Spinarium Casino - Player's account has been blocked after winnings claim.

📜 Official Complaint to Gaming Control Anjouan

From:

[Personal information hidden by Casino Guru]

To:

Gaming Control Anjouan

📧 info@gamingcontrolanjouan.org

Date: 27 August 2025

Subject: Formal Complaint – Spinarium Casino (Account Block, Withheld Winnings, GDPR Breach)

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1. Identification of the operator

The operator is Spinarium Casino, licensed by the Government of Anjouan (License ID: ALSI-202411034-FI1), operated by Cosmogames N.V., Curacao, with EU representation in Cyprus.

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2. My account details

Account email: [Personal information hidden by Casino Guru]

Account ID: [Personal information hidden by Casino Guru]

KYC verified successfully on 13 August 2025 (confirmed in writing by Support Manager [Personal information hidden by Casino Guru]).

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3. Timeline of events

6 August 2025 – Spinarium acknowledged that I mistakenly contacted them from another email. They confirmed the second account had "no funds on the balance."

13 August 2025 – Spinarium confirmed my account verification was successful.

6–26 August 2025 – Despite awareness of the second email, Spinarium accepted deposits from me (hundreds of euros) and allowed unrestricted play.

26 August 2025, 23:10 (CET) – While playing Fruit Train Express, my balance reached €61,685.64 (see screenshot). At the same time, my Spinarium account showed €29,012.61 and €34,587.62. Immediately after this winning session, Spinarium blocked my account under the pretext of "multi-accounting."

27 August 2025 – I formally requested a complete transaction statement (deposits, wagers, wins, losses, bonuses, internal notes) under GDPR Article 15 & 20. Spinarium refused, claiming: "Our Terms and Conditions do not contain the items you mentioned."

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4. Breaches by Spinarium

Breach of their own Terms & Conditions – According to T&C:

> "Accounts are subject to immediate closure if it is found that you have multiple Accounts."

→ Spinarium was aware of a second email already on 6 August but failed to act. Instead, they accepted deposits, completed KYC, and only blocked my account after I won €61,685.64.

Breach of contract (pacta sunt servanda) – By validating KYC, accepting deposits, and allowing play, Spinarium created a binding obligation to honor winnings. Blocking the account retroactively is unlawful.

Unfair commercial practice – Raising "multi-accounting" only after large winnings, despite prior knowledge, is arbitrary and abusive.

Unjust enrichment – Spinarium knowingly accepted my deposits but refuses to release winnings.

Breach of GDPR & data protection law – Under GDPR Art. 15 & 20, I am entitled to access all personal and transactional data. Spinarium refused, claiming it is not in their T&C, which is irrelevant – legal obligations override T&C.

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5. Evidence attached

1. Email 6 August 2025 – acknowledgment of duplicate email, confirmation of no funds.

2. Email 13 August 2025 – KYC verification successful.

3. Screenshots of account balances (€29,012.61 and €34,587.62).

4. Screenshot of in-game balance (€61,685.64 on 26 August 2025, 23:10 CET).

5. Spinarium’s refusal (27 August 2025): "Our Terms and Conditions do not contain the items you mentioned."

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6. Requested action

I respectfully request that Gaming Control Anjouan:

1. Investigates Spinarium Casino for violations of its license conditions, Terms & Conditions, and data protection laws.

2. Orders Spinarium to immediately release my verified winnings of €61,685.64 plus my existing account balances (€29,012.61 and €34,587.62).

3. Ensures Spinarium provides me with a full statement of all transactions, as required under GDPR and AML obligations.

4. Considers sanctions against Spinarium for breach of fair play and consumer protection standards.

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7. Conclusion

Spinarium knowingly ignored its own T&C, validated my account, accepted deposits, and only blocked me after a significant win. Their refusal to provide data further violates GDPR and licensing obligations.

I kindly ask Gaming Control Anjouan to intervene and enforce my lawful rights.

