The Deluxe App — Privacy Policy
Last updated: 13 September 2026
This policy explains how we use personal information under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 when you use The Deluxe App, including membership, rewards, wallet top-ups, venue information and food and drink ordering.
1. Who we are
The Deluxe App is operated by Palace Amusements, trading as Deluxe Bingo (“we”, “us” and “our”). We are the controller responsible for the personal information described in this policy.
- Postal address: Rotunda House, Unit H Concept Court, Shearway Business Park, Folkestone, Kent CT19 4RG
- Privacy email: headoffice@goddengaming.org
- Data Protection Officer: Jordan Godden, headoffice@goddengaming.org
Palace Amusements is responsible for app membership information. Where a venue is operated by a separate business, that business is responsible for the information it uses to provide its own services. Contact our privacy team for details of the operator responsible for your venue.
2. Information we collect
The information processed depends on the features you use:
- Registration and membership: your title, name, date of birth, telephone number, email address, postal address, chosen home venue, membership number or card details, and account identifiers.
- Account access: your password, verification information, login and session tokens, and information needed to link an existing membership or continue registration from a venue kiosk.
- Membership activity: your membership status, available offers, participation in promotional games, prizes, claims and redemptions.
- Wallet and payments: your wallet balance and information associated with top-ups and payments. Payment details entered in a hosted checkout are processed by the payment provider. The app’s native payment interface does not read the card-field values entered in that checkout.
- Food and drink orders: your membership number, selected venue table, delivery timing, items ordered and information you enter in the ordering service.
- Communication choices: your preferences for email, SMS, telephone, post and push notifications, and information you provide when contacting us.
- Technical information: notification and app-installation identifiers, network information such as IP addresses received by services the app connects to, and information needed to deliver content and operate those services.
We receive information directly from you, from your existing venue membership records, from kiosk registration or account-linking processes, and from services that support your payments, orders and membership activity.
The registration form requires identity, age, contact and account information to create your membership. If you do not provide required information, we may be unable to register you or provide the relevant service. Marketing choices are optional.
3. How we use information
We use account and membership information to register and authenticate you, maintain your details, show your digital membership card, link your venue account and respond to service enquiries. We use wallet, order and reward information to provide the services you request and administer offers and redemptions. Our legal basis for processing necessary to provide these services is performance of our contract with you.
We use information necessary to investigate misuse, protect accounts, resolve service problems and maintain reliable systems on the basis of our legitimate interests in operating and protecting the service. We consider the impact on your privacy when relying on these interests.
We use your communication details and preferences to send marketing where you have consented. You can withdraw that consent at any time.
Our customer data protection policy also covers statistical analysis, market research and improving the gaming experience. We use membership activity and customer feedback to understand how our services are used and improve them, relying on our legitimate interests in developing a useful and reliable service. We use anonymous or aggregated information where possible.
Where processing is required by law, we rely on legal obligation. These purposes include maintaining transaction records for accounting requirements and using identity and age information to meet applicable licensing requirements.
4. Marketing and push notifications
You can manage your marketing choices in Communication Preferences in the app or by contacting us. Withdrawing consent does not affect processing that was lawful before you withdrew it. Necessary account or service messages may still be sent.
We use Google Firebase Cloud Messaging and, on Apple devices, Apple’s push notification service. These services process identifiers used to route notifications to your app installation. Notification tokens may be associated with your member account.
Your device’s notification permission and your in-app marketing preference are separate settings. You can disable notifications in your device settings. Disabling their display does not itself delete your membership or all notification-related identifiers. Firebase may create an installation identifier or messaging token as part of initialising the service.
5. Maps, Apple Wallet and external services
The app displays venue locations using Apple Maps on iOS and OpenStreetMap map tiles on Android. Loading a map connects your device to the relevant provider, which may receive your IP address and information about the map requested. The current app’s venue maps do not use your precise device location. If you open an external maps app for directions, its use of location follows its own permissions and privacy policy.
If you choose to add your membership pass to Apple Wallet, the pass and its membership information are provided to Apple Wallet on your device. Removing the pass does not close your membership account.
Some features open hosted pages or other apps. Those services may process information under their own privacy notices, including when they act as separate controllers.
6. Who receives information
Information is provided to the organisations needed to operate the features you use, including:
- The relevant venue and staff handling your membership, orders, enquiries and reward redemptions.
- The provider of our Rotunda-hosted membership and app backend, for account administration, member content and related services.
