Terms and Conditions

Legal Notice and Disclaimer

RaffleGives, Inc. ("RaffleGives") provides software-as-a-service (SaaS) and payment facilitation services only. Each raffle is owned and operated solely by the named nonprofit organization. This public-facing document consolidates Terms of Service, Official Rules, Anti-Money Laundering (AML) and Know Your Customer (KYC) controls, Privacy and Security practices, and Payment Processor Compliance requirements to ensure full regulatory compliance and processor acceptance.

This document has been specifically designed to meet the compliance requirements of major payment processors including PayPal, Stripe Connect, Braintree (PayPal), and Authorize.net, while maintaining full compliance with Nevada Revised Statutes Chapter 462, Nevada Gaming Commission Regulation 4A, Federal Bank Secrecy Act, FinCEN guidelines, and applicable international standards.

© RaffleGives, Inc. All rights reserved. Operates as a Nevada SaaS and payment facilitation provider only. This document is prepared for public notice, regulatory compliance, and payment processor approval.

Table of Contents

Part I – Definitions & Legal Interpretation

Part II – Role Separation & Legal Characterization

Part III – Public Terms of Service (All Users)

Part IV – Official Rules for Charitable Raffles

Part V – Nonprofit Client Terms & Obligations

Part VI – Privacy, Data Protection & Security

Part VII – Anti-Money Laundering & Know Your Customer Program

Part VIII – Fraud Prevention & Technical Security Controls

Part IX – Payment Processor Compliance Framework

Part X – Regulatory Compliance & Legal Framework

Part XI – Enforcement, Penalties & Dispute Resolution

Part XII – Miscellaneous Provisions

Annexes A through L – Detailed Implementation Guides

Part I – Definitions & Legal Interpretation

1.1 Principal Definitions

This section establishes the fundamental terms and concepts that govern the interpretation and application of this Agreement. These definitions are critical for ensuring clarity among all parties and establishing the proper legal framework for charitable raffle operations conducted through the RaffleGives platform.

"Platform" means the comprehensive suite of website services, software applications, application programming interfaces (APIs), mobile applications, and related technologies made available by RaffleGives at www.RaffleGives.com and any associated subdomains or successor websites. The Platform includes all user interfaces, backend systems, payment processing integrations, random number generation services, analytics tools, and administrative dashboards provided to facilitate charitable raffle operations.

"Nonprofit" or "Charitable Organization" means a qualified tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code that has been granted recognition by the Internal Revenue Service, is in good standing with applicable state authorities, and is legally authorized to conduct charitable raffles under Nevada Revised Statutes Chapter 462 and Nevada Gaming Commission Regulation 4A. The Nonprofit must maintain active tax-exempt status and provide current documentation of such status upon request.

"Participant" or "Entrant" means any eligible individual who purchases, receives as a gift, or is otherwise allocated a raffle ticket for a Nonprofit's charitable raffle conducted through the Platform. Participants must meet all eligibility requirements set forth in these Terms and the specific Official Rules for each raffle event.

"Raffle" means a charitable 50/50 drawing or similar game of chance operated exclusively by a qualified Nonprofit under the authority of Nevada Revised Statutes Chapter 462 and Nevada Gaming Commission Regulation 4A, where participants purchase tickets for the opportunity to win a monetary prize, with proceeds benefiting the Nonprofit's charitable purposes. Each raffle must comply with all applicable federal, state, and local laws and regulations.

"Gross Proceeds" means the total amount of money collected from the sale of raffle tickets for a specific raffle event, calculated before any deductions for fees, costs, or expenses. This includes all ticket sales revenue regardless of payment method or processing fees incurred.

"Net Proceeds" means Gross Proceeds less all direct, reasonable, and customary costs associated with conducting the raffle, including but not limited to: (a) RaffleGives platform fees, (b) payment processing fees charged by third-party processors, (c) chargeback reserves and related costs, (d) approved marketing expenses, (e) third-party vendor costs for services such as random number generation, and (f) any other costs specifically authorized in the Master Services Agreement between RaffleGives and the Nonprofit.

"Payment Processor" means any Payment Card Industry Data Security Standard (PCI-DSS) compliant third-party payment processing service provider utilized by the Platform, including but not limited to Stripe (including Stripe Connect), Braintree (a division of PayPal Holdings, Inc.), Authorize.net (a Visa solution), or other qualified processors that have been approved for charitable gaming transactions and maintain appropriate licenses and certifications for processing payments in the gaming and charitable sectors.

"Chargeback Reserve" means five percent (5%) of Gross Proceeds that is held in a segregated account for a period of twelve (12) months following the completion of each raffle to cover potential payment reversals, chargebacks, disputes, and related processing costs. Any remaining balance in the Chargeback Reserve after the twelve-month period shall be disbursed according to the original prize distribution formula.

"Master Services Agreement" or "MSA" means the separate commercial agreement executed between RaffleGives and each Nonprofit client that governs the specific terms of service delivery, fee structures, technical specifications, and operational procedures for conducting raffles through the Platform.

"Official Rules" means the specific terms, conditions, eligibility requirements, prize structures, and procedures established by each Nonprofit for their individual raffle events, which must comply with these Terms of Service and all applicable laws and regulations.

1.2 Interpretation and Construction Principles

The interpretation of this Agreement shall be governed by the following principles to ensure consistent application and understanding among all parties. These principles reflect established legal conventions and are designed to promote clarity and fairness in the administration of charitable raffle operations.

Headings and section titles used throughout this document are included solely for convenience and organizational purposes and shall not be deemed to affect the interpretation, construction, or meaning of any provision. The substance of each section, rather than its title, shall govern in all cases of potential ambiguity.

References to the singular shall include the plural and vice versa, unless the context clearly indicates otherwise. References to any gender shall include all genders, and references to persons shall include individuals, corporations, partnerships, limited liability companies, trusts, governmental entities, and other legal entities as appropriate to the context.

All references to statutes, regulations, rules, or other legal authorities shall include such authorities as they may be amended, modified, supplemented, or superseded from time to time, unless specifically stated otherwise. References to specific sections or provisions of laws shall include any successor or replacement provisions that serve substantially the same purpose.

When multiple documents govern a particular raffle event, including these Terms of Service, the Nonprofit's Posted Official Rules, and the Master Services Agreement, the documents shall be read together harmoniously to the extent possible. In cases of irreconcilable conflict, the Nonprofit's Posted Official Rules for the specific raffle shall govern matters relating to that particular raffle event, provided such rules comply with these Terms of Service and applicable law.

Time periods specified in this Agreement shall be calculated in calendar days unless otherwise specified. When a time period expires on a weekend or federal holiday, the deadline shall be extended to the next business day. All time references shall be to Pacific Time unless otherwise specified.

1.3 Regulatory and Legal Framework References

This Agreement operates within a comprehensive regulatory framework that includes federal, state, and local laws, as well as industry standards and payment processor requirements. Understanding this framework is essential for all parties to ensure full compliance and successful raffle operations.

The primary regulatory authority for charitable raffles conducted through the Platform is the State of Nevada, acting through the Nevada Gaming Control Board and pursuant to Nevada Revised Statutes Chapter 462 and Nevada Gaming Commission Regulation 4A. These authorities establish the fundamental legal framework for charitable gaming activities and define the rights, responsibilities, and obligations of all participants in such activities.

Federal oversight is provided through various agencies and statutes, including the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury, which administers the Bank Secrecy Act and related anti-money laundering regulations. The Internal Revenue Service provides oversight of tax-exempt organizations and reporting requirements for gaming activities and prize distributions.

Payment processing activities are subject to additional regulatory oversight through the Payment Card Industry Security Standards Council, which establishes and maintains the PCI-DSS requirements that govern the secure handling of payment card information. Individual payment processors may impose additional requirements and restrictions based on their own risk management policies and regulatory obligations.

International participants and cross-border transactions may be subject to additional regulatory requirements, including but not limited to the European Union's General Data Protection Regulation (GDPR), various national anti-money laundering regimes, and sanctions programs administered by the Office of Foreign Assets Control (OFAC) and similar international bodies.

Part II – Role Separation & Legal Characterization

2.1 Nonprofit as Exclusive Raffle Operator

The fundamental principle underlying all raffle operations conducted through the RaffleGives Platform is that each Nonprofit serves as the sole and exclusive organizer, owner, and operator of its respective charitable raffles. This principle is essential for regulatory compliance and reflects the legal reality that RaffleGives provides technology services rather than conducting gaming activities.

Each Nonprofit that utilizes the Platform assumes complete responsibility for obtaining, maintaining, and complying with all legal permissions, licenses, registrations, and regulatory requirements necessary to conduct charitable raffles under Nevada Revised Statutes Chapter 462 and Nevada Gaming Commission Regulation 4A. This responsibility includes ensuring that the Nonprofit's tax-exempt status remains current and valid, that all required filings and reports are submitted timely to appropriate regulatory authorities, and that the Nonprofit maintains adequate insurance coverage and financial reserves as may be required by law.

The Nonprofit exercises exclusive control over all material aspects of raffle operations, including but not limited to: establishing ticket prices and prize amounts, determining raffle duration and drawing dates, creating marketing materials and promotional strategies, selecting winners through approved random selection methods, verifying winner eligibility and identity, distributing prizes in accordance with applicable laws, and maintaining all required records and documentation.

RaffleGives does not and shall not exercise any control or influence over the outcome of any raffle, the selection of winners, the determination of prizes, or any other aspect of raffle operations that would constitute conducting or operating a game of chance. RaffleGives' role is strictly limited to providing technological infrastructure, payment processing facilitation, and administrative support services as more fully described in Section 2.2 below.

2.2 RaffleGives' Limited Role as Technology Service Provider

RaffleGives operates exclusively as a software-as-a-service (SaaS) provider and payment facilitator, offering technological solutions that enable Nonprofits to conduct their own charitable raffles more efficiently and in compliance with applicable regulations. This limited role is carefully designed to ensure that RaffleGives does not engage in any activities that would constitute operating or conducting games of chance.

The specific services provided by RaffleGives include: (a) hosting and maintaining the technological platform through which Nonprofits can create and manage their raffle events, (b) providing secure payment processing integration that enables participants to purchase raffle tickets using various payment methods, (c) facilitating random number generation services through qualified third-party vendors acting on behalf of the Nonprofit, (d) offering analytics and reporting tools to help Nonprofits track raffle performance and comply with regulatory requirements, (e) providing customer support services to assist both Nonprofits and participants with technical issues, and (f) maintaining security measures and data protection protocols to safeguard sensitive information.

Importantly, RaffleGives does not sell or resell raffle tickets, does not determine odds of winning, does not select winners or influence the selection process, does not hold or distribute prizes, does not provide legal or tax advice regarding raffle operations, and does not guarantee the success or profitability of any raffle event. All such activities remain the exclusive responsibility and prerogative of the operating Nonprofit.

When RaffleGives engages third-party vendors to assist with specific aspects of raffle operations, such as certified random number generation services, such vendors act solely on behalf of and in the name of the Nonprofit. RaffleGives facilitates these relationships but does not direct or control the vendors' activities, and the Nonprofit remains fully responsible for ensuring that all vendor services comply with applicable legal requirements.

2.3 Fund Flow Architecture and Custody Arrangements

The financial architecture of the RaffleGives Platform is specifically designed to ensure that raffle proceeds flow directly to accounts controlled by the operating Nonprofit, with RaffleGives never taking custody or control of participant funds as a principal. This structure is essential for regulatory compliance and reflects the underlying legal principle that the Nonprofit, not RaffleGives, is conducting the raffle.

When a participant purchases a raffle ticket through the Platform, the payment is processed directly to a merchant account that is owned and controlled by the Nonprofit. This is typically accomplished through payment processor sub-merchant or marketplace arrangements, such as Stripe Connect, Braintree Marketplace, or Authorize.net sub-merchant accounts, where the Nonprofit maintains legal ownership and control of the account while benefiting from RaffleGives' technical integration.

RaffleGives' compensation for platform services is structured as a transparent service fee that is deducted from gross proceeds according to the terms of the Master Services Agreement with each Nonprofit. The standard fee structure includes: (a) an eight percent (8%) platform service fee calculated on gross proceeds, (b) payment processing fees capped at seven percent (7%) of gross proceeds, with actual fees typically lower based on the specific processor and transaction characteristics, and (c) a five percent (5%) chargeback reserve held for twelve months to cover potential payment reversals and disputes.

All fee deductions are clearly disclosed to Nonprofits and participants, and detailed settlement statements are provided to Nonprofits showing the calculation of net proceeds available for prize distribution and charitable purposes. The standard distribution formula allocates fifty percent (50%) of net proceeds to the raffle winner and fifty percent (50%) to the Nonprofit for its charitable activities, though individual Nonprofits may establish different distribution ratios in their Official Rules provided such ratios comply with applicable law.

The chargeback reserve mechanism serves to protect both Nonprofits and the payment processing ecosystem from the financial impact of payment disputes, fraudulent transactions, and other reversals that may occur after a raffle has concluded. Funds held in the chargeback reserve are maintained in segregated accounts and are not available for RaffleGives' general business purposes. After the twelve-month holding period, any unused reserve funds are distributed according to the original prize allocation formula.

2.4 Regulatory Compliance and Oversight Responsibilities

The division of regulatory compliance responsibilities between RaffleGives and operating Nonprofits reflects the fundamental principle that each party bears responsibility for compliance within their respective spheres of activity. This allocation ensures that regulatory obligations are met by the party best positioned to fulfill them while avoiding duplication of effort or gaps in coverage.

Nonprofits bear primary responsibility for all aspects of regulatory compliance related to their status as tax-exempt organizations and their authority to conduct charitable raffles. This includes maintaining current 501(c)(3) status with the Internal Revenue Service, complying with state charitable organization registration requirements, obtaining any required gaming licenses or permits, filing required reports with gaming regulators, maintaining adequate records of raffle operations, ensuring compliance with advertising and marketing regulations, and fulfilling all tax reporting and withholding obligations related to prize distributions.

RaffleGives bears responsibility for regulatory compliance related to its role as a technology service provider and payment facilitator. This includes maintaining appropriate business licenses and registrations, complying with data protection and privacy regulations, implementing and maintaining anti-money laundering and know-your-customer programs, ensuring payment processing compliance with card network rules and regulations, maintaining appropriate cybersecurity measures and incident response procedures, and cooperating with regulatory authorities in investigations or examinations related to platform operations.

Both parties share certain compliance obligations, particularly in areas where their activities intersect. For example, both RaffleGives and Nonprofits have obligations under anti-money laundering regulations, though the specific requirements may differ based on their respective roles. Similarly, both parties have obligations to maintain accurate records and to cooperate with regulatory authorities, though the scope and nature of such obligations may vary.

