Thank you for your response Jaro, and I understand your reservations. But I want to address something that I think changes the picture significantly, because the argument that "Germany is not a restricted country" does not hold up when you look at the full picture.
20Bet operates under a Curaçao license. That license is not just a piece of paper. It comes with legal obligations under the Landsverordening op de kansspelen, which was enacted in December 2024 and governs all Curaçao-licensed operators. Article 1.4 of that law explicitly prohibits a license holder from allowing a person to participate in gambling if there is reasonable suspicion that this person is a vulnerable person. I am registered in the official German OASIS self-exclusion system, which by definition makes me exactly that, a person who is legally excluded from gambling due to a documented gambling problem. This is not a grey area.
Now look at what 20Bet's own terms say. Section 2 point 3 states that persons who are legally prohibited from entering into contracts with a bookmaker are not allowed to play. I am legally prohibited, both under German law and under the Curaçao licensing framework. Section 2 point 7 states that when they become aware that a player resides in a country where their service is illegal, they must close the account and refund the remaining balance. Germany has no GGL license for 20Bet. They are not on the whitelist. That makes their operation in Germany illegal. They had that knowledge, at the latest, when I submitted my formal complaint on April 25. They did not close the account. They did not refund. They sent a copy-paste response quoting section 2 point 6, which is the clause about the player being responsible for checking local laws.
That response is not only inadequate, it is internally contradictory. You cannot selectively apply your own terms. If section 2 point 6 applies to me, then section 2 point 7 equally applies to them. They chose to cite the clause that protects them and ignored the clause that obligates them.
Section 39 of their terms also states they will not target potentially vulnerable customers. I am not potentially vulnerable. I am officially and verifiably excluded from gambling under a national government system. They continued accepting deposits from me anyway.
The Curaçao gaming law under Article 5.4 also requires license holders to maintain a policy for preventing vulnerable persons from participating in gambling. Under Article 2.2, responsible gambling means guaranteeing that vulnerable persons cannot participate. These are not suggestions. These are conditions of the license. By failing to uphold them, 20Bet is not only violating their own terms but also the legal framework of the jurisdiction they are licensed under.
So to summarize: there is not a single clause in their terms that they can legitimately apply to deny my refund. The clause they cited in their response is contradicted by their own section 7. Every other relevant clause, section 2 point 3, section 2 point 7, section 39, section 41, section 43, either directly obligates them to have prevented my registration or to now provide a refund. Add to that the Curaçao license law obligations under Articles 1.4 and 5.4, and the picture is very clear.
A license condition is not optional. It is not a suggestion that an operator can choose to follow when it suits them. If 20Bet's terms reflect their license obligations, which they clearly do, then they cannot legally invoke the player responsibility clause while simultaneously ignoring the refund obligation clause, the vulnerable person clause, and the responsible gambling clause. You cannot have it both ways. Either the terms apply in full or they do not apply at all.
