1. About this Policy
- 1.1
This Complaints policy (the "Policy") explains how you can tell us that something has gone wrong with the Service, how we look into what you tell us, how we decide what to do about it, and what you can do if you disagree with our decision. It governs every Complaint we receive on or after its effective date.
- 1.2
This Policy forms part of the Terms of service (the "Terms") under clause 1.2 of the Terms. Capitalized words that the Terms define, such as Account, Balance, Bet, Business Day, Deposit limit, Game Aggregator, Maximum Payout, Recorded Debt, Round, Seeds, Skins, Step-up Check, Support, Time limit, Verification Level, Verifier and Wagering Requirement, carry the same meanings in this Policy. Section 2 defines the further words this Policy uses.
- 1.3
For the purposes of clause 1.3 of the Terms, this Policy states expressly that it overrides clauses 21.1 to 21.6 of the Terms to the extent that they concern how a Complaint is made, investigated, answered or reviewed, including the time within which a Complaint must be made. On every other matter, including governing law, the courts, the limits of our liability and the time limit for bringing a claim, the Terms prevail.
- 1.4
Every Complaint is answered by the Operator, 3-102-136856 Limitada, trading as Peeks Entertainment Limitada, a company organized under Costa Rican law with corporate identity number (cédula jurídica) 3-102-136856, whose registered address is Provincia 06 Puntarenas, Canton 11 Garabito, Jaco, Costado Este De La Municipalidad Garabito, Bufete Sanchez Chavarria, 61101, Costa Rica. The Operator stays answerable to you even where the Complaint concerns a part of the Service supplied by the Game Aggregator, a Studio, AssetPay, Steam or another provider. In that case we take the matter up with the provider ourselves, and you need not contact the provider unless this Policy says so.
- 1.5
The Operator holds a municipal commercial license for data processing activities, described in clause 3.2 of the Terms and on the Company and license page. That license is not a gambling license, and no gaming authority supervises the Games or hears complaints about them. Section 14 explains the routes that stay open to you outside this Policy.
- 1.6
We handle Complaints in English. Where a member of our staff can correspond in your language, we may do so, but each Written Answer and each Review Decision is issued in English, and if a translation differs in meaning from the English text, the English text prevails.
- 1.7
Making a Complaint and asking for a Review are free. We charge no fee at any stage, and we take nothing from your Balance because you have complained. Costs you choose to incur yourself, such as the fees of a lawyer or another adviser, remain yours unless a court orders otherwise or Applicable Law requires us to bear them.
- 1.8
Nothing in this Policy takes away or limits a right that you have under Applicable Law and that no agreement can exclude or restrict.
- 1.9
You may save or print this Policy at any time. On request to Support, we will send you the version that was in force on a date you name.
2. Definitions and interpretation
- 2.1
In this Policy, the following words have the meanings set out below:
- "Complainant" means the person who makes a Complaint under section 4 and, where the context allows, a Representative acting for that person.
- "Complaint" means a statement made to us, through a channel this Policy lists, that you are dissatisfied with the Service, with an Event or with our conduct, and that you want us to look into it or put it right.
- "Complaint Record" means the record of a Complaint that we keep under section 15.
- "Event" means the act, omission, Bet, Round, result, Deposit, Withdrawal, Tip, Network Check, restriction, decision or other matter that a Complaint concerns.
- "Formal Complaint" means a Complaint made under section 6.
- "Handler" means the member of our staff to whom we assign a Formal Complaint under clause 7.4.
- "Reference" means the identifier we give a Formal Complaint in our acknowledgment under clause 7.1, which you quote in every later message about it.
- "Remedy" means any step we take under clause 9.8 to put an Event right.
- "Representative" means a person who makes or pursues a Complaint for another person under clause 4.5, 4.6 or 4.7.
- "Review" means the examination of a Formal Complaint by a Senior Reviewer under section 10.
- "Review Decision" means the written decision of a Senior Reviewer at the end of a Review.
- "Round Seed" means the secret value generated for a single Round of Crash, as the Fairness policy describes.
- "Safer Play Complaint" means a Complaint described in clause 11.1.
- "Senior Reviewer" means a person appointed under clause 16.1 to carry out Reviews.
- "Support Request" means a chat with Support on the Site, whether you are logged in or chat as a guest, or an email to support@peeks.gg.
- "Written Answer" means our written decision on a Formal Complaint under section 9, and includes a notice under clause 9.5.
- 2.2
Clause 2.2 of the Terms applies to this Policy. In particular, days are calendar days unless Business Days are stated, and times are in Coordinated Universal Time (UTC).
- 2.3
A message reaches us on the day our systems receive it. When this Policy counts a period in Business Days, the day the message reached us is not counted, and a message that arrives on a Saturday, a Sunday or a Costa Rica public holiday is treated as having reached us on the next Business Day. When this Policy counts a period in days, the period starts on the day after the message reached us.
- 2.4
3. Our commitments
- 3.1
We decide each Complaint on its facts, on the evidence and on the rules that applied at the time of the Event. The size of your Balance, how much you have played and the way you express your Complaint do not affect the outcome.
- 3.2
You will not be treated less favorably because you have made a Complaint, asked for a Review or brought a claim against us. We do not restrict an Account, reduce a limit, delay a Withdrawal or close an Account because its holder has complained. A step that we take for a separate reason permitted by the Terms or by clause 7.10 is not a penalty for complaining, and where we take one while a Complaint is open, we tell you the reason unless clause 8.22 or clause 8.23 applies.
- 3.3
We look at the records we hold before we decide, and we do not rely on assumptions where a record exists. Each Written Answer tells you which records and which evidence we examined.
- 3.4
Every Written Answer and every Review Decision gives its reasons. Where we rely on a clause of the Terms, a Policy or the rules of a Game, we name it.
- 3.5
We decide like cases in the same way. Where a decision departs from the way we decided a comparable Complaint before, the Handler records the reason for the difference in the Complaint Record.
- 3.6
If a disability, a health condition or another circumstance makes it hard for you to use the usual channels, to meet a time limit in this Policy or to follow written correspondence, tell Support. We can give you more time, deal with a Representative, write shorter messages or communicate in another way that suits you, and we record the arrangement so that you do not need to explain it again.
- 3.7
We use the information in a Complaint to investigate and answer it, to meet our duties under Applicable Law and to improve the Service, as the Privacy policy explains, and for no other purpose.
- 3.8
We ask only for the information, evidence and checks that a Complaint needs. Where a Complaint does not concern identity, a Withdrawal, the security of an Account or a change to its details, a message from a logged-in session or from the Account's email address is enough for us to proceed. We ask for a document under clause 5.8 only where we cannot otherwise be confident that we are dealing with the holder of the Account or a Representative.
4. Who may complain, and about what
- 4.1
Many concerns are questions that Support can answer at once, such as how to check a result, when a pending Deposit will land or why a Game is not available. Support handles those as Support Requests under section 5. A concern becomes a Complaint when you tell us that you are dissatisfied with what happened, or with our answer, and want us to look into it or put it right. If you are unsure, say that you are making a Complaint, and we will treat your message as one.
