Off the Hook Privacy Policy

Last Updated: March 20, 2025

Konnected Consulting LLC (“Company,” “we,” “us,” or “our”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through:

• Any websites operated by us from which you are accessing this Privacy Policy, including https://offthehook.net (the “Websites”) and any application accessible via our Websites;

• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you; and

• Offline business interactions you have with us.

Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.”

1. Type of Information We Collect

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.

When information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual (“Anonymous Information”) is directly or indirectly associated with Personal Information, the resulting information is also treated as Personal Information.

The Services collect Personal Information, including:

• contact details such as your first and last name, email address, residential address and phone number;

• Account and profile information such as age or your profile image;

• account login details, including your username and password;

• information we obtain from a third party, such as a site or platform provider (including Facebook, Twitter/X, Instagram, and Tik Tok), such as your social media profile image or information about your use of or interest in our services;

• transaction information you provide when you make a purchase, request a redemption or otherwise use the Services, such as your payment or redemption information including banking and financial details, credit card details and bank account statements;

• location information including location information provided by a mobile or other device interacting with our Services, or associated with your IP address;

• activity, technical and device information about your use of the Services, such as the content you view, the time and duration of your visit on the Services, how often you use the Services, how you first heard about the Services, your preferences and information about your interaction with the content offered through the Services, your hardware model, device type, other unique device identifiers, operating system version, browser type and IP address; and

• government identifiers such as passport, driver's license, social security numbers where we are required to do so for tax or other legal reasons.

2. How We Collect Your Information

We collect information in a variety of ways, as set out below. You confirm that any contact information you provide is true and accurate.

Through the Services

We collect Personal Information through the Services, including:

• Information you provide to us directly, including when you visit the Services, register on the Website, make purchases on the Website, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on the Services. We also collect information from you by telephone or in correspondence (including email, mail, text message or social media).

• Information you provide when using the Services. We also collect information about your use of our products and services through a variety of technologies that are present when you visit our Services, including cookies, flash cookies, pixels, tags and application programming interfaces (“API”). Please see the section entitled “Personal Data Collected via Technology” below for further information. Analytics tools are also used by us to collect information, including when you visit or use our Services.

From Other Sources

We receive your Personal Information from other sources, for example:

• From third party service providers. Finally, we also use trusted sources to update or supplement the information you provided, or we have collected, including in order to verify or validate information (for example, postal address, documentation and names).

• From your connections. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services (for example, in connection with any refer-a-friend promotion) you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services.

3. Personal Data Collected via Technology

When you interact with the Services, we try to make that experience simple and useful. We and our partners use industry standard identifiers, such as cookies or other similar technologies.

The Services may use technologies to enhance your experience. These technologies are small files that are placed on your computer, tablet, mobile phone or other devices when you visit a website. They allow us to record certain pieces of information whenever you visit or interact with the Services. Usage information may include, in part, browser type, operating system, device type, an estimate of your geographic location associated with your IP address, the location of your mobile device, the page served, the time, referring URLs and other information normally transmitted in HTTP requests. This statistical data provides us with information about your use of the Services, such as general engagement with a page, the type of content on that page and how long you stay on that page. Usage information is generally non-identifying but if Company associates it with you as a specific and identifiable person, Company will treat it as Personal Information.

The following are examples of these types of technologies:

• APIs. APIs work by allowing different types of software to communicate with each other. They make life a lot easier for programmers and provide a better experience for end users.

• Cookies. These are small text files placed in your device browsers to store your preferences. Most browsers allow you to block and delete cookies. However, if you do that, the service may not work properly.

• Event tagging. Event tagging allows us to track actions that occur on the Websites such as purchase events. By tracking these events we can view analytics, measure ad performance, and build audiences for ad targeting.

• Mobile device identifiers. We may share the advertising identifier associated with your mobile device or tablet with advertisers. It is used to identify your device for internet-based advertising. For instructions for using the advertising choice mechanisms provided by the most popular mobile operating systems, visit the NAI’s Mobile Choices page.

• Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about your engagement on that Service. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on or forwarded.

4. How We Use Your Personal Information

We use your Personal Information to operate the Services and to provide our products and services, to facilitate your financial transactions, to respond to your questions and to fulfill all applicable regulatory requirements such as anti-fraud checks and other checks required by applicable anti-money laundering and other legislation.

We and our service providers use Personal Information for the following purposes:

• To provide and manage the services you request - This includes, for example, processing your registration, setting up and looking after your account, including checks made to guard against fraud.

• To improve customer service and our services - Information you provide helps us respond to your customer service requests more efficiently; we may use feedback you provide to improve our products and services.

• To process payments - We may use the information you provide when placing an order to service that order (including to satisfy our customer due diligence requirements and to establish the source of funds where necessary).

• To process your requests to redeem Prizes.

• To personalize user experience - We may use information which has been aggregated to understand how our users as a group use the services and resources provided on the Services.

• To contact you about our services including marketing - For example by email, live chat, telephone, text message, mail or social media; to manage promotions and competitions you choose to enter. We may periodically contact you with offers and information about our products and services, including in connection with your accounts, promotions, contests, online surveys, new features that you are entitled to access, and other important information. Please see the section entitled ‘Your Privacy Rights for your opt out rights.

• To send important notices to you - From time to time, we may send important notices to you, such as communications about purchases you have made, or legal notices regarding the changes to our terms and conditions or other policies. This information is important to your interactions with us and you acknowledge that you may not opt-out of receiving these communications.

• To comply with our legal and regulatory obligations - We may use information we collect about you to assess your social gameplay activity for responsible social gameplay purposes, for taxation purposes, to comply with fraud and anti-money laundering laws (including to establish the source of funds where a transaction is involved) or to comply with any other legal or regulatory obligations (including the detection, investigation and prevention of activity that violates our terms and conditions or that may be illegal).

• To conduct market research and analysis - to analyze how you interact with our products and services; to monitor and analyze usage and activity trends; and for other research, analytical and statistical purposes.

We may use personal and Anonymous Information to create a third type of information - information about groups or categories of customers, which does not identify and cannot reasonably be used to identify an individual customer (“Aggregate Information”).