The Platform includes various compliance monitoring and reporting features designed to assist Nonprofits in meeting their regulatory obligations. These include automated record-keeping systems, compliance checklists and reminders, integration with tax reporting systems, and alerts for potential compliance issues. However, the availability of these tools does not transfer compliance responsibility from the Nonprofit to RaffleGives, and each Nonprofit remains ultimately responsible for ensuring its own compliance with all applicable requirements.

Part III – Public Terms of Service (All Users)

3.1 Eligibility Requirements and Geographic Restrictions

Participation in charitable raffles conducted through the RaffleGives Platform is subject to strict eligibility requirements designed to ensure compliance with applicable laws and regulations. These requirements reflect the legal framework governing charitable gaming activities and are essential for maintaining the Platform's regulatory compliance and payment processor approval.

All participants must be at least eighteen (18) years of age at the time of ticket purchase, or twenty-one (21) years of age where required by applicable law or the specific requirements of individual raffle events. Age verification may be required through government-issued identification documents, and RaffleGives reserves the right to request such verification at any time before, during, or after a raffle event.

Participants must be physically located within the State of Nevada at the time of ticket purchase and throughout their participation in any raffle event. This geographic restriction is mandated by Nevada gaming law and is enforced through multiple technical measures including IP address geolocation, device location services, and other geographic verification technologies. Attempts to circumvent these geographic restrictions through the use of virtual private networks (VPNs), proxy servers, location spoofing software, or other technical means are strictly prohibited and will result in immediate account termination and forfeiture of any tickets or winnings.

Participants must be legally eligible to participate in gaming activities under all applicable federal, state, and local laws. This includes compliance with any applicable exclusion lists, self-exclusion programs, or other restrictions that may apply to specific individuals. Participants who are employed by RaffleGives, the operating Nonprofit, or their immediate family members may be subject to additional restrictions as specified in individual raffle Official Rules.

International participants are generally prohibited from participating in raffles conducted through the Platform due to the complex legal and regulatory requirements governing cross-border gaming activities. However, specific exceptions may be made for certain international participants who can demonstrate legal eligibility and compliance with all applicable laws in their jurisdiction of residence, subject to additional verification and compliance requirements.

3.2 Account Registration and Information Accuracy Requirements

All users of the Platform must create and maintain accurate user accounts that contain current and complete information. The account registration process is designed to collect the minimum information necessary for identity verification, regulatory compliance, and fraud prevention while respecting user privacy and data protection rights.

Required account information includes: (a) full legal name as it appears on government-issued identification, (b) date of birth for age verification purposes, (c) current residential address, (d) valid email address for account communications, (e) telephone number for verification and security purposes, and (f) such additional information as may be required for enhanced due diligence or regulatory compliance purposes.

Users are strictly prohibited from creating multiple accounts, sharing accounts with other individuals, or providing false, misleading, or incomplete information during the registration process or at any time thereafter. Each individual may maintain only one active account on the Platform, and any attempt to circumvent this restriction will result in the closure of all associated accounts and forfeiture of any tickets or winnings.

Account information must be kept current and accurate at all times. Users are responsible for promptly updating their account information when changes occur, including changes of address, telephone number, or other contact information. Failure to maintain current account information may result in account restrictions, inability to claim prizes, or other adverse consequences.

RaffleGives employs various automated and manual verification procedures to confirm the accuracy of account information and detect potentially fraudulent or duplicate accounts. These procedures may include cross-referencing information against third-party databases, requiring submission of supporting documentation, conducting telephone or video verification calls, and other measures as deemed appropriate based on risk assessment factors.

3.3 Ticket Purchase Terms and Conditions

Raffle tickets are available for purchase exclusively through the official raffle pages hosted on the RaffleGives Platform. Tickets cannot be purchased through any other means, including telephone, mail, email, or third-party websites, unless specifically authorized in writing by the operating Nonprofit and RaffleGives.

All ticket purchases are final and non-refundable except as may be required by applicable law or in cases where a raffle is cancelled or suspended due to circumstances beyond the control of the operating Nonprofit. The specific terms governing refunds, if any, will be set forth in the Official Rules for each individual raffle event.

Ticket prices are established by the operating Nonprofit and are clearly displayed on each raffle page. Prices are quoted in U.S. dollars and include all applicable taxes and fees except for payment processing fees, which may be separately disclosed at the time of purchase depending on the payment method selected by the participant.

Payment for tickets must be made using approved payment methods, which typically include major credit cards, debit cards, and other electronic payment methods as supported by the Platform's payment processors. Cash payments, checks, money orders, and other non-electronic payment methods are not accepted. All payments are processed through PCI-DSS compliant payment processors using industry-standard security measures.

Participants may purchase tickets for themselves or as gifts for other eligible individuals, subject to the gifting policies established by individual Nonprofits in their Official Rules. When purchasing tickets as gifts, the purchaser remains responsible for ensuring that the intended recipient meets all eligibility requirements and agrees to be bound by these Terms of Service and the applicable Official Rules.

Tickets may not be resold, transferred (except as gifts where permitted), or used for any commercial purpose. Any attempt to resell tickets or engage in ticket scalping activities will result in the immediate voiding of all associated tickets and may result in legal action. This restriction is essential for maintaining the charitable nature of raffle activities and preventing the development of secondary markets that could undermine regulatory compliance.

3.4 Drawing Procedures and Winner Determination

All raffle drawings are conducted by the operating Nonprofit using certified random number generation systems that ensure fair and unbiased winner selection. RaffleGives facilitates access to these systems but does not control or influence the drawing process or outcomes in any way.

Random number generation services are provided through qualified third-party vendors who specialize in gaming and lottery applications and maintain appropriate certifications and audit procedures. These vendors operate under strict protocols designed to ensure the integrity and randomness of all drawing results.

Drawings are typically conducted at the date and time specified in the Official Rules for each raffle, though Nonprofits reserve the right to postpone or reschedule drawings in cases of technical difficulties, insufficient ticket sales, or other circumstances that may affect the integrity or fairness of the drawing process. Any changes to scheduled drawing times will be communicated to participants through the Platform and other appropriate channels.

Winners need not be present at the time of drawing to win, and presence at any drawing event (whether conducted virtually or in person) is not required for prize eligibility. However, winners must be able to respond to winner notification communications within the timeframes specified in the applicable Official Rules.

Drawing results are posted on the Platform within forty-eight (48) hours of the drawing and remain publicly available for a minimum of thirty (30) days. Results include the winning ticket numbers, the names of winners (subject to privacy preferences and legal requirements), and the prize amounts awarded.

3.5 Winner Verification and Prize Claim Procedures

All potential winners are subject to verification procedures designed to confirm their identity, eligibility, and compliance with all applicable terms and conditions. These procedures are essential for regulatory compliance and fraud prevention and must be completed before any prizes can be awarded.

Winner verification typically includes: (a) confirmation of identity through government-issued photo identification, (b) verification of age and geographic eligibility, (c) completion of required tax forms and documentation, (d) confirmation that the winner has not violated any terms or conditions of participation, and (e) such additional verification steps as may be required based on prize amount or other risk factors.

Winners must claim their prizes within six (6) months of the drawing date by contacting the operating Nonprofit directly and completing all required verification and documentation procedures. Failure to claim prizes within this timeframe will result in forfeiture of the prize, with disposition of unclaimed prizes determined by the operating Nonprofit in accordance with applicable law and the specific Official Rules for the raffle.

Prize payments are made directly by the operating Nonprofit, not by RaffleGives. Payment methods and timing are determined by each Nonprofit subject to applicable legal requirements and may include electronic transfer, check, or other methods as specified in the Official Rules. Large prizes may be subject to additional verification requirements and may require in-person claim procedures.

All prizes are subject to applicable federal, state, and local tax obligations, which are the sole responsibility of the winner. The operating Nonprofit will issue appropriate tax reporting forms, including IRS Form W-2G where required, and may be required to withhold taxes from prize payments in accordance with applicable law. Winners are strongly advised to consult with qualified tax professionals regarding their tax obligations.

3.6 Prohibited Conduct and Platform Abuse

Users of the Platform are prohibited from engaging in any conduct that violates applicable laws, undermines the integrity of raffle operations, interferes with other users' enjoyment of the Platform, or otherwise violates the terms and conditions set forth in this Agreement.

Specifically prohibited activities include but are not limited to: (a) cheating, collusion, or any attempt to manipulate raffle outcomes, (b) use of automated scripts, bots, or other software tools to purchase tickets or interact with the Platform, (c) tampering with or attempting to exploit vulnerabilities in Platform systems or security measures, (d) harassment, abuse, or inappropriate communication with other users, Nonprofit personnel, or RaffleGives staff, (e) creation of multiple accounts or sharing of account credentials, (f) use of false or misleading information in account registration or verification procedures, and (g) any attempt to circumvent geographic restrictions, age verification, or other eligibility requirements.

The use of VPNs, proxy servers, or other tools designed to mask or alter apparent geographic location is strictly prohibited and will result in immediate account termination. Similarly, the use of identity theft, synthetic identities, or other fraudulent means to create accounts or participate in raffles is prohibited and may result in criminal prosecution.

Users are also prohibited from engaging in any commercial activities related to their Platform participation, including but not limited to reselling tickets, operating ticket purchasing services for third parties, or using the Platform for any purpose other than personal participation in charitable raffles.

Violations of these prohibited conduct provisions may result in immediate account suspension or termination, forfeiture of tickets and winnings, reporting to appropriate law enforcement authorities, and pursuit of civil remedies for damages caused by such violations.

3.7 Intellectual Property Rights and Platform Usage

The RaffleGives Platform and all associated content, including but not limited to software, text, graphics, logos, images, audio clips, video clips, data compilations, and the overall design and functionality of the Platform, are owned by RaffleGives or its licensors and are protected by United States and international copyright, trademark, patent, and other intellectual property laws.

Users are granted a limited, revocable, non-exclusive, non-transferable license to access and use the Platform solely for the purpose of participating in charitable raffles in accordance with these Terms of Service. This license does not permit any commercial use of the Platform or its content, nor does it permit any downloading, copying, or other reproduction of Platform content except as may be necessary for normal Platform usage.

Users are specifically prohibited from: (a) reverse engineering, decompiling, or disassembling any Platform software or systems, (b) scraping, harvesting, or otherwise extracting data from the Platform through automated means, (c) creating derivative works based on Platform content or functionality, (d) removing or altering any copyright, trademark, or other proprietary notices, (e) using Platform content for any commercial purpose without express written permission, and (f) interfering with or disrupting Platform operations or security measures.

The RaffleGives name, logo, and other trademarks are the exclusive property of RaffleGives, Inc. and may not be used by others without express written permission. Similarly, Nonprofit names, logos, and other identifying information displayed on the Platform remain the property of the respective Nonprofits and are used with permission solely for the purpose of identifying the operators of specific raffle events.

Part IV – Official Rules for Charitable Raffles

4.1 Charitable Purpose and Legal Authority

All raffles conducted through the RaffleGives Platform are charitable fundraising activities operated exclusively by qualified 501(c)(3) tax-exempt organizations for the purpose of raising funds to support their charitable missions and activities. This charitable purpose is fundamental to the legal authority under which these raffles are conducted and distinguishes them from commercial gambling activities.

Each raffle must be conducted in accordance with Nevada Revised Statutes Chapter 462 and Nevada Gaming Commission Regulation 4A, which provide the legal framework for charitable gaming activities in Nevada. These statutes and regulations establish specific requirements for charitable organizations, raffle operations, prize structures, record-keeping, and reporting that must be followed by all participating Nonprofits.

The charitable nature of these raffles is further evidenced by the distribution of proceeds, with a substantial portion of net proceeds (typically fifty percent or more) being retained by the operating Nonprofit to support its charitable activities. This distribution structure ensures that the primary beneficiary of each raffle is the charitable cause supported by the operating Nonprofit, rather than commercial interests.

Operating Nonprofits must maintain current documentation of their tax-exempt status and charitable purposes, including IRS determination letters, state charitable organization registrations, and other required documentation. This documentation must be available for review by regulatory authorities, payment processors, and RaffleGives upon request.

The Platform includes features designed to highlight the charitable nature of each raffle, including information about the operating Nonprofit's mission and activities, descriptions of how raffle proceeds will be used to support charitable purposes, and links to additional information about the Nonprofit's work and impact in the community.

4.2 Eligibility and Participation Requirements

Participation in charitable raffles is subject to comprehensive eligibility requirements designed to ensure compliance with applicable laws and regulations while maintaining the integrity and charitable purpose of raffle activities. These requirements apply to all participants regardless of the specific raffle or operating Nonprofit.

Age requirements mandate that all participants be at least eighteen (18) years of age at the time of ticket purchase, with some raffles potentially requiring participants to be twenty-one (21) years of age based on the specific nature of the prizes or other factors. Age verification is conducted through multiple means, including account registration information, payment method verification, and direct identification document review where required.

Geographic eligibility is strictly limited to individuals who are physically present within the State of Nevada at the time of ticket purchase and throughout their participation in the raffle. This requirement is enforced through sophisticated geolocation technology, IP address analysis, and other technical measures designed to prevent participation from prohibited jurisdictions.

Legal eligibility requirements include compliance with all applicable federal, state, and local laws governing gaming activities, as well as confirmation that participants are not subject to any legal restrictions that would prohibit their participation in charitable gaming activities. This includes verification against applicable exclusion lists, self-exclusion databases, and other regulatory restrictions.

Participants must also meet financial eligibility requirements, including demonstration of legitimate sources of funds for ticket purchases and compliance with anti-money laundering requirements. Large or unusual purchase patterns may trigger additional verification requirements, including enhanced due diligence procedures and source of funds documentation.

Certain individuals may be subject to additional restrictions or prohibitions, including employees of RaffleGives, employees and board members of the operating Nonprofit, immediate family members of such individuals, and other persons who may have access to non-public information about raffle operations or outcomes.

4.3 Ticket Sales and Purchase Procedures

Raffle tickets are offered for sale exclusively through the official raffle pages hosted on the RaffleGives Platform, with no alternative purchase methods available unless specifically authorized by the operating Nonprofit and clearly disclosed in the Official Rules for a specific raffle event. This exclusive distribution method ensures proper oversight, regulatory compliance, and fraud prevention.

Ticket pricing is established by each operating Nonprofit based on their fundraising objectives, anticipated participation levels, and prize structures. Prices are clearly displayed on each raffle page and include all applicable fees except for payment processing fees, which may be separately disclosed depending on the payment method selected by the participant.

The ticket sales period for each raffle is clearly defined in the Official Rules, with specific start and end dates and times. Sales typically continue until a predetermined cutoff time before the scheduled drawing, allowing sufficient time for final processing, reconciliation, and drawing preparation. The operating Nonprofit reserves the right to extend or curtail the sales period based on participation levels, technical issues, or other factors that may affect the raffle's success or integrity.

