Casino Cruise - lacks responsible gaming policy

Hi wilhelmina16 - welcome to ThePOGG.com!

Before we go any further I need you to be clear - when you asked to close your account did you make clear to the operator that this was due to problems controlling your gambling? Gambling operators are only required to take responsibility for preventing you accessing their service where they have been clearly informed that you cannot control your own actions. Simply asking to close your account would not be enough for Responsible Gambling policies to be enforced.

It would also be useful to see the communications where you requested that your account be closed. If you could forward these to [email protected] it would be appreciated.

Finally - while Casino Cruise used to run on the EveryMatrix platform, they have had their own license for some time now and as such would not have access to the self-exclusion lists maintained by EveryMatrix.

Thanks,

ThePOGG

Hi Pogg!

I have e-mailed you some stuff again. Talked to the casino ( they are always correct, polite & professionalI must say, and they will send my a list of my openings and closings over there with dates. Couldn't give it on live chat. They say they are still investigating my complaint by the way.

Hi Pogg, the people of casino cruise have sent me the chat history:

Open 20-12-2015

Close 9-2-2016 reason couldn't deposit

Open 21-5-2017 nothing asked

Close 24-5-2017 close permanently asked twice, operator says no worries

Open 3-6-2017 he asked reason for opening, I said angry. That was enough...

Close 4 Juni 2017: note: hello close account permanent!!! Please do!!!!please close immediately!!!!

Open 15-8-2017 no reason asked after that urgent note... just openend it again

Close 18-8-2017

This is besides the asking closing permanently at Spinit.

Seems to me I have asked a lot of times of permantly be closed urgently.

Hi wilhelmina16,

I'm afraid that if you have not made explicitly clear to the operator that you are struggling to control you gambling, the operator are not legally required for the activity on your account. Getting annoyed and asking to close your account is not enough that the operator would be expected to assume you have a gambling problem.

I'll ask to review the communications between yourself and the operator but it's very unlikely you have a case here.

I've reset the password on your account to [REMOVE]fE)[email protected]%P1pqFVSSzZng[REMOVE] - the log in issue should now be resolved.

Thanks,

ThePOGG

Hi Pogg,

So according to you, you have to explicitly say: I have a gambling problem. That's just the point. You feel ashamed by admitting that openly. In my point of view a good casino has a policy over this problem. They have a responsibility to check the symptoms like Unibet explained in Dutch case law on contra indications. In my case like I mailed before: What more can a person do than ask and beg many times to close permanently.

All the signs for addiction are there:

* playing for hours at the same game

* playing during strange hours like at night

* the mail contact from with me was strange, I begging for bonuses, angry for not getting cash back etc. I didn't act as a well thought through customer.

* my playbehaviour was not stable, big differences in the deposited amounts

* I was playing irresponsibly to cover my losses: extreme high betting amounts of 16-32 euros a round, or when I won I completely wager it all.

* setting deposit limit at Spinit.

*many times closing and opening the account and begging to close it permanently and you say it regular opening????

They assured me it could not be reopened again: she said: don't worrie!!

Then it comes to the policy of reopening the account; no questions asked!!! Immediately reopened.

Well I checked Maltese gaming law on this and its says that there have to be a 7 days waiting period for reopening after being excluded for a definite or indefinite period of time. What is legally the difference with asking for permanent closure with indefinite period of time????? Wat is the jurisprudence about that???

They don't close your account upon request but put it open on "withdraw" status. That is NOT what you legally agreed on by asking for permanent closure. They keep the account open, since you can LOG IN. Every other big, legal & trustworthy casino will respect your decision for permanent closure. They offer even in the system to do it yourself, which casino cruise don't have. You always have to contact customer service.

This casino violates unethically rules of customer protection in my opinion. They also violate legal rules by by not acting responsible according to reopening accounts. Plus they violate their own terms, a good agreement has rules for opening and closure of the account. They don't even describe rules about reopening a 'normal' account closure. So that officially don't exist legally. They only describe: should you need a break from gambling, you can exclude yourself for a definite or indefinite period of time. And that is exactly what I asked: a break from gambling for a permanent period of time. And by reopening the account the 7 waiting days apply. You see my point? By accepting their terms by me, I did not agreed on something like reopening a 'normal' account procedure, cause it doesn't exist in their terms!!

And final, the account was created in December 2015, by which they were under the everymatrix label and had access to all the other casino's where I was excluded.

When this casino takes responsibility seriously like they say on their site they act like so, then they should come forward in this case.

And another thing: the night I completely lost it, the game malfunctioned constantly, the notifications of wins and losses where completely not properly working all night. So customer service said they had all night problems. The game never started again, so no chance of winning back, but deposited again. And that amount is for 3 weeks (€416) pending and they don't pay it. They said to me TWICE my account had to be REOPENED again. I told them I don't want that, since there all the problems starts. Now it is 3 weeks later and nothing about the game malfunction ( it had a rtp of probably 5% or so, since I lost that much) and nothing about giving me the €416 back. They told me it's due to the financial procedure. Well they have those kind of procedures but nothing when it comes to customer protection/ responsibility. I wonder what's in their procedure of gambling protection. Saying you have those is a big difference with acting you have those.

This is the stuff with what you are dealing with when you decide to open or close an account here.

They are strong and you are weak...

Hi Pogg,

I forgot: thank you for checking the communication with them and for all of your help in this.

I'll hope they do come forward and show they are in fact not just saying they act responsibly but prove they do.

Plus Pogg: see the complaint of 22th of may about Spinit on your site : a customer asked for closure of 6 months never said SE and then they reopen her account and when she wins they didn't pay, cause of breach of the terms of responsible gaming, cause they say she was SE, but just asked for closure of 6 month ( instead of me asking it permanently)

They just act on how it comes handy to themselves.

This also wouldn't have happend if the always have waiting periods after reopening....

Hi wilhelmina16,

A casino is responsible to prevent you from accessing their services in two situations:

1) you have made clear to the operator that you have a gambling problem and cannot managed your betting on your own

or

2) where outside of your own admission of an issue there is clear and compelling evidence that you are acting irrationally and are not in control.

In no other circumstance would an operator be legally responsible for actions YOU take. Otherwise every player that loses could simply claim their losses back.

You have been clear that you have not informed the operator directly of your issue. That rules out by far the easiest claim in this case. So we have to look at conditions 2). As this is subjective and based on an interpretation of whether or not your behaviour can be considered erratic enough to require the operator to independently take action it is likely to take far longer to review and is far less likely to be successful. This is the point I've made above.

Regarding account closures - any player can ask at any time to have their account closed. They can do this for any reason. They may be unhappy with the speed withdrawals are paid or that they've not receive a bonus when they feel they should have. They may feel that the customer service is poor or that the games aren't returning enough. It is a common occurrence for players to close their accounts for any number of reasons and these closures have no legal requirement for the operator to take any action what-so-ever to prevent the account holder re-opening their account. It is only at the point where the account holder can be reasonably established to not be in control of their own actions that the operator becomes responsible for preventing the re-opening of an account and becomes subject to the Responsible Gaming policies put in place by the MGA. Until that point these policies have no bearing on your case.

The complaint you reference - https://thepogg.com/complaint/spinit-self-exclusion-complaint/ - you've clearly mis-understood. This player never asked for a Self-Exclusion to be applied and and agent incorrectly labelled the closure as a Responsible Gaming closure. As the player never requested a self-exclusion and there was not grounds for the operator to take this action on their own the operator acknowledge the mistake and paid the player. Unlike your case the player was clear that they never asked for a self-exclusion and gave the operator no reason to apply one. You are claiming the opposite, that while you've never asked for a self-exclusion, that they operator should have taken action without the need for your request.