Behavioral Advertising

We may partner with a third party service provider to either display advertising on the Website or to manage our advertising on other websites (for example, using custom audiences on Facebook). Our third party service provider may use technologies such as cookies to gather information about your activities on the Website and other websites in order to provide you advertising based on your browsing activities and interests.

If you wish to opt-out of interest-based advertising click here. Please note you will continue to receive generic advertisements.

5. Disclosure of Personal Information

We disclose Personal Information with:

• To our affiliates for the purposes described in this Privacy Policy

• To our third party service providers, to facilitate services that they provide to us or to you on our behalf

• Third parties that interact with us in connection with the services we perform

• By using the Services, you may elect to disclose Personal Information

• On certain types of multiplayer games, your username and participation in such games is visible to other Players.

• On message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our Social Media Pages), any information you post or disclose through these services will become public and may be available to other users and the general public.

We reserve the right to use your information to announce the winning of any Prize through use of the Services, including your name, the amount of Sweeps Coins or Gold Coins, and your profile image from your social media profile or Customer Account, city and state for marketing purposes including on our Social Media Pages and online, affiliated or physical marketing channels.

We share information with third parties in limited circumstances including the following:

• when you allow us to share your information with third parties;

• when providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;

• with our service providers who enable us to provide our services, such as companies that help us with technology services, storing and combining data, processing payments and redemptions or providing relevant marketing and advertising for our products and services;

• in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, when ordered to do so by any regulatory body and/or under any legal provision contained in the governing law of a particular jurisdiction;

• when instructing and authorizing the financial institution with which a user’s account is held to disclose any information as may be requested by a regulator in respect of the user’s account;

• to enforce our terms and conditions set out on the Websites, to protect our rights and property and the rights and property of our customers and third parties, to detect fraud or other illegal activities, and to comply with law or legal processes; and

• to perform customer due diligence including ID verification.

We may ask you to provide your image to assist us in verifying your identity. We do this by using facial recognition technology provided by service providers that determines whether the photo you take matches the photo in your identification document. The facial recognition technology provided by these service providers collects information from your image capture, including biometric data, and may share this information with us. Biometric data is stored by the third party service provider in accordance with its privacy policy.

We may also share generic aggregated demographic information not linked to any Personal Information regarding visitors to and users of the Services with our business partners, trusted affiliates and advertisers for the purposes outlined above.

6. Your Choices regarding Our Use and Disclosure of Your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:  

• Receiving marketing-related emails from us.  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by clicking on the unsubscribe link in such emails.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

7. Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

8. Use of Services by Minors

The Services are not directed to individuals under the age of 18, and we do not knowingly collect Personal Information from individuals under 18.

9. Third Party Payment Service

The Services may provide functionality allowing you to make payments to Company using third-party payment services with which you have created your own account.  When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

10. Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Meta, X/Twitter, Google or any other social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

11. Updates to this Privacy Policy

The “Last Updated” date at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.

12. Contacting Us

If you have specific questions regarding your personal information or how we use it, please contact us via email at support@offthehook.net.

Off the Hook Sweeps Rules

Last Updated: March 14, 2025

NO PURCHASE OR PAYMENT NECESSARY TO PARTICIPATE. A PURCHASE OR PAYMENT OF ANY KIND WILL NOT INCREASE A PARTICIPANT'S CHANCES OF WINNING.

The Sponsor/Promoter of the Sweepstakes is Konnected Consulting LLC, 3286 Hidalgo Dr, Orlando, FL 32812 (““ Sponsor/Promoter ,” “ we ,” “ us ,” or “ our ”), which operates Off the Hook, an online platform which offers Participants the chance to play games for entertainment and enjoyment. Off the Hook also gives away sweepstakes entries referred to as “Sweeps Coins” as set out in these Sweeps Rules. Sweeps Coins can be used to Participate in Promotional Play for a chance to win further Sweeps Coins which are redeemable for real prizes.

These Sweeps Rules are to be read in conjunction with the Off the Hook Terms and Conditions (“ T&Cs ”). Terms which are defined in the T&Cs have the same meaning in these Sweeps Rules.

THESE SWEEPS RULES INCORPORATE SECTION 20 OF THE T&Cs, WHICH INCLUDE A PROVISION WAIVING THE RIGHT TO PURSUE ANY CLASS, GROUP OR REPRESENTATIVE CLAIM AND REQUIRING YOU TO PURSUE PAST, PENDING, AND FUTURE DISPUTES BETWEEN YOU AND US THROUGH INDIVIDUAL ARBITRATION UNLESS YOU OPT OUT WITHIN THE SPECIFIED TIME FRAME. SEE SECTION 10 OF THESE SWEEPS RULES FOR MORE INFORMATION.

1.  Eligibility to Play Off the Hook

1.1. The following definitions apply to these Sweeps Rules:

1.1.1. “ Eligible Participants ” means legal residents of the Permitted Territories;

1.1.2. “ Permitted Territories ” means the United States (other than the States of Connecticut, Delaware, Hawaii, Idaho, Louisiana, Maryland, Michigan, Montana, Nevada, and Washington);

1.1.3. “ Participant ” means a person who participates in Promotional Play;

1.1.4. “ Postal Request Code ” means the unique combination of 10 digits that Participants can obtain by following the steps outlined in Section 2.1.6. The purpose of a Postal Request Code is to assist with the efficient and effective processing of a Participant's Request Card.

1.1.5. “ Promotional Play ” means Off the Hook sweepstakes promotions. Promotional Play is only open to Eligible Participants, who are at least eighteen (18) years old or the age of majority in their jurisdiction (whichever occurs later) at the time of entry. PARTICIPATION IS VOID WHERE PROHIBITED BY LAW.

1.2. The Sweepstakes is subject to all applicable federal, state, provincial, territorial and local laws and regulations. It is the sole responsibility of a Participant to determine whether the Sweepstakes is legal and compliant with all regulations in the jurisdiction in which the Participant resides.

1.3. Participation constitutes the Participant's full and unconditional agreement to these Sweeps Rules and Sponsor's/Promoter's decisions, which are final and binding in all matters related to the Sweepstakes.

