| 01Legal operator identity | DocumentedThe terms footer names Twocent Technology Limited as the operator of BC.GAME. The footer gives Belize company number 41939 and an address at Sea Urchin Street #2, San Pedro, Ambergris Caye. The licences page, the privacy policy and the AML policy give the same company as number 000041939 at Sea Urchin Street, without the house number. The Anjouan licence register names the same company for bc.game. The pages were read on the official mirror bc.co, which the operator lists at bcgame.com. | DocumentedThe footer and terms clause 1.1 name Novatrix SRL, a Costa Rica company with registration number 3-102-893958. The registered address is in Potrero Cerrado, Oreamuno, Cartago. The terms and the privacy policy also hold a paragraph that names Vixatrix Limited of Cyprus as a payment agent. The page code shows that paragraph only to logged-in users in one user group. The Tobique and Anjouan regulator lists both name Novatrix as a licence holder. |
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| 02Licence and domain coverage | Partial evidenceThe footer, the licences page and the privacy policy state licence ALSI-202410011-FI1 from the Government of the Autonomous Island of Anjouan, Union of Comoros. The public licence register at anjouangaming.com lists the same number for Twocent Technology Limited. The register shows status valid, type B2C, issue date 2024-10-02 and expiry date 2027-10-01. The register row lists bc.game among 12 domains. It does not list bc.co, the mirror that RTP Ledger read. Coverage gaps: licence status. | Partial evidenceThe footer and the Tobique version of the terms state licence No. 0000002 from the Tobique Gaming Commission. The commission's list shows Novatrix S.R.L with a B2C licence that expires on 2027-03-13. The terms shown to Canada, India and Zimbabwe state Anjouan licence ALSI-202508056-FI2 instead. The Anjouan register lists that licence as valid until 2027-08-24, with luckywins.com among its domains. Coverage gaps: licence status. |
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| 03Country restrictions | DocumentedTerms clause 4.3 bars residents of, and access from, 12 named territories. They are Australia, Austria, France, Germany, the Netherlands, Spain, the Union of the Comoros, the United Kingdom, mainland China, Hong Kong, Macau and the United States. The clause also bars all FATF-blacklisted countries and other jurisdictions that the Anjouan Offshore Financial Authority prohibits. The KYC help article lists unsupported regions for verification. That list adds Brazil as a temporary restriction and does not name China, Hong Kong or Macau. The two published lists do not match. | DocumentedClause 2.4 of the Tobique terms names 30 restricted jurisdictions. The list includes the United States, the United Kingdom, the Netherlands, Ontario and New Brunswick. Clause 2.5 excludes players from Sweden from bonuses, promotions and VIP programmes. Clause 3.1 of the Anjouan terms names a different list of 41 territories. Australia, Germany and Spain are on the Anjouan list but not on the Tobique list. |
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| 04Account journey and closure | DocumentedTerms clause 5.1 allows one personal account for each individual. Registration is an invitation to contract, and acceptance occurs only when the account is created. Clause 4.1 sets a minimum age of 18, or a higher age where the law requires it. The registration page states that the registered email address cannot be changed later. The KYC help article describes two levels. Basic KYC needs a government photo ID and a selfie taken from five angles. Advanced KYC needs a proof of address dated within the last 3 months, but only on request. Review is automated in most cases. A player can resubmit up to 6 times, and some cases go to manual review. The article states that a player who fails KYC can still play, but some currencies need KYC for deposits or withdrawals. The self-exclusion help article states that permanent self-exclusion is also used to close accounts. After a permanent exclusion, the player has a 7-day withdrawal period from the date of notification. The account then becomes inaccessible and any remaining balance is forfeited. Funds with open wagering requirements are forfeited at once. The registration page tells a player who needs a new email address to close the account and open a new one. | Not checkedRegistration, verification stages, account currency and closure journey are not checked. No dated source |
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| 05Payment catalogue | DocumentedThe deposit-confirmation article gives a table of 15 entries: BTC, SATS, ETH, XRP, DOGE, USDT, LTC, BCH, XLM, TRX, BSV, EOS, DAI, USDC and XMR. The article tells USDT senders to use the specific ERC20 or TRC20 address. The deposit guide tells the player to choose the coin and the network in the cashier. XRP, XLM and EOS also need a memo, tag or destination ID. Neither article states that the table is the complete list. | DocumentedTerms clause 4.1 lists 21 accepted currencies, including BTC, ETH, USDT, LTC, XRP, TRX, BNB, ADA and BCH. Clause 10.1 names Visa, Mastercard and other methods such as e-wallets and bank transfers. Clause 10.5 names CoinsPaid for crypto transactions. The payments page lists card and e-wallet methods by licence but has no crypto row. No page checked names a network for any crypto asset. |