As stated previously, we will ask to review your communication and activity, but it is far more difficult to construct a valid case in this manner. As such in future if you are expecting the operator to take action to prevent you accessing their services you need to ensure to make clear to them that you have a gambling problem. I'd also encourage you to review our Responsible Gambling sections to see the various tools and services that are available to help you control your gaming activity.

Thanks,

ThePOGG

Hi Pogg,

Thank you for your answer. I understand your points of view about the SE thing. It was not obvious for point 1 and you are investigating a weak point 2.

Well if you see it besides from the gambling problems but purely from a legal view. You can exclude yourself from a casino without saying you have a gambling problem. In my opion it is the same as asking for permanent closure. Then if you asked for exclusion and you want to open your account again, the casino can just do that without waiting period? I disagree.

Permanent closure means exclusion means a waiting period of 7 days before opening. Maltese law is clear about that. The reason for exclusion is not important , the pure handling of the act is.

Legal I have a gambling contract with them based on their terms and for players protection the law is valid and when the law don't provide enough information nor the agreement, then a judge will decide/ recover what the meaning of both parties was. When it's business consumer related, the consumer is the weaker one and a judge will take this argument along in the case.

Casino cruise has nothing in her terms about opening a 'normal' closure. So in fact I never signed this agreement on this point. Then you take a look at the law. It only says opening a excluded account takes 7 days. No matter what the reason is, cause it ain't described.

The question is, is asking for permanent closure the same as exclusion? Yes it is!!! there must be some jurisprudence about that, and if not how do casinos act to asking for permanent closure in general??

Well I can tell that all of the nigh ones have an explanation of reopening a ' normal ' account in their therms, besides from the question of asking for permanent closure is the same as a regular closure.

How do casino customers interprete permanent closure? Well exactly they think it is permanently excluded and don't think you can reopen immediately. You probably have seen this many times in your experience.

I played at many big casinos and if you ask for permantly be closed they do that immediately and you are not able to reopen at them without a waiting period. So why does casino cruise have this procedure ?

why does casino cruise don't ask you what kind of closure you want explicitly?They assume it's a regular one. At other casinos you can do it yourself and choose from the options.

They know they make the most out of addicts this way...

But, back to the point, I asked for permanent closure many times, what they do is not closing your account. They leave it open on withdraw status. So I am able to log in at first and check my account. I can't play but I can withdraw. That is strange because when you ask for closing your account you should not be able to log in.

I think they do this to avoid the legal waiting period.

Well in summary:

Is permanent closure the same as exclusion? Yes

Do reopening rules of waiting period apply? Yes

How do players and other casino's understand permant closure and reopening of that request? It is exclusion so their must be a waiting period by reopening.

Is there anywhere in the casino therms what reopening of a normal closure means? No, so it don't exist!!

By the way the Spinit claim I don't misinterpret.The casino say in that actually their is a policy for my case. And obviously they found it at first appropriate enough to act on that in that persons case, which those persons signs were less severe than mine. She didn't say permantly ( I quote)Wish they acted on my case like this. The problem arose also there by not having a waiting

period....

Thank you for all your trouble, I do hope they come forward with this

Hi wilhelmina16,

I'm sorry but your opinion of what is or is not "legal" isn't relevant here. We deal with self-exclusion cases regularly in multiple jurisdictions including Malta. I'm very familiar with exactly what the MGA requires from their licensees and I'm afraid it does not conform to your interpretation of the law. The MGA decides what the law is with regard to responsible gambling and their license holders and they do NOT require operators to treat any request for an account closure as a responsible gambling issue unless there is a clear statement from the player to support this.

You have misunderstood the other complaint - that claim relates solely to a customer support representative mistakenly tagging a normal account closure as a responsible gambling account closure. There's nothing similar between that case where the support rep incorrectly check a field in the back end and your case where you're insisting that the casino should have checked the field in the back end. In fact, your case is the diametric opposite to the case you are referencing.

You are trying to extend what happened in the other complaint and claim that what happened there was 'standard practice' that has not been applied to you. It was not and never has been standard practice to apply self-exclusion procedures to every account closure request. And that goes for all casinos.

If you're looking to pursue this via contract law because you feel that the operator have not clearly defined what a normal account closure is you need to contact a lawyer and pursue your claim via the courts. This is not something we can or will assist you with. At that point your claim extends beyond the remit of our service. Personally I don't feel you've got any valid claim on this front and that is based on our experience working with the Maltese regulator and knowing what their position on this type of case is, but you are entirely within your rights to contest this in a court if that's what you want to do.

As stated before, you've been clear that you've not been clear with the operator that you had a gambling problem. As such the only issue that requires reviewing here is whether or not the operator should have taken action based on their interactions with you. This service does not accept and will not support a claim that every request for a permanent account closure should be treated as a responsible gambling issue.

Thanks,

ThePOGG

Hi Pogg,

Thx for the really fast reply. I understand your point of view and know you are really experienced with these cases and Maltese law otherwise I wasn't here. (I probably don't need Maltese law if I decide to go to court, due to an European treaty probably Dutch judge is competent and is more strict)

The biggest problem for me is there is no waiting period upon reopening besides and because of the addiction thing. All this stuff wouldn't have happened if they applied that.

For me personally I find it hard to believe your experience is that a casino can get away with this behaviour. It feels like they can go on and on with these practices. It doesn't seem fair and nobody besides government or courts of law can stop them. The customer's protection is way out of balance here in this business.

Fortunately there are casino's who treat their customers like they should do upon agreement, but this one is not the one as explained before. It is no wonder this casino has a lot of complaints ( of course not all are legitimate) every where on the net, they keep acting on or just over de borders. That's the difference with the other big ones.

I understand your point of view of your service acting in the last point you made, your service is balancing with 2 parties off course al the time. I am glad there are services like yourself in this business, really gratefull. My legal point of view is that it is, but not open for discussion on your service, which I completely understand.

If I understand correct you are still asking the correspondence there and investigate point 2 of responsibility or do you close this case in favour of the casino?

Greetz and thank you again!

Hi wilhelmina16,

Yes we are still going to look into your case.

My point with the above is that we absolutely cannot support your interpretation that all account closures should be treated as self-exclusions.

Very few other industries outside of gambling are actively required to take responsibility away from the consumer. While I would fully support operators being required to prevent players with addiction problems accessing gambling services, the rules for requiring operators to take that action have to be absolutely clear and that means that the customer has to have made a direct and clear statement that they can't manage their own behaviour OR there have to be significant enough signals that an objective observer would determine that the player was 'high risk' of gambling addiction. Simply asking for your account to be closed does not qualify for the first instance and would only fall into the second category in extreme circumstances where there was a large body of other signals that were concerning.

To draw a parallel with another industry - if I'm in a pub in the UK and receive bad service, I could tell the owner that I'll never come back. If I then walk in the next week the owner is under no moral or legal obligation to refuse my custom. If however I explain to the owner that I'm an alcoholic and would like them not to serve me in future there's then a moral (and questionable legal) obligation on the owner to decline to serve me in future. That obligation only begins where the owner can reasonably and objectively be expected to know about my problem.

I have not reviewed your communications yet, but I will say that simply asking for your account to be closed a couple of times would not in of itself be enough to require the operator to take action. Nor would playing late at night. Many people do that who don't fall into the 'addict' category.

We will review the communications as we receive them but our position on this issue has to be clear from the start - if you have not clearly informed the operator of your addiction there would need to be significant evidence that falls significantly outwith the normal pattern of behaviour for gamblers before a case could be made that the casino should have acted on their own.

Thanks,

ThePOGG

Hi Pogg,

Thank you for your explanation. And thank you for vieuwing the communication.

Actually your example of the pub hits the nail (is that a English expression?) A drinking problem can be compared to a gambling problem.

