アンジュアンゲーミングライセンス責任あるゲーミングルール/行動規範 (3ページ)

Self-exclusion is meant to be a serious protection tool for players, and it must be treated as such.

I am writing this to highlight a pattern of behaviour that, in my opinion, shows how self-exclusion is being ignored and how vulnerable players are being exploited.

I have permanent self-exclusion active with one casino (22Bet). Despite this, I recently received promotional/spam messages from a related casino (20Bet), which strongly suggests that self-exclusion is not being respected across the same casino group. This is extremely concerning, especially when players have clear gambling problems and have taken the step to protect themselves.

In my case, and in other similar cases I have seen, there is evidence of a broader pattern:

Self-excluded players still receiving marketing messages

Access being enabled through alternative links or related brands

Vulnerable players being targeted instead of protected

This is not only irresponsible, but also an unfair and unethical way of generating profit by exploiting players who are already struggling.

Additionally, I strongly believe that KYC should be mandatory before any deposits are allowed. Without proper verification, casinos cannot know who is actually playing. This creates serious risks, including the possibility of underage gambling, which should never be acceptable.

I am not posting this only for my own case.

I am doing this to emphasize that self-exclusion must be respected across casino groups and brands, and that responsible gambling tools must not exist only "on paper".

Players who choose self-exclusion are asking for protection — not loopholes.

I hope Casino Guru and the community will take this seriously and look into whether these practices align with responsible gambling standards.

I just moved your other post here because it addresses the same issue, and I believe losing the context with AOFA as a licensing authority would be quite a shame. I hope you don't mind.

Hi Radka,

thank you for letting me know — I don’t mind at all.

I agree that keeping the AOFA context is important, especially since licensing authorities play a key role in how self-exclusion and responsible gambling obligations are enforced in practice.

My main intention here is to highlight how self-exclusion can lose its purpose when it is not respected across related brands or groups, regardless of the specific operator involved. From a player’s perspective, this creates a real risk, particularly for vulnerable players who rely on self-exclusion as a last line of protection.

I appreciate you keeping the discussion structured and contextual, and I’m glad this topic can be examined with the broader regulatory framework in mind.

Thank you.

Maybe adding a link to the associated complaint would also enrich the subject. However, I understand that self-exclusion and gambling harm are both sensitive matters, so if you don't like the idea, I'll erase the link.

Here on the forum, we strive to support such topics with concrete details, and complaints play a significant role in this effort.

To be honest, as we discussed earlier, there is actually no working broader regulatory framework when it comes to most of the offshore licenses; therefore, my colleagues are capable of applying our own fair approach instead. Once the specialist is assigned to your complaint, we shall learn more, of course.

Thank you, Radka.

I agree that adding a link to the associated complaint makes sense and can help provide clearer context. I am fine with including it.

I appreciate the careful approach given the sensitivity of self-exclusion and responsible gambling, and I’m looking forward to the specialist reviewing the full details once assigned.

I feel I should thank you for your openness and willingness to discuss topics that can be quite emotional, complicated, and important to address. Thank you for keeping this conversation running.

From my perspective, theoretical instructions, even in the form of a short article in casino terms, are one thing, but when it comes to the actual need for account closure, especially due to health risk, the events get more intense and thus complicated.

I'm not an expert for such debates, but I guess it is still vital to compare reasonable advice with the everyday casino reality. Let's say that sometimes stating "I want to close my account immediately and permanently due to gambling addiction" to the casinos is just a first step. In my opinion things would be much easier for players and casinos alike if the operators agreed to specific standards and procedures.

That's, by the way, something my colleague Šimon strives to achieve.

(https://casino.guru/team/simon-vincze That's him)

Thank you, Radka, for your thoughtful response and for acknowledging how complex and sensitive these situations can be.

I appreciate that Casino Guru is also looking at the broader picture, including initiatives such as the work led by your colleague Simon toward clearer and more consistent self-exclusion standards across the industry. I fully agree that having defined procedures would significantly reduce ambiguity and protect players more effectively.

At the same time, I would like to clarify the sequence of events in my specific case to avoid any misunderstanding:

• I have documented proof that my account was permanently closed due to self-exclusion on 21 October 2024.

• Despite this, I later received promotional SMS messages containing direct links, which allowed me to access the platform again.

• Those links bypassed the existing block, after which I was able to deposit funds that should never have been accepted in the first place.

• As a result of this failure to enforce self-exclusion, I suffered financial losses of approximately €8,000, which are fully documented through bank statements, payment records, and chat screenshots.

This is not a theoretical discussion for me, but a real-world example of what happens when self-exclusion mechanisms fail in practice. My case illustrates precisely why stronger, enforceable standards are needed — not only in policy, but in actual system behavior.

All relevant evidence has been provided, and I am fully cooperating with the complaint process. I believe this case can serve as a concrete reference point for the broader discussion around responsible gambling protections.

Thank you for continuing this dialogue.

Precisely, I see this as a sort of clash of theory challenged by the practices applied.

Back to the details provided: Do I understand correctly that those messages you mentioned allowed you access to your formerly closed account? Or were you perhaps allowed to create a new one?

Thank you for the clarification question, Radka.

To answer it precisely: I was not allowed to create a new account.

The promotional SMS messages contained direct links that enabled access to my previously closed account.

Before receiving those messages, I was not able to log in. However, after clicking the promotional link, I was taken to the platform and was allowed to reset my password, which then granted me full access to the same account that had already been permanently closed due to self-exclusion.