- 4.2
- 4.3
You may make a Formal Complaint without first going through Support where your Complaint concerns the conduct of a member of Support staff or the way Support dealt with you, where you suspect that someone else has used your Account, where Support has not answered your Support Request within 5 Business Days, or where your Complaint is a Safer Play Complaint. In any other case, Support will first try to settle the matter as a Support Request, and the periods in sections 7 and 9 start on the day Support tells you that it cannot settle it or you tell Support that you are not satisfied with its answer.
- 4.4
The following may make a Complaint:
- the holder of the Account that the Event concerns;
- a person who used the Site without an Account, about an Event that affected that person on the Site, such as a block by the Network Check at sign-up or the handling of a guest chat;
- a person who shows that an Event on the Service directly affected them although they never used the Service, such as the owner of Skins or of a Steam account that someone else used to make a Deposit, in which case we discuss with that person only the part of the Event that concerns them and nothing else about another person's Account;
- a person whose personal data we hold, about our use of that data, under section 12; and
- a family member, a friend or another person concerned about the gambling of a player, under clause 11.8, although we cannot discuss that player's Account with them except as clause 4.7 allows.
- 4.5
You may make or pursue a Complaint through a Representative, such as a lawyer, a family member or a person who helps you because of a circumstance described in clause 3.6. The Representative must give us your written authority, signed and dated by you, that names the Representative and describes the Complaint. We check the identity of both you and the Representative before we discuss your Account. We may contact you directly to confirm the authority, and unless you tell us otherwise in writing, we send each Written Answer and each Review Decision to you as well as to the Representative.
- 4.6
Where the person who could make a Complaint has died or has lost legal capacity, the person entitled to act for them or for their estate under clause 16.16 of the Terms may make or pursue it as their Representative. In place of the written authority in clause 4.5, that person gives us the documents we ask for to show the death or the loss of capacity and their own entitlement, such as a death certificate, a court order or a decision in the estate proceedings that names them, or a power of attorney that is still in force. A claim that passes to an estate by operation of law is not a transfer for the purposes of clause 4.8.
- 4.7
A parent or legal guardian may make a Complaint as Representative for a person under 18 who used the Service, or whose Skins or Steam account were used for a Deposit, once the parent or guardian has given us proof of the child's age and of their own parental authority or guardianship. Clause 11.8 does not prevent us from discussing that Account with the parent or guardian as far as the Complaint requires. The Account is dealt with under clause 22.5 of the Responsible gambling policy and clause 14.3 of the Identity verification policy, and any amount due is paid as those clauses provide. Where the child used an adult's Account, the holder of that Account may also complain, and clause 22.7 of the Responsible gambling policy continues to apply to the holder.
- 4.8
A Complaint, and any claim to which it relates, is personal to you. As clause 22.2 of the Terms provides, you may not transfer your rights to another person, so you may not sell or assign a Complaint or a claim, and we do not deal with a person who has bought or taken over a claim against us.
- 4.9
You may complain about any part of the Service, including:
- the acceptance, settlement or result of a Bet, including the Maximum Payout and any automatic cash-out;
- an Original or a Studio game, its rules, its display or its availability;
- a fault, error or outage of the Site that affected a Bet, your Balance, a Deposit, a Withdrawal or your use of a safer play tool;
- an entry in your Balance, in your Vault or in your history of Tips;
- a Deposit, a Withdrawal, a Wagering Requirement, a Skins trade, a Trade hold, a price, a reversal or a Recorded Debt;
- a Network Check, a block, or a decision about your location;
- an identity check, or a request for documents;
- the security of your Account, a login, a session or two-step login;
- a restriction, suspension or closure of your Account, a void Bet or the removal of Winnings;
- a Deposit limit, a Loss limit, a Daily stake limit, a Time limit, a Session reminder, a Play break or a Self-exclusion;
- a barrier that stops you from using the Site with a disability or with assistive technology, as the Accessibility statement describes;
- the conduct of our staff, or the way Support dealt with you;
- the use of your personal data; and
- the wording of the Site, the Terms, a Policy or the rules of a Game, where you say that it misled you.
- 4.10
The following are not Complaints under this Policy, although you may still raise them with Support:
- suggestions and feedback about features, design or the Games we offer;
- disputes between players, including any arrangement made between players inside or outside the Service, to which clause 10.7 of the Terms applies;
- reports that another player is cheating or otherwise breaking the Terms, which Support deals with under clause 14.7 of the Terms without the procedure in this Policy;
- matters that concern only the services of a third party and not the Service, such as a restriction that Valve places on your Steam account, which you must raise with that third party;
- requests to change the Terms, a Policy or the rules of a Game, unless you say that the existing wording misled you;
- a dispute under a separate contract with us, such as a supply, partnership, content or employment contract, which that contract governs, and a claim about intellectual property or a domain name, including a notice under clause 17.8 of the Terms that material on the Site infringes your rights;
- a report of a security weakness, which sections 17 and 18 of the Security policy govern, although you may complain under this Policy about the way we handled your report; and
- matters already decided by a court in proceedings between you and us.
- 4.11
We may deal together with several Complaints that concern the same Event, or with Complaints from several players about the same fault. Each Complainant still receives a separate Written Answer about their own Account. You may describe a series of connected Events, such as several Bets affected by the same fault, in one Formal Complaint. We may divide a Complaint that raises unrelated matters into separate Formal Complaints, each with its own Reference, and we tell you when we do.
- 4.12
If you start a claim before a court, or an arbitration, about an Event that an open Complaint concerns, tell us. We may then pause the Complaint, or close it and deal with the matter in those proceedings, and we tell you in writing which we have done. While the proceedings run, we may correspond with you about the claim through your lawyer or as the court or the arbitrator directs, but our usual messages about your Account continue, including those about safer play, security and identity checks. If the proceedings end without a decision on the merits, you may reopen the Complaint within 30 days of their end or within the period in clause 6.3, whichever ends later. A complaint to a public authority under clause 12.3 or clause 14.6 does not pause or close a Complaint unless the authority asks us to.
- 4.13
We may decline to investigate a message that identifies no Event, that is sent in bulk or by automated means, that repeats a Complaint we have already answered without raising anything new, or whose only purpose is to harass a member of our staff or to obtain money by threats. We record each such decision and tell the sender in writing, with the reason, and clause 9.5 applies to that notice. We never decline a Complaint because of its tone, as clause 13.1 provides, or because it is short or badly expressed, and where we cannot tell what a message is about, we ask.
5. Stage 1: Support
- 5.1
Support can settle most problems quickly, because the member of staff who answers your Support Request can see the records of your Account. Contact Support first, unless clause 4.3 allows you to go straight to a Formal Complaint.
- 5.2
If you can log in, open a chat from the Support page. You may pick a topic (Deposit or withdrawal, A game or bet, My account or Report a bug) and then write your message, which may run to 4,000 characters. You can have up to 3 chats waiting for our reply at one time, and you can start up to 10 new chats in an hour. For an Original, give the Bet ID, which each Bet shows in its details; for a Studio game, give the name of the game and the time of the Round.
- 5.3
If you cannot log in, including because your Account is suspended, you can chat with Support as a guest from the Support page, picking Can't log in, Can't sign up, Blocked in my area or Something else. A guest chat needs cookies to be turned on in your browser, takes messages of up to 2,000 characters, and lets you keep one chat open at a time. It does not ask for your email address, so tell us your username, and we confirm that you hold the Account under clause 5.8 before we discuss it. If you then log in on the same browser within 2 hours of last using the guest chat, the Site offers to move it to your Account.
