Restricted Region Policy
This Restricted Region Policy (the “Policy”) explains where and under what conditions access to sortes.fun (the “Site”) and any site-based interface, content, features, or services (collectively, the “Interface”) is restricted or prohibited.
This Policy is intended to support compliance and risk management for services that may involve probability-based activities (e.g., lotteries and other games of chance), which are regulated and classified differently across jurisdictions. Sortes is described in project materials as a decentralized social welfare system powered by a decentralized lottery mechanism and related on-chain components. :contentReference[oaicite:0]{index=0}:contentReference[oaicite:1]{index=1}
No Legal Advice. This Policy is for informational purposes only and does not constitute legal advice. You are responsible for understanding and complying with all laws applicable to you.
1) Key Concepts
1.1 Non-custodial design
The Interface is designed to be non-custodial. We do not custody user funds or control user private keys. Users interact with blockchain smart contracts using their own wallets, and assets may be held and processed on-chain by smart contracts and DeFi mechanisms. :contentReference[oaicite:2]{index=2}
1.2 Third-party / user-created offerings (sales nodes)
The Protocol contemplates a Lottery-as-a-Service (LaaS) model with lottery sales nodes, where third parties may access a shared prize pool via open APIs and independently configure prize distribution and allocation parameters, including revenue sharing within allowed ranges. :contentReference[oaicite:3]{index=3}
1.3 Lottery vs. gambling classification varies
Some jurisdictions distinguish “lottery” from “gambling” (or treat them the same). Regulatory obligations may attach to (i) operating, (ii) promoting/advertising, or (iii) providing technical access to probability-based activities. This Policy adopts a broad definition to reduce ambiguity.
2) Definitions
For purposes of this Policy:
“Probability-Based Activities” means any lottery, gambling, betting, game of chance, sweepstakes, raffle, drawing, random-reward mechanic, or similar activity where outcomes or rewards depend in whole or in part on chance, randomness, or probabilistic distribution.
“Restricted Region(s)” means any country, territory, state/province, dependency, or other jurisdiction where:
Probability-Based Activities (or access to, facilitation of, promotion of, or participation in them) are prohibited or restricted; or
such activities (or related services) require a license, permit, registration, approval, authorization, or exemption that has not been obtained by the relevant party; or
we determine, in our sole discretion, that access should be restricted due to compliance, sanctions, or risk-management considerations.
“Prohibited Person” means any person or entity that is (i) located in a Restricted Region, (ii) subject to applicable sanctions or embargoes, or (iii) acting on behalf of a sanctioned or restricted party.
“Node Operator” means any third party that creates, configures, promotes, sells, distributes, or operates Probability-Based Activities (including “charity” or “welfare” lotteries) through a website, app, or other channel that integrates the Protocol (a “Node Interface”). The Protocol design contemplates such sales nodes. :contentReference[oaicite:4]{index=4}
3) Restricted Regions
3.1 Baseline Restricted Regions (non-exhaustive)
Without limiting the definition of “Restricted Regions,” the following are baseline Restricted Regions for the Interface:
United States (including territories and possessions)
United Kingdom
European Union / European Economic Area (EU/EEA)
Australia
Singapore
Japan
Mainland China (PRC)
This list is non-exhaustive and may be updated at any time.
3.2 Rule-based restriction (applies worldwide)
Even if a country or region is not listed above, it is still a Restricted Region if:
your local laws prohibit or restrict Probability-Based Activities; or
your local laws require licensing/registration/approval for Probability-Based Activities (or related access/facilitation) and the relevant authorization has not been obtained.
3.3 Sanctions and embargoes
Access is prohibited where doing so would violate applicable sanctions or embargo laws, or where a user is a Prohibited Person.
4) Who Is Prohibited From Accessing or Using the Interface
You must not access or use the Interface if you are:
located in, resident in, or otherwise subject to the laws of a Restricted Region; or
a Prohibited Person; or
attempting to access the Interface on behalf of any Prohibited Person or from any Restricted Region.
5) User Representations and Commitments
By accessing or using the Interface, you represent and warrant that:
You are not located in, resident in, or otherwise subject to the laws of any Restricted Region.
Your access to and use of the Interface is lawful in your jurisdiction.
You are of legal age and have capacity to use the Interface.
You will not access or use the Interface in any manner that violates applicable lottery/gambling, consumer protection, advertising, AML/sanctions, or similar laws.
6) No Circumvention
You agree not to use any technique to bypass restrictions, including:
VPNs, proxies, or anonymization services;
geolocation spoofing, device/location manipulation;
third-party intermediaries or “front” accounts;
any other method intended to evade compliance controls.
7) Enforcement Measures
To the maximum extent permitted by law, we may implement and enforce restrictions using reasonable controls, including:
IP-based geofencing;
device and network signals;
wallet and on-chain risk signals;
blocking or limiting site features, UI flows, or transactions;
requiring additional attestations or information; and/or
refusing access without notice.
We may apply these measures even where we are uncertain about jurisdictional status.
8) Node Operators and User-Created Activities (Sales Nodes)
If you are a Node Operator or you create/promote/sell/distribute/operate Probability-Based Activities via a Node Interface:
You are solely responsible for determining legality and compliance in each jurisdiction you target or where your end users are located.
You must implement reasonable measures to restrict access by Restricted Regions and Prohibited Persons.
You must provide clear end-user disclosures that:
you (the Node Operator) are the operator of the offering; and
participation involves chance and risk; and
access is prohibited in Restricted Regions.
You must not market, solicit, or target Restricted Regions.
The Protocol materials describe a sales node model where third parties can sell lottery tickets and set prize distribution parameters, including revenue sharing rules. :contentReference[oaicite:5]{index=5}
9) Updates to This Policy
We may update this Policy at any time by posting a revised version on the Site. The “Last Updated” date indicates when changes took effect. Continued access or use of the Interface after an update constitutes acceptance of the updated Policy.
10) Contact
If you have questions about this Policy, contact:
Email: contact@sortes.fun
Last updated