Legality
Last updated on 15 June, 2025
ELSEWORLD LABS PRIVATE LIMITED (“Xchange”, “we”, “us”, or “our”) is committed to operating in full compliance with Indian law. This page outlines the legal foundations of our platform and provides users with clarity on how Xchange is structured to ensure that it operates legally and transparently in India.
1. Introduction
1.1 Xchange is a digital opinion trading platform where users can buy and sell units representing their opinion on the outcome of future real-world events.
1.2 We have sought legal clarity to ensure that the design and functioning of the Xchange platform does not fall under any prohibitions under Indian law, especially those governing gambling, betting, or chance-based games.
2. Game of Skill vs Game of Chance
2.1 Indian courts have historically distinguished between:
Games of Skill, which are legal and constitutionally protected under Article 19(1)(g)
Games of Chance, which are considered gambling and may be regulated or prohibited under state laws
2.2 Based on this framework, Xchange has been structured and operates as a Game of Skill. Success on the platform depends on users applying reasoning, judgment, awareness of real-world trends, and accurate forecasting based on skill rather than random chance.
3. How Xchange Complies
3.1 No Betting or Wagering
Xchange does not allow users to bet against the house or engage in games of chance. All transactions are user-to-user; Xchange acts purely as a facilitator by matching orders in the market.
3.2 Skill-Based Decisions
Users must analyze publicly available information, consider historical patterns, and apply reasoning to determine how likely an event is to occur. This decision-making framework aligns with the legal test for a "game of skill".
3.3 No Gambling License Required
Because the platform involves a skill-based activity and does not involve wagering in the traditional sense (i.e. users are not staking money on uncertain outcomes in a manner of gambling), the activity conducted on Xchange does not require a gambling license under current Indian central or state laws.
3.4 User vs User Transactions
There is no house or bookmaker model. Users buy and sell units from one another based on the price they are willing to pay, making this closer to a prediction exchange or a peer-to-peer market.
4. Platform Structure
4.1 The Platform does not set or influence odds. Prices of units are based solely on user activity, and Xchange does not provide any guaranteed outcome or payout.
4.2 Events listed are objectively verifiable, publicly traceable, and resolved using data sources that are transparent and reliable.
4.3 Xchange earns revenue through service fees or transaction commissions, not through gambling profits.
5. Compliance Practices
5.1 KYC & AML
We implement strict Know Your Customer (KYC) protocols in accordance with RBI guidelines and applicable financial regulations. Users must undergo verification before participating in financial activities.
5.2 Payment Gateways
All deposits and withdrawals are processed through RBI-compliant payment aggregators. Funds are not pooled for speculative use, and user balances are transparently maintained.
5.3 Data Integrity & Auditability
All trades are logged, time-stamped, and made available for internal and external audits. The platform uses secure systems to prevent fraud, manipulation, and collusion.
6. No Violation of State Laws
6.1 The platform does not conduct or promote any activity prohibited under the Public Gambling Act, 1867 or the Information Technology Act, 2000.
6.2 Since Xchange is a Game of Skill and not a gambling activity, state-level prohibitions on gambling do not apply to the platform in its current form.
7. Legal Interpretation and Assumptions
7.1 This legality opinion is based on current Indian laws and judicial interpretations as of the date of this document. Should regulations evolve, Xchange is committed to modifying or suspending services as required to maintain legal compliance.
7.2 Users are expected to use the platform only in jurisdictions where participation in skill-based opinion markets is permitted by law. By using Xchange, you represent that your use of the platform does not violate any local laws applicable to you.
8. Legal Summary
Xchange is not gambling
Xchange is not a betting platform
Xchange is not a lottery, fantasy game, or casino
Xchange is a peer-to-peer opinion trading exchange, governed by skill and reasoning, and not governed by chance
9. Contact Us
If you have any questions regarding the legality of Xchange or would like to request clarifications, please contact:
Email: hello@xchange.com
Address: D-9, Associated Apartments, I.P. Extension, Delhi-92