U.S. WEBSITE COMPLIANCE GUIDELINES

 

These United States Website Compliance Guidelines (the “U.S. Compliance Guidelines”) are intended to be used by Better Collective (“us,” “we” or “our”) in order to ensure that our Websites’ Marketing Content (as defined below) is compliant with U.S. laws and regulations. Please note that the contents of these U.S. Compliance Guidelines are strictly confidential and exist solely as an internal website compliance reference tool for us and our employees. Additionally, the U.S. Compliance Guidelines are not legally binding and are specific only to the United States jurisdictions enumerated herein. For a condensed checklist of these U.S. Compliance Guidelines, please reference the U.S. Compliance Guidelines Checklist. Please use the U.S. Compliance Guidelines and the U.S. Compliance Guidelines Checklist in order to ensure that you have included every required U.S. compliance element.

 

TABLE OF CONTENTS

DEFINITIONS 2

AFFILIATE MARKETING DISCLOSURES (“AMD’S”) 4

WEBSITE MARKETING CONTENT 4

Operator Requirements. 4

Marketing Content Best Practices 4

Bonus Offers and Marketing Content 6

Approaches for Marketing Content Editorials. 7

Licensed Operators. 7

Direct Marketing and Prohibited Persons Lists. 8

BC wants to direct email market on behalf of Operator in [State]; 8

WEBSITE FOOTER 8

WEBSITE ODDS, TIPS AND GAMBLING STRATEGY 9

BUMPERS AND EXIT MODALS 10

STATE SPECIFIC REQUIREMENTS 11

NEW JERSEY 11

PENNSYLVANIA 13

INDIANA 14

IOWA 16

WEST VIRGINIA 17

COLORADO 18

NEVADA 19

ILLINOIS 20

TENNESSEE 21

VIRGINIA 22

MICHIGAN 23

ARIZONA 24

ALL OTHER STATES NOT LISTED IN THIS SECTION. 25

U.S. COMPLIANCE GUIDELINES QUESTIONS. 26

EXHIBIT A 26

 

  • DEFINITIONS

For purposes of these U.S. Compliance Guidelines, the following definitions apply to all capitalized terms herein: 

 

“Above the Fold” means the positioning of text or an image on the upper half of a Website page so that it is visible to a Visitor upon entry to the Website page without having to scroll.

 

“AMD” or “Affiliate Marketing Disclosure” means a clear and conspicuous disclosure about the incentivized nature of the Marketing Content on the Website. Please see Section II for more information. 

 

“AMD Disclaimer” means the Affiliate Marketing Disclosure Disclaimer that is located on a separate Website page for which the AMD hyperlinks to. Please see Section II for more information.

 

“Bonus Offer“ means a promotion that is available on a Website that aims to direct Visitors to an Operator. Please see Section III(C) for more information.

 

“Bumper” means the Website page or pop-up that appears before a Visitor is redirected from the Website. Please see Section VI for more information.

 

“Conservative Editorial Approach” has the meaning given in Section III(D)(i).

 

“Footer” means the fixed text and images that appear at the bottom of a Website page. Please see Section IV for more information.

 

“Editorial” means a written article offering an opinion or facts about a topical issue.

 

“Exit Modal” means the modal box which contains Marketing Content and appears when a Visitor is about to leave the Website page. Please see Section VI for more information.

 

“FTC” means the Federal Trade Commission, an independent agency of the United States government, whose principal mission is the promotion of consumer protection.

 

“Gambling Strategy” means any content that presents a plan or set of actions, such as Tips, designed to improve or enhance Visitors’ wagering skills or outcomes. Please see Section V(B) for more information. 

 

“Gambling Strategy Disclaimer” has the meaning given in Section V(B).

 

“Gaming” means, for purposes of these U.S. Compliance Guidelines, the wagering of money or something of value on an event with an uncertain outcome with the primary intent of winning money or material goods, including, but not limited to, real-money sports wagering and internet casino gaming.

 

“Geo-target” means the method of determining the geolocation of a website Visitor and delivering different content to that visitor based on the Visitor’s location.

 

“Marketing Activities” means any Website activity related to the promotion of Marketing Content.

 

“Marketing Content” means all Website content that relates, refers, links or makes reference to Operators’ products, offers, promotions, brand or websites, including Bonus Offers.

 

“Match Bonus Offer” means a Bonus Offer whereby the Operator matches the Visitor’s deposit. Please see Section III(C)(ii)(2) for more information.

 

“Off-Shore Operator” means any Operator who: (i) is operating illegally or without a state Gaming license issued by the appropriate state regulatory body or bodies (i.e., the NJ DGE), and (ii) targets United States Players or Visitors. Please see Section III(E)(i) for more information.

 

“Operator” means any licensed Gaming service provider (i.e., DraftKings, bet365, FanDuel, etc.).

 

“Player“ means any Visitor who generates fees for us by registering with an Operator after accessing a referral through our network. 

 

“Standard Editorial Approach” has the meaning given in Section III(D)(ii).

