Complaints and Dispute Resolution

1. About this procedure

1.1 This procedure explains how to complain to Rust50 Entertainment Ltd ("we", "us", "our") about RUST50/50 at https://rust50.com (the "Site"), how we handle your complaint, the time limits we work to and the independent routes open to you if you are not satisfied with our answer.

1.2 This procedure forms part of our Terms and is summarised in clause 25 of the Terms. It is also published on its own so that it can be found from every page of the Site. Under the order of precedence in Terms clause 1.2, this procedure prevails over the Terms on how a complaint is handled. Any other conflict between this procedure and the Terms or another policy is decided by the order set out in that clause.

1.3 It is written to meet the complaint rules of the National Ordinance on Games of Chance (Landsverordening op de kansspelen, "LOK", P.B. 2024 no. 157), in particular article 5.3, and the Curaçao Gaming Authority ("CGA") Player Complaints Policy (version 1.1, 18 June 2025). Those rules apply to us once the licence shown on our Operator and Licence page is in force.

1.4 Current status. The Site currently runs as a public test preview. Real Steam trading is disabled, the items shown are simulated, and nothing of value can be staked, won or withdrawn. You can still report problems with the preview through support. The independent routes in sections 15 and 16 become available only once the licence is in force and real trading has been enabled. Until then, the time limits in this procedure describe the standard we intend to meet.

1.5 Language. You may write to us in English. As article 5.3 of the LOK allows, we also accept complaints written in Dutch or Papiamentu. We reply in English. If you wrote in Dutch or Papiamentu, we will make reasonable efforts to reply in that language as well.

2. Key terms

2.1 In this procedure:

• Complaint means any expression of dissatisfaction about the Site, a round, a trade, your account, a decision we made or the way we treated you, where you ask us to treat it as a complaint or where support cannot resolve it at first contact.
• Responsible gambling complaint means a complaint that we targeted, or failed to protect, a vulnerable person (see clause 11.2).
• Disputed event means the round, trade offer, decision or incident your complaint is about.
• Round number means the ten-digit public number of a round, shown on the round card as "Round #" followed by the number, and used in the Round checker.
• SteamID64 means the 17-digit number that identifies your Steam account. It is the account identifier we use for you.
• Trade offer ID means the number Steam gives each trade offer. It appears in the address of the offer (steamcommunity.com/tradeoffer/<number>/) and in your Steam trade history.
• Final decision means our reasoned written answer that completes our internal procedure.
• ADR means independent alternative dispute resolution outside the courts.
• Business day means Monday to Friday, excluding public holidays in Curaçao.

3. Support first, complaint at any time

3.1 Many problems, such as a missing trade offer or an expired payout offer, can be fixed quickly by our support team at support@rust50.com. We aim to answer support requests within within 24 hours.

3.2 You do not have to contact support before making a complaint. If support cannot resolve your problem at first contact, or if you tell support that you want it treated as a complaint, we register it as a complaint. The time limits in section 6 then run from the date you first raised the problem with us.

3.3 The public chat is not a support or complaints channel. Do not post your trade URL, trade offer links or other personal details there.

3.4 We will never ask for your Steam password, Steam Guard codes, recovery codes or Steam Web API key. Anyone who asks for them in our name is not us. Please report it to support@rust50.com.

4. Who can complain, time limit and cost

4.1 Only the registered account holder may complain about their own account, rounds and trades. Someone may help you write it, but it must come from you.

4.2 Claims against us cannot be sold, donated, leased, pledged or otherwise transferred (LOK article 1.3(c)). We do not handle complaints brought by someone who has bought or taken over another player's claim.

4.3 Anyone, such as a family member, may tell us at responsible-gambling@rust50.com that they believe a player is a minor or vulnerable. We will act on the concern, but data protection law may stop us from telling you the outcome.

4.4 You must complain within six months after the disputed event. For a round, the six months start when the round settled, meaning when the result was fixed and the settlement recorded. For a trade offer, they start when the offer was sent, accepted, declined or expired, whichever is the event you dispute. For a repeated problem, they start from the last time it happened.

4.5 If a complaint arrives later, we will still help where we reasonably can, but we may decline to investigate it formally. If so, we will tell you in writing, with our reasons.

