibilities of the parties: deliverables, responsible roles, response time.
4. Payment: model (fix/rev-share/CPA/CPI), schedule, deductions, right of set-off.
5. SLA: uptime, RTO/RPO, P1-P3, maintenance windows, reporting.
6. Intellectual property: who owns the results, licenses, restrictions (white-label/OSS).
7. Data and privacy: roles (controller/processor), DPA/DSA, security, cross-border transfers, rights of subjects.
8. Advertising/RG requirements: 18 +/21 +, short terms, mislead prohibitions, pre-clearance.
9. Compliance/sanctions/export: screening of counterparties, prohibition of use in limited jurisdictions.
10. Warranties/representations and indemnities: absence of IP/sanction violations, rectification and damage coverage.
11. Limit of liability: cap (e.g. 12 × average weight payment), carve-outs (intent, IP, confidentiality).
12. Audit and monitoring: right of checks, format of logs/evidence, shelf life.
13. Subcontract/cession: flow-down obligations, no transfer without consent.
14. Exclusivity/competitive restrictions (if applicable).
15. Change Control: procedure, SOW/Change Order, pricing.
16. Force majeure and regulatory events: pause/adaptation when the law changes.
17. Termination: for/without cause, cure period, transitional duties.
18. Dispute resolution: claim → ADR/ombudsman/mediation → arbitration/court; applicable law.
19. Privacy and NDA: "survival" period, return/destruction.
20. Security conditions: encryption, secret management, vulnerabilities (SLA patches), incident reporting.

3) Contract type specificity

3. 1 White-label / Co-brand

Delimit: brand/TM, UI theme, content, code, data.
Prohibition of registration of similar TMs by the partner; domain/handle negotiation.
RG/disclaimers in template layouts, pre-clearance.

3. 2 Affiliate

Short terms next to CTA, 18 +/RG, list of prohibited sites/topics, stop words.
Attribution, transparency of sources, prohibition of sub-affiliates without consent.
Sanctions with gradation (S0-S4), withholding payments for violations.

3. 3 API/SDK

Authentication (OAuth2/HMAC/mTLS), rate limits, quotas.
Versioning (SemVer), EOL window ≥ 9-12 months, migration guide.
Rights to Service-Generated and Derived Data, TTL cache.
Prohibition of reverse engineering/benchmarking without consent.

3. 4 Payment/Data/ACC

Compliance with AML/sanctions, right to stop suspicious transactions.
DPA/DSA, DPIA for high-risk, data storage and aliasing.
Incident reporting ≤ 72 hours, audits and certifications (ISO/SOC).

4) Warranties, Representations and Indemnities

Guarantees: authority to sign, compliance with laws, absence of IP violations, absence of sanctions.
Representations: accuracy of information (finance, licenses, IP rights).
Indemnity: coverage of IP/confidentiality/sanctions claims, control of defense, exceptions in case of violation of the other party.

5) Limits, penalties and KPIs

Limit of liability (cap): differentiated (by type of damage) with carve-outs.
Service Credits: for not achieving SLA (uptime/MTTR).
KPI: uptime, Time-to-Wallet, RG incidents, proportion of compliant creatives/partners, time pre-clearance, Time-to-Takedown.

6) Audit, evidence and storage

Right to audit upon notification (e.g. 10-15 working days).
Evidence base: API logs, screenshots of creatives, CMP logs of consents, versions of offers, SLA reports.
Retention period: legal/contractual (e.g. 2-7 years), protection and availability on request.

7) Law, sanctions, export and geo-restrictions

Clauses on sanctions screening and prohibition of work with sanctioned persons/geo.
Export control (cryptography/technical data).
Geo-restrictions of display/service, country/region block lists.

8) Change Control

1. The initiator creates a Change Request with a description of the cost/timing/SLA effect.
2. The Parties shall agree on the Change Order (updated SOW/Appendix).
3. The roadmap, test plans and acceptance criteria are being updated.

9) Termination and exit

For cause: material breach, unrecoverable RG/sanctions, security mismatch.
For convenience: with notification (e.g. 30-90 days).
Transition period: data export, migration assistance, final reports, calculations.

10) Risk Matrix (RAG)

Zone	R (critical)	A (edits required)	G (control)
IP/Results	No transfer/license	Partially, without modifications	Assignment/license + guide
Data/DPA	No DPA/Roles	Incomplete DPA/TTL	Full DPA, Roles, DPIA
RG/Advertising	No short terms/18 +	Unreadable/not everywhere	Full coverage and pre-clearance
Sanctions/export	No clauses/screening	One-time screening	Policy + Periodic Rescreening
SLA/Credits	No SLA	SLA without metrics	SLA + credits + reporting
Audit/Evidence	No rights/logs	Partially	Audit power + registers

11) Checklists

Before signing

Subject/volume/geo/channels agreed.
IP rights (assignment/license), branding and restrictions are defined.
Prepared DPA/DSA, data roles, cross-border transmissions.
Included RG/ad requirements (18 +, short terms, pre-clearance).
Added sanctions/export and audit rights.
SLAs, service loans, incident procedures are prescribed.
Liability limit and carve-outs are set.
Change Control and termination procedure.

