Last Updated: August 30, 2019
- TYPES OF INFORMATION COLLECTED ABOUT YOU AND HOW IT IS COLLECTED
We and our service providers collect various types of information from and about you, including:
• “Personal information,” which is information by which you may be personally identified or contacted, including, for example, your name, email address, telephone numbers, company affiliation, title, physical address, screen names, credit card details (including the three or four digit security code on the back of your credit card), bank account or other payment information, credit information, birth date, driver’s license number, social security number, passport number, frequent flyer or other affinity program numbers, employment information, and any other information by which you may be personally identified. Personal information also may include information that may not be personally identifiable standing alone (for example, your age), but which may become personally identifiable when combined with personal information (for example, your age combined with your name).
• “Non-personal information,” which is information that is about you but which does not identify you individually and is not linked to any personal information, including: information regarding your computer, devices and Internet connection (such as your IP address, your computer or device type and its capabilities and features, your browser type, the operating system or platform you are using, your general geographic location, and the name and location of your Internet Service Provider), information regarding your use of our Website (including the referring page and the exiting website, clickstream data, the search terms you enter on the Website, your movement within and interaction with the Website, including what pages you look at, and the time, date, and duration of your visit to the Website) and traffic patterns relating to the Website. Non-personal information may include personally identifiable information that has been de-identified, or in other words, rendered anonymous. Non-personal information also may be aggregated with non-personal information about others.
We and our service providers may collect this information through various means, including: (a) directly from you when you provide it to us, for example, via forms that you fill out on the Website, through emails and other communications and information that you submit via the Website, and through your other activities on the Website; (b) automatically as you navigate through and interact with the Website, including via cookies, pixels, beacons, and other tracking technologies; and (c) from third parties, including without limitation our service providers.
- Information You Provide
The information we and our service providers collect may include the following types of information that you provide:
• Information you provide when you register for the Website, make a purchase, participate in a service or offering made available on the Website, or make a reservation, including without limitation your contact information (such as your name, address, email address, phone numbers), your company name, and title and address, your screen name or username, and your payment information (such as your credit card details, bank and bank account routing information, or other information);
• Your demographic information, such as your age, gender, marital status, number of children, and nationality;
• Your travel-related information, such as your frequent flyer number, airlines, rental car providers, passport information, and travel history;
• Information relating to your reservations, visit or stay at our Resort, including your arrival and departure dates, special requests made, spa and dining reservations, your guest preferences, vehicles you may bring to the Resort, and your transactions and purchases;
• Certain sensitive health information that you choose to share with us (such as allergy information or other health conditions that impact your guest preferences or special requests when visiting the Resort);
• Details about events or meetings that you plan with us, such as the date of the event, the guest list, and information about the guests at your event;
• Information you provide to sign up for the Club 52 Program (such as your name, email address, physical address, mobile phone number, gender, zip code, birth date, social media handles, and social blogs) and information needed to administer the CLUB 52 Program;
• Certain personal and sensitive information that you may provide online in connection with casino credit applications and gaming-related aspects and benefits of the CLUB 52 Program, including without limitation your social security number, certain financial information (including your bank and bank account information, your annual income, and other personal financial information), employment information and history, other credit information, and a copy of or the information from official government identification documents, including without limitation, a driver’s license, passport, or non-resident alien identification card for identity verification purposes;
• Information that you share in response to surveys and other market research;
• Information that you post to public areas on our Website, that you include in an email, general comment, or recommendation posted on or sent through on our Website, as well as records and copies of that correspondence (including email addresses);
• If you choose to log into the Website through social sign ins (such as Facebook Connect), information collected from your social media account consistent with your settings within the applicable social media service, such as photos, name, gender, contact information, and other information;
• Resumes and applications for employment at the Resort, including any personal and sensitive information that you provide therein;
• Your communications preferences; and
• Other personal information that you choose to provide to us.
