Responsible Play
RESPONSIBLE PLAY POLICY
WINTHELUXE LTD, Player protection and harm prevention
1. Our Commitment
At WINTHELUXE LTD we want every player to enjoy our competitions safely and within their means. Although our skill-based prize competitions fall outside the scope of the Gambling Act 2005 and do not require a gambling licence, we voluntarily adopt high standards of player protection, drawn from the UK Voluntary Code of Good Practice for Prize Draw Operators published by the Department for Culture, Media and Sport in November 2025.
This Policy sets out the measures in place to identify, prevent and mitigate any harm that could arise from participation in our competitions.
2. Age Verification
Entry to our competitions is strictly limited to persons aged 18 or over. At registration, users must confirm their date of birth. We operate further age-verification checks at risk points, including when a player reaches a spend threshold, and when a player is notified as a Winner.
Advertisements for our competitions are targeted at adult audiences only and are configured in Meta, TikTok, Google and similar platforms with 18+ age restrictions.
3. Spending Limits
3.1 Monthly spend limits: Every player may set a personal monthly spend limit in their account, from £0 (pause) up to the default cap. Limits take effect from the next calendar day. Requests to increase a limit are subject to a 24-hour cool-off.
3.2 Default monthly cap: We apply a default monthly cap of £2,000 per account. Players may request an increase, subject to verification checks.
3.3 Credit card limit: Credit card payments are capped at £250 per player per month, in line with the DCMS Voluntary Code. Credit cards may not be used for any instant-win element.
3.4 Per-competition entry limit: Each competition limits each player to a maximum of fifty (50) entries, unless stated otherwise on the competition page.
4. Account Suspension And Self-Exclusion
4.1 Pause (short cool-off): Players may pause their account for 1, 7, 14 or 30 days at any time. During the pause, no entries may be made and no marketing will be sent. The pause cannot be ended early.
4.2 Self-exclusion: Players may self-exclude for a minimum period of 6 months, extendable to 12 months, 24 months or permanently. Self-exclusion is actioned within 24 hours and cannot be reversed during the exclusion period.
4.3 Effect of self-exclusion: During self-exclusion, the account is disabled, no entries may be made, no marketing is sent, and any attempt to register a new account with matching identity details will be blocked to the extent reasonably practicable.
4.4 Request channel: Players may request a pause or self-exclusion from within the account settings, or by emailing contact@wintheluxe.com with the subject line « SELF-EXCLUSION REQUEST ».
5. Monitoring And Early Intervention
We monitor player activity for indicators of potential harm including, but not limited to:
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Reaching spend limits frequently or requesting limit increases repeatedly;
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Sharp increases in entry frequency or value;
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Multiple failed payment attempts or frequent changes of payment method;
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Play at unusual hours over sustained periods;
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Self-reported concerns in customer support communications;
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Third-party concerns reported to our customer support team.
Where our monitoring identifies meaningful indicators of harm, we take a proportionate approach. Interventions may include sending a responsible play message, temporarily capping further spend, requiring the player to re-set limits, offering a pause, or, in significant cases, suspending the account pending contact.
6. Support Resources
If you, or someone you know, is concerned about participation in prize competitions or any form of gambling, free and confidential support is available from:
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GamCare, www.gamcare.org.uk, 0808 8020 133 (24/7 National Gambling Helpline in Great Britain);
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BeGambleAware, www.begambleaware.org;
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Gordon Moody, www.gordonmoody.org.uk (residential treatment);
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Citizens Advice, www.citizensadvice.org.uk (debt and money advice);
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National Debtline, www.nationaldebtline.org, 0808 808 4000;
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Samaritans, www.samaritans.org, 116 123 (if you are in emotional crisis);
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Mind, www.mind.org.uk, 0300 123 3393 (mental health support).
Players residing in other countries should consult equivalent national services. Our customer support team can help point you in the right direction.
7. Marketing Standards
All marketing complies with the UK CAP Code and, where relevant, the BCAP Code. In particular, our marketing must not:
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Be targeted at persons under the age of 18;
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Suggest that participating in competitions offers an escape from personal, professional, educational or financial problems;
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Suggest that participating in competitions is a solution to financial concerns, a substitute for employment, or a path to financial security;
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Use imagery, language or themes that could particularly appeal to minors or vulnerable adults;
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Misrepresent the chances of winning or obscure the conditions of entry.
8. Transparency
Each competition page clearly displays the maximum number of entries, the entry price, the prize description, the draw date and any material conditions. Our draw mechanism is certified and results are verifiable. On request, we provide the draw certificate for any completed competition.
9. Third-Party Conduct
We expect affiliates, influencers and other marketing partners to abide by this Policy and the relevant advertising codes. Partners who fail to comply may have their affiliation terminated and their commissions forfeited.
10. Staff Training
All customer-facing staff receive training in identifying and responding to signs of player distress or harm, and in signposting support resources. Training is refreshed annually.
11. Review And Reporting
This Policy is reviewed at least annually and updated where necessary. We maintain internal logs of interventions, self-exclusions and incidents, which we may be required to share with the Advertising Standards Authority, the Gambling Commission or other regulators on request.
Feedback, concerns or suggestions on this Policy may be sent to contact@wintheluxe.com.
12. Contact
If you need to exercise any of the protections set out in this Policy, or if you have a concern about your own play or the play of someone you know, please contact us at contact@wintheluxe.com. We treat all communications confidentially and without judgement.
END OF RESPONSIBLE PLAY POLICY