1.4. Winning a prize is contingent upon fulfilling all requirements set out in these Sweeps Rules.

1.5. Employees of Sponsor/Promoter, any of their respective affiliates, subsidiaries, holding companies, advertising agencies, or any other company or individual involved with the design, production, execution or distribution of the Sweepstakes and their immediate family (spouse, parents, siblings and children, whether the relationship is by birth, marriage or adoption) and household members (people who share the same residence at least 3 months of the year) are not eligible to participate.

1.6. To Participate, you must have an active Customer Account. If you do not have a Customer Account, you can create one free of charge at https://offthehook.net. To enter the Sweepstakes, a Participant must access Off the Hook at https://offthehook.net and sign in to their Customer Account. 

2.  How to Collect Sweeps Coins  

2.1. Once Eligible Participants have accessed Off the Hook, there are six potential ways for an Eligible Participant to collect Sweeps Coins:

2.1.1.  Receive Sweeps Coins as part of the sign-up bonus for new players.  

2.1.2.  Purchase Gold Coins, and receive Sweeps Coins as a free bonus . Each Participant may receive Sweeps Coins as a bonus upon the purchase of specifically marked packs of Gold Coins. Gold Coins can be used for social game play in Off the Hook. Gold Coins cannot be redeemed for prizes. The number of Sweeps Coins a Participant will receive as a bonus for each relevant Gold Coin purchase will be stated in the website purchase window. All purchases of Gold Coins are final and no refunds will be given.  

2.1.3.  Receive Sweeps Coins when entering no-cost giveaway contests on the Off the Hook Facebook page . The Sponsor/Promoter regularly holds Sweeps Coins no-cost giveaway contests which Participants can enter by following the instructions provided in the contest. These giveaways may require sharing the Facebook page posts or answering various game-related questions to be eligible for entry. The amount of Sweeps Coins given away will be stated on the applicable no-cost contest post and will be credited to each contest winner's Customer Account.

2.1.4.  Receive Sweeps Coins by logging into your account . Participants can receive free Sweeps Coins on a daily basis (Daily Bonus), or other frequency to be determined by Sponsor/Promoter (Mystery Bonus), by taking the following steps:

2.1.4.1. sign into your Customer Account;

2.1.4.2. if you are eligible, a pop up screen will appear for you to claim your Daily Bonus and/or Mystery Bonus;

2.1.4.3. click the “Claim” button at the bottom of the Daily Bonus and/or Mystery Bonus pop up.

Participants can only claim a Daily Bonus and/or Mystery Bonus once per day (the daily clock resets 24 hours after the Bonus is claimed).

2.1.5.  Receive Sweeps Coins by referring a friend.

2.1.5.1. Participants can receive 20 free Sweeps Coins by referring a friend who verifies their Customer Account and makes a Gold Coin Package purchase valued at $20 or more required by Sponsor/Promoter.

2.1.5.2. For the Participant to receive the Sweeps Coins, the friend must not have a pre-existing Customer Account. 

2.1.6.  Receive Sweeps Coins by sending a request by post .

2.1.6.1. Subject to the terms of this Section 2, Participants can receive free Sweeps Coins by (a) obtaining a Postal Request Code and (b) sending a Request Card (as defined below).

2.1.6.2.  Postal Request Code . A Postal Request Code can be obtained by following each of these steps: (a) sign into your Customer Account; (b) click on the “Postal Request Code” link in the Lobby; and (c) click on the “Postal Request Codes” button and follow the prompts. The Postal Request Code is then displayed for a period of time to enable a Participant to record it on their Request Card.

2.1.6.2.1. A Postal Request Code is unique, can only be used once and expires 90 days after it is displayed. Request Cards containing an expired Postal Request Code at the time of processing will be void.

2.1.6.2.2. A POSTAL REQUEST CODE CAN ONLY BE USED BY THE PARTICIPANT WHOSE CUSTOMER ACCOUNT WAS USED TO GENERATE THAT POSTAL REQUEST CODE. Any Participant suspected by Sponsor/Promoter to have directly or indirectly provided a Postal Request Code to another person may, in the sole discretion of Sponsor/Promoter, be disqualified and lose their eligibility to Participate in the Sweepstakes.

2.1.6.3.  Request Card . A Request Card is a standard post card or piece of white paper inserted in an envelope, that satisfies all the requirements below:

2.1.6.3.1. Request Card must be 4” x 6”, unfolded, blank and unlined

2.1.6.3.2. Request Card must be placed inside a stamped #10 envelope addressed in handwriting, to Off the Hook 3286 Hidalgo Dr, Orlando, FL 32812

2.1.6.3.3. Front of the envelope must have, in the Participants’ handwriting, the Participants’ return address and the words “Sweepstakes Credits”

2.1.6.3.4. One side of the Request Card must have, all of the following, in the Participants’ handwriting:

2.1.6.3.4.1. in the top-left corner, one (and only one) unique one-time Postal Request Code ;

2.1.6.3.4.2. under the Postal Request Code, in the following order: (a) their full name as shown on their government issued identification; (b) the email address registered to their Off the Hook account; (c) the return/residential address registered to their Off the Hook account; and (d) the following statement: “I wish to receive Sweeps Coins to participate in the sweepstakes promotions offered by Off the Hook. By submitting this request, I hereby declare that I have read, understood and agree to be bound by Off the Hook Terms and Conditions and Sweeps Rules.”

2.1.6.3.5. There is a limit of one Request Card per outer envelope.

2.1.6.4. For each Request Card a Participant submits in accordance with the above requirements, the Participant will receive 3 Sweeps Coins. The Sweeps Coins will be added to the Participant's Customer Account.

2.1.6.5. A Participant must ensure that their handwriting is legible. If the Participant's handwriting is not legible, the entry will be void and the Sweeps Coins will not be credited to the Participant's Customer Account. The legibility of a Participant's handwriting will be determined by Sponsor/Promoter in its sole discretion.

