SINGULARITY GAMES PRIVATE LIMITED

Fair Play Policy

Effective Date: April 1st, 2025

Last Updated: March 25th, 2025

A. Introduction


This Fair Play Policy (the ‘Code’) governs the standards of conduct expected from the User participating in the skill-based games offered on the Platform provided by the Singularity Games Private Limited (‘BattleBucks’ or the ‘Company’ or ‘we’ or ‘our’ or ‘us’) The objective of this Code is to delineate a fair, transparent, and competitive gaming environment, where success is determined by skill, strategy, and knowledge, rather than by chance. This Code is intended to supplement and operate in conjunction with the Terms of the Company or BattleBucks (i.e., Singularity Games Private Limited), which can be accessed here. Any term not specifically defined herein shall have the meaning ascribed to it in the Terms.

The Company reserves the right to, from time to time, amend and modify this Code. The User acknowledges and accepts that they may also be subject to receiving periodic communications from the Company related to their obligation to comply with this Code. It is the sole responsibility of the User to stay informed of any updates, or policy amendments or modifications issued by the Company, as more particularly detailed in Section F (Amendments and modifications to the Terms or the BattleBucks Policies) of the Terms.

The Company reserves the right to take necessary actions, determined at its sole discretion, to enforce this Code on all games on the Platform, and hence the User is advised to read this Code carefully before playing a game on the Platform.

Non-compliance with the Code invites penalties depending on the grade of the misconduct as set forth in Section D (Misconduct and Penalty Matrix) of the Rules of Conduct.


B. Skill Based Games


Our Platform hosts and offers online skill-based games as per applicable law. While each game may feature different elements of skill, and the threshold may vary, each game is governed by the skill set you demonstrate to play and achieve the outcome.

The Hon’ble Supreme Court of India, in KR Lakshmanan v. State of Tamil Nadu (AIR 1996 SC 1153), has defined games of skill in this manner: “A game of skill, on the other hand - although the element of chance necessarily cannot be entirely eliminated - is one in which success depends principally upon the superior knowledge, training, attention, experience and adroitness of the player. Golf, chess and even Rummy are considered to be games of skill.”


C. What constitutes Fair Play?


The User is required to engage in gameplay with the utmost fairness, honesty, and integrity. All games must be played strictly in accordance with their respective rules, without resorting to any form of cheating, collusion, or the use of unauthorized tools, methods, or strategies that could compromise fair gameplay. Users are strictly prohibited from engaging in any actions that may defraud the Company, manipulate our systems, exploit vulnerabilities, or otherwise disrupt the level playing field between users.

The User may review the rules for the games offered on our Platform by visiting terms and conditions.

A Fair Play Violation (‘Fair Play Violations’) means any activity of a user that violates this Code. The following are illustrations of Fair Play Violations:

  1. Activity that uses unfair means to manipulate the outcomes of a Game on the Platform, irrespective of whether this is in favour of the user adopting such means.
  2. Activity that is fraudulent, illegal, suspicious or unfair, as determined by BattleBucks in its sole discretion.
  3. Activity that is intended solely to transfer funds from one person to another person, or between distinct sources, thereby amounting to money transferring.
  4. Activity that involves collusion between two or more players to achieve a result during a Game, thereby amounting to syndicate playing.
  5. Misrepresenting the source or identity of funds.
  6. Use of unauthorized components, create or use cheats, exploits, bots, hacks, or any other third-party software designed to modify, intercept, decrypt, or mine the Platform in any manner.
  7. Dissemination or uploading of spam, unlawful content, or any unauthorized communication to other players on the Platform, or employees of Battlebucks.
  8. Use of the Platform as a means of money transfer between persons or separate accounts, or any conduct that may amount to money laundering or other unlawful activities under Indian law.
  9. Uploading any content to the Platform, or registering a user ID, which is racist, casteist, profane, vulgar, offensive, or unlawful in any manner.
  10. Vulgar or abusive language, racist remarks, offensive comments about religion or caste.
  11. Solicitation in any form by any player via the chat, begging, pestering, and causing nuisance of any sort.
  12. Discussion regarding the purchase or sale of chips, or solicitation for the same.
  13. Flooding of chat window with recurring messages, or any sort of persistent or constant unwanted communication.
  14. Revelation of personal details like email address, contact numbers, postal, address, etc.

D. Actions Violating Fair Play


All games on the Platform are monitored for Fair Play Violations, and detection of a Fair Play Violation shall be subject to appropriate consequences as per the Penalty Matrix outlined in Section D (Misconduct and Penalty Matrix) (of the Rules of Conduct).

BattleBucks reserves the right to review any game of any user at any point in time, and if any games are found to be in violation of this Code, then BattleBucks shall be entitled to take action as deemed appropriate in accordance with the Penalty Matrix outlined in Section D (Misconduct and Penalty Matrix) of the Rules of Conduct.

The actions violating Fair Play are more particularly detailed in Section E (Prohibited Uses) of the Terms, and any violation thereof shall be subject to penalties under the Penalty Matrix specified in Section D (Misconduct and Penalty Matrix) of the Rules of Conduct, including without limitation restricting or terminating the User’s access to the Platform and/or the Services, or blocking, withholding, or forfeiting any payments, or rewards that the User may have earned on the Platform.


E. Steps Taken by BattleBucks to Ensure Fair Play


BattleBucks is dedicated to maintaining a fair and competitive environment for all users. To achieve this, we have implemented the following measures:

  1. RNG Certification: BattleBucks will employ certified Random Number Generator (RNG) systems (where applicable).
  2. ISO/IEC 27001:2013 Certification: The Platform uses ISO/IEC 27001 standards to protect User data.
  3. Penalty Matrix: Violations of this Code, the Terms and the BattleBucks Policies are subject to the Penalty Matrix described in Section D (Misconduct and Penalty Matrix) of the Rules of Conduct, which can be accessed at rules of conduct..
  4. Continuous Community Feedback: BattleBucks encourages User to share feedback and concerns, using feedback forms to improve and update fair play measures.

F. Grievance Redressal Mechanism


If you believe you have been unfairly treated, harmed, or have encountered User behavior that violates this Code, you have the right to raise a complaint or grievance in accordance with Section L (Grievance Redressal Mechanism) and Section O (Dispute Resolution and Arbitration Agreement) of the Terms.