Compliance Statement

Lucky Squares Australia is a software-as-a-service platform. We provide digital tools that enable community organisations to conduct grid-based fundraising activities. We are a technology provider, not a fundraising operator, lottery operator, or games of chance provider.

This distinction is fundamental to how we operate and how we understand our obligations under Australian law.

An Organiser (a community group, sporting club, or registered charity) uses our software to:

• Create a numbered grid of 25, 50, or 100 squares
• Set a price per square and prize structure
• Share the grid with their community
• Conduct a randomised draw when squares are sold

Lucky Squares Australia provides the software infrastructure for these activities. The Organiser recruits participants, collects funds, conducts the draw through our platform, and pays prizes. The entire fundraising activity is operated by the Organiser.

Fundraising activities involving consideration, chance, and a prize may be classified as lotteries or games of chance under Australian state and territory legislation. Regulation varies significantly by jurisdiction.

Lucky Squares Australia's position is that:

• The Organiser is the operator of any fundraising activity conducted through the Platform
• The permit and compliance obligations imposed by state and territory gaming legislation fall on the Organiser, not on Lucky Squares Australia
• Lucky Squares Australia's role is analogous to that of other SaaS platforms that provide tools used by operators in regulated industries, without themselves being operators
• The Platform does not solicit participants, collect prize funds, distribute prizes, or promote specific fundraisers to the general public

Organisers are required by our Terms of Service to:

• Ensure their fundraiser complies with all applicable laws in their jurisdiction
• Obtain any required permits or authorisations before launching a fundraiser
• Accurately represent the prize structure and draw rules to participants
• Pay all prizes as advertised
• Manage all participant funds in accordance with applicable law

Lucky Squares Australia does not verify that Organisers have obtained required permits. Organisers warrant compliance as a condition of using the Platform.

The following is a general summary of permit requirements for lucky squares style fundraisers in each Australian jurisdiction. This summary is provided for information only and does not constitute legal advice. Organisers should seek independent legal advice regarding their specific obligations.

Lucky Squares Australia is committed to operating responsibly and supporting Organisers to conduct compliant fundraising activities. We:

• Clearly disclose our role as a platform provider, not an operator, throughout the Platform
• Require Organisers to warrant compliance as a condition of use
• Display clear participant disclosures identifying the Organiser as the operator
• Cooperate with any regulatory authority inquiry or investigation
• Maintain legal review of our platform model and terms on an ongoing basis

This Compliance Statement and Lucky Squares Australia's overall platform model has been reviewed by [Law Firm Name], [City], South Australia. A written legal opinion dated [Date] is held on file.