Terms & Conditions
Club AXO LLC · Effective July 24, 2026 · 21+ · Play Responsibly
These Terms & Conditions (the "Terms") form a binding agreement between you and Club AXO LLC ("Club AXO," the "Company," "we," "our," or "us") and govern your access to and use of the Club AXO website, mobile applications, games, and related services (together, the "Platform"). By creating an account, accessing, or using the Platform, you agree to these Terms and to our Sweepstakes Rules, Privacy Policy, and Responsible Gaming Policy, each of which is incorporated into these Terms by reference. If you do not agree, please do not use the Platform.
The Platform operates a no-purchase-necessary promotional sweepstakes model and is intended for entertainment only — it is not real-money gambling. Please read these Terms carefully. They explain who may use the Platform, how we verify your identity, how our two virtual currencies work, how redemptions and prizes are handled, what conduct is prohibited, and how disputes are resolved.
1. About the Platform
Club AXO offers social casino-style games played with two separate virtual currencies: Gold Coins, which are for entertainment only, and Sweeps Coins, which can be obtained free of charge and, once played, may be redeemed for prizes where permitted. The Platform is a promotional sweepstakes: no purchase is ever necessary to obtain Sweeps Coins or to redeem a prize, and a purchase will not improve your chances of winning.
These Terms work together with the other policies published on the Platform. Where a topic is covered in more detail by our Sweepstakes Rules, Privacy Policy, or Responsible Gaming Policy, that policy applies alongside these Terms.
2. Eligibility
To use the Platform, you must meet all of the following requirements at all times:
- You are at least 21 years old. We verify age at registration and cannot make exceptions; anyone under 21 is prohibited from using the Platform.
- You are physically located in, and a legal resident of, a U.S. jurisdiction where we are permitted to operate.
- You are not located in an excluded state. Sweeps Coin play and redemption are not available in California, Connecticut, Idaho, Indiana, Louisiana, Maine, Michigan, Montana, Nevada, New Jersey, New York, Tennessee, and Washington — and, beginning November 1, 2026, Oklahoma.
- You are accessing the Platform for yourself, using your own identity and your own payment methods, and you maintain only one account.
- You are not on any applicable government sanctions or restricted-persons list, and you are not accessing the Platform from a sanctioned country.
- You are not an employee, officer, contractor, or immediate family member of the Company where participation would create a conflict of interest.
We may add jurisdictions to the excluded list at any time to comply with changing law. Eligibility is a continuing requirement: if you cease to meet it, your access may be suspended or closed.
3. Your Account and Account Security
When you register, you must provide accurate and complete information, including your full legal name, date of birth, residential address, email address, and phone number, and you must keep this information up to date. You are responsible for maintaining the security of your account and for all activity that occurs under it. You may hold only one account, and you may not share it, sell it, or let anyone else use it. Please notify support immediately if you suspect unauthorized use of your account.
Disposable email addresses and internet-based (VOIP) phone numbers may be flagged for additional review, so please register with contact details that genuinely belong to you.
4. Identity Verification (KYC)
We are required by law, and by our banking and payment partners, to confirm that every player is who they say they are, is old enough to play, and is located where we are permitted to operate. We perform identity verification through our verification provider, MojoVerify LLC ("MojoVerify"), which carries out these checks on our behalf.
Basic verification at registration. When you create an account, we automatically check the details you provide — for example, confirming your age and validating your address and contact information. Basic verification must be completed before you can make your first Gold Coin purchase. If something cannot be matched automatically, we may ask you to confirm or re-enter information.
Enhanced verification before redemption. Before you can redeem Sweeps Coins for a prize, you complete a one-time enhanced verification step. This typically requires a valid, unexpired government-issued photo ID (such as a driver's license, state ID, or passport); a live selfie, which we use to confirm that the live person matches the photo on the ID; and your Social Security Number or ITIN (in full or in part, depending on what we request). You generally only need to do this once, unless your information changes. If enhanced verification is not completed, we cannot release a redemption.
Additional documentation. From time to time we may ask for additional documentation — for example, proof of address, or information about the source of the funds behind a larger or unusual transaction. This is a standard step, not an accusation of wrongdoing, and providing what we ask for promptly is the fastest way to keep your account moving. We may pause certain account features while we complete a review. Our collection and handling of verification information, including biometric information used for the selfie match, are described in our Privacy Policy.
