PRIVACY POLICY

I. POLICY

Caesars Windsor is committed to protecting your privacy in accordance with this Privacy Policy and applicable law. This Privacy Policy describes how the Operator of Caesars Windsor (“Caesars Windsor”, “the Property”, “we” “us” and/or “our”) collects, uses and discloses Personal Information of visitors to our website and of individuals with whom we deal offline, including Personal Information of customers and other persons that is collected or received by Caesars Windsor in the course of its commercial activities.  Games of chance conducted at Caesars Windsor are operated by the Operator as agent for the Ontario Lottery and Gaming Corporation (a crown corporation created under the Ontario Lottery and Gaming Corporation Act, 1999) (“OLG”); Caesars Windsor is otherwise operated by the Operator in its capacity as an independent contractor of OLG. We reserve the right to change this Privacy Policy.  “Operator” means Caesars Entertainment Windsor Limited and any successor operator of Caesars Windsor and their respective successors and assigns.

Personal Information is information about an identifiable individual, as more particularly described under applicable privacy legislation.  This Privacy Policy applies to our collection, use and disclosure of Personal Information. This Privacy Policy does not apply to information about employees of the Operator.  When we refer to “Loyalty Programs” or “Loyalty Program” in this Privacy Policy, we mean: (i) the current “Total Rewards” loyalty program which is operated by Caesars Entertainment Corporation. (Caesars or “Caesars Entertainment”) and which Caesars Windsor participates in, as amended or modified from time to time, until such time as such program is discontinued, and/or (ii) any replacement or successor loyalty program introduced at Caesars Windsor.  Loyalty Programs may be located outside of Canada.  The use and disclosure of Personal Information by Loyalty Programs located in other countries (including the United States) will be subject to the laws of that country, which may differ from the laws of Canada and may include, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

Caesars Windsor reserves the right to amend, modify or otherwise change the terms of any Loyalty Program and to terminate or discontinue any Loyalty Program, in its sole and absolute discretion.

When we refer to our “affiliates” in this Privacy Policy we mean the Operator and its shareholders and their respective affiliates together with OLG.

II. WHY CAESARS WINDSOR COLLECTS YOUR PERSONAL INFORMATION

Caesars Windsor collects Personal Information in the conduct of its business including for the following reasons:

a) to correctly identify you;
b) in connection with providing goods and services and improving the goods and services we offer to customers;
c) to learn about the needs, activities and interests of current and potential customers, to develop or offer services and promotions tailored to those needs, activities and interests and to communicate with those customers regarding such services;
d) to administer programs which reward customer activities such as by providing invitations to player parties, concerts, sporting events, tournaments and other events which may be of interest to those customers based on their needs, activities and interests;
e) to provide you and other interested customers with information about activities, new games, tournaments, promotions, contests and other materials regarding services offered by our marketing program;
f) to assess your eligibility for cash-back, free play and complimentaries such as meals, hotel  accommodations, concert tickets and transportation;
g) to respond to your questions and enquiries and to follow up on customer comments, complaints and suggestions; 
h) for account collection purposes;
i) to comply with legal requirements and to cooperate with law enforcement agencies;
j) to protect you and us against fraud;
k) for loss prevention purposes;
l) to ensure minors do not gain entry to the Casino; 
m) to operate the voluntary self-exclusion program for people who have registered for the program;
n) to ensure a secure and safe environment for customers and our employees and to promote responsible gaming;
o) enrolling you in and administering reward or loyalty programs and the Loyalty Programs;
p) if your visit to Caesars Windsor was arranged by a coach or tour operator, “junket” representative or other similar person (each a “Tour Operator”), to remunerate the Tour Operator based on your gaming activity or other transactions at Caesars Windsor;
q) completing transactions;
r) conducting credit checks with your consent;
s) managing and administering our business and performing our business operations;
t) providing you with personalized service and experience in the Property and on our websites;
u) administering your participation in special promotions such as contests;
v) keeping your credit card on file for future purchases unless you instruct us not to;
w) marketing the services and goods we provide such as by sending information about developments and activities at Caesars Windsor and properties and casinos owned or operated by our affiliates, and/or Loyalty Program partners;
x) maintaining business records for reasonable periods;
y) combining Personal Information collected on-line with information you provide off-line;
z) contacting you to conduct market research or request your participation in surveys;
aa) meeting legal, regulatory, insurance, auditing, loss prevention, security and processing requirements;
bb) communicating with you for the purposes described above including to offer and promote our products and services via telephone voicemail broadcast to any phone numbers that you may provide to us, including in the future, or via an email, postal or other address provided by you;
cc) communication with you for the purposes described above including to offer and promote our products and services including telemarketing communications via an Automatic Dialing – Announcing Device and that such calls may be made to any specific phone numbers that you provide to us including in the future; and
dd) otherwise with consent or as permitted or required by law.