2.1.6.6. THE REQUEST MUST ONLY BE MADE BY THE PARTICIPANT AND MUST BE POSTED FROM THE SAME STATE OR PROVINCE AS THE PARTICIPANT'S VERIFIED RESIDENTIAL ADDRESS. Requests made by any other individual or any entity (including but not limited to commercial sweepstakes subscription notification and/or entering services) or posted from a State or Province different to the Participant's verified residential address will be declared invalid and Sweeps Coins will not be credited to the Participant's Customer Account. Tampering with the entry process or the operation of the Sweepstakes, including but not limited to the use of any device or software to automate the Sweeps Coins request/entry process or to unfairly assist the Participant with meeting the handwriting requirement, is prohibited and any requests/entries deemed by Sponsor/Promoter, in its sole discretion, to have been submitted in this manner will be void. Where there is an issue or fault with an envelope used by a Participant to request free Sweeps Coins, such that it does, or is reasonably likely to, cause damage to, or otherwise adversely affect, equipment used or procedures implemented to process mailed in requests (for example, handmade envelopes that are not suitable for machine processing due to poor quality or non-standard adhesive or paper), such entry will be void. In the event a dispute regarding the identity of the individual who actually submitted a request or whether a request satisfies the requirements set out above cannot be resolved to Sponsor/Promoter's satisfaction, the affected request/entry will be deemed ineligible.

2.1.6.7. Sponsor/Promoter is not responsible for lost, late, incomplete, invalid, unintelligible or misdirected Sweeps Coins requests or allocations.

2.2. The amount of Sweeps Coins to be allocated to Participants can be changed at any time by the Sponsor/Promoter in its sole discretion.

2.3. The amount of Sweeps Coins a Participant has will be displayed in their Customer Account on the website.

2.4. In the event of a dispute as to any registration of a Customer Account, the authorized account holder of the email address used to register the Customer Account will be deemed to be the Participant. The “authorized account holder” is the natural person assigned the email address by an internet access provider, online service provider or other organization responsible for assigning email addresses for the domain associated with the submitted address.

2.5. Use of any automated or other system(s) to Participate, to acquire Sweeps Coins or play the games is prohibited and will result in disqualification and loss of eligibility to Participate in the games.

2.6. Sweeps Coins are only valid for 60 days from the date a Participant last logged on to their Customer Account and will then automatically expire.

2.7. Sweeps Coins may also be forfeited if a Participant's Customer Account is closed for any reason, or at the Sponsor/Promoter's discretion.

3.  Using Sweeps Coins to Play Games vs. Redeem for Prizes

3.1. Participants with Sweeps Coins can use those Sweeps Coins to play games within Off the Hook for a chance to win additional Sweeps Coins.

3.2. Within Off the Hook there are different games. The amount of Sweeps Coins required to play each game will be detailed next to the game. A Participant may be able to increase the amount of Sweeps Coins they play the game with such that they can increase their potential winning eligibility.

3.3.  Sweeps Coins won through game play can be redeemed for real prizes. Only games played with Sweeps Coins provide the opportunity to redeem winnings for real prizes. The prize that can be won while playing a game will be shown in Off the Hook by clicking the “Win Table” or “Pay Table” button, denominated as “Sweeps Coins”.

3.4. Unless Sponsor/Promoter requires otherwise, any Sweeps Coins allocated to a Participant are required to be played once before they are eligible to be redeemed for prizes. Sponsor/Promoter may, in its sole discretion, require that any Sweeps Coins allocated to a Participant must be played a greater number of times (not exceeding 20) in any combination of Sweeps Coins games before they are eligible to be redeemed for prizes.

3.5. Each Sweeps Coin that has been won through game play (rather than collected using one of the methods described in Section 2 of these Sweeps Rules) can be redeemed for a prize with value being equivalent to US$1.

3.6. Sponsor/Promoter reserves the right to change the prize win rates and odds of any of the Sweepstakes at any time. A Participant can see the actual and any amended details by clicking on the “Win Table” or “Pay Table” button. It is a Participant's responsibility to check the prize win rate on each occasion before they participate.

3.7. Sponsor's/Promoter's decisions as to the administration and operation of the Sweepstakes, the game and the amount of winnings are final and binding.

4.  Verification and Confirmation of Potential Winners

4.1. POTENTIAL SWEEPSTAKES WINNERS ARE SUBJECT TO VERIFICATION BY SPONSOR/PROMOTER (IN ANY MANNER IT MAY CHOOSE) AND THE DECISIONS OF SPONSOR/PROMOTER ARE FINAL AND BINDING IN ALL MATTERS RELATED TO THE SWEEPSTAKES. A PARTICIPANT IS NOT A WINNER OF ANY PRIZE, EVEN IF THE ONLINE SCREEN INDICATES THEY ARE, UNLESS AND UNTIL THE PARTICIPANT'S ELIGIBILITY AND THE POTENTIAL WINNING PLAY HAS BEEN VERIFIED AND THE PARTICIPANT HAS FULLY COMPLIED WITH THESE SWEEPS RULES AND BEEN NOTIFIED THAT VERIFICATION IS COMPLETE. SPONSOR/PROMOTER WILL NOT ACCEPT SCREEN SHOTS OR OTHER PURPORTED EVIDENCE OF WINNING IN LIEU OF ITS VALIDATION PROCESS.

4.2. Potential prize winners must comply with these Sweeps Rules, and winning is contingent upon fulfilling all requirements.

4.3. A potential prize winner may be required to sign and return to Sponsor/Promoter, an affidavit/declaration of eligibility, and liability/publicity release (except where prohibited) in order to claim his/her prize (if applicable).

4.4. If a potential winner cannot be contacted, fails to properly execute and return the affidavit/declaration of eligibility and liability/publicity release within the required time period (if applicable), fails to comply with these Sweeps Rules, or if the prize or prize notification is returned as undeliverable, that potential winner forfeits the prize.

4.5. In the event that a potential winner of a Sweepstakes prize is disqualified for any reason, Sponsor/Promoter may, in its sole discretion, reseed the prize back into the Sweepstakes.

