| 01Legal operator identity | DocumentedThe terms preamble names Halcyon Super Holdings B.V. as the operator of cloudbet.com. The preamble gives company number 148526 and an address at Boulevard 03. The Curaçao Gaming Authority certificate binds the same company, company number and domain. The privacy policy gives a different postal address for the same company: Boulevard 50. RTP Ledger does not resolve this address discrepancy. | 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 | DocumentedThe terms cite licence OGL/2024/328/0599. The Curaçao Gaming Authority’s own certificate lookup confirms the same licence number. The certificate lookup shows a grant date of 23/05/2025 and a current status of Active. The CGA’s own bulk licence registry PDF is dated 2026-09-10. The registry PDF lists the same licence number and company. The registry PDF gives a different issued date, 23 November 2025, and a different expiry date, 23 May 2026. The registry PDF gives a different status: "Assessment in progress". RTP Ledger does not resolve this discrepancy between the two CGA-published sources. | 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 | DocumentedClause 7.1.3 bars a user physically located in 19 named countries or territories from betting or withdrawing funds. The list includes Australia, Austria, Belgium, China (Macau and Hong Kong SAR), Curaçao, Cuba, France, Germany, Iran, Lithuania and Malta. It also includes Myanmar, the Netherlands, North Korea, Singapore, Syria, Spain, the United States of America and its territories, and the United Kingdom. Clause 7.1.3 also bars three named regions in Ukraine: Crimea, Donetsk and Luhansk. | 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 | Not checkedRegistration, verification stages, account currency and closure journey are not checked. No dated source | Not checkedRegistration, verification stages, account currency and closure journey are not checked. No dated source |
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| 05Payment catalogue | DocumentedThe crypto transaction fees page lists 30 currencies. Each currency shows one or more accepted networks, for example USDT on Ethereum, BNB Smart Chain, Avalanche C-Chain, Solana, Polygon, TRON and The Open Network. The page states that Cloudbet charges no deposit fee. It attributes withdrawal fees to the blockchain network and says these fees can change without notice. Withdrawal minimums are listed separately in the table; the text does not attribute those minimums to the network. | 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 | Partial evidenceThe crypto transaction fees page states a deposit fee of zero for every listed asset. It does not state a deposit minimum, a confirmation-count requirement or a crediting stage for any asset. RTP Ledger found no other page that states the deposit minimum, confirmations or crediting stage. Coverage gaps: deposit route terms. No dated source | 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 evidenceThe crypto transaction fees page states that Cloudbet charges no deposit fee. The page states that the blockchain network sets a flat withdrawal fee. The page states that this fee can change without notice. Clause 7.1.10.1 reserves the right to add a handling charge of up to 5% on deposits and withdrawals. Clause 7.5.8 gives a 24-hour window for a refund request. The window extends to 30 calendar days if the user claims that another person accessed the account. RTP Ledger has not observed a withdrawal on cloudbet.com, so 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 promotion page checked on 26 September 2026 describes a Cash Vault separately from the $2,500 reload and rakeback amount. Clause 8.4 of the terms retains a $2,500 package cap. The previous total-cap and no-wagering summary is withheld pending reconciliation. The separate stored claim that all slots contribute 100% is also withdrawn: clause 8.5 now defines contribution by RTP. Earlier evidence remains in this claim’s history; this check was limited to the changed bonus sources. Section 8.4 states account eligibility, first-deposit activation, a 30-day period and a $2,500 package cap. The promotion page describes the Cash Vault separately from reloads and casino rakeback. RTP Ledger has not established how the stated cap and expiry apply to the whole current offer, so the earlier combined eligibility-and-expiry claim is withheld. This is a public-source check, not an account test or partner confirmation. Coverage gaps: bonus economic terms, 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 evidenceClause 18.1.5 requires identity verification once cumulative deposits reach or exceed USD 2,200. Clause 18.1.3 names Sumsub as the contracted provider for automated KYC verification. Clause 7.5.7 lets Cloudbet ask for identification, proof of address, a card check and a photo before paying a withdrawal. RTP Ledger has not run a test account on cloudbet.com, so the stage at which 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 responsible-gambling page publishes a deposit limit with daily, weekly (7-day) or monthly (30-day) duration options. A stricter limit takes effect immediately. A less strict limit, or a cancelled limit, takes effect after a 24-hour wait. RTP Ledger found no separate wager limit or net-loss limit tool on the page. The responsible-gambling page offers cooling-off for 24 hours, 7 days, 1 month or 3 months. Betting is disabled during cooling-off. The page offers self-exclusion for 1 year, 3 years, 5 years or a lifetime. The page describes a lifetime exclusion as irreversible. The page names four help organisations: Gamblers Anonymous, GambleAware, Gambling Therapy and Gamtalk. | 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 cloudbet.com test account, so 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 | Not checkedComplaint handling and resolution outcomes are not checked in a dated source record. No dated source | 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 | Not checkedParent, sister-brand and material operating relationships are not checked. No dated source | 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 fairness and RNG testing page states that RNGs are certified and tested externally before going live. It states that the theoretical RTP for a game appears in that game’s own information or help section. It states that analysis comparing the actual RTP to the theoretical RTP is carried out quarterly. This custom field name does not match the schema’s Stake Engine catalogue field. Cloudbet publishes a certification and review statement instead of a per-game RTP catalogue. 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 Cloudbet Originals combine a server seed, a client seed and a nonce. It names SHA3-256 as the algorithm that creates the Commitment and the Round Signature. It names SHAKE256 as the algorithm that turns the Round Signature into the outcome stream. The page states a player can reproduce the Commitment and verify a round once the seeds are revealed. 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 | Not checkedTwo-factor authentication (2FA), recovery and withdrawal-protection controls are not checked. No dated source | 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 homepage footer lists a Help Center, labelled "Find answers easily", and live chat, labelled "Get Support 24/7". Clause 7.1.10.2 of the terms gives support@cloudbet.com as the contact address for reactivating a suspended account. RTP Ledger has not timed a support request on cloudbet.com, so 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 | Not checkedVIP earning, tiers, expiry and withdrawal interactions are not checked. No dated source | 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 | Not checkedController, collection, retention, transfers and deletion paths are not checked. No dated source | 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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