In Holland a pub employee can not serve any more liquor to a drunk person. It's penal law. When he does, he is also responsible/ liable for the consequences, like when the person causes an accident when he leaves the pub.

As a bar employee you get instructions on serving people with drinking problems. Of course when he says he has an alcohol problem (like gambling) you can't pore him any drinks anymore, but besides from the obvious case you are liable/ responsible for keeping an eye on persons you serve the drinks too. For example when a person says he is driving a vehicle and you hear that, you are responsible for not serving him drinks anymore, although he is not really drunk on that moment. Even when that person comes every week and never were drunk in your bar. Plus in a pub in Holland there must be all the time somebody in the business with a special education on how to deal with problem drinkers, who almost never say the have a drinking problem. The bartender will not pore him drinks anymore and puts him out of the business plus there is a restriction policy in case the person comes back. So in Holland the complete responsibility lies with the pub....

In order with gambling: Dutch watchdog on gambling is trying to protect the Dutch more from casino's abroad by fining them severely when they make advertisements in Dutch, or when they have a Dutch website, or Dutch paying methods etc. They can get a license probably at the beginning of next year, and there will be a really strict policy on social responsibility. I see movements as well in the U.K. With the 888 casino.

By the way medically you have a gambling addiction when you have only two periods of pathology gambling in a year. Problem gambling is a real disease.

Casino's know exactly who is a problem gambler. At casino cruise and Spinit you get VIP status!!

Problem gamblers raise their stakes irrationally, they play for hours, they play the same game really long, they don't take winnings, but gamble it all, they play at strange times, they make a lot of separate deposits, they don't stop untill the money is gone, have strange deposit amounts, ask for bonusmoney when it is all gone etc etc, I don't need to tell you this. The problem gambler gives them the biggest profit. They only have the responsible gaming section on their site, cause they are obliged, otherwise there would be. They really know exactly who a problem gambler is, just like a bar tender knows who is drunk. I'm so disappointed that it is obviously generally accepted in the casinoworld a player has to admit most of all he has problems. The biggest problem with addicts is they deny there problems and are ashamed to admit it. Casino's know this really well.

My opion still is that someone who wants a regular closure by disliking the service or don't like the games or whatever normal reasons are, will just ask to close. He won't use the word permanent. He most likely will not return at a casino as well. Somebody with problems ask for permanent closure and still wanna come back. The casino knows that.

How far is casino responsibility going? Not far if I understand you well with the words significant evidence. And in my opion that is morally despicable, cause problem gambling is a severe disease. In my opinion it is a casino's duty to have a waiting period before reopening an account, cause most likely most of the reopeners have problems. Even when only 5 persons out of 100 have problems, they are morally and in my opion legally obliged to have a waiting period and prevent them from gambling immediately. Cause gambling is pulse driven. The severeness of the disease weighs so much higher than those 95 who have no problems. But like I sad, I'll bet (-;)) normal gamblers don't ask for the word permanent.

I understand & respect the opion/ normal procedures about these issues from your service and in the business, but of course I can have my point of view about this casino based on my experiences here. And I think the protection of problem gamblers is not enough in the way it is handled at this point in the business, but of course that is just my opinion. The bartender keeps on poring drinks, even though he knows I am drunk, I have a pulse in wanting more drinks, even though he knows it is morally & legally not accepted, cause he has to make more money out of me, and he won't stop untill he is caught. Of course you are responsible for your own behavior, but there are moments people are in a status they can't normally decide for themselves, cause they are sick, and when you keep giving drinks at that moment, that's makes the other person responsible too.

I think in my case an analysis made by 99 persons out of 100 makes the problem gambling clear, but what is significant evidence in these cases?

Thanks for the sharp thoughts & your time & your dedication to this matter as well by the way. I am curious what the outcome of your investigation will be.

Greetz!!

Hi wilhelmina16,

Once again your analysis boils down to 'anyone categorised as a VIP is a gambling addict'. That's painting with a very broad (and self-serving) brush simply isn't the truth. This isn't the way ANY responsible regulator would view the industry.

Every individual has their own resources and is comfortable playing at different levels. Simply because one person is comfortable to lose as much in a month as another person earns does not make them a gambling addict. You might be able to afford to comfortably lose more than me, that doesn't mean you should automatically be classified as an addict.

The alcohol example serves to demonstrate that there has to be some reason for the establishment owner to intervene BEFORE they would be legally expected to do so. Unless you have given the casino a reason to do that they are under no legal obligation to do so. To extend YOUR example, if rather than saying 'I need to drive home' the patron at the bar simply orders another drink without saying anything, the pub owner is not liable to have worked out on their own 'this person must have to drive home'. The statement that the patron intends to do something illegal is the trigger that puts the onus on the establishment.

If you have told the casino that you've just 'lost this months rent' or 'can't afford to feed my kids', then these are clear indications that you are playing beyond your means and need to be stopped. These are just examples, there are others, but it requires a clearly concerning pattern of behaviour - like a statement that you've got to drive home - before the responsibility for YOUR actions would no longer fall on YOUR shoulders.

As to Dutch law - so far the Dutch government have NOT got their act together and actually got a working framework in place to deal with the gambling industry. Their current approach seems to be that it's illegal altogether, but the rules they've put in place don't actually illegalise any operator accepting Dutch players, only those specifically advertising using a .nl domain or using what the Dutch government have dictated are 'Dutch' symbols (tulips, clogs, windmills, Dutch flags). So in fact, if Dutch users go on any site and see advertisements of a general nature and decide to play, there's no problem with that. There's only a problem with sites specifically trying to target Dutch players.

As the Dutch government do not have an adequate framework put in place to either license or regulator operators or even adequately manage a situation such as this one, I'm afraid to say what the Dutch government has to say about this issue (even if they had said anything) would be irrelevant. My understanding is that they intend to have this framework in place sometime next year. At that point operators become subject to the desires of the Dutch government.

Finally, as I've tried to explain to you several times now - 'normal' gamblers close their accounts all the time and the use of the word 'permanent' is not uncommon or only used by addicts. Within the gambling industry specific vernacular has been developed ('self-exclude', 'problem gambling', 'responsible gambling', 'addiction' etc etc) and consistently used to ensure that players know how to tell an operator they're in trouble without mis-understanding. We've fought several cases for players specifically on these grounds. If you choose to use language that has other meanings outside of addiction, you cannot expect this to be enough by itself for the operator to be held financially responsible for your actions.

ThePOGG

Hi wilhelmina16,

I have removed your last post as it once again delves into Dutch law and how you feel this reflects on your situation. It also referenced court material in Dutch that we cannot independently review so would require you to interpret for us. This is obviously not something that we can allow.

I'll again state that if you want to pursue this issue via the Dutch courts you are welcome to do so. We can't help with that.

Thanks,

ThePOGG

Hi Pogg,

I forgot this: I registered at casino cruise under the everymatrix license on 20-12-2015 until last quarter last year.

I was self excluded at several brands of everymaterix,

I have been SE at play Frank at 2016, I have proof of that, they have in their terms they warn die other brands and you account will be closed there within 5 days. Cause of gambling problems!

Also was SE from Florijn Casino from 2015 and Jetbull.

And probably more brands of EM.

Greetz

Hi wilhelmina16,

I've deleted your second to last comment as well as it once again goes into the what you feel are the merits of the case under Dutch law.

This service is here to offer a ruling based on the licenses and rules that are clearly established and in place. That there is a single example, that we cannot verify due to the language barrier, of what may be a similar case going in favour of a player via the Dutch courts is not something that will factor into our assessment of your case. Even if we were to take your interpretation of this case to be entirely accurate, no regulator is going to make a ruling that would contradict their own license based on a single case in a foreign court. So this entire argument would be non-useful until such time as you tested it in your local court system.