- 5.4
You can also email support@peeks.gg at any time. Write from your Account's email address so that we can match your message to the Account; if you write from another address, we confirm that you hold the Account before we discuss it, and clause 7.3 applies where someone else may have changed that address. If the Network Check blocks you, choose Contact support on the block screen, which opens a chat with Support, or send us an email.
- 5.5
The chat takes text only. To send screenshots, screen recordings, documents or exported files, email them to support@peeks.gg, giving in the subject line the date and topic of your chat or, for a Formal Complaint, its Reference.
- 5.6
Our staff's messages in a chat appear under the name Peeks support, or under a staff member's display name followed by "from Peeks support". You can end a chat yourself with End chat, and we end a chat once we have dealt with it. A guest chat that our staff have not yet answered may also end by itself once 24 hours pass with no new message in it. An ended chat is shown as Ended in your list of chats, and when our staff end a chat, we ask whether we solved your problem. Replying to an ended chat within 7 days of its ending reopens it, and so does answering no to that question. After those 7 days, start a new chat. The end of a chat does not withdraw a Formal Complaint or a request for a Review made in it.
- 5.7
Never include in any message to us, and never give to anyone who claims to act for us, your password, a two-step code, a recovery code, a passkey, a Steam Guard code, your Steam Web API key or your Steam login details. Our staff will never ask you for any of them and, as clause 15.5 of the Terms states, will never ask you to send a Tip or Skins to prove who you are. Nor will they ask you to make a Deposit, or to send Skins outside a trade started in the Cashier, in order to settle a Complaint. If anyone asks you for any of these things in our name, stop all contact with that person and tell Support.
- 5.8
Before we discuss an Account, we check that we are dealing with its holder or with a Representative. A message from a logged-in session, or from the Account's email address, is usually enough. Otherwise, or where the Complaint concerns the security of the Account, we may ask you questions about the Account that only its holder could answer, such as the amount and time of recent Bets or Deposits, or ask for a document under the Identity verification policy. We do not discuss the Account until the check is complete.
- 5.9
When Support settles your Support Request, it tells you what it found and what it has done, and closes the chat or answers your email. If you are not satisfied with the answer, you may make a Formal Complaint under section 6.
6. Stage 2: making a Formal Complaint
- 6.1
To make a Formal Complaint, tell us in writing that you are making a Formal Complaint, in one of the following ways:
- email support@peeks.gg from your Account's email address; or
- send Support a chat message, in a new chat or by replying in an existing one.
The clearest way is to start the subject line of your email, or your chat message, with the words "Formal complaint", but any message that tells us plainly that it is a Formal Complaint is treated as one.
- 6.2
A Formal Complaint must give the information listed in section 18 that applies to it. In every case it must identify you and your Account, describe the Event with its date and time, say what you believe went wrong and why, and state the outcome you are asking for.
- 6.3
Make your Formal Complaint within 6 months of the date of the Event or, if later, of the date on which you became aware of the Event or could reasonably have become aware of it. Where the Event is a Bet in a Round that was left open, a Deposit that had not yet landed or a Withdrawal that had not yet been delivered, the 6 months run from the latest of the date of the Event, the day the Round settled, the day the Deposit landed or failed and the day the Withdrawal was delivered, canceled or failed. We may decline to investigate a Formal Complaint made after that time, and if we do, we tell you so under clause 9.5. We will still consider a late Formal Complaint where you show that exceptional circumstances, such as serious illness, prevented you from making it in time.
- 6.4
Records held by the Game Aggregator, by AssetPay and by Steam may not stay available to us indefinitely, so make your Complaint as soon as you can after the Event.
- 6.5
- 6.6
If a Formal Complaint does not contain the information we need to investigate it, we say what is missing in our acknowledgment under clause 7.1 or in a later message under clause 7.9. The periods in section 9 are paused from the day we ask until the day we receive what we asked for. If we receive nothing within 10 Business Days, we may close the Formal Complaint and tell you so under clause 9.5. You may reopen it by sending the missing information within 30 days of the closure, or at any later time within the period in clause 6.3.
- 6.7
Everything you tell us in a Complaint, and every piece of evidence you give us, must be true and unaltered. Making a Complaint on the strength of evidence that you know to be false, edited or taken from another person's Account breaches the Terms and may be Prohibited Conduct under section 14 of the Terms.
- 6.8
While your Formal Complaint is open, keep the evidence you have, including screenshots, emails, Steam trade offers and exported files. Do not reverse, recall or dispute a Deposit or a Skins trade through Steam, AssetPay or any other provider while we are investigating it. Clause 9.20 of the Terms applies to any reversal made without first contacting Support.
- 6.9
You may withdraw a Formal Complaint at any time by telling us in writing. We then close it and record the withdrawal. You may make the Complaint again within the period in clause 6.3.
- 6.10
The closure of your Account, whether at your request or ours, does not end a Formal Complaint that is already open. After closure, you may still make a Complaint about an Event that happened before it, within the period in clause 6.3, through a guest chat under clause 5.3 or by email under clause 5.4.
7. How we handle a Formal Complaint
- 7.1
We acknowledge each Formal Complaint in writing within 2 Business Days of receiving it. The acknowledgment gives:
- the Reference of the Formal Complaint;
- the name under which the Handler will write to you;
- our understanding of the Complaint, so that you can correct it;
- the date by which we expect to send the Written Answer;
- any information or evidence that we need from you; and
- your right under clause 10.1 to ask for a Review if the Written Answer does not reach you within the periods in section 9.
- 7.2
We correspond with you through the channel you used for the Formal Complaint. Subject to clause 7.3, we also send each acknowledgment, Written Answer and Review Decision by email to your Account's email address or, where you have no Account and have given us an email address, to that address. We do not discuss a Complaint by telephone or in any public place, including social media and the public channels of our Discord server. Our staff never send you the first direct message on Discord or on social media, so a direct message about your Complaint that you did not start does not come from us. Our official channels are listed in clause 23.2 of the Terms.
- 7.3
Where a Complaint says that someone else used your Account or changed its email address, we send nothing about the Complaint to an email address that was added to the Account during the period concerned, and we do not discuss it in a session that may belong to that other person. We correspond with you at the address you wrote from once you have shown us, under clause 5.8 and clause 6.14 of the Terms, that you hold the Account, for example by writing from the address that received our notice of the email change. Until that check is complete, we act on no instruction about the Account other than a request to lock it.
- 7.4
We assign each Formal Complaint to a Handler who was not involved in the Event or in the decision complained about. A Complaint about a member of staff is never assigned to that member of staff or to anyone that person manages. If you tell us that you have reason to doubt the impartiality of the Handler, we consider your concern and, where it is reasonable, assign another Handler and tell you.
- 7.5
The Handler is responsible for the Formal Complaint until the Written Answer is sent. The Handler reviews our records, obtains records from providers under clause 8.21, asks you any questions needed, keeps notes in the Complaint Record and writes the Written Answer.
- 7.6
We deal with Formal Complaints in the order in which we receive them. We may deal first with Safer Play Complaints, with Complaints that suggest a fault affecting other players, such as a Game settling Bets wrongly or an error in our ledger, and with Complaints that concern suspected unauthorized access to an Account or money that is missing or held.
