Contest Compliance Guidelines

This document outlines how our platform ensures all contests are skill-based and compliant with applicable regulations, addressing specific considerations for Stripe approval.

Distinguishing Our Platform from Prohibited Contest Types

Skill-Based vs. Chance-Based Contest Framework

Our platform hosts only genuine skill-based contests where:

1. Selection Criteria: Winners are selected based on objective evaluation of skill, quality, and adherence to requirements - never by random selection or chance.
2. Professional Services: Contests involve the creation of actual work products (designs, code, content) by qualified freelancers - not gambling on outcomes.
3. Documented Selection: All winner selections require detailed documentation of how the winning entry met the stated criteria.
4. Value Exchange: Contest organizers receive actual deliverables/work products in exchange for prize money - creating a legitimate business transaction.
5. Professional Context: The platform facilitates business relationships between organizations and skilled professionals - not entertainment gambling.
6. No Entry Fees: Freelancers are NEVER charged entry fees to participate in contests - participation is completely free, eliminating any resemblance to gambling models.

Canadian Provincial Compliance Measures

As a Canadian-headquartered company, we implement specific measures to comply with provincial regulations:

Quebec

1. Registration Requirements: We register contests with prizes exceeding $100 with the Régie des alcools, des courses et des jeux.
2. Bilingual Requirements: All contest rules and communications are available in both French and English.
3. Reporting Requirements: We report winner selection and prize distribution to regulatory authorities.
4. Fee Payment: We pay all required provincial fees for contest operation.
5. Publicity Rules: We adhere to Quebec's specific requirements for publicity of contest winners.

Ontario

1. Consumer Protection: We comply with Ontario's Consumer Protection Act requirements for contests.
2. Disclosure Requirements: We provide clear disclosure of contest rules, odds, and selection criteria.
3. Documentation: We maintain detailed records of all Ontario-accessible contests.

British Columbia

1. Business Practices: We adhere to BC's Business Practices and Consumer Protection Act.
2. Transparency Requirements: We ensure transparent communication of contest terms and conditions.
3. Winner Selection: We document all winner selection processes for regulatory compliance.

Alberta

1. Fair Trading Act: We comply with Alberta's Fair Trading Act provisions for skill contests.
2. Consumer Protection: We implement Alberta-specific consumer protection measures.
3. Documentation: We maintain detailed records of all Alberta-accessible contests.

Prize Threshold Management

1. Quebec Bond Requirements: For high-value contests, we post security bonds as required.
2. Provincial Registration: We register contests with appropriate provincial authorities when prize values exceed thresholds.
3. Prize Caps: Where necessary, we implement prize caps to avoid triggering onerous regulatory requirements.
4. Threshold Monitoring: We track prize amounts against provincial thresholds and alert contest organizers to regulatory requirements.

U.S. State-Specific Compliance Measures

New York

1. Enhanced Documentation: Contest organizers must provide detailed objective criteria for winner selection.
2. Skill Verification: Additional confirmation that contests are genuinely skill-based, not chance-based.
3. Record Retention: Extended record-keeping of selection processes and judging decisions.

California

1. CCPA/CPRA Compliance: Enhanced data protection measures for contest participants.
2. Consumer Protection: Additional disclosures regarding contest terms and winner selection.
3. Documentation: Detailed records of selection criteria and processes.

Florida & Rhode Island

1. Contest Registration: For contests with prizes exceeding state thresholds, we facilitate registration with appropriate authorities.
2. Bond Requirements: We post bonds where required for high-value contests.
3. Prize Documentation: Enhanced record-keeping for prize distributions above threshold amounts.

Arizona, Iowa, Vermont, Delaware, Louisiana, Maryland, Montana, South Carolina, South Dakota, and Tennessee

1. Skill-Based Confirmation: Additional verification steps ensuring contests are based on skill, not chance.
2. No Entry Fees: Clear documentation that no entry fees are ever charged to participants.
3. State-Specific Terms: Additional terms displayed to users in these states.

Prize Threshold Management

1. Registration Thresholds: We monitor prize amounts against state-specific thresholds:
   • Florida: Registration for prizes exceeding $5,000
   • New York: Additional documentation for prizes exceeding $5,000
   • Rhode Island: Registration for prizes exceeding $500
2. Bond Requirements: We post security bonds as required by state regulations
3. Prize Caps: Where necessary, we implement prize caps to remain below regulatory thresholds

Platform Controls for Contest Compliance

Contest Creation Controls

1. Required Selection Criteria: Contest organizers must specify objective judging criteria before contest launch.
2. Skill-Based Declaration: Organizers must confirm their contest is skill-based, not chance-based.
3. Template Restrictions: Pre-approved contest templates ensure compliance with regulations.
4. Invalid Contest Prevention: System flags potentially non-compliant contest structures for review.
5. No Entry Fee Enforcement: System architecture prevents any implementation of entry fees for freelancers.

Winner Selection Process

1. Criteria Documentation: Contest organizers must document how the winning entry met the stated criteria.
2. Selection Verification: Platform review of winner selections for compliance with stated criteria.
3. Audit Trail: Complete records of selection process, including evaluation notes.
4. Dispute Resolution: Structured process for addressing selection disputes based on objective criteria.

Financial Controls

1. Escrow Management: All prize money is held in escrow until winner selection is properly documented.
2. Tax Documentation: Automated generation of required tax forms for prize distributions.
3. State-Specific Withholding: Compliance with varying state and provincial tax withholding requirements.
4. Transaction Records: Detailed history of all financial movements for compliance verification.
5. Prize Threshold Alerts: Automated detection of prize amounts that trigger regulatory requirements.

No Entry Fee Architecture

1. System Design: Platform is architecturally designed to never charge freelancers for contest participation.
2. Financial Flow Protection: Payment pathways can only flow from contest organizers to the platform and from the platform to winning freelancers.
3. Monitoring: Regular system audits to ensure no entry fees are implemented.
4. Clear Documentation: All contest participation pages clearly state that participation is free and no purchase is necessary.

Enhanced Verification Procedures

Contest Organizer Verification

1. Identity Verification: Multi-factor verification of organizer identity.
2. Business Verification: For business accounts, verification of legitimate business operations.
3. Payment Verification: Validation of funding sources.
4. Jurisdiction Tracking: Monitoring of organizer location for jurisdiction-specific compliance.
5. Canadian Business Verification: Enhanced verification for Canadian businesses.

Freelancer Verification

1. Identity Verification: Comprehensive KYC procedures.
2. Skills Verification: Optional credentials verification for specialized contests.
3. Tax Information: Collection and verification of appropriate tax documentation.
4. Location Tracking: Monitoring of freelancer location for jurisdiction-specific requirements.
5. Free Participation Confirmation: Verification that freelancers are never charged to participate.

Compliance Monitoring and Enforcement

1. Regular Audits: Random review of contests for compliance with stated policies.
2. AI-Assisted Monitoring: Automated detection of potentially non-compliant contest structures.
3. User Reporting: Mechanisms for users to report potential policy violations.
4. Staff Review: Trained compliance team for manual review of flagged content.
5. Remediation Processes: Clear procedures for addressing identified compliance issues.
6. No Entry Fee Monitoring: Specific monitoring to ensure no entry fees are ever implemented.

Stripe-Specific Compliance Measures

1. Transaction Transparency: Clear labeling of all financial movements as relating to professional services.
2. Compliance Documentation: Maintenance of all records required by Stripe's policies.
3. Dispute Management: Structured processes for managing disputes in alignment with Stripe requirements.
4. Regular Reviews: Ongoing evaluation of platform policies against Stripe's Prohibited and Restricted Businesses list.
5. State Exclusions: If necessary, ability to restrict certain contest types in specific jurisdictions.
6. Free Entry Documentation: Clear documentation for Stripe that no entry fees are ever charged to freelancers.
7. Prize Threshold Management: Documentation of how we manage contests with prizes exceeding regulatory thresholds.

Bond Requirements and Prize Thresholds

1. Jurisdiction Monitoring: Real-time monitoring of contest prize amounts against jurisdiction-specific thresholds.
2. Bond Posting Process: Established procedures for posting bonds where required:
   • Quebec: For prizes exceeding registration thresholds
   • Florida: For prizes exceeding $5,000
   • Other jurisdictions as required
3. Registration Management: Assistance with contest registration in jurisdictions requiring formal registration.
4. Prize Amount Guidance: Advisory system for contest organizers regarding regulatory thresholds.
5. Prize Cap Implementation: Where necessary, ability to cap prizes to remain below regulatory thresholds.