5.  Prizes

5.1. A Participant's Sweeps Coins balance is shown in the Participant's Customer Account.

5.2. Where a Participant has chosen to redeem prizes for cash, the cash payment will be paid in USD to the financial account or online wallet from which you purchased Gold Coins, or if this is not technically possible, then to an alternative bank account you nominate. Sponsor/Promoter reserves the right to require the use of the same payment method for redemption of prizes as was used to purchase Gold Coins, or a specific payment method at Sponsor/Promoter’s discretion.

5.3. Where a Participant has chosen to redeem prizes for gift cards, the gift cards will be allocated to the email address that the Participant has registered against their Customer Account, or if this is not technically possible, then to an alternative email address you nominate, provided that email address is also your address and not that of a third party.

5.4. Sponsor/Promoter will only process a prize redemption if the redeemed value of the prize is US$40 or more (i.e. a minimum of 40 eligible Sweeps Coins). Consequently, a Participant's Customer Account must have a balance of at least 40 Sweeps Coins before requesting a prize redemption.

5.5. TO BE ELIGIBLE FOR A SWEEPS COINS PRIZE OR A SWEEPS COINS PRIZE REDEMPTION:

5.5.1. A PARTICIPANT MUST BE AN ELIGIBLE PARTICIPANT; AND

5.5.2. THE PARTICIPANT'S DETAILS MUST MATCH THOSE OF THE PARTICIPANT'S ACCOUNT.

5.6. In New York and Florida, the maximum redemption value of a Sweeps Coins prize won on any one spin or play, via a Participant's participation in the Sweepstakes is US$5,000. Any prize valued in excess of US$5,000 will be reduced to a maximum value of US$5,000.

5.7. Sponsor/Promoter reserves the right, in its sole discretion, to limit a Participant's redemption of Sweeps Coins to US$10,000 per day. No more than the stated number of prizes will be awarded.

5.8. Sponsor/Promoter is not responsible for any taxes or fees associated with a prize redemption. Participants are responsible for all applicable taxes and fees associated with prize receipt and/or redemption.

5.9. Sponsor/Promoter is not responsible for any foreign exchange transaction fees, charges or related costs that may be incurred as a result of, or in relation to, a prize redemption, including but not limited to any losses or additional costs arising from foreign exchange fluctuations.

5.10. Sweeps Coins are not transferable, and no substitution will be made except as provided herein at the Sponsor's/Promoter's sole discretion. Sponsor/Promoter reserves the right to substitute the listed prize of equal or greater value for any reason owing to circumstances outside Sponsor's/Promoter's reasonable control.

5.11. Prize winners will be notified by private message or email.

6.  Entry Conditions and Release

6.1. By Participating, each Participant agrees to:

6.1.1. comply with and be bound by: the T&Cs; these Sweeps Rules; and the decisions of the Sponsor/Promoter which are binding and final;

6.1.2. release and hold harmless the Sponsor/Promoter and its parent, subsidiary, and affiliated companies, the prize suppliers and any other organizations responsible for sponsoring, fulfilling, administering, advertising or promoting the Sweepstakes, and all of their respective past and present officers, directors, employees, agents and representatives (collectively, the “ Released Parties ”) from and against any and all claims, expenses, and liability, including but not limited to negligence and damages of any kind to persons and property, including but not limited to invasion of privacy (under appropriation, intrusion, public disclosure of private facts, false light in the public eye or other legal theory), defamation, slander, libel, violation of right of publicity, infringement of trademark, copyright or other intellectual property rights, property damage, or death or personal injury arising out of or relating to a Participant's entry, creation of an entry or submission of an entry, participation in the Sweepstakes, acceptance or use or misuse of prizes (including any travel or activity related thereto) and/or the broadcast, exploitation or use of entry; and

6.1.3. indemnify, defend and hold harmless the Sponsor/Promoter from and against any and all claims, expenses, and liabilities (including reasonable attorneys/legal fees) arising out of or relating to a Participant's participation in the Sweepstakes and/or Participant's acceptance, use or misuse of prizes.

7.  Publicity

Except where prohibited, participation in the Sweepstakes constitutes each Participant's consent to Sponsor's/Promoter's and its agents' use of Participant's name, likeness, photograph, voice, opinions and/or hometown and state for promotional purposes in any media, worldwide, without further payment, notice or consideration.

8.  General Conditions

8.1. Sponsor/Promoter reserves the right to cancel, suspend and/or modify the Sweepstakes or these Sweeps Rules, or any part of the Sweepstakes or these Sweeps Rules, with immediate effect, owing to circumstances outside its reasonable control and only where circumstances make it unavoidable if any fraud, technical failures or any other factor beyond Sponsor's/Promoter's reasonable control impairs the integrity or proper functioning of the Sweepstakes, as determined by Sponsor/Promoter in its sole discretion.

8.2. Sponsor/Promoter reserves the right in its sole discretion to disqualify any individual it finds to be tampering with the entry process or the operation of the Sweepstakes or to be acting in violation of these Sweeps Rules or any other promotion or in an unsportsmanlike or disruptive manner.

8.3. Any attempt by any person to deliberately undermine the legitimate operation of the Sweepstakes may be a violation of criminal and civil law and, should such an attempt be made, Sponsor/Promoter reserves the right to seek damages from any such person to the fullest extent permitted by law. Sponsor's/Promoter's failure to enforce any term of these Sweeps Rules shall not constitute a waiver of that provision.

8.4. In all other cases, the Sponsor/Promoter reserves the right to cancel, suspend and/or modify the Sweepstakes. Any notice regarding cancellation, suspension and/or modification will be posted on the Off the Hook website at https://offthehook.net .

8.5. Whenever we amend these Sweeps Rules in a way that would limit your current rights or which may be to your detriment, we will notify you upon your next visit to the Platform and you will be required to re-confirm your acceptance prior to participating in any Promotional Play. If you do not agree to the amended Sweeps Rules, you may not participate in any Promotional Play.