- 7.7
Where we do not expect to send the Written Answer within 7 days of receiving the Formal Complaint, we send you an update by the end of that period, telling you what we have done, what we are waiting for and when we now expect to answer. We send a further update at least every 14 days until the Written Answer is sent.
- 7.8
- 7.9
We ask for the information and evidence we need as early as we can: in the acknowledgment under clause 7.1 where the need is clear from the Complaint, and otherwise within 7 days of receiving the Formal Complaint. A later request pauses the periods in section 9 only where it arises from something we could not have known by then, such as new evidence from you or a record received from a provider, and we tell you why the request comes late.
- 7.10
Making a Complaint does not by itself suspend your Account or hold your Balance. Where the Complaint concerns an amount that may have been added to your Balance in error, we may hold that amount, and only that amount, until we send the Written Answer, and we tell you when we do so.
8. How we investigate
- 8.1
We investigate using the records we hold and the evidence you give us. Depending on the Complaint, these include:
- the records of each Bet and Round, including the Bet ID, the Round ID, the settings and options recorded, the outcome and the payout;
- the Seeds of each Bet on an Original, including the hash of the server seed shown before the Bet, and for Crash the Round Seed of the Round;
- the journal entries in our ledger for your Balance, your Vault and your Tips;
- the records of each Deposit, Withdrawal and Skins trade, including the records of AssetPay and the status of each Steam trade offer;
- the record of each Network Check that flagged or blocked your connection;
- the records of logins, sessions, password and email changes, two-step login and Step-up Checks;
- the audit records of actions taken by our staff on your Account;
- your Support Requests; and
- our own record of each Round of a Studio game, with the round reference, the stake and the win reported to us through the Game Aggregator, and the Game Aggregator's record of the Round where we can obtain it under clause 8.9.
- 8.2
Under clause 11.7 of the Terms, the result recorded by our server for an Original, or the record of the Round kept by the Game Aggregator for a Studio game, prevails over what your screen showed, and under clause 11.4 of the Terms the rules in force when a Bet was accepted decide it. Under clause 8.5 of the Terms, our ledger records are conclusive evidence of your Balance unless they contain a clear error. These rules do not place our records beyond question. A Complaint may show that a record is wrong, for example because a Bet fails the check described in clause 8.3 or because a journal entry does not match the Round it records, and where that is shown, we correct the record and put right its consequences under section 9.
- 8.3
You can check the result of any Bet on an Original yourself. Open the Bet in Bets and choose Verify. For most Originals you must first rotate your seed on the Seeds page to reveal the server seed that produced the result; a Crash Round can be checked once it has ended. When we investigate a Complaint about a result, we run the same check with the same Verifier. We check that the hash of the revealed server seed, or for Crash of the revealed Round Seed, is the one the Game showed before the Bet; we work out the result again, from that server seed together with your client seed and the nonce, or for Crash from the Round Seed alone; and we compare it with the result we settled and the payout recorded in our ledger. The Written Answer sets out each of those inputs and the outcome of the check, so that you can repeat it.
- 8.4
We never reveal a server seed that is still in use, because that would allow anyone to work out the results of the Bets still to be made with it. If your Complaint concerns a Bet made with a server seed you have not yet rotated, we ask you to rotate it before we answer, so that the check covers a server seed you can see as well.
- 8.5
If the revealed server seed or Round Seed does not match the hash shown before the Bet, or if the result worked out from it differs from the result we settled, the Bet has failed the check. We then:
- settle the Bet again at the result its Seeds, or its Round Seed, produce, and add any shortfall to your Balance under clause 9.10;
- keep the settled result where the recalculation produces a result less favorable to you;
- check every other Bet made with the same Seeds or Round Seed, and correct each of them in the same way, whether or not you have complained about it;
- pause the affected Original until we have found and fixed the cause; and
- tell you in the Written Answer what the cause was and what we have changed.
- 8.6
A Bet that has been accepted is settled whether or not you stay connected, and a Round left open stays open until you return to it, as clause 11.13 of the Terms provides. In Crash, an automatic cash-out set before the Round works without a connection, but a manual cash-out takes effect at the multiplier our server has reached when it receives your request, under clause 11.21 of the Terms. Where you complain that a cash-out or a choice within a Round was not accepted, we compare the time at which your instruction reached our server with the record of the Round. Where you complain that a Bet was placed with settings you did not intend, including automatic play settings, we check the settings recorded with the Bet, and clause 11.20 of the Terms applies.
- 8.7
Where you complain about a cap on a payout from an Original, we check that the Maximum Payout, under clause 11.8 of the Terms, was applied in the way section 4 of the Game rules describes for that Game, whether by refusing the Bet before it was placed, by ending a Round played in steps before a step that could pay more than the Maximum Payout or by cashing a Crash Bet out by itself. An amount above the Maximum Payout is not payable, and a Complaint cannot change that. A Studio game pays under its own rules and any maximum win that its Studio sets. A single win of more than $1,000,000 in a Studio game is not added to the Balance but held for review, and after the review $1,000,000, the amount of the Maximum Payout, is added to the Balance in its place, unless the review finds a malfunction or Prohibited Conduct, in which case clauses 11.14, 11.15 and 14.5 of the Terms apply.
- 8.8
Studio games reach us through the Game Aggregator, and under clause 11.7 of the Terms the record of the Round kept by the Game Aggregator decides its result. For a Complaint about a Studio game, we compare the round reference, the stake and the win reported to us through the Game Aggregator with the entries on your Account, which appear on the Transactions page under Tips and vault as Slot bet, Slot win and Slot refund. If an amount reported as owed to you was never added by our ledger, we add it under clause 9.10. If a Round failed after your stake was taken, we check that the stake was returned under that game's rules, and we return it under clause 9.10 if it was not.
- 8.9
We cannot change the recorded result of a Round of a Studio game, and we cannot check how a Studio game's result is produced, as clause 11.12 of the Terms explains. Where you dispute the result itself, we ask the Game Aggregator for its record of the Round and for a review of it, passing on your Complaint and our records, and we send you the answer together with our own. Where a live casino Round is affected by a dealer error, a misdeal or a problem with the stream, the rules of that game and the record of the Round kept by the Game Aggregator decide the outcome, as clause 11.18 of the Terms provides.
- 8.10
If we pause an Original while your Round is open, the Round stays open until you finish it by an action that closes it without a further stake, such as cashing out, standing in Blackjack or surrendering in War, as the Game rules describe. In Mines, Tower, Chicken Cross, Moles, Hilo and Rock Paper Scissors, a Round in which nothing has yet been won offers no Cash out, so while the Game is paused, or while you are on a Play break or in a Self-exclusion, it stays open unless it is closed with its stake returned as section 16 of the Game rules provides. The open Rounds of a Studio game that we hide or remove are settled under that game's own rules through the Game Aggregator. Where you complain about a Game that was paused, hidden or removed, the Written Answer tells you how each of your open Rounds in it was dealt with.
- 8.11
In Fun play nothing is staked and no Winnings arise, under clause 11.16 of the Terms. A Complaint about Fun play may lead us to correct the Game, but never to a payment. The same applies to the play balances of Access Code Accounts and to any amount shown in an Account before the Launch Date, which are not money and are cleared under clause 6.12 of the Terms, and to Levels, which carry no reward while promotions are paused under clause 12.5 of the Terms.
