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Effective Date: June 16, 2026

Player Accounts, Misuse/Unauthorized Play, Advertising & Marketing Policy

Version 1.0
Effective Date: June 16, 2026
Website: SandmanSports.com

Document Information

Document Name Player Accounts, Misuse/Unauthorized Play, Advertising & Marketing Policy
Version 1.0
Effective Date June 16, 2026
Approved By Bill Sanders
Review Frequency Annual
Owner Sandman Sports, LLC
Classification Internal / Confidential

Purpose

The purpose of this policy is to establish procedures governing player accounts, account security, misuse prevention, unauthorized participation, advertising practices, and marketing compliance for Sandman Sports fantasy sports contests.

These policies are designed to protect contest integrity, ensure fair play, safeguard participants, and comply with applicable fantasy sports regulations and consumer protection laws.

Section 1 – Player Account Complaints and Response Procedures

Policy

Sandman Sports shall maintain procedures to receive, investigate, document, and resolve player complaints related to account activity.

Complaints may include:

  • Unauthorized access
  • Deposit disputes
  • Withdrawal disputes
  • Contest disputes
  • Account restrictions
  • Identity verification issues
  • Technical issues affecting gameplay

Procedures

Complaint Submission

Players may submit complaints through:

  • Customer support email
  • Website contact form
  • Support ticket system

Required information includes:

  • Player name
  • Username
  • Email address
  • Description of issue
  • Supporting documentation

Complaint Tracking

Upon receipt:

  • Complaint is assigned a case number.
  • Complaint is logged in the support system.
  • Date and time are recorded.
  • Status is monitored until resolution.

Investigation

Support personnel shall review:

  • Account activity
  • Login history
  • Contest records
  • Financial transactions
  • Technical logs

Resolution Timeframes

Sandman Sports shall:

  • Acknowledge complaints within 72 hours.
  • Resolve complaints within 10 business days whenever reasonably possible.

Documentation

All findings and resolutions shall be documented and retained.

Section 2 – Player Account Closure

Policy

Players may voluntarily close accounts at any time.

Sandman Sports may suspend or close accounts when required by law, regulation, or company policy.

Procedures

Player Requested Closure

Prior to closure:

  • Identity may be verified.
  • Active contests must be completed.
  • Available balances must be withdrawn.

Company-Initiated Closure

Accounts may be closed for:

  • Fraud
  • Multiple account violations
  • Underage participation
  • Identity verification failures
  • Terms of Service violations
  • Regulatory requirements

Closure Process

  • Access is suspended.
  • Investigation is completed.
  • Final balances are processed.
  • Closure reason is documented.
  • Fraud prevention records are retained.

Section 3 – One Active Account Per Player

Policy

Each player is limited to one active account.

Multiple accounts intended to gain a competitive advantage are prohibited.

Procedures

Duplicate Account Monitoring

Sandman Sports reviews:

  • Name matches
  • Date of birth matches
  • Email addresses
  • Phone numbers
  • Government ID records
  • Payment methods

Technical Monitoring

Systems monitor:

  • Device fingerprints
  • Browser signatures
  • IP addresses
  • Geolocation history

Enforcement

Potential duplicate accounts may be:

  • Restricted
  • Suspended
  • Investigated
  • Permanently closed

All findings shall be documented.

Section 4 – Player Identity Verification

Policy

All players must successfully complete identity verification prior to participating in paid contests.

Procedures

Information Collected

During registration:

  • Full legal name
  • Date of birth
  • Residential address
  • Email address
  • Telephone number

Electronic Verification

Sandman Sports utilizes approved identity verification providers to verify:

  • Identity
  • Age
  • Address
  • OFAC sanctions status

Enhanced Verification

Additional documentation may include:

  • Government-issued ID
  • Proof of address
  • Selfie verification

Accounts failing verification remain restricted until resolved.

Section 5 – Prevention of Minor Participation

Policy

Individuals under the minimum legal age may not participate in contests.

Procedures

Age Verification

Age is verified during registration using:

  • Date of birth collection
  • Identity verification services

Detection Controls

Monitoring includes:

  • Failed age verification
  • Identity mismatches
  • Reports from third parties

Enforcement

If underage participation is suspected:

  • Account is suspended immediately.
  • Investigation is initiated.
  • Contest access is removed.
  • Account is permanently closed if confirmed.

Section 6 – Account Monitoring and Misuse Prevention

Policy

Sandman Sports continuously monitors account activity to detect misuse, fraud, and unauthorized participation.

Administrative personnel review flagged activity daily.

Section 6.1 – Prevention of Proxy Server and VPN Use

Policy

Players may not use VPNs, proxy servers, TOR networks, or similar technologies to conceal their true location.

Procedures

The platform monitors:

  • VPN databases
  • Proxy databases
  • TOR exit nodes
  • Datacenter IP ranges
  • Rapid IP switching

Flagged accounts may be:

  • Restricted
  • Subject to additional verification
  • Suspended pending review

Section 6.2 – Location Verification

Policy

Players may only participate from approved jurisdictions.

Procedures

Location verification occurs through:

  • IP geolocation
  • GPS verification
  • Device location services
  • Wi-Fi triangulation

Checks occur:

  • Registration
  • Login
  • Contest entry
  • Risk-triggered events

Accounts failing verification may be restricted.

Section 6.3 – Prevention of Unauthorized Scripts

Policy

The use of bots, automation software, scripts, crawlers, or similar technologies is prohibited.

Procedures

Systems monitor:

  • Excessive request volume
  • Automated behavior patterns
  • API abuse
  • Browser automation indicators
  • Automated contest entry activity

Preventive measures include:

  • CAPTCHA
  • Rate limiting
  • Device fingerprinting
  • Behavioral analytics

Violations may result in permanent suspension.

