Dear Spinsy Team,
Thank you for the clarification.
I appreciate Spinsy confirming that the withdrawals submitted on 17 and 18 August were completed and sent on 18 August. I also appreciate the clarification that the July payouts are not being used to delay or restrict my August withdrawals.
That clarification is important, because it appears to resolve one aspect of the dispute in my favour: Spinsy has now expressly confirmed that the completed July withdrawals did not restrict or delay my August withdrawals.
However, I respectfully do not believe the latest response resolves the central issue concerning the delay to my 12 August withdrawal.
In fact, the latest response narrows the issue considerably.
1. Spinsy has now confirmed that July withdrawals did not affect August
Spinsy states:
“completed July payouts are not being used to delay or restrict your August withdrawals.”
I appreciate that clarification.
This means that the previous references to the €7,000 paid out during July cannot now be relied upon as an explanation for why my August withdrawals were delayed or restricted.
I therefore believe this particular point can now be put to one side.
The remaining question is much simpler:
Why was my 12 August withdrawal pending for the period that it was, and what contractual provision authorised that processing period?
That question remains unanswered.
2. The latest response does not explain the delay to the 12 August withdrawal
My original complaint was not simply that Spinsy had applied a withdrawal limit.
I expressly acknowledged that Spinsy is entitled to apply whatever withdrawal limits are contractually applicable to my account.
The issue was the distinction between:
* the amount a customer is permitted to withdraw; and
* the length of time Spinsy is entitled to keep a valid withdrawal request pending.
Those are two separate issues.
Spinsy’s latest response confirms that the July withdrawals did not restrict the August withdrawals, but it does not explain why the 12 August withdrawal remained pending until it was eventually completed.
I therefore respectfully ask Spinsy to answer this specific question:
What was the actual reason that my 12 August withdrawal remained pending?
Was it:
1. a verification review;
2. a compliance review;
3. a source-of-funds review;
4. an account-balance review;
5. a payment-provider issue;
6. an internal finance-processing issue; or
7. something else?
If none of these applied, I would appreciate Spinsy simply stating what caused the delay.
3. Section 6.16 still needs to be addressed
This is particularly important because Spinsy previously referred me to section 6.16 of its Terms and Conditions.
A publicly available copy of Spinsy’s terms has previously been quoted in a Spinsy dispute as stating, in substance, that:
“The Company may delay processing of your withdrawal request to perform checks of your identity, account balance, source of funds and compliance with the Terms…”
and that the Company may postpone payments until verification procedures have been completed. (Casino.Guru)
I am not disputing Spinsy’s right to conduct legitimate verification or compliance checks.
My question is much narrower:
Was section 6.16 actually relied upon in relation to my 12 August withdrawal?
If the answer is yes, please state:
* what check was conducted;
* when that check commenced;
* when it was completed;
* whether any information or documentation was requested from me;
* whether the withdrawal was prevented from being processed while that check was ongoing; and
* when the withdrawal was approved for payment.
If section 6.16 was not relied upon, I would appreciate Spinsy confirming that expressly.
This would resolve a significant part of the uncertainty.
4. Spinsy’s latest answer appears to remove the €7,000 July explanation
I think it is important to record the position accurately.
Previously, Spinsy referred to the fact that €7,000 had been paid out across six withdrawals during July.
That appeared to be relevant to the explanation for the withdrawal situation.
I asked how July withdrawals could affect an August withdrawal if the €7,000 figure represented a monthly limit.
Spinsy has now clarified:
“completed July payouts are not being used to delay or restrict your August withdrawals.”
I accept that clarification.
However, this also means that the €7,000 July figure cannot explain the delay to my 12 August withdrawal.
Therefore, if Spinsy maintains that the 12 August withdrawal was processed correctly, there should now be no difficulty identifying the actual reason for the delay.
5. The VIP issue also remains relevant, although I accept it is separate from the August delay
I also appreciate Spinsy’s explanation that VIP status is determined by activity over the preceding 90 calendar days and can change depending upon deposits, withdrawals and bonuses.
That explains, at least generally, how a VIP level can change.
However, it does not fully answer the question I raised about how my withdrawal limits were calculated during July.
Spinsy’s own VIP information states that VIP Levels 3, 4 and 5 receive:
“Higher Withdrawal Limits”
and specifically states that Spinsy reserves higher daily and monthly withdrawal limits for VIP customers. (Spinsy online casino and sports betting)
Spinsy also publicly describes VIP customers as receiving priority in relation to withdrawals. (Spinsy online casino and sports betting)
Therefore, if I was genuinely at VIP Level 5 during part of July, it is reasonable to ask how that status was reflected in my account.
I am not saying that my Level 5 status automatically entitles me to a particular amount without reference to the applicable Terms.
Rather, I am asking Spinsy to provide the factual account history necessary to establish what limit actually applied.
In particular:
* What dates was my account recorded as Level 5?