- 8.12
Every change to your Balance is recorded as a journal entry in our ledger. Where you do not recognize an entry, or believe one is wrong, we trace it to the Bet, the Round, the Tip, the movement to or from the Vault, or the Deposit or Withdrawal that caused it, and we explain each entry in the Written Answer. The CSV files of your Bets and transactions that you can download help us to find the entries quickly. Where an entry was made in error, we correct it under clause 9.10, and clause 8.7 of the Terms applies to an amount added to your Balance by mistake. Where your Account carries a Recorded Debt, the Written Answer shows how the debt arose and how it has been set off under clauses 8.8 and 8.9 of the Terms.
- 8.13
A Tip is final once sent, and under clause 10.3 of the Terms we do not reverse a Tip sent to the wrong player. Where you complain about a Tip, we check that it was sent from your Account, after a Step-up Check, to the username recorded in the Tip. If you say that you did not send it, we treat your Complaint as one about the security of your Account under clause 8.17. While a lock on the Vault is running, you cannot move money out of it, under clause 10.9 of the Terms, although we may still take from it an amount you owe us under clause 8.8 of the Terms, and a Complaint does not end a lock early.
- 8.14
For a Complaint about a Skins Deposit, we examine the AssetPay record of the trade, identified by the trade ID shown with the trade in the History tab of the Cashier, and the status of the Steam trade offer. We check the items received, the price you accepted and the state of the trade. A Counter-Strike 2 Deposit stays pending until its hold ends, which is 7 days plus any days for which Steam holds the trade, even where part of it is added to your Balance early under clause 6.4 of the Payments policy, and the Cashier shows the date the hold ends. Neither we nor a Complaint can shorten Steam's hold. A Deposit reversed before it lands adds nothing to your Balance. Where one is reversed after it lands, the amount it added is taken from your Balance, and any part your Balance cannot cover becomes a Recorded Debt, under clause 9.9 of the Terms. We cannot override a limit, a Trade hold or another restriction that Steam places on your account or your Skins, as clause 9.4 of the Terms explains. A transfer sent by a method not offered in the Cashier is dealt with under clause 9.18 of the Terms, and the Written Answer tells you what we have been able to trace and whether it can be returned.
- 8.15
For a Complaint about a Skins Withdrawal, we trace the amount reserved from your Balance, the purchase of the Skins, the trade offer sent to your Trade URL and its outcome. Under clause 9.12 of the Terms, where a Withdrawal trade offer is declined, expires or fails, the amount reserved for each Skin not delivered returns to your Balance, and where a Withdrawal cannot be completed for a reason on our side or on AssetPay's side, the Cashier shows its state: the amount reserved returns to your Balance, or the Withdrawal stays pending while we try again or our staff review it. For a delayed Withdrawal, we look at each step that can affect its timing, including the wait, currently 24 hours, after you link a new Steam account or change your Trade URL, any check under section 7 of the Terms, the Network Check and the seller of the Skins. Where you reverse a delivered Withdrawal in Steam, clause 9.13 of the Terms decides what is returned.
- 8.16
Each Skins trade is priced under clause 9.5 of the Terms, and we check that the amount added to or taken from your Balance is the one that clause provides, starting from the price you accepted in the Cashier. A difference between that price and a price shown on Steam or elsewhere, or a later movement in the market, is not a ground for upholding a Complaint. A price that was plainly wrong because of a technical or pricing error is dealt with under clause 8.7 of the Terms.
- 8.17
For a Complaint that someone else used your Account, we examine the login and session records, including the end of any session caused by a login elsewhere, every change of password or email address, whether two-step login was turned on, each Step-up Check, and the Bets, Tips and Withdrawals made in the period concerned. We may lock your Account while we investigate, under clause 6.9 of the Terms, and clause 7.3 governs how we correspond with you. Responsibility for activity on your Account is decided under clause 6.9 of the Terms, but where our records show that a loss resulted from a failure of our own systems and not from the use of your login details or your devices, we put it right under section 9. If you have lost access to your email address, your password and your two-step method, clause 6.14 of the Terms applies.
- 8.18
For a Complaint about a Network Check, we review the record of the check that flagged or blocked you, including the checkpoint, the time, the country, the signals found and the network range of your IP address, which we keep with a one-way coded form of the address but not the address itself. We may ask you to choose Try again on the block screen, or to log in again, on the connection you are using now; a check that finds no signal, or only a Private Relay signal, leaves no record, so tell us the result. We may also ask you for the name of your internet provider, whether you were connected through a work, school, hotel, public or mobile network, and whether a browser feature, security software, a router setting or another service may have routed your traffic through another network. A Private Relay signal or a time zone signal does not by itself block you, as clause 5.5 of the Terms states.
- 8.19
If we find that no Masking Tool was in use, we lift any restriction on your Account and reverse every step taken under clause 5.8 of the Terms for that connection, as clause 5.10 of the Terms provides, making any change to your Balance under clause 9.10. We cannot exempt a connection from the Network Check, so a connection that still shows a signal that blocks access under the Restricted countries and VPN policy stays refused, and you will need to use a different one. We tell you which signal led to the block, but we do not disclose the scores, thresholds or provider data that would help anyone defeat the Network Check. A check that passes shows the state of your connection at that moment only and does not mean that later checks will pass.
- 8.20
Where Bets were voided because you used the Service while in a Restricted Territory, we review the evidence of where you were at the time, which may include documents you give us under clause 5.7 of the Terms. If the evidence shows that you were not in a Restricted Territory and no Masking Tool was in use, we reverse the steps taken under clause 5.8 of the Terms, making any change to your Balance under clause 9.10.
- 8.21
Where an Event involves the Game Aggregator, AssetPay, Steam, the Identity Partner, once connected, the lookup service that the Network Check uses or another provider, we ask that provider for its records and its view, and we give it only the information it needs to answer. We remain the party you deal with. A decision that Steam or Valve takes about your Steam account is theirs alone, and we cannot change it.
- 8.22
Where your Account has been restricted, suspended or closed, the Written Answer states the grounds and the clause of the Terms on which we relied, unless clause 7.9 of the Terms or clause 16.17 of the Terms prevents us from giving them, in which case clause 8.23 applies. While your Account is suspended you cannot log in, so use a guest chat or email under clause 5.3 or clause 5.4. Only our staff can release a Withdrawal or the Balance of a suspended Account, after review, as clause 9.17 of the Terms provides, and the closure of an Account and the payment of its Balance are decided under section 16 of the Terms.
- 8.23
Where an Event is the subject of an investigation by the police, a court or another authority, or of a report we must make under clause 7.9 of the Terms, the law may prevent us from telling you what we found, or that an investigation exists. We still acknowledge your Complaint and answer every part of it that we may lawfully answer, within the periods in section 9. Where we cannot answer a part, we say so, without giving the reason where the law forbids it, and we answer that part once the restriction ends, without your needing to complain again.
- 8.24
For a Complaint about an identity check, we tell you what the check requires, what we have received and what is still missing. Verification Level 1 details can be corrected only through Support once given, and only with proof once Verification Level 2 begins, as clause 7.2 of the Terms explains.