 

“Tips” means any Gaming information or advice given to Visitors that pertains to the likely outcome of a sporting event, or other event. Please see Section V(B) for more information.

 

“Website” means a website owned and operated by us. 

 

“Welcome Bonus Offer” means a Bonus Offer that references a “welcome bonus,” a “first time bonus” or something similar for the benefit of the Visitor. Please see Section III(C)(ii)(1) for more information.

 

“Visitor” means any person who visits our Website(s).

  • AFFILIATE MARKETING DISCLOSURES (“AMD’S”)

  • Affiliate Marketing Disclosure Requirements.  AMD’s must be displayed Above the Fold on (i) every Website page and (ii) every Website page that contains Editorials that incorporate Marketing Content (such as Operator reviews, etc.).  

 

  1. AMD must appear on all Website pages. The phrase “This site contains commercial content” must be displayed Above the Fold on every Website page. 

 

  1. Additional AMD on Website pages that contain Marketing Content Editorials. The phrase “We may be compensated for the company links provided on this page” should be displayed Above the Fold or under the Editorial title on every Website page that contains Editorial(s) that incorporate Marketing Content, such as Operator review Website pages.

 

  1. All AMD’s must Hyperlink to AMD Disclaimer Website Page. AMD text must be hyperlinked to a separate standalone AMD Disclaimer Website page, which must contain some form of the following text: “We hope you enjoy the companies that we recommend! Just to be clear, please note that we may collect a share of sales or other compensation from the company links provided on this Website. If you have any questions, please do not hesitate to contact us or reference our terms and conditions.”  

  • WEBSITE MARKETING CONTENT

  • Operator Requirements. 

        1. Always ensure that Marketing Content complies with external Operator requirements. Please check if there are any specific Operator requirements in the USA Market Intelligence spreadsheet. If you’re unsure whether there are external Operator requirements, please contact our Partner Operations Manager, Marko Stojanovic.

  • Marketing Content Best Practices

      1. Clear and Conspicuous.  All facts and information related to Marketing Content and Bonus Offers must be clearly visible and not obscured by any type, size, location, lighting, illustration, graphic depiction or color.

 

  1. Honest.  All Bonus Offers and Marketing Content must reflect the honest intent of the content creator. Remember, the FTC expressed that, “unfair or deceptive acts or practices in or affecting commerce, is declared unlawful.” 

 

  1. 21+.  Marketing Content must not target or appeal to persons under the age of 21. For example, depicting cartoon characters and/or featuring entertainers or music that appeals primarily to audiences below the age of 21 is strictly prohibited on our Websites. A “21+” logo must always appear in the Footer of our Websites. 

 

  1. English.  Marketing Content must be written in plain English.

 

  1. Prizes.  Never claim that a Visitor “won a prize” if, in order to claim that prize, the Visitor is required to do any act, purchase any item or submit to a sales promotion.

 

  1. Tips and Guarantees.  No Website page should ever suggest that social, financial or personal success is guaranteed.

 

  1. Free Offers. Never describe a product, Marketing Content or Bonus Offer as “free,” “gratis,” “without charge” or similar if the Visitor has to pay to receive the product.

 

  1. Promotional Language. Never imply that chances of winning increase if the Visitor increases participation or spends more money. Website pages must never promise or imply certain results or benefits unless expressly approved by Legal.

 

  1. “T&C’s Apply”. Where possible link to the Operator’s terms and conditions when promoting Marketing Content. See “Bonus Offers & Marketing Content” for more details.

 

  1. Geo-targeting and Applicable States. Always use Geo-targeting (defined in Section I above) to determine the Geolocation of a Website Visitor and deliver different Marketing Content to that Visitor based on the Visitor’s location. If Geo-targeting is not possible, you must reference the states where the Market Content or Bonus Offer is applicable when promoting the Marketing Content. For example, “only available in NJ, PA, IN, and WV,” etc.

 

  1. Approved Events. Wagers can only be placed on sporting and Gaming events that are approved for Wagering by the appropriate state regulator. Each state regulator provides a list of “approved events” that are permitted to be Wagered on. Bonus Offers and Marketing Content must not be promoted for events that are not deemed an “approved event” by the targeted state. If you are unsure whether an event is approved and cannot locate a state’s pre-approved events list, please contact Legal.

  • Bonus Offers and Marketing Content

    1. Always include “T&C’s Apply, 21+” and reference the states where the Bonus Offer is available.  Bonus Offers and all Marketing Content that aims to direct Visitors to an Operator must always include text that expresses “T&C’s Apply, 21+” and, if Geo-targeting is not possible, must reference the states where the Bonus Offer is available in close proximity to the Bonus Offers and all Marketing Content that aims to direct Visitors to an Operator.
      1. Where space is not limited, it is recommended to include ‘’Key terms of the Bonus Offer’’ as provided in the BC US Offers API (Example:‘’New customers only. Make a qualifying deposit (min $10), place bets to deposit value, once they are settled, matched amount in Bet Credits available to use. Bet Credits risk excluded from returns. 21+. T&Cs apply. NJ Only.’’ If you have any questions in regard to BC US Offers API please contact our Partner Operations Manager, Marko Stojanovic.
      2. If possible, “T&C’s Apply” should hyperlink to the Operator’s full terms and conditions regarding the Bonus Offer, which are located on the Operator’s website. 
        1. If no adequate tracking link is available, “T&C’s Apply” should not be hyperlinked.
        2. “T&C’s Apply” should never be hyperlinked to any other page (e.g. registration page, Operator’s homepage) as this can be seen as misleading.

