22bet Casino - Pelaajan kotiutus viivästyy tilin vahvistusongelmien vuoksi.

On the 25th of June I made a €375.84 withdrawal from 22Bet, I was told to send them copies of my ID + receipts of my payments. The security team accepted my ID instantly, but weren't accepting my payment receipts until I sent them a bank statement that showed the deposits.

After that they asked me for a picture of me holding my ID & the email conversation I had with them open on my phone, which I provided, after that they demanded a similar picture but this time with the 22Bet Profile Menu open. I told them that the picture quality will make it so that the details will be unreadable, and they kept being unprofessional & rude saying to just comply with with their request. After I tried to reason with them and saying that I simply can not provide the documents, due to the insane glare that my phone screen will cause, and that my webcam isn't good enough to take a picture with all the details, they told me "Without providing the requested files any further actions are impossible. All further messages from you will be ignored." and thus far have ignored all of my attemps at figuring out a middleground.

I ask that CasinoGuru tries to either get 22Bet's team to mediate and agree on a middle ground with me so I am able to get the money out of my account in a reasonable timeframe. since I am unable to comply with the requests of the security team, since I do not own a better camera that would be able to take such a picture. I have attached a copy of my conversation with 22Bet but with certain personal details blanked out (such as a copy of my ID)

Important notice:

Casino Guru will never ask for payments or access to your accounts to complete KYC. If someone claims to be from Casino Guru and does that, do not share any information.

We only contact players through this official complaint thread or via @casino.guru e-mail addresses. Always check the sender’s domain and verify your complaint resolver’s e-mail address by clicking on their avatar visible inside the official complaint thread.

If anything seems suspicious, contact us directly.

Stay safe.

Hello,

Thank you very much for submitting your complaint. I’m sorry to hear about your problem.

Please understand that KYC is a very important and essential process, during which the casino makes sure that the money is sent to the rightful owner. As they don't have the luxury of being able to physically see all of the players and check their identification and documents, this is the only way gambling establishments are able to complete the verification procedures. None of the serious and licensed casinos takes KYC lightly and it might take a few working days to complete this thorough process.

Could you please confirm exactly which documents and photos you have already provided, and when you submitted the last one? Additionally, have you informed the casino that you are unable to provide the requested selfie due to technical limitations, and did the casino propose any alternative method of verification?

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

Best regards,

Attila

Hello Attila,

Here is a clear timeline:

• On the 25th of June, I won & withdrew my winnings, and the withdrawal was denied citing to contact the Security Team
• Security team asked me for copies of my ID on the 25th
• Security Team asked me for payment receipts on the 25th
• They rejected the intial documents, since they didn't meet their requirements
• On the 26th I provided them with Bank Statements
• On the 26th I was asked to take a selfie with me holding my ID + phone with the email thread, which I submitted on the same day, but was apparently rejected.
• In this case the support team was very rude and we're constantly just copy pasting parts of their script, without specifying what things they would have needed me to do
• On the 26th I was asked to take a selfie with me holding my ID + my phone having 22Bet's profile page opened
• I tried to ask for a alternative, since at that time I didn't think of a good solution to fix a glare problem that my phone screen caused, on white backgrounds (which 22Bets UI almost exclusively is)
• I provided what was asked and tried to fullfill the requirements, security team didn't accept and RUDELY weren't even willing to come to a compromise even after I asked them for a alternative or a compromise
• Afterwards the Security team responded with "Without providing the requested files any further actions are impossible. All further messages from you will be ignored." Basically saying "We aren't willing to compromise".
• I complained to 22Bets Complaints Email on the 29th regarding this, and got a reply saying "As part of our commitment to maintaining a secure environment, we are required to verify our customers through Know Your Customer (KYC) process. To complete the verification process, we may request additional documentation." Basically saying to just comply and try to figure out a way
• On the 29th I provided a picture of me holding my laptop + my ID, the security team responded to me by saying that "Dear customer, thank you for providing the requested data. Wait for the answer, please. Your data is under verification now."
• On the 2nd of July - They asked for me to send them copies of my utility bill, since I was unable to provide them (due to not paying for utilities) they allowed me to send a bank statement
• I sent them a Account Confirmation letter from Revolut, which showed all the information which matches up with the bank statement(s) provided before in the email chain
• Currently it is being reviewed by a specialist - which is in my honest opinion, a delaying tactic

It has been over 3 days since the verification was completed, and 22Bet still hasn't responded to me or verified the details. In my opinion this is just delaying my withdrawal in the hopes of getting me to lose my funds before I am able to complete the verification and withdraw my winnings.

Toaday on the 5th of July their security team asked for a copy of my Drivers License which is highly irregular as they already have enough data to verify my identity (Drivers License, Bank Statements, Payment Receipts). In my opinion this is a delaying tactic to get me to gamble away my funds.