Beyond this, the arguments you are making we simply don't agree with. We've been clear that simply asking for a 'permanent' account closure would not automatically require the operator to view you as a problem gambler. This is a position supported by the regulator responsible for this business and multiple other regulator bodies.

While I appreciate your frustration, at this end your motivations do not come across as the altruistic 'educating other users' objectives that you claim. We regularly make very clear to players that we feel have either a legitimate case, a case we cannot help with, or who strongly objects to our rulings that they are always welcome to pursue their claims via their local legal system. That being the case your repeated return to this issue reads at this end as both a refusal to accept our position and as an effort to actively damage the operator's reputation via evidence that we simply cannot verify. I'm sorry your unhappy with our position but further posts of this nature will not receive approval.

It is possible that you are right and I would encourage you to pursue whatever course of action you feel is legitimate, but the case you've highlighted against Unibet will not be taken into consideration here.

Regarding the likelihood of a casino favourable ruling - you are right that this case is likely to go in favour of the casino. I've been clear about this from the outset. You have been clear that you've not clearly informed the operator that you are experiencing gambling problems. This means that the case has to be assessed entirely on your email, live chat and phone communication with the operator alongside your transaction and play history. From historical experience I can say that these cases are FAR more difficult to construct a legitimate argument from. That's simply fact and that is why I've stated from the start that it is unlikely you have a legitimate case here. We need to construct an argument based on observing remote behaviour patterns that would be convincing enough that the operator should have been expected to infer that you have a gambling problem. Is it impossible? No. We've seen other cases where there have been clear enough marker that the player has a problem and some of these cases have resulted in the player being refunded. However, the majority of this type of case are unsuccessful as there simply isn't enough to assert that the operator should have known that the player was a problem gambler without any type of direct statement.

Until I have reviewed the complete complaints package I can't say more than it is "unlikely" you have a valid claim.

Finally, EveryMatrix. Unfortunately the EveryMatrix license is irrelevant in this case for two reason:

i) EveryMatix are the license holder and make all decisions with regard to Responsible Gambling issues. This means that if a self-exclusion is expected to be carried over from one of their operators to another, EveryMatrix are the group that manage this. Casino Cruise would have no role to play in that action.

Basically Casino Cruise would not have had any responsibility for a failure on this level as they're not the body that would action this policy. Your complaint in this instance would fall against EveryMatrix themselves.

Unfortunately EveryMatrix have demonstrated via previous complaints to be unwilling to enter into any discussion of complaints with this service, and based on complaints of this nature against their previous licensees, will not even discuss these issue with their former licensees.

ii) As far as I'm aware the MGA license does not require white label platforms like EveryMatrix to carry over self-exclusions to other white label properties. So a self-exclusion at another EveryMatrix property would not automatically be applied to other EveryMatrix properties. This is a requirement of the UKGC license but the UKGC license is only currently applicable to UK citizens and as such isn't relevant to this case.

I have contacted the MGA to ask for clarification on this specific issue to be entirely sure, but even if they inform us that they do expect self-exclusions to carry over we're back to point i), EveryMatrix would be the party accountable for this and will not discuss complaint.

Thanks,

ThePOGG

Hi wilhelmina16,

I've spoken with the MGA about the multiple licensees aspect of this case. I was in error. In fact the MGA do expect multi-property license holders to extend a self-exclusion at one property to others under their license. It should be noted that this does not apply if the player has changed their details between account in such a manner that automated detection systems would not catch the account.

Once I've reviewed the communication history between yourself and the operator, if no legitimate case can be built using this information, I will look to direct you to the relevant parties who can force EveryMatrix to respond to the complaint.

Thanks,

ThePOGG

Hi Pogg,

Oh thank you. I see a small light now.

I checked right away. I was SE at jetbull in april 2014! I just contacted them and made copy of the chatWith the same name and email

I was SE at play frank in 2016 due to gambling problems, also got chat proof from them.

I know i was excluded from florijn but i cant ask since they dont exist anymore, but that was around 2014/2015.

Greetz and thx!

Hi Pogg,

I just asked casino cruise about the SE under everymatrix. They say it doesn't matter if I was self excluded then and opened an account with them at that time since they have their own license, now. Well they did keep their everymatrix clients, so you would say they also take everything from the past from those clients. I find that strange cause my account should have been closed upon registration within 5 days by SE at other brands, which everymatrix say they do. And this whole matter wouldn't have been able to exist.

Well I wait for your findings on matter 1 and then it would be really great if you could provide the right information on how to deal with this at everymatrix, but I also think casino cruise has a matter in this, since they kept all the Clients, otherwise they should have informed me my account was created again on the day of the license and they are not liable for everymatrix account taking over. What do you think? Casino cruise or every matrix or both?

Thx again!

Hi Pogg,

Sorry to mail again, but is there any news this past week?

Greetz

Hi Pogg,

Some news/ update here. I have had back the €416 from casino cruise, but the softwareprovider still haven't answered casino cruise on it after a month.

I mailed everymatrix 3 times now for a list of SE at casinos of them, since I dont know all, but I dont get a respond.

Hi wilhelmina16,

I spent several hours yesterday looking through the various communications you’ve had with CasinoCruise and SpinIt. Unfortunately you don’t have a case here.

I’m going to give a basic outline of the timeline of events with some key inclusions from your communications to emphasize points.

- You created an account with Casino Cruise on the 20/12/2015 but there is no activity in terms of transactions until the 21/05/2017.

- On the 09/02/2016 you contact customer support and this conversation resulted in a request to close your account. The body of your communications are included here:

[CASINO CRUISE REP] (Tue, 2/9/2016, 11:11:01 am Asia/Beirut) Greetings! A crew member will be with you in a moment and will be delighted to provide you with service and amazing offers

[PLAYER] (Tue, 2/9/2016, 11:11:15 am) Hi [CASINO CRUISE REP]

[CASINO CRUISE REP] (Tue, 2/9/2016, 11:11:30 am) Hi! My name is [CASINO CRUISE REP] and I am your Casino cruise hostess. How may I help you?

[PLAYER] (Tue, 2/9/2016, 11:11:37 am) Do you have ideal payment?

[PLAYER] (Tue, 2/9/2016, 11:11:58 am) Not on mobile i can see

[CASINO CRUISE REP] (Tue, 2/9/2016, 11:12:10 am) One moment please

[PLAYER] (Tue, 2/9/2016, 11:12:21 am) Ok

[CASINO CRUISE REP] (Tue, 2/9/2016, 11:13:48 am) Unfortunately we dont have it

[PLAYER] (Tue, 2/9/2016, 11:13:59 am) Oh... Cant play then

[CASINO CRUISE REP] (Tue, 2/9/2016, 11:14:31 am) We have other payment methods which you can use: debit/credit cards, e-wallets, bank transfers

[PLAYER] (Tue, 2/9/2016, 11:14:45 am) Not good for me

[PLAYER] (Tue, 2/9/2016, 11:14:56 am) Can you clise this account then

[CASINO CRUISE REP] (Tue, 2/9/2016, 11:15:18 am) Yes one moment please

[PLAYER] (Tue, 2/9/2016, 11:15:29 am) Ok bye bye

There’s nothing in the above conversation that would lead an objective observer to conclude that you are experiencing problems controlling your gambling. You are simply unhappy that they don’t offer the payment method you would prefer to use. As such this account closure is viewed outside of Responsible Gambling policies. The account is permanently closed unless you give a direct contrary request.

- On the 23/11/2016 you create an account with SpinIt.

- Over the next two days you lose €1000. This isn’t an unusual enough loss to trigger any special attention for your account.

