Complaints

[pinnit2015]

This is the key bit in the LCCP. Should be noted that the UKGC recommended (to the government)that that in their view, no further legislation was needed, but a strengthening of the casinos' commitment to this.

People wondering why casino's now get a bit funny if you ask for a bonus: below is your answer

 

[pinnit2015]

On a side note, re regulation - https://www.thisismoney.co.uk/money/markets/article-7220011/Betting-crackdown-drive-punters-offshore-sites-says-William-Hill-boss.html

Obviously WH have a vested interest in this but the points still valid. 

[pinnit2015]

Last thing, there are calls for more to be done by some (who may/may not have an agenda)

 - Greater information exchanges between casinos, essentially tracking betting and deposit patterns to identify players,

 - Mandatory default deposit limits, raised only upon completion of a credit check/affordability check.

I tend to take a lot of views with a pinch of salt: you have political groups connected with the gambling sector (so their view will be it's fine as it is), and there are those on the other side of the spectrum who seem to protect all individuals against any harm, ever. 

[Steven339]

Interesting read. I’ve compiled a list of events over the a 16 month period in relation to the events surround my sons interaction  with this casino. We have requested a further subject access request to ensure there are no further account closures we have missed. I’ve also copied in just 1 e mail below withholding information about identity but the majority of e mails follow the same patern. The phone calls have also been of the same nature. My understanding is once a have had a response We need to discuss this with the Ukgc as per the statement on ibas website

. 

 

This is the wording of 3  of the e mails. My son tells me the casino would call him if they did hear back to then discuss this further, and on occasions they would intice him into re opening with further offers and invites to race days , boxes as comedy Events and fight profile football games

you might have an opinion on these like I said lots of e mails 

Hi Steven

I’ve noticed you closed your account with one of our live chat agents 2 days ago. I saw the reasons for closing the account and I did do a review on your account and you are right that you account has been a little under our usual bonuses recently. If you would be happy to re-open the account I can put £50 cash onto the account for you based on your current activity this month.

Going forward we are always more than happy for you to send us a quick email asking if there are any bonuses we can add to your account (about once a week is a good number) and then myself or one of the other VIP Executives here will be able to take a look at your account and if we are able to add something on we will. We are here to make sure everything is going well and your having fun playing and especially if you have been having some bad luck recently we can always look to add a cash bonus to your account for you. Keep in mind 99% of the time our bonuses are Cash and do not require any wagering so it really beneficial for our players.

Hopefully you will reconsider, I know you have been a customer of ours for a long time but hopefully with the above taken in mind you will agree we can do more and will be happy to do so.

Thank you,

 

 

 

Hi Steven, 

Thanks for getting back to me, I'm sorry to hear that things have not been going your way on the site. I would like to offer you a £150 VIP Bonus for you to have some play on me to see if you can turn things around. Let me know if you want me to re-open your account and add the bonus for you. 

I look forward to hearing from you.  

 

Hi Steven, 

I am sorry to see that you have requested to close your account last night. Is there any particular reason why you have come to this decision? Is there anything I can do to help in anyway? Obviously we do not like it when any of our player close their accounts, especially if there is something that can be done to help. 

I look forward to hearing from you.

 

[pinnit2015]

The wording sounds familiar to one of the casinos i use.

What reason did your son give for closing the account? Lack of bonus's? Bad luck?

Asking players to re-open accounts, after they request closure, is  a tricky one: in todays era, i envisage the UKGC not being overly impressed. It's one thing to try and get back dormant players, but they may see trying to get someone to re-open a closed account (just showing you that closed never means closed!) as somewhat predatory; particularly, if their accounts points to heavy losses over a short period.  Again, it's a balancing act: people are quick to say casinos aren't personal anymore/that they don't care for customer retention etc. 

My layman's view (and i'm not an expert in this, just a passing interest) is that even if he said it was because of bonus's, but his account showed heavy losses in a short period, there could be the perception that they are a tad predatory in the 're-open' emails. The casino would, quite rightly, say that as he didn't Self Exclude, how were they to know - recent cases by the UKGC have said, and i paraphrase, that this doesn't matter (and this is where the casinos come unstuck - they would argue they aren't mind readers).

It will come down to what policies/procedures/risk assessments they have in place - if they have NONE, your son could have said he was closing it as the casino was looking at him funny, and it wouldn't matter. 

Also, i'm not agreeing with either view on this: just giving a view from reading the recent decisions as to what their mindset is. 

[pinnit2015]

Also, from a Privacy Policy point of view - upon account closure they should stop processing your data ie. your contact details. Might be worthwhile throwing that into the mix as to what they continued to process his personal data (in making contact) when most privacy policies state that this ceases at the point of closure. 

[Steven339]

My son always gave 2 reasons 1.bad luck 2. Lack of bonuses. The first e mail above was from his last closure, I think this was either 13th or 14th closure we are just waiting for confirmation as some were closed via online chats, but in reality it was always after a heavy loss every time. The minute it was closed they would be on the phone in less than 24h if he didn’t pick up they would e mail him with the offering. 

The other 2 casinos in question didn’t do either he said he contacted them not the other way round after a month or so and they refused to reopen the accounts based on his account activity losses etc. 

 

It’s a learning curve for him, and me and im just as angry with him as I am with the casino so let me make it clear i will take the advise and follow up on what ever that may be if there’s no case then I accept that too, but judging by what I have researched and the advise I’ve been given I think there’s an argument here but I may be wrong. interestingly  Also he has now been informed he has a lifetime ban with the group, so even when his exclusion finishes he can’t rejoin either, that with the GameStop tool at least gives me piece of mind.

we will see what comes back from them I suppose.  

I have access to his e mails too

 

[pinnit2015]

Well, that's the thing: we have tools such as Gamstop/Bet Blocker etc but that's all they are, tools. Hopefully he decides he wants to quit for good as there will also be some Curacao/Costa Rica clip joint who will accept custom from the UK and negate at least the first tool. 

I've heard some people signing over control to their financial affairs as well, certainly at the start, that might serve him well.

Whatever it is , obviously, it's essentially down to him to succeed: in all our lives we hit that point of 'oops, gone too far' and it kick starts the recovery process; maybe this is his oops moment. 

 

[pinnit2015]

With the casinos who contacted him once he closed the account, there's probably a few key questions for them to answer. This is an extract of the Casumo decisions - I imagine your case is stronger here (given the limited info caveat), as they actually contacted him, rather than review him for possible issues. Should be noted that the UKGC, to my knowledge, wouldn't instruct a casino to reimburse any monies (Leo Vegas did but that was when they closed accounts with money in them) but it may be, depending on how it goes, that the casino do so: if so, make sure it goes to any debt accrued as part of this...

 

[Steven339]

Thanks again for you’re help.

i really don’t envisage any refunds tbh, what I would at the very least like them to do is acknowledge some failings and a promise to have a more proactive approach similar to what the other 2 casinos did. That would satisfy me at the very least, somewhat but we will Pursue this  nevertheless and will take it as far as we can.I’ve paid his debts off so any money her gets now has to go through me anyhow. 

My son has advised to 2 casinos who didn’t allow his to reopen where 32red and mansion I believe if that means anything 

[Steven339]

This was also another e mail of a different nature but supports the same argument no mention in this about there being a reason for failed deposits, anyway

Hi Steven,

In line with our payments procedures, and for your protection, following a large number of unsuccessful deposit attempts your Xxxx Casino cashier was temporarily disabled. 

Following a review of your account, your cashier is now enabled. 

If you continue to experience issues with your deposits, please contact your bank or payment provider for further information. In some instances payment providers may place restrictions on gaming transactions and will advise further. 

If you require any further information, please  click here to access the Xxxx Casino Help Centre

Kind regards,

  

[pinnit2015]

6 hours ago, Steven339 said:

Thanks again for you’re help.

i really don’t envisage any refunds tbh, what I would at the very least like them to do is acknowledge some failings and a promise to have a more proactive approach similar to what the other 2 casinos did. That would satisfy me at the very least, somewhat but we will Pursue this  nevertheless and will take it as far as we can.I’ve paid his debts off so any money her gets now has to go through me anyhow. 

My son has advised to 2 casinos who didn’t allow his to reopen where 32Red and Mansion I believe if that means anything 

To be honest, i'm more surprised 32red were the good ones as their RG history is patchy - if you ask to Self-Exclude they told you they'd email, you'd complete a form and then return it for it to be actioned. May have changed now but that wasn't that long ago.  Not singling these casinos out, all public information, but again this has been the UKGC's view for a number of years. 

 

[pinnit2015]

2 hours ago, Steven339 said:

This was also another e mail of a different nature but supports the same argument no mention in this about there being a reason for failed deposits, anyway

Hi Steven,

In line with our payments procedures, and for your protection, following a large number of unsuccessful deposit attempts your Xxxx Casino cashier was temporarily disabled. 

Following a review of your account, your cashier is now enabled. 

If you continue to experience issues with your deposits, please contact your bank or payment provider for further information. In some instances payment providers may place restrictions on gaming transactions and will advise further. 

If you require any further information, please  click here to access the Xxxx Casino Help Centre

Kind regards,

  

Been a while since i looked at it but IIRC a company receives a D code (for example) = declined, for example or a V code = Validation error (CVV), so they'll know whether i input the wrong CVV code 10 times or simply tried to deposit 100 quid with only a 10 balance, ten times. 

[Steven339]

16 minutes ago, pinnit2015 said:

To be honest, i'm more surprised 32Red were the good ones as their RG history is patchy - if you ask to Self-Exclude they told you they'd email, you'd complete a form and then return it for it to be actioned. May have changed now but that wasn't that long ago.  Not singling these casinos out, all public information, but again this has been the UKGC's View for a number of years. 

 

I Suppose this is the inconsistency referred to in your previous posts. Interestingly  my son says it was in fact this operator who called him late at night after a slightly large credit card deposit. They were the ones who asked all the questions about his welfare etc.

they said it was because he failed his first attempt by entering the wrong details and also it wasn’t inline with any of his previous sized deposits, so they asked him various questions before they allowed him to continue on there site. 

After the account closures later on the 3rd request he thinks they denied him access due to the number of closures in a short space of time. He said they advised him he could request again after what he recalls was either 3 or 6 months and they would look at it again. He didn’t go back after that.

[TheAverageGuy]

20 minutes ago, pinnit2015 said:

something I didn't mean to quote

 

30 minutes ago, pinnit2015 said:

To be honest, i'm more surprised 32Red were the good ones as their RG history is patchy - if you ask to Self-Exclude they told you they'd email, you'd complete a form and then return it for it to be actioned. May have changed now but that wasn't that long ago.  Not singling these casinos out, all public information, but again this has been the UKGC's View for a number of years. 

 

Times are tight.. Taxes are high, competition fierce.. The "smaller" shops can only afford the monetary slap on the wrist so many times before their margins don't work

Not everyone has the bankroll of say GiG/MTST who can just write it into the bottom line, close up some less popular clones and consolidate their dominion..

[Steven339]

This was another e mail I found this was earlier on in my sons earlier days with the site 

Hi xxxxx

 

Thank you for your e mail. The reason I'm closing the account is because I'm reducing the number of sites, I play on as it's hard to keep track of the cash flow best regards 

 

this is was followed by a call the following day with another gesture

 

anyways there are loads I could post on here but I feel there’s not much point now. I guess we will see what happened 

 

 

[Steven339]

Hi 

So we was promised that we would have heard from a senior manager within 28 days. It’s been over this and not heard anything. I’ve chased this 3-4 times as well as our request for my sons data but don’t seem to be getting anything back.

do we have options to explore?

Thanks 

[pinnit2015]

They’ve one month to supply the data. If they have gone over, this report them to the ICO. 

No harm in cc’ing the UKGC into a final chaser to at least show how much they care for their legal obligations.

‭(not sure if the above helps but I know someone who had  the UKGC take an interest in something using the above approach)

[pinnit2015]

Complaints about licensees
4.16 WhilsttheCommissiondoesnothaveaspecificstatutorydutytoinvestigatecomplaints about licensees, depending on the issues raised the Commission may decide to look into matters relating to the complaint. Further details of the Commission’s approach to complaints can be found in the Commission’s Complaints Policy which is on our website.

No spacing on the website; check out their complaints policy if you haven’t.

As someone who worked previously in doing risk assessments for organisations I’d be very surprised if their risk assessment procedures didn’t factor in any ‘notifications’ of licence breaches, to determine who to review. Hence why I said no harm in notifying them. 

[pinnit2015]

No harm in doing the final one to them, copy in and add a few bits of the code; For example, ‘as you know, under section 116 of the Act your licence may be reviewed’ etc ‘I will be asking the UKGC to take into account all the information supplied to them in determining the use of s116’ etc etc

Amazing what casinos do when they think you know what you’re talking about. 

Apart from that, you’ve pretty much done all you can. 

[Steven339]

Hi 

We have receive a respond from the company in question see below 

 

 

Dear xxxxxx

We write further to our email dated 18th June 2019. 

 

We have now concluded our review into your claim towards xxxx xxxxxxfailure in relation to Responsible Gambling policies and procedures.

 

We monitor accounts regularly and we act upon any gambling concerns that are raised through to the Responsible Gambling Team. Also, in line with our Responsible Gambling policies and procedures we offer gambling tools to all our customers. Information about these tools and how to instigate them are available on our website for all customers to view and all accounts are designed to be self-managed.

 

Following a thorough investigation, we can confirm that after multiple account closures, your account was referred for a Responsible Gambling chat in October 2017. In this conversation, you confirmed that you were happy with the levels of spend, had a deposit limit which you didn't go over and you were made aware of the Responsible Gambling tools that we offer. Following this chat, as you had satisfied us with your answers, your account remained open with no concerns. 

 

Your account was reviewed again in April 2018 after a number of account closure requests. During this conversation you were specifically asked about constant account closures and you responded advising that you play at a few other sites and you have a monthly gambling budget. As you were 'not very lucky' on our site, you would ask your account to be closed after any losing session. More often or not you would re-open the account and play again. You also advised that you were playing Leo Vegas at the time as you were getting 'few wins' there. 

 

We can confirm that you showed no signs of problem gambling when we attempted to reach out to you. However, once you requested Self Exclusion on your Xxxxxxxxxxx account on 21st May 2019, all of your Xxxxxxxxxxx accounts were immediately closed as per our Terms and Conditions. 

 

In conclusion and for absolute clarification, as we have acted in accordance with our Responsible Gambling policies, we will not be offering any form of refund/compensation for the dispute at hand, and we have satisfied with our legal requirements regarding Responsible Gambling.

 

Please be advised that this email represents the final stage of our internal complaints process as we have now reached a deadlock with your complaint. Therefore, should you remain dissatisfied with the outcome of your dispute, please be advised that you do have the option of referring your dispute to an approved Alternative Dispute Resolution provider (ADR) such as the Independent Betting Adjudication Service. You may also use the Online Dispute Resolution (ODR) platform to refer your dispute to IBAS, however, if you choose to use the ODR platform you would not be referring your dispute directly to IBAS and this may then prolong the process of resolving your dispute. Please use case reference Xxxxxx when escalating your dispute through the ADR authority. 

 

Please visit section 18.6 of our Terms and Conditions for more information on this point.

 

We have taken this opportunity to ensure that you have all the information regarding the help organisations that are available to provide support with problem gambling. We included this information at the end of this email.

 

Kind Regards,

 

 

In one one way we expected this but they have really dodged around the specific questions we asked. In particular they have failed the mention the number of account closures during the dates they believe they did the responsible gambling check, furthermore they have not offered any explanation of the reason why my son was contacted every time the account was closed, they have not answered when my son was upgraded on there vip status how they conducted a risk assessment  on him or why after frequent failed deposit attempts nothing was ever questioned.

ive responded asking some key questions that have been advised by you kind people but ccd the gambling commission in on this e mail.

 

will of course keep you posted 

 

regards 

 

[pinnit2015]

9 minutes ago, Steven339 said:

Hi 

We have receive a respond from the company in question see below 

 

 

Dear xxxxxx

We write further to our email dated 18th June 2019. 

 

We have now concluded our review into your claim towards xxxx xxxxxxfailure in relation to Responsible Gambling policies and procedures.

 

We monitor accounts regularly and we act upon any gambling concerns that are raised through to the Responsible Gambling Team. Also, in line with our Responsible Gambling policies and procedures we offer gambling tools to all our customers. Information about these tools and how to instigate them are available on our website for all customers to View and all accounts are designed to be self-managed.

 

Following a thorough investigation, we can confirm that after multiple account closures, your account was referred for a Responsible Gambling chat in October 2017. In this conversation, you confirmed that you were happy with the levels of spend, had a deposit limit which you didn't go over and you were made aware of the Responsible Gambling tools that we offer. Following this chat, as you had satisfied us with your answers, your account remained open with no concerns. 

 

Your account was reviewed again in April 2018 after a number of account closure requests. During this conversation you were specifically asked about constant account closures and you responded advising that you Play at a few other sites and you have a monthly gambling budget. As you were 'not very lucky' on our site, you would ask your account to be closed after any losing session. More often or not you would re-open the account and Play again. You also advised that you were playing Leo Vegas at the time as you were getting 'few wins' there. 

 

We can confirm that you showed no signs of problem gambling when we attempted to reach out to you. However, once you requested Self Exclusion on your Xxxxxxxxxxx account on 21st May 2019, all of your Xxxxxxxxxxx accounts were immediately closed as per our Terms and Conditions. 

 

In conclusion and for absolute clarification, as we have acted in accordance with our Responsible Gambling policies, we will not be offering any form of refund/compensation for the dispute at hand, and we have satisfied with our legal requirements regarding Responsible Gambling.

 

Please be advised that this email represents the final stage of our internal complaints process as we have now reached a deadlock with your complaint. Therefore, should you remain dissatisfied with the outcome of your dispute, please be advised that you do have the option of referring your dispute to an approved Alternative Dispute Resolution provider (ADR) such as the Independent Betting Adjudication Service. You may also use the Online Dispute Resolution (ODR) platform to refer your dispute to IBAS, however, if you choose to use the ODR platform you would not be referring your dispute directly to IBAS and this may then prolong the process of resolving your dispute. Please use case reference Xxxxxx when escalating your dispute through the ADR authority. 

 

Please visit section 18.6 of our Terms and Conditions for more information on this point.

 

We have taken this opportunity to ensure that you have all the information regarding the help organisations that are available to provide support with problem gambling. We included this information at the end of this email.

 

Kind Regards,

 

 

In one one way we expected this but they have really dodged around the specific questions we asked. In particular they have failed the mention the number of account closures during the dates they believe they did the responsible gambling check, furthermore they have not offered any explanation of the reason why my son was contacted every time the account was closed, they have not answered when my son was upgraded on there vip status how they conducted a risk assessment  on him or why after frequent failed deposit attempts nothing was ever questioned.

ive responded asking some key questions that have been advised by you kind people but ccd the gambling commission in on this e mail.