9.  Limitations of Liability

9.1. Insofar as permitted by law in the respective territories, the Released Parties (as defined above) are not responsible for:

9.1.1. any incorrect or inaccurate information, whether caused by a Participant, printing error or by any of the equipment or programming associated with or utilized in the Sweepstakes;

9.1.2. technical failures of any kind, including, but not limited to malfunctions, interruptions, or disconnections in phone lines or network hardware or software;

9.1.3. unauthorized human intervention in any part of the entry process or the Sweepstakes;

9.1.4. technical or human error which may occur in the administration or operation of the Sweepstakes; or

9.1.5. any injury or damage to persons or property which may be caused, directly or indirectly, in whole or in part, from Participant's participation in the Sweepstakes or receipt or use or misuse of any prize.

9.2. If for any reason a Participant's Sweeps Coins or winning play is confirmed to have been erroneously deleted, lost, or otherwise destroyed or corrupted, Participant's sole remedy is replacement by Sponsor/Promoter of an equivalent amount of Sweeps Coins.

10.  Disputes

Section 20 of the T&Cs (Dispute Resolution and Agreement to Arbitrate on an Individual Basis) is incorporated herein by reference with the same force and effect as though fully set forth herein. By agreeing to these Sweeps Rules, you agree to be bound by the dispute resolution and arbitration provisions contained in Section 20 of the T&Cs.

11.  Other

11.1. Under no circumstances will any Participant be permitted to obtain awards for, and Participant hereby waives all rights to claim, punitive, incidental or consequential damages, or any other damages, including attorneys' fees, other than Participant's actual out-of-pocket expenses (i.e., costs associated with participating in this Sweepstakes), and Participant further waives all rights to have damages multiplied or increased. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATIONS OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE MAY NOT APPLY TO YOU.

11.2. All issues and questions concerning the construction, validity, interpretation and enforceability of these Sweeps Rules, or the rights and obligations of the Participant and Sponsor/Promoter in connection with the Sweepstakes, are governed by, and construed in accordance with, the laws of the State of Florida, without giving effect to any choice of law or conflict of law rules (whether of the State of Florida or any other jurisdiction), which would cause the application of the laws of any jurisdiction other than the State of Florida.

11.3. To ensure fairness and the integrity of the promotion to all Participants, the Sponsor/Promoter will respond to questions to Customer Support via email at support@offthehook.net  and may post updates/communications on its Facebook page.

11.4. Any Participant posting or seen to be posting comments on Sponsor's/Promoter's Facebook page or elsewhere during the promotion that are considered bullying, spiteful or upsetting to other Participants, players or fans of Off the Hook or directly aimed at the Sponsor/Promoter, will have their comments removed and may be disqualified from the Sweepstakes. The Sponsor/Promoter reserves the right to alert Facebook to any such behavior and Participant may have his/her Facebook account frozen pending investigation.

12.  Participant’s Personal Information

            Information we collect about Participants is subject to the Sponsor's/Promoter's Privacy Policy .

Off the Hook Responsible Social Gameplay Policy

Last Updated: March 18, 2025

We believe it is our shared responsibility with you, our customers, to ensure that you enjoy your experience on our platform while remaining aware of the potential risks that can be associated with online gameplay if you don't remain in control. 

We encourage you to use the responsible social gameplay tools described below available at your disposal. We reserve the right to activate these measures unilaterally if, in our sole discretion, we consider them necessary.

1. Introduction 

   1. This Responsible Social Gameplay Policy (“RSG Policy”) describes the control tools, information and resources available to registered players on Off the Hook.

   2. This RSG Policy forms part of the Off the Hook Terms and ConditioDelawarens. Terms which are defined in the Terms and Conditions have the same meaning in this RSG Policy.

   3. We may update the RSG Policy at any time. Any amendments will be published on the Platform and such changes will be binding and effective immediately. 

2. Off the Hook RSG Program

   1. Our Responsible Social Gameplay Program (RSG Program) is centered around our guiding principles of providing our customers with control tools, information and help resources needed to (a) make an informed decision in gameplay, and (b) prevent problem gameplay from occurring on our site.

   2. The RSG Program is designed to support the needs of individuals at any stage of the customer journey, from registration to redemption, and any level of gameplay. To do this, the RSG Program offers a range of player education, control tools and resources for professional help when needed.

   3. Off the Hook also understands that it is a shared responsibility to achieve a fun and affordable gameplay environment and that it is ultimately an individual's choice to play. We do not provide counseling services nor do we police customer behavior. Instead, we focus on providing control tools and informing, educating and supporting informed decisions.

   4. Off the Hook has staff available to assist you in relation to your gameplay. Our staff are encouraged and empowered to provide information and offer control tools. 

3. RSG Play Control Tool

   1. Activity Reminders - Accessible through Account Settings

      1. Off the Hook assists your play by providing an Activity Reminder every hour.

      2. The Activity Reminder:

         1. suspends play and indicates how long you have been playing

         2. displays your play history since logging in

         3. allows you to end the gameplay session or continue playing.

   2. Accessible through Account Settings.

      1. Gameplay History: Shows the result of each spin/play over a 2 week period.

      2. Purchase & Prize History: Shows your purchase and redemption history over a 2 week period.

   3. Limits - Accessible on the Platform  under “Responsible Social Gameplay options.”

      1. Purchase Limit

         1.  Provides the ability to limit the amount of Gold Coins you can purchase during your chosen time period. Once the limit is reached, you will not be able to make any new purchases until the limit resets.

         2. Period options are Daily, Weekly or Monthly.

         3. The limit can be adjusted or removed at any time. A decrease to the limit will take immediate effect. In contrast, an increase to the limit value or removal of the limit will take effect following a 72-hour cooling period.

      2. Play Limit

         1. Provides the ability to set the maximum amount of Sweeps Coins you can play for your chosen time period. Once the limit is reached, you will not be able to play any more Sweeps Coins until the limit resets.

         2. Period options are Daily, Weekly or Monthly.

         3. The limit can be adjusted or removed at any time. A decrease in the limit will take immediate effect. In contrast, an increase to the limit or removal of the limit will take effect following a 72-hour cooling period.

      3. Daily Time Limit

         1. Provides the ability to set exactly how many hours you are logged into your account, up to a maximum of 10 hours per day. Once the limit is reached you will be logged out until the next day.