- The next notable activity on your SpinIt account is on the 19/12/2016 when you ask to close your account. The relevant section of the Live Chat conversation in question is included below:

[PLAYER] hi [SPINIT REP]

now connection was lost

[SPINIT REP] yes

[PLAYER] well have you got something for me

[SPINIT REP] no, sorry no free bonus

[PLAYER] Free spins?

[SPINIT REP] No, I see that your last transaction was a free bonus so I cant add you anything right now

[PLAYER] was cash back cause i lost a lot

[SPINIT REP] sorry, cant give anything right now

[PLAYER] well ok then, its time for me to close my account

can you do that?

[SPINIT REP] and what is the reason that you want to close your account

[PLAYER] was not that happy how it went here with the cashback and all and no free spins

so nothing here for me left

waited for more than a week to settle the cash back

didnt feel appreciated

so

[SPINIT REP] ok, I have blocked your account now

Again there’s nothing in the above conversation that would lead an objective observer to conclude that you are experiencing problems controlling your gambling. You seem emotionally in control and are simply unhappy that the operator won’t provide you with another bonus. At best this looks to be you trying to pressure the operator into providing a bonus by stating you'll withhold your custom. As such this account closure is viewed outside of Responsible Gambling policies. The account is permanently closed unless you give a direct contrary request.

- On the 21/05/2017 you request that your Casino Cruise account be reopened. As you haven’t informed the operator that you are experiencing gambling problems and there’s nothing within your account activity on either casino run by this group at this point that would indicate to the operator that you are not in control of your actions this reopening request is rightly dealt with outside of Responsible Gambling policies and can be actioned immediately.

- Between the 21/05/2017 and the 24/05/2017 you go on to lose a total of €408. Again this loss isn’t particularly remarkable in size and wouldn’t be expected to trigger a Responsible Gambling review on the operator’s part.

- On the 25/05/2017 you ask to close your Casino Cruise account again over Live Chat. The relevant sections of the Live Chat conversation are included below:

[PLAYER] Hello can i have bonusmoney?

[CASINO CRUISE REP] Hello there! This is [CASINO CRUISE REP] Can I please have your username so I can check that for you?

[PLAYER] hello

[EDIT]

[CASINO CRUISE REP] Thank you

One moment please

[PLAYER] ok

[CASINO CRUISE REP] Unfortunatly I cannot offer you anything today :(

[PLAYER] has left the chat. Close this window

[CASINO CRUISE REP] Greetings! A crew member will be with you in a moment and will be delighted to provide you with service and amazing offers

Hello there! This is [CASINO CRUISE REP], How can I help you?

[PLAYER] Hello can i habve bonusmoneu

Player [EDIT]

[CASINO CRUISE REP] Unfortunately I cannot give you anything today

[PLAYER] ok can you cloSe account permanent?

tyvm

[CASINO CRUISE REP] Is this becouse of a gambling issue?

[PLAYER] no just close

[CASINO CRUISE REP] You will miss out on all of our offers..

Are you sure you want to close?

[PLAYER] yes

if you have nothing I close

thx

[CASINO CRUISE REP] I can offer you a 25% bonus on a deposit of 20 or more :)

[PLAYER] no

just close

permanent

[CASINO CRUISE REP] Ok I will close it for you

I wish you all the best

[PLAYER] I have had it here

thx! U2

Permanent please

Once again nothing about the above conversation demonstrates an emotional state heightened enough that you would be considered out of control. You’re simply annoyed that they’re not offering you the bonus you want. Given that the bonus that they eventually do offer you is rather weak in nature it’s not surprising that you would decline this. The Live Chat rep even goes so far as to specifically ask you whether you were looking to close your account due to gambling issues and you explicitly say no.

- On the 03/06/2017 you asked to reopen your Casino Cruise account. The relevant excert of the conversation is included below:

[CASINO CRUISE REP] I am not finding an account under that Username unfortunately. Please may you provide me with your name or your registered email address?

[PLAYER] [EDIT] then

[PLAYER] [EDIT]

[PLAYER] [EDIT]

[CASINO CRUISE REP] Thank you, one moment please whilst I investigate your query for you.

[PLAYER] Ok

[CASINO CRUISE REP] I am just reviewing your account to see the reason why you closed it :)

[PLAYER] Was angry

[CASINO CRUISE REP] Okay, I am happy to confirm that your account is now open again and welcome back! :)

[PLAYER] Ok thx

[CASINO CRUISE REP] You're more than welcome.

Again this Live Chat rep makes enquiries as to why you closed your account and you respond simply saying “Was angry”. This isn’t enough that the Live Chat rep would be expected to recognise a gambling problem.

- On the 03/06/2017 you lose €385. Again this isn’t a significant enough a loss that it would be indicative of a gambling issue.

- On the 4/6 you emailed through to ask that your casino account is closed. Casino support respond to your email asking for a reason for the closure and specifically enquiring if this closure was related to a gambling issue. They don’t receive any response so again while your account is closed, it is not closed under Responsible Gambling policies.

- The next activity on your account does not occur until the 15/08/2017 when you ask to reopen your account and proceed to experience a large loss.

Unfortunately throughout all of the above up till the 15/08/2017 there is no clear indication that you are experiencing gambling issues nor is there any clear statement to this effect. Without this the operator cannot be reasonably expected to know that you’re having problems.

You do open and close your accounts a few times, but your direct statements around these closures would lead an objective reader to the impression that you are trying to apply pressure to the operator to give you more bonuses by withhold your custom. You certainly don’t seem emotionally inflamed enough at the points of closure requests to draw the conclusion that you are not in control of your own actions.

With regard to your account closures with other EveryMatrix properties, to properly review this issue you would need to contact the Malta Gaming Authority as EveryMatrix will not discuss complaints with this service. You can find their complaints form here - http://www.mga.org.mt/support/online-gaming-support/. I will say two things about this aspect of your claim however:

i) Unless your previous account closure requests have been significantly clearer in informing the involved operator that you are experiencing problem gambling issues it would be very unlikely your claim will be successful.

ii) I have enquired with Casino Cruise about the EveryMatrix self-exclusions and have been informed that you were NOT on the EveryMatrix list of Responsible Gambling exclusions at the time that Casino Cruise moved off of the EveryMatrix license. This would suggest that your previous account closure requests have not been dealt with as Responsible Gambling issues and as such would not result in a closure at one property being extended to other operators.

Sorry we cannot be of further help,

ThePOGG

Hi Pogg,

Thank you very very much to put time and effort in investigating. You highlighted everything well, exept the permanent closure request of june 4. I mailed in these exact words:" Hello, close account permanent!!! Please do!! Immediately "

This seems an indication in my point of view. The funny thing is I cant recall the mail after that from them. They didnt send it either when asking for all communication!

And by reopening on the 15th they didnt ask a reason! So if they had sent that mail of responsible gaming then you would think they are suspicious and ask for a reason to reopen!

Then, did you see the mail of tini on 16-8? I have asked for permanent closure on Spinit. She admits that it was set on cool off! Then she admits that during this status it should have not been possible to open an account at casino cruise! Then she suddenly changes her story!!! Check that mail.

There is another closure before the june 4th when I ask for permanet closure and she says ok and i asked again permanent cause i didnt trust it and she said: no worries.

Besides from all this is my question of the violation of their terms by not having a waiting period of 7 days. Like explained before. Can you give me your opinion of that?

I understand Pogg, you did you utmost best, but offcourse a big disappointment to me, since I asked so many times permanent. Seen a lot of cases for one time ask of that and they get their money refunded.

I still think casino cruise violated my requests of permanent closure and they twist their story on the tini mail, about the Spinit closure. Check that.

I still haven't got an answer of the game malfunction also.