- 8.25
Where a Game or our systems malfunctioned, clause 11.14 of the Terms applies, and where a Bet was settled wrongly because of an error, clause 11.15 of the Terms applies. We establish whether the fault lay in the Game, in our systems, in the systems of the Game Aggregator or a Studio, or in your own device, software or connection, and we tell you which.
- 8.26
We consider every screenshot, recording and document you give us, and we may ask for a file in its original form. Under clause 11.24 of the Terms, a screenshot or recording of your screen does not prevail over the record of the Event, but it may show that the record needs to be checked again, and where it does, we check it again.
- 8.27
For a Complaint about a member of our staff, we review the Support Requests concerned, the audit records of the actions that member of staff took on your Account and any other relevant record. We tell you whether the Complaint is upheld and what we have done about it. We do not disclose disciplinary measures concerning a member of staff.
- 8.28
From the day we receive a Complaint, we keep every record we hold that concerns its Event, including the records listed in clause 8.1, even where our usual retention period would otherwise end, until the Complaint is closed and the time limit for claims in clause 19.7 of the Terms has passed, or until any proceedings about the Event have ended, whichever is later. We ask each provider concerned to keep its own records for the same period. The Privacy policy applies to the personal data in those records.
9. The Written Answer and Remedies
- 9.1
Where a Formal Complaint can be decided on our own records, we send the Written Answer within 14 days of receiving it. In every other case, including where we need records from the Game Aggregator, AssetPay, Steam or another provider, we send the Written Answer within 30 days of receiving the Formal Complaint.
- 9.2
Where a provider has not given us the records or the answer we need, or where the Complaint is unusually complex, we may extend the 30-day period once, by up to 30 further days. We tell you before the first period ends, giving the reason for the extension and the new date.
- 9.3
If a provider has still not given us what we asked for when the extended period in clause 9.2 ends, we send the Written Answer on the records we hold. It says what we asked the provider for, when we asked, and that the answer is still awaited. A provider's delay never counts against you: where our own records support your Complaint, we put it right without waiting. When the provider's answer arrives, we consider the Complaint again and, if the answer changes anything, send you a further Written Answer within 14 days, without your needing to complain again. The period for asking for a Review under clause 10.2 then runs from the date of the further Written Answer.
- 9.4
The Written Answer states:
- the Reference;
- the Complaint as we understood it;
- the records and evidence we examined;
- what we found;
- our decision, which is that the Complaint is upheld, partly upheld or not upheld;
- the reasons for our decision, naming each clause of the Terms, a Policy or the rules of a Game on which we rely;
- for a Bet on an Original, the server seed, the client seed, the nonce and the outcome of the check under clause 8.3, or for Crash the Round Seed and the outcome of that check;
- any Remedy, and the date by which we will carry it out; and
- how to ask for a Review, and the date by which you must ask.
- 9.5
Where we decline or close a Complaint without deciding it, because it falls outside this Policy under clause 4.10, was made late under clause 6.3, is incomplete under clause 6.6 or is not a genuine Complaint under clause 4.13, we tell you in writing which clause we applied and why, and what you can do about it. That notice is a Written Answer for the purposes of section 10, so you may ask for a Review of it.
- 9.6
On request, we send you with the Written Answer a copy of the records we relied on that concern your Account, such as the record of a Bet or a Round, the journal entries concerned, the record of a Skins trade and the record of a Network Check, in a form you can keep. We may withhold or redact a record, or part of one, where it contains another person's personal data, where the Game Aggregator or another provider gave it to us on terms that forbid us to pass it on, or where it would reveal how we detect Prohibited Conduct or how the Network Check works. Where we do so, we tell you what we have withheld and, in general terms, why.
- 9.7
We uphold a Complaint, in whole or in part, where we find that the Event, or part of it, did not happen as the Terms, a Policy or the rules of a Game required, or that our conduct fell short of what this Policy or the Terms require.
- 9.8
Where we uphold a Complaint in whole or in part, the Remedy may consist of any of these steps:
- settling a Bet again, paying a shortfall or returning the stake on a void Bet;
- returning an amount that was taken from your Balance in error;
- completing a Withdrawal or returning the amount reserved for it;
- lifting a restriction or reversing a step taken under clause 5.8 of the Terms;
- restoring access to your Account, or correcting the details held on it;
- putting right what a safer play tool should have stopped, under clause 11.6;
- correcting the Game, the wording or the process that caused the Event; and
- an explanation and an apology.
- 9.9
A Remedy aims to put you in the position you would have been in if the Event had happened as it should have, measured by our records and by the rules of the Game. We do not pay for Winnings from Rounds that were never played, for the loss of an opportunity to play, for a movement in the price of Skins after a trade or for indirect loss, except where Applicable Law requires it. Clauses 19.3 and 19.4 of the Terms apply to every Remedy, but they do not reduce an amount that is properly due to you under the rules of a Game, including the result of a Bet settled again under clause 8.5.
- 9.10
We carry out each Remedy within 5 Business Days of the Written Answer or, where a Review changes the Remedy, within 5 Business Days of the Review Decision. A Remedy that changes your Balance is made by a journal entry in our ledger that records the amount, the time and the reason, and we confirm the amount and the date to you in writing. Where a Remedy needs a third party, such as a Skins trade through AssetPay and Steam, we start it within that period and tell you when it is complete.
- 9.11
We carry out a Remedy even where the Account has been closed, or is suspended or in a Self-exclusion. An amount due is added to the Balance under clause 9.10 and paid out as section 16 of the Terms provides for the Balance of a closed or suspended Account. A Remedy never reopens an Account closed under clause 16.11 of the Terms, and never ends a Play break or a Self-exclusion early. Where the Account carries a recorded debt, an amount due under a Remedy is first set off against it under clauses 8.8 and 8.9 of the Terms, and the Written Answer shows the calculation.
- 9.12
You do not have to give up any right in order to receive a Remedy. Accepting a Remedy does not prevent you from asking for a Review of any part of the Written Answer with which you still disagree.
- 9.13
Where we uphold a Complaint because of a fault that may also have affected other players, we correct the Accounts of the players affected under clause 9.10, whether or not they have complained, and we tell each of them what we have corrected.
- 9.14
Where we do not uphold a Complaint, we may still offer a payment or another step as a goodwill gesture. A goodwill gesture is not an admission that we were at fault, is not a decision for the purposes of clause 3.5, and does not oblige us to make the same gesture to anyone else. We may ask you to keep the amount and terms of a goodwill gesture or of a settlement confidential, but we never ask you to keep silent about the Event itself, to give up a right that clause 1.8 protects, or to withdraw a complaint to a public authority.
10. Stage 3: Review by a Senior Reviewer
- 10.1
You may ask for a Review if you disagree with the Written Answer, if we have not sent the Written Answer within the periods in section 9, or if we have not carried out a Remedy by the date the Written Answer gave.
- 10.2
Ask for a Review no later than 30 days after the date of the Written Answer or, where you did not receive one in time or a Remedy was not carried out, no later than 30 days after the date by which it was due. Reply to the email that carried the Written Answer, email support@peeks.gg with a subject line that starts with "Review request" and the Reference, or send a chat message that starts with those words and the Reference. Say which parts of the Written Answer you disagree with and why, and send any further evidence.