I've told the security team that I'm refusing to provide them a copy of my drivers license due to security concerns, since all of the discussion is happening via email, and to a seemingly shared inbox (that is monitored by multiple "security team" members), which increases the risks of copies of my ID and other personal data being leaked, if for example one of the team members is targeted thru a phishing / hacking campaign.

It has now been over 10 days since I originally requested my withdrawal - This "delay" is excessive and I'm fairly sure is illegal under Curacao, Estonian & Canadian Law (Since seemingly the company holds licenses in all the 3 jurisdictions).

I have provided the casino a copy of my ID on the 6th of July but also requested details about where and how my verification data is stored.

Its apparently going to a specialist and no response about the Data Protection 😕

Thank you for your response. Have you received any communication indicating the status of your latest document submission? Additionally, could you kindly confirm if you have submitted your driver's license in accordance with the casino's instructions?

Thank you in advance for your reply.

I've submitted my Drivers License & other documents following their guidelines but I still haven't received a response from their security team.

I just followed up but they usually takes ages to reply

Now their security team is asking for my Passport after following up.

This is starting to feel very very weird, and a overreach of the KYC process, since it doesn't really make sense why would you need a copy of my Passport, National ID Card & Drivers License to successfully verify my Identity.

I dont feel comfortable with sharing my passport, since I've already shared my National ID Card & my Drivers License, which should be enough for verifying my identity? Since at this point I feel like their security team is trying to overreach and to try to steal my identity since they're avoiding questions regarding data privacy.

Can you please try to get a 22Bet representative here to explain why they're now demanding a copy of my passport, and why is it required when they've already verified my identity via:

• National ID Card
• Drivers License
• Pictures showing my National ID Card + Laptop with 22Bet Opened
• Bank Statements from 2 different banks (OP & Revolut)
• Bank Confirmation Letter (Revolut)
• Bank Transfer Receipts (from OP/Revolut due to depositting via Zimpler)

Overall, this is just a delaying tactic over €375, this isn't a "Big Win" of over €10,000. I've never had such overreach before from a casino.

I also want that the 22Bet's team here on Casino.Guru responds to my concerns over data-privacy.

Since the KYC process is being done via email, which is inherintly insecure - Can the 22Bet team explain to me what is being done to protect my data after its been sent to your security department that you seemingly share with other whitelabel casinos that run the same software.

How can I be sure that my data doesn't fall into the hands of identity thiefes or get sold on dark-web marketplaces after submitting it to your shared "security" department?

Alongside this I want to point out the unprofessional behaviour of the seemingly outsourced "security department"

After I asked for a reason as to why they're asking for a copy of my passport I was provided with this copy & paste response:

"The Company’s management is entitled to request at their discretion any documents from the bettor substantiating their identity or other data they have provided (for example, passport details, residential address), as well as to cancel any payments until all such details have been verified. The Company also reserves the right to inform the regulatory bodies and local authorities of such fraudulent actions performed by the player. Verification may take up to 72 hours from the receipt of documents."

Hello not3of,

We would like to update you that due to Attila, your designated resolver, being on vacation, we have opted to extend the timeline by an additional 7 days. Since Attila has an in-depth understanding of your situation and maintains direct communication with the casino, we find this extension justified. Your patience is sincerely appreciated, and I assure you that Attila will contact you at the earliest opportunity.

Thank you for your understanding and ongoing patience.

Best regards, Casino Guru

Hello,

Thank you for your reply. I understand your concerns regarding the amount of documentation requested during the verification process. However, please note that KYC verification is a standard and essential procedure at online casinos, and licensed operators may request additional documents if they deem them necessary to complete the verification.

Regarding your concerns about how the casino stores or processes your personal data, unfortunately, we are unable to handle complaints related to GDPR or data privacy. If you wish to pursue this aspect of your case, we recommend contacting the appropriate data protection authority, as these matters fall outside Casino Guru's scope.

Finally, could you please confirm whether any of the documents or photos you submitted to the casino were edited or altered in any way (for example, cropped, blurred, or otherwise graphically modified)?

Thank you in advance for your reply.

Hey Attila,

The documents that I submitted to the casino were in no way altered, blurry or otherwise "unreadable".

I understand that KYC verification is an essential part of verifying a players identity to comply with the licensing requirements, but at this point the KYC verification is very excessive after the casino has already verified my identity via the 2 pieces of ID that I have submitted to them. I assume you'd agree that it is weird that a casino is asking for a Drivers License, National ID & now a passport to an unencrypted email address seemingly shared with other casinos part of the casino group / software provider.

Best,

[Redacted]

Hello,

Thank you for your reply.

Requesting a passport as part of the KYC process is not unusual, and casinos may ask for additional identity documents if they deem them necessary to complete the verification.

Could you please forward the email in which the casino requested your passport and any other additional documents? You can send it to me at attila.g@casino.guru or attach it here in the complaint thread.