 

  1. Types of Bonus Offers and Related Requirements.

 

  1. Welcome Bonus Offers.  Welcome Bonus Offers or standard Bonus Offers must clearly express that the Bonus Offer is a “one-time offer.” 

 

  1. Match Bonus Offers. Match Bonus Offers must clearly express whether the Match Bonus Offer is distributed by the Operator in the form of free bets or withdrawable cash.

 

  1. “Free” Bonus Offers. If Marketing Content describes a Bonus Offer as “free,” the steps the Visitor must take to obtain the free offer must be clearly expressed on our Website. For example, “If you open an account with [Operator] and place a first bet of at least $20.00, the [Operator] will give you a $30.00 free bet!” Further, never describe a product or Bonus Offer as “free,” “gratis,” “without charge” or similar if the Visitor has to pay to receive the product.

  • Approaches for Marketing Content Editorials. 

In addition to the enumerated compliance requirements set forth in these U.S. Compliance Guidelines, when creating or implementing Editorials that utilize Marketing Content, please use either the Conservative Editorial Approach or the Standard Editorial Approach. The editorial approach taken depends on our commercial status with the Operator, as defined below. 

 

  1. Conservative Editorial Approach. The following standards apply to Marketing Content Editorials that discuss Operators who: (i) have Editorial or Marketing Content restrictions, (ii) we do not have an active affiliate agreement with, or (iii) are not yet launched or are awaiting a license to operate in a certain U.S. market.  

 

  1. Website pages must include a disclaimer regarding the Operator’s availability. For example: “Betting or wagering is not permitted or may be restricted in certain jurisdictions. You are not permitted to wager with Operators who are not licensed in your state. Please check your local rules and regulations.” 

 

  1. Do not use the Operators’ identifying marks or images, unless we have the Operator’s express permission to do so.

 

  1. Do not promote the Operator with Operator links, unless we have the Operator’s and Legal’s express permission to do so. 

 

  1. The content created must be limited to purely informative and factual information.

 

  1. Standard Editorial Approach. The following standards apply to Marketing Content Editorials which discuss Operators who are party to an affiliate agreement with us, and/or Operators who do not restrict Editorials or Marketing Content.

 

  1. Website pages must include a disclaimer regarding the Operator’s availability. For example: “Betting or wagering is not permitted or may be restricted in certain jurisdictions. You are not permitted to wager with Operators who are not licensed in your state. Please check your local rules and regulations.” 

 

  1. The Editorial content must be limited to purely informative and factual information that is permissible according to the terms of the Operator Affiliate Agreement.

  • Licensed Operators. 

Marketing Content and Bonus Offers must only promote Operators that are appropriately licensed. For example, if Operator X is only licensed in New Jersey, we cannot promote Operator X Marketing Content and Bonus Offers in West Virginia.  Note, Marketing Content for unlicensed Operators, such as Off-Shore Operators, is never permitted on our Websites. If you’re unsure whether an Operator is licensed, please contact our Partner Operations Manager. Marko Stojanovic

 

  1. Off-Shore Operators. Marketing Content that is about, related to, references, or is affiliated with Off-Shore Operators is strictly prohibited from being displayed on our Websites. Marketing Content from Off-Shore Operators includes, but is not limited to, Off-Shore Operator: (i) odds, (ii) promotions, (iii) advertisements, (iii) articles, (iv) hyperlinks, (v) Bonus Offers or (vi) reviews. The only Off-Shore Operator content that is permitted on our Websites is content that can be classified as “journalistic reporting” that uses the Conservative Editorial Approach, but even this is strongly advised against and requires Legal’s approval.

  • Direct Marketing and Prohibited Persons Lists.

We must not send direct marketing messages or information to individuals who are prohibited from receiving such content or information by a state or by voluntary subscription to a state self-exclusion list. Prohibited persons must be scrubbed from our marketing emails and correspondence databases. For more information on state specific prohibited persons lists, please reference Section VII below. Note, most exclusion lists only include names and dates of birth (not email addresses).  Accordingly, all persons with common names must be removed from email and/or other marketing lists. Note, these lists are confidential and must only be shared internally with BC persons who reasonably need access to them.  In order to handle direct email marketing on behalf of U.S. operators compliantly please follow the steps listed below: 

  1. BC wants to direct email market on behalf of Operator in [State];

  2. BD / PO reach out to Operator affiliate manager for direct email marketing approval;
  3. BD / PO request exclusion list from Operator XYZ affiliate manager;
  4. BD / PO share the [State] exclusion list w/ BC Marketing;
  5. BC Marketing scrubs BC [State] email database against Operator [State] exclusion list and removes excluded persons from BC database;
  6. BC may now directly market on behalf of Operator in [State], per the terms of our affiliate agreement.