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Sincerely,

[Personal information hidden by Casino Guru]

Hello,

Thank you very much for submitting your complaint. I'm sorry to hear about the difficulties you’re experiencing. To better understand your situation, I’d like to ask you a few clarifying questions:

• Did you knowingly create two accounts at this casino? If so, could you please specify when exactly the first account was opened and when the second one was created?
• Was the first account closed before the second one was opened, or were both accounts active at the same time?
• Have you completed the full KYC verification on any of your accounts?
• Did you activate any bonuses in both accounts?

I hope we will be able to help you resolve this issue as soon as possible. Thank you in advance for your reply.

Best regards

Veronika

Important Notice:

Casino.Guru will never ask for any payments or access to your accounts in order to complete KYC. If someone claims to be from Casino.Guru and makes such a request, do not share any information. We only contact players through this official complaint thread or via email addresses ending in @casino.guru. Always check the sender’s domain and verify your resolver’s email by clicking on their avatar within the official complaint thread.

If anything seems suspicious, please contact us directly. Stay safe.

Must send screenshot with final balance

Thank you for your responses. However, I need you to answer the questions I asked in my initial reply clearly and simply so that we can continue with the investigation:

1. Did you knowingly create two accounts at this casino? If so, could you please specify when exactly the first account was opened and when the second one was created?
2. Was the first account closed before the second one was opened, or were both accounts active at the same time?
3. Have you completed the full KYC verification on any of your accounts?
4. Did you activate any bonuses in both accounts?

Thank you very much, Benray, for providing all the necessary information. I will now transfer your complaint to my colleague Kubo (jakub.m@casino.guru) who will be at your assistance. I wish you the best of luck and hope to see your problem being resolved to your satisfaction in the near future.

Dear Benray,

It’s a pleasure to e-meet you. My name is Kubo, and I’ll be handling your complaint moving forward.

If there have been any updates or new developments since your last message, please don’t hesitate to share them with me.

In accordance with our standard procedure, I’d like to invite a representative from Spinarium Casino to join this conversation. Their participation will help ensure a smoother and more efficient resolution of your case.

Dear Spinarium Casino,

Could you please provide a comprehensive explanation of this case, including the specific reasons for the closure/blocking of the player's account? Your detailed insight will help us proceed with a fair and informed resolution.

Thank you in advance for your cooperation and prompt response.

Best regards,

Kubo

Dear Casino Guru Team,

Dear Benray,

After a compliance review, we confirm that the account in question was closed due to a breach of our Terms & Conditions, section 5.4, which prohibits the registration of multiple accounts. It is important to highlight that under our policy, the violation occurs at the moment of creating more than one account, regardless of how those accounts were later used.

Our systems and manual checks identified clear links to previously registered accounts that were already blocked for the same reason. This decision was therefore applied consistently with our rules, which are designed to ensure fairness, protect promotional integrity, and maintain a safe environment for all players.

We understand that such actions may cause frustration, but multi-accounting is considered a serious violation across the industry.

Please note that we maintain complete back-office records, including technical logs and account link evidence. If Casino Guru requests, we are fully prepared to provide proof through a secure, private channel to protect sensitive player data.

We appreciate your understanding and assure you that these measures are applied fairly and equally to all players, in line with our Terms & Conditions.

Sincerely,

Spinarium Support Team

Final Statement

Spinarium’s unfair conduct is not an accident – it has the hallmarks of an established practice. They rely on the assumption that such behavior will go unchallenged, hiding behind Terms & Conditions which can never stand above human rights, civil law, commercial law, or criminal law.

If no consequences are drawn, it will send a dangerous signal that players have no guaranteed fundamental rights, while casinos continue to enrich themselves at their expense and openly disregard licensing conditions.

This does not only damage individual players – it undermines the credibility of the entire online gambling industry. It also tarnishes the reputation of the licensing jurisdictions themselves, since regulators are seen as tolerating operators who knowingly accept deposits while having no intention of paying winnings.