III. WHAT PERSONAL INFORMATION IS COLLECTED AND HOW WE COLLECT SUCH PERSONAL INFORMATION

1. Identification ("ID") Verification.  Casinos are required to verify the photo ID at the Casino entrances of all individuals who appear to be under 30, to ensure that no one under the legal gambling age of 19 is permitted entry.   Security Officers posted at the entrance of the Casino may use identification verifiers to scan any ID including if they believe it may have been tampered with or altered.  

Casinos are also required, under provincial and federal laws, to verify government-issued photo ID and to record certain information, including, but not limited to name, date of birth, address, type of ID, place of issuance of ID, expiration date and ID reference number, before conducting certain types of transactions.  These transactions include but are not limited to foreign exchange transactions of Cdn.$3,000 or more, cash transactions of Cdn.$10,000 or more (see Large Cash Transaction Records), casino disbursement transactions of Cdn.$10,000 or more, credit extensions of any amount, and opening a front money account in any amount.

Caesars Windsor also requires government-issued photo ID before issuing or permitting use of a loyalty card for its Loyalty Program such as the Total Rewards Card to protect customers who may lose or misplace their cards and to ensure customers are of legal age to gamble and are not part of the self-exclusion program.

2. Photography.  To protect your privacy, photography is prohibited on the gaming floor.  The only exceptions to this prohibition are photographs of jackpot and tournament winners, who consent in writing to their picture being taken, and special events, such as “meet and greets”..  Except for your spouse or significant other, no other customers will be included in the photographs.  Caesars Windsor may also take photographs inside the casino for publicity purposes and advertising campaigns.  In these cases, only actors are used in the photographs, and signage is posted to advise customers of the photography shoot.  In some cases, entertainers will have their performances in the Entertainment Centre videotaped and photographed. When this is happening, we will notify you through signage and/or an announcement at the beginning of the performance.

3. Video Surveillance.  In order to comply with the AGCO Registrar’s Standards for Gaming, Caesars Windsor is required to have surveillance systems to monitor all gaming and sensitive areas of the Casino.  We also have surveillance systems that monitor other areas for safety and security purposes.  Video surveillance cameras are used to protect Caesars Windsor, its customers and employees against potential violations of criminal and/or civil laws.  Surveillance camera output is monitored by Caesars Windsor Surveillance personnel, authorized Caesars Windsor officers or directors, Ontario Provincial Police and regulatory authorities.

4. Self-Exclusion and Facial Recognition.  Self-exclusion is a voluntary program offered by Caesars Windsor and the OLG to individuals who choose to be included in the program because they wish to limit or stop their gambling.  In addition to the information collected directly from individuals who have completed the Self-Exclusion Form as described below, the self-exclusion program also uses an automated facial recognition technology system to identify self-excluded individuals.  This technology captures facial images of Casino customers at a distance and compares such images to the images of those who have voluntarily provided their photograph to the self-exclusion program.  This technology only identifies possible matches with those registered with the self-exclusion program and does not identify or retain the images of other individuals.  Access to the information gathered as part of the self-exclusion program, including facial recognition information, is limited to the individuals who require the information in order to operate the self-exclusion program.  All information gathered as part of the self-exclusion program, including all facial recognition information, is protected by the appropriate technological systems including encryption algorithms.