  • WEBSITE FOOTER 

  • Footer Requirements:

 

  1. Age Requirement; 21+ Logo. The Footer of every Website page must display a 21+ Age requirement logo. Please see Exhibit A for a general “21+” logo. You may change the color and font style of the 21+ logo, but it must remain “clear and conspicuous.”  

 

  1. Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display the relevant state Responsible Gaming Logo. Please see Section VII of these U.S. Compliance Guidelines for state specific requirements. If no state specific Responsible Gaming logo is available, please use the “general Responsible Gaming Logo” provided for on Exhibit A. 

 

  1. Gambling Problem Disclaimer.  The Footer of every Website page must be Geo-targeted to display the relevant Gambling Problem Disclaimer that encourages the Visitor to seek help if he or she has a gambling problem. Please see Section VII of these U.S. Compliance Guidelines for state specific requirements. If no state specific Gambling Problem Disclaimer is available, please use the “general Gambling Problem Disclaimer” described in Exhibit A.

 

  1. U.S. Compliance Plugin. Please note that you can find the U.S. Compliance Plugin here, when installed this plugin will automatically display the relevant state Responsible Gaming Logo and Gambling Problem Disclaimer.

 

  1. Contact Information.  The Footer of every Website Page must contain either (i) contact information for Better Collective, or (ii) “contact us” text that hyperlinks to a separate Website contact page.

 

  1. Privacy Policy and Cookie Policy.  The Website’s Footer must contain a hyperlink to the Website’s Privacy Policy and Cookie Policy. For all questions related to Privacy Policy and Cookie Policy please reach out to our Data Protection Advisor Dusan Pavlovic.

 

  1. Terms of Service.  All Website’s with the login function/any other strong user engagement must contain a hyperlink to the Website’s  Terms of Service Terms and Conditions in the footer. In all other cases there is no requirement to provide Terms of Service in the Website’s footer.

 

  1. State Specific Requirements. Please reference Section VII of these U.S. Compliance Guidelines for state specific Footer requirements that must be included in addition to the Footer requirements enumerated above. 

  • WEBSITE ODDS, TIPS AND GAMBLING STRATEGY


  • Odds.  

 

  1. Legitimate Odds. All Odds that appear on our Websites must be provided by, come from and/or reference legal or licensed Operators. If Odds contain a commercial hyperlink, the commercial hyperlinks must be Geo-targeted only to permissible state jurisdictions where both we and the Operator have the appropriate state licenses in place. Odds from Off-Shore Operators are strictly prohibited from appearing on the Websites. 

 

  1. Odds Sources. Odds sources must be clearly expressed and visible. If the odds presented are custom-made (i.e., the odds are custom created by a Website or external algorithm), the Odds Website page should be clear as to how the odds are created (i.e, “* custom created odds“).

 

  • Odds Tables. All Website pages that contain Odds tables with Marketing Content on different Operators which are not available in all states must contain the Availability Disclaimer in close proximity to the Odds table. The Availability Disclaimer must express that: “Operators are not available in all states. You are only permitted to wager with Operators that are licensed in the state where you reside. Please check your local state rules and regulations. 21+, T&Cs apply.“


  • Tips and Gambling Strategy.  

 

  1. Gambling Strategy Disclaimer. All Website pages that contain, pertain to, reference, explain, describe or allude to Tips or Gambling Strategy must contain a clear Gambling Strategy Disclaimer near the Tips or Gambling Strategy. The Gambling Strategy Disclaimer must express that: “The content on this page is for informational purposes only. [insert our domain name] makes no representation or warranty as to the accuracy of information given or the outcome of any game or event.” 

  • BUMPERS AND EXIT MODALS

  • Website Bumper/Exit Modal Requirements. If a Website uses a Bumper or displays an Exit Modal, the Bumper/Exit Modal must be Geo-targeted to include: (i) the general age requirement (“21+”) logo or clear text that expresses that Visitors must be 21 years of age or older; (ii) the relevant state responsible gaming logo or general responsible gaming logo (if technically not possible it is not needed for Exit Modals to have this element); and (iii) the relevant state gambling problem disclaimer or general gabling problem disclaimer. Please reference Section VII for state specific requirements and Exhibit A for logos.  

 

  1. Bumpers with Bonus Offers.  If a Bonus Offer is used in connection with a Bumper, the Bumper must clearly express that “Terms and Conditions apply,” however, there is no requirement that the text be hyperlinked. Always use Geo-targeting to determine the Geolocation of a Website Visitor and deliver different Bonus Offers to that Visitor based on the Visitor’s location in order to remain compliant. If Geo-targeting is not possible, you must reference the states where the Bonus Offer is applicable. For example, “only available in NJ, PA, IN, and WV,” etc.