- 10.3
If you do not ask for a Review within the period in clause 10.2, the Written Answer becomes our final position on the Complaint, and clause 10.9 applies to it as it applies to a Review Decision. We will still consider a late request for a Review where you show that exceptional circumstances, such as serious illness, prevented you from making it in time.
- 10.4
Each Review is carried out by a Senior Reviewer who had no part in the Event, in the investigation or in the Written Answer.
- 10.5
We acknowledge each request for a Review in writing within 2 Business Days, giving the name of the Senior Reviewer.
- 10.6
The Senior Reviewer examines the whole Complaint Record afresh, including any new evidence, may ask you or a provider further questions, and may confirm the Written Answer, change it or replace it, including its Remedy. Clause 7.8 applies to any question the Senior Reviewer asks.
- 10.7
We send the Review Decision within 30 days of receiving the request for a Review. Where the Senior Reviewer needs records from a provider, we may extend that period once, by up to 30 further days, in the way set out in clause 9.2.
- 10.8
The Review Decision is final. It is our final position on the Complaint and ends the procedure in this Policy. It states that it is final and reminds you of the routes that remain open to you under section 14, which it does not affect.
- 10.9
We do not reopen a Complaint after a Review Decision unless you give us new evidence that was not available to you before the Review Decision and that could change the outcome, or unless we find an error in our records that affected the decision. Where we reopen a Complaint, we tell you which stage it returns to. If you make a new Complaint about the same Event without new evidence, we may answer it by referring you to the Review Decision.
11. Safer play complaints
- 11.1
A Safer Play Complaint is a Complaint that:
- a Deposit limit, a Loss limit, a Daily stake limit, a Time limit, a Session reminder, a Play break or a Self-exclusion did not work as the Terms or the Responsible gambling policy describe;
- we accepted a Bet, a Deposit or a Tip that a safer play tool should have refused;
- we did not act on a request you made about your gambling, such as a request under clause 16.11 of the Terms to close your Account because of gambling harm; or
- concerns gambling harm in any other way, including a concern raised by another person under clause 11.8.
- 11.2
You may make a Safer Play Complaint at any stage, through any channel in section 5 or section 6. We acknowledge each Safer Play Complaint within 1 Business Day and send the Written Answer within 5 Business Days. We may extend those 5 Business Days only where we need records from the Game Aggregator or another provider, or are waiting for something we asked you for; we then tell you before the period ends, with the reason and the new date, and send the Written Answer within 10 Business Days of receiving the Safer Play Complaint, plus any time spent waiting for you. Clause 9.2 does not apply to Safer Play Complaints, and any step you ask for under clause 11.4 is taken at once, without waiting for the Written Answer.
- 11.3
A member of our staff reads and answers every Safer Play Complaint.
- 11.4
If you tell us that you are at risk of harm, we can, at your request, suspend your Account at once while we investigate. While it is suspended you cannot log in, and only our staff can release its Balance, as clause 8.22 explains. You can also start a Play break yourself on the Responsible play page. A Play break starts at once and cannot be shortened, and during it you may still make Withdrawals.
- 11.5
To establish whether a safer play tool worked, we compare the settings on your Account, and the history of changes to them, with the Bets, Deposits and Tips that we accepted. That history shows, for example, when a Deposit limit, a Loss limit or a Time limit was set, lowered, raised or removed, and when a raise or removal took effect after its 24-hour wait. Open Bets count toward a Loss limit at the most they could lose, and the Daily stake limit resets at 00:00 UTC. Session reminders are set and shown on your device only, so we hold no record of the reminders shown to you; we can check that the feature works, but not whether a particular reminder appeared on your screen.
- 11.6
Where a safer play tool failed and we accepted a Bet that the tool should have refused, we void that Bet, return the stake to your Balance and remove any Winnings it produced. Where a Deposit that landed during a Play break or a Self-exclusion, or that took you over a Deposit limit, was added to your Balance instead of being held apart from it under clause 9.16 of the Terms, our staff deal with it as that clause provides. Where a Tip was sent during a Play break or a Self-exclusion, we reverse it where it can still be reversed. Each of these steps is made under clause 9.10. We also fix the cause of the failure and check the Accounts of other players for the same fault under clause 9.13.
- 11.7
A Play break or a Self-exclusion continues while a Safer Play Complaint is investigated, and a Complaint cannot shorten it.
- 11.8
If you are concerned about the gambling of a player, tell Support. Except as clause 4.7 allows, we cannot tell you anything about that player's Account, including whether one exists. We consider the concern under the Responsible gambling policy and may contact the player, restrict the Account or close it. We tell you only that we have received your concern and looked into it.
- 11.9
The Responsible play page lists organizations, independent of us, that offer help with gambling.
12. Complaints about personal data
- 12.1
You may complain about how we collect, use, share, protect or keep your personal data, or about how we dealt with a request to see, correct or delete it. Send your complaint to the privacy officer, at the address given in clause 2.3 of the Privacy policy. You may instead email support@peeks.gg with a subject line that starts with the words "Privacy complaint", or send a chat message that starts with those words, and Support passes it to the privacy officer. The privacy officer, or a Handler the privacy officer supervises, deals with it under this Policy, except that where clause 19.1 of the Privacy policy sets a shorter time for our answer, the shorter time applies. The Privacy policy sets out your rights and the time within which we answer a request to exercise them.
- 12.2
We check your identity under clause 5.8 before we disclose personal data or act on a request about it.
- 12.3
As clause 21.11 of the Terms states, you may also complain to the Agency for the Protection of the Data of Inhabitants (PRODHAB), the data protection authority of Costa Rica, under Law 8968 as the Privacy policy defines it. You may do so at any time, whether or not you have used this Policy first, as clause 19.2 of the Privacy policy states. You may also complain to the data protection authority of the country where you live, where its law gives you that right.
- 12.4
Some records cannot be deleted while Applicable Law requires us to keep them, including the records described in clause 7.11 of the Terms. A Written Answer about a request to delete data tells you which records we must keep and why.
- 12.5
Where a Complaint suggests that personal data we hold has been lost, disclosed or accessed without authority, or that our systems have been breached, the Handler refers it at once to be dealt with under section 16 of the Privacy policy and section 16 of the Security policy, and the Complaint continues under this Policy. The Complaint Record notes the referral. The Written Answer tells you what we found about your own data, and section 16 of the Privacy policy decides when we notify you, other people affected and PRODHAB.
13. Conduct during a Complaint
- 13.1
Our staff will treat you with courtesy, and we ask you to do the same. We do not close a Complaint because of the tone in which it is written.
- 13.2
Where a Complainant is abusive, threatening or harassing toward our staff, or sends repeated messages that raise nothing new, we may limit contact to email, set how often we will reply, or name a single member of staff to correspond with. Except where clause 4.13 applies, we still investigate and answer the Complaint, and, as clause 15.1 of the Terms provides, we always leave you a way to raise matters about your Account in writing. We report threats of violence to the police, and threatening, harassing or abusing our staff is Prohibited Conduct under clause 14.2 of the Terms.
- 13.3
Posts on social media, in the public channels of our Discord server or in any other public place are not Complaints under this Policy, and we do not discuss an Account in public. A member of our staff who sees such a post may reply only to direct you to Support.
- 13.4
- 13.5
Do not publish the personal data of another player or of a member of our staff in connection with a Complaint. Where you need to show us a message or a document that contains such data, send it to Support.
