Permanent gambling-addiction exclusion not implemented at LuckyPays
Complaint summary
On 26 October 2024 at 06:21:48, I sent an unequivocal permanent exclusion request because of problematic gambling and gambling addiction.
The request expressly stated that all of my accounts should be closed permanently, without any possibility of reopening, and that the exclusion should apply to every relevant brand, subsite, company and licence structure. I did adress this request directly to luckypays.io and 16 other brands.
CoinKings(associated with luckypays) confirmed the closure of my account at 06:24:31, only two minutes and forty-three seconds after the exclusion request had been sent.
The response stated:
> “As per your request, we have closed your account with us.”
The speed of this response establishes that the gambling-addiction notification had been received, read and actively processed almost immediately.
CoinKings response sent through LuckyPays infrastructure
The CoinKings closure confirmation was sent through authenticated LuckyPays email infrastructure.
The message:
* was sent from `[email protected]`;
* used the LuckyPays domain in its technical email routing;
* contained the subject “CoinKings: Account Closed”;
* was signed by CoinKings Support;
* formed part of a support thread handled through the same infrastructure later used for my LuckyPays complaint.
This establishes a direct operational connection between the receipt of the exclusion request, the CoinKings support response and the LuckyPays support environment.
I do not rely on this fact alone to allege that LuckyPays and CoinKings must necessarily be the same legal entity. However, it clearly demonstrates that the exclusion request was known and processed within support infrastructure directly connected with LuckyPays.
LuckyPays remained open despite immediate knowledge of the exclusion
Although the request had been processed for CoinKings within less than three minutes, my LuckyPays account remained accessible.
Deposits and gambling remained possible after the permanent gambling-addiction notification.
On 1 November 2024, I replied to the CoinKings closure thread and expressly stated:
> “Hello my LuckyPays account wasn’t closed, why was I able to deposit.”
Instead of addressing why the exclusion had not been applied to LuckyPays, the support team later responded:
> “Kindly note that we are supporting only CoinKings Casino.”
This response is inconsistent with the documented support and email infrastructure.
The team claimed that it was only responsible for CoinKings even though:
1. the CoinKings closure confirmation was sent from `[email protected]`;
2. the original permanent exclusion request had been received through that LuckyPays address;
3. the request had been processed within less than three minutes;
4. I raised the continued availability of LuckyPays directly within the same support thread;
5. a separate LuckyPays account-closure confirmation was subsequently sent from the same email address and support environment.
The statement that the team only supported CoinKings therefore does not explain why CoinKings support was operating through LuckyPays infrastructure or why the LuckyPays account remained open after the exclusion had already been received and processed.
LuckyPays closed only after the renewed complaint
My LuckyPays account was not closed until 1 November 2024, after I had repeatedly complained that the exclusion had not been implemented and that deposits had remained possible.
LuckyPays then confirmed:
> “As per your request, we have closed your account with us.”
This was approximately six days after the original permanent gambling-addiction notification.
LuckyPays subsequently rejected a refund on the basis that the deposited funds had already been gambled.
That response does not address the actual responsible-gambling failure. The relevant issue is not merely what happened to the deposited funds after they were accepted. The issue is that the deposits should not have been accepted at all after a clear permanent gambling-addiction exclusion had already been received and processed through the connected support infrastructure.
Payment evidence and amount to be determined
My Revolut data contains completed card payments using the merchant descriptor “BitSent” after the exclusion request.
Payments of EUR 210 and EUR 279 were made on 31 October 2024, shortly before I complained that deposits had remained possible at LuckyPays.
The available evidence strongly supports that these payments relate to the relevant casino activity. However, the external banking descriptor alone does not permit a final allocation of every transaction between LuckyPays and any other connected account.
I therefore do not present a fixed final refund amount at this stage.
The exact amount must be determined from records controlled by LuckyPays, CoinKings, the relevant operator and their payment providers, including:
The refund claim should cover the complete verified net loss accepted by LuckyPays after the permanent exclusion request.
Wider group concerns
The present complaint is focused on LuckyPays and the documented CoinKings support connection.
There is also evidence of further failures concerning other brands that received or should have been affected by the same permanent gambling-addiction notification. Deposits or continued account access appear to have remained possible elsewhere after the request.
Those matters may be submitted as separate complaints once the relevant transactions and responsible entities have been fully allocated.