Please also note that if you decide not to provide the documents requested for KYC verification, there will unfortunately be very little we can do to assist you, as the casino is entitled to complete its verification process before processing withdrawals.

Thank you in advance for your cooperation.

Hey Attila,

The casino requested documents from security@22bet.com, which follows the same format as other BetB2B Casinos (such as 1XBet/Spinbetter/etc) leading me to believe the department is shared or outsourced to them.

Requesting a passport as part of the KYC process is not unusual, and casinos may ask for additional identity documents if they deem them necessary to complete the verification.

I do understand the need for verificiation but dont you agree this is very unsual, why would a casino ask for a passport after receiving and accepting 2 valid forms of ID? They didn't reject the copies of the drivers license or national ID card.

I'd be happy to send the passport over if I can for example add a watermark or use masking tape to remove parts of the MRZ since that would make the passport useless if the data ended up getting leaked. I think that would be a fair compromise for both as long as it is the last document needed to release my funds

I've sent you the full email chain where they keep requesting more documents over & over.

Hello,

Thank you for your cooperation and for providing all the necessary information. I truly appreciate the time and effort you’ve taken to share everything with us so far.

Your complaint will now move to the next stage of our process and be handled by your dedicated Resolver, Michal (michal.k@casino.guru). This is a standard step in our procedure, as the Resolver will take over communication with the casino directly and manage your case from this point onward.

No action is required from you right now. Your Resolver will reach out through this thread if any additional details are needed. You can rest assured that your case is in very capable hands.

I wish you the best of luck and hope your case will be resolved to your satisfaction soon.

Kind regards,

Attila

Hello not3of,

I'm Michal, and I have taken over your complaint. I have reviewed this case, and I will contact the casino to shed more light on this matter and to see if I can help somehow.

We would like to invite 22bet Casino to join the conversation.

Dear 22bet Casino,

We would be grateful for your help in clarifying the current status of the player's verification process. The player already provided various documents for the verification process, and I am eager to know the reasons behind the delay and the reasons why the player's withdrawal has not been processed yet.

If there are any other considerations affecting this situation that cannot be disclosed publicly, please do not hesitate to reach out to me directly at michal.k@casino.guru.

Dear not3of,

Your account has been referred for an additional review by our Security Department. At this stage, we kindly ask you to wait for their response.

You will be informed directly once the review is completed. Thank you for your patience and understanding.

Dear 22Bet representative,

Can you please give me an estimated timeline of the additional review? I haven't been contacted by the security team nor have received any emails from them.

Dear not3of,

Our colleagues requested the required document from you on July 9, but it has still not been provided. Please check the message you received from the relevant team and submit the document exactly as requested. Once it is received, our colleagues will be able to continue reviewing your case.

Thank you for your cooperation.

Dear 22Bet representative,

Have you read the thread before you were asked to join by Michal? I've already stated that I feel uncomfortable with providing more documents to your team due to the fact that:

• I have already provided your team with 2 VALID pieces of Identification (National ID Card & Drivers License), which you have already used to verify my identity
• Your security team has ignored my valid questions regarding how long will my data be kept and other valid data protection questions.

Earlier in the thread, I have already proposed a compromise that I think would be fair for both of us, which I think you skipped over?

As a reference, here is the compromise that I've already offered that I think would be fair to both parties:

I'd be happy to send the passport over if I can for example add a watermark or use masking tape to remove parts of the MRZ since that would make the passport useless if the data ended up getting leaked. I think that would be a fair compromise for both as long as it is the last document needed to release my funds

If you can confirm with your security department that I can cover certain parts of the MRZ with masking tape / cut up post-it notes, in-order to protect my privacy in the case that thedocument is improperly handled by your 3rd-party outsourced security team and that the passport is the last document needed, in-order for my €375 withdrawal to be paid out, I will happily submit it to them with certain parts of the MRZ covered.

If you are unfamiliar with the "MRZ" zone of an passport, below is an attached copy of an sample german passport, with the MRZ zone highlighted.

We would like to ask the casino to reply to this complaint. We are extending the timer by 7 days. If the casino fails to respond in the set time frame, we will close the complaint as ‘unresolved’ which may negatively affect its rating.

Dear not3of,

We would like to clarify that the MRZ is not an optional or irrelevant part of a passport. It is the machine-readable section of the document and forms an integral part of the information used during identity and document verification.

For this reason, a passport with the MRZ covered, a watermark placed over the document details, or any other intentional alteration cannot be accepted for verification. The requested document must be provided in full, clearly visible, and without editing or concealed information.

Identity verification is a standard and mandatory security procedure carried out in accordance with KYC/AML requirements, including measures aimed at preventing fraud and money laundering.

The possibility of requesting additional verification documents is also provided for in our Terms and Conditions, which the player accepts upon registration.

