Safer play policy

1. Purpose and status of this policy

1. 1.1This Safer Play Policy sets out the commitments of Williwaw Studios OOD (Виливау Студиос ООД), UIC/EIK 206530664, 51 Business Park Sofia, Building 11A, floor 4, Sofia 1766, Bulgaria (the Operator, we, us) in relation to age assurance, player protection and support signposting on stratosphynx.com (the Site).
2. 1.2The commitments in sections 4 to 8 are binding on the Operator and are enforceable as terms of the agreement described in the Terms and Conditions, into which this policy is incorporated by reference.
3. 1.3Nothing in this policy is medical, clinical, psychological or legal advice. The services listed at section 9 are independent of us and are the appropriate route for advice about a person.

2. This is not a gambling service

1. 2.1The Site offers free, browser-based simulations of online casino games: roulette, online pokies, card games, scratch cards and bingo. Each Board reproduces the published rules, probabilities and pay table of the format it simulates. The simulation covers the play only: no commercial feature of a gambling service is reproduced.
2. 2.2Every Board is played with a points counter. No money or money's worth is staked, no money or money's worth is won, and no prize of any kind is offered, paid or payable.
3. 2.3Because there is no consideration and no prize, the activity does not constitute a gambling service within the meaning of section 4 of the Interactive Gambling Act 2001 (Cth) of Australia, and does not constitute gambling under the gambling legislation of the Australian States and Territories, all of which require a stake, a prize, or both.
4. 2.4For the same reason the activity falls outside the Bulgarian Gambling Act, which requires a stake and a prize, and outside the corresponding legislation of Poland, Romania and Germany. The Operator holds no gambling licence in any jurisdiction and neither requires nor seeks one.
5. 2.5The Site does not accept deposits, does not process payments, does not operate a wallet, does not permit transfers between users and does not link to, promote, refer or introduce any operator that does. There is no affiliate arrangement of any kind.

3. Points have no value

1. 3.1Points are a scorekeeping number generated locally in your browser. They are not currency, not a voucher, not a token, not a security, not property, and not convertible into anything at all.
2. 3.2Points cannot be bought, sold, gifted, transferred, redeemed, exchanged, withdrawn or carried between devices, and they carry no expectation of value now or in the future.
3. 3.3Where a points balance runs out, the Site offers one free reset per browser and continues to work with no purchase and no waiting period, because there is nothing to purchase.

4. Age assurance

1. 4.1The Site is intended for adults aged 18 or over. Under-18s must not use it, and we do not knowingly permit them to do so.
2. 4.2A visitor is asked once to confirm they are 18 or over. The confirmation is a self-declaration, held only on the visitor's own device, and it is not verified against any identity document or database, because the Site collects no personal data with which to verify anything.
3. 4.3Because the declaration cannot be verified, the Operator additionally does not present the Site as a route to real-money play, does not advertise it on channels directed at children, and does not use characters, imagery or language of primary appeal to minors.
4. 4.4A parent or guardian who believes a minor has used the Site may write to [email protected]. Because nothing is transmitted to us, the effective remedy is the erasure control described at section 8, together with a device-level content filter.

5. Our design commitments

1. 5.1We publish the probabilities and pay tables of every board, computed from the same numbers the board itself uses, so that no visitor is invited to play on a mistaken idea of the odds.
2. 5.2We do not use loss-chasing prompts, countdowns to a lapsing offer, artificial scarcity, streak pressure, notifications to return, or any mechanic whose purpose is to extend a session beyond the point the visitor chose.
3. 5.3We do not offer, and will not offer, bonuses, deposits, top-up purchases, loot boxes, paid continues, or any other mechanic that converts attention into a payment.
4. 5.4We do not run advertising on the Site, and we do not permit third-party advertising on it. Nothing on the Site profiles a visitor for any purpose.
5. 5.5Where a board reproduces the rules of a well-known format, it does so accurately and states its own long-run return in the guide for that board, including where that return is below the entry total.