5. Location and Geographic Restrictions
You may use the Platform only while physically located in a permitted jurisdiction. We check your location at registration, login, game launch, purchase, and redemption using data provided through MojoVerify. Using a VPN, proxy, or any other method to hide or misrepresent where you are is prohibited and may result in loss of access to your account and forfeiture of balances and prizes. Certain game types are not available in certain states, as described in Section 12.
6. Gold Coins and Sweeps Coins
The Platform uses two separate virtual currencies held in separate wallets. There is no crossover between them, and they cannot be transferred between players.
Gold Coins. Gold Coins are used to play games for entertainment only. They may be purchased or obtained through promotions, they have no monetary value, and they can never be redeemed for cash, prizes, or anything of value.
Sweeps Coins. Sweeps Coins cannot be purchased. You can obtain Sweeps Coins only by one of the following methods, each of which has the same value and the same odds: (a) as a free bonus that accompanies a Gold Coin purchase; (b) through a daily login bonus; (c) through promotions and giveaways; or (d) through our free postal request method (AMOE) — the mail-in instructions and the free postal request address are set out in the Sweepstakes Rules. Sweeps Coins must be played at least once before they become "Redeemable Sweeps Coins" that are eligible for redemption.
7. Purchases and Payments
You are never required to purchase anything to use the Platform. If you choose to buy Gold Coins, purchases are subject to a minimum of $10 and are processed by our third-party payment processor, Coinflow. By making a purchase you authorize the applicable charge and confirm that you are using a payment method that belongs to you. Prices and package contents are shown at the point of purchase and may change.
All Gold Coin purchases are final. Because Gold Coins have no monetary value and are delivered immediately, we do not offer refunds except where required by law. Initiating a chargeback or payment dispute in bad faith may result in account restriction, suspension, or closure and forfeiture of balances and prizes.
8. Anti-Money Laundering and Financial Crime
We maintain a formal, risk-based anti-money-laundering (AML) program, overseen by a designated Compliance Officer and supported by MojoVerify's screening infrastructure, and we apply the same standards to everyone, including players who take part only through free entry. Although the Platform is not real-money gambling, we take financial crime seriously, particularly at redemption — the point where value can leave the Platform.
Play with your own money and value. Fund your account only with payment methods that belong to you, and play and redeem for yourself — not on behalf of, or for the benefit of, anyone else. If a payment method or a pattern of activity does not appear to belong to the account holder, we may place a hold while we take a closer look.
Prohibited financial activity. The following are prohibited: money laundering (using the Platform to disguise, move, or cash out the proceeds of crime); structuring (breaking up purchases or redemptions to stay under our checks or reporting thresholds); third-party funding (depositing with, or redeeming to, accounts or payment methods that are not yours, or bankrolling someone else's play); collusion or value transfer (working with others, or using more than one account, to shift value between players or cash out on someone else's behalf); and automation or manipulation (using bots, scripts, or other tools to exploit gameplay, promotions, or redemptions).
Source of funds, monitoring, and sanctions. For larger or unusual activity, we may ask you to tell us — and sometimes to document — where your funds come from. We monitor account and transaction activity for signs of
fraud, money laundering, or other misuse using a combination of automated systems and human review, and we screen against government sanctions and politically-exposed-person lists. We are legally prohibited from doing business with sanctioned persons or from sanctioned locations.
Account action and reporting. Where we identify a real risk of financial crime or a breach of this section, we may restrict, suspend, or close an account (and any linked accounts) and withhold or forfeit balances, prizes, and pending redemptions. Where the law requires, we report suspicious activity to the appropriate authorities and cooperate with law-enforcement and regulatory investigations, and in some cases we are legally required to keep the details of a review or report confidential. We retain account, transaction, and review records for as long as the law requires, which for AML purposes is a number of years even after an account closes.
9. Redemptions
Redemption is available only for Redeemable Sweeps Coins — Sweeps Coins that have been played at least once. The following conditions apply:
- Minimum redemption: you must have a balance of at least $20 in Redeemable Sweeps Coins to request a redemption.
- Identity verification: you must complete the enhanced verification described in Section 4 before any redemption is released.
- Daily limit: redemptions are subject to a limit of $500 per 24-hour period. Higher limits may be available to certain verified accounts.
- Review and holds: we may place a redemption on a hold while we complete a routine identity, eligibility, or compliance review, and we may require an affidavit or declaration of eligibility. A first redemption, or a redemption that follows a recent purchase, may take longer while these checks complete.
- Payment: approved redemptions are paid out through our redemption provider, MojoWallet. Processing times vary by method.