4.6 Complaining is free, and so is ADR under section 15. You only pay costs you choose to incur, such as a lawyer you decide to hire.

5. How to make a complaint

5.1 Email your complaint to complaints@rust50.com with a subject line such as "Complaint: round 1234567890" (using your own round number) or "Complaint: payout not received".

5.2 You may also use our Complaint Submission Form, which asks for the same information.

5.3 Please include the following information.

5.4 If you do not have everything, send what you have. If we need more, we will ask within the first four weeks, and we will only ask for what is reasonably needed to handle your complaint.

5.5 To confirm that a complaint comes from the account holder, we may ask about your recent round numbers and trade offer IDs or, once identity checks are in place, ask you to complete a check through an EU-approved identity verification provider. We ask for identity documents only through the verification flow on the Site or by email from compliance@rust50.com, never in the public chat or by Steam message (see our AML and KYC Policy).

5.6 Complaint categories: deposits; payouts and refunds; item values and the house fee; round results and fairness; promotions and referrals; account restrictions, mutes, bans and closures; responsible gambling; identity checks (KYC) and anti-money-laundering holds; data protection; technical problems; suspected minors; fraud or impersonation; licensing; unfair terms; other.

6. Acknowledgement and time limits

6.1 We work to the following time limits. They are counted in calendar days from the day your complaint reaches us (or, under clause 3.2, from the day you first raised the problem with support), unless business days are stated. They follow article 5.3 of the LOK and section 4 of the CGA Player Complaints Policy.

6.2 Our acknowledgement gives you a reference number, explains how we will handle the complaint and states our current average resolution time.

6.3 Including any extension, a general complaint never takes more than eight weeks from receipt. An extension notice gives our reasons and the new date.

6.4 Responsible gambling complaints are handled first. Where someone may be at risk, we may act at once, for example by applying an exclusion you asked for, without waiting for the final decision. A request for a limit, a cooling-off period or self-exclusion sent to responsible-gambling@rust50.com is not a complaint and does not wait for this procedure: it is applied on receipt, and at the latest within 24 hours, as our Responsible Gambling Policy describes.

6.5 You will always receive a written final decision, or written reasons why we are not handling the complaint.

6.6 If we miss any time limit in this section, you may go to ADR under section 15 without waiting for our final decision, subject to the ADR provider's rules.

7. How we investigate

7.1 Every complaint is handled by a person who, where our team size allows, was not involved in the matter. Otherwise, the person responsible for compliance reviews the outcome before it is sent.

7.2 Depending on the complaint, we check:

• the round record: participants, item lists and values, the server seed hash published before the round, the client seed, the nonce, the revealed server seed, the roll, the result, the fee items, the payout and the timestamps;
• the trade offer records: offer IDs, type (deposit, join, payout or refund), state, value and times, and the status Steam reports for each offer;
• your account record: your trade URL, any ban or mute and its end time, and when the account was created and last seen;
• the audit log of moderation actions, including the reason recorded for each action;
• server and network logs, where they are still kept;
• the evidence you sent us.

7.3 If we use automated tools or artificial intelligence to sort complaints or draft replies, a person reviews the outcome before it is sent. Responsible gambling complaints and complex complaints are always handled by a person, and we monitor any automated output for consistency.

7.4 If we intend to rely on information you have not seen, we will tell you what it is and, where the time limits allow, let you comment first.

7.5 We will not restrict your account because you complained. Separate grounds, such as suspected fraud, an identity check or a responsible gambling concern, may still apply.

7.6 We keep the records relevant to a complaint until it is closed and for the period in section 18, even if they would otherwise be deleted sooner.

8. Round result disputes and the provably fair record

How a result is decided

8.1 Every round result is fixed by the provably fair calculation described on our Fairness page. In short:

1. When a round is created, a random server seed is generated and its SHA-256 hash (the "commitment") is published. The seed stays secret until the round is finished.
2. The client seed is chosen by the creator or, if left blank, generated at random. New rounds use their ten-digit round number as the nonce. Older rounds keep the nonce originally stored for them, which is never rewritten, so their nonce differs from their round number.
3. The roll is the first 8 hexadecimal characters of HMAC-SHA256 (key: the server seed; message: client seed, colon, nonce), divided by ffffffff (hexadecimal), giving a number from 0 to 1.
4. The creator's chance is the creator's stake value divided by the pot value. The creator wins if the roll is lower than that chance. Otherwise the joiner wins.

