Risk Management Toolkit

Below is a detailed look into our Risk Management Toolkit and associated policies.

Transactions

• Lucra monitors all deposits and withdrawals made on the platform and has a system set in place such that any transaction which is deemed potentially fraudulent is failed. The user who encounters a failed transaction will be prompted to contact our support team for assistance with the issue.

Deposits

• Lucra accepts deposits from credit card and direct from bank account. All deposits are instant, once they occur there is no waiting period. Once the deposit has been completed, the funds will be in the users account and available for them to use.

• Fees associated with deposits can be found below. By default, the user covers these fees. If you would like to adjust the fee the user covers by covering a portion yourself, please reach out to your Account Manager.

Transaction	Service Fee	Flat Fee
Deposit via Credit Card	1.5%	$0.20
Deposit via Bank Account	1.65%	$0.20

• Lucra limits the amount of funds being deposited into a user’s account to $500 per deposit, $3,500 per week, and $14,000 per month.

Withdrawals

• After a deposit, a user must play a contest before withdrawing funds.

• Withdrawal Types

  • ACH withdrawals are instant

  • Lucra uses Sardine, a transaction monitoring tool, to monitor withdrawals in real time.

    • If a transaction appears fraudulent, it will fail and the user will be flagged.

    • If a transaction is not fraudulent, it should complete immediately.

      • If the transaction is taking longer than expected, the user should reach out to our support team ([email protected]) so that we can investigate the issue.

• These policies are subject to change based on industry standards, best practices, and Lucra’s compliance.

Type of Transaction	Service Fee	Flat Fee
Withdrawal	None	$1.30

• Lucra limits the amount of funds being withdrawn from a user’s account to $500 per withdrawal.

Contests

• Lucra limits the amount of funds that a user can wager on a contest to $500 per contest.

• Why do we limit deposits/withdrawals/contests to $500 per transaction?

  • Our intention is to make this a friendly platform and larger amounts attract users that may try to take advantage of other users and the platform.

  • From a compliance perspective, these limits restrict risk and exposure for fraud and money laundering.

  • These limits are all subject to change but you would receive notification of any changes.

User Data Collection - What data do we collect?

KYC (Identity Verification)

• Users are asked to submit a few pieces of personal information (name, address, phone number, birthday) in the SDK so that Lucra can identify that they are a unique user. If they fail this process, they are allowed to try again and also allowed scan their ID and submit.

  • Most ID scans are processed by our automated systems. In the event our systems are unable to complete the process the scan may be put into a manual processing queue.

• This KYC process allows us to identify the user and ensure that their personal information is accurate and unique in our database. This process prevents users from creating multiple accounts with the same personal information.

• If a user already has an account on Lucra, they will create a new account on your platform and we will link these accounts behind the scenes. There is no work that is needed to be done by the user to attach their accounts on Lucra and your platform.

SSN

• Why does Lucra collect SSN from users?

  • We collect SSN from users before they withdraw funds due to tax reasons which can be found below under ‘Tax Reporting.’

  • We do not store users' SSN after initial collection.

  • More information about SSN collection can be found in Lucra’s Terms of Service.

• Tax Reporting - 1099 Creation

  • We collect the information for 1099 forms at withdrawal and may be required to submit it for tax purposes.

  • These purposes include users who have net winnings over $600 in a calendar year who will receive a 1099 in January of the following year. Users do not need to withdraw these funds to qualify.

• What data does Lucra save?

  • Lucra saves a user’s email, phone number, name, address, and date of birth during KYC verification

  • Lucra is required to re-verify users once a year. We will attempt to do so with the information already on record to minimize the impact to users but users may be required to update their information if we are not able to re-verify them.

User Suspensions

• Our policy is a strict one account per device and one account per user.

• Users can be suspended for any of the following reasons:

  • Operating multiple accounts on one device

    • This suspension will occur if there is more than one account logged in on a single device.

  • A single user creating multiple accounts (KYC Match)

    • This suspension will occur if a user attempts to make more than one account with the same personal information.

  • More than three failed credit card transactions in a period of seven days

    • Lucra has rules in place around credit card transactions where if the risk of the transaction indicates fraud after three attempts, the account will be suspended.

    • The most common reason for a failed transaction is a pickup card error which means the bank has declined the customer’s transaction. The user/customer needs to reach out to their bank and confirm that the charge is not fraudulent.

• Why are these policies important?

  • Ensuring that each individual user is unique prevents fraudulent activity that can involve a single user playing contests against themself so that they can eventually withdraw money won from promotions, contests, etc.

  • Operating multiple accounts on one device can allow a user to abuse promotions run by you and Lucra

  • Multiple accounts being operated on 1 device or a user having multiple accounts is a risk for money laundering and fraud.

  • Suspending users who have multiple failed credit card transactions protects from potential fraud and allows time for our team to investigate the cause of the transaction failures. We can then, depending on the findings of our investigation, inform the user of the best course of action.

User Blockages

• The following are potential reasons why a user can be blocked:

  • Collusion

  • Credit card fraud

  • Promotion abuse

• Users with a blocked status have been set to blocked manually which means that there was a level of account review done by Lucra and although we typically do not unblock these accounts, we will under certain circumstances.

Responsible Gaming

• Lucra also has a Responsible Gaming Policy where we allow users to self-limit their ability to play, deposit, and withdraw on the platform.

• More info about these policies can be found here: Responsible Gaming

Customer Support

• How will Lucra’s customer support work?

  • The SDK offers a way for us to expose our customer support in the app, which end users can access via their profile in the hamburger menu or by reaching out directly to [email protected]

  • See End User Support for more information.