 

  • NEGATIVE KEYWORDS (KWs)


  • Personal Problem KWs.  Gambling must not be portrayed as a way to resolve personal issues (psychological/social). If the following phrases are used in this prohibited context, they must be removed from content: Addict/Addiction, Anxiety, Boredom, Change my/your life, Life changer/changing, Debts, Family issues, Solve my/your (financial) problems.


  • No risk/promised win KWs
    1. Gambling should not be portrayed as the activity that involves no risk by using the following phrases: Cannot lose, Does not lose, No risk, Risk free (Risk free offers may be an exception).
    2. Gambling must not be promoted as a means to earn money through use of the following phrases: Cash making, Cash maker, Get rich, Earn cash/money, Fast cash/money/profit, Free cash/money, Make cash/money, Double the size of your wallet.
    3. We must not promise winnings of any kind. The following phrases should be removed: Guaranteed/Secured/Sure, Start winning, Win big.

  • STATE SPECIFIC REQUIREMENTS

  • NEW JERSEY

      1. New Jersey Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in New Jersey:

 

  1. New Jersey Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display the New Jersey Responsible Gaming Logo to Visitors of the site who reside in New Jersey. Please see Exhibit A for the New Jersey Responsible Gaming Logo.

 

  1. New Jersey Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following New Jersey Problem Gaming Disclaimer to Visitors of the site from New Jersey: “Bet with your head, not over it! Gambling Problem? Call 1-800-Gambler.” Note, “Call 1-800-Gambler” must be hyperlinked to https://800gambler.org/.

 

  1. Hyperlink to the New Jersey Self-Exclusion Program. The Footer of every Website page must be Geo-targeted to New Jersey Visitors to display hyperlinked text that states “New Jersey Self-Exclusion Program“. 

 

  1. New Jersey Marketing Content Requirements.

 

  1. New Jersey Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within New Jersey must refer only to those Operators licensed by the New Jersey Division of Gaming Enforcement (NJ DGE) (or the New Jersey Casino Control Commission (NJ CCC) in the case of casinos). Operators licensed by the NJ DGE or NJ CCC are listed on the NJ DGE Website. If you cannot locate a particular Operator on the NJ DGE Website and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic

 

  1. New Jersey Prohibited Persons Lists.  

 

  1. New Jersey Prohibited Individuals. We must not send direct marketing messages or information to individuals who are prohibited from receiving such content or information by the state of New Jersey. The NJ DGE identifies these persons on the NJ Prohibited Individuals List.  Note, that the NJ DGE’s exclusion lists only includes names and dates of birth (not email addresses).  Accordingly, all persons with common names must be removed from email and/or other marketing lists. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

 

  1. New Jersey Self-Excluded Individuals. We must not send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in New Jersey.  The NJ DGE does not make this list publicly available.  However, Operators may share information identifying self-excluded players with Better Collective upon request.  This list is confidential and must only be shared internally with BC persons who reasonably need access to it.  Please contact Legal for more information about New Jersey self-excluded individuals.

 

  1. Miscellaneous New Jersey Requirements.

 

  1. New Jersey College Sports Prohibition: If the Website refers to sports wagering on college sports, that Website page must always include language related to NJ’s college restriction, such as: “New Jersey college teams and college events taking place in New Jersey are excluded”.

  • PENNSYLVANIA

    1. Pennsylvania Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Pennsylvania:   

 

  1. Pennsylvania Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display the Pennsylvania Responsible Gaming Logo to Visitors of the site from Pennsylvania. Please see Exhibit A for the Pennsylvania Responsible Gaming Logo.

 

  1. Pennsylvania Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Pennsylvania Problem Gaming Disclaimer to Visitors of the site from Pennsylvania: ‘‘If you or someone you know has a gambling problem, help is available, call 1-800-Gambler.” Note, “Call 1-800-Gambler” must be hyperlinked to https://responsibleplay.pa.gov/ .

 

  1. Hyperlink to the Pennsylvania Self-Exclusion Program. The Footer of every Website page must be Geo-targeted to Pennsylvania Visitors to display hyperlinked text that states “Pennsylvania Self-Exclusion Program“. 

 

  1.  Pennsylvania Marketing Content Requirements.

 

  1. Pennsylvania Problem Gaming Disclaimer. In addition to the Footer, the Pennsylvania Problem Gaming Disclaimer must be placed next to or near all Marketing Content and Bonus Offers Geo-targeted or direct marketed to Pennsylvania Visitors. The size of the font used for the Pennsylvania Problem Gaming Disclaimer must never be smaller in size than the majority of the font in the surrounding area of the Website, and the Problem Gaming Disclaimer must always be clear and conspicuous. 

 

  1. Pennsylvania Conditions on Bonus Offers. We must always disclose conditions or limiting factors associated with Marketing Content and Bonus Offers in Pennsylvania.

