General Data Protection Regulation (GDPR)

This is a forum for discussing privacy abuse. Some bookmakers secretly use insidious tracking techniques on computers and smartphones. The one product most talked about is 'iesnare', which is never specifically mentioned in terms and conditions, but there are plenty of other privacy abuses you may not be happy with. Let everyone know.
Jimmy Justice
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Re: General Data Protection Regulation (GDPR)

Post by Jimmy Justice » Mon Jul 15, 2019 10:28 am


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Re: General Data Protection Regulation (GDPR)

Post by micmacg » Thu Aug 29, 2019 3:14 pm

I recently had an account closed and over £1,000 confiscated by 10Bet, who claimed that I was colluding with another anonymous account and determined that this £1,000 of profits in the 'collusion period' that they identified was now theirs to confiscate.

Upon requesting any evidence of collusion they responded with the following:
"We have detected coordinated activity between you and another account, however, we are unable to provide additional details as per our GDPR obligations.

Many bettors think it is acceptable to open accounts in the names of third parties in order either to avoid stake limits or to collect more than one bonus or promotional offers, and for that reason the Operator is entitled to make identity and gameplay checks. Upon detection of irregularities or prohibited activities the operator is entitled to apply sanctions, which in this case resulted in voiding the profit generated in the period 13/06/2019 - 08/07/2019."
My account had been opened and used since 2014 without issue (other than going through extended KYC and providing numerous selfies holding my passport).

I continued to complain but was unable to get any further information from 10Bet, so I filed a Subject Access Request (SAR) using the template provided by J4P ... -template/ .

Today I received the reply to my SAR which I am posting here to show how little information I was actually able to receive from 10Bet:
With respect to your request to receive information relating to Iovation – if you would like to access the personal data which is being processed by Iovation, you may contact them at the following address: Iovation’s Privacy Policy is available at the following URL: .

Kindly note that as detailed in our privacy policy, we regularly share personal data with fraud prevention services, risk analysis vendors and data verifiers, in order to meet our regulatory obligations under various Know Your Customer and Anti-Money Laundering regulatory requirements, as well as to prevent fraudulent or illegal activities, and in order to prevent abuse of our policies or suspicious betting patterns. Accordingly, kindly note that we are not able to process your request to receive information relating to such activity, due to the following reasons:

· Pursuant to our consideration, exercising your right of access with respect to any fraud prevention or risk analysis procedures would adversely affect our own and our third parties’ rights, as such information is considered to be protected intellectual property and trade secret of our respective service provider.
· Further, disclosing such data may compromise the integrity of our services and may result in the ability to deliberately abuse our policies, in particular, the prohibition on utilizing betting techniques for the purpose of circumventing the operation of our services. Such actions are contrary to our rules and policies, and refusal to disclose such data is considered to be legitimate and reasonable, in accordance with Article 15(d) of the General Data Protection Regulations (“GDPR”).

With respect to your request to receive information regarding all organizations with whom your information was disclosed, we would like to kindly refer you to our privacy policy, where we provide information relating to the categories of recipients to whom your personal data have been disclosed, as required under Article 15(c) of the GDPR.

With respect to your request to receive details of the reasoning behind the decision to restrict/close your account, kindly note that this request does not fall within Article 22 of the GDPR, as such decision was not solely based on automated means.

To summarise, they:
  • 1. Will not provide me with the data they have shared with Iovation
    2. Will not disclose the names of any external organizations with whom they have shared my personal information
    3. Will not disclose any of the information/evidence used in their decision to close my account
It would seem gambling operators are able to manually close accounts and steal money from customers at their will once a customer wins a few bets.

Jimmy Justice
Site Admin
Posts: 757
Joined: Wed Jan 13, 2016 9:16 am

Re: General Data Protection Regulation (GDPR)

Post by Jimmy Justice » Fri Aug 30, 2019 8:33 am


Thank you for your detailed post.

The simple part first; 10xBet can't keep your money without providing evidence; under UK and Irish law that is theft.

Now the more complex things. There is only one person who truly knows what has happened when you've been gambling; that is you. You, therefore have a decision to make. Would you stand up in an English (Scottish or Irish) court and testify? If the answer is yes, you should pursue every avenue open to you. If the answer is no, you need to think very carefully about proceeding with anything. You may have read our advisory leaflet already, if not, I've attached it for you.