Prize availability and limits vary by state; see Section 12. You are responsible for all taxes on prizes. Prize redemptions that reach the applicable annual threshold (generally $600 or more in a calendar year) may be reported to tax authorities, and we may be required to collect your Social Security Number or ITIN and to issue a tax form. Where required by law, we may also withhold a portion of a prize for federal or state taxes, including backup withholding if you have not provided a valid taxpayer identification number.
10. Prizes
Prizes are described at the time they are offered and are subject to verification. We may substitute a prize of equal or greater value where necessary, and a cash-equivalent alternative applies only where stated. If you do not meet the eligibility or verification requirements, or if you have breached these Terms, the prize and any related balances may be forfeited.
11. Prohibited Conduct
In addition to the financial-crime prohibitions in Section 8, you agree not to: provide false, inaccurate, or incomplete information; open or control more than one account, or help someone else evade our checks; use another person's identity, documents, or payment methods, or let anyone use yours; use bots, scripts, automation,
or exploit software errors; misrepresent or conceal your location, including through a VPN or proxy; or engage in collusion, fraud, harassment, intellectual-property infringement, or any unlawful activity on the Platform.
12. Game Availability and Prize Limits by State
Where required by state law, certain game types and prize amounts are restricted. In particular: in Florida, card games are not available and the maximum prize is $5,000; in Georgia, card games and live dealer games are not available; and in Hawaii and West Virginia, card games are not available. We enforce these restrictions by geography, and the games available to you may differ depending on where you are located.
13. Sweepstakes Nature; No Gambling
The Platform is a promotional sweepstakes offered for entertainment. No purchase is necessary to obtain Sweeps Coins or to redeem a prize, a purchase will not increase your chances of winning, and free entry through our postal method carries the same odds and redemption rights as any other method. Nothing on the Platform constitutes real- money gambling.
14. Responsible Gaming
We are committed to responsible play and provide tools to help you stay in control, including deposit limits, session time limits, spending alerts, reality checks, cool-off periods, and self-exclusion. These tools, and the support resources available to you, are described in our Responsible Gaming Policy. Attempting to circumvent a self-exclusion or other responsible-gaming control — for example, by opening additional accounts — is prohibited and may result in closure of all linked accounts and forfeiture of balances and prizes.
15. Intellectual Property
The Platform and all of its content — including software, games, graphics, text, logos, and the Club AXO name and marks — are owned by the Company or its licensors and are protected by intellectual-property laws. We grant you a limited, personal, non-transferable, revocable license to use the Platform for its intended purpose. You may not copy, modify, distribute, reverse-engineer, scrape, or create derivative works from any part of the Platform.
16. Third-Party Services
We rely on third-party providers to operate the Platform, including MojoVerify (identity verification, geolocation, and screening), Coinflow (purchase processing), MojoWallet (redemption payouts), and our game content providers. Your use of these services may be subject to their own terms. We are not responsible for the acts or omissions of third parties, though we remain responsible for our own obligations to you.
17. Suspension, Termination, and Forfeiture
We may suspend, restrict, or close your account (and any linked accounts) if you breach these Terms, if we are required to do so by law, or if we reasonably believe it is necessary to protect the Platform, our players, or our partners. Where a breach involves fraud, financial crime, prohibited conduct, or circumvention of our controls, we may withhold or forfeit balances, prizes, and pending redemptions. You may close your account at any time by contacting support; certain records are retained as required by law even after closure.
18. Disclaimers
The Platform is provided "as is" and "as available." To the fullest extent permitted by law, we disclaim all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, and non- infringement. We do not warrant that the Platform will be uninterrupted, error-free, or secure.
19. Limitation of Liability
To the fullest extent permitted by law, the Company will not be liable for any indirect, incidental, special, consequential, or punitive damages, or for any loss of profits, data, or goodwill, arising out of or relating to your use of the Platform. To the extent liability cannot be excluded, our total liability to you will not exceed the greater of the amount you paid to us in the six months before the event giving rise to the claim, or one hundred U.S. dollars ($100).
20. Indemnification
You agree to indemnify and hold harmless the Company and its officers, employees, and agents from any claims, losses, liabilities, and expenses (including reasonable legal fees) arising out of your use of the Platform, your breach of these Terms, or your violation of any law or the rights of any third party.
