Casino Heroes – Query about responsible gambling complaint

Hi ruby99 - welcome to ThePOGG.com!

Yes, we're happy to review Responsible Gambling related complaints so please provide further information. I will state in advance however that this type of issue - where you are relying on the operator to have detected your gambling issue without you having explicitly told them are usually very difficult to prove.

Thanks,

ThePOGG

Thanks very much for your reply, I understand.

I have sent in a complaint to Casino Heroes about responsible gambling but they have rejected this. My complaint is as follows (sorry for the length):

I self-excluded myself from Casino Heroes on about 18 October for the longest available period, 5 years. I am a compulsive gambler and am seeking help for my addiction. Earlier this year, I self-excluded myself from all sites/groups I had previously played at, but during a time of personal stress in June, I signed up and played at this casino.

I played on the site for a few days in June and then from about 4 September to 18 October. During this time, I made a huge number of deposits ranging from £10 up to about £100, to a total net loss of nearly £5500. The five or six withdrawals I made were redeposited and lost within days.

Due to my addiction, I often started playing late at night and then felt unable to stop, and was chasing losses, until 2 or 3 am. Sometimes, like on 16 October, I played all day and evening, a session lasting more than 12 hours. I estimate that about 90% of my play was on just two, highly volatile games, Bonanza and White Rabbit.

Despite gross deposits of about £8000, I was not asked to provide any evidence of the source of my income, nor at any time did a casino representative contact me to enquire about the number of deposits I was making, their speed (within minutes of each other as I chased losses), and the length of my play sessions. I also requested eight limited self-exclusions as 'time outs' all of which I believe showed clearly I was suffering from compulsive gambling behaviour.

I believe Casino Heroes has breached the UK's Gambling Commission's Social Responsibility code provision 3.4.1(e) customer interaction, which states:
1 Licensees must put into effect policies and procedures for customer interaction where they have concerns that a customer’s behaviour may indicate problem gambling. The policies must include:
(e) specific provision for making use of all relevant sources of information to ensure effective decision making, and to guide and deliver effective customer interactions, including in particular
(i) provision to identify at risk customers who may not be displaying obvious signs of, or overt behaviour associated with, problem gambling: this should be by reference to indicators such as time or money spent.

And also provision 3.1.1:
1 Licensees must have and put into effect policies and procedures intended to promote socially responsible gambling including the specific policies and procedures required by the provisions of section 3 of this code.

I accept my own responsibility for opening an account and playing at the site, although this was done during a period of personal stress and illness, but having made use of the 'time out' facility on at least eight occasions, and taking into account:

1. the very high number of deposits in short periods of time (and often within minutes of each other)
2. the total amount of these deposits (including on credit cards directly, or through Skrill)
3. the pattern of my play (only a couple of slots played at, chasing losses), and
4. time spent (lengthy sessions, late at night or throughout a working day),

I believe I should have been identified and contacted by Customer Support through the Code of Practice social responsibility provisions of the Casino Heroes UK gambling licence to discuss my situation. I believe this would have led to them closing my account or me selecting 5-year self-exclusion as I would have been unable to deny the fact of my addiction and even a cursory examination of my account would highlight the problems listed above.

In view of this, and I believe shared responsibility for allowing the situation to progress, I would like to request a refund of 50% of my net deposits to Casino Heroes.

With regards
[EDIT]

Casino Heroes rejected my complaint saying:

Hi [EDIT]!
We have now concluded our internal investigation on your account. After the investigation, we have come to the conclusion that there is no claim here for refunding your deposits. We have done what is required from as when it comes to measures protecting our players, provided tools for breaks and also checked Source of Funds.

Based on your previous emails, we have now closed your account permanently without possibility to reopen.

We wish you all the best, and would like to encourage you once more to look into below helpful links:
[Links given]
This will be our final decision on this matter,

Br,

Best Regards,
[EDIT]
Support Manager

I repeated my request for a refund as I explained that I did not think they had done enough to protect me as a player and I queried about the source of funds, and their response was as follows:

Hi [EDIT],
The Source of Funds form pops up on your account after you have reached a certain activity level on your account and you would not have been able to continue playing without filling this in. There is no email communication about this, but the the information you fill in is registered on your user account, and you are responsible for making sure that this information is correct.
Please see below for the information you filled in:
### Sources of Funds
**Id: 379**
**Employment** Self-Employed
**Occupation** Account Executive
**Salary** 20001-40000
**Sources of Income** None
**Submitted at** 2018-09-04 18:22:50 +0200
**Checked** Yes
**Verified at**
2018-09-05 12:10:49 +0200
We can also confirm that you sent your ID and proof of address in an email to us on September the 5th as these were requested via email.
As mentioned before our decision on this case is still final, and this has been escalated to the responsible departments already.
Best,
[EDIT]
Shift Manager

My self-employed income (my only income) is about £29,000 gross (so about £1917 net /month), but I was never asked to prove this and I think the income range they provide (£20,001-£40,000) is too wide to be of any use in determining affordability. It would imply that they are happy that someone self-employed earning £20,001 (= about £1445/month after tax and NI) with no other declared source of income has deposited about £8000 in about 6 weeks at the casino, and lost about £5500 ...

To me it is a huge sum, and I am heavily in debt with a loan and credit cards maxed out.

I’m not saying that Casino Heroes, or any casino for that matter, should conduct an in-depth review of every player down to requesting proof of income, but I really feel that even a cursory examination of my account should have alerted them to my gambling addiction and prompted them to contact me to investigate this.

I’d be very grateful if you could take up this complaint with Casino Heroes on my behalf.

Hi ruby99,

The nature of this case will require us to discuss the expectations and standards of the UKGC with the regulator. As that is the case it is likely to take a significant period of time to review. Please be patient while that happens.

Thanks,

ThePOGG

Hi,
Thank you very much for taking the time to look into this, it's much appreciated.

I wanted to reiterate that the amount I deposited and lost is a huge amount for me. I don't have any saving and borrowed most of what I spent via credit cards and a loan. It all now seems like a bad dream as I was under a lot of personal stress at the time and just kept playing rather manically thinking I would eventually 'win big' and pay it all off...

Anyway, at this rate I will be paying it off for years.

Thank you again for your time and effort.

Hello,
I appreciate that you mentioned that it could take a significant length of time to review this complaint, but I was wondering if the UKGC has been able to start looking into this or if it is still awaiting their attention?
Thank you again for your help.
Ruby99

Hi Ruby99,

We've now concluded our conversation with the regulator and the operator.

The UKGC has NOT provided any feedback on your specific case - they do not review individual cases in this manner and do not provide feedback where they do. Instead they've provided general guidance regarding where and when Source of Wealth checks should take place.

The operator has the details of your specific case, but after an extended conversation about where/when they can discuss player complaints with 3rd parties, has chosen to decline to speak to us about this case. I do need to be clear that this was a choice on their part - there are no legal or regulatory barriers to them engaging this conversation if they choose to.

My understanding based on the documentation provided by the UKGC is that if you have made deposits of £8k in the space of a month, this would significantly exceed the average UK monthly income and even the monthly salary at the top end of the bracket you provided for your income. That being the case it seems likely that Source of Wealth checks should have taken place on that basis alone.

At this stage all we can do is recommend you contact the operator's ADR eCOGRA, though they decline the case as historically they have not been willing to review responsible gambling issues, or the UKGC directly.

Sorry we could not be of more help!

ThePOGG