         2. The limit can be adjusted or removed at any time. A decrease to the limit will have an immediate effect. In contrast, an increase to the limit or removal of the limit will take effect following a 72-hour cooling period.

4. RSG Access Control Tools

   The access control tools described below are available if your gameplay may have become, or is at risk of becoming, problematic (see “What is Problem Gameplay” in section 7.2).

   1. Taking a Break - Accessible on the Platform under “Responsible Social Gameplay options.” Allows you to take a short break from gameplay. During this time you will not be able to access your account.

      1. Available options are 1 day, 7 days, or 30 days.

      2. You can change or revoke the limits you have set by sending us a request by contacting us at support@offthehook.net.

   2. Self-Exclusion - Accessible on the Platform under “Responsible Social Gameplay options.” A self-exclusion allows you to suspend your account for a longer time period. During this period you will not be able to access your account.

      1. Available time period options are 3 months, 6 months, 1 year, 3 years, and 5 years.

      2. If your account has been verified to our satisfaction, we will use reasonable endeavors to arrange for any Sweeps Coins remaining in your account which satisfy our playthrough requirements and meet our minimum redemption threshold to be redeemed.

      3. You will be unsubscribed from receiving any marketing communications.

      4. You can change or revoke the limits you have set by sending us a request by contacting us at support@offthehook.net.

      5. Where a defined self-exclusion is in effect, your account will automatically reactivate once the chosen time period has lapsed.

   3. Permanent Closure - Please contact Customer Support

      1. You may choose to permanently close your account. If you wish to do so, via email at support@offthehook.net requesting a “Permanent Account Closure” and state the reason for the closure. Please note that a permanent closure is irreversible and cannot be reactivated under any circumstances.

5. Self-Assessment 

   If you think your or someone else's computer gameplay is becoming problematic, then it may be handy to consider the self-assessment questions available here.

6. Support Organizations

   If your gameplay may have had, or is at risk of having, a negative impact on your mental health, finances or relationships with friends or family, we encourage you to get in touch with the following help and support organizations:

   1. Counseling: Gaming Addicts Anonymous (GAA) is a fellowship of people who support each other in recovering from the problems resulting from excessive game playing.

   2. Credit Counseling:

      1. Financial Counseling Association of America (FCAA)  is a professional association of financial counseling agencies that assist consumers with financial counseling services of all kinds, as well as debt management plans for the repayment of unsecured debts.

      2. National Foundation for Credit Counseling (NFCC)  is one of the oldest networks of non-profit financial counseling agencies. The NFCC helps people to defeat their debt and look forward with confidence.

   3. Please note that these organizations are independent support services and are NOT in any way affiliated with Off the Hook. They do NOT provide customer support or dispute resolution services. Should you wish to discuss any matter or complaint related to your account, you can do so by contacting us via email at support@offthehook.net.

7. Education Information on Responsible Social Gameplay

   1. Tips for Safe Gameplay

      1. Avoid gameplay while upset or emotional.

      2. Take frequent breaks during your gameplay sessions.

      3. Avoid gameplay while intoxicated.

      4. Avoid canceling redemptions.

      5. Remember that gameplay is only a form of entertainment, it should not be seen as a source of income or an escape from reality.

      6. Purchase only with money that you can afford to spend.

      7. Don’t spend above your means. Set a budget and don't go over it.

      8. Set a time limit before playing.

      9. Understand how games work before playing and remember that the results are random.

      10. Never let gameplay affect your employment, relationships, health or commitments.

   2. What is Problem Gameplay?

      1. Financial

         1. Cannot pay bills

         2. Borrowing money to maintain life expenses

         3. Eviction or loss of home

         4. Repossession of car and valuables.

      2. Family

         1. Unhappy home environment

         2. Missing family events and gatherings

         3. Disconnect and disassociation of family members.

      3. Employment

         1. Missing work

         2. Reduction in productivity and competence

         3. Loss of employment.

      4. Health

         1. Anxiety

         2. Depression

         3. Isolation

         4. Increases stress.

      5. Know the Signs

         1. Purchasing beyond one's means

         2. Not being able to pay bills due to excess spending

         3. Staying home from work to play

         4. Feeling frustrated on days when not playing

         5. A constant need to increase the level of play to reach the same levels of fulfillment and excitement

         6. Playing in order to escape from the stress of life

         7. Lying about the amount of money or time that is spent

         8. Hiding play behavior from significant others

         9. Putting gameplay above one's family, friends or other interests

         10. Lying, borrowing, stealing, or committing fraud to get money to play

         11. Depressive or even suicidal feelings during or after playing.

8. Player Protection Policy

   1. Protection of the vulnerable

      1. Make sure that the decision to play on our platform is your own personal choice and responsibility.

      2. We do not recommend playing on our platform if you:

         1. are being treated or are in recovery for an addiction/dependency

         2. are under the influence of alcohol or any other substance

         3. are currently experiencing financial difficulty or a traumatic life event

         4. do not understand how to play the games

         5. have any mental health concerns, cognitive impairment or brain injury.

   2. Protection of Minors

      1. Off the Hook has identity checks in place to mitigate and prevent the risk of underage gameplay on our Platform.

      2. If you share your mobile phone, tablet, laptop or computer with friends or family who are under the legal age to participate in online social gameplay, we recommend that you restrict their access to our Platform by using one of the below services:

         1. Netnanny.com - filtering software that protects children from inappropriate web content.

         2. Cybersitter.com - filtering software that allows parents to add their own sites to block.

Off the Hook AML & KYC Policy

Last Updated: March 18, 2025

Section 1: Background and Introduction

On October 26, 2001, the USA PATRIOT Act (the "Act") became law (amending certain provisions of the Bank Secrecy Act of 1970). Section 352 of the Act requires every "financial institution" to establish an anti-money laundering (AML) program, which includes at a minimum:

•    The development of internal policies, procedures, and controls

•    The designation of a compliance officer

•    An ongoing employee training program

•    An independent audit function to test the program

Section 2: Konnected Consulting LLC Policy

Konnected Consulting LLC is committed to full compliance with all applicable laws and regulations regarding Money Laundering & Terrorist Financing. Konnected Consulting LLC consider Integrity as a key commitment on the part of the firm to uphold strict standards of ethical conduct and hence preservation of a stable value for society confidence. These policies endorse the strict compliance with the legal framework governing the prevention of money laundering and terrorism financing.