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| 06Deposit terms | DocumentedThe deposit-confirmation article states that the minimum deposit differs by cryptocurrency and that support can give the figure. It states that there is no maximum. Deposits take between 1 minute and 2 hours. Deposits from contract wallets can take up to 12 hours. The table asks 1-3 confirmations for BTC, 6 for ETH and USDT, 2 for BCH, 9 for BSV and 6-12 for most other coins. Terms clause 10.5 states that limits normally show before the transaction completes. | DocumentedTerms clause 10.4 sets a minimum deposit of EUR 20 or the equivalent. The maximum depends on the payment method. Clause 10.5 states that crypto deposits through CoinsPaid have no upper limit. Clause 10.3 forbids deposits from accounts in another person's name. Clause 9.7 requires each deposit to be wagered three times before withdrawal. Otherwise the casino can charge a processing fee or refuse the withdrawal. |
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| 07Withdrawal terms | Partial evidenceTerms clause 11.1 makes withdrawals subject to identity verification and promotional conditions. Clause 11.4 allows a delay while the operator reviews fraud or compliance risk. Clause 11.7 allows a withdrawal fee only where it shows before confirmation. The fee guide states a minimum withdrawal fee of 0.1%. The VIP page lists fee-free deposits and withdrawals as a VIP reward. Help articles state a 24-hour withdrawal hold after a password change and after 2FA is disabled. No checked page states a minimum withdrawal amount. RTP Ledger has not observed a withdrawal on bc.game. Processing time and effective fees are not established. Coverage gaps: first-party withdrawal processing observation. | Partial evidenceTerms clause 11.1 sets a minimum withdrawal of EUR 20, or the crypto equivalent. Clause 11.6 aims to process withdrawals within 72 hours of approval. Clause 11.7 limits withdrawals to EUR 7,500 per rolling 7 days and EUR 15,000 per month. Progressive jackpot wins do not count toward these limits. Clause 11.10 warns that intermediary banks can charge fees on bank transfers, typically up to EUR 16. RTP Ledger has not observed a withdrawal on luckywins.com. Actual processing time and effective fees are not established. Coverage gaps: published crypto withdrawal rules, first-party withdrawal processing observation. |
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| 08Bonus terms | Partial evidenceThe Monthly 4 Deposit Bonus article lists four stages in a fixed order. They are 180% from a $5.00 deposit, 240% from $10.00, 300% from $20.00 and 360% from $30.00. The bonus goes to locked rakeback. It unlocks into withdrawable cash as the player wagers on non-PvP games. The stages reset on the 1st of each month at 00:00 UTC. The article does not state the unlock rate, a maximum bonus amount or an expiry. Terms clause 12.2 states that each promotion can carry its own rules. Coverage gaps: bonus eligibility and expiry. | DocumentedThe bonus terms offer two first-deposit packages. A deposit of EUR 20 or more gets 100% up to EUR 1,000 plus 100 free spins. A deposit of EUR 100 or more gets 150% up to EUR 1,500, 100 free spins and 7 days of 5% daily cashback. The bonus and free-spin winnings carry 40 times wagering. Bonus winnings are capped at 5 times the bonus. The maximum bet with an active bonus is EUR 5 or USD 5. The bonus terms allow one offer per person, family, home address, email, IP address, payment account and device. Terms clause 2.5 excludes players from Sweden from bonuses. The first-deposit free spins and their winnings expire after 7 days. A player can cancel a bonus without loss of their own funds. |
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| 09KYC and source-of-funds process | Partial evidenceTerms clause 5.3 allows document requests at any time, including before deposits or withdrawals. Clause 6.2 lists photo ID, proof of address, payment-method and wallet ownership, a selfie, source of funds and source of wealth. Clause 6.7 allows delayed withdrawals and a suspended account if the player does not complete verification. The KYC help article states that some currencies need KYC for deposits or withdrawals. No checked page states a withdrawal amount that triggers verification. RTP Ledger has not run a test account on bc.game. The stage where verification is requested in practice is not established. Coverage gaps: observed KYC trigger and stage. | Partial evidenceTerms clause 18.4 requires verification by the earliest of three points. These are 30 days after the first deposit, EUR 2,000 in deposits or own-funds wagers, or the first payout. Clause 2.7 requires a valid ID before a player plays with BTC. Clause 9.5 lists photo ID, proof of address and payment-method proof. Clauses 8.4 and 9.3 allow a phone call as part of verification. The KYC-AML policy allows up to 30 working days for document review. RTP Ledger has not run a test account on luckywins.com. The stage where verification is requested in practice is not established. Coverage gaps: observed KYC trigger and stage. |
