No Winning Statement

Effective Date: July 20, 2025

1. Official Declaration

DIGITAL COURSERA LTD ("we," "us," or "our") hereby officially declares and confirms that our social casino platform, Spinarello, available at spinarello.com:

• Does NOT offer real money gambling
• Does NOT provide opportunities to win real money
• Does NOT award real money prizes
• Does NOT allow conversion of virtual currency to real money
• Does NOT facilitate real money transactions between players

2. Nature of Virtual Currency

2.1 Virtual Coins

All currency used within our games consists exclusively of virtual coins that:

• Have absolutely no real-world monetary value
• Cannot be exchanged for real money under any circumstances
• Cannot be transferred to other platforms or services
• Cannot be sold, traded, or bartered for real-world goods or services
• Are provided free of charge for entertainment purposes only

2.2 No Purchase Required

Our platform operates on a completely free-to-play model:

• No payment is required to access any games or features
• Virtual coins are provided free of charge
• No in-app purchases or monetization of virtual currency
• No premium subscriptions or paid content

2.3 Game Outcomes

All game results and virtual coin awards:

• Are purely for entertainment and scoring purposes
• Have no correlation to real money value
• Cannot be redeemed for cash, prizes, or rewards
• Do not represent any form of investment or financial return

3. Entertainment Purpose Only

3.1 Social Casino Model

Spinarello operates under the social casino model, which means:

• Games are designed purely for entertainment and social interaction
• Virtual winnings simulate traditional casino games for fun
• Players enjoy the thrill of gaming without financial risk
• Social features allow sharing achievements with friends

3.2 No Financial Risk

Since no real money is involved:

• Players cannot lose real money
• There is no financial risk associated with gameplay
• Virtual losses have no real-world financial impact
• Players can enjoy games without monetary concerns

4. Legal Compliance

4.1 Regulatory Compliance

Our no real money model ensures compliance with various jurisdictions by:

• Avoiding real money gambling regulations
• Operating as an entertainment service rather than a gambling operator
• Maintaining clear separation from real money gaming
• Following responsible gaming guidelines for entertainment platforms

4.2 Age Verification

Despite not involving real money, we maintain 18+ age restrictions to:

• Promote responsible gaming habits
• Ensure mature understanding of casino-style games
• Comply with best practices in the social gaming industry
• Protect minors from casino-style content

5. Clear Disclaimers

5.1 Website Disclaimers

Throughout our platform, we clearly display disclaimers stating:

• "This game does not offer real money gambling"
• "Virtual coins have no real-world value"
• "Entertainment purposes only"
• "18+ age restriction for responsible gaming"

5.2 Game Interface Disclaimers

Within our games, prominent notices remind players that:

• All currency is virtual and has no cash value
• Winnings cannot be converted to real money
• Games are for entertainment only
• No real money gambling is taking place

6. Comparison with Real Money Gambling

Aspect	Real Money Gambling	Spinarello (Social Casino)
Currency Used	Real money deposits	Free virtual coins only
Winnings	Real money prizes	Virtual coins (no value)
Financial Risk	Can lose real money	No financial risk
Withdrawals	Cash withdrawals possible	No withdrawals available
Purpose	Potential financial gain	Entertainment only

7. Responsible Gaming

7.1 Entertainment Limits

Even though no real money is involved, we promote responsible gaming by:

• Encouraging players to set time limits
• Promoting healthy gaming habits
• Providing information about responsible gaming
• Maintaining clear communication about the entertainment nature of our games

7.2 Support Resources

We provide information about gambling addiction support resources for educational purposes and to promote awareness of responsible gaming practices.

8. Technical Implementation

8.1 No Payment Processing

Our platform is technically designed to prevent real money transactions:

• No payment gateways or credit card processing
• No cryptocurrency or digital payment integration
• No mechanisms for purchasing virtual currency
• No withdrawal or payout systems

8.2 Virtual Economy

Our virtual economy is completely isolated from real-world financial systems:

• Virtual coins exist only within our platform
• No APIs or connections to financial services
• No exchange rates with real currencies
• Virtual balances reset as needed for game balance

9. Marketing and Advertising

9.1 Truthful Advertising

All our marketing materials clearly communicate that:

• No real money is involved in our games
• Virtual winnings have no real-world value
• Our platform is for entertainment purposes only
• We are a social casino, not a real money gambling site

9.2 Google Ads Compliance

Our advertising complies with Google Ads policies by:

• Clearly stating "no real money gambling" in all ads
• Avoiding misleading claims about winnings or prizes
• Maintaining transparent communication about our service
• Following all social casino advertising guidelines

10. Legal Certification

11. Contact for Verification

12. Regulatory References

This statement aligns with guidelines from:

• UK Gambling Commission guidance on social gaming
• Google Ads policies for social casino advertising
• Facebook advertising policies for social games
• Apple App Store guidelines for social casino apps
• International Association of Gaming Regulators (IAGR) best practices

This No Winning Statement was issued on July 20, 2025 and reflects our current and ongoing business practices.