14. Outside bodies and the courts
- 14.1
No gaming authority, ombudsman or alternative dispute resolution body has been appointed to hear complaints about Peeks, and none supervises the Games, as clause 21.6 of the Terms states. We do not refer Complaints to an outside body, except where you and we agree to mediation or arbitration under clause 14.3. If we appoint such a body in the future, we will name it in this Policy and state when and how you may refer a Complaint to it.
- 14.2
- 14.3
After a Review Decision, or at any earlier stage, you and we may agree in writing to refer the dispute to mediation or arbitration in Costa Rica under clause 21.9 of the Terms. Neither of us is obliged to agree, and an agreement to mediate does not end the procedure in this Policy unless we both say so in writing.
- 14.4
Where you and we agree to mediation, we choose the mediator together. Nothing said or offered in the mediation may be used as evidence afterwards, and an agreement reached in it binds us only once both of us have signed it. If the mediation ends without agreement, you keep every right under this section.
- 14.5
- 14.6
Nothing in this Policy limits any right you have to complain to a public authority that protects consumers in the country where you live, or in Costa Rica.
- 14.7
The time limit for bringing a claim against us is set out in clause 19.7 of the Terms.
- 14.8
Where a court or a public authority asks us about a Complaint, we cooperate as Applicable Law requires, and we may give it the Complaint Record.
- 14.9
A complaint made on a website run by a third party that publishes or mediates complaints about gambling sites is not a Complaint under this Policy and does not stop the periods in this Policy from running, so make your Complaint to us as well. Where we reply to such a website, we give it no information about your Account unless you have authorized it in writing as a Representative under clause 4.5. Its view binds neither you nor us, and it does not replace the procedure in this Policy or your rights under this section.
15. Records and confidentiality
- 15.1
We keep a Complaint Record for every Complaint, whether it is settled at Stage 1 or goes on to a Formal Complaint or a Review. It contains, as far as each applies:
- each Reference, and the dates on which the Complaint was received and acknowledged, each update was sent, and the Written Answer and any Review Decision were sent;
- the channel through which the Complaint reached us;
- the Handler and any Senior Reviewer;
- the subject of the Complaint and a summary of it;
- the records and evidence examined;
- our correspondence with you and with any provider;
- the notes of the Handler and of any Senior Reviewer;
- the decision, the reasons and any Remedy, with the date on which the Remedy was carried out;
- any decision to decline or close the Complaint without deciding it, with the reason;
- any goodwill gesture or settlement, and its terms;
- any referral under clause 12.5;
- whether the matter was taken to mediation, arbitration, a court or a public authority, and the result; and
- any arrangement made under clause 3.6.
- 15.2
Every reply, internal note, assignment and closure in a chat with Support is logged with the member of staff who made it and the time. Only members of staff with permission to read and reply to chats can be assigned to one. A member of staff who opens the investigation records of an Account must hold a permission for that purpose and confirm their own identity again before the records open.
- 15.3
Access to a Complaint Record is limited to the members of staff who need it to handle the Complaint, to carry out a Review, to put right a fault, or to meet our duties under Applicable Law. We share the information in a Complaint with a provider only to the extent needed under clause 8.21, and with a court or a public authority only under clause 14.8. We may also share it with a mediator or an arbitrator appointed under clause 14.3, with our lawyers and auditors, and with an insurer that covers the matter, each bound to keep it confidential and each given only what its role needs. Where you and we agree to mediation or arbitration, we send the Complaint Record to the mediator or arbitrator within 5 Business Days of being asked. We never publish a Complaint or the identity of a Complainant.
- 15.4
On request, we give you a copy of the personal data in your Complaint Record under the Privacy policy. We may withhold parts of it where Applicable Law allows, such as the personal data of other people or information whose disclosure would weaken the security of the Service or of the Network Check.
- 15.5
We review the Complaints we receive to find their causes and the patterns among them. We use what we find to correct Games, safer play tools, the wording of the Site and our processes, and to put things right for other players under clause 9.13.
- 15.6
Each year we publish on this page a summary of the Complaints we received in the previous year: how many there were, what they concerned, how many were upheld in whole or in part, how many went to a Review, and the average time to a Written Answer and to a Review Decision. The summary identifies no Complainant and no member of staff.
16. Responsibility and changes
- 16.1
The Operator appoints each Senior Reviewer. A Senior Reviewer may act as a Handler on other Complaints, but never carries out the Review of a Complaint that they handled.
- 16.2
We review this Policy at least once a year, and also after a change in Applicable Law, a change to the Service that affects how Complaints are made or decided, or a pattern of Complaints showing that the Policy is not working as it should.
- 16.3
We may change this Policy. The date shown at the head of this Policy is the date of its latest change, and each earlier version is kept on our records with its date. Clause 1.7 of the Terms applies to a change that reduces your rights in a material way.
- 16.4
A Complaint is handled under the version of this Policy in force on the day we received it. If a later version is more favorable to you, we apply the later version where you ask us to.
17. Contact
- 17.1
You can reach Support through a chat on the Support page, as a logged-in player or as a guest, or by email at support@peeks.gg.
- 17.2
The Operator's details are set out in clause 1.4 and on the Company and license page.
18. Formal Complaint checklist
- 18.1
The information that clause 6.2 requires is each of the following that applies to your Formal Complaint:
- your username and your Account's email address;
- your full name as given for Verification Level 1, if you have given it, and the country where you live;
- the date and topic of any chat with Support about the matter, or the date of your email;
- which of the subjects in clause 4.9 your Complaint concerns;
- the date and time of the Event, with your time zone, and the date on which you became aware of it where that is later (clause 6.3);
- the amount in dollars involved;
- what happened, what you expected to happen, and why you believe something went wrong;
- what you have already done about it, including any answer from Support;
- the outcome you are asking for;
- the language you would like us to use, if not English (clause 1.6); and
- the evidence you have, such as screenshots, screen recordings, emails and the CSV files of your Bets or transactions.
- 18.2
For a Bet on an Original, also give the Game, the Bet ID, the amount staked and the options you chose.
- 18.3
For a Studio game, also give the name of the Game and of its Studio where the Game shows it, the time of the Round, the amount staked, any round number the game shows, and the Slot bet, Slot win or Slot refund entries concerned, as they appear on the Transactions page under Tips and vault.
- 18.4
For a Skins trade, also give the trade ID shown with the trade in the History tab of the Cashier, whether it was a Deposit or a Withdrawal, the items, the price you accepted, the status of the Steam trade offer and a screenshot of the trade offer page in Steam.
- 18.5
For a Network Check, also give the date and time, the message shown, the device and browser you used, your internet provider and the kind of network you were using.
- 18.6
For a Balance, Vault or Tip entry, also give the date, the amount and the entry as it appears in your transaction history or your CSV file.
- 18.7
For a Complaint about personal data, also say which data or which request it concerns and the date of any request you made; what you believe went wrong, such as a request left unanswered, data that is wrong, or data disclosed or kept without a right to do so; and what you are asking for, such as access, correction, deletion or an end to a use of your data.
- 18.8
- 18.9
Never include your password, a two-step code, a recovery code, a passkey, a Steam Guard code, your Steam Web API key or your Steam login details, as clause 5.7 explains.