The description of the self-exclusion program and facial recognition technology as set out in this Privacy Policy does not amend or supersede the terms and conditions that any individual agreed to when registering for the self-exclusion program and, specifically, does not provide any kind of representation or guarantee with respect to the effectiveness of the self-exclusion program.

5. Involuntary Exclusion. To protect the safety or security of our customers and employees, and to comply with Caesars Windsor’s commitment to responsible gaming and a safe and secure gaming environment, you may be involuntarily excluded from Caesars Windsor (by Notice of Trespass or otherwise) if we believe that you have difficulty gaming responsibly, if you have been involved in a safety or security incident at Caesars Windsor, another Ontario Casino or another Casino owned, operated or managed by Caesars and its affiliates, or if you have otherwise demonstrated behaviour that we believe puts you, other customers or our employees at risk.  We will collect and retain information relating to the circumstances leading to our determination that you should be excluded from the premises. 

6. Manual and Electronic Forms.  During your visit to Caesars Windsor, you may be asked to provide information for various forms, requiring different types of Personal Information. The forms you may be asked to complete fall in the following categories:

(a) Customer Tracking and Reward Programs.  From time to time Caesars Windsor has established and may in the future establish various player tracking and reward programs.  For example, you may choose to become a member of our Loyalty Program so that you can redeem your slot points for cash back, free play, reward credits for cash, or qualify for complimentaries, and many other promotional offers, and receive invitations to parties and events.   If you choose to join the Loyalty Program and have your play rated, we may collect certain information about you including name, address, telephone number, e-mail address, interests, gaming history, number of visits to the Casino, and level of play.  If you choose to join the Loyalty Program through one of our affiliates, including through a website or mobile application owned, controlled or operated by one of our affiliates, the affiliate may disclose this information to us and we may collect it from them. Caesars Windsor uses this information to better understand the interests of its customers, to provide you with valuable marketing information, and to assess your eligibility for cash back, reward credits for cash, complimentaries, and other promotional offers, and to invite you to parties and events.

(b) Credit Applications.  As a service to eligible customers, Caesars Windsor may extend you credit to facilitate gaming.  To assess your eligibility for credit and determine a line of credit that corresponds with your financial means, we will first have to obtain information about you and verify your financial history. You will be required to provide us with your name, address, income, banking information and credit history.  To determine your eligibility for credit, we may disclose your Personal Information to credit reporting agencies, financial institutions and other casinos.    This information may also be shared with other casinos including those taking part in the Loyalty Program.  Such casinos may be located outside of Canada.

(c) Other Financial Services.  As a service to customers, Caesars Windsor may open a front money account for you, advance you cash on your credit card, transfer your funds by wire to a financial institution, or permit you to use a safety deposit box.  Before we can facilitate these services, we will require certain Personal Information.  Depending on the type of service you are interested in, the Personal Information may include your name, address, date of birth, signature, etc.  This information may be shared with other casinos including those taking part in the Loyalty Program.  Such casinos may be located outside of Canada.  Where these transactions (excluding use of safety deposit box) amount to Cdn.$10,000 or more in the gaming day, a Large Cash Transaction Record is required under law. 

(d) Large Cash Transaction, Large Casino Disbursement, and Multiple Transaction Records.  Under provincial and federal laws, Casinos are required to complete a Large Cash Transaction or Casino Disbursement Record before conducting any transactions of Cdn.$10,000 or more (including multiple transactions, where cash is received from the same person, amounting to Cdn.$10,000 or more in a gaming day) and Multiple Action Logs before conducting certain transactions of Cdn.$2,500 or more in a gaming day.  These records include Personal Information such as your name, address, date of birth, and business or principal occupation.  Where we determine that a reportable transaction is being conducted on behalf of a third party, Personal Information on the third party is also required, including the third party's name, address, date of birth, business or principal occupation and the nature of the relationship between you and the third party.  In addition, we are required to report to the Financial Transactions Reports Analysis Centre of Canada (“FINTRAC”), transactions where Cdn.$10,000 or more in cash is received (including multiple cash transactions, by the same person, amounting to Cdn.$10,000 or more in a  gaming day) or when the total amount disbursed is Cdn.$10,000 or more (including multiple transactions amounting to Cdn.$10,000 or more in a gaming day).  The recording and reporting requirements for large cash transactions and large casino disbursements apply not only to all casinos/slot facilities in the country, but also to all financial institutions, foreign exchange dealers and other regulated financial service providers.

