CAESARS ENTERTAINMENT CORPORATION
REVISED: JUNE 2020 - About this Update
1. DEFINED TERMS
(d) “Personal information” refers to any information by which you can be personally identified, such as your first name, last name, address, phone number, email address, credit card number, social security number, driver license number, passport number, license plate number, geolocation information, Caesars Rewards number, date of birth, purchase information, gaming activity information, biometric information and other similar information.
(e) “Non-personal information” refers to information by which you cannot be personally identified.
(f) “Caesars Rewards” or “Caesars Rewards Program” refers to our Caesars Rewards® loyalty program.
2. INFORMATION WE MAY COLLECT.
As part of our efforts to keep our employees and customers safe during the COVID-19 pandemic, we may also collect certain relevant information from our customers, including any of the following: experiences with symptoms consistent with COVID-19, bodily temperature readings and/or thermal scans, results of COVID-19 testing, names of other employees or customers with whom you have come in contact on Caesars Properties, or other relevant medical or other personal information that you disclose to us. This information will be collected by Caesars employees and will be kept confidential; however, we may disclose this information to government regulatory agencies if an agency requests that we identify guests who have exhibited symptoms associated with COVID-19 or who have tested positive for COVID-19, or to other third parties when otherwise required by law. While we understand the sensitive nature of some of this information, refusal to provide such information may result in our denial of services to you and/or other restrictions being placed upon you at Caesars Properties. We appreciate your understanding.
3. HOW WE COLLECT YOUR INFORMATION.
(a) Information You Directly Provide to Us. You may provide information directly to us under a wide range of circumstances, such as when you submit information to us through the Caesars Websites or Caesars Mobile Apps, use any gaming or non-gaming services at a Caesars Property, are videotaped or photographed in connection with a security incident or for other surveillance purposes, sign up to receive email or text messages from us, sign up to access Wi-Fi at a Caesars Property, park at a Caesars Property, install or use one of the Caesars Mobile Apps, sign up for Caesars Rewards, log in as a Caesars Rewards member, book a reservation for a Caesars Property, enter an online promotion, request information from us, scan your ID at check-in kiosk at a Caesars Property, apply for casino credit or provide feedback in a survey.
(b) Information Automatically Collected Through the Caesars Websites.
(i) Traffic Data. We automatically track and collect general log information when you visit the Caesars Websites, including your: (A) Internet Protocol (IP) address, (B) domain server, (C) operating system, and (D) type of Web browser as well as the pages you visit on the Caesars Websites (collectively “Traffic Data“). Traffic Data does not personally identify you, however, if you choose to provide us with personal information, we may store some items of your personal information and use it with the Traffic Data to better personalize your experience on the Caesars Websites. We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of the Caesars Websites. It enables us:
- to estimate our audience size and usage pattern;
- to learn what information is of most and least interest;
- to speed up your searches; and
- to learn of any possible Caesars Website performance problems.
We, or our service providers, may also use Traffic Data to identify your physical location to confirm that you are in a jurisdiction where you can use our online gaming services. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and transparent GIFs (Graphics Interchange Format, a software technology also known as a pixel tag).
(v) Information You Share on Third Party Websites or through Social Media Services. The Caesars Websites may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services. We may also monitor sentiments regarding Caesars that you publicly post on social media services or customer review sites. We may reach out to you regarding these postings to address customer service issues and to otherwise help ensure that you have a positive customer experience.
(vi) Information You Post on the Caesars Websites. If you post information on any public areas of the Caesars Websites, that information may be collected and used by Caesars, other users of the Caesars Websites, and the public generally. We strongly recommend that you do not post any information through the Caesars Websites that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
(e) Information We Automatically Collect When You Use Our Wi-Fi Services. If you use Wi-Fi services that we make available at a Caesars Property, we might collect information about your use of our Wi-Fi services, including your IP address, Wi-Fi information (such as SSID), mobile carrier, the websites you visit, the type of device and browser you are using, your device identification number, bandwidth used and session time. See subsection (f) below for more information regarding the collection of information regarding your physical location if you are located on one of the Caesars Properties.
(f) Information We Automatically Collect from Mobile Devices on Caesars Properties. If you have a mobile device, are located on a Caesars Property and have your Wi-Fi or Bluetooth functionality enabled, we may collect information concerning your mobile device, including the type of device, device ID, and the precise physical location of your device within and around the Caesars Properties (including geolocation and beacon-based location), for analytics and non-marketing related purposes, such as enabling us to understand our customers’ preferences and use of our properties, including general traffic patterns. With your consent, we might also use your location information for marketing purposes, such as to provide you with real-time offers and personalized promotions. If you do not want information concerning your precise location to be collected on Caesars Properties, you may adjust your mobile device location sharing settings and disable the Wi-Fi and Bluetooth functionality in your mobile device settings.
(g) Other Information We Collect Relating to Your Gaming and Purchase History and Other Interactions with Us. When you use any of our gaming services or make a purchase at any of the Caesars Properties, we may collect transactional information about these activities and store it with your customer account. We may use this information to determine your Caesars Rewards tier level (if you are a Caesars Rewards member) and to make predictions about your preferences, and interests, future spending and gaming activity.
