During reading your terms, two things draw my attention. It's about age restrictions and suspended accounts. Since you aren't verifying user KYC, then how are you going to ensure users age? I am not sure if there are any other alternatives to make sure users aren't underage.
Buying crypto in general requires a KYC so it should make sure the users are 18+. Also parents should be responsible for their children.
In most cases KYC doesn't care about the age it just tries to stop users from withdrawing money.
And another thing is you can suspend accounts with or without reasons, which is quite alarming to me. If you suspend, then what about the winners who win funds, or what about the initial deposits? I am expecting honest answers from you.
If users abuse bonuses the inital deposit wont be refunded ofc. Till now nobody who didn't abuse has been banned.