We therefore kindly ask you to provide the passport exactly as requested by our Security Department so that the verification process can continue.

Dear 22Bet representative,

You still haven't answered my questions about if the passport is the last document needed. You have in my eyes already verified my identity, under both Curacao, Estonian and Canadian law (since you're seemingly operating under those 3 licenses), and requesting a passport after 2 valid forms of ID is concerning in terms of data privacy.

How am I supposed to trust that my data is kept secure & private, when the verification process is being done via email, and when your security team has refused to disclose, how my data is kept secure during the verification process?

The reason I wanted to compromise with you regarding covering parts of the MRZ, was to make sure if my data ended up getting stolen, due to for example bad data security practices from your outsourced 3rd-party security team, the passport would be useless for the fraudsters. Since as you can imagine a hacked email server that contains all verification documents would be a goldmine for hackers.

I'm willing to provide my passport as long as:

• You point to a part of your privacy policy, where you state how documents are handled and how long they're kept after verification
• And that the passport will be the last document needed, in-order to process my withdrawal

Alternatively, I'm willing to join a call with a security team member and present my passport to them in-order to verify my account, if you are unable to point me to a part of your Privacy Policy which states how the documents are handled and how they're kept secure.

In my eyes this is just disingenuous behaviour with verification delays, insanely complicated demands and constant asking of more documents in-order to get most gamblers lose their winnings, instead of being able to withdraw them. I'm disappointed in how you've chosen to handle the process by constantly pushing back on fair compromises that should be enough to allow you to verify my identity, as is required under KYC/AML regulations.

Dear not3of,

Thank you for explaining your concerns. I understand why you may feel uncomfortable providing another identification document, particularly since you have already provided two valid forms of ID and have questions regarding the handling and retention of your personal data.

At the same time, I believe it is important to distinguish between your concerns about the verification process and the casino's right to request additional documentation. Under the Terms and Conditions you accepted when registering, the casino reserves the right to request further documents or information as part of its KYC/AML and security procedures. This is in alignment with the general industry standards. The fact that you have already provided two forms of identification does not necessarily prevent the casino from requesting an additional document if its Security Department considers it necessary.

Ultimately, it is your decision whether you are comfortable providing the requested passport without any editing. However, if you choose not to provide the documentation requested as part of the verification process, the casino team will be unable to complete the verification. In such circumstances, the casino would not be able to proceed with the withdrawal until the required verification has been successfully completed.

I appreciate that you would prefer confirmation that the passport will be the final document required. I can certainly ask the casino to clarify this, although I cannot guarantee that no further verification may be requested if additional concerns arise during the review.

Regarding your concerns about data protection and the handling of your documents, I can also ask the casino to clarify how the documents are handled and retained. However, these concerns would not, by themselves, remove the casino's ability to carry out reasonable KYC/AML checks in accordance with its procedures.

I hope this clarifies the situation and helps you decide how you would like to proceed.

Dear 22Bet representative,

Can you please address the player's concerns?

Hey Michal, I want to address a few points

At the same time, I believe it is important to distinguish between your concerns about the verification process and the casino's right to request additional documentation. Under the Terms and Conditions you accepted when registering, the casino reserves the right to request further documents or information as part of its KYC/AML and security procedures. This is in alignment with the general industry standards. The fact that you have already provided two forms of identification does not necessarily prevent the casino from requesting an additional document if its Security Department considers it necessary.

I do understand that the casino has the right to ask and request additional documentation, but this should be used when the casino can not properly identify the player from the already provided documentation. If this case was brought to a regulator in most cases they would side on the players side if verification was excessive, which it has been in this case.

Under GDPR the casino has to be transparent about how the data is secured, and how long it is kept - this should be a relatively simple task for the casino to disclose and to point out in their privacy policy.

I appreciate that you would prefer confirmation that the passport will be the final document required. I can certainly ask the casino to clarify this, although I cannot guarantee that no further verification may be requested if additional concerns arise during the review.

This should be a relatively simple thing to confirm that the passport is the last document needed (unless other issues arise from the passport submission), but by looking at the almost 2 month verification circus, which is designed to be predatory and to get the player to just lose their money while awaiting for the security team to invent a new document that has to be sent out. If there are other obstacles to paying out my funds or other documents that have to be provided, they should be provided all at once, so I can properly relay them to the security team, alongside the passport.

Regarding your concerns about data protection and the handling of your documents, I can also ask the casino to clarify how the documents are handled and retained. However, these concerns would not, by themselves, remove the casino's ability to carry out reasonable KYC/AML checks in accordance with its procedures.

It should be relatively easy to point out to a part of the privacy policy or to overall explain (as is required under GDPR law) how the documents are handled and retained (eg are they encrypted or not).