Such practices directly contradict binding law, including:

GDPR Art. 15 & 20 (EU Regulation 2016/679) – right of access and data portability,

Swiss Data Protection Act (DSG, Art. 25 & 32) – right of access and liability for damages,

EU Consumer Protection Directive 2005/29/EC – prohibition of unfair commercial practices,

International Anti-Money Laundering standards (FATF) – obligation to maintain and disclose full transaction histories,

Licensing rules (Curaçao, Cyprus, Anjouan) – requirement of fair treatment, transparency, and safeguarding of player funds.

A casino that accepts deposits without the genuine intention to honor winnings destroys the very principle of fair play on which regulated gambling is built.

Therefore, either Spinarium must pay out the winnings owed to me and provide the full account statement as required by law, or regulators must treat this as a serious violation of licensing conditions and impose sanctions, up to revocation of their license.

Precedents commonly applied in similar cases:

1. UK Gambling Commission Guidance (2018, 2021)

Established that an operator may not "selectively enforce" Terms & Conditions after already accepting deposits and allowing play.

If the operator was aware of multiple accounts but failed to act, it remains responsible for paying winnings on the KYC-verified account.

2. Maltese ADR (Alternative Dispute Resolution) decisions – 2020–2023

In several rulings, it was recognized that only the KYC-verified account is valid.

If a casino was aware of account duplication in advance but did not act immediately, it violates the principles of fair play and must pay out winnings.

3. ECOGRA & ADR for Curaçao cases (2022, 2023)

Confirmed that ignoring multi-accounting until the moment of a large win is unfair.

The casino must bear the consequences, as it knowingly accepted deposits and created a legitimate expectation of payout.

4. EU Consumer Protection Directive (2005/29/EC)

Explicitly prohibits "misleading and unfair commercial practices".

If an operator accepts deposits while intending to later invoke duplication as a reason to avoid payout, this constitutes deception and unfair practice.

Dear Spinarium Casino,

Thank you for your response. In order to proceed with the investigation, I kindly request that you provide the records and evidence supporting your claims. Please send all relevant materials to my email address at jakub.m@casino.guru.

Thank you in advance for your cooperation.

Dear Jakub,Spinarium ,

I just want to show how it was all of these mails have in original saved,

And make your own opinion about this

Breach of Terms & Conditions: Spinarium’s own rules require fair treatment and transparency. They accepted deposits and completed verification despite already knowing about both accounts. Selectively applying "multi-accounting" after a win contradicts their own T&Cs.

27.8.my oficial request for acountstatement 27.9.deadline

Violation of Law: By failing to deliver the requested account statement within 30 days, Spinarium has breached fundamental consumer protection obligations (e.g., EU Directive 2013/11/EU on Alternative Dispute Resolution and general principles of fair gaming under licensing law).

Abusive Conduct: The account closure was sudden, without due process, and can be described as violent/abusive in execution – cutting off access while holding my funds.

Unlawful Enrichment: Accepting deposits while knowingly planning to deny payouts is fraudulent behavior and constitutes illegal enrichment.

Precedents:

CJEU Case C-49/11 (Content Services Ltd v. Bundesarbeitskammer): The Court confirmed that failure to provide essential contractual information in due time is a breach of consumer protection law.

eCOGRA & MGA Rulings (multiple cases, 2019–2023): Regulators have repeatedly ruled that casinos cannot enforce T&Cs selectively after the fact, especially after KYC completion and deposit acceptance.

ADR decisions (UKGC & IBAS cases): Multi-accounting arguments were dismissed where casinos had prior knowledge yet still verified accounts and accepted funds.

Requested Resolution:

1. Immediate payment of my full withheld winnings.

2. Delivery of the complete account statement (both e-mails/accounts).

3. Formal acknowledgment of wrongdoing and corrective action to prevent repetition.

Conclusion:

The facts prove that Spinarium knowingly accepted my deposits, processed my verification, and only used the "multi-accounting" argument after I achieved winnings. This is unlawful, abusive, and inconsistent with licensing obligations.

