Freerolls in Belgium

[zyklon0]

Hi,

As a player from Belgium I don't have access to supermoon freerolls, is this normal? My loyalty level should be high enough.

On this page https://www.unibet.com/poker/unibetpokerloyalty I can find this sentence:

• Players from Sweden, Belgium and Germany are excluded from earning monetary rewards in the Unibet Poker Loyalty System due to restrictions of local gaming legislation. Please see country specific client for details.

Is a Freeroll considered a "monetary reward" as well?

Regards

Gert

[zyklon0]

According to this topic, the freerolls are considered non-monetary rewards

 

[Stubbe-Unibet]

7 hours ago, zyklon0 said:

According to this topic, the freerolls are considered non-monetary rewards

 

You'll have to explain how you got to that conclusion 🙂 if freerolls pay prizes of monetary value, they are monetary rewards 

[zyklon0]

6 hours ago, Stubbe-Unibet said:

You'll have to explain how you got to that conclusion 🙂 if freerolls pay prizes of monetary value, they are monetary rewards 

In the topic where you go over the new loyalty system, you talked about the freerolls in the section about “non monetary rewards”. I understand that they have some value but since the entrance fee is was hoping that they really were considered non monetary. Is it kind of a gray area or is it black or white 100% monetary?

[zyklon0]

I did an inquiry with the belgian gaming commission (kansspelcommissie). I asked if awarding freeroll tickets as part of a loyalty system is allowed or not in belgium. 
I got a very simple reply from them: “this is not forbidden”. So according to belgian law, you can give freeroll access to belgians as well. 
So my question remains why unibet chooses not to do this?

[Stubbe-Unibet]

On 6/11/2022 at 6:29 AM, zyklon0 said:

In the topic where you go over the new loyalty system, you talked about the freerolls in the section about “non monetary rewards”. I understand that they have some value but since the entrance fee is was hoping that they really were considered non monetary. Is it kind of a gray area or is it black or white 100% monetary?

I see. Understand how it can be confusing. Not really meant to be part of that section.

43 minutes ago, zyklon0 said:

I did an inquiry with the belgian gaming commission (kansspelcommissie). I asked if awarding freeroll tickets as part of a loyalty system is allowed or not in belgium. 
I got a very simple reply from them: “this is not forbidden”. So according to belgian law, you can give freeroll access to belgians as well. 
So my question remains why unibet chooses not to do this?

Loyalty rewards of monetary value are not allowed from what I know - there's a reason no one is doing them (to my knowledge). A reply from someone at the gaming commission, to a consumer, doesn't change anything in this regard. We do not have a way to confirm whether specific promotions or incentives are compliant. It's about interpretation of the legal texts and we generally don't gamble here but play it safe.

[zyklon0]

3 minutes ago, Stubbe-Unibet said:

I see. Understand how it can be confusing. Not really meant to be part of that section.

Loyalty rewards of monetary value are not allowed from what I know - there's a reason no one is doing them (to my knowledge). A reply from someone at the gaming commission, to a consumer, doesn't change anything in this regard. We do not have a way to confirm whether specific promotions or incentives are compliant. It's about interpretation of the legal texts and we generally don't gamble here but play it safe.

I understand that this is way too less to change your mind about this. But I did some digging in legal texts as well and there is no where any indication of this being illigal. “Being on the safe side” would mean that you dont do it for any country. But for some reason Belgium is explicitely held out of this reward system. There must be then some law here which Unibet interprets that it is forbidden here. A reasoning like that is something I could completely understand. Do you know, or can I inquiry somewhere, on which Belgian law this is based? Because, based on my research and inquiry, I dont think such a law/royal decree exists. It would be rather unfair too exclude people based on nationality without a reason for it?

[Stubbe-Unibet]

8 minutes ago, zyklon0 said:

I understand that this is way too less to change your mind about this. But I did some digging in legal texts as well and there is no where any indication of this being illigal. “Being on the safe side” would mean that you dont do it for any country. But for some reason Belgium is explicitely held out of this reward system. There must be then some law here which Unibet interprets that it is forbidden here. A reasoning like that is something I could completely understand. Do you know, or can I inquiry somewhere, on which Belgian law this is based? Because, based on my research and inquiry, I dont think such a law/royal decree exists. It would be rather unfair too exclude people based on nationality without a reason for it?

You should forget about it being a freeroll reward. It's in principle no different to €1000 cash reward for putting in x volume. It's a loyalty/volume based reward and these should be strictly banned in Belgium as far as I know.

Belgium together with Sweden have the most strict rules on rewards.

https://thelawreviews.co.uk/title/the-gambling-law-review/belgium

"A number of operators introduced requests for annulment of the Royal Decree of 25 October 2018. The Council of State in February 2020 partially annulled the Royal Decree on two aspects: (1) the possibility for online operators to offer bonuses has been removed entirely so that bonuses for online gambling and betting are considered illegal; and"

 

[zyklon0]

Thank you, that was clear information. I looked up the passage and i found this:

https://www.gamingcommission.be/sites/default/files/2021-02/20-02-19 - Informatieve nota nr 14.pdf

Bijgevolg is het voor de houders van een aanvullende vergunning verboden om gratis speldeelnames of bonussen in enigerlei vorm aanbieden. 

translated: therefore it is forbidden for regulated instances to offer free game participations or bonusses in any form. 
 

which indicates indeed a clear no-no. I passed this on to the gaming commission because it contradicts their answer to me.

 

 

[zyklon0]

@Stubbe-UnibetI finally got a response from the gaming commission:

”De regelgeving rond bonussen is zeer onduidelijk, daar niet is gedefinieerd wat precies onder bonus mag/kan/moet worden begrepen.

In uw mail sprak u van deelname aan een gratis pokertoernooi waar u een kleine prijs kan winnen, hetgeen als het resultaat van een gratis spel kan worden beschouwd.

Niettemin oordeelde de Raad van State zeer recent dat het begrip bonus zeer ruim moet worden opgevat, en elk voordeel omvat dat aan een speler wordt toegekend om de deelname aan kansspelen aan te moedigen.

Dit heeft de operator ertoe aangezet om ook deze vorm van 'voordeel' niet aan de Belgische spelers toe te kennen. “

translated:

“

The law does not define well what should be understood as a "bonus". 

A poker freeroll can be considered a free game which can result in a small price. 

Nevertheless, recently the council of state has judged that the concept of "bonus" should be interpreted as broad as possible. And includes any benefit that a player receives to encourage participation in games of chance. 

The above judgement is what inspired the operator to exclude Belgian players from this type of benefit.”

 

So yeah, it seems like a gray area at best. I now understand the safe approach that Unibet takes on this issue. 

A legal way to make this available for Belgian players would be to take it out of the loyalty system for Belgium and give all Belgian players access, regardless of their loyalty level. Is this something that Unibet would consider? Since we are already excluded from the rest of the loyalty system and cannot get cashbacks, this would make it a bit more fair 😀

Regards

[Andy-Relax]

Stubbe is away for a little while so I'll fill in on this one 🙂

Regardless of what % of Belgian players could enter it, a freeroll with prizes that "encourage" players to play more is considered a bonus and should be excluded based on the text you posted.