As long as 22Bet uphelds their end, in addressing my concerns over both data privacy & making sure that for now the passport is the last document needed in order to pay out my €375 withdrawal, I will upheld my end and complete the verification, and not open a complaint with the 3 regulators, that have provided licenses to 22Bet.

Dear not3of,

Please note that we are not Customer Support or the Security Department and do not personally conduct document verification. The verification process is handled by a dedicated team, and the documents required are determined based on their review.

For this reason, we cannot guarantee in advance that the passport will be the final document requested. If additional information or documents are considered necessary during the review, the Security Department may request them.

As already noted, verification and the possibility of requesting additional documents are provided for in the Terms and Conditions accepted upon registration. This is a standard KYC/AML and security procedure.

Without the documents requested by the Security Department, the verification cannot be completed and we cannot proceed further with the withdrawal.

We therefore kindly ask you to cooperate with the verification team and provide the document exactly as requested.

I think this case is going nowhere, since 22Bet is overall refusing to cooperate or even answer my concerns, since in this case:

• 22Bet is refusing to answer or even confirm that for now the passport is the last document needed
• 22Bet is refusing to point out to a part of their privacy policy, regarding how my documents are handled

Refusing to answer and cooperate, even on the minor issues such as data protection, shows the lack of care from the casino and doesn't properly address my concerns over identity theft, since by refusing to answer a very simple question, the casino doesnt know how verification documents in general are handled or retained.

I think in this case since it is very clear that the 22Bet presentatives are refusing to cooperate, since it is very clear that they are not talking internally with their security team or with the proper departments to address my concerns.

Refusing to even address my data protection question leads me to believe that my verification documents are at risk of getting leaked, since seemingly the documents are being processed & handled improperly.

This behaviour is really sketchy and against fair gambling. I think it would be better to move the case to the regulators alongside with the DPO, since its seemingly very clear that TechSolutions/22Bet doesnt care about their players or following the law in terms of making sure their processes are secure.

Thank you all for your responses.

Dear not3of,

I am starting to feel that, rather than appropriately cooperating with the casino's verification process, you are focusing on finding reasons to avoid providing the documents requested by the casino's Security Department for the purposes of KYC/AML verification.

As I have already explained, under the Terms and Conditions you accepted when registering, the casino reserves the right to request additional documents or information as part of its KYC/AML and security procedures. This is also in line with general industry standards. The fact that you have already provided two forms of identification does not necessarily prevent the casino from requesting an additional document if its Security Department considers it necessary.

You are certainly entitled to consider the casino's request excessive. However, based on the information available to me, I do not agree with that assessment. The documents requested appear to be standard documents that may reasonably be requested as part of a KYC/AML or security verification.

You are, of course, free to pursue the matter with the casino's licensing authority or another relevant authority if you genuinely believe that the casino's requirements are unjustified. However, from the perspective of an independent dispute mediator reviewing this complaint, the situation is relatively clear: the casino has requested additional documentation as part of its verification process, and the verification can proceed only once you provide the requested documents. The longer you delay providing the documents, the longer it will take to complete the verification process.

Regarding your question about how your documents are handled, have you reviewed the casino's Privacy Policy? The casino's Privacy Policy provides information how personal information and documents are handled and processed. If you have concerns after reviewing it, please specify exactly which part remains unclear to you and why it prevents you from appropriately cooperating with the verification process.

You can refer to the casino's Privacy Policy here: Terms and Conditions and Game Rules - 22Bet

If there is a specific provision or aspect of the casino's Privacy Policy that remains unclear to you, please point it out to the casino's support team at support-en@22bet.com. The relevant team should be able to provide you with the appropriate clarification.

That being said, please clearly confirm whether you intend to provide the requested documents for verification and, if so, when you expect to do so.

Please note that while you are certainly entitled to have concerns or reservations regarding the casino's Privacy Policy or the way your personal data is handled, such concerns do not affect the casino's request for the documents required to complete the verification process. They also cannot, on their own, constitute a reason for keeping this complaint open indefinitely.

If you believe that the casino's data-handling practices or Privacy Policy do not comply with the applicable data-protection requirements, this is a matter that should be addressed through the appropriate data-protection or regulatory channels. Our complaint forum is intended to address disputes concerning gambling-related issues and is not the appropriate platform for resolving data-protection or privacy-related disputes.

For the purposes of this complaint, therefore, we need your clear confirmation as to whether you are willing to cooperate with the requested verification and provide the necessary documents or not.

I look forward to your clear response.

Dear Michal, I feel offended by your baseless accusations.

I've been cooperative in the process but in my eyes you're not taking your own fair gambling codex seriously when the casino is refusing to answer very simple questions.

I am starting to feel that, rather than appropriately cooperating with the casino's verification process, you are focusing on finding reasons to avoid providing the documents requested by the casino's Security Department for the purposes of KYC/AML verification.

