This policy applies to applications which are operated by Daub Alderney Limited (‘Daub’) (Bailiwick of Guernsey) which is a company registered in Alderney and licensed by the Alderney Gambling Control Commission (AGCC) and by the UK Gambling Commission (UKGC) to provide its online gaming products and services to its customers. Daub is a data controller and is registered with the Office of the Data Protection Commissioner in the Bailiwick of Guernsey.

Daub is part of The Rank Group Plc group of companies (‘Rank Group’) which operates gaming venues in Europe and digital gaming sites, including the Bella Casino, Enracha, Grosvenor Casino, Luda Bingo and Mecca Bingo brands.

For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ means Daub Alderney Limited (‘Daub’) (Bailiwick of Guernsey) and ‘you’, ‘user(s)’, ‘customer(s)’, ‘player(s)’, ‘individual(s)’ or ‘data subject(s)’ means the data subjects about whom we process personal data. We respect the privacy of all our customers and visitors and are committed to processing personal data in a transparent, accountable and consistent way.

In order to provide our products and services to our customers we need to process personal data about them. The processing activities that we may carry out in relation to your personal data include requesting it, collecting it, storing it, analysing it and sharing it.

Please read this Privacy Policy carefully. This Privacy Policy explains how we process personal data. It also explains the rights of individuals or data subjects about whom we process personal data. Any questions about personal data processed by us should be directed to our Data Protection Officer.

In this Privacy Policy we provide information on the following:

  • Collection of Personal Data
  • Collection of Special Categories of Personal Data
  • Legal Reasons for collecting Personal Data
  • Consent and the Withdrawal of Consent
  • Use of Information Collected
  • Marketing
  • Data sharing
  • Automated Individual Decision Making and Profiling
  • International data transfers
  • Information technology and data security
  • Public forums
  • Child safety
  • Retention of personal data
  • Your rights
  • Exemptions to data subject rights
  • Cookies and pixels
  • How to contact us


    Personal data is information about you and that identifies you or may reasonably identify you (in conjunction with any other information that we hold about you) for example, your name, e-mail address, address or telephone number, IP address, copies of ID, proof of address, etc.

    The personal data that we may collect and process includes information within the following categories:

    Personal data collected directly from data subjects:
    • Registration Details: we will collect personal data from you when you register with us, for example, first and last name, email address, gender, birth data (date and place of birth), physical address, country of residence, city of residence, email address, phone number etc.;

    • Payment Information: for billing arrangements payment information may be collected from you, such as your currency, bank account details, e-wallet details, PayPal account, Pay by Mobile etc.;

    • Identity and verification information: due diligence documentation including passport, identity card, bank statement, driving licence, utility bill, photograph, occupation etc. We may also ask for additional information regarding account funding and your affordability;

    • Communications: communications you have with us by telephone, via email or on chat features, in games, competitions, promotions or surveys, when submitting queries, and when you report any user problems etc. This will include information which you provide to us on a voluntary basis.

    Personal data collected from your use of our websites:

    We will automatically collect information from you each time you visit or otherwise use our websites. This includes:

    • Technical and Device Information: We may collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as a device’s unique identifiers, IP address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and geolocation data (to comply with our anti-money laundering policy). We use Google Analytics and abide by the Google Analytics Terms of Service and are subject to the Google Analytics Policies;

    • Gaming and account transactions: transactions, wins, wagers, deposits, withdrawals, bonuses, balances, bets etc. We also collect information from your patterns of transacting across our platforms and use this information, as required by applicable gambling/gaming legislation, in order that we may identify gambling problems or addictions and to ensure that we maintain a responsible gaming environment; and

    • Social networks: registrations made through social network accounts (such as your Facebook account), will give us access to basic information from your social network account, such as name, date of birth, profile picture and friends list, as well as information that you make publicly available on such an account.

    Personal data collected from other sources:

    Occasionally, we may be provided with or request the provision of personal data by or from a third party or alternative source which is not the data subject. Examples include:

    • Verification data: information in order to verify the identity of a data subject in order to prevent fraudulent or illegal activity;

    • Service providers: personal data about a data subject from other sources including third party service providers of risk intelligence and other platform providers. Our providers may check the details we supply against any particulars on any database (public or otherwise) to which they have access. They may also use your details in the future to assist other companies for verification purposes. A record of the search will be retained;

    • Credit agencies: information about a data subject’s credit history from credit agencies (but never full credit card information) and other financial information; and

    • Open-source: open source and publicly available sources such as the internet and social networks.


    Special categories of personal data are specific categories of personal data related to a person’s profile: race or ethnicity; political, religious or philosophical beliefs; sexual life or sexual orientation; health; genetic or biometric data; or trade union membership.