21. Dispute Resolution; Governing Law
These Terms are governed by the laws of the State of Wyoming, without regard to its conflict-of-laws rules. Except where prohibited by law, any dispute arising out of or relating to these Terms or the Platform will be resolved through binding individual arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, rather than in court, and you and the Company waive the right to participate in a class or representative action. You may opt out of this arbitration agreement by sending written notice to support@clubaxo.com within 30 days of first accepting these Terms; if you opt out, neither you nor the Company will be required to arbitrate. Nothing in this section prevents either party from seeking relief in small-claims court where available.
22. Changes to These Terms
We may update these Terms from time to time to reflect changes in our practices, industry standards, or legal requirements. Updated versions are published on the Platform and take effect upon publication unless we state otherwise. Your continued use of the Platform after an update means you accept the revised Terms.
23. Miscellaneous
If any provision of these Terms is found unenforceable, the remaining provisions remain in effect. Our failure to enforce a provision is not a waiver of it. You may not assign these Terms without our consent; we may assign them in connection with a merger, acquisition, or sale of assets. These Terms, together with the policies incorporated by reference, are the entire agreement between you and the Company regarding the Platform. We are not liable for failures caused by events beyond our reasonable control.
Contact
You can ask a question about these Terms, or about a hold or review on your account, at any time through your account settings or by contacting support at support@clubaxo.com.
Sweepstakes Rules
Club AXO LLC · Effective July 24, 2026 · 21+ · Play Responsibly
These Sweepstakes Rules govern the promotional sweepstakes offered on the Club AXO platform (the "Platform") operated by Club AXO LLC ("Club AXO," the "Company," "we," "our," or "us"). They should be read together with our Terms & Conditions, Privacy Policy, and Responsible Gaming Policy.
NO PURCHASE OR PAYMENT IS NECESSARY TO PARTICIPATE OR WIN. A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. VOID WHERE PROHIBITED.
1. Sponsor
The sponsor of the sweepstakes is Club AXO LLC. All questions or comments regarding the sweepstakes should be directed to support at support@clubaxo.com.
2. Eligibility
- You must be at least 21 years old.
- You must be a legal resident of, and physically located in, a U.S. jurisdiction where we are permitted to operate.
- Sweeps Coin play and redemption are not available in California, Connecticut, Idaho, Indiana, Louisiana, Maine, Michigan, Montana, Nevada, New Jersey, New York, Tennessee, and Washington — and, beginning November 1, 2026, Oklahoma.
- You must maintain only one account and participate only for yourself.
- Employees, officers, and contractors of the Company, and their immediate family members, are not eligible where participation would create a conflict of interest.
The sweepstakes is void where prohibited or restricted by law.
3. Promotion Period
The sweepstakes operates on an ongoing basis until modified, suspended, or ended by the Company. Individual promotions or giveaways within the Platform may have their own start and end dates, which will be disclosed at the time they are offered.
4. The Two Virtual Currencies
The Platform uses two separate virtual currencies. Gold Coins are used to play games for entertainment only; they have no monetary value and cannot be redeemed for prizes. Sweeps Coins cannot be purchased; they can be obtained free of charge by the methods below and, once played, may be redeemed for prizes where permitted.
5. How to Obtain Sweeps Coins
You can obtain Sweeps Coins by any of the following methods. Every method carries the same value, the same odds, and the same redemption rights:
- As a free bonus that accompanies a Gold Coin purchase;
- Through a daily login bonus;
- Through promotions, giveaways, and similar offers; or
- Through the free postal request method (AMOE) described in the next section.
6. Free Method of Entry (AMOE)
To request free Sweeps Coins by mail, hand-print the following on a standard 4″ × 6″ piece of plain white paper or card (unfolded and unlined): your full legal name, the email address and phone number associated with your account, your unique Club AXO player ID, and a statement requesting Sweeps Coins and confirming your acceptance of these Sweepstakes Rules and the Terms & Conditions.
Mail your request in a stamped #10 envelope to our postal request address:
Club AXO LLC — Sweeps Coins Request, 4145 Gessner Rd, Suite B, Mailbox #403, Houston, TX 77080
The following conditions apply:
- One request per envelope.
- Your request must be mailed from the same state as the residential address registered to your account.
- Requests are valid for 60 days from your last login.
- There is no limit on the number of requests you may submit.
- Each valid request receives Sweeps Coins in an amount determined by the Company.
- Requests are typically processed within 5 to 7 business days of receipt.
Sweeps Coins obtained by mail have the same odds and the same redemption rights as Sweeps Coins obtained by any other method.
7. Playing and Play-Through
Sweeps Coins must be played at least once before they become "Redeemable Sweeps Coins." Only Redeemable Sweeps Coins are eligible for redemption.
8. Redemptions
To request a redemption, you must have a balance of at least $20 in Redeemable Sweeps Coins and must have completed identity verification. Redemptions are subject to a limit of $500 per 24-hour period (higher limits may be available to certain verified accounts) and are paid out through our redemption provider, MojoWallet. We may place a redemption on hold while we complete an identity, eligibility, or compliance review, and we may require an affidavit or declaration of eligibility. Full redemption terms are set out in the Terms & Conditions.
9. Prizes
Prizes are described at the time they are offered. Prizes are non-transferable, and no substitution is permitted except by the Company, which may substitute a prize of equal or greater value. Where lawful, a winner may be required to complete identity verification and to sign an affidavit or declaration of eligibility and a liability and publicity release before a prize is awarded.
10. Odds
The odds of obtaining a prize depend on the number of eligible entries and on gameplay. The odds are the same across all methods of obtaining Sweeps Coins, including the free postal method.
11. Prize Limits and Game Availability by State
Where required by state law, certain prizes and game types are limited or unavailable. In Florida, the maximum prize is $5,000 and card games are not available. In Georgia, card games and live dealer games are not available. In Hawaii and West Virginia, card games are not available. The games and prizes available to you may differ depending on your location.
12. Taxes
Winners are solely responsible for all federal, state, and local taxes on prizes. Where required, prize redemptions that reach the applicable annual threshold (generally $600 or more in a calendar year) will be reported to tax authorities, and the Company may be required to collect your Social Security Number or ITIN and to issue a tax form. Where required by law, the Company may also withhold a portion of a prize for federal or state taxes, including backup withholding if you have not provided a valid taxpayer identification number.
13. Verification and Disqualification
The Company reserves the right to verify the eligibility of any participant and to disqualify any person who tampers with the operation of the sweepstakes, opens or controls multiple accounts, provides false information, or otherwise violates these Sweepstakes Rules or the Terms & Conditions. Any attempt to obtain Sweeps Coins or prizes through fraud may be referred to the appropriate authorities.
14. General Conditions
The Company reserves the right to modify, suspend, or cancel the sweepstakes, in whole or in part, at any time, including if fraud, technical failure, or any other factor impairs its integrity. To the fullest extent permitted by law, participants release the Company from any liability arising out of participation in the sweepstakes or the acceptance or use of any prize. Any dispute arising from the sweepstakes is governed by the dispute-resolution and governing-law provisions of the Terms & Conditions.
15. Privacy
Information collected in connection with the sweepstakes is handled as described in our Privacy Policy.
Contact
For questions about these Sweepstakes Rules, the free method of entry, or a redemption, contact the Sponsor at any time through your account settings or at support@clubaxo.com.
Privacy Policy
Club AXO LLC · Effective July 24, 2026 · 21+ · Play Responsibly
This Privacy Policy explains how Club AXO LLC ("Club AXO," the "Company," "we," "our," or "us") collects, uses, shares, and protects your personal information when you use the Club AXO platform (the "Platform"). It applies to all Users and works alongside our Terms & Conditions, Sweepstakes Rules, and Responsible Gaming Policy.
The Platform is intended only for individuals who are at least 21 years old and located in a jurisdiction where we are permitted to operate. By using the Platform, you agree to the practices described in this Policy.
1. Who We Are
Club AXO LLC is the controller of the personal information described in this Policy. You can reach us about privacy matters at support@clubaxo.com.
2. Information We Collect
Information you provide. When you register and use the Platform, we collect your full legal name, date of birth, residential address, email address, and phone number. To verify your identity and process redemptions, we collect government-issued identification, a live selfie, your Social Security Number or ITIN, and, where required, proof of address and source-of-funds documentation. We also collect the content of your communications with our support team.
Biometric information. As part of identity verification, we collect biometric information derived from your selfie and identification — such as facial-geometry data used for liveness detection and to confirm that the live person matches the photo on the ID. This is described in more detail in Section 4.
Payment information. When you purchase Gold Coins, your payment card and transaction details are collected and processed by our payment processor, Coinflow. When you receive a redemption, your payout details are processed through MojoWallet. We do not store full payment card numbers on our own systems.
Information collected automatically. When you use the Platform, we automatically collect device and browser information, IP address, device identifiers and fingerprint data, geolocation data, gameplay and transaction activity, and usage information, including through cookies and similar technologies.
3. How We Use Your Information
We use your information to: create and operate your account and provide the Platform; verify your identity, age, and location; process Gold Coin purchases and Sweeps Coin redemptions; detect and prevent fraud, money laundering, and other misuse; enforce eligibility, geographic restrictions, and our responsible-gaming controls; comply with legal, tax, and regulatory obligations; communicate with you about your account and provide support; improve and secure the Platform; and, where permitted, send you promotional messages (which you can opt out of at any time).
4. Biometric Information
We collect and use biometric information solely to verify your identity, confirm liveness, prevent fraud and duplicate accounts, and meet our legal and compliance obligations. This information is collected and processed on our behalf by our verification provider, MojoVerify, and your consent is obtained during the verification flow, which identifies Club AXO as the party on whose behalf the information is collected.
We do not sell, lease, or trade biometric information. The facial-geometry templates and liveness data used for the match are permanently destroyed once the verification decision has been completed. Any identity images retained as verification evidence are kept only as long as needed for the purpose for which they were collected and, in any event, are permanently destroyed no later than the timeframe required by applicable law — generally when the purpose has been satisfied or within three years of your last interaction with us, whichever occurs first — except for records we are required to retain for anti-money-laundering or other legal obligations.
5. How We Share Information
We share personal information only as needed to operate the Platform and meet our obligations, including with:
- Service providers that support the Platform — including MojoVerify (identity verification, biometric matching, geolocation, and fraud and sanctions screening), Coinflow (purchase processing), MojoWallet (redemption payouts), our game content providers, and our hosting, communications, and analytics providers. To perform identity verification, geolocation, and fraud prevention, we provide MojoVerify with identifying information together with device and network information, including your IP address and device fingerprint.
- Regulators, law-enforcement, tax authorities, and other government bodies where required by law or to protect our legal rights;
- Sanctions and politically-exposed-person screening services;
- State self-exclusion registries and a cross-platform self-exclusion network (through our verification provider), to enforce responsible-gaming exclusions; and
- A successor entity in connection with a merger, acquisition, or sale of assets.
We do not sell your personal information for money. Where certain sharing for targeted advertising is considered a "sale" or "share" under state law, you may opt out as described in Section 8.
6. Cookies and Tracking Technologies
We use cookies and similar technologies to keep you signed in, remember your preferences, secure the Platform, and understand how it is used. You can control cookies through your browser settings, and we honor recognized universal opt-out signals where required by law. Some features of the Platform may not function properly if certain cookies are disabled.
7. Data Retention
We keep personal information for as long as needed to provide the Platform and meet our legal obligations. Certain records must be kept longer: anti-money-laundering records are retained for at least seven (7) years, and limited identifying information tied to a self-exclusion is retained for as long as necessary to enforce that exclusion. When information is no longer required, we delete or anonymize it.
8. Your Privacy Rights
Depending on your state of residence, you may have rights under comprehensive state privacy laws (including the laws of California, Colorado, Connecticut, Virginia, and other states) to: access the personal information we hold about you; correct inaccurate information; request deletion; obtain a portable copy; and opt out of targeted advertising, the "sale" or "sharing" of your information, and certain profiling. You can exercise these rights by contacting us at support@clubaxo.com, and you can opt out of the "sale" or "sharing" of your personal information and of targeted advertising through the "Do Not Sell or Share My Personal Information" link in our website footer. You may appeal a decision if we decline a request, and we will not discriminate against you for exercising your rights.
Some information is exempt from deletion because we are legally required to keep it — in particular, anti-money- laundering records and self-exclusion identifiers. If you make a deletion request, we will complete a partial deletion and tell you which records are exempt and why.
9. How We Protect Your Information
We protect your information with appropriate technical and organizational safeguards, including encryption of data at rest (AES-256) and in transit (TLS 1.3), tokenization of payment data consistent with PCI DSS, multi-factor authentication for sensitive functions, and due-diligence and contractual safeguards with our vendors. If a data breach affecting your information occurs, we will notify you and the appropriate authorities as required by applicable law.
10. Children and Minors
The Platform is strictly for adults who are at least 21 years old. We do not knowingly collect personal information from anyone under 21. If we learn that we have collected information from a person under 21, we will close the account, void related activity, and delete the information except where we are required to retain it.
11. Third-Party Links and Services
The Platform may link to or integrate third-party websites and services that we do not control. Their handling of your information is governed by their own privacy policies, and we encourage you to review them.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Updated versions are published on the Platform and take effect upon publication unless we state otherwise.
Contact
To ask a question about this Privacy Policy or to exercise your privacy rights, contact us at any time through your account settings or at support@clubaxo.com.
Responsible Gaming Policy
Club AXO LLC · Effective July 24, 2026 · 21+ · Play Responsibly
This Responsible Gaming Policy describes the measures that Club AXO LLC ("Club AXO," the "Company," "we," "our," or "us") has put in place to support responsible participation on the Club AXO platform (the "Platform"). Its purpose is to help you keep your play fun and balanced, to give you real tools to manage your activity, and to make sure help is available if you ever need it.
The Platform operates a no-purchase-necessary promotional sweepstakes model and is intended for entertainment only — it is not real-money gambling. Even so, we recognize that some people can develop unhealthy patterns of play, and we provide the tools and resources in this policy to everyone who uses the Platform. This policy applies to all Users and forms part of the broader framework governing our services, alongside our Terms & Conditions, Sweepstakes Rules, and Privacy Policy.
1. Our Commitment
We are committed to providing a safe and responsible environment for all Users. We want you to treat play as a form of entertainment rather than a way to make money, and we do not encourage excessive play. Our responsible- gaming program is overseen by our Compliance Officer, our staff are trained to handle responsible-gaming requests promptly and without discouraging you, and we review the program — including confirming that self- exclusions were properly enforced — at least once a year.
2. Your Player Tools
You can manage your play at any time from your account settings. The tools available to you include:
- Deposit limits — set a maximum you can spend on Gold Coin purchases each day, week, or month. Lowering a limit takes effect immediately. Raising or removing a limit takes effect only after a 24-hour waiting period, during which you can cancel the change.
- Session time limits — set a maximum length for a single play session (for example, 30 minutes, 1 hour, 2 hours, 4 hours, or 8 hours). When you reach your limit, we notify you and prompt you to take a break or end your session.
- Spending alerts (where available) — choose to be notified when your spending crosses an amount you set. Alerts are reminders only; they do not block your play.
- Reality checks — on-screen reminders of how long you have been playing (see Section 6).
- Cool-off and self-exclusion — take a short break or a longer break from the Platform (see Sections 3 to 5).
You can view your active limits, any pending changes, and your responsible-gaming history at any time from your account.
3. Taking a Short Break (Cool-Off)
If you want a short break, you can start a cool-off of 24 hours, 48 hours, 7 days, or 30 days from your account settings or by contacting support. A cool-off starts immediately, and any active game session ends.
During a cool-off you cannot play or make purchases, but you can still log in, view your balances and history, complete a prize redemption, contact support, and change your responsible-gaming settings. A cool-off cannot be shortened or cancelled once it has started. Access returns automatically when the cool-off ends, and we will let you know.
4. Self-Exclusion
If you need a longer break, you can self-exclude for 6 months, 1 year, 5 years, or on a lifetime basis. Before it takes effect, you will be asked to confirm your choice and to acknowledge that a self-exclusion cannot be undone before it ends. Self-exclusion starts immediately, and any active game session ends.
5. What Self-Exclusion Does
While you are self-excluded, we lock your account against all play: you cannot log in to play, deposit, purchase, wager, or start a new redemption; your wallet is locked; and any open game sessions are closed. Any redemption you had already submitted before self-excluding will continue to be processed. You will still receive legally required communications (for example, identity-verification or tax notices), and you can contact support about your exclusion status or to ask for responsible-gaming help.
We will not reactivate your account early. A self-exclusion cannot be reversed, shortened, or paused before it ends, and no member of our staff, management, or leadership can override it. If you contact us asking to return early, we will provide problem-gambling support resources rather than reinstate your account.
When a self-exclusion ends. Timed exclusions do not reactivate automatically. After your exclusion period ends, you must contact support to reinstate your account, and a 24-hour waiting period applies before play or deposits resume. We will invite you to set responsible-gaming limits before you start again.
Lifetime self-exclusion. A lifetime self-exclusion permanently deactivates your account. Any remaining Gold Coin balance is forfeited, and any redeemable Sweeps Coin balance is processed for a final redemption, subject to identity checks. Reinstatement after a lifetime exclusion requires a written request, senior-management approval, and a 30-day waiting period.
6. Reality Checks
While you are playing, we show a reality-check reminder by default after 60 minutes of continuous play. You can set this reminder to appear more often — as frequently as every 15 minutes — but it cannot be turned off. Each reminder shows how long you have been playing, how much you have wagered, whether you are up or down, how many rounds you have played, and a support helpline. You will need to acknowledge the reminder to keep playing, and you can choose to take a break or set a limit instead.