The KYC/AML review for now has been a invasive process to get me to gamble away my funds, while blocking my withdrawals, by adding new requirements and finding issues with all documents.

I've offered fair compromises to the casino multiple times, since their team is overall refusing to address my concerns properly. Sending all my documents such as a Passport, ID card & Drivers license isnt even a thing that a bank would do for KYC/AML. As I've said multiple times, as long as the casino properly confirms that the passport is the last document needed for the KYC process and that the data is kept private, nowhere in their privacy policy is it stated how the data is kept private.

I'm willing to provide the passport as long as 22Bet is willing to confirm in writing that:

1. The passport is currently the only document needed
2. The data is kept secure via the means of encryption or other similar methods

As long as those 2 things have been confirmed, I will provide the copy of the passport directly to the security team and not move the casino to the regulator.

Dear not3of,

As I previously mentioned, I understand that you have concerns regarding both the verification process and the handling of your personal data. However, I believe some clarification is necessary, as the discussion appears to be shifting away from the core issue of the complaint.

First, have you reviewed the casino's Privacy Policy in full? I previously provided you with the relevant link. If you have reviewed it and believe that it does not adequately address the handling, retention, or security of your documents, please identify the specific part that you consider insufficient and explain what information you believe is missing.

Afterwards, forward your concerns to the casino team, and the relevant department should answer your questions.

You have also referred several times to GDPR and other applicable laws and regulations and stated that the casino's conduct is concerning from a data-protection perspective. Could you please clarify which specific legal or regulatory requirement you believe the casino is failing to comply with and why you consider the current verification request to be inconsistent with that requirement?

General concerns regarding data security or the possibility of a data breach, without any evidence of an actual security issue, do not establish that the casino's handling of your documents is or will be improper.

Not answering your questions does not change the contractual fact.

22 Bet just like any other casino cannot reasonably guarantee in advance that no additional information or evidence could ever be required if something further arises during the review. You, like any other player, accepted the casino's Terms and Conditions upon registration, including the provisions allowing the casino to request additional documentation as part of its KYC/AML and security procedures. It is therefore your responsibility to cooperate with reasonable verification requirements imposed under those terms. You may not like this requirement, but it is a standard practice within the industry, and, as mentioned, you accepted the casino's Terms and Conditions. We cannot hold it against the casino for following its own Terms and Conditions and standard industry practices.

I would also note that, given your previous experience with various online casinos, one could reasonably expect that you are already familiar with the fact that additional verification documents may be requested when a casino's Security or Verification Department considers them necessary as part of its standard procedures. This is one of the reasons why I am starting to feel that, rather than simply cooperating with the verification process—which could potentially have been completed by now had you provided the requested passport—you are instead focusing on finding reasons not to provide the latest document requested by the casino's Security Department.

For this reason, I do not consider my previous statement to have been baseless or inconsistent with the facts available to me. You have repeatedly made your cooperation conditional upon the casino first accepting conditions that you have proposed, including guaranteeing that no further documents will be requested and providing specific assurances regarding the technical security of your documents. I am not sure on what basis you believe that you can determine which documents the casino should accept or require and which documents should be considered sufficient for its verification purposes.

Regarding the verification itself, the casino has requested a passport as part of its KYC/security procedures. It is not reasonable to require the casino to guarantee in advance that no further information could ever be requested, as additional verification may become necessary if new concerns arise during the review.

Please clearly specify how this is not in alignment with the industry standard regulations or our fair gambling codex, if you truly believe it is.

You are certainly entitled to pursue any data-protection concerns through the appropriate regulatory or data-protection channels. However, such concerns do not, in themselves, remove the requirement to cooperate with a legitimate verification request, and our complaint forum is not the appropriate platform for determining whether the casino's data-processing practices comply with applicable data-protection legislation.

Please therefore clarify the specific points above.

It certainly is not my intention to exchange lengthy responses with you. As I previously mentioned, from the perspective of an independent dispute mediator reviewing this complaint, the situation is relatively clear: the casino has requested additional documentation as part of its verification process, and the verification can proceed only once you provide the requested documents. The longer you delay providing the documents, the longer it will take to complete the verification process.

Therefore, I kindly ask you to clearly confirm whether you are willing to provide the requested document to the casino's Security Department without further delay.

If you confirm that you are willing to provide it, I will continue pursuing the matter with the casino. If you are not willing to provide the requested document without your conditions, I will proceed with closing the complaint, as the verification cannot move forward without your adequate cooperation.

Hey Michal,

Yes I have reviewed it in full and in multiple ways they state that they are unable to guarantee that the data is kept secure. In 18.11 the casino admits that all data sent to them is at my own risk since they are unable to guarantee that the data will be kept secure

Therefore, please be warned that you SEND ANY DATA AT YOUR OWN RISK. Once your data is received, 22bet has appropriate procedures and methods in place to ensure its security.