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| 10Responsible-gambling controls | DocumentedThe gambling limits page offers loss or wagering limits over a daily, weekly, monthly or quarterly period. Active limits reset at 00:00 UTC at the end of each period. Removing a limit takes effect at 00:00 UTC after a cooling-off period of at least 24 hours. Terms clause 16.4 also names deposit limits, session reminders and cooling-off periods where the platform supports them. The self-exclusion page and help article describe a 24-hour cooldown first. The player then chooses 1 day, 1 week, 1 month, 6 months or a permanent exclusion. Both pages state that self-exclusion cannot be reversed. A self-excluded player can still log in to withdraw. Discrepancy: the responsible gambling FAQ states that self-exclusion locks the account for a minimum of 6 months. The same FAQ offers a 7-day cooling-off period. This claim record states both and does not resolve the difference. | DocumentedThe responsible gaming page offers deposit, loss and wager limits per day, week or month. A lower limit applies at once. A higher limit needs email confirmation and starts only after the old limit expires. The page warns that deposit limits cannot always apply to crypto deposits. The responsible gaming page offers cooling-off for 1 week, 1 month, 3 months or 6 months. Self-exclusion runs for 6 months, 9 months, 1 year or indefinitely. Both periods block fiat deposits and promotions. The page warns that some crypto deposits can still go through during either period. |
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| 11RTP Ledger cashout test | Partial evidenceRTP Ledger has not withdrawn funds from a bc.game test account. Cashout speed and fees are not observed. Coverage gaps: first-party cashout test. No dated source | Partial evidenceRTP Ledger has not withdrawn funds from a luckywins.com test account. Cashout speed and fees are not observed. Coverage gaps: first-party cashout test. No dated source |
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| 12Complaint handling | Partial evidenceTerms clause 20.1 tells players to contact customer support first. Clause 20.2 allows escalation for internal review. Clause 20.5 allows confidential arbitration under rules that the company specifies, where the law permits. The terms do not name an external dispute body or a response deadline. Coverage gaps: attributable complaint cases. | Partial evidenceTerms clause 15.1 sends complaints to the support team first, with internal escalation. Clause 15.5 names EGIS, which operates under Tobique Gaming Commission rules, as the ADR body. Disputes go to disputes@egis-adr.com. Clause 13 bars claims filed more than one year after they arose. Clause 17 sends disputes to arbitration in Costa Rica. Coverage gaps: attributable complaint cases. |
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| 13Ownership and related brands | Partial evidenceThe Anjouan register row for Twocent Technology Limited lists 12 domains under one licence, including hash.game, bc.fun, bcpoker.com and blaze.game. The licences page names two more brands under other companies and other licences. BlockDance Africa Limited runs bcbet.ng under a Nigerian permit. PRODUCCIONES MOVILES S.A DE C.V. runs bcgame.mx under a Mexican permit, and PUBLIPLAY MEXICO, S.A. of C.V. manages it. The privacy policy mentions affiliated companies within a BC.GAME corporate group. No checked page names a parent company. Coverage gaps: parent/legal-group relationship. | Partial evidenceThe Anjouan register lists 64 domains under the Novatrix SRL licence ALSI-202508056-FI2. The domains include luckywins.com, casinonic.com, woocasino.com and kingbillycasino.com. The Tobique list shows two Novatrix S.R.L licences, one B2C and one B2B. Neither list names a parent company. luckywins.net serves a WordPress page titled "LuckyWins Australia Casino". Its footer links Terms and Conditions, Privacy Policy, Responsible Gaming, FAQ and Support to www.luckywins.com. The page names no operator company and no licence number. RTP Ledger has not established who publishes luckywins.net. Coverage gaps: parent/legal-group relationship, related-brand relationship. |
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| 14Game catalogue and RTP evidence | Partial evidenceThe provably fair page gives a worked Crash calculation that sets a 1% house edge. The responsible gambling FAQ states that all games have an RTP and a house edge. No checked page publishes an RTP figure for each game. RTP Ledger records the catalogue fields as unknown. Coverage gaps: published game RTP values. | Not checkedCasino-specific game availability and deployed RTP evidence are not checked. No dated source |