8.2 The coin animation does not decide anything. After both stakes are in, there is a 4-second countdown, followed by the coin animation: a spin followed by a slowing landing, which together last several seconds. The animation is cosmetic and displays a result that was already fixed before it started. A frozen, skipped or stuttering animation, a lost connection, or reloading the page during the flip does not change the result.

Checking a result yourself

8.3 Enter the ten-digit round number in the Round checker on the Site. Before the result, it shows the commitment. After the result, it shows the revealed server seed and recomputes the roll and the winner. You can also enter all the values by hand.

What we check when you dispute a result

8.4 We confirm that:

1. the SHA-256 hash of the revealed server seed equals the commitment published before the round;
2. the client seed and nonce are the ones recorded when the round was created;
3. the roll recomputed from those values equals the roll stored for the round;
4. the creator's chance follows from the recorded stake values;
5. the recorded winner follows from comparing the roll with that chance; and
6. the payout went to the winner, and the fee items follow the rule in clause 9.6.

8.5 Example. A creator stakes items worth USD 100.00 on Black. A joiner may join with items worth USD 94.00 to USD 106.00 (within 6% either way) and joins with USD 96.00. The pot is USD 196.00. The creator's chance is 100.00 ÷ 196.00 = 0.5102 (51.02%), and the joiner's is 48.98%. These chances are shown before the joiner confirms. If the roll is 0.5307, it is not below 0.5102, so the joiner wins (White). If the roll were 0.4100, the creator would win.

Outcome of a result dispute

8.6 If every check in clause 8.4 passes, the result stands, and our decision gives you the values so you can repeat the check.

8.7 If any check fails, or a software error affected the round, we treat it as a malfunction under clause 13 of our Terms (errors, malfunctions, void rounds and refunds). The remedies are described in section 13 of this procedure. Any correction is recorded separately. The original fairness record is never rewritten or deleted.

8.8 Nobody can change a result to settle a complaint. No admin, promotion or test control can change a result, the odds, the seeds or a payout, and the owner console shows rounds read-only. We cannot replay a round.

8.9 We will not uphold a complaint only because the displayed chance seemed unfair (it was shown before you confirmed), a different client seed would have won, or the animation seemed to land differently. We will still explain the result.

9. Trades, payouts, item values and the fee

9.1 Real Steam trading is currently disabled. This section describes how trades will work once real trading is enabled, and how we will handle complaints about them.

Deposits and joins

9.2 To create or join a round, you receive a trade offer from one of our bot accounts. You must confirm it in Steam, with Steam Guard, within 90 seconds. Your items count only after Steam has completed the trade.

9.3 A round does not start, and is placed under manual review, if Steam completes your trade after the 90 seconds have passed, or if we cannot confirm that an expired offer was cancelled. A round in review produces no result. We check the trade records and return your items, as clause 13.8 of our Terms describes. Please include the round number and trade offer ID in any complaint about this.

Payouts and refunds

9.4 Winnings and refunds are sent as trade offers to the Steam trade URL saved on your account. You must accept a payout offer within 3 days. If an offer fails, is declined or expires, the winner (or, for a refund, the round's creator) can ask support to send it again. Please keep your trade URL up to date.

9.5 Steam can hold, delay or block trades, for example on accounts without the Steam Guard Mobile Authenticator. We cannot remove Steam holds or reverse completed Steam trades, but we will give you our records to help you deal with Steam.

Item values and the house fee

9.6 Item values are in US dollars and come from the Steam Community Market. They are shown before you confirm, and they may change between rounds. A round always uses the values recorded for your items when you confirmed your stake. Those values are shown on the round card. We do not revalue a settled round because market prices changed later. The current preview uses the owner's reference prices, not live market quotes.

9.7 The house fee is taken when a round settles, as whole items from the pot. We take the set of whole pot items worth as close as possible to, but not more than, 8% of the pot value, with the 8% cap calculated to the nearest cent. The fee can therefore be lower than 8%, and it is zero when no item fits. It is not a percentage of your profit. The winner receives all the other items.