 

  1. Pennsylvania Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within Pennsylvania must refer only to those Operators licensed by the Pennsylvania Gaming Control Board (PGCB). If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic

 

  1. Pennsylvania Prohibited Persons Lists. 

 

  1. Pennsylvania Prohibited Individuals. We must not send direct marketing messages or information to individuals who are prohibited from receiving such content or information by the state of Pennsylvania. The Pennsylvania Gaming Control Board (PGCB) identifies these persons on the Involuntary Exclusion List. Accordingly, all persons with common names must be removed from email and/or other marketing lists. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

 

  1. Pennsylvania Self-Excluded Individuals. We cannot send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in Pennsylvania.  The Pennsylvania Gaming Control Board (PGCB) does not make this list publicly available. However, Operators may share information identifying self-excluded players with Better Collective upon request. This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information about Pennsylvania self-excluded individuals.

  • INDIANA

    1. Indiana Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Indiana: 

 

  1. Indiana Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Indiana. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Indiana Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Indiana Problem Gaming Disclaimer to Visitors of the site from Indiana: “If you or someone you know has a gambling problem and wants help, call 1-800-9-WITH-IT.” Note, “call 1-800-9-WITH-IT’’ must be hyperlinked to https://www.in.gov/igc/problemgamblinghelp/.

 

  1. Hyperlink to the Indiana Self-Restriction Program. The Footer of every Website page must be Geo-targeted to Indiana Visitors to display hyperlinked text that expresses “Indiana Self-Restriction Program“. 

 

  1. Indiana Marketing Content Requirements. 

 

  1. Indiana “Free” Bonus Offers and Marketing Content. Bonus Offers and Marketing Content must not be described as “free” unless the offer absolutely is free; if the Visitor must risk or may lose the Visitor’s own money or there are conditions attached to the Visitor receiving the Bonus Offer, then the Bonus Offer or Marketing Content must disclose those terms.

 

  1. Indiana Licensed Operators. All Website Marketing Content that targets Visitors within Indiana must refer only to those Operators licensed by the Indiana Gaming Commission (“IGC“). Operators licensed by the IGC are listed on the IGC Website. If you cannot locate a particular Operator on the IGC Website and need to check if the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic

 

  1. Indiana Self-Exclusion Program. We cannot send Marketing Content, direct marketing messages or information to individuals who have self-excluded themselves from participating in Gaming activities in Indiana.  The Indiana Gaming Commission does not make this list publicly available.  However, Operators may share information identifying self-excluded Players with Better Collective upon request.  This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information about Indiana prohibited persons. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

 

  • IOWA

    1. Iowa Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Iowa:   

 

  1. Iowa Responsible Gaming Logo. The Footer of every Website page must Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Iowa. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Iowa Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Iowa Problem Gaming Disclaimer to Visitors of the site from Iowa: “If you or someone you know has a gambling problem and wants help, call 1-800-BETS-OFF.” Note, “call 1-800-BETS-OFF“ must be hyperlinked to https://yourlifeiowa.org/gambling.

 

  1. Hyperlink to the Iowa Self-Exclusion Program. The Footer of every Website page must be Geo-targeted to Iowa Visitors to display hyperlinked text that expresses “Iowa Voluntary Self-Exclusion Program“. 

 

  • Iowa Marketing Requirements

 

  1. Iowa Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within Iowa must refer only to those Operators licensed by the Iowa Racing and Gaming Commission (IRGC). If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic

 

  1. Iowa Self-Excluded Individuals. We cannot send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in Iowa. Names of self-excluded individuals are available only to Iowa Racing and Gaming Commission (IRGC) and State licensed operators, and are not publicly available. However, Operators may share information identifying self-excluded players with Better Collective upon request.  This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

  • WEST VIRGINIA

    1. West Virginia Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in West Virginia:   

 

  1. West Virginia Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from West Virginia. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. West Virginia Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following West Virginia Problem Gaming Disclaimer to Visitors of the site from West Virginia: “If you or someone you know has a gambling problem and wants help, call 1-800-GAMBLER.” Note, “call 1-800-GAMBLER” must be hyperlinked to https://www.1800gambler.net/treatment.

 

  • West Virginia Marketing Requirements

 

  1. West Virginia Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within West Virginia must refer only to those Operators licensed by the WV Lottery Commision. If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic

 

  1. West Virginia Self-Excluded Individuals. We must not send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in West Virginia. This list is not publicly available. However, Operators may share information identifying self-excluded players with Better Collective upon request.  This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information about West Virginia self-excluded individuals. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

 

  • COLORADO

    1. Colorado Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Colorado:   

 

  1. Colorado Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Colorado. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Colorado Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Colorado Problem Gaming Disclaimer to Visitors of the Website from Colorado: “Gambling problem? Call 1-800-522-4700.” Note, “Call 1-800-522-4700“ must be hyperlinked to http://www.problemgamblingcolorado.org/.

 

  1. Hyperlink to the Colorado Self-Exclusion Program. The Footer of every Website page must be Geo-targeted to Colorado Visitors to display hyperlinked text that expresses “Colorado Self-Exclusion“.

