1. Introduction/Purpose
This Complaints Policy (“Policy”) sets out the procedures and standards by which Medium Rare N.V. (hereinafter “Stake” or the “Company”) receives, manages, and resolves complaints submitted by end-users in accordance with Article 5.3 of the National Ordinance on Games of Chance (“LOK”) of Curaçao and with the Provisional Online Gaming License Conditions of the Curacao Gaming Authority. This Policy applies to all complaints related to the player’s experience with any Game of Chance offered by the Company.
2. Scope of Policy
This Policy applies to Stake and specifically its Customer Support channels and teams and any other team which has direct or indirect contact with customers.
3. Submitting a Complaint
End-users may submit a complaint free of charge within six (6) months of the occurrence of the incident that gave rise to the complaint.
To submit a complaint, players have the option to request from support@stake.com, the official complaint form provided by the Company. This form complies with the Curaçao Gaming Authority (CGA) guidelines and must include the following:
Full name of the complainant.
Residential address and place of residence.
Date of the incident.
Factual description of the behavior or incident being complained about; and
Complaints must be submitted in English.
Alternatively, the complainant may submit their complaint through the various below channels:
If the information provided is insufficient to investigate the complaint, the Complaints Team will notify the player promptly and request additional information required to proceed.
4. Acknowledgment and Initial Response
Within one (1) week of receiving a complaint through either medium in Section 3, the Complaints Team will:
Send a written acknowledgment of receipt to the complainant
Provide a clear explanation of the complaints handling process
5. Compliance Handling and Decision
The Complaints Team will assess and investigate the complaint fairly and objectively.
Within four (4) weeks of receiving the complaint, we will provide the complainant with a written response, which will include:
If the complaint is not accepted for processing, the reason for this decision;
If the complaint is accepted for processing, a written final decision supported by relevant evidence and findings
If additional time is required due to complexity or unforeseen circumstances, the complaint response period may be extended once by up to four (4) additional weeks. In such cases, the complainant will be informed in writing of the extension and the reasons for it.
If the Complaints Team deem that the response time is required to be extended, they will raise this matter with their manager who will then determine the outcome of the complaint, based on the facts or escalate further.
If the complaint is deemed to be of a serious nature or a potential legal risk, the complaint/dispute will be escalated to the Legal & Compliance Team who will assess each case and decide the appropriate course of action.
6. Alternative Dispute Resolution (ADR)
If a complainant is dissatisfied with the Company's final decision on their complaint and has notified the Company of this, the complainant may refer the dispute to CADRE B.V. (“CADRE”), an independent alternative dispute resolution entity certified by the Curaçao Gaming Authority (CGA) under certification number CGA/ADR/2025/01.
A complainant may refer a dispute to CADRE by completing the Claims Form available at https://cadre.online or by email to operators@cadre.online if they wish to commence the alternative dispute resolution process in order to resolve the matter in dispute.
Before referring a dispute to ADR, the complainant must have completed the Company's internal complaints process under this Policy and received the Company's final decision. The ADR entity may decline to consider a dispute that has not been through the internal complaints process. In addition, a dispute is not admissible before CADRE if, among other things:
it is not referred to CADRE within one (1) year from the date on which the complainant first submitted the complaint to the Company;
the value of the claim is below USD 50 or above USD 500,000;
the dispute is being or has previously been considered by another ADR entity or by a competent court or tribunal;
the complainant is below the age of 18 and is not represented by a parent, guardian or lawyer; or
the complainant does not submit a complete Claims Form, or fails to submit missing information within fourteen (14) days of a request from CADRE. The full grounds of inadmissibility are set out in CADRE's Rules of Procedure.
In accordance with CADRE's Rules of Procedure and the agreement between the Company and CADRE, a decision issued by CADRE will be final and binding on the Company only if:
the dispute is admissible under CADRE's Rules of Procedure; and
the dispute relates to an issue with gameplay or the operations of games of chance on the platform; and
the claimed value of the dispute is less than USD 5,000 (or the equivalent in another currency).
Dispute resolution by CADRE is free of charge for the complainant, irrespective of the outcome. CADRE's fees are borne by the Company. Any costs the complainant incurs in obtaining independent advice or in being represented or assisted by a third party are borne by the complainant.
Decisions of CADRE that do not meet the conditions set out in Clause 6.4 constitute a non-binding proposed solution, which the Company will consider in good faith. Neither the referral nor the determination affects any right of the complainant to seek redress from a court of competent jurisdiction.
The complainant and the Company may each appeal a decision of CADRE to the CADRE Board within two (2) weeks of notification of that decision, on the grounds of substantial legal or factual errors. Pending the determination of an appeal lodged by the Company, the decision appealed against is not binding on the Company
In accordance with its Rules of Procedure, CADRE will use its reasonable best efforts to conclude the dispute resolution process within ninety (90) days of receiving the dispute and all other information relevant to enable the dispute to be processed. CADRE decides the dispute on the basis of the information submitted by the complainant and the Company and does not itself investigate the facts of the dispute.
Once the ADR provider has issued its decision, the matter may not be recommenced by the complainant or the Company with CADRE or any other ADR entity. Where a complainant discontinues the ADR process after it has commenced, the complainant is not entitled to file or submit the same dispute at a later date with CADRE or any other ADR entity. This Clause does not affect the complainant's right to seek redress from a court of competent jurisdiction.
The Curaçao Gaming Authority does not mediate in individual disputes between players and the Company.
If CADRE B.V. ceases to hold CGA certification or is removed from the CGA's list of certified ADR entities, the Company will engage a replacement certified ADR entity without delay, notify the CGA accordingly, and update this policy and the Company's terms and conditions.
Once a dispute has been referred to CADRE, the complainant and the Company will refrain from contacting each other in relation to the dispute, and all communication about the dispute will be channelled through CADRE. This does not restrict communications in the ordinary course of the account relationship, including communications required for regulatory, responsible gambling, anti-money laundering or account security purposes. Correspondence with CADRE is conducted by e-mail and in English.
The complainant and the Company are required to keep the details of the dispute and of any resulting decision confidential, save for any disclosure required by applicable law, by a court or by a competent regulatory authority, including disclosure by the Company to the Curaçao Gaming Authority. By referring a dispute to CADRE, the complainant consents to the transfer by the Company to CADRE of any data relevant to the dispute.
7. Reporting
The Company may be required to report on the outcome of a specific complaint. If required, the communications with the regulator will be handled by the Legal & Compliance team exclusively to maintain consistent communication.
8. Record Keeping
The Company maintains detailed records of all complaints for a minimum period of five (5) years. These records include:
A copy of the original complaint.
Correspondence with the complainant.
The final decision or outcome; and
Any escalation to ADR.
Records are stored securely and may be made available to the Curaçao Gaming Authority (CGA) upon request.