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, or a representative or member of one of these organisations) uses our software to:

• Create a numbered grid of 25, 50, 100, 500 or 1,000 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 software and sharing tools through which Organisers make their Fundraisers available to Participants. Each Fundraiser is created, offered, promoted and conducted by its Organiser.

The Organiser determines the Fundraiser rules, prize structure, intended participants and whether and when to initiate the draw. Lucky Squares Australia provides the software infrastructure and does not independently determine whether a Fundraiser proceeds.

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 Organiser is responsible for the permits and conduct requirements applying to its Fundraiser. Lucky Squares Australia remains responsible for any obligations that legislation independently imposes on it as the Platform provider
• 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
• Lucky Squares Australia provides software and sharing tools through which Organisers make their Fundraisers available to Participants. Each Fundraiser is created, offered, promoted and conducted by its Organiser. Lucky Squares Australia does not independently determine whether a Fundraiser is offered, who it is offered to, its prize structure, or whether its draw proceeds
• Lucky Squares Australia does not hold participant funds beneficially and does not pay prizes. Payouts to an Organiser are only ever suspended or delayed for fraud prevention, compliance, chargeback, or dispute-management reasons
• Winning squares are selected using a cryptographically secure random-number generator designed to produce unpredictable and impartial results

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 Organiser is responsible for conducting the Fundraiser and satisfying all legal, licensing, permit and conduct requirements applying to it. Lucky Squares Australia remains responsible for its own obligations as provider of the Platform and does not exclude any responsibility that cannot lawfully be excluded.

The following is a general summary of permit-free thresholds for community and charity raffles in each Australian jurisdiction. This summary is provided for information only and does not constitute legal advice.

In every jurisdiction, the dollar threshold shown is necessary but not sufficient. Staying under the threshold does not, by itself, guarantee your raffle is compliant. Permit-free status also depends on being an eligible organisation type (charity, not-for-profit, or club), following the specific conduct rules that apply (ticket pricing, draw timing, record-keeping), and not operating for private or commercial gain.

Thresholds checked against each regulator's published page in July 2026. Some (particularly Victoria's) are periodically indexed or adjusted. Always confirm current rules on the regulator's own page, linked below, before relying on any exemption.

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

July 2026: Lucky Squares Australia obtained independent legal advice on its platform model. That advice concluded that the current model is more properly characterised as a technology facilitation model than a promoter or operator model, provided the Organiser retains responsibility for creating the campaign, setting prizes, initiating the draw, meeting permit and licensing requirements, notifying winners and paying prizes. Lucky Squares Australia has requested written confirmation from Consumer and Business Services regarding the application of South Australia's supplier licensing regime.