| 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 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 | 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 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 | 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. | 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 | Not checkedRegistration, verification stages, account currency and closure journey are not checked. No dated source | 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 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. | 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 | 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 | 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 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 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 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. | 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 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 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 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. | 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 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 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 | Not checkedComplaint handling and resolution outcomes are not checked in a dated source record. No dated source | 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 | Not checkedParent, sister-brand and material operating relationships are not checked. No dated source | 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 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 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 | Not checkedTwo-factor authentication (2FA), recovery and withdrawal-protection controls are not checked. No dated source | 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 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 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 | Not checkedVIP earning, tiers, expiry and withdrawal interactions are not checked. No dated source | 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 | Not checkedController, collection, retention, transfers and deletion paths are not checked. No dated source | 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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