Payment for tickets must be made using approved electronic payment methods processed through PCI-DSS compliant payment processors. Accepted payment methods typically include major credit cards, debit cards, and other electronic payment options as supported by the Platform's integrated payment systems. Cash, checks, money orders, and other non-electronic payment methods are not accepted to ensure proper transaction tracking and regulatory compliance.

All ticket purchases are immediately confirmed through automated email confirmations that include ticket numbers, purchase details, drawing information, and links to the applicable Official Rules. These confirmations serve as proof of purchase and contain important information about prize claim procedures and other participant obligations.

Participants may purchase multiple tickets for the same raffle, subject to any limits established by the operating Nonprofit in the Official Rules. Bulk purchase discounts may be available for certain raffles, with specific terms and conditions clearly disclosed at the time of purchase.

4.4 Prize Structures and Distribution Methods

Prize structures for charitable raffles conducted through the Platform are designed to balance attractive prizes for participants with meaningful fundraising results for operating Nonprofits. The most common structure is the "50/50 raffle" format, where fifty percent of net proceeds are awarded as prizes and fifty percent are retained by the Nonprofit for charitable purposes.

Alternative prize structures may be employed by individual Nonprofits, including fixed prize amounts, multiple prize tiers, or other configurations that comply with applicable legal requirements and regulatory guidelines. All prize structures must be clearly disclosed in the Official Rules for each raffle and cannot be changed after ticket sales have commenced.

Prize calculations are based on net proceeds as defined in these Terms of Service, which represents gross ticket sales less platform fees, payment processing costs, chargeback reserves, and other authorized deductions. Detailed calculations are provided to participants through the Platform and are included in the final drawing results and winner notifications.

For 50/50 raffles, the prize amount fluctuates based on ticket sales volume, with higher participation levels resulting in larger prizes. This variable prize structure creates incentives for participants to promote the raffle to others while ensuring that the Nonprofit's fundraising objectives are met regardless of participation levels.

Prize payments are made directly by the operating Nonprofit, typically within thirty (30) days of winner verification and completion of all required documentation. Payment methods may include electronic transfer, certified check, or other methods as specified in the Official Rules and agreed upon by the winner and the Nonprofit.

Large prizes may be subject to additional verification requirements, extended processing times, and mandatory tax withholding as required by federal and state tax laws. Winners of prizes exceeding certain thresholds will receive appropriate tax reporting forms, including IRS Form W-2G, and are responsible for reporting prize winnings on their tax returns.

4.5 Drawing Procedures and Randomization Standards

All raffle drawings are conducted using certified random number generation systems that meet or exceed industry standards for fairness, unpredictability, and auditability. These systems are provided by qualified third-party vendors who specialize in gaming and lottery applications and maintain appropriate certifications from recognized testing laboratories.

The drawing process begins with the generation of a complete list of all eligible tickets sold for the raffle, with each ticket assigned a unique sequential number based on the order of purchase. This ticket list is then used as the basis for random number generation, ensuring that each ticket has an equal probability of being selected as the winner.

Random number generation is typically conducted using hardware-based random number generators or cryptographically secure pseudorandom number generators that have been certified for gaming applications. The specific technology and procedures used for each drawing are documented and available for review by regulatory authorities upon request.

Drawings are conducted at the date and time specified in the Official Rules, typically in the presence of representatives of the operating Nonprofit and with appropriate documentation and witnessing procedures. While drawings may be conducted virtually through secure online systems, the same standards for randomness, documentation, and oversight apply regardless of the specific method used.

Drawing results are immediately recorded and verified through multiple independent checks before being posted on the Platform and communicated to winners. This verification process includes confirmation that the selected ticket number corresponds to a valid ticket purchase, that the associated participant meets all eligibility requirements, and that all drawing procedures were followed correctly.

In the event of technical difficulties, system failures, or other issues that may affect the integrity of a drawing, the operating Nonprofit reserves the right to postpone the drawing until such issues can be resolved. Any such postponements will be communicated to participants through the Platform and other appropriate channels, with new drawing dates and times clearly specified.

4.6 Winner Notification and Verification Procedures

Winner notification procedures are designed to ensure that legitimate winners are promptly informed of their success while maintaining appropriate security measures to prevent fraud and protect winner privacy. These procedures comply with applicable legal requirements and industry best practices for prize notification and verification.

Initial winner notification is typically conducted through multiple channels, including email to the winner's registered account, telephone contact using verified contact information, and posting of results on the Platform. Winners are generally required to respond to notification attempts within a specified timeframe, typically seventy-two (72) hours, to begin the prize claim process.

Winner verification procedures include comprehensive identity confirmation through government-issued photo identification, verification of age and geographic eligibility at the time of ticket purchase, confirmation of account ownership and authenticity, and completion of required legal documentation including prize claim forms and tax reporting documents.

Enhanced verification procedures may be required for large prizes, unusual circumstances, or participants who present elevated risk factors. These enhanced procedures may include in-person verification meetings, additional documentation requirements, background checks, or other measures deemed necessary to ensure the integrity of the prize award process.

Winners must complete all verification requirements within six (6) months of the drawing date to claim their prizes. Failure to complete verification within this timeframe, or failure to meet verification requirements, will result in forfeiture of the prize. Forfeited prizes are typically retained by the operating Nonprofit to support their charitable activities, though specific disposition procedures may vary based on applicable law and individual Official Rules.

The verification process also includes confirmation that winners have not violated any terms or conditions of participation, including prohibited conduct provisions, multiple account restrictions, or other eligibility requirements. Any violations discovered during the verification process may result in disqualification and prize forfeiture.

Privacy protection measures are implemented throughout the winner notification and verification process, with winner information disclosed only as necessary for prize award purposes and as required by applicable law. Winners may request that their names not be disclosed publicly, subject to any legal requirements for transparency in charitable gaming activities.

Part V – Nonprofit Client Terms & Obligations

5.1 Nonprofit Qualification and Compliance Responsibilities

Organizations seeking to conduct charitable raffles through the RaffleGives Platform must meet stringent qualification requirements designed to ensure regulatory compliance, protect participants, and maintain the integrity of charitable gaming activities. These requirements reflect both legal mandates and industry best practices for charitable gaming operations.

Qualifying organizations must maintain current and valid tax-exempt status under Section 501(c)(3) of the Internal Revenue Code, as evidenced by an IRS determination letter and confirmed through regular verification procedures. This tax-exempt status must be maintained throughout the duration of any raffle activities, and any changes in status must be immediately reported to RaffleGives.

Organizations must be in good standing with all applicable state and local authorities, including current registration as a charitable organization in Nevada and any other jurisdictions where required. This includes compliance with annual filing requirements, maintenance of registered agent services, and adherence to any specific requirements for charitable gaming activities.

Each Nonprofit must demonstrate legal authority to conduct charitable raffles under Nevada Revised Statutes Chapter 462 and Nevada Gaming Commission Regulation 4A. This may require obtaining specific gaming licenses or permits, depending on the organization's structure, activities, and the scope of proposed raffle operations. RaffleGives assists Nonprofits in understanding these requirements but does not provide legal advice regarding compliance obligations.

Nonprofits must maintain adequate insurance coverage appropriate to their raffle activities, including general liability coverage, directors and officers coverage, and such other insurance as may be required by applicable law or prudent risk management practices. Evidence of current insurance coverage must be provided to RaffleGives upon request.

Financial stability and operational capacity requirements ensure that Nonprofits can fulfill their obligations to participants, including prize payments, regulatory compliance, and proper stewardship of charitable funds. This may include review of financial statements, operational procedures, and management capabilities as part of the initial qualification process and ongoing monitoring.

5.2 Operational Obligations and Standards

Nonprofits utilizing the RaffleGives Platform assume comprehensive operational obligations designed to ensure successful raffle execution, regulatory compliance, and participant satisfaction. These obligations reflect the Nonprofit's role as the exclusive operator of raffle activities and their responsibility for all material aspects of raffle management.

Truthful and accurate representation of raffle terms, conditions, and procedures is fundamental to maintaining participant trust and regulatory compliance. Nonprofits must provide complete and accurate information for all raffle descriptions, including prize structures, drawing dates and procedures, eligibility requirements, and any special terms or conditions that may apply to specific raffles.

Marketing and promotional activities must comply with all applicable laws and regulations governing charitable gaming advertising, including truth-in-advertising requirements, disclosure of material terms, and avoidance of misleading or deceptive practices. All marketing materials must clearly identify the Nonprofit as the raffle operator and include appropriate disclaimers regarding eligibility restrictions and other important terms.

Prize fulfillment obligations require Nonprofits to honor all prize commitments in accordance with the published Official Rules and applicable legal requirements. This includes timely payment of prizes, proper tax reporting and withholding, and maintenance of adequate reserves to ensure prize payment capability regardless of participation levels.

Record-keeping requirements mandate maintenance of comprehensive documentation regarding all aspects of raffle operations, including ticket sales records, drawing procedures and results, winner verification and prize payment documentation, financial records showing the disposition of proceeds, and correspondence with participants and regulatory authorities.

Customer service obligations require Nonprofits to provide responsive and professional support to raffle participants, including answering questions about raffle procedures, assisting with technical issues related to ticket purchases, providing information about drawing results and prize claim procedures, and addressing any complaints or concerns that may arise.

5.3 Fee Structure and Financial Arrangements

The financial relationship between RaffleGives and Nonprofit clients is structured to align incentives, ensure sustainable operations, and provide transparent pricing that enables Nonprofits to accurately project fundraising results. The fee structure is designed to be competitive with alternative fundraising methods while providing comprehensive technology and support services.

The standard platform service fee is eight percent (8%) of gross proceeds from each raffle, calculated on the total amount of ticket sales before any other deductions. This fee compensates RaffleGives for providing the technology platform, payment processing integration, customer support services, regulatory compliance tools, and other services necessary for successful raffle operations.

Payment processing fees are capped at seven percent (7%) of gross proceeds, though actual fees are typically lower based on the specific payment processors used, transaction characteristics, and volume discounts that may apply. These fees cover the costs of credit card processing, electronic payment handling, fraud prevention services, and compliance with payment card industry security standards.

The chargeback reserve represents five percent (5%) of gross proceeds held in segregated accounts for twelve (12) months to cover potential payment reversals, disputes, and related costs. This reserve protects both Nonprofits and the payment processing ecosystem from the financial impact of chargebacks while ensuring that legitimate disputes can be resolved without affecting the Nonprofit's fundraising results.

Monthly settlement statements provide detailed accounting of all transactions, fees, and distributions, enabling Nonprofits to track their fundraising performance and comply with their own financial reporting requirements. These statements include gross proceeds, itemized fee deductions, net proceeds available for distribution, prize payments made, and amounts retained by the Nonprofit for charitable purposes.

Alternative fee arrangements may be available for high-volume Nonprofits or those with special circumstances, subject to negotiation and execution of customized Master Services Agreements. Such arrangements may include volume discounts, performance incentives, or other terms designed to support the Nonprofit's specific fundraising objectives.

5.4 Technology Integration and Support Services

RaffleGives provides comprehensive technology integration and support services designed to enable Nonprofits to conduct professional, compliant, and successful raffle operations without requiring specialized technical expertise or significant technology investments. These services are continuously updated to reflect evolving regulatory requirements, industry best practices, and participant expectations.

Platform integration services include setup and configuration of customized raffle pages that reflect each Nonprofit's branding, mission, and specific raffle parameters. This includes integration of the Nonprofit's logos, colors, and messaging, configuration of ticket pricing and prize structures, setup of drawing schedules and procedures, and integration with the Nonprofit's existing website and social media presence.

Payment processing integration connects each Nonprofit with appropriate merchant account services through established relationships with major payment processors including Stripe Connect, Braintree Marketplace, and Authorize.net sub-merchant programs. This integration enables secure, PCI-compliant processing of participant payments while maintaining the Nonprofit's control over their merchant account and funds.

Analytics and reporting tools provide real-time visibility into raffle performance, including ticket sales tracking, participant demographics, marketing effectiveness metrics, and financial performance indicators. These tools enable Nonprofits to optimize their raffle strategies, comply with reporting requirements, and demonstrate accountability to their stakeholders.

Customer support services include technical assistance for both Nonprofits and their participants, covering account setup and management, payment processing issues, drawing procedures and results, prize claim assistance, and resolution of any technical or operational issues that may arise during raffle operations.

Training and educational resources help Nonprofit staff understand their obligations and optimize their use of the Platform, including compliance training, best practices guidance, marketing support, and ongoing consultation on raffle strategy and execution.

5.5 Compliance Monitoring and Reporting

RaffleGives implements comprehensive compliance monitoring and reporting systems designed to assist Nonprofits in meeting their regulatory obligations while providing transparency and accountability to regulatory authorities, payment processors, and other stakeholders. These systems reflect industry best practices and evolving regulatory expectations.

Automated compliance monitoring includes real-time tracking of participant eligibility verification, geographic restriction enforcement, age verification compliance, transaction monitoring for unusual patterns or potential fraud indicators, and adherence to established raffle procedures and timelines.

Regulatory reporting assistance includes preparation and submission of required reports to gaming authorities, assistance with tax reporting obligations related to prize distributions, coordination with regulatory examinations or investigations, and maintenance of documentation necessary for regulatory compliance demonstrations.

Financial monitoring and reconciliation services ensure accurate tracking of all funds, proper calculation and distribution of proceeds, compliance with reserve requirements and escrow obligations, and transparent reporting of all financial activities related to raffle operations.

Audit support services include maintenance of comprehensive audit trails for all Platform activities, assistance with internal and external audit procedures, preparation of documentation for regulatory examinations, and coordination with independent auditors or compliance consultants as may be required.

Risk assessment and management services include ongoing evaluation of compliance risks, implementation of enhanced controls for high-risk activities or participants, coordination with law enforcement and regulatory authorities regarding potential violations or criminal activity, and development of corrective action plans for any compliance deficiencies that may be identified.

5.6 Indemnification and Risk Allocation

The allocation of legal and financial risks between RaffleGives and Nonprofit clients reflects the fundamental principle that each party bears responsibility for risks within their respective spheres of control and expertise. This allocation is designed to provide appropriate protection for all parties while ensuring that risks are managed by those best positioned to control and mitigate them.

Nonprofits agree to defend, indemnify, and hold harmless RaffleGives, its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or relating to the Nonprofit's raffle operations, including but not limited to claims related to prize obligations, regulatory compliance failures, advertising or marketing activities, participant disputes, tax obligations, and any violations of applicable laws or regulations.

This indemnification obligation extends to claims by payment processors, regulatory authorities, participants, and other third parties that may arise from the Nonprofit's activities or failures to comply with applicable requirements. The indemnification is essential for enabling RaffleGives to provide services to multiple Nonprofits while managing aggregate risk exposure across the Platform.