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| 15Fairness and verification | Partial evidenceThe provably fair page states that BC.GAME generated 10 million hashes for Crash and releases them in reverse order. Each hash maps to one Crash multiplier, so each result exists before the round starts. The page shows how to turn a hash into a multiplier with a 1% house edge. It links to a verification script on GitHub. The checked section covers Crash only. RTP Ledger has not reproduced a BC.GAME Crash round with the published method. Independent confirmation of a real result is not established. Coverage gaps: reproduced account-bet verification. | Partial evidenceThe FAQ states that iTech Labs, a testing laboratory, certified the casino software. The FAQ states that the random number generator meets industry requirements. No page checked links or quotes a certificate. Coverage gaps: published fairness algorithm, reproduced account-bet verification. Checked Oct 24, 2026LuckyWins FAQ ↗ |
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| 16Account and withdrawal security | Partial evidenceThe 2FA help article explains how to enable authenticator-app 2FA after email or phone verification. The Google Authenticator page states that an enabled 2FA code is required at each login and each withdrawal. The 2FA article states that withdrawals are disabled for 24 hours after 2FA is disabled. Terms clause 7.2 recommends multi-factor authentication where available. The password-change article states that withdrawals stop for 24 hours after any password change. Terms clause 7.3 asks the player to report a suspected compromise without delay. The same clause lets the operator suspend access while it completes security and identity checks. Coverage gaps: withdrawal re-verification. | Partial evidenceThe privacy policy states that the account opens only with the player ID and password. The privacy policy also states that the player can turn on two-factor authentication (2FA). Coverage gaps: withdrawal re-verification, recovery and session controls. |
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| 17Support and escalation | Partial evidenceThe support page states that a 24-hour online customer support team is available at any time. The licences page gives compliance@bcgame.com for legal and compliance questions. Terms clause 20.1 sends complaints to customer support first. RTP Ledger has not timed a support request on bc.game. Response times are not established. Coverage gaps: timestamped support-response test. | Partial evidenceThe support page gives support@luckywins.com and states that the support team works 24/7. The responsible gaming page names LiveChat and the same email address as contact routes. RTP Ledger has not timed a support request on luckywins.com. Response times are not established. Coverage gaps: timestamped support-response test. |
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| 18Product and user experience | Not checkedProduct catalogue, devices and observed usability defects are not checked. No dated source | Not checkedProduct catalogue, devices and observed usability defects are not checked. No dated source |
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| 19VIP and loyalty mechanics | Partial evidenceThe VIP level article lists seven tiers: Beginner, Bronze, Silver, Gold, Platinum, Diamond and Eternal. Each tier has levels I to X. XP comes from valid bets on non-PvP games. Each level gives a level-up reward with no expiry. The VIP Club page lists lossback, reloads, fee-free deposits and withdrawals and a VIP host. The page states no rate or threshold for those perks. Coverage gaps: effective VIP value and expiry. | Partial evidenceThe loyalty page data lists ten levels from 0 to 500,000 status points. Weekly cashback starts at the fifth level at 5% with 15 times wagering. The top level lists 25% weekly cashback with 1 times wagering. The level terms credit cashback every Thursday at 06:00 UTC. The maximum win from weekly cashback is EUR 5,000. Coverage gaps: effective VIP value and expiry. |
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| 20Privacy and data rights | DocumentedThe privacy policy names Twocent Technology Limited as the company that processes personal data. Section 2 lists account, contact, device, financial, location, government ID, usage and fraud-prevention data. Section 4 allows transfers outside the player's country under Standard Contractual Clauses and Data Processing Agreements. Section 9 allows sharing within the BC.GAME corporate group and with service providers. Section 5 of the privacy policy keeps account data while the account is active. It keeps transaction records for up to 7 years and fraud-prevention data for up to 5 years. It keeps marketing preferences until the player opts out. After those periods the data is deleted or anonymised, unless the law requires longer retention. Section 6 of the privacy policy lists a right to erasure when it is legally applicable, plus rights to access, correction, restriction, objection and portability. The policy does not describe a separate deletion request path. The self-exclusion help article states that permanent self-exclusion is used to close accounts. | Partial evidencePrivacy policy section 2 names Novatrix SRL as the data controller. It gives DPO@novatrixsrl.net as the data protection officer contact. Section 9 keeps personal data for at least five years after account closure under anti-money-laundering rules. Erasure requests within that period are not processed. Coverage gaps: privacy policy coverage, data deletion and account closure. |
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