I completely understand your point, and I appreciate you being honest with me. I also understand that, from a strictly responsible-gambling perspective, the fact that I only explicitly informed MyStake about my gambling problem on August 10, after the losses had already occurred, makes the claim more difficult.
However, I believe there are several other aspects of my case that may be relevant and go beyond the communication on August 10.
Within just 4 days, I made 19 deposits totalling approximately €14,000, with a very significant portion of that amount deposited on the final day. I am also registered with the RGIAJ, Spain's national self-exclusion register. I understand that such a high and concentrated volume of deposits, particularly considering my RGIAJ registration, could be relevant when assessing whether adequate responsible-gambling controls were in place and whether this activity should have triggered any warning or intervention.
I am also concerned about the way the payments were processed. The deposits were not all made directly under the MyStake name.
For the card payments, different merchant descriptors/names appeared, including Traski, Dkuepi and other names, rather than directly identifying MyStake.
On the other hand, the deposits made by bank transfer were channelled through UTORG PAY LTD, using a ClearBank Europe account. In other words, these transfers also did not appear as direct bank transfers to MyStake.
Furthermore, MyStake itself offered Revolut as one of the available deposit methods, alongside cards, Skrill, bank transfers and cryptocurrencies.
I believe the use of different third-party payment processors and payment channels may also be relevant when looking at how the deposits were presented to the customer and how the funds were ultimately channelled to the operator.
There is also a separate legal issue that I am currently trying to clarify with the DGOJ. Spanish Law 13/2011 regulates gambling activities in Spain and establishes the licensing requirements for operators offering gambling services to customers in Spain. My question is whether an operator without a Spanish licence was legally permitted to offer these services in these circumstances, and what the possible consequences could be regarding the validity of the gambling contracts and restitution of the payments.
I have also seen references to the possibility that gambling contracts with operators who are not legally authorised in the relevant jurisdiction may be considered invalid and that restitution of payments could potentially arise, although I fully understand that this is a legal matter and that you cannot determine whether it applies to my particular case.
Therefore, I am not asking you to tell me that I am definitely entitled to a refund. I would simply like to know whether, taking all these elements together — 19 deposits, approximately €14,000 in only four days, a particularly large amount on the final day, my RGIAJ registration, the use of different payment processors and the possible Spanish licensing issue — you think there is any aspect of the case that deserves further investigation, even if the traditional responsible-gambling route through Casino Guru is not particularly promising.
If you believe these issues should be dealt with exclusively through the DGOJ or a legal professional, I completely understand. I just want to make sure I am not overlooking a potentially relevant avenue for pursuing the matter.