Section 3: Key Definitions    

1. Money Laundering

   Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds in a way to make those proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages.

2. Placement

   Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions.

3. Layering

   At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.

4. Integration

   At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate business.

Section 4: Customer Due Diligence Procedures

Konnected Consulting LLC  . has an established Customer Due Diligence Procedures (CDD) which requires customer to provide following information at minimum:

-    Customer Full Name

-    Date of Birth

-    Full Address with Zip Code 

-    Telephone Number

-    Email address

Section 5: Sanctions Screening 

Konnected Consulting LLC  will screen customer name against OFAC list to ensure customer is not in SDN list. If there is an indication of a possible match, transaction will put on hold and reviewed by the MLCO and will only be processed, if approved by MLCO.

Section 6: Enhanced Due Diligence Procedures 

1. High-Risk Clients 

Konnected Consulting LLC will take enhanced measures for identifying customers, keeping records, and monitoring financial transactions in respect of the activities that pose the high risk. Konnected Consulting LLC must periodically conduct ongoing monitoring of the business relationship with its customers based on risk. The level of monitoring which is conducted varies depending on the customer’s risk assessment results.

Based on risk assessment, if there is a need for any additional information about the user or the transaction purpose, Konnected Consulting LLC  may perform enhanced due diligence which include:

• Obtaining additional information on a client i.e. public database and the internet); and,

• Obtaining information on the client's source of funds or source of wealth

6.2     Politically Exposed (PEP) 

Politically Exposed Persons (PEP) is defined as “a person entrusted with a prominent position that typically comes with the opportunity to influence decisions and the ability to control resources. The influence and control a PEP have, puts them in a position to impact policy decisions, institutions, and rules of procedure in the allocation of resources and finances, which can make them vulnerable to corruption.” 

As part of KYC Process, Konnected Consulting LLC  is required to make the PEP determination when entering a business relationship with customers whether a person is a foreign PEP, a domestic PEP, a Head of International Organization (HIO), or a family member or close associate of one of these people. Also required to conduct periodic monitoring of business relationships and determine when a fact is detected about an existing business relationship and determine if they become a PEP or HIO, or a close associate. 

Konnected Consulting LLC  will ensure the required PEPs are identified, and that CEO/CCO approval is obtained for establishing a business relationship with a PEP. 

Section 7: Roles and Responsibilities

1. Money Laundering Compliance Officer (MLCO) Designation and Duties

   Konnected Consulting LLC has designated Anti-Money Laundering Program Compliance Officer with full responsibility for the company’s AML program. The duties of the AML Compliance Officer will include monitoring the company’s compliance with AML obligations, overseeing communication, and training for Management, and employees in the areas of AML/BSA and OFAC compliance. The AML Compliance Officer will also ensure firm keeps and maintains all required AML records and will ensure Suspicious Activity Reports (SARs) are filed with the Financial Crimes Enforcement Network (FinCEN) when appropriate. Responsibilities of the MLCO include the following: 

• Coordination and monitoring of Konnected Consulting LLC day-to-day compliance with applicable Anti- Money Laundering Laws and Regulations and firm internal Anti-Money Laundering Policy and Procedures.

• Conduct staff training programs for appropriate personnel related to the Konnected Consulting LLC  .’s anti-money laundering policy and procedures and maintaining records evidencing such trainings.

• Receive and review any reports of suspicious activity from staff.

• Sanction Screening of customer names before processing order to ensure compliance with OFAC and other applicable Sanctions lists

• Coordination of enhanced due diligence procedures regarding clients and respond to both internal and external inquiries regarding Konnected Consulting LLC AML/CFT policies and procedures.

• Notify the Authority of any suspicious money laundering or financing of terrorism activity

2. Employees 

It is the policy of the firm that every member of staff shall pay attention to and report to the MLCO if any transactions made on behalf of a person whose identity has not been established or suspicious transaction.

Section 8: Monitoring Accounts for Suspicious Activity

Konnected Consulting LLC  MLCO will monitor account activity for unusual size, volume, pattern or type of transactions, accounting for risk factors and red flags which are appropriate to our business. 

Section 9: Suspicious Transaction Reporting (SAR) and BSA Reporting

Konnected Consulting LLC will file a SAR with FinCEN for any transactions conducted or attempted by, at or through firm where we know, suspect, or have reason to suspect:

• The transaction involves funds derived from illegal activity or is intended or conducted to hide or disguise funds or assets derived from illegal activity as part of a plan to violate or evade federal law or regulation or to avoid any transaction reporting requirement under federal law or regulation.

• The transaction is designed, whether through structuring or otherwise, to evade any requirements of the BSA regulations.

• The transaction has no business or apparent lawful purpose or is not the sort in which the customer would normally be expected to engage, and after examining the background, the possible purpose of the transaction and other facts, we know of no reasonable explanation for the transaction; or

• The transaction involves the use of the firm to facilitate criminal activity.

• Konnected Consulting LLC  . will retain copies of any SAR filed and the original or business record equivalent of any supporting documentation for five years from the date of filing the SAR. We will identify and maintain supporting documentation and make such information available to FinCEN, as well as any other appropriate law enforcement agencies, federal or state regulators upon request.

• Konnected Consulting LLC  . will not notify any person involved in the transaction, which is being reported except as permitted by BSA regulations. 

Section 10: AML Recordkeeping

It is the policy of firm to follow its Records Retention Policy. This policy complies with existing BSA and other recordkeeping requirements.

Section 11: Training Programs

Company-Wide Training – All employees are required to participate in a yearly training program which currently has following components at minimum:

•    Ethics

•    Compliance Essentials

•    Anti-Money Laundering

•    Economic Sanctions 

Section 12: Independent Review of Compliance Program

Section 13: Periodic Review

This policy to be reviewed on an annual basis.