A court claim should always be your last option, but if they've taken your money and you know you've done nothing wrong I doubt they will go to court, because a judge can force them to provide the evidence they're claiming they have.

Re Iovation; it's true that you are not allowed to view other account data, but either 10xBet or Iovation have to provide you with all the Iovation data related to your account. I would report their refusal immediately to the Information Commissioner's Office. It's possible, at last, that the ICO are getting the message that gambling companies frequently breach GDPR. They are also keeping a close eye on Iovation.

Some gambling companies frequently try to use secrecy relating to criminal procedures to cover up their actions. Of course sometimes this is valid, but in our experience it often isn't and when challenged legally they tend to pay. I can't guarantee this and I'm not a lawyer, so please do not see any of my text as legal advice. We can, however, put you in contact with relevant people if you want legal advice.

Everything written here is based on what you've outlined and nothing else, e.g. I don't have 10xBet's side of the story.

Best of luck and if you've done wrong DO NOT give in. As a last resort do go to court, but try to avoid it if you can.

Know your rights when betting 11-18.pdf
(1.4 MiB) Downloaded 3 times

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Re: General Data Protection Regulation (GDPR)

Post by micmacg » Fri Aug 30, 2019 10:44 am

Hi JJ,

Thanks for the detailed response.

The account they are accusing me of colluding with belongs to my brother. We both gamble for a living, he has held a 10Bet account since January 2015 and I have held one since September 2014, both without issue until now. He has also had his account terminated and money stolen. 10Bet refused to tell either of us who the other account was that they had evidence of collusion with but of course we could tell.
I think you will find the details of what they call a ‘collusion period’ between the two accounts very interesting, so I’ll provide a summary.

Brother’s Account:
• 45 bets placed
• £7,102.38 total staked
• £4,391.89 total profit

My Account:
• 9 bets placed
• £621.68 total staked
• £1,209.96 total profit

In total we had 54 bets placed between us. Of these 54 bets, none were identical.

Of these 54 bets, one from my account and two from my brother’s account were placed on the same match, although the bets were different. I had a bet on a -1.5 Asian handicap whilst he had a bet on the -2 euro and -3 euro handicaps on the same football match.

The three bets which were placed on the same football match but with different outcomes totaled £43 of stake and £57.42 of profit.
10Bet have decided that this is enough evidence to take £4,391.89 from my brother and £1,209.96 from me. In total they have taken £5,601.85 from us because we won £57.42 on the same football match. This is one percent of our total profits.

My bet was the last I placed on my account, yet they have taken the profit from the 8 bets preceding it.
My brothers bets were the 3rd and 4th last placed on his account, yet they have taken the profit from the 41 bets preceding them.

Considering all of this, both of us would be more than happy to stand up in a court and testify.

I will report the Iovation data issue to the ICO, although I have already reported another operator for refusing to respond to my SAR and the ICO have informed me that they are facing a huge backlog of complaints of this nature so it will be at least three months before a case worker is assigned to my complaint. Still worth making them aware I suppose.

Jimmy Justice
Site Admin
Posts: 757
Joined: Wed Jan 13, 2016 9:16 am

Re: General Data Protection Regulation (GDPR)

Post by Jimmy Justice » Mon Sep 02, 2019 10:20 am

Thank you for all this detail and being so open.

10Bet will no doubt claim they have other data, but it is probably time to challenge that and make them produce it.

You've probably read this: Quite detailed to be fair. I think you need to get to the IBAS stage asap. In theory since Ocotber 31st last year this means 10Bet will have to provide all the evidence they have to IBAS and you are entitled to see it. In practice this sometimes doesn't happen; no surprise there. However, if IBAS refuse to provide you with the data and/or they find in 10Bet's favour then move to the courts where 10Bet will have to provide their evidence in a public forum and prove you have colluded, which remains to be seen if they can? I suspect, but can't guarantee that they will end up having to pay you.

Of course, it's all hassle, but that's where we are in this crazy world of gambling regulation. DO NOT give in.


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