Customer Care and Player Dispute Resolution Policy
Version 1.2 (SEP 2024)
1. Introduction
1.1. Background
This Policy (the “Policy) pertains to Section 24.02 of the current Operating Agreement (the “OA”) between iGaming Ontario (“iGO”) and High Flyer Casino and should be read in conjunction with that document as well as iGO’s Brand Guide Policy and Finance Policy. The CCDR Policy also complies with the AGCO Registrar’s Standards for Internet Gaming.

The OA establishes iGO’s oversight of customer care and dispute resolution (“CCDR”) and specifically requires that High Flyer Casino have processes and protocols in place to address and respond to Player Disputes. It also outlines reporting requirements for High Flyer Casino related to their CCDR program.

The intent of iGO’s CCDR Policy is to establish iGO’s expectations for what High Flyer Casino’s CCDR programs should contain, including providing recourse for Players who have serious concerns, allegations or disputes related to the products, services, or actions of an Operator.

Disputes related to routine transactional issues (e.g., game play, account status, player account management, payment issues, technical issues such as the site being down, games being down for maintenance etc.), are to be resolved directly by High Flyer Casino with the Player in accordance with the parameters established with this Policy.

Player allegations of serious concerns and Player Disputes brought forward to iGO will be reviewed and where appropriate, iGO will work with High Flyer Casino and the Player on remedies to achieve resolution.

iGO will not directly address concerns where the allegation is regulatory or criminal in nature and will refer these matters to the appropriate authorities.

The Policy does not change, diminish or otherwise modify any Operator Obligations as defined the OA, unless expressly provided.

Capitalized terms used in this Policy have the meanings provided within. Where no such definition is provided, the capitalized term will have the meaning given in the current OA.

1.2.Applicability
The Policy is applicable to High Flyer Casino and their employees who interact directly with Players. The CCDR Policy is also applicable to any third-party vendor and employees who are providing customer care and Player support services on behalf of High Flyer Casino.

1.3. Responsibilities
Upon launching in the regulated igaming market in Ontario, High Flyer Casino is able to demonstrate to iGO that it has CCDR resolution policies in place together with strong operating protocols and program methodologies. High Flyer Casino is aware that iGO may request documentation, details and reports in respect of any aspect of High Flyer Casino’s CCDR program. High Flyer Casino will provide requested information within 5 Business Days of iGO requesting documentation.

1.4. Governance Framework
For Player Disputes received by iGO that are related to routine and/or transactional issues

Players will be referred to High Flyer Casino if the High Flyer Casino CCDR process has not been initiated and/or followed to conclusion. Players should demonstrate good faith in working with High Flyer Casino.
In certain instances, the iGO Account Manager assigned to High Flyer Casino may reach out to High Flyer Casino to assist with resolution (e.g., too slow to resolve an issue, Player still not satisfied with resolution).
If a Player brings to iGO’s attention serious concerns, allegations or disputes related to the products, services, or actions of High Flyer Casino, iGO has implemented an operating framework that ensures appropriate escalation and prioritization of these complaints takes place.

In accordance with iGO’s Brand Guide Policy, High Flyer Casino has provided a link to iGO’s website. The iGO website will provide information and direction for Players, through a dedicated Player Complaints page, providing steps a Player can take to solve a Player Dispute, as well as how to contact iGO (e.g., by telephone or email) and submit Player Disputes for resolution. The iGO contact centre and website will require Players to provide a copy of the original complaint filed with High Flyer Casino along with the response and/or proposed resolution from High Flyer Casino. iGO will have dedicated staff who will be responsible for reviewing all Player Disputes received.

iGO’s review of Player Disputes will reflect the following non-exhaustive principles:

Disputes escalated to iGO will be reviewed with High Flyer Casino (as appropriate), unless directed otherwise by the Player.
iGO will refer complaints for regulatory matters to the Alcohol and Gaming Commission of Ontario (AGCO) (e.g., allegations of integrity, marketing complaints).
iGO will refer allegations of unlawful activity (e.g., fraud, theft) to the AGCO and/or the appropriate enforcement authorities.
For other Player Disputes that are not regulatory or do not involve allegations of unlawful behaviour, iGO may intervene if it deems it necessary. In such instances, iGO’s resolution of the Player Dispute will be binding on High Flyer Casino.
1.4.1 iGO’s Oversight Framework
High Flyer Casino must comply with their CCDR obligations established in the OA. The iGO Account Manager assigned to High Flyer Casino will work with High Flyer Casino when required to assist with Player Dispute resolution for those Player Disputes that are not resolved within the established Operator service standards, as described below.

2. High Flyer Casino Customer Care Dispute Resolution Program (CCDR)
2.1. Customer Care General Requirements
Information about the CCDR program and the Player Dispute process are readily accessible to Players at all times on High Flyer Casino’s Website.

Acceptance of Terms & Conditions:
All new account registrations require players to acknowledge and accept that they have reviewed Ellipse Entertainment Limited, Terms and Conditions that clearly outline the Player Dispute process. The date and time of initial acknowledgement and subsequent acknowledgments of updates is recorded and stored on the player account profile in the back-office system.

Any time the terms and conditions have a subsequent material change, the update will trigger a message to all players on their next login informing them that an update has been made to the terms and conditions. Players are required to acknowledge that they have reviewed the updated version of the terms and conditions. Only after the acknowledgement is registered, will the login be successful. No claim or dispute by a Player with regard to any bet, wager, or purchase of a game, including the outcome of such game, will be considered by High Flyer Casino if initiated more than 30 days following the date on which the game is completed.