Whether you provide this information is your choice; however, please bear in mind that in many instances personal information is required for you to participate in a particular activity, for us to provide a certain service or benefit to you, or for you to gain access to certain features, services, or content on our Website. If you elect not to provide us with certain personal information, you may not be able to participate in a particular activity, realize a benefit we may offer, or gain access to certain content, functionalities, or services.
- Automatically-Collected Information
When you visit and as you navigate through and interact with the Website, we, our service providers, and third parties may automatically collect information about your visits to our Website, your equipment, and your browsing action and patterns and your activities on the Website. This information may include, but is not limited to:
• Details of your visits to our Website and the resources that you access, such as traffic data, location data, logs and other communication data, the third-party website from which your visit originated, clickstream data, the search terms you use on our Website, your movement within and interaction with the Website, including what pages you look at, and the time, date, and duration of your visit to the Website.
• Information about your computer or devices and Internet connection, such as your IP address, your general geographic location, your computer or device type and its capabilities and features, the operating system or platform you are using, your browser type, and your Internet Service Provider.
• Information about traffic patterns, number of visits to certain pages, visits from other websites or to third-party websites linked to the Website, and visitors’ use of particular services and interest in services, information or features of the Website.
- Cookies and Other Tracking Technologies
We, our service providers and other third parties may place “cookies” on our Website to collect certain information. A “cookie” or “browser cookie” is a small data text file that can be stored on your computer’s hard drive or other device, if your web browser or device settings permit. Certain features of the Website also may use local stored objects (or Flash cookies) to collect and store information, including information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. Cookies may allow us and our service providers, for example, to customize your experience and make your visit to the Website easier (for example, recognizing when you return, remembering your viewing preferences, enabling social sign ins, facilitating social sharing, and, if you are a registered user, remembering your password), measure activity on the Website, track conversions, target ads, and provide analytics. While some cookies are deleted when you close your browser, others remain even after you close your browsing session.
We, our service providers and other third parties also may use pixel tags, web beacons or clear gifs, which are tiny files with a unique identifier, similar in function to cookies, that are placed in the code of a web page or an email. These technologies might be used, for example, to allow us and our service providers to track conversions, to send emails to you in a format you can read, to count users who have visited our Website, seen our ads, opened our emails or clicked on any links in our emails, to inform us what content and advertising is effective, to optimize the Website and its content, to reduce or eliminate messages sent to customers, to enhance Website usability, to provide you ads and other promotions and content that may be of interest to you, and to collect other information about you and your visit when you use the Website. In addition, when you click on a link in an email, we or our service providers may record the individual response to allow us to customize our offerings to you.
We and our service providers may analyze the information derived from cookies, pixels and other technologies and match or combine that information with data provided by you or another party. We engage various service providers who may use unique identifiers, cookies, pixels, beacons, and other technologies to provide analytics and to deliver you advertisements and content that may be of interest to you. To the extent that our service providers are using pixels, cookies, beacons, or other tracking technologies, we do not control the use of those technologies or the resulting information, and we are not responsible for the policies of those companies.
For more information on how to manage cookies, see http://www.allaboutcookies.org.
Please keep in mind, however, that you may not be able to access the full functionality of our Website if cookies are disabled.