Then the everymatrix thing. I was SE at jetbull and play frank. According to loyd from casino cruise on askgamblers complaint from somebody, that is enough!

I' ll send you the things by mail and hope you want to take a look again at these things? Would really appreciate that.

Thanks for viewing though! Appreciate all the time and effort by you doing this,

Greetz

Hi wilhelmina16,

You asked for the account closure to be permanent. In my opinion that email was the most concerning exchange to have happened prior to the 15/08/2017. However it is not concerning enough when viewed in isolation to require the operator to take further action. At this point the operator did the correct thing and followed up with you enquiring as to whether you were experiencing gambling issues. The operator included both your email and their response in the package that was sent over. When no response was received and there is then a significant break where no activity took place the factors that were concerning about the initial email lose weight. When you come back on the 15th and ask to reopen they've got no reason to be suspicious. They've got a player who asked to close their account and when they asked if this was for Responsible Gambling reasons didn't come back to them at all.

With regard to the Live Chat transcript from the 16th - yes I have reviewed this. The mistake that the operator is admitting to is NOT that your account should have been self-excluded. The operator is saying that your account should have been 'closed', i.e. you would need to request to reopen it before you could log in. They had mistakenly set it to withdrawal only previously instead, meaning that you could log in but could only take the action of withdrawing funds. This is a technicality that made no difference to your ability to wager - you would not be able to deposit or wager until you'd spoken to support to request your account be re-opened.

The discussion of being able to open another account is relevant to that point on - you've specifically and clearly used the words 'self-exclusion' during this conversation on the 16th which now opens the Responsible Gambling policies. The operator then asks "how long would you like to self-exclude yourself?" showing that they are now enacting self-exclusion policies. At this point you are insisting that you had previously self-excluded, which is causing confusion for the operator as they can't see a previous self-exclusion specifically because you've only ever previously asked to close your account. In short, the mistake that the operator admits to is not that your account should have previously been self-excluded and the discussion of not being able to open other accounts is specific to accounts that HAVE self-excluded.

Regard the statements related to requiring 7 days before an account can be open - this is only made on the Responsible Gambling page under the heading of 'Self-Exclusions'. This is not a policy that would apply outside of a self-exclusion situation and there is no discussion of cooling off periods in the general terms and conditions.

With regard to EveryMatrix - I can only comment on what I've been told on this front and that is "The player was not flagged as being SE when we were under the EM license". I've looked at AskGamblers and I cannot see any complaint posted by you for either Casino Cruise or SpinIt. My recommendation would still be to consult the MGA if you feel that you have a legitimate self-exclusion at other EveryMatrix brands.

Sorry!

ThePOGG

Hi! Thx I understand your experienced views of this business and your honestly look of chances in a case. However I still think Casino Cruise is finding the borders in this case. (Is that English?) They also have a lot issues on SE elsewhere cause their policy is not sharp enough. I obviously played a lot and almost every respectfull brand takes a question for permanent closure as a self exclusion or be sure the account is closed for 7 days after reopening. There are a lot of cases where other casino's refund money with permanent closure requests, why is that when not obliged ? I didnt file a complaint at ask gamblers about this. I told you about another person has set SE at another everymatrix casino and casino cruise did come forward. See complaint: Casino Cruis refuses to refund deposits despite my self exclusion from Everymatrix date 3-12-2014. Everymatrix says: There is even an email from Every Matrix legal department on that complaint that reads: "Kindly be advised that our system has detected that you have registered multiple accounts on our network and that you have opted to self-exclude on another account/s. As per our commitment to endorse responsible gaming, it is our policy that if you have self-excluded on an account on our network, you will also be excluded on all other accounts within the same network for the same self-exclusion period". Then a complaint again at casino cruise, date: 9-2-2015 name Casino Cruise failed to follow responsible gaming and self exclusion casino cruise answers: We take the issue of problem gambling very seriously, and act to prevent any self-excluded client from wagering with our casino; such policy is reflected in the fact that if a punter self-excludes himself or herself from any online gambling website that operates under the same regulatory license under which Casino Cruise operates, he or she will also be self-excluded from the Casino Cruise website. 13-2-2016Casino Cruise - Confiscated winnings due to previous self exclusions with another brand, refusing to refund deposits. Here casino cruise refunded deposits. Then I see [EDIT], a casino cruise rep or director saying in another complaint : Please understand if you self exclude in one everymatrix license casino, you can't play in another, Because the self exclusion is your message to the Maltese regulator that you have a gambling problem an you need a time out from playing in other casino' s under that license and you cant win or loose money under MGA There is so much to find on it! Casino cruise obviously didnt check my SE well since I know for now I am permanent SE at play Frank (August 2016) and SE at Jetbull (17-4-2014) and for sure Florijn casino but I cant contact them anymore, since they dont have Dutch players anymore. And 1 December 2016 Betadonis. 7-3-2016 permanent SE at Superlenny!! They Share info with casino cruise according to [EDIT] on Casinomeister. I'll send them to you to check. They knew it! Casino cruise obviously don't manage my case with things they say in other complaints, plus they seek the borders of closures. A long time problem of SE/ permanent closure in their casino. It certainly needs improvement! Other respected casino's handle these matters in a better way. Betser example included I have understand today that my case is still open at upper management. Ofcourse they have known about the permanent SE, there are many! Perheps when you discuss it with Lloyd Apter they come to see there is some responsibility from there side and a settlement is possible? He is the managing director I believe and know a lot about these SE cases I have understood. Otherwise I do have to try at MGA, since my stakes. I'll hope you can... Greetz again!

Hi Pogg,

I forgot, another good solution for casino cruise in preventing these cases is that they have it build in in the system to exclude yourself. Now it seems they only offer it for UK, why not for MGA??

Now you always have to go to customer service to get limits or closing account. They interpreted how you feel about closing your account..."close the account permanent!!! Please. Permanent immediately" is obviously on their judgement not enough.

If I could have done this myself this problem would never ever have happend. And when you can donut yourselve, you can do it immediately and not having to wait for them to mail you.

This is another example of seeking the borders in my opinion. A lot of improvement on their policy can be done, like Lloyd Apter says in his correspondence at Casinomeister on EM, but they still after years go on in the same way, as it seems to me.

And I honestly didn't see their mail after 4-6-2017 asking about the reason. Can you send this to me, cause it could be ended up in my spam.

Thx Pogg!

Hi wilhelmia16,

Unfortunately your insistence that "permanent" should be self-exclusions simply isn't in line with our experiences of what any of a number of regulators require, not is it the practice being put into place by the multitude of other operators we have managed this type of dispute for. I appreciate that this interpretation of permanent would help your case, but our function here is to remain impartial and ensure that the operators adhere to the regulatory rules that are in place.

I'd also say that it's not only the operators judgement of your communications that have found Responsible Gambling policies not to apply it's ours as well.

I know the member of staff that you're quoting and the information he's giving out is correct. That is how self-exclusions work across the EveryMatrix platform and they did share information with EveryMatrix while they were on the EveryMatrix license. At the current time EveryMatrix do not cooperate with Casino Cruise even to review complaints that date to when Casino Cruise were on the EveryMatrix license. This is the reason I've directed you to the MGA.

Whether or not you are actually self-excluded on the EveryMatrix license is going to come down to how clearly you've communicated your need to be self-excluded to the other operators you claim to have to have restricted yourself at.

The details that you've used when signing-up at the various operators are also likely to be relevant to any claim as if you've altered your registration details from operator to operator their automated detection systems would not pick up additional accounts being registered.

My concerns here are that you've listed self-excluding at multiple different EveryMatrix properties. A single self-exclusion should have applied to all EveryMatrix properties. This suggests to me that your closure requests have not been dealt with under Responsible Gambling policies. This conclusion would be in line with your name not having been included on the self-exclusion list when Casino Cruise left the EveryMatrix license. If that's the case this once again comes back to reviewing your communication with each operator to determine whether or not they should have acted without a direct statement that you were experiencing gambling issues.

