Αρχική ΤΕΧΝΙΚΕΣ ΠΡΟΔΙΑΓΡΑΦΕΣ ΔΙΟΡΓΑΝΩΣΗΣ ΚΑΙ ΔΙΕΞΑΓΩΓΗΣ ΤΥΧΕΡΩΝ ΠΑΙΓΝΙΩΝ ΜΕΣΩ ΤΟΥ ΔΙΑΔΙΚΤΥΟΥΆρθρο 16 – Σύστημα Αναφορών (Reporting)Σχόλιο του χρήστη The Stars Group | 4 Φεβρουαρίου 2019, 11:14
  • Σχόλιο του χρήστη 'The Stars Group' | 4 Φεβρουαρίου 2019, 11:14

    (a) In paragraph 1, it is not specified whether the respective reports shall be saved, each time, on the vault or not. Moreover, the licensees’ obligation to provide reports (“written documentation”) on the HGC’s demand is very vague both in terms of the format of HGC’s request and the means of submission of the respective reports. Those points shall be clarified, so that licensees may respectively comply with such requirements. (b) In paragraph 2, the elements of the respective report refer exclusively to actions or data which are done or created only if the player is online. However, there are actions or data (related to a session) which are done or created when the player is offline (e.g. promotional credits received). In that respect we propose either to clearly exclude such “offline” actions or data (i.e. those created when the player is not logged in) or to change the basis of the reporting from “session” to “daily” basis. (c) In paragraph 2, it also unclear whether the figure of a player’s account balance shall include (or not) non-cash assets (e.g. won tickets for participation in poker tournaments etc.). This point shall be clarified. (d) In paragraph 4, the licensees’ obligation to provide data, yet with the exclusion of amounts originated from promotions, is technically problematic. We propose to change the respective reporting requirements either on the basis of game winnings or, alternatively, on the basis of account balance changes and the changes in in-play money. (e) In paragraph 5, the reporting requirements are too detailed and would impose important technical issues for the licensees. We propose to limit the required data to only those which are indeed important for auditing purposes. (f) In paragraph 7, as regards the requirement for reporting “repeated failed attempts to log into the system”, this is something that is not requested by any gaming regulatory authority and serves no purpose. We, thus, propose to delete it. Moreover, the terms “Significant periods of time when the interactive gaming system was unavailable or any component thereof was unavailable (e.g. failure to process a transaction)”, “System voids, overrides and corrections”, “Mandatory deactivation of an authorized player”, “Any other activity that requires the intervention of employees and occurs outside the normal scope of the system’s operation” and “Other significant or unusual events” (i.e. points “b”, “e”, “f”, “g” and “h”) are very vague and shall be defined. (g) In paragraph 8, the term “change in the system” is very vague. We propose that this shall be clearly defined and limited to changes which are indeed significant for auditing purposes. (h) In paragraph 11, the terms “Total amount of prizes per type of promotion”, “Total adjustment amount per type of promotion” and “Total amount per type of promotion” (i.e. points “b”, “e” and “f”) are vague and have to be defined. (i) In paragraph 14, it is not clear whether the reporting refers to a licensee’s overall bonus activity or to a specific player. It is also unclear whether the total amounts under this paragraph 14 shall match with the figures related with the promotional account summary (as provided in paragraph 11). If positive, then the draft regulation should provide the ability to provide such data in the context of paragraph’s 11 summary. (j) In paragraph 15 (“upcoming events report”), the requested information is very vague. Definitions and / or examples shall be provided. (k) In paragraph 16, it is unclear whether the reporting requirement refers to both completed and in-progress tournaments. If both shall be included in a report, then this would result in a specific tournament appearing in several reported periods. We propose to clarify that the reporting refers only to completed tournaments.