We also make every possible effort to ensure that adequate security measures are taken by our affiliates, subsidiaries, agents, suppliers etc. However, you should be aware that sending information over the internet is by definition never totally secure, and as a result we are unable to guarantee the security of your data when transferring it.

The reason I've been trying to find a good middle-ground for both parties since a passport leak, can be way more catastrophic than a ID Card or a Drivers License getting leaked, since for example in many jurisdictions a scan of the passport is the only thing needed to open up an bank account remotely, or to get a loan, or overall do things that could ruin your life.

If or example a cybercriminal got your passport Michal, they could easily start using it to open up bank accounts, take out loans, and doing other things that would cause you harm and damage in the future. You obviously wouldn't want that to happen to you, but this is a risk you're apparently wanting me to accept when a casino multiple times states in their privacy policy that all data sent to them is at our own risk and that they are unable to guarantee the security of the data?

I've stated multiple times in this thread that I'm willing to complete the KYC process till the end and send them a copy of my passport (as requested). My position hasn't changed, I'm willing to provide a copy of my passport (as requested) but you need to understand my point when as far as I understand that the casino is stating that they cant guarantee the security of my KYC data.

Dear not3of,

I acknowledge your concerns, and I do not consider the questions you have raised regarding the handling of your personal data or the possibility of further verification to be unreasonable in themselves. It is understandable that you would prefer to know how your documents are handled.

However, I believe we need to distinguish between these concerns and the actual issue preventing the verification from progressing.

The casino's Security Department has requested a passport as part of its usual verification process. Whether you consider this request excessive or whether you would prefer the casino to provide additional assurances regarding data security does not, in itself, remove the requirement to cooperate with a legitimate verification request.

Similarly, neither you nor we can require the casino to guarantee in advance that the passport will be the final document required. The verification is conducted by the casino's Security Department, and if additional concerns arise during the review of the passport or other information, it may reasonably request further documentation.

Regarding your data-protection concerns and the casino's privacy policy, you have pointed out that the casino states that data is sent at your own risk and that they cannot guarantee security.

I understand your point, and I agree that such wording is not particularly reassuring. However, I would also note that this type of disclaimer is standard across the industry and is not unique to 22Bet. Its purpose is to acknowledge the inherent risks associated with transmitting information over the internet; it should not, by itself, be interpreted as an admission that the casino has inadequate internal security measures.

I understand that you would like the casino to provide specific information regarding encryption, retention, and the handling of your documents. However, these are matters concerning the casino's data-processing practices and compliance with applicable data-protection legislation. Our complaint forum is not the appropriate platform for determining whether the casino's data-processing practices comply with GDPR or other applicable privacy legislation. If you believe that the casino has failed to meet its data-protection obligations, you are entitled to pursue that matter with the casino's Data Protection Officer or the competent data-protection authority.

I also cannot agree with the conclusion that the casino's failure to provide the specific assurances you have requested means that your documents are being handled improperly or are at an imminent risk of being leaked. There is simply no evidence available to me that would support such a conclusion. The absence of a specific assurance regarding encryption or retention does not, in itself, demonstrate that appropriate security measures are not in place.

22Bet is a licensed operator and, as such, is expected to comply with the applicable regulatory and data-protection requirements governing its operations. While this does not mean that a potential data breach is impossible, there is no basis in the evidence available to me to assume that your documents are or will be handled improperly.

Therefore, while I do not consider your questions or concerns unreasonable in principle, I do not believe that receiving satisfactory answers to those questions can reasonably be made a precondition for complying with the casino's verification request.

Furthermore, you accepted the casino's Terms and Conditions upon registration, including the provisions allowing the casino to request additional documentation as part of its KYC/AML and security procedures. Unless there is evidence that the requested verification is unreasonable, disproportionate, or otherwise contrary to applicable requirements, which it isn't, you are expected to fully cooperate with those verification procedures.

At this stage, I believe we are going in circles. The casino has requested a passport, and you have not provided it; thus, the verification remains incomplete.

Therefore, kindly confirm whether you will provide the requested passport without further delay. If you provide it without delay, I will continue pursuing the matter with the casino and will ask them to proceed with the verification as soon as possible. If you are not willing to provide it unless your conditions are accepted, I will respect that; however, I will have to close the complaint, as there is no further action we can reasonably take while the verification remains blocked by your refusal to provide the requested document.

As I mentioned previously, you may not like this requirement, but it is a standard practice within the industry, and, as mentioned, you accepted the casino's Terms and Conditions. We cannot hold it against the casino for following its own Terms and Conditions and standard industry practices.

You remain free to pursue your data-protection concerns separately through the appropriate channels, but those concerns cannot be used as a basis for keeping this complaint open.

I hope you understand the distinction between acknowledging your concerns and being able to make those concerns a condition for proceeding with the casino's verification process.

I look forward to your clear response.

Hey Michal,

We've been going in circles because Casino.guru brands itself as a "mediation" service, for casinos & players, you've been overall refusing to hear out legitimate concerns over the protection of the data, as we both know licensing means one thing and data security means a another thing. Most of the time casinos are self-auditing their whitelabel software providers and whom they're getting their "Security" services from. I'll be opening a complaint with the relevant authorities after this whole case, since as far as Estonian & Canadian law the AML/KYC process overall has been designed in a predatory manner.

Regarding the issue if the passport was the last remaining document.

Similarly, neither you nor we can require the casino to guarantee in advance that the passport will be the final document required. The verification is conducted by the casino's Security Department, and if additional concerns arise during the review of the passport or other information, it may reasonably request further documentation.

I assume that your team has read most complaints on your forum against 22Bet? Most of the cases are about verification and the overall predatory, way of asking a document and then asking for a another, to keep the player going in circles. It is relatively easy for the casino to confirm that the passport is the last document needed for now - Even if additional concerns arise, they should be relatively easy to handle, for now means that currently the passport is the only document needed.

I've sent the casinos security team the passport so we can keep this case open - I'm going to be closing my 22Bet account after this whole fiasco is over, and relaying the relevant details of to the licensing authorities & the DPO so they can decide afterwards if the behaviour has been predatory/over-reaching or not.

Dear not3of,

Casino Guru was, is, and will remain an independent source of information about online casinos and casino games, as well as an independent mediator in resolving disputes between players and casinos. We are not controlled by or acting on behalf of any gambling operator.

As anyone following this complaint can see, your concerns have been heard and considered, and I have already explained our position regarding the issues you have raised.

You may not agree with our position, which you are of course entitled to do. However, I believe I have explained the reasoning behind our position, the general industry practice in situations of this nature, and the options available to you should you wish to pursue the matter further.

I will continue handling your complaint, just as we handle all other cases, in accordance with our complaint resolution policy, How We Resolve Casino Complaints and Why | Casino Guru, and our Casino Guru's Fair Gambling Codex | Casino Guru. These documents outline our approach to complaint resolution, as well as the expected standards and responsibilities of both casinos and players.

If you believe that another dispute-resolution service or relevant authority would be better suited to addressing your concerns, you are, of course, free to pursue that option as well. I will nevertheless continue to assess your complaint independently and objectively based on the available information and evidence.

Regarding your reference to other complaints involving 22Bet, each complaint must be assessed individually based on its specific circumstances and the evidence available. Given the large number of customers served by an operator of this size, it is inevitable that some players may encounter some difficulties or perhaps disagreements during the verification process. However, other complaints do not, by themselves, establish that the same approach has been taken in your case or that the document requests made to you were excessive or improper.

This being said, since, as you mentioned, you have now provided your passport to the casino team, I will continue to oversee this matter.

I hope that we will be able to see a positive outcome soon.

Dear 22Bet Casino Team,

We look forward to your timely review of the player's documents and hope that the KYC/AML verification process can be concluded successfully.

Hello,

An additional document was requested from the player on August 23, but we have not received it yet.

Dear  not3of, please cooperate with our verification team and provide the documents requested from you so the review can proceed.

Hey, I asked for clarification from your team since the message was a bit unclear, I've sent your security team what as far as I understood was requested.

I asked for clarification on this step

Please make a selfie with a sheet of paper with the current date and code XXXXX written on it. Your face and all data should be clearly and fully visible.

By sending this message:

Hello, I want to ask for clarification, do you want me to send the following details: Holding Passport & Paper with current date & XXXX. I'm currently away from home, so I'll send the documents as soon as I return on Wednesday.

But your team replied very rudely:

The Security Department is waiting for the requested files. Without providing the requested files, any further actions are impossible.

And refused to clarify on what was exactly required.

I've sent them what I understood was required but you have to understand that if your security team does not want to clarify what they're requesting, providing documents will become almost impossible

Casino has sent out my withdrawal - though the security teams behaviour has been really really unprofessional and downright predatory.

We'd like to inform everyone following this case that the player has marked this complaint as resolved using the dedicated button.

Dear not3of,

We are pleased to hear that your issue has been resolved. We will mark the complaint as 'Resolved' in our system. Thank you for your cooperation and confirmation. If you experience any future issues with this or any other casino, please don’t hesitate to reach out to our Complaint Resolution Center. We are here to assist you.

As always, our services are free of charge, and we do not accept any gratuities. However, we would greatly appreciate it if you could take a moment to share your experience with our services on Trustpilot: https://trustpilot.com/evaluate/casino.guru. Your honest review, along with any suggestions for improvement, would be incredibly valuable. It can also help others who are considering contacting us for assistance with online casino-related matters.

Thank you in advance for your time and feedback.

Best regards,

Michal

Casino Guru