* On what date was it downgraded?
* What withdrawal limit applied while I was Level 5?
* What withdrawal limit applied after the downgrade?
* Was the €7,000 figure a Level 1 limit?
* If so, why was that figure presented as the relevant July limit when I was apparently Level 5 for part of the month?
* Was my July allowance calculated according to my actual VIP status at the relevant times?
Spinsy’s latest explanation about how VIP levels are determined does not answer those questions.
6. The distinction between a withdrawal limit and a processing period remains unanswered
This is, in my view, the most important point.
Even if Spinsy establishes that €7,000 was the applicable monthly withdrawal limit, that does not by itself explain the time taken to process a withdrawal that was within the applicable limit.
A monthly withdrawal limit answers:
“How much may the customer withdraw?”
It does not necessarily answer:
“How long may the operator keep an otherwise valid withdrawal pending?”
For the latter question, I would expect there to be a contractual provision dealing with withdrawal processing, verification, payment processing, or similar matters.
If Spinsy says that section 6.16 is that provision, then please say so and explain how it was applied to my particular withdrawal.
If another section is relied upon, please identify it.
I am not asking Spinsy to provide confidential internal procedures. I am asking for the contractual basis for the treatment of my withdrawal.
7. Spinsy’s own latest response makes this a relatively straightforward issue to resolve
I believe the dispute can now be reduced to three straightforward questions.
First: Spinsy has confirmed that my July withdrawals did not restrict or delay my August withdrawals.
I accept that clarification.
Second: Spinsy has confirmed that my 17 and 18 August withdrawals were completed and sent on 18 August.
I also accept that clarification.
Third: The outstanding issue is therefore the reason and contractual basis for the processing time applied to my 12 August withdrawal.
That is the point I would like Spinsy to address.
8. I am not disputing Spinsy’s right to verify withdrawals
For the avoidance of doubt, I am not suggesting that Spinsy should be prohibited from carrying out KYC, AML, source-of-funds or other legitimate compliance checks.
I accept that such checks can be necessary.
Indeed, section 6.16 appears specifically designed to address circumstances where such checks are required.
My concern is simply that if Spinsy relies upon that provision, there should be some factual connection between the provision and the particular withdrawal in question.
It would therefore be helpful if Spinsy could say something as simple as:
“Section 6.16 was/was not relied upon in relation to the 12 August withdrawal.”
If it was relied upon, please identify the nature and duration of the relevant check.
If it was not relied upon, then please identify what other contractual provision governed the processing period.
9. I also note the significance of Spinsy’s statement that the August withdrawals were completed on 18 August
Spinsy has now confirmed that withdrawals submitted on 17 and 18 August were completed and sent on 18 August.
I appreciate that.
However, that also demonstrates why it is important to distinguish between a withdrawal being submitted, being approved, being released for payment, and ultimately being sent.
For the 12 August withdrawal, I would therefore appreciate the following information:
* date and time submitted;
* date approved;
* date released to the payment provider;
* date actually sent;
* whether any verification hold existed between submission and approval; and
* if so, the contractual provision relied upon.
This would provide a factual timeline rather than simply a general statement that the withdrawal was processed.
10. I believe this is a reasonable request for clarification
I want to stress that I am not trying to manufacture a dispute where one does not exist.
I am pleased that the withdrawals have now been completed and sent, and I appreciate Spinsy’s clarification regarding the July payouts.
However, a successful eventual payment does not necessarily answer the question of whether the time taken to process an earlier withdrawal was contractually justified.
Likewise, Spinsy’s statement that the July payouts were not used to restrict August withdrawals is helpful, but it means that explanation can no longer account for the delay to the 12 August withdrawal.
I therefore respectfully ask Spinsy to provide a final, specific response to the following:
1. What was the actual reason for the delay to the 12 August withdrawal?
2. Was section 6.16 relied upon in relation to that withdrawal?
3. If yes, what verification or review was undertaken and when was it completed?
4. If no, what contractual provision governed the processing period?
5. When was the 12 August withdrawal approved?
6. When was it released to the payment provider?
7. When was it sent?
8. Was the withdrawal within the applicable withdrawal limit at the time it was submitted?
9. What VIP level was recorded on my account during the relevant July periods, and what withdrawal limit applied at those times?
10. How was my Level 5 status reflected in the July withdrawal-limit calculation?
I believe these are reasonable questions and, importantly, they can be answered without any disclosure of confidential internal information.
I am simply asking Spinsy to explain the factual and contractual basis for what happened.
I also want to acknowledge that Spinsy’s latest response has clarified one important point: the July withdrawals were not used to delay or restrict my August withdrawals. I appreciate that clarification and consider that part of the matter resolved.
What remains is the original question concerning the processing delay itself.
I hope Spinsy can now provide a clear answer to that point so that this complaint can be brought to a satisfactory conclusion.
Thank you again for your cooperation.
Kind regards,
Neal
