| 01Legal operator identity | 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. | 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 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. | 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 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. | 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 | 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. | 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 | 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. | 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 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. | 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 | 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. | 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 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. | 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 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. | 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 luckywins.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 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. | 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 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. | Not checkedParent, sister-brand and material operating relationships are not checked. No dated source |
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| 14Game catalogue and RTP evidence | Not checkedCasino-specific game availability and deployed RTP evidence are not checked. No dated source | Not checkedCasino-specific game availability and deployed RTP evidence are not checked. No dated source |
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| 15Fairness and 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 ↗ | 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 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. | 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 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. | 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 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. | 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 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. | 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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