9.8 Example 1. A pot of USD 196.00 contains items worth 60.00, 26.00, 9.50 and 4.50 from the creator and 70.00, 12.00, 9.00 and 5.00 from the joiner. The limit is 8% of 196.00, which is USD 15.68. The closest combination of whole items not over that limit is 9.50 + 5.00 = USD 14.50 (about 7.4% of the pot), so the winner receives items worth USD 181.50.

9.9 Example 2. A pot of USD 10.00 contains items worth 3.20 and 1.80 from the creator and 5.00 from the joiner. The limit is USD 0.80, and no single item is worth that little, so no fee is taken and the winner receives all three items.

9.10 If you dispute a fee, we recompute the selection from the recorded pot items and values. If a value was clearly wrong because of a pricing error, tell us. Pricing errors are handled under the error clauses of our Terms.

Events outside our control and impersonation

9.11 Valve or Facepunch may change or remove items, or restrict our bot accounts, which could stop us from delivering items. Our Terms then apply.

9.12 Only accept trade offers that match a round you have just created or joined. Decline any offer you did not expect, and tell us.

10. Account, moderation and chat complaints

10.1 We can mute a player from chat for 1 hour, 24 hours or 7 days, or ban an account. Every action is recorded in an audit log with the reason given at the time.

10.2 You may ask what action was taken against your account and why. We will give you the recorded reason unless the law prevents it.

10.3 We will review whether the action was justified and lift it if it was not. The reversal is a new audit log entry, and the original entry is kept.

10.4 The public chat keeps only the latest 50 messages, in server memory. They disappear when the server restarts, and we cannot recover older messages. If you complain about something said in chat, send screenshots that show the time.

10.5 Complaints about suspension, closure or items held on a closed account are handled under this procedure. The grounds for those decisions are set out in our Terms.

11. Responsible gambling complaints

11.1 Send responsible gambling complaints to responsible-gambling@rust50.com or complaints@rust50.com, with "Responsible gambling" in the subject line. They follow the shorter time limits in section 6.

11.2 Examples: you received promotional messages while self-excluded or in a cooling-off period; you were able to play during a self-exclusion or cooling-off period; a limit you set was not applied; you believe a minor is using an account; or our marketing appeared aimed at minors or vulnerable people.

11.3 If a self-excluded person or a minor was able to play, we will block the account, return the items deposited within two business days (unless the law requires us to hold them), and report the case to the CGA within five working days, in line with our Responsible Gambling Policy and the CGA Responsible Gaming Policy.

11.4 If gambling is causing you harm, you do not need to make a complaint to get help. Our Responsible Gambling Policy lists support organisations.

12. Identity checks, AML holds and personal data

12.1 If your account or items are held because of an identity check or an anti-money-laundering review, you may complain under this procedure or contact compliance@rust50.com. We will explain what we need from you and why. The law forbids us to tell you whether we have reported a transaction to the Financial Intelligence Unit, so we will not confirm or deny it. See our AML and KYC Policy.

12.2 For questions or complaints about your personal data, write to privacy@rust50.com. Our Privacy Policy explains your rights. You may also complain to the data protection supervisor in Curaçao, the College bescherming persoonsgegevens, or go to the courts of Curaçao, and, if the GDPR or UK GDPR applies to you, complain to the data protection authority where you live.

13. Our final decision and remedies

13.1 Our final decision is in writing and includes:

• your complaint reference and a summary of the complaint;
• the records and evidence we checked;
• what we found;
• our decision (upheld, partly upheld or not upheld) and the reasons for it;
• any remedy, and when we will carry it out; and
• how to take the matter to ADR, with the provider's contact details and any deadline, and the information in sections 16 and 17.

13.2 Depending on the complaint, remedies may include: returning items or resending a payout or refund offer; voiding a round and returning both stakes; correcting a settlement; lifting a mute, ban or restriction; correcting your personal data; an explanation and apology; and changes to our processes.

13.3 The Site deals only in Steam items, so remedies are delivered as Steam items by trade offer. We do not pay cash or cryptocurrency, and we do not guarantee that any item has a cash value.