All we can do is recommend you contact the MGA.

Sorry,

ThePOGG

Hi Pogg!

No sorry please! Really thx for your sincere and impartial investigation. Even when it's not at my advantage, I really thank you for giving a serious look at this matter. It is nice to know you are heard in these delicate matters!

I understand there is not a partial solution possible with casino cruise since your view is I have no case on your experience?

I do still feel Casino Cruise is searching for the borders, by reopening accounts immediately without a waiting period and by not having an automatic SE system, so an employee judges about your feelings about this subject.

I also investigated a lot of cases of permanent closures in the mean time and a lot of casino's do acknowledge in these cases and refund the deposited money.

It is still not obvious for casino's and gamblers what is the correct policy on this matter, cause they all interpret different, of which I asked to a lot casino's recently.

I still think Casino Cruise breached their own terms by not describing an reopening of a 'normal account'. They only have reopening under responsible gaming in their terms, so those rules are valid.

Just like I still believe regular closings are under MGA rules the same as excluded accounts (they don't talk about self excluded) since their is no more law about it in MGA.

I also still think MGA sees a exclusion as important under a license and not only self exclusion, since they only speak of excluding instead of selfexcluding. Just like Lloyd Apter says about MGA in a former quote here.

I wonder if MGA is the institution for me to go to, since they check regulations of the license. Legally I suspect there must rice suspicion on so many SE in one license, but like you explained, MGA has a different scope. But I can sure try before a civil lawsuit.

Anyway a law suit should never be the first intention, i like to sort it out before, so when it ain't possible for you to speak to Lloyd Apter, I will approach him for further procedures next week. As you probably noticed I am a person with perseverence....

I sincerely thank you, Pogg, for viewing and all your effort and especially your gained wishdom on this subject plus for hearing me out, cause my experience is, and probably a lot of readers here, you walk into a brick wall in this business, which can completely ruin your life with your own permission to do so. In my personal opinion there should be more protection. Luckily that will be the tendency in at least British and Dutch regulators, as I have noticed. And they are not to dependent of money from the gambling industry....

I'll keep you posted on MGA if you like, or do you also provide a service how to proceed with MGA?

Many thx again,

Greetz!!!

Oh ! PS, can you mail me the respons of Casino Cruise after my last urgent permanent closure request of June 4th?

Many thanks!

Hi Pogg,

Still some last thoughts...

I was wondering Pogg over a night sleep,

You are absolutely sure cc did everything possible in this case to meet responsible gaming requirements??? So there was never any doubtfull moment?? Not enough to at least give some money back?

They never ever once offered me a self exclusion option while upon closing the account. There is no option of closing the account yourself, so the employee needs to decide

If it's my will to close permanent why does the casino don't just do that? What do those words mean????? Why they don't ask directly when closing an account on having problems?? Why can I open immediately??? They should have been investigating during 7 days if there is a problem with gambling. Not open immediately without even questions asked.

Summary:

Regarding to these facts

-able to open an account on Casino Cruise on 20-12-2015, even there where numerous SE on other everymatrix brands. Which is requiered under the same license to execute according to MGA

-able to open an account in nov 2016 on Spinit, even when they Exchange SE, not under Everymatrix license, with Superlenny, where i was permanently self excluded on 7-3-2016, which Lloyd Apter says they still do.

-losing not €1000 on Spinit,but €1250 payd in 20 terms which is not a high enough amount to consider gambling problems according to you. Allthough I spend from 23:30-03:00 at night on thursday in payments every copple of minutes in the same game a €1000?

-extremely much multiple discussions/ argues on cashback in a month on Spinit, I was called impatience, this goes on and on multiple asks of bonusmoney or free spins. Cause all of my money was gone. My balance was all the time 9 ct, cause I couldnt make deposits anymore of the huge loss of €1000, all my money was gone. I said: its your system I am a victim off. I have 20 chats on this matter.

-19-12-2016 asked for permanent BLOCK on account, no asking of gambling problems.

-set a responsible gambling limit on my deposits of Spinit as well there

No indication whatsoever???

Close 9-2-2016 reason couldn't deposit

Open 21-5-2017 nothing asked

Close 24-5-2017 close permanently asked twice, operator says no worries

Open 3-6-2017 asked for the reason of reopening, i said was angry, took her only 40 seconds to reopen, see chat. Obviously properly viewed.

Close 4 Juni 2017: note: hello close account permanent!!! Please do!!!!please close immediately!!!!

Open 15-8-2017 no reason asked after that urgent note... just openend it again in a sec.

I played from 11:00-14:45 the same game over and over again. I had a appointment then and lost already like 5k then. On that doomday, I suddenly received a verificationmail on 18:00. Where they suspicious of gambling suddenly? Cause I didnt play for a couple of hours and it was problematic then?? And I played again after a few hours break, for the real big loss.

Close 18-8-2017 by my own. not even on my chat with Leonardo 16-8 it was enough reason to suspect gambling problems,

-still getting promotional e-mails now.

So, Pogg, you are utmost sure, they did everything in their powers like they should have done? Even considered they Exchange information with Superlenny? Even considered my new points of view of Spinit argueing for like 20 chats of cashback bonus and spins is not irrational and depositing 12 times at night on wednesday 23:30-3:00 on workday totally €1000 on the same game?

and for the break of hours the after losing a extensive amount on 15th of August when I got the verificationmail suddenly?

There is nothing irrational on playing the same game for hours and hours?

If you are absolutely sure, there was nothing in this matter that is only a bit of their responsibility to refund me some than this case here can be closed.

I know I talk in circles a bit... sorry.

Like to hear on the new views,

Many thanks!

Hi wilhelmina16,

I've already reviewed all of the chats that you've just sent through. They were part of the package the operator provided. As I said, I went through ALL your communication for the relevant time period.

With regard to the time of play - this isn't a factor for consideration. Not everyone has the same routine and if everyone who played in unusual hours was to be assumed to be a problem gambler, operators would be as well closing their services at night. The same can be said for the day of the week.

The Live Chats - I'm aware of the Live Chats regarding this specific issue. This isn't irrational behaviour, there appears to have been a specific issue with both the technical function on the of the site and with the operator going back on their assurance of a cashback bonus in form of compensation. While you do seem irate, you appear to be irate due to what you poor service you're receiving, not because of a sustained loss or engagement with gambling.

Finally - as I've been clear about above - no-one is denying that EveryMatrix shared self-exclusion information with Casino Cruise/SpinIt when these casinos were on the EveryMatrix license. However, for Casino Cruise to be aware of a self-exclusion at other EveryMatrix properties you would actually have had to be on the EveryMatrix self-exclusion list. The information I've been given clearly states that you were not on EveryMatrix's self-exclusion list at the time Casino Cruise left the EveryMatrix license. This means that either the EveryMatrix operators that you self-excluded at have made a mistake and marked your account as simply closed rather than self-excluded or, as with this case, you were not clear enough in telling the involved operators that you wanted to close your account due to problem gambling issues. The only way you can resolve whether or not you should have been on the EveryMatrix self-exclusion list is to contact the MGA.

I'm sorry you're unhappy with our ruling, but there's nothing further we can do to help you.

ThePOGG

Hi Pogg, I suddenly see something else again. You stated above: "The account is permanently closed unless you give a direct contrary request." Well does the first reopening on may of a permanent closed account sounds like a direct contrary request? [EDIT] 09:32:31 pm Would you like the account re open. Player: 09:32:42 pm do i need to wait a week? [EDIT] 09:33:12 pm I will open it up for you now. It has been done for you. Enjoy. He just opens it on his own!!!! I only asked do I need to wait a week? An indication of me knowing SE procedures, which I thought I was under at this casino. I have sent you this chat and all Spinit communication and my madness bankpayments plus the proove Casino Cruise exchanges SE info with Superlenny. Greetz!

Hi Pogg,

Two last things before MGA for an answer:

1) the operator openend on his own my permanent closed account without me not Asking to! This is not a direct contrary request as you stated.

2, what about opening on Spinit and They Share SE info with Superlenny, while they were of Everymatrix? I was PERMANENT SE there. They knew upon that reason.

Greetz!

I mean I didnt ask to open my account

And I mean they were not of everymatrix in december 2016 but getting SE info from Superlenny.

Sorry for the miscorrect spelling!

Hi wilhelmina16,

1) You contacted support because you were actively trying to deposit. Support identified that the reason you couldn't deposit was that you're account had been previously closed. They then re-opened your account to solve the problem. The fact that you were actively trying to deposit logically implies that you wanted the account open.

2) I'm at a loss as to how to be any clearer in conveying this information - Casino Cruise could still be sharing self-exclusion information with EveryMatrix right now. It would make no difference what-so-ever if your name is not on the EveryMatrix self-exclusion list. This leads us back to my previous response:

"either the EveryMatrix operators that you self-excluded at have made a mistake and marked your account as simply closed rather than self-excluded or, as with this case, you were not clear enough in telling the involved operators that you wanted to close your account due to problem gambling issues. The only way you can resolve whether or not you should have been on the EveryMatrix self-exclusion list is to contact the MGA."

Thanks,

ThePOGG

Hi Pogg,

I disagree on this, but it don't matter I guess.

1) This is not a direct contrary request to open my permanent closed account by me just because I push some buttons to see the system works, since I was able to log in. That I am saying the deposit button etc. doesn't work, is not saying I want to deposit! He just did without my direct approval or without me asking to!

2) I dont understand this, since Superlenny is not Everymatrix, and I am referring to registering at Spinit under their own license in 2016 December. But you mean obviously that all doesn't matter cause it's the license where it should be registered on a list.

? sorry

MGA finds SE accounts automatically as problem gambling I have understand. I hope so, well see.

Some closure thoughts of this complaint for casino cruise:

Still feel like Casino Cruise should update their policy on many points about these serious problems and not seeking the borders wherever possible in responsible gaming. Cause they do on the contrary of many licensed casino's. A lot of gamblers find permanent closure requests the same as SE. Check the numerous complaints on the subject elsewhere.

I finally want to give some recommendations to Casino Cruise from a gamblers point of view with troubles:

1) set a 7 day waiting period after all permanent closure requests ( not a normal one) who wants reopening just like all major casino's.

2) if someone wants permanent closure ask if they have gambling problems straight ahead, cause in 90% of the cases they have problems for sure.

3) update the terms on what is normal closure and reopening and what is not. Be very explicit about that.

4) set a electronic system up to let it do yourself, do not solely let an employee decide if it's a regular closure or SE

5) don't just open accounts when not asked explicitly

6) be extra alert of gambling problems when somebody ask for multiple times to close and reopen.

7) be extra alert when somebody says please please close it permanently, ask what they mean. Ask if they have problems.

8) get extra staff training on this issue, cause like at other casino's they are warned when somebody asks for cashback or deposits back or permanent closures.

9) set a max deposit limit a day automatically of for example €500 when you are not VIP and are just registered.

10) let there be an automatic alert to agents when someone is playing for hours and hours the same game.

11) do a check up when 10x depositing within a couple of hours in the system.

Thx Pogg for all again!!!

Hope Casino Cruise strict their policy on responsible gaming more so these complaints will be less on the subject, when they claim they find responsible gaming utmost important. I know you disagree on my recommendations as an ADR, but I just giving a gamblers addiction point of view, since they are the weakest parties and not the casino's. Rules upon problem gamblers can't go far enough, due to the severity of this disease!

Hi wilhelmina16,

I'm afraid that this argument doesn't make any sense. You were pressing the deposit button, a button that's only purpose is to deposit funds, and even went so far as to contact support when you found this button didn't allow you to deposit but you're arguing that you never wanted to deposit?

I understand that you have a vested interest in arguing your case here, but that argument does not make any sense what-so-ever. When you contact support because you can't get the deposit button to work you were clearly trying to deposit.

If you are referring to SuperLenny outside of the EveryMatrix license (I believe they were on the EveryMatrix platform previously as well) this would still be irrelevant. These properties are not on the same license. If they're sharing some self-exclusion information that would be over and above the requirements of their licenses. Both the MGA and UKGC do require the extension of self-exclusions, but ONLY to other properties on the same license.

In response to your list:

1) You're right I don't agree with you on this point at all. Your position is based on the assumption that the only person that would ever ask for a permanent closure is a problem gambler and in my experience this simply isn't the case.

2) You were asked this on a number of occasions and where you responded you explicitly stated that you were not a problem gambler.

3) There's no need for this - the terms in place that you've referenced in this complaint are specifically and exclusively found on the Responsible Gambling page. As you are convinced that you've asked for a self-exclusion under Responsible Gambling policies, having secondary terms related to normal account closure policies in the general terms would have made no difference to your case. Your case hinged on whether or not you'd actually asked for a self-exclusion, not which set of closure terms would apply.

4) I do agree with this.

5) As pointed out above that's not a fair representation of what happened to you.

6) I'd agree with this but don't agree that this would have made any difference to your case. That made up part of our review of your interactions. Your activity did not represent a worrying pattern of account closures.

7) This is a repetition of point 2). Again, the operator did explicitly ask whether you had a gambling problem at this point. You did not respond.

8) While all operators should engage training on this issue, your behaviour simply would not fall into a 'high risk' category at any point prior to you engaging in a session that was vastly different to any of your activity before this point. While the operator's actions after this point could be improved, as no play occurred after this point this is something they need to address in terms of training but once again would not have impacted your case.

9) No gambling license requires this and this would presume that every player has the same limits they are comfortable with. As a point, Casino Cruise do offer deposit limits that you can set up at any time by contacting support.

10) Again no gambling license requires this.

11) This would only work if there were staff who were expert in problem gambling behaviour available to review activity immediately. All licenses provide operators a reasonable length of time to review concerning account activity, usually 24h. 24h would have been too slow to make any difference to you.

I do feel a great degree of sympathy for you - €17k is a big loss and would cause a lot of people significant distress - but I do feel we're now going back over ground that's already been covered. As such I'm now closing this complaint.

I wish you the best of luck in the future.

ThePOGG

Hi wilhelmina16,

As has been explained to you twice now this complaint has now been closed. No further comments made on this thread will receive approval.

The SpinIt terms and conditions regarding Responsible Gambling missing the section on a 7 day cooling off period does not mean that all account closures need to be viewed as self-exclusions, it means that self-exclusions need to be viewed as self-exclusions and the Responsible Gambling section of their website needs to be updated.

Regarding your balance, you know you didn't just forget about €3k and you spend a lot of time the next day on Live Chat without mentioning any balance anomaly.

We are not here to negotiate a settlement for you in this case. This isn't a situation where there has been fault on both sides. We've reviewed your account activities and communication and I've been clear with you that we do not view the operator to have done anything wrong. I appreciate you find that difficult to accept, but our role in this conversation is now at an end. If you want to pursue this further you need to take this issue to the MGA or through your local court system as you seemed intent on doing at the start of this conversation.

I do understand why you're being so tenacious, but I'm also being clear that our involvement in the discussion of your case is now at an end. We have reviewed the relevant information and we cannot uphold your claim.

ThePOGG