Player complaints and Player Disputes must be recorded and addressed in a timely, fair, transparent, and appropriate fashion.

High Flyer Casino must have processes in place that ensure that all Player Disputes and complaints are reviewed and escalated to their relevant team(s) of customer support who are trained and knowledgeable to determine the validity of the complaint and who will take the necessary action to resolve the complaint within the established service levels.

2.2 Customer Care Player Disputes, Complaints and Escalated Matters
Players are provided with mechanisms to contact High Flyer Casino at any point with inquiries, issues and complaints relating to their player account, funds management or game play by using either our live chat mechanism or email.

High Flyer Casino service standards for CCDR across all player communication channels are listed below:

Live-Chat:
9AM EST - 1AM EST, 7 days per week and 365 days per year; Average Wait Times: within 15 minutes during operational hours.

Email:
Operational Hours: 24 hours per day, 7 days per week and 365 days per year; Average Response Times: Within 72 hours.

Live Agent Customer Support Centre:
Operational Hours: 9AM EST - 1AM EST, 7 days per week and 365 days per year;

High Flyer Casino will have in place varying methods to meet our service standards including player wait times to connect with Live Chat.

Submitting a Complaint:
Players are able to reach out to us on Live Chat or Email to make a complaint within 30 days of the issue.

Player complaint information:

Player’s Full Name
Player’s User Name
Full Details of complaint, including:

Date of issue
Time of issue
Game details (if applicable)
Employee details (if applicable)
A member of the Customer Support Team will be assigned to assess and respond to the issue within 72 hours. A response may be provided by email within 7 days. Note, that a resolution may take longer as the customer support team may have to reach out to other teams like technology, marketing, and business management for a resolution.

If resolution of the case takes longer than 7 days, the customer support team will provide an update on the status of the case and progress towards resolution every 7 days from then.

Public Complaints
Reports regarding any public complaints related to compliance with the Standards and Requirements or Player Disputes, including any actions taken to resolve the complaints, will be reported in accordance with iGaming Ontario’s Customer Care and Player Dispute Resolution Policy and the AGCO in accordance with the established notification matrix.

Escalation to Senior Management:
If a Player is unsatisfied with the Customer Support Team response, they can request the complaint be escalated to a Senior Manager for investigation and review. This can be viewed as High Flyer Casino’s final response to the issue.

Decision making process will:

a) Identify the facts and issues on which there is agreement and all issues in dispute. b) Allow either party to deliver relevant documents. c) Reference relevant written rules and regulations, under Ontario & Canadian law. d) Document key findings e) Document a final response (within an additional 7 days from the escalation date)

The High Flyer Casino Customer Care Policy allows players to contact us in a timely fashion with issues and complaints related to their player account, funds management, game play or any matter a player would like to discuss.

The AGCO shall be notified of any player complaints or disputes related to compliance with the AGCO Registrar’s Standards for Internet Gaming, in accordance with the established notification matrix. Player complaints, disputes and inquiries must be recorded and addressed in a timely, fair, transparent, and appropriate manner.

Relevant information about the AGCO shall be displayed and easily accessible to the player.

2.3 Customer Care Employee Training
High Flyer Casino has a comprehensive CCDR training program in place that is kept current and updated as required. All Player-facing staff are evaluated prior to interacting with Players on their training knowledge of the activities required to handle customer complaints and disputes and to ensure that documentation, follow-up, accountabilities and escalation as required, regarding customer care and player service standards are clear and followed.

The quality assurance (QA) program in place ensures reviews are completed on a selection of interactions across all Player-facing staff on an established cadence. The QA program is designed to ensure interactions with Players have been actioned in accordance with Operator-approved procedures. The Operator is to provide coaching and feedback to staff as required.

3. High Flyer Casino CCDR Program Reporting and Record Keeping
3.1. Regulatory Reporting
Regulatory Reporting
High Flyer Casino will provide iGO with a quarterly report on their CCDR program within 30 days of the end of each Quarterly Period as defined in the Finance Policy (“Quarterly CCDR Program Report”), specifically: Q1 April 1 to June 30; Q2 July 1 to September 30; Q3 October 1 to December 31 and Q4 January 1 to March 31.

Each report lists Player Disputes that High Flyer Casino was made aware of at least 90 days earlier and that are not resolved (“Unresolved Player Disputes”) and contain the following information:

Details of the Player Dispute
Age of the Player Dispute since initiation
For clarity, Unresolved Player Disputes include:

Player Disputes where iGO Account Managers are working together with High Flyer Casino on resolution
Player Disputes where High Flyer Casino has taken all possible steps to remedy the Player Dispute, but the Player is not satisfied with the remedies proposed by High Flyer Casino
Player Disputes pending litigation
The Quarterly CCDR Program Report will also include a status update on any previously reported Unresolved Player Disputes that have since been resolved that includes details of the resolution and outcome (“Resolved Player Disputes”).

iGO may require that High Flyer Casino provide further information related to Resolved or Unresolved Player Disputes and may intervene if required. In such instances, iGO’s resolution of the Player Dispute will be binding on High Flyer Casino.

3.2 Record Retention
Record Retention
Documentation, details, and reports in respect of any aspect of this CCDR program will be retained for a minimum of seven (7) years and provided to iGO if requested within five (5) business days of iGO’s request.