 

  1. Colorado Marketing Content Requirements

 

  1. Colorado “Free” Bonus Offers and Marketing Content. Bonus Offers and Marketing Content must not be described as “free” unless the offer absolutely is free; if the Visitor must risk or may lose the Visitor’s own money or there are conditions attached to the Visitor receiving the Bonus Offer, then the Bonus Offer or Marketing Content must disclose those terms.

 

  1. Colorado Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within Colorado must refer only to those Operators licensed by the Colorado Division of Gaming. If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic

 

  1. Colorado Self-Exclusion List. Each Operator in Colorado is obliged to establish and maintain a self-exclusion program for Players specific to that Operator. The lists are not publicly available. However, operators may share information identifying self-excluded Players with Better Collective upon request. Please contact Legal for more information about Indiana prohibited persons. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

 

  • NEVADA

    1. Nevada Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Nevada:

 

  1. Nevada Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Nevada. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Nevada Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Nevada Problem Gaming Disclaimer: “If your gambling is no longer fun, don’t wait for the problem to get worse. Contact the Nevada Council on Problem Gambling or call 1-800-522-4700”  with Nevada Council on Problem Gambling hyperlinked to https://www.nevadacouncil.org/.

 

  1. Nevada Marketing Content Requirements

 

  • Nevada Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within Nevada must refer only to those Operators licensed by the Nevada Gaming Commision. List of Nevada Approved and Licensed Operators of Interactive Gaming can be found here. If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager,.Marko Stojanovic

 

  1. Nevada Self-Excluded Individuals. Nevada Operators are required to maintain self-exclusion lists. We cannot send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in Nevada. The lists are not publicly available. However, operators may share information identifying self-excluded Players with Better Collective upon request. Please contact Legal for more information about Nevada self-excluded individuals.

 

  • Nevada Excluded Person List. The Nevada Gaming Control Board (GCB) identifies these excluded persons on the GCB Excluded Person List. Note, that the Nevada GCB Exclusion Person List only includes names, aliases and dates of birth (not email addresses). Accordingly, all persons with common names must be removed from email and/or other marketing lists. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 


  • ILLINOIS


  • Illinois Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Illinois:

 

  1. Illinois Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Illinois. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Illinois Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Illinois Problem Gaming Disclaimer to Visitors of the site from Illinois: “If you or someone you know has a gambling problem, crisis counseling and referral services can be accessed by calling 1-800-GAMBLER (1-800-426-2537).” Note, “1-800-GAMBLER (1-800-426-2537)’’ must be hyperlinked to https://weknowthefeeling.org/.

 

  • Hyperlink to the Illinois Self-Exclusion Program. The Footer of every Website page must be Geo-targeted to Illinois Visitors to display hyperlinked text that expresses “Illinois Self-Exclusion Program“.

 

  1. Illinois Marketing Requirements.

 

  • Illinois Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within Illinois must refer only to those Operators licensed by the Illinois Gaming Board (IGB). Operators licensed by the IGB are listed on the IGB Website.  If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic.

 

  1. Illinois Self-Excluded Individuals. We must not send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in Illinois. This list is not publicly available. However, Operators may share information identifying self-excluded players with Better Collective upon request. This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information about Illinois self-excluded individuals. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

 

  • TENNESSEE

 

  1. Tennessee Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Tennessee: 

 

  1. Tennessee Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Tennessee. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Tennessee Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Tennessee Problem Gaming Disclaimer to Visitors of the site from Tennessee: “Gambling Problem? Call or Text the Tennessee REDLINE: 800-889-9789.” Note, “Call or Text the Tennessee REDLINE: 800-889-9789’’ must be hyperlinked to https://www.taadas.org/our-programs-and-services/redline.

 

  1. Tennessee Marketing Requirements

 

  1. Tennessee Licensed Operators.  All Website Marketing Content, including Bonus Offers, that targets Visitors within Tennessee must refer only to those Operators licensed by the TN Education Lottery Corporation. Operators licensed by the TN Education Lottery Corporation are listed on the TN Lottery Website.  If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic.

 

  1. Tennessee Self-Excluded Individuals. We must not send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in Tennessee. This list is not publicly available. However, Operators may share information identifying self-excluded players with Better Collective upon request. This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information about Tennessee self-excluded individuals. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

 

  • VIRGINIA

 

  1. Virginia Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Virginia:

 

  1. Virginia Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Virginia. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Virginia Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Virginia Problem Gaming Disclaimer to Visitors of the site from Virginia: “If you or someone you know has a gambling problem, please call, text or chat, our confidential and toll free helpline at: 1-888-532-3500.” Note, “1-888-532-3500’’ must be hyperlinked to http://www.vacpg.org/ .

 

  1. Hyperlink to the Virginia Self-Exclusion Program. The Footer of every Website page must be Geo-targeted to Virginia Visitors to display hyperlinked text that expresses “Virginia Voluntary Exclusion Program“.

 

  1. Virginia Marketing Requirements

 

  1. Virginia Licensed Operators. All Website Marketing Content, including Bonus Offers, that targets Visitors within Virginia must refer only to those Operators licensed by the Virginia Lottery Board.  If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic.