RaffleGives maintains appropriate insurance coverage for its own operations and agrees to indemnify Nonprofits for claims arising solely from RaffleGives' negligence, willful misconduct, or material breach of its service obligations. However, this indemnification does not extend to claims arising from the Nonprofit's own actions, decisions, or compliance failures.

Risk mitigation procedures include comprehensive insurance requirements for Nonprofits, regular compliance monitoring and reporting, implementation of industry-standard security measures, coordination with qualified legal and compliance professionals, and maintenance of appropriate reserves and escrow arrangements to ensure financial obligations can be met.

Limitation of liability provisions establish reasonable caps on potential damages while ensuring that essential obligations, such as prize payments and regulatory compliance, remain fully enforceable. These limitations reflect the service-based nature of the relationship and the need to maintain sustainable operations across multiple Nonprofit clients.

Part VI – Privacy, Data Protection & Security

6.1 Data Collection and Processing Principles

RaffleGives is committed to protecting the privacy and personal information of all Platform users while maintaining the comprehensive data collection and processing capabilities necessary for regulatory compliance, fraud prevention, and effective raffle operations. Our data handling practices are designed to comply with applicable privacy laws including the European Union's General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and Nevada Revised Statutes Chapter 603A.

The collection of personal information is limited to data that is necessary for legitimate business purposes, including identity verification, age and geographic eligibility confirmation, payment processing, regulatory compliance, fraud prevention, customer support, and marketing communications where consent has been provided. We employ data minimization principles to ensure that only necessary information is collected and retained.

Personal information collected through the Platform includes: (a) identification information such as full name, date of birth, and government-issued identification numbers, (b) contact information including residential address, email address, and telephone numbers, (c) payment information including credit card details, bank account information, and transaction history, (d) technical information such as IP addresses, device identifiers, and geolocation data, (e) behavioral information including Platform usage patterns, raffle participation history, and communication preferences, and (f) verification information including documentation submitted for identity confirmation and enhanced due diligence procedures.

The legal basis for processing personal information varies depending on the specific type of data and purpose for processing. Primary legal bases include: (a) contractual necessity for information required to provide Platform services and fulfill raffle participation obligations, (b) legal compliance for information required to meet regulatory obligations under gaming, anti-money laundering, and tax reporting laws, (c) legitimate interests for information used for fraud prevention, security, and business operations, and (d) consent for information used for marketing communications and optional services.

Data subjects have comprehensive rights regarding their personal information, including the right to access information about what data is collected and how it is used, the right to correct inaccurate or incomplete information, the right to delete information in certain circumstances, the right to restrict processing for specific purposes, the right to data portability for information provided directly by the data subject, and the right to object to processing based on legitimate interests.

6.2 Data Security and Protection Measures

RaffleGives implements comprehensive security measures designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures reflect industry best practices and regulatory requirements for organizations handling sensitive financial and personal information in the gaming and payments industries.

Technical security measures include encryption of all data in transit using Transport Layer Security (TLS) 1.2 or higher protocols, encryption of sensitive data at rest using Advanced Encryption Standard (AES) 256-bit encryption or equivalent, secure tokenization of payment card information through PCI-DSS compliant payment processors, multi-factor authentication for administrative access to Platform systems, and regular security assessments and penetration testing by qualified third-party security firms.

Administrative security measures include role-based access controls that limit employee access to personal information based on job responsibilities, comprehensive background checks for all employees with access to sensitive information, regular security training and awareness programs for all staff members, incident response procedures for security breaches or suspected unauthorized access, and regular review and updating of security policies and procedures.

Physical security measures include secure data centers with appropriate environmental controls, access restrictions, and monitoring systems, secure disposal procedures for hardware containing sensitive information, and protection of backup media and other physical storage devices containing personal information.

Network security measures include firewalls and intrusion detection systems to monitor and control network traffic, regular security updates and patches for all systems and software, network segmentation to isolate sensitive systems from general business networks, and continuous monitoring for suspicious activity or potential security threats.

Data breach response procedures include immediate assessment and containment of any suspected security incident, notification of affected individuals and regulatory authorities as required by applicable law, coordination with law enforcement agencies when criminal activity is suspected, implementation of remedial measures to prevent similar incidents, and regular review and updating of incident response procedures based on lessons learned.

6.3 Data Retention and Disposal Policies

RaffleGives maintains comprehensive data retention policies designed to balance legitimate business needs, regulatory requirements, and privacy rights. These policies ensure that personal information is retained only as long as necessary for the purposes for which it was collected, while meeting legal obligations for record-keeping in the gaming and financial services industries.

Standard retention periods vary based on the type of information and its purpose: (a) account and identity verification information is retained for a minimum of two (2) years after account closure or last activity, (b) transaction and payment information is retained for a minimum of five (5) years to comply with financial services regulations, (c) tax reporting information is retained for seven (7) years to comply with IRS requirements, (d) suspicious activity reports and related documentation are retained for five (5) years as required by anti-money laundering regulations, and (e) marketing and communication preferences are retained until consent is withdrawn or the individual requests deletion.

Extended retention periods may apply in certain circumstances, including ongoing legal proceedings or regulatory investigations, unresolved disputes or claims involving the individual, suspected fraudulent activity or other criminal conduct, and specific regulatory requirements that mandate longer retention periods for certain types of information.

Secure disposal procedures ensure that personal information is permanently destroyed when retention periods expire or when deletion is requested by data subjects (where legally permissible). Disposal methods include secure deletion of electronic data using industry-standard data wiping techniques, physical destruction of storage media containing sensitive information, and certification of destruction for all disposal activities.

Data subjects may request information about retention periods applicable to their personal information and may request deletion of information in certain circumstances, subject to legal and regulatory requirements that may mandate continued retention. All deletion requests are carefully reviewed to ensure compliance with applicable laws while respecting individual privacy rights.

6.4 Third-Party Data Sharing and Processing

RaffleGives shares personal information with carefully selected third-party service providers who assist in delivering Platform services, ensuring regulatory compliance, and supporting business operations. All third-party relationships are governed by comprehensive data processing agreements that establish appropriate safeguards for personal information and ensure compliance with applicable privacy laws.

Payment processing partners, including Stripe, Braintree (PayPal), and Authorize.net, receive payment and transaction information necessary to process raffle ticket purchases and facilitate fund transfers. These processors maintain their own PCI-DSS compliance certifications and privacy policies governing their handling of personal information.

Identity verification services receive identification and verification information necessary to confirm participant eligibility and comply with anti-money laundering requirements. These services are provided by specialized vendors who maintain appropriate certifications and security measures for handling sensitive identification information.

Cloud hosting and infrastructure providers receive technical information necessary to provide secure, scalable hosting services for the Platform. These providers maintain appropriate security certifications and compliance with industry standards for data protection and security.

Regulatory authorities may receive personal information as required by applicable laws and regulations, including gaming regulators, financial crimes enforcement agencies, tax authorities, and law enforcement agencies. Such disclosures are made only as required by law and are limited to the minimum information necessary for the specific regulatory purpose.

Legal and professional service providers may receive personal information in connection with legal proceedings, regulatory examinations, compliance audits, and other professional services. These providers are bound by professional confidentiality obligations and appropriate data protection agreements.

International data transfers, where necessary, are conducted in compliance with applicable legal requirements, including the use of Standard Contractual Clauses approved by the European Commission for transfers to countries without adequacy decisions, and implementation of appropriate technical and organizational measures to ensure data protection.

6.5 Individual Rights and Privacy Controls

RaffleGives provides comprehensive mechanisms for individuals to exercise their privacy rights and maintain control over their personal information. These mechanisms are designed to be user-friendly and responsive while ensuring compliance with applicable legal requirements and operational necessities.

Access rights enable individuals to obtain information about what personal information is collected, how it is used, who it is shared with, and how long it will be retained. Access requests can be submitted through the Platform's privacy portal or by contacting customer support, and responses are provided within the timeframes required by applicable law.

Correction rights allow individuals to update or correct inaccurate or incomplete personal information. Most account information can be updated directly through the Platform's user interface, while other corrections can be requested through customer support channels.

Deletion rights, also known as the "right to be forgotten," enable individuals to request deletion of their personal information in certain circumstances. However, deletion requests may be subject to legal and regulatory requirements that mandate continued retention of certain information, particularly in the gaming and financial services context.

Restriction rights allow individuals to limit the processing of their personal information for specific purposes while maintaining their account and participation eligibility. This may include opting out of marketing communications while continuing to receive transactional and regulatory communications.

Portability rights enable individuals to obtain copies of personal information they have provided in a structured, commonly used format that can be transmitted to other service providers. This right applies primarily to information provided directly by the individual rather than information generated through Platform usage.

Objection rights allow individuals to object to processing of their personal information based on legitimate interests, including marketing and profiling activities. However, objections may be overridden by compelling legitimate grounds for processing, particularly those related to regulatory compliance and fraud prevention.

Consent withdrawal rights enable individuals to withdraw consent for processing activities that are based on consent, such as marketing communications and optional services. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

6.6 Privacy Governance and Compliance Monitoring

RaffleGives maintains a comprehensive privacy governance program designed to ensure ongoing compliance with applicable privacy laws, industry standards, and internal policies. This program includes regular assessment of privacy practices, monitoring of regulatory developments, and continuous improvement of privacy protection measures.

Privacy impact assessments are conducted for new products, services, and processing activities to identify and mitigate potential privacy risks before implementation. These assessments consider the nature and scope of processing, the purposes and legal basis for processing, the risks to individual rights and freedoms, and the measures implemented to mitigate identified risks.

Regular compliance audits are conducted by internal and external auditors to assess adherence to privacy policies, effectiveness of security measures, compliance with legal requirements, and identification of areas for improvement. Audit findings are addressed through corrective action plans and ongoing monitoring.

Staff training and awareness programs ensure that all employees understand their privacy obligations, recognize potential privacy risks, and know how to respond to privacy-related inquiries and incidents. Training is provided regularly and updated to reflect changes in laws, regulations, and internal policies.

Privacy by design principles are integrated into all Platform development and business processes, ensuring that privacy considerations are addressed from the earliest stages of product development and business planning. This includes data minimization, purpose limitation, security measures, and user control mechanisms.

Regulatory monitoring includes ongoing assessment of privacy law developments, participation in industry associations and privacy organizations, engagement with regulatory authorities on privacy matters, and implementation of necessary changes to maintain compliance with evolving requirements.

Incident response procedures specifically address privacy-related incidents, including unauthorized access to personal information, data breaches, and other privacy violations. These procedures include immediate containment and assessment, notification of affected individuals and regulatory authorities as required, implementation of remedial measures, and documentation of lessons learned for future prevention.

Part VII – Anti-Money Laundering & Know Your Customer Program

7.1 AML/KYC Program Framework and Governance

RaffleGives maintains a comprehensive Anti-Money Laundering (AML) and Know Your Customer (KYC) program designed to comply with the Bank Secrecy Act, FinCEN regulations, and international standards established by the Financial Action Task Force (FATF). This program reflects the elevated compliance requirements applicable to organizations facilitating financial transactions in the gaming sector and ensures that the Platform cannot be used for money laundering, terrorist financing, or other illicit financial activities.

The AML/KYC program is overseen by a designated compliance officer who reports directly to senior management and maintains independence from business development and revenue-generating activities. This compliance officer is responsible for program development and implementation, staff training and oversight, regulatory reporting and communication, investigation of suspicious activities, and coordination with law enforcement and regulatory authorities.

Risk assessment procedures form the foundation of the AML/KYC program and include comprehensive evaluation of customer risk factors, transaction patterns and characteristics, geographic and jurisdictional risks, product and service risks, and delivery channel risks. These assessments are conducted regularly and updated to reflect changes in the regulatory environment, business operations, and identified risk factors.

The program includes written policies and procedures that address all aspects of AML/KYC compliance, including customer identification and verification requirements, enhanced due diligence procedures for high-risk customers, transaction monitoring and reporting obligations, record-keeping requirements, training and awareness programs, and audit and testing procedures to ensure program effectiveness.

Independent testing and audit procedures are conducted annually by qualified internal or external auditors to assess program effectiveness, identify deficiencies or areas for improvement, ensure compliance with regulatory requirements, and validate the accuracy and completeness of compliance reporting. Audit findings are addressed through corrective action plans and ongoing monitoring.

7.2 Customer Identification and Verification Procedures

All Platform users are subject to comprehensive customer identification and verification procedures designed to establish and verify their identity, assess their risk profile, and ensure compliance with applicable legal and regulatory requirements. These procedures are implemented at account opening and may be repeated or enhanced based on ongoing risk assessment and transaction monitoring.

Winner Identification Requirements

Identity verification is required only for the individual claiming a prize. The Winner must provide full legal name, date of birth, current residential address, government-issued identification (driver’s license, state ID, or passport), and Social Security Number or Taxpayer Identification Number where required for tax reporting. Contact information, including telephone number and email address, will also be collected for prize notification and fulfillment.

Verification Methods

The Winner’s identity will be confirmed through multiple methods, which may include cross-referencing information against authoritative databases and public records, authenticating government-issued documents using fraud-detection technologies, knowledge-based or biometric checks where legally permissible, and manual review by compliance personnel in higher-risk situations.

Address Verification

The Winner’s residential address will be verified through supporting documentation such as utility bills, bank statements, or official correspondence, as well as postal database cross-checks and technical validation measures where appropriate.

Enhanced verification procedures may be required for certain customers based on risk factors including: (a) high-value transaction patterns or unusual spending behavior, (b) geographic risk factors such as residence in high-risk jurisdictions, (c) occupation or business activities that present elevated money laundering risks, (d) adverse media coverage or law enforcement attention, (e) politically exposed person (PEP) status or close association with PEPs, and (f) previous suspicious activity reports or law enforcement inquiries.

Ongoing customer due diligence includes regular review and updating of customer information, monitoring for changes in risk profile or suspicious activity patterns, periodic re-verification of identity and contact information, and enhanced scrutiny for customers who exhibit unusual transaction patterns or other risk indicators.

7.3 Transaction Monitoring and Suspicious Activity Detection

RaffleGives employs sophisticated transaction monitoring systems designed to detect potentially suspicious activity patterns that may indicate money laundering, fraud, or other illicit activities. These systems utilize both automated detection algorithms and manual review procedures to ensure comprehensive coverage of potential risks.

Automated monitoring systems analyze transaction patterns in real-time and generate alerts based on predetermined criteria including: (a) velocity monitoring to detect unusually rapid or frequent transactions, (b) threshold monitoring for transactions exceeding specified dollar amounts or frequency limits, (c) pattern recognition to identify unusual spending behaviors or transaction characteristics, (d) geographic analysis to detect transactions from unexpected or high-risk locations, and (e) relationship analysis to identify potential connections between seemingly unrelated accounts or transactions.