I request the arbitration body to rule in my favor and compel Spinarium to release my winnings without further delay.Selective Enforcement: Spinarium was aware of two e-mails/accounts, yet only enforced the "multi-accounting" argument after a large win, which demonstrates an intentional strategy to avoid payouts.

Unfair Enrichment: By accepting my deposits and allowing me to play while being aware of the situation, Spinarium unlawfully profited at my expense.

Breach of Transparency: Failure to deliver the requested account statement within the required 30-day period is a violation of fair gaming and consumer protection standards.

Violation of Trust: Conducting full KYC, approving deposits, and only then applying selective rules is a fraudulent and exploitative practice.

Requested Resolution:

1. Immediate release of my withheld winnings in full.

2. Delivery of the complete account statement covering both accounts (benray@azet.sk & milankuffaml@gmail.com).

3. Formal acknowledgment of wrongdoing and corrective measures to prevent future selective enforcement against players.

Conclusion:

The evidence clearly shows that Spinarium knowingly verified my account, accepted my deposits, and allowed my gameplay, only to later invoke "multi-accounting" as a pretext to avoid paying legitimate winnings. Such conduct constitutes unfair business practice, fraudulent enrichment, and a violation of both licensing obligations and consumer protection laws.

I respectfully request that the relevant authority/arbitration body reviews this matter and compels Spinarium to settle my winnings in accordance with fair gaming regulations.

It is unthinkable that players should be subjected to terror and abuse from a casino that deliberately manipulates its own system in order to profit at the expense of its customers.

As a paying customer, I also have rights – no business can lawfully rob me, cause me harm, and then hide behind selectively constructed rules designed only to deny payouts. If this practice is tolerated, then the entire online casino industry becomes nothing more than a black hole of injustice, where players are left without any protection or enforceable rights.

By enforcing questionable, purposefully fabricated rules only when it suits them, Spinarium engages in theft, unlawful enrichment, abuse of customer trust, and damages the reputation of the entire licensed gaming sector.

This behavior is not only an insult to me as a customer but also a mockery of the licensing authorities that are supposed to oversee and ensure fairness in this industry.

The central question arises: Is the law still enforceable in this sector, or are we witnessing the dictatorship of large casinos deciding who is "allowed" to win and who is merely exploited?

Dear Casino Guru Team,

Please find attached the relevant evidence to support our claim in the email we have sent.

Kindly let us know if any additional information or documentation is required.

Warm regards,

Spinarium Team

Dear Spinarium Casino,

Thank you for providing the additional evidence regarding this matter. I will review it as soon as possible and get back to you with our conclusion.

Dear Benray,

You previously stated that you had only one account at Spinarium Casino. However, according to the casino’s records, there is also an account registered under your second email address. Could you please clarify this discrepancy and explain the situation?

Dear Benray,

Your knowledge and preparation for this case are truly commendable. However, I’d like to clarify one point. You continue to claim that the casino was aware of your second account because you sent an inquiry regarding one account from the email address of another, and therefore the casino "should have known." While it would certainly be convenient if casinos could instantly detect such situations, that’s simply not how these systems operate. In reality, account checks are typically conducted following certain triggers, such as significant withdrawals or suspicious activity, not merely upon receiving an email.

In reality, account checks are typically conducted following certain triggers, such as significant withdrawals or suspicious activity, not just because an email was received. It’s highly unlikely that customer support staff are manually cross-checking every incoming email address against the entire user database unless something specific prompts them to do so.

In short, you breached the casino’s rules, and it isn’t reasonable to fault the casino for discovering this only later.

Additionally, I’d like to note the inconsistency in your statements. Earlier, you confidently asserted that you had only one account:

"My only active account (b****y@a***.sk) was opened in 2025. The other e-mail was never a valid account – just an accidental message to support on 6 August 2025."

Now, however, you claim that the second account might have been created unintentionally. That’s a rather puzzling shift in explanation.