Their existence is nevertheless relevant here because it indicates that the failure at LuckyPays may not have been an isolated account-level mistake. It may reflect a broader failure to distribute and enforce responsible-gambling information across connected brands, support systems or operator structures.
I remain interested in a coordinated group-wide solution. However, the present LuckyPays complaint should first address the directly documented facts:
* the exclusion request was received;
* CoinKings processed it within less than three minutes;
* the response was sent through LuckyPays infrastructure;
* LuckyPays remained open;
* deposits remained possible;
* the support team then claimed that it was only responsible for CoinKings;
* LuckyPays was closed only after a renewed complaint approximately six days later.
Any wider settlement would need to identify all affected accounts and transactions and must not require a waiver of unknown claims before the relevant account and payment records have been disclosed.
Requested resolution
I request that LuckyPays and the responsible operator:
1. acknowledge receipt of the permanent gambling-addiction exclusion request on 26 October 2024;
2. acknowledge that CoinKings processed the request within two minutes and forty-three seconds;
3. explain why a CoinKings support response was sent through authenticated LuckyPays infrastructure;
4. explain why the support team later claimed that it only supported CoinKings;
5. explain why the LuckyPays account remained open after the exclusion request had already been received and processed;
6. disclose the complete LuckyPays account, deposit, withdrawal, wagering and bonus history;
9. disclose how the LuckyPays and CoinKings accounts were linked or separated within the support, CRM, payment and responsible-gambling systems;
10. calculate and refund the complete verified LuckyPays net loss accepted after the exclusion request;
11. preserve all account, payment, support, device, IP, KYC, responsible-gambling and internal audit records;
12. state whether a coordinated review of further related group violations is possible.
The precise refund amount must remain open until the operator discloses the records necessary to calculate it. The absence of a final figure does not undermine the complaint because the decisive account and payment information is under the operator’s control.
I can provide Betpack with the original, unredacted email files for confidential verification, but I do not wish to upload or publish them publicly due to the personal data they contain.
The sum entered is only a placeholder
Thanks for your help!
Dear JonasGamble,
Thank you for bringing this issue to our attention. We have contacted representatives of LuckyPays and asked them to respond to this inquiry directly. We appreciate your patience during this time and hope to resolve this complaint soon.
Best Regards,
Betpack Team
Hello,
Thank you for bringing this matter to our attention.
We have reviewed the account referenced in the complaint. Our records confirm that the account was permanently closed at the customer's request approximately two years ago. Following the closure, no further deposits or gambling activity took place on the account.
We would also like to clarify that LuckyPays has no association whatsoever with CoinKings. CoinKings is a separate operator, and we are not affiliated with or connected to them in any way. As such, we cannot comment on any matters relating to their operations, responsible gambling procedures, or account management.
Based on our records, the requested permanent account closure was implemented successfully, and there was no subsequent activity on the LuckyPays account.
Kind regards,
The LuckyPays Team
Thank you for the response. However, it does not address the actual subject of my complaint and contains a material statement that is objectively contradicted by the available evidence.
The relevant exclusion request was sent directly to LuckyPays
On 26 October 2024 at 06:21:48, I sent my permanent gambling-addiction exclusion request directly to [email protected].
This was not merely a request concerning CoinKings. I expressly informed the recipients that I was suffering from problematic gambling and gambling addiction. I requested permanent closure of all of my accounts, without any possibility of reopening, and expressly stated that the exclusion should apply to all relevant brands, websites, companies and licence structures.
LuckyPays was therefore itself a direct recipient of the gambling-addiction notification. The central question is whether LuckyPays properly acted upon an exclusion request that had been sent directly to its own support address.
Only two minutes and forty-three seconds after the request was sent, at 06:24:31, a CoinKings closure confirmation was issued through [email protected]
The message was sent from the LuckyPays email domain, used LuckyPays infrastructure in its technical routing, carried a CoinKings subject and signature, and confirmed that the exclusion request had already been received and processed.
This is direct evidence that the gambling-addiction notification reached a support environment operated through or on behalf of LuckyPays and that this support environment was also processing CoinKings account matters.
The statement that there was no connection whatsoever is objectively false
LuckyPays now states:
“LuckyPays has no association whatsoever with CoinKings. CoinKings is a separate operator, and we are not affiliated with or connected to them in any way.”