(e) Suspicious Transaction Reporting.  Under federal law, when an employee suspects, on reasonable grounds, that a transaction (regardless of the amount) or attempted transaction is related to the commission of, or attempted in the commission of, a money laundering offence or a terrorist activity financing offence, a Suspicious Transaction Report must be filed with FINTRAC. Certain Personal Information about the person conducting the transaction is required on these reports. Federal law prohibits us from disclosing that a Suspicious Transaction Report has been completed or reported, or the content of such a report.

(f) Self-Exclusion Forms.  If you wish to limit or stop your gambling, or for whatever reason, you may wish to complete a Self-Exclusion Form.  The form requires that you disclose your name, address, date of birth, and a piece of ID, and that you allow us to take a photograph of you.  This information is shared with OLG, all gaming premises in the Province of Ontario and all casinos owned, operated or managed by Caesars and its affiliates, for purposes of the self-exclusion program.

(g) Security Incidents.  Details of security incidents, such as assaults, thefts, drunkenness or disorderly conduct, etc., are recorded.  If you are involved in or witness a security incident, you may be asked to provide us with your name, address, and telephone number. 

(h) Health and Safety.  If you or a family member become ill or are involved in an accident while visiting Caesars Windsor, we may ask you to provide us with your contact information, health history, physician and next of kin.  Other information may be documented depending on the nature of the medical incident or accident.   

7. Concert Ticket Purchase.  When you purchase tickets for concerts or other events at Caesars Windsor’s Entertainment Centre through Ticketmaster, Ticketmaster releases certain of your Personal Information to Caesars Windsor, including your name, address and telephone number.  Caesars Windsor may use this information to notify you of other concerts or events at our Entertainment Centre.

When you accept complimentary tickets to a concert or event at Caesars Windsor’s Entertainment Centre, you may provide us with certain Personal Information including your name, address and telephone number.  Caesars Windsor or Ticketmaster may use this information to notify you of other concerts or events at our Entertainment Centre.

8. Website.  The Caesars Windsor website www.caesarswindsor.com provides information about the services, events and other activities available at Caesars Windsor.  Our Internet servers may passively and automatically collect certain information about website visitors' traffic patterns, which may be linked to their Internet Protocol (IP) addresses (which are unique Internet "addresses" assigned to all Internet users by their Internet Service Providers). Server logs may record statistical information, such as visitors' IP addresses, type of operating systems, time and duration of visit, pages requested, and identify categories of visitors by items such as domains and browser types.  These statistics are generally collected and used on an aggregate basis.

9. Cookies. Our website makes use of cookies.  Cookies are small text files offered to your computer by servers in order to keep track of your browser as you navigate the website. Cookies may be stored on your hard drive in which case they remain on your hard drive until deleted, or in temporary memory in which case they are deleted when you shut down your browser or turn off your computer.  We may use cookies to record session information, such as your browsing habits and past activity, to enable us to provide you with improved services such as customized Web page content.  You can disable cookies using your Internet browser's settings. Please consult your browser's help function for information on how to disable cookies. Note that if you disable cookies, certain features of our website may not function properly.

