Dear Google Play Policy Team

Thank you for taking the time to review our application.

We fully understand and respect that Google Play has its own internal policies and compliance framework.
Our team is committed to aligning our app with all of your requirements to ensure full compliance.

However, we would like to draw your attention to the fact that Apple initially rejected our app for similar reasons.
Once we submitted our detailed legal and technical explanations, Apple acknowledged the lawful and skill-based nature of our platform consistent with the legal standards of the United States and most international jurisdictions.

As a result, our app was approved and successfully published on the Apple App Store under the Board Games category, where it is now available in over 99% of global regions, including all U.S. states and European countries.

📱 Approved App Store link:
👉 https://apps.apple.com/app/palgam/id6747165623

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Overview of Our Application

The wallet component in Palgam is purely non-custodial, meaning the application does not handle, store, or access any user funds or private keys.
No fiat or cryptocurrency transactions are processed within the app itself.
It functions solely as an interface to display users’ decentralized wallet balances, similar to Trust Wallet or MetaMask.

We would also like to draw your attention to the following key points regarding our innovative and skill-based gaming application:

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1. Skill-Based Nature

The Palgam platform is entirely skill-based.
All match and tournament outcomes are determined solely by the players’ performance, decision making, and skill.
There are no random algorithms, elements of chance, or probability based factors influencing the results.
Our application does not include any chance-based systems such as slot machines, roulette, or lotteries.

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2. Legal Definition of “Gambling”

The legal definition of “gambling” requires the presence of an element of chance, not skill.
According to internationally recognized regulatory standards including those of the UK Gambling Commission (UKGC) and the U.S. Federal Trade Commission (FTC) a game is classified as “gambling” only when chance or randomness plays a material role in determining the outcome.

Since the mechanics of Palgam’s games rely entirely on skill, strategy, and player decision making, they cannot be legally categorized as gambling.

From the perspective of international law (United Kingdom, United States, and the European Union):
A game whose outcome depends on player skill, where chance does not exist or does not play a significant role,
is not considered gambling or betting under any jurisdiction.

Therefore, the reasoning presented above is not only correct but also fully consistent with the letter and spirit of applicable laws.

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Legal References

a. United Kingdom – Gambling Act 2005 (Section 6(2–3))

“Gaming” means playing a game of chance for a prize.
A game of chance includes games that combine skill and chance,
but does not include games that are determined purely by skill.
https://www.legislation.gov.uk/ukpga/2005/19/section/6

b. United Kingdom – Gambling Commission Guidance (2017)

“Games that are determined by skill, judgment, or knowledge and not by chance are not gambling under UK law.”

https://www.gamblingcommission.gov.uk/news/article/raffling-big-ticket-items-prizes-pitfalls-and-potential-risks

c. United States – Illegal Gambling Business Act (18 U.S.C. §1955)

Defines “gambling” as the act of betting or wagering on games of chance.
Skill-based competitions, where chance plays no material role, do not constitute gambling under federal law.

https://www.law.cornell.edu/uscode/text/18/1955

d. United States – Federal Trade Commission (FTC)

The FTC recognizes skill-based contests as lawful, provided that outcomes depend on participant skill rather than chance.

https://www.ftc.gov/lottery-sweepstakes

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3. No Betting or Prediction Functionality

There is no betting or prediction functionality within Palgam.
Users cannot place wagers on outcomes or stake any amount on uncertain events.
The application serves solely as a fair competition platform where players engage in skill-based games such as billiards, backgammon, and table soccer, with results determined entirely by player performance.

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4. Non-Custodial Wallet and KYC Exemption

The in-app Tether (USDT) wallet is non-custodial, meaning users retain full control of their private keys and funds.
Similar to decentralized wallets such as Trust Wallet and MetaMask, Palgam does not have access to or custody over user assets, and therefore, under U.S. federal regulations (FinCEN) and equivalent international frameworks, such applications are not required to perform KYC verification.

Supporting References:

a. FinCEN (U.S. Department of the Treasury) – Guidance FIN-2019-G001

“An application that only provides users with a non-custodial wallet or the ability to store and transmit virtual currency where the user retains control of the private keys is not a money transmitter under the Bank Secrecy Act (BSA).”

https://www.fincen.gov/resources/statutes-regulations/guidance/application-fincens-regulations-certain-business-models

b. European Banking Authority (EBA) – Opinion (2020)

“Providers of non-custodial wallet software that do not control users’ private keys are outside the scope of AMLD5.”

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32018L0843

c. Trust Wallet – Official Policy

“Trust Wallet is a non-custodial wallet, meaning we never access or store your private keys, backup files, or funds. Users are responsible for managing their own security.”

https://trustwallet.com/privacy-policy

Under FinCEN’s 2019 Guidance and equivalent international interpretations,
decentralized non-custodial wallets  where users control their own private keys  are not money transmitters and thus not required to perform KYC.
Palgam’s wallet follows the same lawful model as Trust Wallet and MetaMask.

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5. Licensing and Audit

Our smart contract, which guarantees fairness, transparency, and integrity in all financial transactions,
has been independently audited by the globally recognized blockchain security firm CertiK.
This demonstrates our commitment to compliance, attention to detail, and adherence to international technical and legal standards.

• Palgam Whitepaper: https://palgam.com/whitePaper

• CertiK Audit Report: https://skynet.certik.com/projects/palgam

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6. Revenue Model

Our revenue model is structured such that the application itself does not directly handle or control any user funds.
The app functions solely as a decentralized bridge and smart contract executor between players.
When two players engage in a one-on-one match, the smart contract automatically processes all financial instructions between them, ensuring full transparency and fairness without any manual intervention by the platform.

Under Palgam’s revenue structure:
• A 3% service fee is automatically deducted from the winner’s earnings in “Play-to-Earn” matches as the platform’s operational revenue.
• In tournament modes, the application deducts 10% of the total prize pool as a service fee, while the remaining 90% is automatically distributed among the top three winners according to predefined ratios.

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Conclusion

We have developed our gaming application with full respect for all applicable legal and regulatory requirements to ensure that our product operates within a lawful and transparent framework.
Compliance and transparency have always been the foundation of our project.

This commitment to legality and clarity was precisely the reason why our app was approved and successfully published on the Apple App Store.

Therefore, in light of the clear explanations and legal references we have provided,
we respectfully request that our application be recognized as a skill-based gaming app with earning features, which accurately reflects its true nature.

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Best regards,
Palgam LLC