7. How We Look Out for You
We monitor account activity for patterns that may signal that play is becoming harmful — for example, sharply increasing deposits, very long sessions, or repeated attempts to raise limits. Depending on what we see, we may
show you responsible-gaming information, reach out directly to offer help with setting limits, a cool-off, or self- exclusion, or place temporary limits or a mandatory cool-off on your account while we check in with you. These steps are overseen by our Compliance Officer and are recorded. We may also apply responsible-gaming restrictions to any account where we reasonably believe that continued unrestricted play risks harm.
8. Getting Help
If you feel your play is becoming a problem, help is available and confidential. You can reach any of these organizations at any time, whatever the status of your account. We also display "If you or someone you know has a gambling problem, call 1-800-GAMBLER" across the Platform, and we encourage you to reach out early.
- National Problem Gambling Helpline (operated by the National Council on Problem Gambling) — call or text 1-800-GAMBLER, available 24/7, or visit ncpgambling.org
- Gamblers Anonymous — gamblersanonymous.org
- SAMHSA National Helpline — 1-800-662-4357
- Crisis Text Line — text HOME to 741741
9. Marketing During a Break
While you are on a cool-off or self-exclusion, we suspend all promotional messages to you (email, push, SMS, and in-app). After a cool-off ends, promotional messages stay paused for a further 7 days before they resume. We will always still send you legally required messages, such as identity-verification, tax, security, or legal notices.
10. Age Protection (21+)
You must be at least 21 years old to use the Platform. We verify age during registration and prohibit anyone under 21 from participating. If we find that someone under 21 has accessed the Platform, we will permanently close the account, void all gameplay, refund all deposits to the original payment method, forfeit any winnings, Sweeps Coin balances, and pending redemptions, document and report the incident to the appropriate authorities, and review any linked accounts.
11. Responsible Promotional Practices
We work to ensure that our promotional materials, sweepstakes offers, and marketing communications are presented responsibly. Our promotions emphasize that the Platform is for entertainment, do not present play as a source of income, do not encourage excessive participation, and do not misrepresent the likelihood of winning a sweepstakes prize. All of our advertising carries "21+ Play Responsibly" and the problem-gambling helpline 1-800-GAMBLER, and we do not target promotions at people who are on a cool-off, are self-excluded, or have been identified as at-risk.
12. How We Keep and Protect Your Responsible-Gaming Records
We keep records of your responsible-gaming activity — your limits and changes to them, cool-offs, self- exclusions, reality-check history, and related account activity — for at least seven (7) years, as required by anti- money-laundering and gaming record-keeping rules. To make sure a self-exclusion cannot be bypassed by opening a new account, we keep certain identifying information, in secured and encrypted form, for as long as necessary to
enforce the exclusion, and we may check and share limited self-exclusion information with state self-exclusion registries and a cross-platform exclusion network through our identity-verification provider.
Because of these legal obligations, responsible-gaming and self-exclusion records are not eligible for deletion, even if you ask us to delete your other personal information, and an account with an active self-exclusion cannot be deleted. If you make a deletion request, we will tell you which records are exempt. Information that is not subject to these rules is handled as described in our Privacy Policy.
13. Enforcement and Circumvention
Trying to get around our responsible-gaming tools — for example, by opening multiple accounts to bypass a limit or exclusion, using someone else's identity or payment method, using a VPN or other means to evade our controls, or helping someone else do so — is prohibited. If we detect circumvention, we may suspend all linked accounts, forfeit balances, pending redemptions, and prizes across those accounts, and permanently close the accounts without reinstatement. Where circumvention suggests fraud or money laundering, we may file reports with the authorities and refer the matter to law enforcement.
14. Policy Enforcement
Violating responsible-participation standards or attempting to circumvent responsible-gaming tools may result in account restrictions, suspension, or termination in accordance with our Terms & Conditions and Sweepstakes Rules. We reserve the right to take any action we consider necessary to maintain a responsible environment for our Users.
15. Updates to This Policy
We may update or modify this Responsible Gaming Policy from time to time to reflect evolving industry standards, our operational practices, or legal requirements. We review it at least annually and whenever there is a significant platform or regulatory change. Updated versions are published on the Platform and take effect upon publication unless we state otherwise.
Contact
You can set limits, activate a cool-off, request self-exclusion, or find responsible-gaming resources at any time through your account settings or by contacting support at support@clubaxo.com.