This is an absolute statement. It does not merely state that LuckyPays and CoinKings maintained separate player accounts, used different front-end brands or were formally allocated to different legal entities. It asserts that there was no association and no connection of any kind.
That assertion is objectively contradicted by the available evidence.
A CoinKings account closure was sent from [email protected]. The CoinKings closure was processed in response to an addiction-related request sent directly to the LuckyPays support address. The same correspondence subsequently contained my complaint that LuckyPays had remained open and accepted deposits. LuckyPays and CoinKings were also connected through the identified support and CRM environment. The same support personnel appeared in communications involving both and other brands. Both domains are also associated with the same Anjouan B2C licensed operation ALSI-142311005-FI2. These are today on 04.08.2026:
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The use of the LuckyPays email domain to process CoinKings account matters is itself a connection. The use of the same support environment is a connection. Shared support personnel constitute a connection. Their placement within the same licensed operation constitutes a regulatory connection.
LuckyPays may attempt to argue that the brands were operated separately for certain administrative or corporate purposes. That would not make the statement that they were “not connected in any way” accurate.
The statement is therefore not merely incomplete or imprecise. It is materially misleading and objectively false.
The statement is particularly serious because it concerns the operator’s own systems
This does not involve an obscure external fact that the responding team might reasonably have been unable to verify.
The statement was made by the operator responding through the same infrastructure that had previously received my gambling-addiction request, sent the CoinKings closure confirmation from the LuckyPays domain, handled my complaint that LuckyPays had remained open, and subsequently processed the LuckyPays closure.
The categorical denial is therefore difficult to explain as an innocent misunderstanding.
If the operator made the statement without reviewing its own email records, support records, CRM records and licensing structure, the statement was at minimum reckless and inconsistent with fair and transparent complaint handling.
If the responding team knew that CoinKings matters had been processed through the LuckyPays email domain and support environment, the assertion that there was no connection whatsoever appears to have been knowingly misleading.
I ask Betpack to treat this as a serious credibility issue and not to accept the operator’s categorical denial without supporting records.
The operator’s response addresses the wrong period
LuckyPays states that the account was permanently closed and that no further deposits or gambling activity took place following the closure.
That point is not disputed. It does not answer my complaint.
I do not claim that deposits or gambling continued after the LuckyPays account was eventually closed.
The complaint concerns the period between 26 October 2024, when the permanent gambling-addiction exclusion request was sent directly to LuckyPays and immediately processed through its support environment, and 1 November 2024, when LuckyPays was finally closed only after I complained that the account had remained open and deposits had been possible.
On 1 November 2024, I expressly wrote in the same correspondence:
“Hello my LuckyPays account wasn’t closed, why was I able to deposit.”
LuckyPays was closed only after this renewed complaint.
LuckyPays subsequently rejected reimbursement on the basis that the deposited funds had already been gambled. That earlier response itself confirms that the dispute concerned deposits accepted before the delayed LuckyPays closure.
The present statement that there was no activity after the eventual closure therefore avoids the actual issue. The issue is why LuckyPays remained accessible after the addiction-related exclusion had been sent directly to LuckyPays on 26 October 2024.
The LuckyPays support environment had actual knowledge of my gambling addiction
The operator cannot avoid the responsible-gambling issue by describing CoinKings as a separate operator.
The exclusion request was sent directly to . It expressly referred to gambling addiction. It expressly covered all of my accounts, brands, companies and licence structures. It was received and processed within less than three minutes. The resulting response was sent through the LuckyPays domain.
The support infrastructure acting through [email protected] therefore had actual knowledge of my gambling addiction on 26 October 2024.
An internal division between brands, support queues, legal entities or player databases does not extinguish that knowledge.
An operator cannot receive an express group-wide gambling-addiction exclusion through its own support address, implement it selectively for one brand, leave another expressly covered account accessible and then argue that it was unable to comment because the brands were supposedly unconnected.
Even if separate legal entities were involved, LuckyPays still directly received the exclusion request. The operator must therefore explain why the request was not implemented immediately for the LuckyPays account.
The Anjouan responsible-gaming obligations support this conclusion
The Anjouan responsible-gaming framework treats player-protection obligations as a condition of licensure.