Dear Spinarium Casino,

Could you please confirm the registration date of the second account and indicate whether there was any related activity (deposits, withdrawals, bonus claims, or gameplay)? Please feel free to send the relevant evidence to my email address at jakub.m@casino.guru.

Thank you for your cooperation.

Dear Casino Guru Team,

Please find attached the relevant evidence to support our claim in the email we have sent.

Kindly let us know if any additional information is required.

Warm regards,

Spinarium Team

And i will repeat that not ones but more times was exactly same cases used law ,precedense

Precedents commonly applied in similar cases:

1. UK Gambling Commission Guidance (2018, 2021)

Established that an operator may not "selectively enforce" Terms & Conditions after already accepting deposits and allowing play.

If the operator was aware of multiple accounts but failed to act, it remains responsible for paying winnings on the KYC-verified account.

2. Maltese ADR (Alternative Dispute Resolution) decisions – 2020–2023

In several rulings, it was recognized that only the KYC-verified account is valid.

If a casino was aware of account duplication in advance but did not act immediately, it violates the principles of fair play and must pay out winnings.

3. ECOGRA & ADR for Curaçao cases (2022, 2023)

Confirmed that ignoring multi-accounting until the moment of a large win is unfair.

The casino must bear the consequences, as it knowingly accepted deposits and created a legitimate expectation of payout.

4. EU Consumer Protection Directive (2005/29/EC)

Explicitly prohibits "misleading and unfair commercial practices".

If an operator accepts deposits while intending to later invoke duplication as a reason to avoid payout, this constitutes deception and unfair practice.

My question is how many times have to use casino Spinarium this T&C doubleaccounting against the player in unclear cases when they have to win some money but casino punch they with this stupid unfair practice i Dont believe i am first ,they use this how they like but it must be end with this screws for ever

Dear Benray,

Thank you for your patience, and I apologize for the delay in responding.

After carefully reviewing your case, I would like to provide a clear explanation of why Spinarium Casino’s decision has been considered justified. Your interpretation of the situation is not only inconsistent with the casino’s Terms and Conditions but also with elementary logic and our perspective at Casino Guru.

1. Multiple accounts and bonus use: Our investigation confirmed that two separate accounts were created and used at Spinarium Casino, both of which were used to claim promotional bonuses. This directly violates the casino’s Terms and Conditions, which - like most operators - strictly limit each player to a single account. The rule exists to ensure fair play and to prevent bonus abuse, which undermines the integrity of the promotional system designed for individual users.
2. Initial denial of multiple accounts: It is also important to note that you initially denied having created a second account. However, the evidence clearly shows that both accounts were registered and used by you. This contradiction weakens the credibility of your claim and further confirms that the duplicate account was not the result of an accidental or unintentional registration. If the second account had been created by mistake, we would expect immediate clarification or no bonus-related activity on it.
3. Casino’s responsibility versus player’s responsibility: You have argued that the casino should have detected the duplicate account because you contacted them from a different email address. While this may seem reasonable from your perspective, casinos do not continuously monitor user data in real time. Account reviews are conducted at specific trigger points, such as bonus redemptions, withdrawals, or verification checks. The fact that the casino did not identify the duplicate account immediately does not shift the responsibility away from you as the player. Compliance with the Terms and Conditions always remains the player’s obligation.
4. Final assessment: Based on the evidence, Spinarium Casino acted within its Terms and Conditions by voiding the winnings and closing the accounts. The actions taken are proportionate, fully justified, and consistent with standard industry practice.
5. Recommendations: To avoid similar issues in the future, we strongly recommend that you:

• Maintain only one active account per casino.
• Review Terms and Conditions carefully before claiming bonuses or promotions.

We understand that this outcome is disappointing, but it reflects a fair and logical resolution based on the available evidence. If you experience difficulties with other casinos in the future, please feel free to reach out to our Complaint Resolution Center - we will always be happy to assist.

Kind regards,

Kubo