Dear Katarina,
Thank you for your response and for clarifying the current position.
I fully understand that Curaçao regulations do not explicitly require cross-brand self-exclusion among operators holding a common license.
However, the issue here is not about database sharing, but rather about the license holder’s legal duty of care and its failure to protect a self-excluded player, as required by the Curaçao Gaming Control Board’s Responsible Gambling Framework.
According to Section 2.6 (License Holder’s Responsibility) of the GCB Responsible Gambling Guidelines:
"The license holder must have measures in place to protect vulnerable persons, including self-excluded players, and has a duty of care to identify, monitor, and restrict the activity of such individuals."
Furthermore, Section 3.4 (Player Protection Principles) states that:
"License holders must ensure that appropriate measures are in place to prevent gambling-related harm and to ensure fair treatment and protection of players at all times."
The company TechSolutions Group N.V., holder of Curaçao eGaming License No. 8048/JAZ, operates several casinos under the same license, including 22Bet, 20Bet, National Casino, and Granawin.
The fact that I was able to open a new account and gamble on Granawin, despite having already self-excluded from other TechSolutions brands using the same personal data (name, email, and country), demonstrates a failure to apply the duty of care required under these provisions.
This cannot be dismissed as a mere technical limitation — it is a systemic Responsible Gambling failure and a breach of license conditions under the Curaçao regulatory framework.
Therefore, I respectfully maintain that my case constitutes a clear Responsible Gambling violation by TechSolutions Group N.V., and I reiterate my request for the refund of €1,750, representing the total amount lost after the operator failed to uphold its regulatory obligations to protect a self-excluded player.
Thank you for your understanding and professionalism in handling this matter.
Dear Katarina,
Thank you for your response and for clarifying the current position.
I fully understand that Curaçao regulations do not explicitly require cross-brand self-exclusion among operators holding a common license.
However, the issue here is not about database sharing, but rather about the license holder’s legal duty of care and its failure to protect a self-excluded player, as required by the Curaçao Gaming Control Board’s Responsible Gambling Framework.
According to Section 2.6 (License Holder’s Responsibility) of the GCB Responsible Gambling Guidelines:
"The license holder must have measures in place to protect vulnerable persons, including self-excluded players, and has a duty of care to identify, monitor, and restrict the activity of such individuals."
Furthermore, Section 3.4 (Player Protection Principles) states that:
"License holders must ensure that appropriate measures are in place to prevent gambling-related harm and to ensure fair treatment and protection of players at all times."
The company TechSolutions Group N.V., holder of Curaçao eGaming License No. 8048/JAZ, operates several casinos under the same license, including 22Bet, 20Bet, National Casino, and Granawin.
The fact that I was able to open a new account and gamble on Granawin, despite having already self-excluded from other TechSolutions brands using the same personal data (name, email, and country), demonstrates a failure to apply the duty of care required under these provisions.
This cannot be dismissed as a mere technical limitation — it is a systemic Responsible Gambling failure and a breach of license conditions under the Curaçao regulatory framework.
Therefore, I respectfully maintain that my case constitutes a clear Responsible Gambling violation by TechSolutions Group N.V., and I reiterate my request for the refund of €1,750, representing the total amount lost after the operator failed to uphold its regulatory obligations to protect a self-excluded player.
Thank you for your understanding and professionalism in handling this matter.