- HOW WE USE YOUR INFORMATION
• To provide, track, and process the services, purchases and transactions that you request, including facilitating hotel accommodation, spa, dining, and entertainment reservations;
• To process enrollments and applications, including casino credit applications as well as registration in, the administration of, and the award and redemption of benefits under the CLUB 52 Program;
• To accommodate your preferences, to personalize and enhance your experience and the services provided to you at the Resort, and to improve the Resort and our services;
• To validate your identity, to verify communications from you, and to respond to your emails, submissions, questions, comments, requests for information, and complaints and to provide customer service;
• To manage, store and enhance guest data and preferences;
• To send you important notices, such as communications about purchases, programs you have joined, and changes to our terms, conditions and policies;
• To conduct customer satisfaction, market research or quality assurance surveys ;
• To conduct market research and to develop new services;
• To conduct and administer sweepstakes, prize draws and other contests;
• To record gaming-related activity;
• For marketing purposes, including without limitation interest-based advertising, other targeted promotions, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities;
• To send you marketing communications about the products and services offered by our property owners, marketing partners and other third parties, including without limitation offers regarding residential sales opportunities;
• To monitor, track, and analyze Website usage and trends, to personalize and improve the Website, and to increase the Website’s functionality;
• To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Website;
• To protect the security or integrity of our Website, the Resort, and business;
• To prevent fraud and other prohibited or illegal activities, to investigate and resolve disputes and problems, and to otherwise comply with applicable laws and regulations;
• For any other purpose that is disclosed to you at the point of collection of the personal information, for any purpose for which you provide your prior consent, in other ways naturally associated with the circumstances in which you provided the personal information, and for any other lawful purpose.
Every computer and device that is connected to the Internet is assigned an Internet Protocol (IP) address. When visitors request pages from our Website, our servers typically log their IP addresses. While we generally collect IP addresses for purposes of system administration, for Website optimization, Website security assessments, to report non-personal aggregate information to others, to track the use of our Website, and to get a sense of where our Website visitors are located, we reserve the right to use your IP address to personalize content on the Website and to identify you and to share that information as described in the “How We Share Your Information” section below.
- HOW WE SHARE YOUR INFORMATION
• Marketing Partners: We may share your personally identifiable information with our co-promotional partners and other business partners with whom we have marketing or other relationships for joint marketing purposes or such partners’ own marketing purposes.
• Service Providers: We may share your information with our service providers who assist us by performing core services (such as reservations, hosting, billing, fulfillment, data storage, security, processing credit card payments, customer service, credit reporting, property management, customer relationship management, “know-your-customer,” accounting, auditing, processing insurance claims, investigating accident reports, administering sweepstakes, surveys, email and mailing services, and delivering packages) related to the operation of the Resort, the provision of services at the Resort, the operation of the Website, the processing and fulfillment of reservations or product orders, and/or by making certain Website functionality available to our users.
• To fulfill the purpose for which you provide it.
• With your consent.
We will not disclose the amount of your specific gaming winnings or gaming losses to any third party unless required by applicable law or regulation.
- Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. SAHARA aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by following the procedure describe in the “Contact Us” section, below.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification.You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object.You have the right to object to our processing of your Personal Data.
- The right of restriction.You have the right to request that we restrict the processing of your personal information.
- The right to data portability.You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent.You also have the right to withdraw your consent at any time where SAHARA relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in EEA.
SAHARA’s compliance with GDPR is voluntarily. SAHARA does not consent or submit to the jurisdiction of the European Union for any purpose or matter of any kind or waive any rights or defenses in law or equity with respect thereto.
- Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Las Vegas Resort Holdings, LLC may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- To comply with the law
- HOW WE RESPOND TO DO NOT TRACK SIGNALS
Some web browsers may give you the ability to enable a “do not track” setting that is an HTTP header field indicating your preferences regarding tracking or cross-site user tracking. This is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. The Website does not recognize web browser “do not track” signals at this time. We may work with third parties that use tracking technologies on the Website, including in order to serve tailored advertisements on our behalf and on behalf of other advertisers across the Internet. These companies may collect information about your activity on the Website and other websites over time, as well as your interaction with our advertising and other communications, and use this information to determine which ads you see on third-party websites and applications. For more information about this practice and to understand your options, please visit http://www.networkadvertising.org/ or http://www.aboutads.info.
- INTEREST-BASED ADVERTISING
- PUBLIC FORUMS
- WIRELESS MARKETING SERVICES
If you register for wireless marketing services, you understand and agree that you may be charged by your wireless carrier for all messages sent to you. Standard messaging rates will apply, unless noted otherwise. Under no circumstances will we be responsible for any wireless email or text messaging charges incurred by you or by a person that has access to a your wireless device, telephone number, or email address.
You may cancel one or more services via your wireless device at any time by using the unsubscribe mechanism provided by at the time the message is sent, or by sending a text message that says “UNSUBSCRIBE,” “STOP” or such other code referenced in the message. If you unsubscribe, the applicable service(s) will be terminated and will cancel your previous opt-in.
You understand, acknowledge and agree that we may, in our sole discretion and without liability to any user, terminate any offer of any specific wireless marketing service or all wireless marketing services at any time without advance notice. We may provide notice of terminations or changes in services on this Website.
The Website is a general audience site, and the features, programs, promotions, and other aspects of our Website requiring the submission of personal information are not intended for anyone under 21 years of age. If you are under 21, you may not access, use, or register on the Website. We do not knowingly collect personal information from individuals under the age of 18. If you are a parent or guardian of an individual under the age of 18 and believe he or she has disclosed personal information to us without your permission, please contact us at [email protected] or otherwise as provided in the “Contact Us” section below. A parent or guardian of a child under the age of 18 may request deletion of such child’s personal information as well as prohibit the use thereof.
We take reasonable steps to protect against the loss, misuse and alteration of the information under our control, including Secure Sockets Layer (SSL) technology to encrypt the transmission of non-public personally identifiable financial and transaction information over the Internet, provided you are using an SSL-enabled device. We also utilize other reasonable security measures such as firewalls, security patches, and anti-virus programs, to protect your personal information. Despite these efforts, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks), and we cannot and do not guarantee or warrant the security of any information you disclose or transmit to us via the Internet, and are not responsible for the theft, destruction, or inadvertent disclosure of your personal information. For your own privacy protection, we recommend that you do not include any non-public personal or sensitive personal information such as passwords, social security numbers, credit card details, or bank account information, in any emails that you send to us. We will not contact you by email or text message to ask for such information.
M OTHER WEBSITES/LINKS
Our Website may link to third-party websites that we do not control or maintain. Be aware that those third-party websites collect information and operate according to their own privacy practices. We are not responsible for the privacy practices employed by any third-party website. We encourage you to note when you leave the Website and to read the privacy statements of all third-party websites to understand how they collect, use and disclose personal information before submitting any personal information to those websites.
- YOUR CHOICES AND ACCESS
If you have registered on the Website, or are a member of the CLUB 52 Program, you can login to your account to change or update certain information and preferences to keep such data accurate, complete and up-to-date. You also can contact us as described in the “Contact Us” section to update or correct certain personal information.
In addition, as described above, you can set your web browser to refuse browser cookies (but not Flash cookies). For more information on how to manage browser cookies, click here. For information about how to manage Flash cookies, click here. Please keep in mind, however, that you may not be able to access the full functionality of our Website if cookies are disabled.
In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, you can agree to receive some communications but not others. At any time, you also may opt-out of receiving future commercial emails from us by following the “Unsubscribe” instructions contained in any commercial emails that you receive from us. You also may contact us as described in the “Contact Us” section if you want to opt-out from receiving future commercial correspondence, including marketing emails, from us. We will respond to your request and, if applicable and appropriate, make the requested change in our active databases within a reasonable timeframe. Please remember that we may not be able to fulfill certain requests while allowing you access to certain benefits and features. Even if you unsubscribe from our marketing communications, you may continue to receive certain communications from us, such as transactional, customer service or other relationship messages, messages about your account and profile, and emails in response to communications or requests for information that we receive from you. Please also note that we may not be able to remove your personal information from the databases of third parties to whom we already provided your personal information as of the date of your opt-out request.
- YOUR CALIFORNIA PRIVACY RIGHTS.
California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personal information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send an email to [email protected] with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
- CONTACT US