6. Recognising a problem

1. 6.1The mechanics used here are the same ones used by formats that do involve money: a fast result, a variable reward, and a near miss that reads as progress. They hold attention just as effectively when nothing can be lost, which is why the following are worth taking seriously here as well.
2. 6.2
   • You keep going after you meant to stop, repeatedly, and the stopping point keeps moving.
   • You think about the next session while you are meant to be doing something else.
   • You feel irritated or flat when you cannot play, and relieved rather than pleased when you can.
   • You have started looking for the same mechanics somewhere that does involve money.
   • You hide how much time you spend, or you round the number down when asked.
   • Sleep, work, study or people have moved down the list to make room for it.
3. 6.3If any of these describes you, the services at section 9 will speak to you about it whether or not money is involved, and none of them requires you to give a name.

7. Practical limits that work

1. 7.1
   • Set the length of a session before it starts, using a timer that is not on the same screen.
   • Take a full day off. If a full day is difficult, that difficulty is the useful piece of information.
   • Keep it out of the hours where it displaces something: not the last thing at night, not the first thing in the morning.
   • Tell one person how much time you are spending. Saying the number out loud is usually more effective than any setting.
   • Block the Site in your browser or on your device for a period. Nothing here requires an account, so nothing is lost when you come back.
   • If you notice yourself looking for real-money versions, treat that as the moment to make the call rather than a moment to decide later.
2. 7.2The Operator will not attempt to reverse, discourage or delay any of these steps, and will not contact a visitor to bring them back, because it has no means of contacting anyone.

8. Self-exclusion equivalent and erasure

1. 8.1A conventional self-exclusion register cannot exist here, because there is no account on our side and no identity to register. The equivalent measures available to you take effect immediately and without our involvement.
2. 8.2The Cookie Policy page lists every item the Site writes to your device and carries a control that erases all of them and reloads, returning the Site to the state of a first visit, including the points counter and any local account.
3. 8.3A device-level or browser-level block of stratosphynx.com is fully effective, because the Site holds no server-side state that could survive it. We commit not to circumvent, detect or work around such a block.
4. 8.4If you would like written confirmation that we hold no account and no record for you, write to [email protected] and we will confirm in writing.

9. Free and confidential support

1. 9.1The following services are free, independent of the Operator, and staffed by people who work with compulsive play whether or not money is involved. None of them requires you to give a name.
2. 9.2

   Country	Service	Telephone
   🇦🇺 Australia	Gambling Help Online	1800 858 858
   🇬🇧 United Kingdom	GamCare	0808 8020 133
   🇧🇬 Bulgaria	Nadezhda Center	02 981 90 40
   🇵🇱 Poland	Uzależnienia Behawioralne	801 889 880
   🇷🇴 Romania	Joc Responsabil (ONJN)	0800 800 099
   🇩🇪 Germany	BZgA	0800 137 27 00

3. 9.3In an emergency, or where there is an immediate risk to a person, contact your local emergency number rather than any of the services above.

10. Communications and marketing standards

1. 10.1The Operator does not send marketing email, push notifications, SMS or any other unsolicited communication, and holds no mailing list. The unsubscribe page exists so that anyone who believes they have been contacted in our name can tell us and be given a written confirmation.
2. 10.2Where the Operator advertises the Site, it does so without any claim of winnings, prizes, payouts or earnings, without any suggestion that play is a way to make money, and without targeting an audience defined by age below 18 or by an interest in real-money gambling.
3. 10.3We do not use testimonials, endorsements, invented winners or fabricated results in any material. Any figure we publish about a board is computed from that board's own configuration.

11. Complaints and enforcement of this policy

1. 11.1If you consider that the Operator has departed from any commitment in this policy, write to [email protected] with the page and a description. We will answer in writing within thirty days.
2. 11.2A complaint about the handling of personal data may be made under the Privacy Policy, including to the Bulgarian Commission for Personal Data Protection and, for visitors in Australia, to the Office of the Australian Information Commissioner.
3. 11.3Nothing in this policy excludes or limits any right you hold under mandatory consumer law in the country where you live, including the Australian Consumer Law in Schedule 2 to the Competition and Consumer Act 2010 (Cth).

12. Review and contact

1. 12.1This policy is reviewed at least once a year and whenever a change is made to the Site that affects any commitment in it. The version date appears at the head of this page.
2. 12.2General and contractual questions: [email protected]. Questions about personal data: [email protected]. Postal address: Williwaw Studios OOD (Виливау Студиос ООД), UIC/EIK 206530664, 51 Business Park Sofia, Building 11A, floor 4, Sofia 1766, Bulgaria.