 

  1. Virginia Self-Excluded Individuals. We must not send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in Virginia. This list is not publicly available. However, Operators may share information identifying self-excluded players with Better Collective upon request. This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information about Virginia self-excluded individuals. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

  • MICHIGAN

 

  1. Michigan Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Michigan:   

 

  1. Michigan Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Michigan. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Michigan Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Michigan Problem Gaming Disclaimer to Visitors of the site from Michigan: ’’If you or someone you know has a gambling problem and wants help, call the Michigan Department of Health and Human Services Gambling Disorder Help-line at: 800-270-7117’’. Note, “call the Michigan Department of Health and Human Services Gambling Disorder Help-line at: 800-270-7117 must be hyperlinked to  https://www.michigan.gov/mgcb/0,4620,7-351-79256-231582–,00.html

 

  1. Hyperlink to the Michigan Disassociated Persons Program. The Footer of every Website page must be Geo-targeted to Michigan Visitors to display hyperlinked text that expresses “Michigan Disassociated Persons Program“.

 

  • Michigan Marketing Requirements

 

  1. Michigan Licensed Operators. All Website Marketing Content, including Bonus Offers, that targets Visitors within Michigan must refer only to those Operators licensed by the Michigan Gaming Control Board. If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic.

 

  1. Michigan Self-Excluded Individuals. We must not send direct marketing messages or information to individuals who have self-excluded themselves from participating in gambling activities in Michigan. This list is not publicly available. However, Operators may share information identifying self-excluded players with Better Collective upon request. This list is confidential and must only be shared internally with BC persons who reasonably need access to it. Please contact Legal for more information about Michigan self-excluded individuals. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section.

 

ARIZONA

 

  1. Arizona Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors in Arizona:   

 

  1. Arizona Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site from Arizona. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Arizona Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Arizona Problem Gaming Disclaimer to Visitors of the Website from Colorado: “Gambling problem? Visit problemgambling.az.gov, text NEXTSTEP to 53342, or call 1-800-NEXT-STEP.” must be hyperlinked to problemgambling.az.gov

 

  1. Hyperlink to the Arizona Self-Exclusion Program. The Footer of every Website page must be Geo-targeted to Arizona Visitors to display hyperlinked text that expresses “Arizona Self-Exclusion“.

 

  1. Arizona Marketing Content Requirements

 

  1. Arziona “Free” Bonus Offers and Marketing Content. Promotions and/or bonuses described as free shall clearly disclose material facts, terms, and conditions.

 

  1. Arizona Licensed Operators.  Event wagering operators are subject to the licensing requirements. Event wagering operators shall have obtained from the Arizona Department of Gaming (ADG) a renewal of the license every five (5) years thereafter before continuing to operate event wagering. If you cannot locate the jurisdiction of a particular Operator and need to check whether the Operator is licensed, please contact our Partner Operations Manager, Marko Stojanovic

 

  1. Arizona Self-Exclusion List. Each Operator in Arizona is obliged to establish and maintain a self-exclusion program for Players specific to that Operator. The lists are not publicly available. However, operators may share information identifying self-excluded Players with Better Collective upon request. For steps required to handle direct email marketing please refer to the Direct Marketing and Prohibited Persons Lists section. 

  • ALL OTHER STATES NOT LISTED IN THIS SECTION. 

    1. All Other States Footer Requirements. In addition to the Footer requirements enumerated in Section IV of these U.S. Compliance Guidelines, the following Footer requirements must be Geo-targeted to Visitors from all other states:

 

  1. Responsible Gaming Logo. The Footer of every Website page must be Geo-targeted to display a general Responsible Gaming Logo to Visitors of the site. Please see Exhibit A for a general Responsible Gaming Logo.

 

  1. Problem Gaming Disclaimer. The Footer of every Website page must be Geo-targeted to display the following Problem Gaming Disclaimer to Visitors of the site: “Gambling Problem? Call 1-800-Gambler.” Note, “Call 1-800-Gambler” must be hyperlinked to https://www.ncpgambling.org/.

 

  • All Other States Marketing Requirements.

 

  1. Marketing Content and Bonus Offers Prohibition. All forms of Marketing Content and Bonus Offers that promote licensed Operators are generally prohibited from being promoted to Visitors from any states not provided for in this Section VII. Visitors from all other states should only receive Geo-targeted Marketing Content and Bonus Offers for Operators that are permitted in the relevant state and for which we are licensed to promote. If you have questions regarding whether we are licensed in a state, please contact Legal. If you have questions regarding whether we are permitted to promote an Operator in a certain state, please contact our U.S. Partner Operations Manager, Marko Stojanovic.

  • U.S. COMPLIANCE GUIDELINES QUESTIONS.  

  • For any matters not specifically covered by these U.S. Compliance Guidelines please refer to the Better Collective Marketing Standards Handbook. If you have questions in regard to these U.S. Compliance Guidelines, please email [email protected] addressed to Legal or contact Legal via Slack channel #us-sites-compliance or  #sites-compliance (direct to @Eric Hornick or @Ana Dulovic).

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