 

will of course keep you posted 

 

regards 

 

Few points:

Why have they referred you to an ADR like IBAS? - they will not touch a case regarding the adherence to the responsible gambling element of the LCCP. It's a regulatory matter, not a transactional dispute. 

To be fair to the casino:

If there is an element of them 'reaching out' to the player, asking questions...then that would be a plus point, so to speak for them. Casumo, to add context, were criticised for not even contacting the player when they ought to have.  From the above, this appears to have been what happened? 

This is also KEY - it's, in many ways irrelevant that your son had a gambling problem in the end - the key is whether their policies and procedures were reasonable to A. Identify him as requiring a follow up and then B. Upon following up, if the policies were sufficient and the decision based upon sufficient scrutiny,  to allow him to continue. That's a question only a regulator can take a view on IMHO - but sadly one that will probably not. 

The only thing that, depending on their policies, that could be lacking is the lack of a SOW/SOF on the back of this. The UKGC view, could - and i say could- be that it's all very well asking someone 'are you OK?' but there has to be something else behind this such as a SOW/SOF (depending on the circumstances)

The VIP element is missing - certainly, as i stated before, the due diligence should be higher for a player if the casino puts them in this bracket. As is the contact after account closure, which may go in your favour. 

Apologies if I'm contradicting previous statements but as you can imagine, the area is a mine-field and even I constantly swivel over this: each is a case by case basis - when i started as a wet behind the ears Auditor, we'd get accused of 'Not finding the fraud' by clients but at the end of the day, our policies and procedures were reasonable and therefore we couldn't be charged should one have occurred; hence, my mild casino sympathy in this respect. 

Personal view? - you've made the UKGC aware and that's as far as I can see it going pal. If it was me as the casino, given the bonus requests, the constant account closures, the heavy losses in short periods, I'd probably have suspended the account until a SOF/SOW came through. Or, hedged my bets and closed the account if I had real worries: again, the issue is that some people are wealthy and losing 100k a year is the same as Jo Punter losing 200 quid. 

[pinnit2015]

[TheAverageGuy]

The question as I see it, based on their clever bit of legal-speak, becomes "are their responsible gambling policies sufficient in achieving the required due diligence  to satisfy the standards of their licensing and are there any weaknesses that were clearly overlooked or "good enough to pass the bar" that in fact allowed them to ignore very clear and obvious signs of a player who was above their limits, beyond their means and out of their depth emotionally?

Previous decisions I've read on such matters held the casinos to task for far, far less "warning signs" than mentioned resulting in rather large financial levies against the sites who were given opportunity to revamp/create internal policies as required and have appropriately trained and experienced individuals working the necessary roles in the company to adequately fulfill the terms of their licensing rather than just pay it lip service. Those who were on second and third opportunities at times have had licenses pulled and doors shuttered..

Of course it entirely depends on who is hearing the case being made, their own particular viewpoint and political/professional stake to be gained in the outcome.

Obviously "Well I'm playing elsewhere.. so obviously the clear signs of an out of control player should just be ignored, keep perusing me, I just need a little more sugar to sweeten the pot" is WEAK as can be while claiming they acted in the best interest of the player. "What? I stopped slapping her aound and she went right over to bob's house and he hit her too.. it's pretty obvious she just enjoys rough role play..nothing to see here"

Best of luck in the continued journey

[pinnit2015]

That's the thing - we've seen casino's have, for example, a duty re Money Laundering and in some VERY recent decisions, we've seen they don't even have a Money Laundering Reporting Officer. These things will only really be tested upon a UKGC investigation, whereby they'll look at the staff training etc as well - the full shabang. 

Good point re TAG - the politics at the time is crucial - right now there is a huge focus on this and 'Well, we asked them if the weather was nice and if they had enough money for the weekly baked beans shop', may not cut it. 

Always been the argument about setting rigid, minimum standards for companies to follow - they'll meet it and go no further. Job's a good 'un. 

Seems they've done ELEMENTS of what's expected but, as to whether the above discharges their responsibilities, is a matter of debate.