| 01Legal operator identity | DocumentedThe terms define the Company as Hot Streak Ltd., registered in Nevis under number C 60238. The registered address is Unit 5, Long Stone House, Main Street, Charlestown, Nevis. The privacy policy names Hot Streak Ltd. as the Company and as data controller for EU and EEA residents. | 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 state that The Anjouan Betting and Gaming Board authorises Hot Streak Ltd. under licence ALSI-202504045-FI2. The applicable law is that of Anjouan, Union of Comoros. No licence seal or validator link was found on the pages checked. RTP Ledger has not read a regulator record for this licence. | 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 3.1.6 requires the account holder not to be resident in 38 named jurisdictions. The list includes Australia, Estonia, Finland, France, Germany, Spain, Sweden and Türkiye. It also includes the United Kingdom, the United States and its territories, and the Union of the Comoros. Curaçao is listed with the other Dutch Caribbean islands. | 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 | Partial evidenceThe signing-in article lists email and password, Google and Facebook. Bank login works only in Finland and Estonia. A password reset uses an email link. Coverage gaps: registration terms, observed verification journey, observed account-closure journey. | 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 accepted crypto article names BTC, ETH, USDT, USDC, LTC and SOL as examples and sends players to the cashier for the full list. The player chooses the network in the cashier, for example Tron (TRC20). The withdrawal article also names card and bank account routes. Available methods depend on the country. | 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 accepted crypto article states that the cashier shows the minimum deposit. A deposit below that minimum, or sent on a different network, can be lost. A deposit is credited after blockchain confirmation. Terms clause 3.8.26 states that the Company charges no deposit or withdrawal fees. | 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 help centre requires every deposit to be wagered at least once before withdrawal. Terms clause 3.8.25 and the withdrawal article cap withdrawals at EUR 50,000 or equivalent per 24 hours. Clause 3.8.26 charges no fee, but allows a fee after notice for irregular withdrawal activity. Withdrawals go to the last deposit method, in the player's own name. RTP Ledger has not observed a withdrawal on epicbet.com. Actual 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 bonus article states that bonuses are issued automatically, based on account activity and eligibility. The article states no welcome offer terms. RTP Ledger did not read a current welcome offer page, so its terms are unknown. 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 evidenceTerms clause 3.8.3 allows extra security checks, including source of funds and source of wealth declarations with bank statements or payslips. Clause 3.8.2 allows the account to be blocked if documents are missing or false. The withdrawal article states documents may be requested before approval. Accepted identity documents are a passport, national ID card or driving licence. No checked page states an amount threshold. RTP Ledger has not run a test account on epicbet.com. 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 Sustainable Gaming page offers a loss limit per day, week or month. A daily limit resets every 24 hours, and weekly and monthly limits run on 7-day and 30-day cycles. A decrease applies at once. An increase or removal waits 48 hours. The Sustainable Gaming page offers self-exclusion of up to 180 days in the account. An active exclusion cannot be lifted early. Longer or indefinite exclusion goes through support@epicbet.com. The help article adds that self-exclusion covers this brand only and not the operator's other platforms. | 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 an epicbet.com 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 3.5 requires transaction claims within 30 calendar days and game outcome claims within 14 calendar days. Complaints go to support@epicbet.com and then to complaints@epicbet.com. The Company aims to resolve a complaint within 30 calendar days. Unresolved complaints can go to ADR through EGIS - FZCO. 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 About Us page names ReSpin Casino as a sister brand, launched in January 2024. The help centre states that self-exclusion does not extend to the operator's other platforms. No checked page names the company behind ReSpin Casino. The terms name Hot Streak Ltd. and no parent company. Clause 3.8.4 allows another group company to accept deposits and make withdrawals. The group structure is not established. 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 casino games article states that every game shows its RTP inside the game through the (i) button. RTP Ledger has not captured per-game RTP values on epicbet.com. 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 casino games article states that slots and digital table games use a random number generator. It states that licensed providers make the games and independent testing labs check them. The article names no lab and publishes no provably fair method. Coverage gaps: published fairness algorithm, 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 help centre articles send players to Support Chat. Terms clause 3.5.3 and the Sustainable Gaming page name support@epicbet.com. Clause 3.5.3 names complaints@epicbet.com for escalation. RTP Ledger has not timed a support request on epicbet.com. 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 Epicverse article enrols eligible players automatically. Real-money bets earn XP. A slot with RTP from 80% to 97% earns 1 XP per EUR 1, and higher-RTP slots earn less. Coins have no cash value and work only in the Epicverse Shop. Coins can expire after an email notice of at least 30 days. 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 | Partial evidenceThe privacy policy names Hot Streak Ltd. as the Company. Its Data Controller section makes the Company the controller for residents of the EU and the EEA. The privacy policy deletes personal data five years after the account closes. The help article lets a player request closure through support chat or email. Terms clause 3.7.1 also allows closure through customer support. Coverage gaps: category-level retention schedule. | 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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