- Sticky and the payment providers used by its hosted services, for wallet and food-ordering features.
- Google Firebase and Apple, for notification delivery and the Apple features described above.
- OpenStreetMap’s tile service, for Android venue maps.
- Hosting, content-delivery and technical support providers needed to operate the app.
- Authorities or professional advisers where disclosure is legally required or necessary to establish, exercise or defend legal claims.
Our membership technology supplier processes account data to support our service; our ordering and payment suppliers process the information needed to fulfil orders and payments. A supplier may also act as an independent controller for its own legal and regulatory obligations. Contact our privacy team for supplier details.
7. Device storage and cookies
The app stores account information and sign-in details, including credentials and session information, on your device to restore your session. It also stores settings such as notification-prompt and review-prompt history, and caches content such as images and map tiles.
Logging out removes the locally saved login and member-session information managed by the app. Other cached content or preferences may remain. Removing the app or clearing its data does not delete records held in our membership systems.
Embedded checkout and ordering pages may use cookies or similar storage to maintain sessions and process transactions. Essential cookies keep checkout and ordering sessions working. Where non-essential cookies require consent, the relevant hosted service asks for your choice. Details are provided in that service’s cookie notice.
This policy covers the app. Information about cookies and other processing on the website hosting this page is available at Website privacy and cookie notice.
8. International processing
Some technology providers may process personal information outside the United Kingdom. Where a transfer is subject to UK transfer rules, we use an applicable UK adequacy arrangement or appropriate safeguards, such as the UK International Data Transfer Agreement or UK Addendum to approved standard contractual clauses. You can contact our privacy team for details of the countries involved and a copy of the safeguards relevant to your information.
9. How long we keep information
We keep information for the period needed for its purpose, taking account of the life of your membership, outstanding transactions or disputes, applicable record-keeping obligations and the need to respect your marketing choices.
- Membership and account records: for the duration of your membership and up to 24 months after account closure, unless a longer period is needed for a specific legal obligation or unresolved dispute.
- Payments, orders, rewards and redemption records: up to six years after the relevant transaction or activity, subject to the applicable record-keeping requirement.
- Support enquiries and technical records: up to 24 months after an enquiry is resolved for support records, and up to 90 days for routine technical logs.
- Marketing consent and opt-out records: we keep consent records while relying on that consent and for a reasonable period afterwards to demonstrate compliance; retain a minimal opt-out record for as long as needed to avoid contacting you against your wishes.
- Notification identifiers and backups: we remove inactive notification identifiers within 90 days of identifying inactivity or account closure, and expire deleted information from routine backups within 90 days, except where specific retention is legally required.
10. Security
Our data protection policy requires appropriate technical and organisational measures to protect personal information, access limited to people who need it for their work, and secure disposal when information is no longer required.
The app connects to its membership backend using HTTPS. You should protect access to your device and keep your login details private. Contact us if you believe someone has accessed your account without permission.
11. Your rights and account deletion
Depending on the circumstances, you can ask us for access to your personal information, correction of inaccurate information, deletion, restriction of processing, or a portable copy of information you provided. Where we rely on consent, you can withdraw it at any time.
You can object to direct marketing at any time. You can also object to processing based on legitimate interests for reasons relating to your situation.
To exercise a right or request closure of your app account and deletion of its personal information, contact headoffice@goddengaming.org. We may need information to verify your identity. We will explain any records that must be retained and why. Closing an account may affect access to membership features, rewards and wallet services; outstanding balances or transactions will need to be addressed as part of that process.
You do not need to use a special form to request access to your information. We normally respond to rights requests within one month. Where the law allows extra time, such as for complex or numerous requests, we will explain the extension. Requests are normally free of charge; we only charge or refuse a request where the law permits, and will explain our reasons.
Deleting the app from your device does not submit an account-deletion request.
12. Automated decisions
We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Automated checks may support account access or offer eligibility. Contact us if you would like a member of our team to review an issue affecting your account.
13. Age restrictions
The Deluxe App is intended for people aged 18 and over. Registration requires a date of birth and rejects applicants under 18. If you believe a child has provided personal information through the app, contact us so we can investigate and take appropriate action.
14. Questions and complaints
Please contact headoffice@goddengaming.org with privacy questions or complaints. You also have the right to complain to the UK Information Commissioner’s Office. Information about raising a concern is available on the ICO website.
15. Changes to this policy
We may update this policy as our services or information practices change. The date at the top shows when it was last updated. We will bring material changes to your attention through an appropriate app or service communication.