Specific monitoring scenarios include: (a) rapid succession of large ticket purchases followed by immediate account closure or inactivity, (b) purchases using multiple payment methods or cards in short time periods, (c) transactions from IP addresses or locations inconsistent with registered address information, (d) unusual patterns of winning and losing that may indicate manipulation or collusion, (e) transactions involving known high-risk payment methods or financial institutions, and (f) activity patterns consistent with structuring or other evasion techniques.

Manual review procedures are conducted by trained compliance personnel who investigate alerts generated by automated systems, conduct additional research using internal and external databases, document findings and recommendations in compliance case management systems, and escalate suspicious activities for potential suspicious activity report (SAR) filing.

Enhanced monitoring may be applied to high-risk customers or transactions, including: (a) real-time review of all transactions above specified thresholds, (b) additional verification requirements for unusual transaction patterns, (c) temporary holds or restrictions pending completion of enhanced due diligence, and (d) ongoing monitoring for specified periods following suspicious activity investigations.

Transaction monitoring systems are regularly tested and calibrated to ensure effectiveness, minimize false positives while maintaining comprehensive coverage of potential risks, and adapt to evolving money laundering and fraud techniques. System parameters are reviewed and updated based on regulatory guidance, industry best practices, and internal risk assessments.

7.4 Sanctions Screening and Prohibited Persons Lists

RaffleGives maintains comprehensive sanctions screening procedures designed to prevent transactions with individuals and entities subject to economic sanctions, trade restrictions, or other legal prohibitions. These procedures comply with requirements established by the Office of Foreign Assets Control (OFAC), international sanctions regimes, and other applicable legal authorities.

Sanctions screening is conducted at multiple points including: (a) initial account registration and identity verification, (b) real-time screening of all transactions and payment processing, (c) periodic batch screening of all active accounts against updated sanctions lists, (d) enhanced screening for high-risk customers or transactions, and (e) immediate screening when new sanctions designations are announced.

Screening databases include: (a) OFAC Specially Designated Nationals (SDN) list and other OFAC sanctions programs, (b) United Nations Security Council consolidated sanctions list, (c) European Union sanctions lists and other international sanctions regimes, (d) politically exposed persons (PEP) databases and adverse media screening, (e) law enforcement and regulatory exclusion lists, and (f) internal watchlists based on previous suspicious activity or risk assessments.

Screening procedures utilize sophisticated name-matching algorithms that account for variations in spelling, transliteration, and cultural naming conventions while minimizing false positive matches that could disrupt legitimate transactions. Manual review procedures are employed for potential matches to determine whether true matches exist and what actions are required.

When potential sanctions matches are identified, immediate actions include: (a) blocking or freezing the transaction or account pending investigation, (b) conducting enhanced due diligence to confirm or rule out the match, (c) reporting confirmed matches to appropriate authorities as required by law, (d) maintaining detailed records of screening results and actions taken, and (e) implementing ongoing monitoring for any accounts that present elevated sanctions risks.

Sanctions compliance procedures are regularly updated to reflect changes in sanctions programs, new designations or removals from sanctions lists, and evolving regulatory guidance. Staff training ensures that all personnel understand sanctions requirements and know how to respond to potential matches or compliance issues.

7.5 Suspicious Activity Reporting and Law Enforcement Cooperation

RaffleGives maintains comprehensive procedures for identifying, investigating, and reporting suspicious activities that may indicate money laundering, terrorist financing, fraud, or other criminal activities. These procedures comply with FinCEN requirements for suspicious activity reporting and reflect best practices for cooperation with law enforcement and regulatory authorities.

Suspicious activity identification includes recognition of red flags and indicators such as: (a) transactions that appear to lack legitimate business purpose or economic rationale, (b) customers who provide false or suspicious identification information, (c) unusual transaction patterns that may indicate structuring or other evasion techniques, (d) transactions involving known high-risk jurisdictions or sanctioned persons, (e) activities that appear designed to avoid reporting or record-keeping requirements, and (f) transactions that may be related to other known criminal activities.

Investigation procedures include: (a) comprehensive review of customer account history and transaction patterns, (b) analysis of available internal and external information sources, (c) consultation with law enforcement databases and public records, (d) coordination with payment processors and other financial institutions where appropriate, (e) documentation of all investigative steps and findings, and (f) determination of whether suspicious activity reporting is required.

Suspicious Activity Report (SAR) filing procedures ensure timely and accurate reporting to FinCEN when required, including: (a) filing within thirty (30) days of initial detection of suspicious activity, (b) inclusion of all required information and supporting documentation, (c) coordination with law enforcement agencies when criminal activity is suspected, (d) maintenance of strict confidentiality regarding SAR filings, and (e) ongoing monitoring for additional suspicious activity by the same customer or related parties.

Law enforcement cooperation includes: (a) responding promptly to lawful requests for information or assistance, (b) providing testimony or documentation in criminal or civil proceedings when required, (c) coordinating with regulatory examinations and investigations, (d) implementing account restrictions or other measures when requested by law enforcement, and (e) maintaining appropriate records of all law enforcement interactions and requests.

Confidentiality requirements ensure that information about suspicious activity investigations and SAR filings is strictly protected and disclosed only as required by law or authorized by appropriate legal process. Staff training emphasizes the importance of confidentiality and the legal prohibitions against disclosing SAR-related information to customers or unauthorized persons.

7.6 Record-Keeping and Compliance Documentation

RaffleGives maintains comprehensive record-keeping procedures designed to support AML/KYC compliance, facilitate regulatory examinations, and provide necessary documentation for law enforcement investigations. These procedures comply with Bank Secrecy Act requirements and industry best practices for compliance documentation.

Customer records include: (a) all identification and verification documentation collected during account opening, (b) records of enhanced due diligence procedures and findings, (c) transaction history and monitoring results, (d) correspondence and communications with customers, (e) documentation of any suspicious activity investigations or reports, and (f) records of account closures and the reasons for closure.

Transaction records include: (a) detailed information about all payment transactions processed through the Platform, (b) documentation of transaction monitoring alerts and investigations, (c) records of any holds, restrictions, or other actions taken on transactions, (d) correspondence with payment processors and financial institutions, and (e) documentation of any chargebacks, disputes, or other transaction-related issues.

Compliance program records include: (a) written policies and procedures and all updates or revisions, (b) training records for all staff members involved in compliance activities, (c) audit and testing reports and corrective action plans, (d) regulatory correspondence and examination reports, (e) suspicious activity reports and supporting documentation, and (f) records of law enforcement cooperation and information requests.

Record retention periods comply with regulatory requirements and include: (a) customer identification and verification records retained for five (5) years after account closure, (b) transaction records retained for five (5) years after the transaction date, (c) suspicious activity reports and supporting documentation retained for five (5) years after filing, (d) compliance program documentation retained for five (5) years after supersession or revision, and (e) law enforcement correspondence retained permanently or as directed by legal counsel.

Electronic record-keeping systems include appropriate security measures to prevent unauthorized access, alteration, or destruction of compliance records, backup and disaster recovery procedures to ensure record preservation, audit trails to track access and modifications to compliance records, and search and retrieval capabilities to support regulatory examinations and law enforcement requests.

Access controls ensure that compliance records are available only to authorized personnel with legitimate business needs, with all access logged and monitored for security purposes. Regular reviews of access permissions ensure that former employees and contractors cannot access compliance records after their employment or engagement ends.

Part VIII – Fraud Prevention & Technical Security Controls

8.1 Comprehensive Fraud Prevention Framework

RaffleGives employs a multi-layered fraud prevention framework designed to protect participants, Nonprofits, and payment processors from various forms of fraudulent activity while maintaining a positive user experience for legitimate participants. This framework combines advanced technology solutions, human expertise, and industry best practices to create a robust defense against evolving fraud threats.

The fraud prevention framework addresses multiple categories of potential fraud including: (a) identity theft and synthetic identity fraud where criminals use stolen or fabricated personal information to create accounts, (b) payment fraud involving stolen credit cards, account takeover, or other unauthorized payment methods, (c) promotional abuse where individuals attempt to exploit system vulnerabilities or promotional offers, (d) collusion and insider fraud involving coordination between multiple parties to manipulate raffle outcomes, and (e) money laundering schemes that attempt to use raffle activities to obscure the source of illicit funds.

Risk-based authentication procedures evaluate multiple factors to assess the legitimacy of each user and transaction, including: (a) device fingerprinting to identify unique characteristics of computers and mobile devices, (b) behavioral biometrics that analyze typing patterns, mouse movements, and other user behaviors, (c) geolocation analysis to verify that users are accessing the Platform from expected locations, (d) velocity checks that monitor the frequency and volume of transactions, and (e) pattern recognition algorithms that identify unusual or suspicious activity patterns.

Real-time fraud scoring systems assign risk scores to all users and transactions based on hundreds of data points and risk factors, enabling automated decision-making for low-risk activities while flagging high-risk situations for manual review. These systems are continuously updated based on new fraud patterns, false positive analysis, and feedback from fraud investigators.

Machine learning and artificial intelligence technologies enhance fraud detection capabilities by identifying subtle patterns and correlations that may not be apparent through traditional rule-based systems. These technologies adapt to new fraud techniques and improve detection accuracy over time while reducing false positives that could impact legitimate users.

8.2 Identity Verification, Authentication, and SMS Verification

RaffleGives may require users to complete identity verification, account authentication, or security verification before accessing certain Platform features, creating or managing an account, participating in certain transactions, receiving payouts, administering raffles, or taking other actions that RaffleGives determines may require additional security review.

To protect users, nonprofit organizations, donors, participants, and the integrity of the Platform, RaffleGives may use one or more verification methods, including account credentials, email verification, SMS-based one-time passcodes, device verification, manual review, document review, payment verification, fraud-screening tools, and other commercially reasonable security procedures.

SMS Verification and One-Time Passcodes

RaffleGives may send SMS messages to users who request account verification, login verification, account recovery, or account-security verification. These messages are transactional in nature and are limited to one-time passcodes, security codes, account-verification notices, and account-recovery notices.

Users receive SMS verification messages only after entering their mobile phone number on the RaffleGives website or application and requesting a verification code. By clicking “Send Verification Code,” “Verify by SMS,” or a similar button, the user agrees to receive a one-time SMS verification code from RaffleGives at the mobile number provided.

Message frequency varies and is limited to user-requested account verification and security messages. Message and data rates may apply. Users may reply STOP to opt out of receiving SMS messages or HELP for help. Users may also contact RaffleGives support through the contact information provided on the RaffleGives website.

RaffleGives does not send marketing, promotional, fundraising, raffle-entry, or solicitation SMS messages under its SMS verification program. Consent to receive SMS verification messages is not a condition of purchase.

RaffleGives does not sell, rent, share, or disclose mobile phone numbers, SMS opt-in data, or SMS consent information with third parties or affiliates for their marketing or promotional purposes.

Fraud Prevention and Security Review

RaffleGives may monitor account activity, login behavior, device information, IP address information, transaction activity, and other Platform usage data to detect suspected fraud, account misuse, unauthorized access, identity theft, payment abuse, regulatory violations, or other suspicious activity.

RaffleGives may require additional verification before allowing high-risk activity, including but not limited to account changes, payout requests, administrative access, changes to organization information, suspicious login activity, or other actions that RaffleGives determines may present increased risk.

If RaffleGives is unable to verify a user’s identity, account authority, payment information, eligibility, or compliance with applicable laws or Platform requirements, RaffleGives may delay, restrict, suspend, or terminate access to the Platform, withhold or delay certain transactions, require additional documentation, or take other actions reasonably necessary to protect the Platform and its users.

Users are responsible for providing accurate, current, and complete information when creating an account, requesting verification, participating in Platform activities, or responding to security or compliance requests. Users may not impersonate another person, use false information, create unauthorized accounts, or attempt to bypass RaffleGives’ identity verification, authentication, fraud-prevention, or security controls.

8.3 Transaction Monitoring and Anomaly Detection

Sophisticated transaction monitoring systems analyze all Platform activities in real-time to identify potentially fraudulent transactions, unusual patterns, or other activities that may indicate fraud or abuse. These systems utilize both automated algorithms and human expertise to ensure comprehensive coverage while minimizing disruption to legitimate users.

Velocity monitoring tracks the frequency and volume of transactions across multiple dimensions including: (a) individual user transaction patterns over various time periods, (b) payment method usage patterns to detect potential card testing or other payment fraud, (c) device-based transaction patterns to identify potential bot activity or automated fraud, (d) geographic transaction patterns to detect unusual location-based activity, and (e) cross-account patterns that may indicate coordinated fraud schemes.

Behavioral analysis systems establish baseline patterns for individual users and identify deviations that may indicate account compromise, fraud, or other suspicious activity. These systems consider factors such as typical transaction amounts and timing, preferred payment methods, device and location patterns, and interaction behaviors with the Platform.

Payment fraud detection specifically targets credit card fraud, account takeover, and other payment-related fraud through: (a) real-time authorization monitoring to detect declined transactions and retry patterns, (b) BIN (Bank Identification Number) analysis to identify high-risk card types or issuing banks, (c) CVV and AVS (Address Verification Service) mismatch analysis, (d) chargeback and dispute pattern analysis, and (e) coordination with payment processor fraud detection systems.

Network analysis identifies potential fraud rings or coordinated attacks by analyzing relationships between accounts, devices, payment methods, and other data points. This analysis can reveal hidden connections between seemingly unrelated accounts that may indicate organized fraud schemes.

Threshold-based monitoring automatically flags transactions or activities that exceed predetermined risk thresholds, including: (a) transaction amounts that exceed typical patterns for individual users or the Platform overall, (b) frequency of transactions that may indicate automated or abusive behavior, (c) geographic anomalies such as transactions from unexpected locations, and (d) time-based anomalies such as activity during unusual hours or patterns.

8.4 Device and Network Security Measures

Comprehensive device and network security measures protect the Platform infrastructure and user data from cyber attacks, unauthorized access, and other security threats. These measures are continuously updated to address evolving threat landscapes and maintain the highest levels of security for all Platform operations.

Device fingerprinting technology creates unique identifiers for computers, mobile devices, and other endpoints accessing the Platform, enabling detection of suspicious device patterns, identification of devices associated with previous fraud attempts, tracking of device reputation over time, and detection of device spoofing or emulation attempts.

Network security controls include: (a) distributed denial of service (DDoS) protection to maintain Platform availability during attacks, (b) web application firewalls (WAF) to filter malicious traffic and protect against common web-based attacks, (c) intrusion detection and prevention systems (IDS/IPS) to monitor for and block suspicious network activity, (d) network segmentation to isolate critical systems and limit the impact of potential breaches, and (e) regular vulnerability assessments and penetration testing to identify and address security weaknesses.

Bot detection and mitigation systems identify and block automated traffic that may be used for fraud, abuse, or other malicious purposes. These systems analyze traffic patterns, behavioral characteristics, and technical indicators to distinguish between legitimate human users and automated bots.

Encryption and data protection measures ensure that all sensitive information is protected both in transit and at rest, including: (a) TLS encryption for all data transmitted between users and Platform systems, (b) strong encryption for sensitive data stored in databases and file systems, (c) secure key management practices to protect encryption keys, (d) tokenization of payment card information to reduce the scope of sensitive data storage, and (e) secure deletion procedures for data that is no longer needed.

API security controls protect the Platform's application programming interfaces from abuse, unauthorized access, and other security threats through: (a) authentication and authorization controls for all API access, (b) rate limiting to prevent abuse and ensure fair usage, (c) input validation and sanitization to prevent injection attacks, (d) logging and monitoring of all API usage, and (e) regular security assessments of API endpoints and functionality.

8.5 Chargeback Prevention and Management

Effective chargeback prevention and management procedures protect Nonprofits, payment processors, and the Platform from the financial and operational impacts of payment disputes while ensuring that legitimate disputes are resolved fairly and efficiently. These procedures address both fraudulent chargebacks and legitimate disputes arising from customer service issues.

Chargeback prevention strategies include: (a) clear and accurate transaction descriptors that help cardholders recognize legitimate charges, (b) proactive customer communication about transaction processing and timing, (c) responsive customer service to resolve issues before they escalate to chargebacks, (d) fraud prevention measures that reduce the likelihood of unauthorized transactions, and (e) comprehensive transaction documentation to support dispute resolution efforts.

The chargeback reserve system maintains five percent (5%) of gross proceeds in segregated accounts for twelve (12) months to cover potential chargebacks and related costs. This reserve system protects Nonprofits from the immediate financial impact of chargebacks while ensuring that funds are available to resolve legitimate disputes.

Chargeback monitoring and alerting systems track chargeback rates and patterns across the Platform, individual Nonprofits, and payment processors to identify trends that may require intervention. Early warning systems alert relevant parties when chargeback rates approach thresholds that could result in penalties or account restrictions from payment processors.

Dispute response procedures ensure that all chargebacks are addressed promptly and effectively, including: (a) immediate notification of relevant parties when chargebacks are received, (b) comprehensive evidence gathering to support dispute responses, (c) coordination with payment processors and card networks throughout the dispute process, (d) tracking of dispute outcomes and success rates, and (e) analysis of dispute patterns to identify opportunities for prevention.

Representment strategies for fighting illegitimate chargebacks include: (a) compilation of comprehensive evidence packages including transaction records, customer communications, and fraud prevention data, (b) coordination with specialized chargeback management services where appropriate, (c) tracking of representment success rates and adjustment of strategies based on outcomes, and (d) escalation to pre-arbitration and arbitration processes when justified by the evidence and potential recovery amounts.

8.6 Incident Response and Recovery Procedures

Comprehensive incident response procedures ensure that security incidents, fraud attempts, and other threats are detected quickly, contained effectively, and resolved with minimal impact on Platform operations and user experience. These procedures are regularly tested and updated to address evolving threat landscapes and operational requirements.

Incident detection capabilities include: (a) automated monitoring systems that generate alerts for suspicious activities or security events, (b) user reporting mechanisms for suspected fraud or security issues, (c) coordination with payment processors and other partners who may detect relevant incidents, (d) threat intelligence feeds that provide information about emerging threats and attack patterns, and (e) regular security assessments that may identify ongoing or historical incidents.

Incident classification procedures categorize incidents based on severity, impact, and required response actions, including: (a) critical incidents that pose immediate threats to Platform security or user safety, (b) high-priority incidents that require urgent attention but do not pose immediate threats, (c) medium-priority incidents that require investigation and response within defined timeframes, and (d) low-priority incidents that can be addressed through routine procedures.

Response team activation procedures ensure that appropriate personnel are notified and engaged based on incident classification and requirements, including: (a) immediate notification of senior management for critical incidents, (b) engagement of technical specialists for security-related incidents, (c) coordination with legal counsel for incidents involving potential criminal activity, (d) communication with regulatory authorities when required by law or regulation, and (e) coordination with law enforcement agencies when criminal activity is suspected.

Containment and mitigation procedures limit the impact of incidents and prevent further damage, including: (a) immediate isolation of affected systems or accounts, (b) implementation of additional security controls to prevent incident escalation, (c) preservation of evidence for investigation and potential legal proceedings, (d) communication with affected users when appropriate and legally permissible, and (e) coordination with external partners such as payment processors when their systems or processes are affected.

Recovery and restoration procedures return Platform operations to normal while implementing lessons learned to prevent similar incidents, including: (a) systematic restoration of affected systems and services, (b) validation of system integrity and security before returning to normal operations, (c) implementation of additional security measures based on incident analysis, (d) documentation of incident response actions and outcomes, and (e) post-incident review and improvement of response procedures.

Part IX – Payment Processor Compliance Framework

9.1 Multi-Processor Compliance Strategy and Risk Management

RaffleGives maintains a comprehensive compliance framework designed to meet the requirements of multiple payment processors simultaneously, ensuring operational flexibility while maintaining the highest standards of regulatory compliance and risk management. This multi-processor approach provides redundancy, competitive pricing, and specialized capabilities while distributing risk across multiple processing relationships.

The primary payment processors utilized by the Platform include Stripe Connect, Braintree Marketplace (a PayPal company), and Authorize.net sub-merchant programs, each of which has been specifically approved for charitable gaming transactions and maintains appropriate licenses and certifications for processing payments in regulated industries. Additional processors may be integrated based on specific Nonprofit needs, geographic requirements, or specialized capabilities.

Processor-specific compliance requirements are carefully analyzed and implemented to ensure that all Platform operations meet or exceed the standards established by each processor. This includes adherence to acceptable use policies, implementation of required fraud prevention measures, maintenance of appropriate reserve levels, compliance with reporting and documentation requirements, and coordination with processor risk management and compliance teams.

Risk distribution strategies ensure that no single processor relationship creates undue operational risk for the Platform or its Nonprofit clients. This includes diversification of transaction volume across multiple processors, maintenance of backup processing capabilities in case of service disruptions, regular assessment of processor financial stability and regulatory standing, and development of contingency plans for processor relationship changes.

Compliance monitoring and reporting procedures ensure ongoing adherence to all processor requirements, including regular review of transaction patterns and risk metrics, proactive communication with processor compliance teams, implementation of recommended risk mitigation measures, and maintenance of comprehensive documentation to support processor audits and reviews.

9.2 PayPal and Braintree Compliance Requirements

PayPal's Acceptable Use Policy and Braintree's processing requirements establish specific standards for charitable gaming activities that must be met to maintain processing privileges. These requirements reflect PayPal's position as a leading payment processor with conservative risk management policies and extensive regulatory oversight.

Charitable organization verification requirements include confirmation of current 501(c)(3) tax-exempt status, verification of legal authority to conduct charitable gaming activities, review of organizational governance and financial stability, and ongoing monitoring of charitable organization compliance with applicable laws and regulations. PayPal may require additional documentation or verification procedures based on specific risk factors or regulatory requirements.

Pre-approval requirements for charitable gaming activities mandate that all raffle operations be specifically approved by PayPal before processing can commence. This pre-approval process includes review of raffle structures and procedures, assessment of compliance with applicable laws and regulations, evaluation of risk management and fraud prevention measures, and establishment of appropriate monitoring and reporting procedures.

Geographic restrictions limit charitable gaming processing to specific jurisdictions where PayPal has determined that such activities can be conducted in compliance with applicable laws and regulations. Currently, this includes the United States (with state-specific restrictions), Canada, the United Kingdom, and select other jurisdictions where charitable gaming is clearly regulated and permitted.

Transaction monitoring and reporting requirements include real-time monitoring of all gaming-related transactions, regular reporting of transaction volumes and patterns to PayPal compliance teams, immediate notification of any suspicious activities or compliance concerns, and maintenance of comprehensive records to support PayPal audits and regulatory examinations.

Reserve and settlement requirements may include enhanced reserve levels for charitable gaming transactions, extended settlement periods to allow for additional risk assessment, and specific procedures for handling chargebacks and disputes related to gaming activities. These requirements are designed to protect PayPal from the elevated risks associated with gaming transactions while ensuring that legitimate transactions are processed efficiently.

9.3 Stripe Connect Marketplace Compliance Standards

Stripe's approach to charitable gaming processing emphasizes transparency, compliance, and risk management through their Connect marketplace platform, which enables RaffleGives to facilitate payments while maintaining appropriate oversight and control over transaction processing. Stripe's requirements reflect their position as a technology-forward processor with sophisticated risk management capabilities.

Marketplace operator responsibilities include comprehensive due diligence on all connected Nonprofit accounts, ongoing monitoring of transaction patterns and risk indicators, implementation of appropriate fraud prevention and compliance measures, maintenance of accurate records and reporting capabilities, and coordination with Stripe's risk and compliance teams on all gaming-related activities.

Connected account requirements mandate that each Nonprofit maintain a separate Stripe account with appropriate verification and documentation, including confirmation of tax-exempt status, verification of legal authority for gaming activities, completion of enhanced due diligence procedures, and ongoing compliance with Stripe's terms of service and acceptable use policies.

Charitable gaming specific requirements include clear disclosure of the charitable nature of all raffle activities, appropriate geographic restrictions to ensure compliance with applicable laws, implementation of age verification and eligibility controls, maintenance of transparent prize structures and distribution procedures, and compliance with all applicable gaming regulations and licensing requirements.

Risk management and monitoring procedures include real-time transaction monitoring for unusual patterns or potential fraud, regular assessment of chargeback rates and dispute patterns, implementation of appropriate reserve levels based on risk assessment, and coordination with Stripe's machine learning and fraud detection systems to optimize risk management effectiveness.

Compliance reporting and documentation requirements include regular reporting of gaming activity volumes and patterns, maintenance of comprehensive audit trails for all transactions and activities, coordination with regulatory examinations and audits, and implementation of any additional controls or procedures recommended by Stripe's compliance team.

9.4 Authorize.net Gateway Integration and Compliance

Authorize.net's approach to charitable gaming processing focuses on providing gateway services while relying on underlying merchant account providers to establish appropriate risk management and compliance controls. This structure provides flexibility in merchant account selection while maintaining consistent gateway functionality and security standards.

Gateway service requirements include implementation of appropriate security measures for payment card data handling, compliance with PCI-DSS requirements for secure payment processing, integration with fraud detection and prevention systems, maintenance of appropriate transaction logging and reporting capabilities, and coordination with merchant account providers on risk management and compliance matters.

Merchant account provider coordination ensures that underlying merchant accounts are appropriate for charitable gaming activities and maintain necessary licenses and approvals. This includes verification that merchant account providers understand and approve gaming activities, confirmation of appropriate risk management and reserve requirements, and ongoing coordination on compliance and risk management matters.

Technical integration requirements include secure API implementation with appropriate authentication and authorization controls, proper handling of sensitive payment card information through tokenization and encryption, implementation of appropriate fraud prevention and risk management tools, and maintenance of comprehensive logging and audit trails for all gateway activities.

Compliance monitoring and reporting procedures include regular review of transaction patterns and risk metrics, coordination with merchant account providers on compliance matters, implementation of any additional controls recommended by Authorize.net or merchant account providers, and maintenance of appropriate documentation to support audits and regulatory examinations.

Backup and redundancy planning ensures that gateway services remain available even in case of technical issues or service disruptions, including implementation of failover procedures, maintenance of backup processing capabilities, and coordination with merchant account providers on business continuity planning.

9.5 PCI-DSS Compliance and Payment Security Standards

Payment Card Industry Data Security Standard (PCI-DSS) compliance is mandatory for all payment processing activities and represents a fundamental requirement for maintaining payment processor relationships. RaffleGives maintains Level 1 PCI-DSS compliance through a combination of technical controls, operational procedures, and third-party validation.

Secure payment processing architecture ensures that sensitive payment card information is never stored on RaffleGives systems, with all payment data handled through PCI-compliant tokenization services provided by payment processors. This approach minimizes the scope of PCI compliance requirements while maintaining the highest levels of payment security.

Network security controls include implementation of firewalls and network segmentation to protect payment processing systems, regular vulnerability assessments and penetration testing of all systems handling payment data, encryption of all payment card data in transit and at rest, and implementation of strong access controls and authentication mechanisms for all systems.

Operational security procedures include comprehensive background checks for all personnel with access to payment systems, regular security training and awareness programs for all staff, implementation of incident response procedures for security breaches or suspected compromises, and maintenance of comprehensive audit logs for all payment processing activities.

Third-party validation includes annual PCI-DSS assessments by qualified security assessors (QSAs), regular vulnerability scans by approved scanning vendors (ASVs), and ongoing monitoring and validation of security controls and procedures. All validation reports and certificates are maintained and provided to payment processors as required.

Continuous compliance monitoring includes regular review of security controls and procedures, implementation of security updates and patches for all systems, ongoing monitoring for security threats and vulnerabilities, and coordination with payment processors on security matters and incident response.

9.6 Chargeback Management and Processor Relations

Effective chargeback management is critical for maintaining positive relationships with payment processors and ensuring continued processing privileges. RaffleGives implements comprehensive chargeback prevention and management procedures designed to minimize chargeback rates while ensuring fair resolution of legitimate disputes.

Chargeback prevention strategies include clear and accurate transaction descriptors that help cardholders recognize legitimate charges, proactive customer communication about transaction processing and settlement timing, responsive customer service to resolve issues before they escalate to chargebacks, and comprehensive fraud prevention measures to reduce unauthorized transactions.

Early warning systems monitor chargeback rates across all processors and provide alerts when rates approach thresholds that could result in penalties or account restrictions. These systems enable proactive intervention to address chargeback trends before they impact processor relationships.

Dispute response procedures ensure that all chargebacks are addressed promptly and effectively, including immediate notification of relevant parties, comprehensive evidence gathering to support dispute responses, coordination with specialized chargeback management services where appropriate, and tracking of dispute outcomes to identify opportunities for improvement.

Processor communication and relationship management includes regular communication with processor risk and compliance teams, proactive reporting of any issues or concerns that may affect processing relationships, coordination on risk management and fraud prevention initiatives, and participation in processor training and education programs.

Reserve management procedures ensure that appropriate funds are maintained to cover chargeback and dispute costs, including the standard five percent (5%) chargeback reserve held for twelve months, additional reserves that may be required by specific processors based on risk assessment, and coordination with Nonprofits on reserve requirements and settlement procedures.

Performance monitoring and optimization includes regular analysis of processing performance metrics, identification of opportunities to improve approval rates and reduce processing costs, coordination with processors on system optimizations and enhancements, and evaluation of new processing technologies and capabilities that may benefit Platform operations.

Part X – Regulatory Compliance & Legal Framework

10.1 Nevada Gaming Law Compliance and Licensing Requirements

All charitable raffle activities conducted through the RaffleGives Platform operate under the authority of Nevada Revised Statutes Chapter 462 and Nevada Gaming Commission Regulation 4A, which establish the comprehensive legal framework for charitable gaming activities in Nevada. Compliance with these requirements is mandatory for all participating Nonprofits and forms the foundation of the Platform's regulatory compliance program.

Nevada Revised Statutes Chapter 462 establishes the fundamental legal authority for charitable gaming activities, including specific requirements for eligible organizations, permissible gaming activities, prize structures and limitations, record-keeping and reporting obligations, and regulatory oversight and enforcement procedures. These statutes provide the primary legal framework within which all Platform activities must operate.

Nevada Gaming Commission Regulation 4A provides detailed implementing regulations that specify operational requirements for charitable gaming activities, including licensing and registration procedures for charitable organizations, technical standards for gaming equipment and procedures, financial controls and reporting requirements, advertising and marketing restrictions, and audit and examination procedures.

Charitable organization licensing requirements mandate that all Nonprofits conducting raffles through the Platform maintain appropriate licenses and registrations with Nevada gaming authorities. This includes initial licensing applications with comprehensive background checks and financial reviews, annual license renewals with updated documentation and compliance certifications, and ongoing compliance with all licensing conditions and requirements.

Operational compliance requirements include adherence to specific procedures for raffle operations, including ticket sales and distribution procedures, drawing and winner selection protocols, prize payment and tax reporting obligations, record-keeping and documentation requirements, and reporting and audit compliance procedures.

Regulatory oversight and examination procedures ensure ongoing compliance with all applicable requirements through regular examinations by Nevada gaming authorities, investigation of complaints or suspected violations, coordination with law enforcement agencies on criminal matters, and implementation of corrective actions for any identified deficiencies.

10.2 Federal Tax and Reporting Compliance

Charitable raffle activities are subject to comprehensive federal tax and reporting requirements that apply to both the operating Nonprofits and individual participants. RaffleGives provides tools and support to assist with compliance but does not provide tax advice, and all parties are responsible for ensuring their own compliance with applicable tax obligations.

Nonprofit tax obligations include reporting of gaming revenue and expenses on annual Form 990 filings, compliance with unrelated business income tax (UBIT) requirements where applicable, proper classification and reporting of gaming activities versus other fundraising activities, and maintenance of appropriate documentation to support tax reporting and potential IRS examinations.

Prize winner tax obligations include reporting of prize winnings as taxable income on individual tax returns, compliance with estimated tax payment requirements for large prizes, and coordination with Nonprofits on tax withholding and reporting procedures. Winners are strongly advised to consult with qualified tax professionals regarding their specific obligations.

Tax withholding and reporting requirements mandate that Nonprofits withhold appropriate federal and state taxes from prize payments exceeding specified thresholds, issue Form W-2G or other appropriate tax reporting forms to prize winners, and submit required reports to tax authorities. The Platform provides tools to assist with these requirements but does not assume responsibility for tax compliance.

Information reporting requirements include maintenance of comprehensive records regarding all gaming activities, including participant information, transaction details, prize payments, and tax withholding. These records must be available for review by tax authorities and maintained for the periods specified in applicable regulations.

International tax considerations may apply to participants from foreign countries, including potential withholding tax obligations, treaty benefits that may reduce tax obligations, and reporting requirements under various international tax agreements. Such situations require specialized tax advice and may result in additional compliance obligations.

10.3 Anti-Money Laundering and Financial Crimes Compliance

RaffleGives operates under comprehensive anti-money laundering (AML) and financial crimes compliance requirements established by the Bank Secrecy Act, FinCEN regulations, and related federal and state laws. These requirements reflect the elevated compliance obligations applicable to organizations facilitating financial transactions in regulated industries.

Bank Secrecy Act compliance includes implementation of comprehensive customer identification and verification procedures, maintenance of appropriate records regarding all financial transactions, reporting of suspicious activities to FinCEN through Suspicious Activity Reports (SARs), and compliance with currency transaction reporting requirements where applicable.

FinCEN regulations establish specific requirements for money services businesses and other financial institutions, including registration and licensing requirements where applicable, implementation of anti-money laundering programs with appropriate policies and procedures, designation of compliance officers with appropriate authority and independence, and regular training and testing to ensure program effectiveness.

Customer due diligence requirements mandate comprehensive verification of customer identity and assessment of money laundering risks, including enhanced due diligence for high-risk customers or transactions, ongoing monitoring of customer activities for suspicious patterns, and maintenance of current customer information and risk assessments.

Suspicious activity monitoring and reporting procedures ensure that potential money laundering, terrorist financing, or other financial crimes are detected and reported appropriately, including implementation of automated monitoring systems, investigation of suspicious activity alerts, filing of SARs when required, and coordination with law enforcement agencies on criminal investigations.

Sanctions compliance requirements include screening of all customers and transactions against applicable sanctions lists, including OFAC Specially Designated Nationals (SDN) list and other sanctions programs, implementation of blocking and reporting procedures for sanctions matches, and ongoing monitoring for changes in sanctions designations and requirements.

10.4 Consumer Protection and Fair Gaming Standards

Consumer protection requirements ensure that all raffle participants are treated fairly and that raffle operations meet appropriate standards for transparency, honesty, and consumer protection. These requirements reflect both legal mandates and industry best practices for consumer-facing gaming activities.

Truth in advertising requirements mandate that all marketing and promotional materials provide accurate and complete information about raffle terms and conditions, including clear disclosure of eligibility requirements, prize structures and odds of winning, drawing dates and procedures, and any restrictions or limitations that may apply to participation or prize claims.

Fair gaming standards ensure that all raffles are conducted in a manner that provides equal opportunities for all eligible participants, including use of certified random number generation systems for winner selection, implementation of appropriate security measures to prevent manipulation or fraud, and maintenance of comprehensive audit trails to verify the integrity of all raffle operations.

Dispute resolution procedures provide fair and efficient mechanisms for resolving participant complaints and disputes, including clear procedures for submitting complaints, investigation and resolution of disputes by qualified personnel, escalation procedures for unresolved disputes, and coordination with regulatory authorities when appropriate.

Consumer privacy and data protection requirements ensure that participant personal information is collected, used, and protected in accordance with applicable privacy laws and industry standards, including implementation of appropriate security measures, provision of clear privacy notices and consent mechanisms, and compliance with individual rights regarding personal information.

Responsible gaming measures help ensure that raffle participation remains appropriate and does not contribute to problem gambling behaviors, including provision of information about responsible gaming resources, implementation of self-exclusion mechanisms where appropriate, and monitoring for signs of problem gambling behavior.

10.5 Interstate and International Compliance Considerations

While RaffleGives operates primarily under Nevada law and restricts participation to Nevada residents, various interstate and international compliance considerations may apply to Platform operations, particularly regarding marketing activities, data protection, and coordination with other jurisdictions.

Interstate commerce regulations may apply to certain Platform activities, including marketing and advertising that may reach residents of other states, coordination with Nonprofits that may have operations in multiple states, and compliance with federal laws that govern interstate gaming and commerce activities.

International data protection requirements, including the European Union's General Data Protection Regulation (GDPR), may apply to Platform operations even when direct participation is restricted to Nevada residents. This includes compliance with data protection requirements for any international visitors to Platform websites, implementation of appropriate privacy controls and consent mechanisms, and coordination with international regulatory authorities when required.

Cross-border payment processing considerations may arise when payment processors or other service providers operate across international boundaries, including compliance with international sanctions and export control requirements, coordination with foreign regulatory authorities on compliance matters, and implementation of appropriate controls for international data transfers.

Tribal gaming coordination may be required when Platform activities intersect with tribal gaming operations or when Nonprofits operate on tribal lands, including compliance with tribal gaming regulations and compacts, coordination with tribal gaming authorities, and respect for tribal sovereignty and regulatory authority.

Federal preemption issues may arise when state and federal laws conflict or when federal agencies assert jurisdiction over Platform activities, including coordination with federal regulatory authorities, compliance with federal gaming and financial services regulations, and resolution of jurisdictional conflicts between state and federal authorities.

10.6 Regulatory Examination and Audit Procedures

RaffleGives maintains comprehensive procedures for regulatory examinations and audits to ensure ongoing compliance with all applicable requirements and to demonstrate transparency and accountability to regulatory authorities. These procedures reflect best practices for regulated industries and are designed to facilitate effective regulatory oversight.

Examination preparation procedures ensure that all required documentation and records are maintained in an organized and accessible manner, including comprehensive policies and procedures documentation, transaction records and audit trails, compliance monitoring and testing reports, and correspondence with regulatory authorities and other stakeholders.

Regulatory cooperation procedures ensure prompt and complete responses to all regulatory inquiries and examination requests, including designation of appropriate personnel to coordinate with examiners, provision of requested documentation and information in a timely manner, and coordination with legal counsel and other advisors as appropriate.

Audit support services include coordination with independent auditors and compliance consultants, provision of necessary documentation and access to systems and personnel, and implementation of audit recommendations and corrective actions as appropriate.

Corrective action procedures ensure that any deficiencies identified through examinations or audits are addressed promptly and effectively, including development of corrective action plans with specific timelines and responsibilities, implementation of enhanced controls and procedures as necessary, and ongoing monitoring to ensure that corrective actions are effective.

Regulatory reporting requirements include submission of required periodic reports to gaming and other regulatory authorities, notification of material changes in operations or compliance status, and coordination with regulatory authorities on policy developments and regulatory changes that may affect Platform operations.

Continuous improvement procedures ensure that regulatory compliance programs are regularly updated and enhanced based on examination findings, regulatory developments, and industry best practices, including regular review and updating of policies and procedures, implementation of enhanced controls and monitoring systems, and ongoing training and education for compliance personnel.

Part XI – Enforcement, Penalties & Dispute Resolution

11.1 Violation Detection and Investigation Procedures

RaffleGives maintains comprehensive procedures for detecting, investigating, and addressing violations of these Terms of Service, applicable laws and regulations, and Platform policies. These procedures are designed to ensure fair and consistent enforcement while protecting the rights of all parties and maintaining the integrity of raffle operations.

Automated monitoring systems continuously scan Platform activities for potential violations, including unusual transaction patterns that may indicate fraud or abuse, multiple account creation or other attempts to circumvent eligibility restrictions, geographic violations through IP address analysis and other technical measures, age verification failures or attempts to circumvent age restrictions, and payment fraud indicators such as declined transactions or chargeback patterns.

User reporting mechanisms enable participants, Nonprofits, and other stakeholders to report suspected violations or concerns, including dedicated reporting channels for different types of violations, anonymous reporting options where appropriate, and clear procedures for submitting reports with necessary supporting information.

Investigation procedures ensure that all reported or detected violations are thoroughly and fairly investigated, including assignment of qualified personnel to conduct investigations, collection and analysis of relevant evidence and documentation, interviews with affected parties and witnesses where appropriate, coordination with law enforcement or regulatory authorities when criminal activity is suspected, and documentation of all investigation activities and findings.

Due process protections ensure that all parties are treated fairly during investigation and enforcement procedures, including notification of suspected violations and opportunity to respond, access to relevant evidence and documentation, opportunity to present defenses or explanations, and right to appeal enforcement decisions through established procedures.

Coordination with external authorities includes reporting of suspected criminal activity to appropriate law enforcement agencies, cooperation with regulatory examinations and investigations, sharing of information with payment processors and other partners when required for risk management purposes, and compliance with legal process such as subpoenas and court orders.

11.2 Graduated Enforcement and Penalty Structure

RaffleGives employs a graduated enforcement approach that provides appropriate penalties based on the severity and frequency of violations while offering opportunities for correction and rehabilitation where appropriate. This approach balances the need for effective deterrence with fairness and proportionality in enforcement actions.

Warning and educational interventions are typically used for first-time or minor violations that do not pose significant risks to Platform integrity or other users, including written warnings that explain the violation and required corrective actions, educational materials about Platform policies and requirements, temporary restrictions on account activities pending completion of corrective actions, and enhanced monitoring to ensure compliance with corrective measures.

Account restrictions and suspensions may be imposed for more serious violations or repeated minor violations, including temporary suspension of account access or specific Platform features, restrictions on transaction amounts or frequency, requirements for additional verification or documentation before account restoration, and implementation of enhanced monitoring and compliance measures.

Account termination and permanent exclusion are reserved for the most serious violations or cases where other enforcement measures have proven ineffective, including immediate termination of account access and forfeiture of any pending transactions or winnings, permanent exclusion from Platform participation, reporting to relevant authorities and industry databases where appropriate, and pursuit of legal remedies for damages caused by violations.

Financial penalties and restitution may be imposed where violations result in financial harm to other parties, including forfeiture of winnings obtained through fraudulent or abusive activities, restitution to harmed parties for documented losses, recovery of costs associated with investigation and enforcement activities, and coordination with law enforcement on asset recovery where criminal activity is involved.

Regulatory reporting requirements mandate that certain violations be reported to appropriate regulatory authorities, including suspicious activities that may indicate money laundering or other financial crimes, violations of gaming laws or regulations, consumer protection violations that may require regulatory intervention, and coordination with regulatory enforcement actions where appropriate.

11.3 Appeal and Review Procedures

Fair and transparent appeal procedures ensure that enforcement decisions can be reviewed and corrected when appropriate while maintaining the integrity and efficiency of the enforcement process. These procedures provide multiple levels of review and incorporate appropriate due process protections.

Initial appeal procedures allow affected parties to request review of enforcement decisions within thirty (30) days of notification, including submission of written appeals with supporting documentation, review by personnel who were not involved in the initial enforcement decision, consideration of new evidence or circumstances that may affect the decision, and provision of written decisions with explanations of the basis for upholding or modifying enforcement actions.

Independent review procedures provide additional appeal opportunities for serious enforcement actions such as account termination or significant financial penalties, including review by independent arbitrators or hearing officers, opportunity for oral hearings where appropriate, representation by counsel or other advocates, and application of appropriate standards of evidence and burden of proof.

Expedited review procedures are available for time-sensitive matters such as account suspensions that may affect ongoing raffle participation, including emergency review processes for urgent situations, temporary relief pending completion of full review procedures, and coordination with Nonprofits and other affected parties to minimize disruption to legitimate activities.

Settlement and alternative dispute resolution options may be available for certain types of disputes, including mediation services to facilitate resolution of disputes between parties, settlement agreements that provide mutually acceptable resolutions, and coordination with external dispute resolution services where appropriate.