10. Other. Other Personal Information we collect includes:

a) name, home and business address(es), home and business telephone number(s), email address(es), fax number(s), title, company or organization name and other contact information;
b) information we receive about you from others, including credit bureaus, relating to your credit history and financial transactions with others;
c) information about your transactions, including your payment history, hotel preferences, hotel account information, details of credit transactions and/or gaming activity;
d) information you provide such as your name, birth date, address, business and home phone number(s), government-issued photo identification number and e-mail address when you sign up for loyalty, reward or player tracking programs that reward customer activities such as the Loyalty Programs that we may offer from time to time and information concerning your participation in any Loyalty Program;
e) information you provide such as Loyalty Program number, date of birth, first name, last name, address, phone number(s), email address and credit card number (required when booking a hotel reservation) and whether you wish to receive future communication from Caesars Windsor and any Loyalty Program;
f) member ID and account passwords;
g) credit card, bank account, credit rating or other payment and financial information;
h) your interests and preferences, age, gender, language, marital status and other demographic information, some of which may be optional;
i) information regarding your use of Casino, hotel and restaurant facilities at Caesars Windsor and other properties operated or owned by our affiliates and/or Loyalty Program partners (including playing habits, preferences and history (including the type of machine or game played, the length of time played, the average bet)), food preferences, hotel/accommodation preferences and participation in promotional activities;
j) information you provide when you contact us by any means including online, by phone, or by mail;

k) Personal Information we receive from a company who has advised us that it has your consent to provide us with your Personal Information for marketing purposes; and
l) such other information we may collect with consent or as permitted or required by law.

IV. DISCLOSURE OF PERSONAL INFORMATION

1. General.  Caesars Windsor discloses Personal Information in the course of its business such as in the following circumstances:

a) to manage and administer player’s accounts including to process credit card, cheques or other forms of payment;
b) to manage and administer our business including to enforce our policies and procedures;
c) as permitted by law to protect the rights, property or safety of Caesars Windsor and its employees, representatives, agents, affiliates and any operator of any Loyalty Program or any other partners in such Loyalty Programs;
d) to enforce any debts that you may owe to us;
e) with your consent to conduct credit checks when you enroll and from time to time;
f) with your consent to other marketers of products or services;
g) to other Ontario Casinos, OLG, and other Casinos owned, operated or managed by Caesars and its affiliates, if you have completed a self-exclusion form;
h) if you have been involuntarily excluded from Caesars Windsor (by Notice of Trespass or otherwise), we may share information relating to the circumstances leading to our determination to exclude you with other Ontario Casinos, OLG, and other Casinos owned, operated or managed by Caesars and its affiliates, where we believe it is necessary to protect the safety or security of their customers and employees or to promote responsible gaming;
i) to affiliates for the purposes of marketing and/or promoting Caesars Windsor or any property of an affiliate (affiliates may be located outside of Canada);
j) if your visit to Caesars Windsor was arranged by a Tour Operator, we may disclose information about your gaming activity, gaming preferences, and hotel account, to such Tour Operator in respect of such visit;
k) to the operator of any Loyalty Program that Caesars Windsor may participate in from time to time;
l) to any partners in any Loyalty Program, for the purposes of marketing and promoting Caesars Windsor, the Loyalty Program and/or any products or services offered by any of the partners in the Loyalty Program; the Loyalty Program operator and Loyalty Program partners may be located outside of Canada;
m) to affiliates and/or to the operator of any Loyalty Program,(including those outside of Canada) for internal audit, management, billing, insurance, regulatory or administrative purposes;
n) aggregate (non-personally identifying) information is provided to third parties such as advertisers;
o) to OLG if required by law or the terms of any agreement between OLG and the Operator of Caesars Windsor; as noted above, OLG is a crown corporation formed under the Ontario Lottery and Gaming Corporation Act, 1999 and the Operator of Caesars Windsor operates games of chance at Caesars Windsor as agent for OLG;  OLG is governed by its own Privacy Policy which can be found at www.OLG.ca and includes contact information to reach an OLG representative in case you have any questions regarding their Privacy Policy;
p) as necessary to meet legal, regulatory (including but not limited to gaming regulators including the AGCO, see below), insurance, audit, processing and security requirements; and
q) with your consent or as permitted or required by law such as where we are required to do so by subpoena, court order, warrant or legally permitted inquiry by a government agency.