Section 6.4 – Prevention of Preselected Teams and Automated Entries

Policy

Players may not use prohibited automated methods to generate entries or gain an unfair advantage.

Procedures

Monitoring includes:

  • Identical entry patterns
  • Repeated lineup structures
  • Bulk entry generation
  • Automated contest submissions

Confirmed violations may result in:

  • Entry disqualification
  • Contest forfeiture
  • Account suspension
  • Permanent account closure

Section 7 – Prevention of Unauthorized Play by Restricted Persons

Policy

The following individuals are prohibited from participating where required by law or company policy:

  • Employees
  • Officers
  • Directors
  • Contractors
  • Household family members of restricted persons
  • Professional athletes
  • Amateur athletes
  • Sports agents
  • Team employees
  • Referees
  • League officials

Procedures

Restricted Person Database

Sandman Sports maintains records of restricted individuals.

Screening

Registration information is screened against:

  • Employee records
  • Contractor records
  • Restricted participant lists

Ongoing Monitoring

Periodic reviews include:

  • Shared addresses
  • Shared payment methods
  • Shared devices
  • Identity matching

Enforcement

Violations may result in:

  • Suspension
  • Disqualification
  • Forfeiture of winnings
  • Permanent account closure

Section 8 – Advertising and Marketing Policy

Policy

All advertising and marketing materials must be truthful, accurate, and not misleading.

Sandman Sports shall not misrepresent:

  • Chances of winning
  • Number of winners
  • Contest payouts
  • Contest eligibility
  • Contest availability

Section 8.1 – Advertising Review Process

Procedures

Prior to publication, all advertising materials shall be reviewed by management to ensure:

  • Accuracy
  • Regulatory compliance
  • Consumer protection compliance
  • FTC compliance

Approval records shall be maintained.

Section 8.2 – Representations of Winning and Winners

Policy

Advertising must accurately represent:

  • Prize amounts
  • Number of winners
  • Winning opportunities
  • Contest outcomes

Procedures

Advertisements shall not:

  • Suggest guaranteed winnings
  • Exaggerate winning odds
  • Create unrealistic expectations

Acceptable Example: "Top 10% of entries receive prizes."

Unacceptable Example: "Everyone wins."

Section 8.3 – Representation of Chances of Winning

Policy

Any statement regarding winning probabilities must be factually accurate and supportable.

Procedures

Sandman Sports shall:

  • Base claims on actual contest structures.
  • Maintain documentation supporting any published odds or statistics.
  • Avoid misleading language regarding player success.

Section 8.4 – FTC Endorsements and Testimonials Compliance

Policy

Sandman Sports complies with the Federal Trade Commission's Guides Concerning Use of Endorsements and Testimonials in Advertising (16 CFR Part 255).

Procedures

Testimonials must:

  • Be genuine
  • Reflect actual experiences
  • Not be materially altered

Records supporting authenticity shall be maintained.

Section 8.5 – Winner Testimonials

Policy

When testimonials discuss winnings or financial success, Sandman Sports shall disclose when such results are not typical.

Required Disclosure

“This testimonial reflects an individual experience. Results are not typical and may vary based on skill, participation level, and other factors.”

Section 8.6 – Influencer and Affiliate Disclosures

Policy

Material relationships must be clearly disclosed.

Acceptable disclosures include:

  • #Ad
  • #Sponsored
  • Paid Partnership with Sandman Sports
  • Sponsored by Sandman Sports

Disclosures must be clear and conspicuous.

Section 8.7 – Employee and Contractor Endorsements

Employees, contractors, owners, and affiliates may not present themselves as independent users.

Any material relationship must be disclosed.

Example: "I am a contractor for Sandman Sports."

Section 8.8 – Social Media Compliance

All social media marketing must:

  • Comply with FTC disclosure requirements
  • Include sponsorship disclosures
  • Avoid misleading claims
  • Accurately represent contests

Section 8.9 – Prohibited Advertising Practices

Sandman Sports shall not:

Misrepresent Winning Opportunities

  • Guarantee winnings
  • Guarantee profits
  • Exaggerate success rates

Misrepresent Contest Availability

  • Advertise contests where unavailable
  • Misstate eligibility requirements

Target Minors

Marketing shall not be directed toward individuals under 18 years of age.

Misrepresent Predictive Models

Sandman EDGE AI models may not be marketed as guaranteed winners.

Required disclosure:

“Predictions and projections are generated using statistical and machine learning models and are provided for informational purposes only. Future outcomes are not guaranteed.”

Section 9 – Recordkeeping

Sandman Sports shall maintain records relating to:

  • Complaints
  • Account closures
  • Identity verification
  • Duplicate account investigations
  • Underage participation investigations
  • VPN and proxy investigations
  • Restricted participant investigations
  • Advertising campaigns
  • Testimonials
  • Influencer agreements
  • Marketing approvals

Records shall be retained for a minimum of five (5) years unless a longer period is required by law.

Section 10 – Compliance Oversight

The Chief Technology Officer acting as Compliance Officer is responsible for:

  • Policy administration
  • Investigation oversight
  • Compliance monitoring
  • Staff training
  • Regulatory updates
  • Record retention

Required Disclosure for All Contest Pages

Fantasy sports contests involve skill and competition. Winning is not guaranteed. Past performance does not guarantee future results. Prize availability, contest rules, and eligibility requirements apply. See Official Rules for complete details.

Approved By: Bill Sanders
Title:
Date: June 16, 2026
Next Review Date: June 2027

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