| 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 names GG Gaming SRL, registration number 3-102-916906, at Sabana Business Center in San José, Costa Rica. Terms clause 2.1 and privacy policy section 2 name GG Gaming LLC at the same address. The privacy policy gives the same registration number. The About Us page names both GG Gaming LLC and GG Gaming Sociedad de Responsabilidad Limitada. The Tobique licence-holder list names GG Gaming S.R.L. This record notes the different company names and does not resolve them. |
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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 evidenceTerms clause 2.1 and the footer state that GG Gaming is licensed by the Tobique Gaming Commission. The help centre licence article names the Tobique Gaming Act 2023. The commission's licence-holder list names GG Gaming S.R.L with a B2C licence that expires on 2027-05-08. The list shows no licence number and no domain. None of the Winna pages checked publishes a licence number. 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. | DocumentedTerms clause 4.3 names 35 prohibited jurisdictions and states that the list may change. The list includes the United States, the United Kingdom, Germany, Spain, the Netherlands, Ontario and New Brunswick. AML policy clause 24.1 names 21 jurisdictions and omits Germany, Spain, the Netherlands and Ontario. The help centre lists Canada as supported except New Brunswick. That article does not mention the Ontario restriction in the terms. The article also states that access from a restricted region puts the account in withdrawal-only mode. |
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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. | Partial evidencePayment policy clause 2.1 lists the registration fields: email address, country, username and password. Clause 2.2 requires more data before any deposit or withdrawal. The extra fields are full name, residential address, date of birth, gender and a valid phone number. RTP Ledger has not tested this journey with an account. Coverage gaps: observed verification journey, observed account-closure journey. |
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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. | DocumentedThe help centre lists 13 assets for deposits and withdrawals. The networks article lists USDT on Ethereum (ERC-20), TRON (TRC-20), Solana and BNB Smart Chain (BEP-20). It lists USDC on ERC-20, Solana and BEP-20, and DAI and SHFL on ERC-20. The other assets use their own main networks. The About Us page lists "Gram" and does not name Toncoin. About Us also places USDC on TRC-20, a route the networks article does not list. |
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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. | DocumentedThe deposit article states that a deposit is credited after the required blockchain confirmations. It does not give the number of confirmations. Payment policy clause 3.2 states that deposit limits vary by method and jurisdiction, with no figure. Terms clause 8.4 and payment policy clause 4.1 require each deposit to be wagered once before withdrawal. The coins article warns that assets sent on an unsupported chain cannot be recovered. |
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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 8.8 and the withdrawal article set a minimum withdrawal of $20 or the equivalent. Terms clause 8.7 sets a standard limit of $10,000 per 24 hours. A VIP host and the company can raise that limit for higher VIP levels. Terms clause 8.5 allows a processing fee on several withdrawals within 24 hours. The withdrawal article states that blockchain fees appear before the player confirms. RTP Ledger has not observed a withdrawal on winna.com. Actual processing time and effective fees are not established. Coverage gaps: 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. | Partial evidenceThe bonus policy states that the cash balance is used before the bonus balance. Each bonus has a fixed validity period. Terms clause 10.1 states that bonuses carry wagering requirements and a maximum stake. A breach can void the bonus and its winnings. None of the pages checked states a welcome offer amount, match percentage or wagering multiple. The bonus policy gives general rules only. RTP Ledger found no page that states the amount, wagering multiple or expiry of a referral or welcome offer. Coverage gaps: bonus economic terms. |
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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 evidenceAML policy clause 8.2 requires customer due diligence within 30 days of the first deposit. The same clause requires it before the first withdrawal or before EUR 2,000 is wagered. Terms clause 8.5 allows enhanced checks on withdrawals of EUR 2,000 or more. Payment policy clause 5.1 lists photo ID, proof of address and payment-method proof. Clause 5.2 states verification typically takes 72 hours. Clause 5.3 allows a pending withdrawal to be cancelled after 30 days without documents. RTP Ledger has not run a test account on winna.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. | Partial evidenceThe self-exclusion article describes the path through Profile and Winna Cares. The player selects a category and confirms by email. A 24-hour cooldown then starts and cannot be cancelled. Players can also ask for self-exclusion by email or live chat. The responsible gambling page offers a cool-off period through customer support. The responsible gambling page, the About Us page and the self-exclusion article describe self-exclusion and cool-off only. None of them describes a deposit, loss or wager limit tool. RTP Ledger has not checked the account settings for such a tool. Coverage gaps: loss and wager limit tools. |
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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 winna.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 11.1 sends complaints to support@winna.com. Clause 11.2 allows escalation to the EGIS resolution body at disputes@egis-adr.com. Privacy policy section 7 promises an acknowledgement within 48 hours and a full response within 14 business days. Section 7 names the Tobique Gaming Commission as the escalation route. 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. | Not checkedParent, sister-brand and material operating relationships are not checked. No dated source |
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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 provably fair page describes a hashed server seed, a client seed from the browser and a nonce that rises by one per bet. Rotating the seed pair reveals the previous server seed. A verification interface lets a player reproduce a result. The page states that every game on Winna uses provably fair technology. The licence article limits that statement to Winna Originals. Terms clause 9.2 states that certified random number generators decide game outcomes. RTP Ledger has not reproduced a Winna Originals bet with the verification interface. Independent confirmation of a real result is not established. Coverage gaps: reproduced account-bet verification. |
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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 2FA article describes set-up through an authenticator app. After set-up, each login needs a code that refreshes every 30 seconds. Privacy policy section 6 lists SSL encryption, two-factor authentication and lockout after repeated failed logins. Terms clause 7.1 makes the player responsible for login credentials. 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 evidenceTerms clause 2.2 gives support@winna.com for all support questions. The help centre articles state that support is available 24/7 through live chat or email. RTP Ledger has not timed a support request on winna.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 VIP article sets six tiers with five levels each, based on total amount wagered. Bronze 1 starts at $1,000 wagered and Nebula 5 at $1,000,000,000. Instant Rakeback can be claimed every 7 minutes. Platinum and higher levels get lossback of up to 25% and a VIP host. The rakeback article states no rakeback percentage. 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 10 keeps player data for up to 6 years after account closure. Section 9 names the third parties that can receive data. Those include payment processors, identity verification providers and game providers. Section 9 also allows transfers outside the European Economic Area under standard contractual clauses. Coverage gaps: privacy policy coverage, data deletion and account closure. |
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