2. Third Party Vendors.  Certain amenities at Caesars Windsor are operated by third parties (“Vendors”).  Personal Information collected by Vendors in connection with your use of the amenities that they operate is governed by the applicable Vendor’s privacy policy.  We may share Personal Information with, and collect Personal Information from, Vendors where necessary to make a reservation on your behalf, to process a payment (including to charge a service to your room or credit card number on file with us), to verify your status as a Caesars Windsor guest or Loyalty Program member, in connection with complaints, inquiries or disputes, and to promote the safety and security of the Property.   Please visit our website for information about the amenities operated by Vendors.  

3. Ontario Lottery and Gaming Corporation for Anti-Money Laundering and Counter-Terrorist Financing Programs.  As described in Part III above, Ontario casinos are required to report certain transactions to FINTRAC.  For casinos like Caesars Windsor that are operated by a third party operator on behalf of OLG, the operator may file reports to FINTRAC and does this in its capacity as agent to OLG.  As a result, any report sent by the Operator to FINTRAC will also be shared with OLG.  OLG has responsibilities under federal law to develop and administer anti-money laundering and counter-terrorist financing programs.  Such programs are required to assess and evaluate information and activities taking place across all casinos in Ontario, whether operated by OLG itself or by a third party operator on behalf of OLG.  As a result, in addition to providing OLG with reports sent to FINTRAC, all third party operators of casinos in Ontario are required to provide additional Personal Information relating to their customers to OLG in certain circumstances.  This information may include name and contact information, date of birth, employment information, casino assigned player number or risk level, government issued identification numbers, information about accounts, transactions and gaming activity, and any other personal information that is reasonably required by OLG to effectively administer its anti-money laundering and counter-terrorist financing program.  OLG uses the information it receives from all casino operators for the purposes of administering its anti-money laundering and counter-terrorist financing programs.  OLG may also disclose personal information received from the Operator to FINTRAC. OLG is governed by its own Privacy Policy which can be found at www.OLG.ca and includes contact information to reach an OLG representative in case you have any questions regarding the OLG Privacy Policy.

4. Caesars Total Rewards and Adoption of Successor or Replacement Loyalty Program.  We disclose information we receive from you, and about your transactions or Loyalty Program participation with us, with Caesars Entertainment the operator of the Total Rewards Loyalty Program, and such information may be available to all other partners participating in the Loyalty Program. If we join or implement a new Loyalty Program, this will, among other things, allow the partners of the new Loyalty Program to recognize you and to quickly respond to applications for credit or financial services at their respective properties to better serve our customers. The Caesars Total Rewards Loyalty Program and any new Loyalty Programs may be located outside of Canada.  The use and disclosure of Personal Information by Caesars Total Rewards and any new Loyalty Programs located in other countries (including the United States) will be subject to the laws of that country, which may differ from the laws of Canada and may include, for example, lawful requirements to disclose Personal Information to government authorities in those countries. The Total Rewards program is not operated by Caesars Windsor, and Personal Information connected with the program will be subject to Caesars Privacy Policy.  The Corporate Privacy Policy and Online Privacy Policy can be found by visiting www.caesars.com.  You may also contact Caesars at 1-800-CAESARS or by mailing to:

ATTN: Loyalty Marketing
Caesars Entertainment P.O. Box 98905
Las Vegas, NV 89193

5. Personal Information Disclosure to Non-Affiliated Entities.  In addition to sharing Personal Information as described above, we share the information we collect about our customers with credit bureaus, collection agencies, and other non-affiliated third parties with consent and as permitted or required by law.

6. Service Providers.  Personal Information may also be transferred to our third party agents or service providers (including to our subsidiary Windsor Casino Limited acting in the capacity of a service provider) we engage to provide various services such as: hosting and maintaining our web sites, database and information management; telemarketing; marketing; mailing; data and other processing; providing some of the services you use on our web sites; managing some of our internal operations such as data analysis, site activity data collection and e-mails; customer service and fulfillment vendors; call centre, administrative, billing or other processing services on our behalf, some or all of which may be located outside of Canada. Some of our services may be provided by our affiliates including in the United States or elsewhere outside of Canada.  We take reasonable measures to ensure that your Personal Information that may be collected, used, disclosed or otherwise processed by these service providers or our affiliates on our behalf is protected and not used or disclosed for purposes other than as directed by us, subject to legal requirements in foreign jurisdictions applicable to those organizations, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

Chief Privacy Officer, c/o Legal Department
Caesars Windsor
377 Riverside Drive East
Windsor, Ontario N9A 7H7
Facsimile: (519) 985-5925
E-mail Address: privacyofficer@caesarswindsor.com

7. Business Transactions.  Personal information may be used by Caesars Windsor and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of Caesars Windsor or our business or assets, for the purposes of evaluating and/or performing the proposed transaction.  These purposes may include, as examples: permitting those parties to determine whether to proceed or continue with the transaction fulfilling reporting, inspection or audit requirements or obligations to those parties Assignees or successors of Caesars Windsor or our business or assets may use and disclose your personal information for similar purposes as those described in this Privacy Policy.

V. CONSENT AND YOUR CHOICE TO SHARE INFORMATION

Consent to the collection, use and disclosure of Personal Information may be given in various ways.  Consent can be express (for example, orally, electronically or on a form you may sign either referencing our Privacy Policy or describing the intended uses and disclosures of Personal Information) or implied (for example, when you provide information necessary for a service you have requested).  You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your Personal Information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any.  Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).  Generally, by providing us with Personal Information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Policy, if applicable, or otherwise at the time of collection.  You may withdraw your consent to our collection, use and disclosure of Personal Information at any time, subject to contractual and legal restrictions and reasonable notice by notifying us as set out in this section.  Note that if you withdraw your consent to certain uses of your Personal Information, we may no longer be able to provide certain of our products or services.

If you prefer that we not share Personal Information as part of a Loyalty Program, you can notify us by mail, including your name, address, account number and signature, in the manner set out below:

Chief Privacy Officer, c/o Legal Department
Caesars Windsor
377 Riverside Drive East
Windsor, Ontario N9A 7H7
Facsimile: (519) 985-5925
E-mail Address: privacyofficer@caesarswindsor.com

Please note that if you withdraw consent to use Personal Information as outlined for a Loyalty Program your membership in the Loyalty Program may be terminated.

Caesars Windsor collects, uses and discloses your Personal Information with your consent, except as permitted or required by law.  We may be required or permitted under statute or regulation to collect, use or disclose Personal Information without your consent, for example to comply with a court order, to comply with local, provincial or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

VI. SECURITY SAFEGUARDS

Caesars Windsor strives to ensure that its security measures will protect against loss, theft, unauthorized access, disclosure, use or modification of information.  Such measures will vary depending on the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures.

VII. LEGAL AGE POLICY

Caesars Windsor does not knowingly or intentionally collect any personally identifiable information from, or market to, individuals under the age of 19. If you know of a minor who has provided us with personally identifiable information, please contact us immediately so that we may identify the information that needs to be removed from our database. No information collected through the sites from users self-identified as minors will knowingly be used for any marketing or promotional purposes whatsoever, either inside of outside Caesars Windsor.

Ontario law prohibits anyone under the age of 19 from entering casino gaming establishments.  Individuals who appear to be under 30 years of age will be asked to provide government issued photo ID.  Acceptable valid government issued photo ID may include, but is not limited to: drivers license, military ID card, passport or immigration papers. Two pieces of ID will be required from those individuals 19 to 21 years of age.  An acceptable second piece of ID from those individuals 19 to 21 years of age may include, but is not limited to: credit card, bank card or passport. Although all ages are welcome in our Augustus Tower and convention complex, only persons 19 years of age or older will be permitted  in the Casino and related outlets.  Thus, any offers we make or any contests we conduct whether online or offline, unless otherwise noted, are not open to persons younger than 19 years of age.  Further, persons younger than 19 year of age are not allowed to use our website, accept offers, or win contests, and we do not knowingly collect information from such persons.  We reserve the right to verify age at any time for any reason and may reject a person who does not have valid age identification from participating on any part of our website. Affiliated sites and casinos may have different legal age requirements and policies which will apply when you interact with those sites and/or casinos.

VIII. OTHER WEBSITES

Our website contains links to other websites owned and operated by third parties.  The third parties who operate these sites may treat the collection, use and disclosure of Personal Information differently than we do.  This could be the case even for those websites which carry Caesars Windsor’s trade-marks or logos or which are framed by this website.  We therefore encourage you to review the privacy policies of these websites before disclosing your information to any third party.  Caesars Windsor is not responsible for the data collection, use and disclosure practices of companies or organizations to which our website may provide links.

IX. HOW TO ACCESS OR CORRECT YOUR PERSONAL INFORMATION

If you wish to request to access, verify or change your Personal Information, please write to:

Chief Privacy Officer, c/o Legal Department
Caesars Windsor
377 Riverside Drive East
Windsor, Ontario N9A 7H7

In addition, you can attend in person at a Total Rewards Booth.  To protect your privacy, we will take reasonable steps to verify your identity before granting you access to, or making corrections to, your  Personal Information.

X. CHANGES TO THIS PRIVACY POLICY

Caesars Windsor reserves the right to modify or change this Privacy Policy or the privacy practices set out in this Policy from time to time.  If Caesars Windsor makes a material change, this Privacy Policy will be updated accordingly and the revised version will be posted on our website in a timely manner.

XI. CONTACT US FOR FURTHER INFORMATION

Individuals may forward any question or concern regarding this Privacy Policy or the use and disclosure of their Personal Information to Caesars Windsor’s Privacy Officer either by mail or E-mail as follows:

Chief Privacy Officer
c/o Legal Department
Caesars Windsor, 377 Riverside Drive East
Windsor, Ontario N9A 7H7
Facsimile: (519) 985-5925
E-mail Address: privacyofficer@caesarswindsor.com

XII. PERSONAL INFORMATION COLLECTED BY THE ALCOHOL AND GAMING COMMISSION OF ONTARIO AND THE ONTARIO PROVINCIAL POLICE (OPP)

The AGCO is an agency of the Government of Ontario.  The AGCO is responsible for ensuring that gaming in this province is conducted with honesty and integrity.  This involves overseeing the operation of Ontario’s gaming facilities.  Officers of the OPP are seconded to the AGCO to carry out law enforcement activities within gaming facilities.

The AGCO Registrar’s Standards for Gaming require that gaming facility operators install video surveillance in certain parts of the facilities.  OPP officers monitor the video surveillance in order to identify any illegal activity.  In cases where illegal activity is suspected, OPP officers carry out an investigation.  Some investigations may involve use of facial recognition information comparing a facial scan to a database of known or suspected criminals.

Patrons of gaming facilities do not automatically have their facial recognition information gathered by the OPP when they enter a gaming facility.  Facial recognition information is gathered and used strictly in the course of police investigations.  Access to information gathered by OPP officers is restricted to the officers who are assigned to work in the gaming facility.  All information gathered is protected by sophisticated systems.  Once an investigation is completed, the relevant face recognition information is removed from the OPP database.  The collection of facial recognition information described in this section is separate from and in addition to the facial recognition information collected pursuant to the self-exclusion program described elsewhere in this Privacy Policy.

The AGCO gathers Personal Information in accordance with the Freedom of Information and Protection of Privacy Act for the purpose of law enforcement.  Anyone seeking access to the information must meet the requirements set out in the Freedom of Information and Protection of Privacy Act.  If you have any questions or would like more information about the role of the AGCO or its use of face recognition, please contact:

Alcohol and Gaming Commission of Ontario
90 Sheppard Avenue East
Toronto, Ontario, Canada M2N 0A4
Telephone: (416) 326-8700; 1.800.522.2876
www.agco.on.ca