    We process the following Special Categories of Personal Data:

    • Health data

    We may process these special categories of personal information in order to comply with any legal, regulatory and social protection obligations to which we are subject.


    We process personal data for a number of legal reasons or grounds which may include:

    • for the performance of our contract with you: for example, to set-up and register, manage and operate your account, to verify your identity and process payments;
    • the exercise of rights or obligations conferred on us, or the performance of or compliance with duties imposed on us, by applicable laws and regulations (for example, where we must assist the relevant authorities with the prevention, detection and investigation of crime, and where we are obliged to do so by the terms of our regulatory licences;
    • compliance with due process in connection with legal proceedings, the taking of legal advice or otherwise in connection with legal rights; and
    • for the furtherance of our legitimate interests in delivering customer focused and personalised content to our players and generally improving the content and delivery of our products and services.

    Where the processing of personal data about you is necessary for the furtherance of our legitimate interests, that processing is conditional upon those legitimate interests not being overridden by your interests or by your fundamental rights and freedoms. You are entitled to request information from us concerning the decisions that we may have made to process your personal data for the purposes of our legitimate interests.


    There are cases where in order to process your personal data, we need your consent to do so. However, we are under legal and regulatory obligations to obtain certain personal data from you before we can provide our products and services to you. Accordingly, while you may not be obliged to provide us with your personal data, if you do not do so, we may be unable to provide you with products and services.

    Where the legal basis for processing personal data about you is your consent (for example, to send you marketing materials), then you may at any time withdraw your consent by contacting the website support centre for the application(s) concerned, by changing the settings in your account or changing the settings of your cookies. Where you withdraw your consent for us to process personal data about you, we may not be able to provide you, or continue to provide you, with certain products and services.

    Where you have not provided consent and/or have withdrawn your consent to certain processing activities (for example, marketing activities) we may need to continue to process your personal data for other legal reasons which may include: other aspects of performance in relation to the contract between us, for a legitimate interest, or in connection with legal or regulatory obligations to which we are subject.


    We use personal data for the following purposes:

    • to register user accounts;
    • to update user accounts and perform business and administrative activities that support the maintenance of those accounts;
    • to provide users with access to the games and services available on our platforms;
    • to identify and authenticate user access to certain features for example, restricted access products and services on the platforms;
    • to communicate with our users and keep them informed of our latest services, updates and special offers;
    • to enhance user experience of our products and services and to continually improve those products and services;
    • to provide a responsible gaming environment to our users including monitoring to detect patterns of behaviour (for example, play, deposits and other variables) that may be an indication of problem gambling;
    • to collect monies, to allow you to place deposits and wagers, to enable withdrawal of funds;
    • to send you notifications about operational requirements, technical service issues, security issues, account balance information and promotional information;
    • to respond to queries, requests, complaints and provide customer support services;
    • for marketing analysis and to market our service including to provide you with promotional update communications by email, post, telephone, direct messaging, direct mail and other digital channels (pop ups, push notification, banner advertising, etc.) about our products and services, promotional materials, as well as products, services, websites and applications which relate to products and services from companies within the Rank Group which we believe may interest you;
    • to understand customer needs and preferences in order to provide bespoke offers to our customers;
    • to process any requests for information;
    • to investigate and resolve disputes concerning our services;
    • to comply with the conditions of our regulatory licences and with other regulatory and/or legal requirements;
    • to conduct credit searches;
    • to improve user experience through data collected through analytics;
    • to carry out customer due diligence;
    • to ensure that the quality and accuracy of the data we process;
    • for monitoring user activity on the platforms in order to help us develop the platforms and the services offered on them;
    • to detect and prevent fraudulent, otherwise illegal or anti-social activities;
    • to investigate violations of our policies and user agreements;
    • to prevent money laundering and to prevent the financing of terrorism; and
    • where otherwise required to do so by law, regulation or other binding authority.
    • Research and statistical analysis


    Subject to customer consent, we share personal data with carefully selected third parties engaged in the business of providing marketing and promotional services. We do this in order to improve customer experience of our products and services, to make additional and promotional products and services, to develop new and improved services, and to offer promotions and rewards.

    Where you have provided your consent to further marketing activities you may receive advertisements and other promotional materials about the products and/or services of third parties which may be of interest to you. In order to ensure that we offer our users carefully selected additional products and services we use data analysis techniques, including profiling, in order to analyse your age, location, playing patterns and behaviour, preferences and interests. The conclusions that we make, having undertaken such customer analysis, enables us to ensure that you receive marketing, promotional and other additional material which is uniquely tailored to you.