There was no new registration, no new identity, and no new account created.

This means the self-exclusion was technically bypassed, as a closed account should never allow login or password reset under any circumstances.

I have screenshots documenting:

the promotional SMS messages,

confirmation of my account closure,

the password reset process,

and the subsequent access and deposits.

I hope this clarifies the situation clearly.

Your experience appears to be the most severe of those two scenarios. Allowing a player to access a previously closed account, when gambling harm was the reason for the closure, is far worse than providing a promotional link for new registration.

I'd say that such action completely circumvents any system restrictions that the platform may impose.

All of the screenshots mentioned will undoubtedly have an impact on the complaint.

Hello Radka,

I just wanted to update you on the situation. Casino Guru has closed my complaint because I was unable to provide proof of my original self-exclusion request. As I mentioned before, I had deleted those emails and messages two years ago because I wanted to completely distance myself from gambling and move on.

I wanted to make sure you understand why the complaint was closed despite the documented timeline of events.

Hello Radka,

Just to keep you updated — I have now submitted a formal GDPR data access request to the casino asking for all records related to my account, including my original self-exclusion and account closure.

If they provide any documentation confirming this, I will share it with you.

Thank you for your time and guidance.

Hello. First of all, I'm sorry I wasn't here to respond. I felt ill, but I'm back "online."

Quite often are my colleagues from the Complaint Team in similar situations to yours. The situation seems clear, but we lack the evidence to confront the casino. I wish we could act differently, but from the practical perspective there is truly no way round it.

In my opinion, it was pretty smart to use GDPR as a way to get that email once more, and hopefully it will turn out positively.

Hi Radka,

I would like to provide an important update regarding my case with Boomerang Casino.

I submitted a GDPR data access request more than 30 days ago, requesting all records related to my account, including communication history, responsible gambling notes, and self-exclusion records.

However, I have not received any data to this day. The casino only states that the request is "in process", which does not comply with GDPR requirements.

This is very concerning because I previously requested permanent self-exclusion due to problem gambling, yet I was later able to reset my password, access my account, deposit funds, and continue gambling.

Additionally, I received promotional communications encouraging me to play again.

Without the GDPR data, I am unable to prove my case properly, and it seems the casino is delaying or avoiding providing key evidence.

I would kindly ask you to take this into consideration, as I believe this is a serious issue involving both responsible gambling violations and lack of transparency.

Thank you for your help.

Kind regards, 

Marko

Hello, Marko.

I understand what you're saying. However, my acknowledgement won't very much affect the complaint. I suggest you keep your mediator always up-to-date. In my view, the lack of evidence you described prevented the original complaint from reaching further states, but providing new information or the missing proof is crucial for the new request or for reopening the request. Once the complaint reaches the stage where my colleagues could not challenge the casino actions, the only way through is with new information.

Just as stated:

"However, we won’t be able to assist further in this matter. The self-exclusion request, where a player stated the gambling problem clearly, is the essential evidence that each player must provide in order for us to proceed with a case like this. Since you didn't provide the request, we cannot handle this case as a failed self-exclusion and request a refund."

In my opinion, the main problem is not with DGPR data, but please feel free to explain your viewpoint further.

Hi,

Thank you for your response.

I understand that proof of self-exclusion is required. However, I would like to clarify an important point.

I have submitted a GDPR data access request to Boomerang Casino more than 30 days ago, specifically requesting all communication history, including any self-exclusion requests and responsible gambling records.

To this day, the casino has failed to provide this data and only states that the request is "in process".

This means I am currently unable to provide the required evidence, not because it does not exist, but because the casino is withholding it.

I believe this should be taken into consideration, as the lack of cooperation from the casino directly prevents me from proving my case.

Additionally, I have received marketing communications after my attempt to stop gambling, which further raises concerns about their responsible gambling practices.

I kindly ask you to reconsider the case or advise how this situation can be fairly evaluated when the casino is not complying with GDPR obligations.

Kind regards,

Hello, I understand this viewpoint, but to me, it seems you expect something a bit different from such a step. For instance, I don't know what the correct request looks like or who to send it to. A text generated by ChatGPT, for instance, won't work in a chat. Aside from that, finding the official way to enforce such action is also quite complicated. As far as I can tell, the GDPR procedure is not a way to ask for documents out of a company; it serves to protect privacy. And we are in no position to escalate GDPR requests. Moreover, an incorrect MCC code is not ultimately a reason for a refund or chargeback. The overseeing protection authority in your country and your national bank may provide you proper information.

Even if the casino later provides your data, it must clearly demonstrate that a valid self-exclusion request was submitted and received. Without that, the complaint cannot be evaluated as a failed self-exclusion case.

Hi Radka,

I understand your point.

The problem is that I cannot provide the evidence you are asking for because the casino is not giving me my GDPR data, even after more than 30 days.

So I am basically stuck – I need the data to prove my case, but the casino is not providing it.

That’s why I believe this situation is not entirely fair, because I am trying to cooperate and provide evidence, but I’m unable to access it.

I will wait for their response and update the case if I receive anything.

Kind regards,

Marko

Hi Marko, I truly understand it. We have always tried to encourage players to take screenshots of those requests or to save the emails for later "use." Because such crucial evidence is inaccessible, we cannot investigate further; this situation does not imply you did something wrong. From our perspective, it's just impossible to challenge casinos without having something in our hands. The mediators and I will be here if something changes, of course.

Stay well, please.

Interesting and useful topic, thank you.