Dispute Resolution and Arbitration

1) Purpose and principles

The Dispute Resolution System is a transparent process for resolving disagreements between the platform and the user:

Accessibility and clarity: clear steps, contacts, deadlines, statuses.
Fairness and impartiality: independent consideration, right to be heard.
Evidence: Decisions rely on facts, logs, and artifacts.
Proportionality: escalation as necessary (claim → mediation/ombudsman → arbitration/court).
Speed: Target SLAs, automatic reminders and deadline control.
Compliance: the process is compatible with terms (Terms), payments/CUS, bonus rules, privacy.

2) Dispute area (iGaming-specific)

1. Calculation of bets/game outcomes (errors, cancellations, sources of official results).
2. Bonuses and promos (vager, games contribution, max bet, exceptions).
3. Payments/payments/KYC/SoF (same-method, terms, refusal according to documents).
4. Technical failures (session breaks, provider unavailability, interface bugs).
5. Antifraud/sanctions/blocking (multi-accounts, VPN, collusions).
6. Chargebacks and bank disputes (link to internal claim).
7. Privacy (data errors, access/correction/deletion).

3) Process map (levels and timelines)

U0 - Information Request

Channel: chat/ticket/mail.

Response SLA: Up to 24 hours

Result: quick clarifications, references to rules, no legal positions.

U1 - Internal Complaint

Form: standard (account ID, disputed transaction/game, requirement, arguments, files).
Admission/registration SLA: 1 business day.
SLA solutions: up to 15 calendar days (complex cases - up to 30 days).
Result: decision/partial satisfaction/refusal + motivation and appeal procedure.

U2 - Mediation/Ombudsman/ADR

If available in a jurisdiction: free/low-cost alternative procedure.
Terms: 15-45 days.
Result: recommendation/mandatory prescription (depends on the regime).

U3 - Arbitration/Court

Under the contract - preferably commercial arbitration; otherwise, a court of competent jurisdiction.
Timing: Depends on schedule/load (usually 3-12 months).
Enforceability: Arbitral awards are subject to recognition and enforcement under applicable law.

4) Evidence and artifacts (what to store and show)

Game logs: round hash tickets, time, bets/winnings, provider, client version.
Payment data: deposit/withdrawal requests, statuses, PSP codes, commissions.
KYC/AML: date of requests, document versions, inspection results (without excessive disclosure).
System logs: failures, rollback times, restarts, incidents at providers.
Communications: tickets, e-mail, timestamps, proposed solutions.
Screenshots/videos of the user: if available, linking to the event.

Shelf life: in accordance with the law (often 5-10 years for finance/AML) + privacy regulations.

5) Typical cases and decision logic

Case A - Bet/Play Calculation

Check the source of the official result, the rules of the game/line.
If provider/feed error: cancel/recalculate, compensation within reasonable limits.

Case B - Bonus Dispute

Check WR/Max Bet/contribution of games/timing against published offer.
Under hidden/non-obvious conditions - a decision in favor of the user or "voluntary settlement" (goodwill).

Case C - Payout/LCC

Check compliance of the name, status of sanctions/PEP, Ownership/SoF documents.
In case of objective non-compliance - a motivated refusal with instructions on how to eliminate.

Case D - Technical Failure

Check incidents (provider statuses, logs).
Restitution: return of the bet/maximum correct restoration of state.

Case E - Antifraud/interlock

Human review of evidence is mandatory; without "black boxes."

Provide the user with a list of facts (to the extent permissible), an appeal channel.

Case F - Chargeback

Freeze balance until dispute is resolved.
In the solution - mutual settlement, prohibition/limits of methods, mark in the risk profile.

6) Responsibility and compensation matrix (recommendation)

Situation	Platform responsibility	Compensation examples
Calculation error due to provider/feed fault	High	Recalculation + goodwill bonus (cap%)
Non-obvious bonus conditions	Medium-high	Payment according to the best interpretation, correction of the offer
Payment delay without user's fault	Average	Compensation Bonus Fixed/% of Amount
Reasonable refusal (name/sanction mismatch)	Low	Clarification, correction checklist
Service technical failure	Medium-high	Bet return, freespin repeat, goodwill

Compensations are voluntary, do not admit guilt, are recorded in the decision log.

7) Communications and tone (UX requirements)

Single claim form with mandatory fields and attachment checklist.
Cabinet statuses: Accepted → Under review → Data needed → Resolution → Closed/Escalation.
Deadlines and ETAs: Display deadlines and the date of the next update.
Clarity of language: avoid jargon, juridesis, passive collateral.
Link to the rules: next to the subject of the dispute (game, bonus, conclusion).

8) Conflict of interest and independence

Disputes over game providers - a dedicated officer/committee unrelated to commercial KPIs.
Complex cases - internal "appeal board" from Legal/Compliance/Payments/Support.
Transparent journal: who made the decision, based on what data.