Licensed operators are required to maintain effective self-exclusion procedures and to honour valid self-exclusion requests. The regulatory standards also require operators to take measures intended to reduce gambling-related harm, including self-exclusion mechanisms and other player-protection controls.
The relevant obligation rests with the licensed operator responsible for the licensed operation. It is not merely a voluntary customer-service function belonging to an individual front-end brand.
My request was not an ordinary request to close one account for convenience. It was an unequivocal notification of gambling addiction and a request for permanent exclusion across all relevant accounts, brands, companies and licence structures.
Once that request had been received directly through the LuckyPays support address, the operator was required to treat it as a serious player-protection matter and take effective steps to identify and restrict the accounts expressly covered by the request.
Instead, the request was implemented immediately for CoinKings while LuckyPays remained accessible. Deposits remained possible, and LuckyPays was closed only after I raised the failure again.
The operator has not explained how this selective implementation complied with its responsible-gambling obligations.
The current response also raises a Code of Conduct concern
The present response is not merely an inadequate explanation of the events of October and November 2024. The response itself raises a separate and current concern under the Anjouan Code of Conduct for Licensed Operators.
The Code requires licensed operators to deal fairly and honestly with consumers. It also requires fair, transparent and responsible treatment and prohibits misleading or deceptive conduct in connection with licensed gambling services.
The statement that LuckyPays and CoinKings had “no association whatsoever” and were “not connected in any way” is incompatible with those obligations when the operator’s own communications and support infrastructure demonstrate a connection.
The response appears designed to create the impression that LuckyPays could not have received, known about or acted upon the CoinKings responsible-gambling information.
That impression is false.
The exclusion was sent directly to [email protected]. It was processed through that address. A CoinKings closure confirmation was sent from that address. The same support correspondence later addressed the fact that LuckyPays had remained open.
The operator is therefore attempting to use an alleged separation between the brands to obscure the more important fact that the LuckyPays support environment had already received and processed my gambling-addiction notification.
The gambling-addiction context makes this conduct more serious
This was not a routine commercial disagreement.
I had expressly disclosed gambling addiction and requested permanent exclusion without any possibility of reopening.
The requirement to deal fairly and honestly with a consumer is particularly important where the consumer has identified himself as vulnerable and has directly requested protection from further gambling.
An operator should not exploit its internal corporate, technical or brand structure to obscure who received an exclusion request, who had access to the information, why the request was implemented selectively or why gambling remained possible.
Nor should an operator make an absolute denial of any connection where its own email domain, support systems, personnel and licensing structure provide evidence to the contrary.
The response therefore raises both a responsible-gambling concern and an honesty and transparency concern under the Code of Conduct.
The operator must disclose the underlying records
My records show completed transcations.
These payments occurred after my exclusion request of 26 October 2024
LuckyPays should therefore provide the exact date and time at which my exclusion request was received by [email protected], the exact date and time at which my LuckyPays account was restricted and permanently closed, and the complete deposit, withdrawal, wagering and bonus ledger covering the period from 26 October to 1 November 2024.
The operator should disclose the complete responsible-gambling notes, internal account flags, support tickets, ticket-routing records, CRM audit history and access logs relevant to my exclusion request.
Requested resolution
I ask Betpack to keep this complaint open.
I request acknowledgement that my permanent gambling-addiction exclusion was sent directly to LuckyPays on 26 October 2024.
I request acknowledgement that the request was received and processed through the LuckyPays support environment.
I request that LuckyPays withdraw or correct the objectively false and materially misleading statement that LuckyPays and CoinKings had “no association whatsoever” and were not connected “in any way.”
I request a complete explanation of the documented email, support, CRM, personnel and licensing connections between the two brands.
I request disclosure of the relevant account, payment, support, responsible-gambling, technical and licensing records.
I request calculation of the verified net loss incurred after the exclusion request of 26 October 2024 but before the delayed LuckyPays closure on 1 November 2024.
I request reimbursement of that verified post-exclusion net loss.
I can provide Betpack confidentially with the original unredacted EML files, complete email headers, payment records and the technical support-infrastructure analysis.
The operator’s statement that no activity occurred after the eventual closure does not resolve the complaint. The complaint concerns the failure to implement a permanent gambling-addiction exclusion when it was received directly by LuckyPays on 26 October 2024, followed by a current response that denies documented connections within the operator’s own support and licensing environment.
Thanks to Betpack for tacking over that complaint
