No its not, it states up to 20 royal spins, where does it state the other spins are 20p in the first 4 lines? Plus '20 royal spins' in bold but nothing about the 20p ones in bold or anything. Where else does it state the spin value apart from in the T&C's?
As I said, I imagine most on here would know, but I will bet a lot of casual players see royal spins and free spins mentioned and think they are the same.
Ok It's in big bold letters underneath and then says in big bold letters 20 Royal spins and explains what they are and how much you need to deposit.
Might catch a few players out, but your painting it as a deliberate ploy to fleece people.
But all the info is still in the first paragraph.