9) Escalation policy

Auto-time escalation: no solution to the deadline → auto-reminder → transfer to a higher level.
Auto Risk Escalation: Sanctions/Significant Volume/Public Complaint → Immediate L3.
Open door: the user can ask for a review at the top level once without sanction.

10) Arbitration clause (template - adapt with lawyer)

💡 Arbitration and Applicable Law. Any dispute arising out of or in connection with these Terms shall be finally settled by commercial arbitration in [city, country] under the rules of [name of institution]. The number of arbitrators shall be one (or three). The language of the proceedings is [language]. Applicable substantive law is [country] law, without regard to conflict of laws rules. The parties agree that the award is final and enforceable by the competent courts. Before submitting to arbitration, the parties undertake to go through the pre-trial claim procedure for a period of [30] calendar days.

Notes:

For consumer markets, consider ombudsman/ADR access regulations and a ban on "unduly burdensome" clauses.
For B2B (affiliates/providers) - more stringent arbitration conditions are allowed.

11) Claim procedure (Terms section template)

💡 Complaints and grievances. The user has the right to file a claim through the account form or by [email]. A claim must contain: (i) an account identifier; (ii) event description, date/time; (iii) the requirement; (iv) supporting documents/screenshots. The platform confirms receipt within 1 working day and provides a motivated response within 15 calendar days. In exceptional cases, the period can be extended up to 30 days - with notification. The user has the right to appeal the decision internally and/or contact the Ombudsman/ADR (if available) or arbitration/court according to the section "Arbitration."

12) Relationship with chargebacks

An internal claim does not cancel the consumer's right to dispute at the bank, but:

recommend completing the internal process (faster and more transparent for the game/bonuses);
with chargeback - fix hold residues until the outcome;
avoid "double recovery."

13) Privacy and data disclosure in disputes

Reveal exactly the required volume (minimization, masking).
Separate categories (KYC biometrics) - only if strictly necessary.
Separate register of requests and issues (who, when, why).

14) Quality metrics and controls

SLA compliance:% of cases closed on time.
Time-to-Decision (p50/p95) and escalation share.
Win/Lose/Goodwill Rate by topic (payments, bonuses, technical failures).
Repeated disputes (%) at 30/90 days.
Reasons for disputes (top 5) - for product edits.
Satisfaction (CSAT) by case outcome.

15) Checklists

Before publishing the procedure:

Channels, shape, and SLAs are defined at each layer.
Solution and letter templates are ready.
Evidence and access map (who sees what).
Procedure for sanctions/RAP and technical failures.
Agreed with Terms/Bonus/Withdrawal/Privacy.
Versioning and change log.

For agent (each case):

User identification.
Subject of dispute and norms (game/bonus/payout).
Evidence collected, logs verified.

[The] decision is motivated, clear and benevolent.

Path forward indicated (appeal/ADR/arbitration).
Registry entry and metrics updated.

16) Letter templates (abbreviated)

A. Proof of Claim

Subject: Accepted your claim # [ID]

Text: Hello, [Name]! We registered your claim for [subject] on [date/time]. The deadline is [date]. The next status update is [date/time]. If you need documents, we will report separately.

B. Request Information/Documents

Topic: Need Additional Claim Data # [ID]

Text: For an objective decision, please attach: [list]. The deadline is [date]. If not, we will continue the consideration based on the available materials.

C. Reasoned decision (satisfied/partially/denied)

Subject: Claim Resolution # [ID]

Text: We reviewed the case and made a decision: [outcome]. Grounds: [briefly]. You can appeal by [date] or go to [ADR/Ombudsman/Arbitration] under the rules.

D. Escalation in ADR/Ombudsman

Topic: Alternative Dispute Resolution Information

Text: If you disagree with the decision, the ADR/Ombudsman procedure is available. Instructions: [how to submit/what data]. We will provide materials upon request.

17) Section for Terms (concentrate)

key> Dispute Resolution. In the event of a dispute, the User files a claim through an account or [email], indicating the details and attaching documents. The platform confirms receipt within 1 working day and provides a motivated response within 15 days (in exceptional cases - up to 30). In case of disagreement, the User has the right to apply to the independent ADR/Ombudsman procedure (if available) or refer the dispute to arbitration/court according to the section "Arbitration." Before going to arbitration, the parties undertake to go through the pre-trial procedure in good faith.

18) Implementation and operational maturity

1. Reflect the procedure in the interface: form, statuses, ETA, decision histories.
2. Train support/risk/payments on checklists and templates.
3. Set up a dashboard of metrics and monthly analysis of top reasons.
4. Synchronize the regulations with B2B contracts (game providers/PSP) - who provides logs and in what time frame.
5. Review Terms/Bonus/Within language quarterly for controversial interpretations.

19) Conclusion

A good dispute procedure is not only a "shield" against risks, but also a trust tool. Clear steps, fast deadlines, verifiable evidence and benevolent communication reduce transaction costs and increase loyalty. Build a transparent settlement ladder (claim → ADR → arbitration), fix it in Terms and interface - and you turn a potential conflict into a manageable process.