In progress

Regular SLA/KPI reports.
Updating registries (offer versions, logs, CMP, creatives).
Vulnerability Management Plan (SLA patches).

At closing

Export/delete data, revoke accesses.
Act of acceptance, Fin. calculation, archive of evidence.
Post-risk analysis and template update.

12) Templates of contractual clauses (fragments)

A. IP and deliverables

💡 All Results (code, design, texts, video, documentation) are created under the terms of work-for-hire or transferred to the Customer by Assignment with the right to modify and sublicense. The Executing Party guarantees that the Results do not violate the rights of third parties and do not contain OSS with conflicting licenses.

B. Data and privacy (DPA link)

💡 Parties agree on processing roles (Controller/Processor). Processing is by DPA/DSA, including security, sub-processors, cross-border transfers, and retention periods. The rights of data subjects are secured under applicable law.

C. RG/Advertising Requirements

💡 Any content is required to contain 18 +/21 +, "Play responsibly" and short offer terms (vager, max bet, term, contribution/exclusions) in a readable format next to the CTA. Pre-clearance is mandatory.

D. Sanctions and exports

💡 Each party confirms its absence from the sanctions lists and undertakes to screen counterparties. Transfer of technologies and cryptographic materials - in accordance with export control.

E. SLA and Service Credits

💡 At least 99 available. 9%. P1: answer ≤ 15 min, MTTR ≤ 2 h. If not fulfilled, service loans according to Appendix No. __.

F. Limit of liability and carve-outs

💡 Total liability is limited to payments for the 12 months preceding the event, excluding breaches of confidentiality, IP, intent or gross negligence.

G. Audit and evidence

💡 The Customer has the right to conduct an audit of compliance with the contract with 10 working days notice. The Contractor keeps logs, CMP-logs and versions of materials for at least [X] years and provides them upon request.

H. Termination and Transition Period

💡 Upon termination, the Contractor shall provide reasonable assistance on migration, transfer data in a machine-readable format and delete copies, confirming this in writing.

13) Recommended registries (YAML)

13. 1 Contract Register

yaml contract_id: "CTR-2025-072"
counterparty: "GameProviderX Ltd"
type: "SDK/License"
geo: ["UA","MT","CA-ON"]
term: "2025-11-01 — 2027-10-31"
sla:
uptime: "99. 9%"
p1_response_min: 15 mttr_p1_hours: 2 ip:
ownership: "license"
oss_policy: "permissive_only"
privacy:
dpa_signed: true roles: "processor"
retention_days: 365 compliance:
rg_required: true sanctions_screening: "quarterly"
change_control: true audit_rights: true owner: "Legal/Ops"
status: "active"

13. 2 Register of versions of offers/creatives

yaml offer_id: "OFF-2025-118"
version: "v2. 1"
short_terms: "18+      WR 30x      MaxBet 5      7d      slots 100%, jackpots 0%"
preclearance_ticket: "#PL-4412"
evidence:
screenshots: ["off_118_v21_mobile. png","off_118_v21_tvframe. png"]
cmp_consent_log: "link:consentlog/2025-11"

14) Playbooks (operational scenarios)

P-CON-01: SLA failure (uptime)

Counterparty monitoring → notification → service loan calculation → remediation plan → closing control → report.

P-CON-02: Violation of RG/advertising by affiliate

Screenshots/fixation → immediate withdrawal → withholding of payments → adjustment/training → entry in the register → upon repetition - termination.

P-CON-03: Data Incident

Isolation/forensics → notifications ≤ 72 h → fix/patch → update DPA/post-sea → policies.

P-CON-04: Sanction flag

Autoblock → Rescreening → JUR → Suspension/Termination → Documentation for Regulator.

P-CON-05: IP Dispute

Cease & Desist → negotiations/co-existence → if necessary - arbitration/court → updating guides/IP processes.

15) KPIs and reporting

SLA Compliance%, Service Credits (cash equivalent/month).
Time-to-Takedown by Ad/Affiliate.
DPA Coverage%, Data Incidents/Quarter.
Sanctions Screening Coverage %.
Share of contracts with current applications (brand guide, RG standards).
Average time of Change Order from application to signing.

16) Mini-FAQ

Do I need a separate DPA? Yes, if personal data is processed.
Is it possible to limit liability to "zero"? In B2B rarely acceptable; usually a reasonable cap with carve-outs.

How much to keep the API deprection window? Recommended 9-12 months

Who owns Derived Data? Under the contract: more often the owner of the platform is depersonalized.

17) Conclusion

A contract is a collaboration "operating system." Clearly capture subject, data roles, IP, RG/advertising, sanctions, and SLAs; maintain registries, logs, and evidence; use standardized playbooks. This will reduce legal risks, speed up partner onboarding and ensure predictable execution.