4. HOW WE MAY USE YOUR INFORMATION.
- to operate our Caesars Rewards Program and provide information to you about your Caesars Rewards Program activity;
- to improve the products and services we provide you and develop new products and services;
- to improve the Caesars Properties, Caesars Websites and Caesars Mobile Apps;
- to track your use of the Caesars Properties, Caesars Websites and Caesars Mobile Apps for our internal market research and analytics;
- to create a more accurate and complete customer profile for you to better understand and predict the products and services you want to use and to provide a more personalized level of service;
- to notify you about promotions and special offers regarding products and services provided by us or our affiliates or other associated third parties, including our Joint Marketing Partners (defined below);
- to ask for your participation in our internal market research;
- to generate aggregate statistical studies about our customers to better understand how our customers use our services;
- to contact you in response to your inquiries, comments and suggestions;
- to provide a healthy, secure, and safe environment for our customers or employees;
- to protect and defend our rights or property or enforce our agreements with you;
- to perform background checks for any reason (to the extent permitted by applicable laws), which includes but is not limited to any investigation into your identity, any credit checks or any inquiries into your personal history:
- to cash your checks, extend you credit, process credit card, ACH and/or other financial transactions;
- administer general recordkeeping for financial statements and audits;
- comply with our internal records management policy and retention schedules;
- to contact you otherwise when necessary; and
- otherwise with your consent or as permitted or required by law.
5. HOW WE SHARE YOUR INFORMATION WITH OUR AFFILIATES.
For business purposes, we may share certain information we receive from you, and about your transactions with us, with our affiliates, including our owned, operated, and managed casinos, hotels, online and web-based businesses, and other corporate entities or affiliates. Doing so allows us to provide the products and services you have requested and quickly respond to applications for credit or other financial services. We may also disclose your personal information to all Caesars Properties and other affiliates if you participate in our “self-restriction” or “self-exclusion” programs. Please click here for more information.
6. HOW WE SHARE YOUR INFORMATION WITH NON-AFFILIATED THIRD PARTIES.
As permitted by law, we may share the information we collect from and about you with non-affiliated third parties as follows:
(a) Third Party Service Providers. Your information may be shared with or collected by third party service providers who provide us with services, including but not limited to data hosting or processing, credit card processing, credit or background checks, or processing and fulfilling reservations or purchases. We require these providers to exercise reasonable care to protect your personal information and restrict the use of your personal information to the purposes for which it was provided to them.
(b) Third Party Joint Marketing Partners. We may share certain information about you with other companies with whom we have joint marketing or similar agreements, or other businesses with whom we have a contractual relationship (“Joint Marketing Partners”), who may contact you with marketing and promotional offers. These businesses generally include financial services companies, such as banks and insurance companies, other service providers, such as airlines, hotels and car rental agencies, and retailers, but may include others. If you would like us to stop providing your information to these Joint Marketing Partners, you may opt-out of personal information sharing by following the instructions in Section 11 below
(d) Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies and Applicable Law. To the extent permitted by law, we will disclose your information to government authorities or third parties: (i) if required to do so by law, or in response to a subpoena or court order, search warrant or other valid legal process, (ii) to comply with legal, regulatory or administrative requirements of any governmental authorities, including but not limited to gaming regulators, (iii) in connection with any legal action, claim or dispute, including but not limited to the collection of debts, (iv) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large, or (v) we believe that you have abused a Caesars Website or Caesars Mobile Application by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
(e) Aggregate Information. We may share your information with affiliated or non-affiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.
7. ONLINE ADVERTISING; TRACKING.
(a) Online Advertising. Caesars and third parties may use the information collected through the Caesars Websites using cookies, web beacons, and other similar technologies to help manage online advertising programs. This information may enable advertising services to track the actions of users online over time and across different web sites or platforms to measure statistics relating to marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience. For information about how tracking works for online advertising purposes, and what happens when you elect a do-not-track option, visit http://www.aboutads.info/choices. For more information about the Network Advertising Initiative opt-out process, you may visit the Network Advertising Initiative website, available at: http://www.networkadvertising.org/managing/opt_out.asp.
(b) Do Not Track. Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, at the present time we do not disable tracking technology that may be active on the Caesars Websites in response to any “do not track” requests that we receive from your browser.
8. YOUR CALIFORNIA PRIVACY RIGHTS.
(a) Shine the Light. As provided under California Civil Code Section 1798.83, also known as the “Shine the Light” law, we provide our customers with the ability to “opt out” of having their personal information shared with independent affiliates and non-affiliated third parties for their direct marketing purposes. You may opt-out of having your personal information shared with these affiliated and non-affiliated third parties for their direct marketing purposes by following the opt-out instructions in Section 11 below.
(b) California Consumer Privacy Act. This section only applies to customers who are residents of California under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (together “California Laws”).
1. Information we collect.