    You may at any time object to and/or withdraw your consent to the any further marketing activities by checking and updating your contact details within your account or selecting the ‘unsubscribe’ link at the end of our marketing and promotional update communications to you, or by contact us. If you decide to withdraw your consent for the use of your personal data for marketing purposes, we will cease to process personal data concerning you for such purposes.


    The sharing of personal data about our customers between entities within the Rank Group is governed by a binding corporate agreement pursuant to which all members of the Rank Group have agreed to adhere to the standards of GDPR.

    We may share personal data with other entities or third parties but will only do so in the circumstances described in this privacy policy and where the third parties concerned have agreed to adhere to the standards of GDPR. We will only provide these third parties with the specific information that they require in order to provide the services for which they are being engaged and they will be prohibited from using that information for any other purposes. When third parties have access to your personal data, we also require that they protect the confidentiality of your personal data. These third parties may include:

    • organisations providing website and data hosting services, storage and hosting providers, cloud provision services, fulfilment services, communications distribution services, marketing lists and support services, feedback services, IT support services, marketing and promotional services, including events services, promotional and advertising etc.;
    • credit reference agencies for the purpose of assessing credit scores where this is a condition of us entering into a contract with a customer, user verification and authentication services providers, and fraud prevention service providers and chargeback investigation providers;
    • payment processing providers who provide us with secure payment processing services and related banking services;
    • research, data analysists, technical and diagnostic services;
    • services concerned with maintaining responsible gaming practices;
    • accountants, auditors, lawyers, other experts and other professional service providers; and
    • licensing authorities, governmental and regulatory bodies if required to do so by law or regulation in connection with the licences under which we conduct our gaming business.

    We may also be required to disclose personal data in certain circumstances which may include:

    • where we are required to do so by a court of law in connection with legal proceedings;
    • where we are required to do so by regulatory and/or supervisory authority in connection with any aspect of the regulated environment in which we conduct our online gaming services (such as law enforcement agencies, government agencies, the controllers of public registers, other regulators and supervisory bodies);
    • where we are required to so protect our legal rights and/or enforce our legal obligations for example, to our customers, employees and to members of the public;
    • in the event of an insolvent situation; and
    • in connection with a sale of or investment in one or more of the companies within the Rank Group, or a restructuring, refinancing, consolidation, dissolution or other corporate procedure concerning all or part of the Rank Group.


    Automated individual decision making refers to a decision made solely on the basis of automated processing of your personal data, without human involvement. Profiling is defined as automated processing of personal data to evaluate certain things about an individual.

    We conduct automated decision making to verify your identity before we allow you to play on our game sites. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between you and us; or is not based on your explicit consent.


    The Rank Group operates globally. The sharing of personal data about our customers between entities within the Rank Group is governed by a binding corporate agreement pursuant to which all members of the Rank Group, regardless of their geographic location, have agreed to adhere to the standards of GDPR. We need to transfer personal data within and between the Rank Group in order to provide and support the products and services that we provide to our customers.

    It is the case that some countries outside of the European Economic Area (‘EEA’) may not protect personal data to standards equivalent to those applicable under GDPR. Where we need to transfer personal data outside of the EEA, we will take all appropriate steps to ensure that personal data is transferred only where subject to appropriate safeguards which are designed to ensure the protection of personal data and the enforceability of personal data rights. We will, for example, seek to rely on a recognised legal adequacy mechanism, on a binding and enforceable instrument or to transfer only on the basis of standard data protection clauses.


    All personal data held by us is stored on secure servers. We use strict procedures and security features to maintain the security of our systems and the personal data and other information stored in them. We take cyber-security very seriously and implement multiple different layers of physical and technological controls to prevent unauthorised access and to ensure data security, integrity and privacy. Systems and controls include, but are not limited to:

    • firewalls, network segmentation, anti-malware scanning, intrusion detection and prevention systems;
    • penetration testing and vulnerability management and remediation;
    • security events and incident management program through a 24/7 security operations centre;
    • encryption for sensitive data in transit and at rest;
    • strict access controls and authentication procedures;
    • regular cyber-security audits;
    • TLS encryption for payment transactions; and
    • use of ISO27001:2013 accredited hosting and co-location facilities.

    Where we have given you (or where you have chosen) a password which enables you to access certain parts of our applications you are responsible for keeping your password(s) confidential. We will never ask you to disclose your password to us and we would ask you not to share your password with anyone.

    Our websites may contain links to external or third party websites. We are not responsible for content of such websites. You should carefully read the privacy policies and the terms of use for third party websites and/or services that you wish to visit or use particularly before providing any of your personal information to them.


    The websites contain places that are public such as chat rooms, message boards, news groups and/or other forums. Any information that you disclose in these areas becomes public information. You should therefore exercise caution when using these public areas and avoid posting any personal data on them. Any information that you communicate in these public places may be viewed and utilised by third parties, for example to send you messages, to send you advertising or for any other purposes. We are unable to control the activities and behaviours of third parties in public areas. Accordingly, if you disclose personal data in public spaces, you do so at your own risk. We recommend that you review the privacy policies of any relevant third parties before disclosing your personal data on their websites or platforms.


    Protecting the safety of children when they use the internet is important to us. Our websites are intended for use only by persons who are at least 18 years of age. By using the products and services available on the websites you confirm to us that you meet this minimum age requirement. If you are not at least 18 years old, then you should not use any of the products or services that we offer nor provide us with any of your personal data. We may verify personal data provided by you. If we are unable to verify minimum age of 18 years, we will deal with any information, including personal data that has been provided to us in accordance with applicable legal and/or regulatory obligations. If you have reason to suspect that a minor has transacted with us, please contact us.


    We retain personal data for as long as necessary for the purpose(s) for which the personal data was collected. For example:

    • for as long as you have an account with us, we need to retain your personal data in order to meet our contractual obligations to you;
    • to comply with our licence conditions and any other regulatory and legal requirements;
    • for a period after termination of a customer relationship with us in order to comply with ongoing legal and regulatory provisions (such as employment law and tax law); and
    • where there are compelling legitimate grounds to do so.

    We may retain aggregate information for longer periods in order to conduct market research and to help us to continue to develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

    Periodically we review the personal data that we hold on all of our customers in order to ensure that we are not retaining it for any longer than is necessary.


    GDPR provides data subjects with a number of rights. We are significantly invested in protecting data subject rights and upholding the protections of GDPR. A data subject about whom we hold personal data may approach us at any time to request to review the personal data that we hold in relation to them, ask us to amend it, request that we erase it, ask us to cease using it, or request that it be transferred to another party. In summary, your rights in relation to your personal data may include the following rights:

    • to receive confirmation as to whether we are processing personal data about you;
    • to access the personal data about you held by us;
    • to be informed of the legal bases for the processing of your personal data by us;
    • to withdraw your consent to any processing of your personal data based solely on your consent;
    • to be informed of the recipients of any personal data that we have shared outside of the Rank Group;
    • to be advised of any retention periods applicable to the storage, by us, of your personal data;
    • to request the rectification of inaccurate personal data, to have incomplete personal data about you completed, or the erasure of your personal data if it is no longer required by us;
    • to restrict our processing activities in relation to your personal data;
    • to be advised of the source of personal data that we hold on you, where you are not the direct source of that personal data;
    • to have your personal data transferred to another controller, where technically possible, by automated means;
    • to object to the continued processing by us of your personal data;
    • the right to object to the processing of personal data which is based on the legitimate interests of the Rank Group; and
    • information on any profiling or automated decision making undertaken by us in relation to your personal data.

    Any data subject who wishes to exercise rights under GDPR in relation to Daub should send their request to our Data Protection Officer in writing.

    We will deal with your request within one month of receiving it, save that in certain circumstances we have the right to seek an extension to this period, and free of charge (unless your requests are for some reason repetitive, unfounded or otherwise excessive).

    Where a data subject has reason to make a complaint in relation to the Daub’s processing of their personal data or the protection of their data protection rights, they may make a complaint, in writing, to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

    GDPR provides for a data subject who has reason to complain about the handling of their complaint by a data protection authority to appeal to court where specified grounds exist.


    There are circumstances where certain data rights may not be applicable. These circumstances may include cases where to apply a data subject right may conflict with other legal obligations. For example, your right to erasure of personal data may not be applicable where we are under an obligation to retain the personal data concerned in order to comply with applicable legislation or regulation, to comply with a legal or a licensing requirement or in connection with legal proceedings. Further, we may be able to demonstrate compelling legitimate grounds for the processing of your personal data which override your personal data rights.


    If you would like to contact us with any queries or comments concerning data protection, our contact details are as follows:

    Data Protection Officer
    Daub Alderney Limited
    Turing House
    St Peter Port
    GY1 1XN
    Telephone: 0845 565 2059


      When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. Cookies are small text files containing small amounts of information which are downloaded on your device when you visit a website. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies.

      Cookies set by the website owner (Us) are called "first party cookies". Cookies set by other parties are called "third party cookies". Third-party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

      Why do we use cookies?

      There are different types of cookies. Some cookies are "strictly necessary" which enable you to access and use our entertainment services.

      We also use functional, performance and advertising cookies to make your experience more enjoyable. You can switch these on or off at any time and you can always change your mind. We’ll only use them if you have agreed to them.

      The last type of cookie which may be used are those from other companies. These "third-party cookies" might track how you use different websites, including ours. For example, you might get a social media company’s cookie when you see the option to share something. You can turn them off, but not through us.

      How long do cookies last?

      Some are erased when you close the browser on your website or app. Others stay longer, sometimes forever, and are saved onto your device so that they’re there when you come back.

      We use the following types of cookies:

      Cookie typeDetermined byHow to refuse
      Strictly necessary cookies:

      These are cookies that are required for the operation of our websites and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our websites, use a shopping cart or make use of e-billing services.
      These are first-party cookies set by us.Because these cookies are strictly necessary to deliver the Website to you, you cannot refuse them.

      You can block or delete them by changing your browser settings as described below under the heading "Disabling cookies".
      Functionality Cookies

      These are used to recognise you when you return to Our Site. This enables us, subject to your choices and preferences, to personalise Our content, greet you by name and remember your preferences (for example, your choice of language or region).
      These are first-party cookies set by us or third-party cookies (such as Google).To refuse these cookies, please follow the instructions below under the heading "How can I control cookies?"
      Analytical/performance cookies:

      These cookies allow us to monitor traffic on our websites, to recognise and count the number of visitors and to see how visitors move around our websites when they are using them. These cookies help us to continually improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
      We use Google Analytics for analytics cookies. This is a third-party cookie.To refuse these Cookies, please follow the instructions below under the heading "How can I control cookies?"

      For more information about how Google uses cookies and how you can manage your Cookies, please click here:
      Targeting/advertising cookies:

      These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests

      Subject to your consent, we may share this information with third parties for this same purpose. We may also work with advertising networks that gather information about the content on those of our websites that you visit and on information on other websites and services you visit. This may result in you seeing advertisements on/or through our websites or our advertisements when you visit other websites and services of third parties which we believe may be of interest to you. For more information about how to turn this feature off see below or visit
      These are first-party cookies set by us or third-party cookies (such as DoubleClick which is owned by Google).To refuse these Cookies, please follow the instructions below under the heading "How can I control cookies?"

      For more information about DoubleClick and how you can manage your Cookies, please visit Google’s cookies page at

      How do I control my cookies and tracking?

      When you visit us for the first time we will ask you if you wish to accept the cookies we use.

      You can choose whether or not to accept cookies by activating a setting on your browser which allows you to refuse the setting of cookies. If you choose to reject cookies, you may still use our Website however access to some functionality and areas of our Website may be restricted.

      You can learn more about cookies by visiting which provides useful information on cookies and further information on how to block cookies using different types of browser or mobile device. You may also find the following links helpful:

      • (contains information about cookies on a wide variety of desktop browsers.)
      • Cookie settings in Internet Explorer
      • Cookie settings in Firefox
      • Cookie settings in Chrome
      • Cookie settings in Safari
      • Cookie settings in Edge

      Please note, however, that by blocking or deleting cookies used on the platforms, you may not be able to take full advantage of the products and services that are on offer.

      What about other tracking technologies?

      Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Website (or opened an email that we have sent them). This allows us, for example, to monitor the traffic patterns of users from one page within our Website to another, to deliver or communicate with Cookies, to understand whether you have come to our Website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on Cookies to function properly, and so declining cookies will impair their functioning.

      Google Analytics

      This Website uses Google Analytics, a web analysis service from Google Inc. ("Google"). Google Analytics uses cookies or text files. These are saved on your computer and allow your usage of the Website to be analysed. The information generated by the cookie about your usage of this Website is generally sent to a Google server in the USA and saved there. However, if IP anonymisation is activated on this Website, your IP address is shortened by Google within the member states of the EU or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this Website to evaluate your usage of the Website, to compile reports about the Website activities and to perform further services connected to Website usage and Internet usage in its dealings with the Website operator. The IP address sent by your browser as part of Google Analytics is not combined together with other data by Google.

      You can prevent these cookies from being saved by making an appropriate setting in your browser software. However, you may then not be able to use all the Website’s functions to their full extent.

      You can also prevent the data (incl. your IP address) generated by the cookie and related to your usage of the Website from being sent to Google and processed by Google by using the above-mentioned opt-out links. More information is available at


      We use pixel-based tracking to track a visit or event on the Platforms and to track advertisement.

    This Privacy Policy was last updated on 3 April 2020