Final appeal procedures provide ultimate review authority for the most serious enforcement actions, including review by senior management or independent review panels, consideration of precedent and consistency with previous enforcement decisions, and implementation of policy changes or procedural improvements based on appeal outcomes.

11.4 Dispute Resolution Between Participants and Nonprofits

Disputes between raffle participants and operating Nonprofits are addressed through comprehensive dispute resolution procedures designed to provide fair, efficient, and cost-effective resolution while maintaining positive relationships and protecting the interests of all parties.

Initial dispute resolution procedures encourage direct communication between participants and Nonprofits to resolve disputes at the earliest possible stage, including clear contact information and procedures for submitting complaints, requirements for Nonprofits to respond promptly and professionally to participant concerns, documentation of all communications and resolution efforts, and escalation procedures when direct resolution is not successful.

Platform-mediated dispute resolution services provide neutral assistance when direct resolution efforts are unsuccessful, including review of dispute circumstances and applicable terms and conditions, facilitation of communication between parties, recommendation of appropriate resolution approaches, and coordination with external mediation services where appropriate.

Formal complaint procedures provide structured processes for resolving disputes that cannot be resolved through informal means, including submission of written complaints with supporting documentation, investigation by qualified personnel with appropriate expertise, consideration of applicable laws, regulations, and Platform policies, and issuance of binding decisions with appropriate remedies.

Regulatory complaint procedures ensure that participants have access to appropriate regulatory authorities when Platform-based dispute resolution is unsuccessful or inappropriate, including information about relevant regulatory authorities and complaint procedures, assistance with preparation and submission of regulatory complaints where appropriate, and coordination with regulatory investigations and enforcement actions.

Legal action procedures provide information about participants' rights to pursue legal remedies through court systems, including preservation of evidence and documentation that may be relevant to legal proceedings, cooperation with legal process and court orders, and coordination with legal counsel and other advisors as appropriate.

11.5 Nonprofit Compliance Enforcement

Nonprofit compliance with Platform requirements and applicable laws is enforced through comprehensive monitoring and enforcement procedures designed to ensure that all charitable organizations maintain appropriate standards while providing support and assistance to help Nonprofits achieve and maintain compliance.

Compliance monitoring procedures include regular review of Nonprofit activities and performance metrics, automated monitoring of transaction patterns and compliance indicators, periodic audits of Nonprofit records and procedures, coordination with regulatory authorities on compliance matters, and implementation of corrective actions for identified deficiencies.

Progressive enforcement measures provide appropriate responses to Nonprofit compliance issues based on severity and frequency of violations, including educational interventions and compliance assistance for minor or first-time violations, formal warnings and corrective action requirements for more serious issues, temporary suspension of Platform access pending resolution of compliance issues, and termination of Platform access for serious or repeated violations.

Compliance assistance programs help Nonprofits understand and meet their obligations, including training and educational resources on Platform requirements and applicable laws, consultation services to help Nonprofits develop appropriate policies and procedures, technical assistance with Platform features and compliance tools, and coordination with legal and compliance professionals where appropriate.

Financial consequences for Nonprofit violations may include withholding of proceeds pending resolution of compliance issues, recovery of costs associated with compliance violations and enforcement activities, adjustment of fee structures to reflect increased compliance risks, and coordination with payment processors on risk management measures.

Regulatory coordination ensures that serious Nonprofit compliance violations are appropriately reported to regulatory authorities, including coordination with gaming regulators on licensing and compliance matters, reporting of suspected criminal activity to law enforcement agencies, cooperation with regulatory examinations and investigations, and implementation of regulatory enforcement actions and corrective measures.

11.6 Legal Remedies and Litigation Procedures

RaffleGives maintains comprehensive procedures for pursuing legal remedies when violations result in significant harm or when other enforcement measures are insufficient to address serious violations. These procedures are designed to protect the Platform, Nonprofits, and participants while ensuring appropriate use of legal resources.

Civil litigation procedures provide mechanisms for pursuing legal remedies against parties who violate Platform terms or cause harm to other users, including assessment of legal claims and potential remedies, coordination with qualified legal counsel, preservation of evidence and documentation for litigation purposes, and pursuit of appropriate damages and injunctive relief.

Criminal referral procedures ensure that suspected criminal activity is appropriately reported to law enforcement authorities, including coordination with federal, state, and local law enforcement agencies, provision of evidence and assistance for criminal investigations and prosecutions, protection of witnesses and other parties involved in criminal proceedings, and coordination with regulatory authorities on criminal matters.

Intellectual property enforcement procedures protect Platform intellectual property rights and address violations by users or third parties, including enforcement of trademark and copyright protections, pursuit of remedies for unauthorized use of Platform content or technology, coordination with domain name and hosting providers on infringement matters, and implementation of takedown procedures for infringing content.

Contract enforcement procedures ensure that contractual obligations are appropriately enforced through legal action when necessary, including enforcement of Master Services Agreements with Nonprofits, collection of unpaid fees and other financial obligations, enforcement of indemnification and other protective provisions, and coordination with insurance carriers and other risk management resources.

Regulatory defense procedures provide appropriate responses when Platform operations are challenged by regulatory authorities or other parties, including coordination with qualified regulatory counsel, preparation of responses to regulatory inquiries and enforcement actions, representation in administrative proceedings and hearings, and coordination with industry associations and other stakeholders on regulatory matters.

International legal coordination may be required when violations involve parties or activities in foreign jurisdictions, including coordination with foreign law enforcement and regulatory authorities, compliance with international legal assistance treaties and procedures, enforcement of judgments and other legal remedies across international boundaries, and coordination with international industry organizations and regulatory bodies.

Part XII – Miscellaneous Provisions

12.1 Governing Law and Jurisdiction

This Agreement and all matters arising out of or relating to Platform operations, raffle activities, and the relationships between parties shall be governed by and construed in accordance with the laws of the State of Nevada, without regard to conflict of law principles that might apply the laws of another jurisdiction. This choice of Nevada law reflects the Platform's primary regulatory framework under Nevada gaming law and ensures consistent legal interpretation across all Platform activities.

Exclusive jurisdiction for all disputes arising out of or relating to this Agreement, Platform operations, or raffle activities shall be vested in the state and federal courts located in Clark County, Nevada. All parties consent to the personal jurisdiction of such courts and waive any objection to venue in such courts, including any claim that such courts constitute an inconvenient forum.

Federal court jurisdiction shall be available for disputes involving federal law, constitutional issues, or diversity of citizenship where the amount in controversy exceeds the federal jurisdictional threshold. State court jurisdiction shall apply to all other disputes, including those involving Nevada gaming law, state regulatory matters, and disputes between Nevada residents.

International parties who participate in Platform activities or enter into agreements related to Platform operations consent to the jurisdiction of Nevada courts and agree that Nevada law shall govern their relationships with RaffleGives and participating Nonprofits, regardless of their country of residence or the location of their activities.

Service of process may be accomplished through any method permitted by Nevada law or applicable federal rules, including personal service, certified mail, electronic service where permitted, and service through designated agents or representatives. International parties agree to designate agents for service of process within Nevada or to accept service through alternative methods permitted by applicable international treaties or conventions.

12.2 Limitation of Liability and Damages

The liability of RaffleGives, its officers, directors, employees, agents, and affiliates for any claims arising out of or relating to Platform operations, raffle activities, or this Agreement shall be limited to the maximum extent permitted by applicable law. These limitations reflect the service-based nature of the Platform and the need to maintain sustainable operations while providing appropriate protections for users.

In no event shall RaffleGives be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to lost profits, lost revenue, lost data, business interruption, or other commercial losses, regardless of the theory of liability and whether or not RaffleGives has been advised of the possibility of such damages.

The total liability of RaffleGives for any claims arising out of or relating to Platform operations or this Agreement shall not exceed the total amount of fees paid by the claiming party to RaffleGives during the twelve (12) months preceding the event giving rise to the claim, or one thousand dollars ($1,000), whichever is greater.

These liability limitations shall not apply to: (a) claims for intentional misconduct or gross negligence by RaffleGives, (b) violations of applicable law that cannot be limited by contract, (c) indemnification obligations specifically set forth in this Agreement, (d) claims related to intellectual property infringement, and (e) any other claims where liability limitations are prohibited by applicable law.

Participants and Nonprofits acknowledge that the Platform facilitates charitable raffle activities but does not guarantee any particular outcomes, including winning of prizes, successful fundraising results, or compliance with all applicable legal requirements. All parties assume appropriate risks associated with their participation in or use of Platform services.

12.3 Indemnification Obligations

Nonprofits agree to defend, indemnify, and hold harmless RaffleGives, its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or relating to: (a) the Nonprofit's raffle operations and activities, (b) violations of applicable laws or regulations by the Nonprofit, (c) breach of this Agreement or any Master Services Agreement by the Nonprofit, (d) claims by raffle participants or other third parties related to the Nonprofit's activities, and (e) any negligent or wrongful acts or omissions by the Nonprofit or its personnel.

Participants agree to defend, indemnify, and hold harmless RaffleGives and participating Nonprofits from and against any claims arising out of or relating to: (a) violations of this Agreement or applicable Official Rules by the participant, (b) fraudulent or abusive activities by the participant, (c) violations of applicable laws or regulations by the participant, and (d) any negligent or wrongful acts or omissions by the participant.

RaffleGives agrees to defend, indemnify, and hold harmless Nonprofits from and against claims arising solely out of: (a) gross negligence or willful misconduct by RaffleGives, (b) material breach of this Agreement or any Master Services Agreement by RaffleGives, (c) violations of applicable laws or regulations by RaffleGives in the performance of Platform services, and (d) infringement of third-party intellectual property rights by Platform technology or services.

Indemnification procedures require that the indemnified party provide prompt notice of any claims subject to indemnification, cooperate reasonably in the defense of such claims, and allow the indemnifying party to control the defense and settlement of claims, subject to the indemnified party's right to participate in the defense with counsel of its own choosing at its own expense.

The indemnifying party shall not settle any claim without the prior written consent of the indemnified party, which consent shall not be unreasonably withheld, unless the settlement provides for a complete release of the indemnified party and does not include any admission of liability or wrongdoing by the indemnified party.

12.4 Force Majeure and Business Continuity

Neither RaffleGives nor participating Nonprofits shall be liable for any failure or delay in performance of their obligations under this Agreement when such failure or delay results from circumstances beyond their reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, civil unrest, government actions, labor disputes, epidemics or pandemics, and failures of internet or telecommunications infrastructure.

When force majeure events occur, the affected party shall promptly notify other parties of the circumstances causing the delay or failure and shall use reasonable efforts to mitigate the impact and resume normal operations as quickly as possible. The affected party's obligations shall be suspended only to the extent and for the duration that performance is prevented by the force majeure event.

Business continuity procedures ensure that Platform operations can continue during force majeure events to the extent possible, including backup systems and alternative processing capabilities, coordination with payment processors and other service providers on continuity planning, communication with Nonprofits and participants about service disruptions and alternative procedures, and implementation of emergency procedures for critical functions such as drawing and prize payment activities.

If force majeure events prevent the completion of scheduled raffle activities, affected Nonprofits may postpone drawings and other activities until normal operations can be resumed, provided that participants are promptly notified of any changes and that all postponed activities are completed within reasonable timeframes.

Extended force majeure events that prevent performance for more than thirty (30) days may provide grounds for termination of affected agreements or activities, with appropriate provisions for refunds, prize payments, and other obligations that may have accrued prior to the force majeure event.

12.5 Amendment and Modification Procedures

This Agreement may be amended or modified only through written agreement signed by authorized representatives of RaffleGives and, where applicable, participating Nonprofits. Amendments that affect the rights or obligations of participants must be posted on the Platform and communicated to participants through appropriate channels.

Minor amendments that do not materially affect the rights or obligations of parties, such as updates to contact information, clarifications of existing provisions, or corrections of typographical errors, may be made by RaffleGives with appropriate notice to affected parties but without requiring formal agreement from all parties.

Material amendments that significantly change the terms of this Agreement, including changes to fee structures, liability allocations, dispute resolution procedures, or fundamental operational requirements, require formal agreement from all affected parties and may require regulatory approval where applicable.

Amendment procedures include: (a) preparation of written amendment documents that clearly identify the changes being made, (b) review and approval by appropriate legal counsel and compliance personnel, (c) execution by authorized representatives of all affected parties, (d) filing with regulatory authorities where required, and (e) communication to all affected parties with appropriate effective dates.

Participants will be notified of material amendments through email notifications to registered account addresses, prominent posting on the Platform website, and other appropriate communication channels. Continued use of the Platform following notice of amendments constitutes acceptance of the amended terms.

12.6 Severability and Entire Agreement

If any provision of this Agreement is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be deemed severed from this Agreement, and the remaining provisions shall continue in full force and effect to the maximum extent permitted by law. The parties agree to negotiate in good faith to replace any severed provision with a valid and enforceable provision that achieves the same or similar purpose.

This Agreement, together with any Master Services Agreements, Official Rules for specific raffles, and other documents specifically incorporated by reference, constitutes the entire agreement between the parties with respect to the subject matter hereof and supersedes all prior and contemporaneous agreements, understandings, negotiations, and discussions, whether oral or written.

No waiver of any provision of this Agreement shall be deemed or shall constitute a waiver of any other provision, and no waiver shall be effective unless made in writing and signed by the party to be charged with such waiver. No single or partial exercise of any right, power, or privilege shall preclude any other or further exercise thereof or the exercise of any other right, power, or privilege.

The headings and captions used in this Agreement are for convenience only and shall not affect the interpretation or construction of any provision. References to sections, subsections, and other subdivisions refer to the corresponding sections, subsections, and subdivisions of this Agreement unless otherwise specified.

This Agreement shall be binding upon and inure to the benefit of the parties hereto and their respective successors and permitted assigns. No party may assign this Agreement or any rights or obligations hereunder without the prior written consent of the other parties, except that RaffleGives may assign this Agreement in connection with a merger, acquisition, or sale of all or substantially all of its assets.

Conclusion and Effective Date

This Comprehensive Terms of Service, Official Rules, Privacy Policy, and Compliance Manual represents the complete legal framework governing all activities conducted through the RaffleGives Platform. It has been specifically designed to meet the compliance requirements of major payment processors including PayPal, Stripe, and Authorize.net while ensuring full compliance with Nevada gaming law, federal regulations, and industry best practices.

This document becomes effective immediately upon posting and applies to all current and future Platform activities. All parties are encouraged to review this document carefully and to seek qualified legal and tax advice regarding their specific obligations and circumstances.

For questions about this document or Platform operations, please contact:

RaffleGives, Inc.11035 Lavender Hill Dr., Ste 160Las Vegas, NV 89135Email: legal@rafflegives.comPhone: (702) 674-6222

Document Control:Version: 1.5Effective Date:09/01/2025Next Review Date: 09/01/2025 + 12 months