13.4 We carry out an agreed remedy promptly. A trade offer sent as a remedy must be accepted within 3 days. If you do not accept the remedy, you may take the dispute to ADR.

14. Internal review

14.1 Before our final decision, you may ask the person responsible for complaints oversight to review how your complaint is being handled. The review does not extend the time limits in section 6.

14.2 If new evidence comes to light after our final decision, send it to us and we will consider reopening the complaint. That does not stop you going to ADR.

15. Independent alternative dispute resolution

15.1 If you are not satisfied with our final decision, you may refer the dispute to our independent ADR provider, the Cyprus Consumer Protection Service (Ministry of Energy, Commerce and Industry), which you can contact at https://www.mcit.gov.cy. ADR is free to you, because we pay all of its costs. We provide ADR as article 5.3 of the LOK requires.

15.2 You may go to ADR after you receive our final decision or, subject to the provider's rules, if we have not given you a final decision within the time limits in section 6.

15.3 To start ADR, contact the Cyprus Consumer Protection Service (Ministry of Energy, Commerce and Industry) directly. Give them our complaint reference number, a copy of our final decision if you have one, and your evidence. The provider applies its own rules, including any time limit for referrals.

15.4 The effect of the ADR decision on you and on us, including whether it is binding and how it affects your right to go to court, is set out in the provider's rules. We will send you those rules with our final decision.

15.5 Once ADR with one certified provider is complete, the same dispute cannot be started again with another provider. If you withdraw from ADR, you may not raise the same dispute in ADR again.

15.6 Responsible gambling disputes, such as a self-excluded person being allowed to play, may be referred to ADR whatever amount is involved.

16. The Curaçao Gaming Authority

16.1 Once our licence is in force, the CGA is our licensing authority and supervises our licensed activity. The CGA does not decide individual disputes about rounds or transactions. It does not review our decisions or ADR decisions, unless a complaint was handled inadequately.

16.2 You may contact the CGA at any time about suspected malpractice, a breach of our licence, or as a whistleblower, through its website at https://www.cga.cw. We will never restrict or discourage this, and nothing in our Terms prevents it.

16.3 The current test preview is not offered under a CGA licence. Please send complaints about the preview to us.

17. Courts and your legal rights

17.1 Our agreement with you is governed by the law of Curaçao, in line with article 5.5 of the LOK, and disputes may be brought before the competent court in Curaçao, as set out in clause 26 of our Terms.

17.2 This procedure does not limit your right to go to court, except as set out in ADR rules that you have agreed to. It does not remove any right you have under mandatory law.

18. Records we keep

18.1 Our complaints register records, for each complaint, the reference, the key dates, the category, your SteamID64, the evidence and correspondence, the decision and remedy, any ADR referral and outcome, and whether each time limit was met.

18.2 We keep complaint records for at least five years after the complaint is closed, or longer if the law or a regulator requires it. Records linked to a complaint that we must keep under anti-money-laundering law follow their own periods: transaction records (rounds, trades and fees) are kept for at least five years after each transaction, and identification and customer due diligence records for at least five years after the business relationship ends, in each case for up to ten years if the Financial Intelligence Unit or another competent authority orders it. The moderation audit log is kept for five years after the account concerned is closed, and each entry for at least five years from its date. The full retention rules are in section 13 of our Privacy Policy.

18.3 Round and fairness records are never rewritten. Any correction is stored as a separate record that refers to the original.

18.4 Once licensed, we report complaint and ADR figures to the CGA twice a year, by 15 January and 15 June.

18.5 We use complaint information only to handle the complaint, meet our legal duties and improve our service (see our Privacy Policy).

19. No fees, no retaliation, respectful contact

19.1 Complaining is free, and you will not be treated less favourably because you complained.

19.2 If messages become abusive or threatening, we may ask that further contact be in writing only. We will still decide your complaint.

19.3 If you repeat a complaint we have decided, without new information, we will refer you in writing to our decision and to ADR.

20. Changes and contact summary

20.1 We may update this procedure, for example to reflect changes in the law, CGA policy or our service. The version and effective date at the top show which version applies. A complaint is handled under the version in force when we received it, unless a later version is better for you.

20.2 Contacts: