Simulated Gambling Disclosures — Bet Playground

This document is the canonical statement of how Bet Playground complies with App Store Review Guideline 5.3 ("Gaming, Gambling, and Lotteries") and how the product is designed to avoid the harms typically associated with real-money gambling apps. It supplements — and is consistent with — the in-app Terms of Service, Privacy Policy, and Community Guidelines.

1. What Bet Playground is

Bet Playground is a simulated sports betting application for iOS. Users can browse real sporting events, view odds sourced from a licensed third-party data provider, and place bets — using virtual currency only. No real money enters or leaves the App at any point.

The product is positioned as a harm-reduction alternative to real-money sportsbooks: a place where the cognitive and behavioural patterns of betting can be exercised without the financial harm. Every feature decision in the App is filtered through that frame, including the absence of features that would normally be considered standard for the betting category (see Section 4).

2. Apple App Store guideline alignment

We believe Bet Playground falls under Guideline 5.3.4 — Simulated gambling apps, which requires that such apps:

3. Currency model

• One-time starter grant. New accounts receive a one-time £100 virtual starter bonus. This is a courtesy grant; it has no cash value, cannot be purchased, and cannot be redeemed.
• User-initiated virtual deposits. Users can top up their virtual balance from within the App. This adds simulated currency to the account ledger; no payment method is collected, no payment processor is called, and no money changes hands.
• System-level caps. Single deposits are capped at £10,000 in virtual currency. Wallet ceiling is £100,000 in virtual currency. Both are enforced server-side.
• No conversion path. Virtual currency cannot be exchanged for real money, goods, services, or any other thing of value. There is no withdrawal feature, no peer-to-peer transfer, no marketplace, and no redemption mechanism. This is enforced architecturally — the system has no payment-processor integration of any kind.
• Account closure. When a user deletes their account (Profile → Delete Account), the entire virtual wallet is destroyed along with bet history, Fantasy data, and all other user-linked data. There is no offer to "buy back" or "convert" the balance.

4. Real-money gambling features deliberately absent

To make the harm-reduction stance unambiguous, Bet Playground does not ship features that are standard in real-money sportsbook apps:

• No deposit bonuses, free bets, or accumulator boosts that pull users into wagering more.
• No VIP tiers or "high-roller" rooms.
• No cashback or refer-a-friend bonuses.
• No advertising for real-money operators. No banner ads anywhere in the App. No affiliate links.
• No daily-login streak bonuses. Deliberately dropped because they conflict with the harm-reduction positioning — they reward compulsive opens, not measured play.
• No kickoff reminders or odds-movement push notifications. Same reason.
• No in-play (live) betting. Bets close at kickoff and stay closed for the duration of the match. The In-Play tab shows live scores with a "Betting Suspended — Match Has Begun" notice instead of a placeable card.
• No purchase of virtual currency. As covered in Section 3.

5. Responsible-gambling controls shipped in-App

The App ships the following controls, enabled at no cost and accessible from Profile → Responsible Gambling. Setting any limit only tightens — there is no "easy mode" path for loosening a limit mid-session.

These controls are not marketing copy — they are wired into bet placement, deposits, and login flows server-side. A user who has self-excluded cannot log in; a user past their loss limit cannot place a bet, regardless of UI state.

6. Age gating

• Age rating: 17+ ("Simulated Gambling — Frequent/Intense") in App Store Connect.
• Terms of Service: Section 3 requires the user to be at least 17 to use the App.
• Sign-up flow: Account creation surfaces the age requirement.
• Children under 17: The App is not directed at users under 17, does not knowingly collect data from users under 17, and the Privacy Policy (Section 7) commits to deletion if such data is identified.

7. Geo-restriction

The App refuses connections from the following jurisdictions, enforced both via header check on every authenticated endpoint and re-checked at sign-up so a header-spoof during account creation also fails:

Users in blocked jurisdictions see HTTP 451 with a clear message. Other markets (UK, EU, Australia, New Zealand, Canada outside Quebec) are unblocked. The list is configurable via SSM SecureString and can be amended quickly if Apple Review or a regulator flags a specific market.

8. Sports data provenance

Match data, fixture lists, and odds are sourced from Odds-API.io under a paid commercial licence. The data is used exclusively to populate the simulation. Bet Playground does not operate, host, or facilitate any real-money market — the displayed "odds" exist only for the App's virtual settlement engine. No proprietary content from any real-money operator is used or reproduced.

9. No payment processing

The App does not integrate with Stripe, Apple Pay (for in-app purchases), Google Pay, or any other payment processor. The Apple StoreKit framework is not linked into the build. There is no client-side payment SDK. The backend has no payment integration. This is verifiable from the build manifest and the open-source AWS Terraform modules — neither references any payment processor.

10. No advertising or third-party tracking

• No banner ads, interstitials, rewarded video, or any other ad format appears in the App.
• No advertising SDKs are integrated.
• No advertising identifiers (IDFA, GAID) are collected.
• The App does not ask for App Tracking Transparency (ATT) consent because it does not track.
• Diagnostic tooling (Sentry for crash reporting, PostHog for product analytics) is disclosed in the Privacy Policy and user-toggleable to off.

11. Backend availability during review

The production backend runs on AWS in eu-west-2 with an Elastic IP. The public domain betplayground.co.uk resolves to that address. The platform stays online during App Review. If the reviewer encounters connectivity issues, contact support@betplayground.co.uk for an immediate response.

12. Privacy and data minimisation

A separate Privacy Policy details what we collect, why, where it lives, and how to delete it. Headline: we collect email, password (hashed in Cognito), simulated betting activity, and opt-in diagnostic data (crash reports, opt-out-able product analytics). We do not collect: real names, payment data, location, contacts, photos, or advertising identifiers.

Self-service account deletion (Profile → Delete Account) deletes the account in Cognito and cascades through all linked data — wallet, bets, Fantasy, social, support tickets, devices, and the audit log references — within a single transaction.

13. Contact