HOTEL PRIVACY POLICY

We collect the email addresses of those who communicate with us via email, aggregate information on what pages consumers access or visit, and information volunteered by the consumer (such as survey information and/or site registrations). The information we collect is used to improve the content of our Web pages and the quality of our service, and is not shared with or sold to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:

  1. It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
  2. We transfer information about you if Fifth Street Gaming or Downtown Grand Hotel & Casino (Downtown Grand) is acquired by or merged with another company. In this event, we will notify you before information about you is transferred and becomes subject to a different privacy policy.

 

TABLE OF CONTENTS

 

INFORMATION GATHERING AND USAGE

  1. When you register for the GRAND REWARDS program or you subscribe to our newsletter, we ask for information such as your name, date of birth, company name, email address, and affinities.
  2. Downtown Grand uses collected information for the following general purposes: products and services provision, services improvement, contact, advertising and research.

 

COOKIE DECLARATION

This website uses cookies. We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our website.

Cookies are small text files that can be used by websites to make a user's experience more efficient.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website.

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy.

Please state your consent ID and date when you contact us regarding your consent.

Your consent applies to the following domains: www.downtowngrand.com

Your current state: Allow all. 

Your consent ID: w3GOJkUiJiTA/AOE6ZVZn/9HT7W4BaWJaXPvRo5GIapGxMA6QnwpQQ==Consent date: Friday, October 1, 2021, 02:04:15 PM EDT


Cookie declaration last updated on 1/11/22 by Cookiebot:

Necessary (3)

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Name Provider Purpose Expiry Type
CONSENT YouTube Used to detect if the visitor has accepted the marketing category in the cookie banner. This cookie is necessary for GDPR-compliance of the website. 2 years HTTP Cookie
CookieConsent Cookiebot Stores the user's cookie consent state for the current domain 1 year HTTP Cookie
request_method theguestbook.com Used to optimize the loading speed on the website. This is done by pre-loading some procedures in the visitors' browser. Session HTTP Cookie

Statistics (7)

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Name Provider Purpose Expiry Type
_dc_gtm_UA-# Google Used by Google Tag Manager to control the loading of a Google Analytics script tag. 1 day HTTP Cookie
_ga Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 2 years HTTP Cookie
_gat Google Used by Google Analytics to throttle request rate 1 day HTTP Cookie
_gid Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 1 day HTTP Cookie
collect Google Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. Session Pixel Tracker
triptease-session-id api.triptease.io Contains an visitor ID - This is used to identify the visitor upon re-entry to the website. 1 day HTTP Cookie
triptease-user-id api.triptease.io Contains an visitor ID - This is used to identify the visitor upon re-entry to the website. 1 year HTTP Cookie

Marketing (31)

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Name Provider Purpose Expiry Type
_fbp Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. 3 months HTTP Cookie
_gcl_au Google Tag Manager Used by Google AdSense for experimenting with advertisement efficiency across websites using their services. 3 months HTTP Cookie
_session_id theguestbook.com Stores visitors' navigation by registering landing pages - This allows the website to present relevant products and/or measure their advertisement efficiency on other websites. 1 day HTTP Cookie
_uetsid Microsoft Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. 1 day HTML Local Storage
_uetsid_exp Microsoft Contains the expiry-date for the cookie with corresponding name. Persistent HTML Local Storage
_uetvid Microsoft Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences. 1 year HTML Local Storage
_uetvid_exp Microsoft Contains the expiry-date for the cookie with corresponding name. Persistent HTML Local Storage
ads/ga-audiences Google Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. Session Pixel Tracker
IDE Google Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user. 1 year HTTP Cookie
MUID Microsoft Used widely by Microsoft as a unique user ID. The cookie enables user tracking by synchronising the ID across many Microsoft domains. 1 year HTTP Cookie
pagead/1p-user-list/# Google Tracks if the user has shown interest in specific products or events across multiple websites and detects how the user navigates between sites. This is used for measurement of advertisement efforts and facilitates payment of referral-fees between websites. Session Pixel Tracker
pagead/landing x2 Google Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. Session Pixel Tracker
test_cookie Google Used to check if the user's browser supports cookies. 1 day HTTP Cookie
tr Facebook Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. Session Pixel Tracker
track/evnt The Trade Desk Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers. Session Pixel Tracker
triptease.integration.previous-pages onboard.triptease.io Used in connection with the travel/booking integration which allows users to search for relevant holiday and travel opportunities. The cookie collects information on search criteria for relevant promotions and advertisement. Session HTML Local Storage
triptease-anonymous-id onboard.triptease.io Used in connection with the travel/booking integration which allows users to search for relevant holiday and travel opportunities. The cookie collects information on search criteria for relevant promotions and advertisement. Persistent HTML Local Storage
tt_message_engine_latest_visit_info onboard.triptease.io Determines which products the user has viewed, allowing the website to promote related products. Persistent HTML Local Storage
tt-domain-user-id onboard.triptease.io Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website. Persistent HTML Local Storage
VISITOR_INFO1_LIVE YouTube Tries to estimate the users' bandwidth on pages with integrated YouTube videos. 179 days HTTP Cookie
YSC YouTube Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Session HTTP Cookie
yt.innertube::nextId YouTube Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Persistent HTML Local Storage
yt.innertube::requests YouTube Registers a unique ID to keep statistics of what videos from YouTube the user has seen. Persistent HTML Local Storage
yt-remote-cast-available YouTube Stores the user's video player preferences using embedded YouTube video Session HTML Local Storage
yt-remote-cast-installed YouTube Stores the user's video player preferences using embedded YouTube video Session HTML Local Storage
yt-remote-connected-devices YouTube Stores the user's video player preferences using embedded YouTube video Persistent HTML Local Storage
yt-remote-device-id YouTube Stores the user's video player preferences using embedded YouTube video Persistent HTML Local Storage
yt-remote-fast-check-period YouTube Stores the user's video player preferences using embedded YouTube video Session HTML Local Storage
yt-remote-session-app YouTube Stores the user's video player preferences using embedded YouTube video Session HTML Local Storage
yt-remote-session-name YouTube Stores the user's video player preferences using embedded YouTube video Session HTML Local Storage

Unclassified (4)

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

Name Provider Purpose Expiry Type
__sw_downtown-grand__ forge.gtsgapps.com Pending Persistent HTML Local Storage
__sw_engaged_key__ forge.gtsgapps.com Pending Session HTML Local Storage
__sw_session_key__ forge.gtsgapps.com Pending Session HTML Local Storage
__sw_uuid_key__ forge.gtsgapps.com Pending Persistent HTML Local Storage

 

DATA STORAGE

Downtown Grand uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the website. Although Downtown Grand owns the code, databases, and all rights to the Downtown Grand website, you retain all rights to your data.

 

EMAIL PREFERENCES

You can also opt-out or unsubscribe from any future email communications from within each email correspondence that we send you.

 

SMS TEXTING

Downtown Grand Las Vegas takes protecting your privacy seriously.  We will never, under any circumstances, sell or otherwise distribute your cell phone numbers to third parties or Downtown Grand’s partners for which you have not opted in. We will not market to you directly any services for which you have not opted in, either by cell phone text message or email.

 

DISCLOSURE

We will never distribute any personal information about you, including your phone number, name, billing information, or any other piece of identifying information. We will only provide you with exclusive and informative mobile content, and never spam.

Downtown Grand may disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate local, regional, or national laws.

 

CHANGES

Downtown Grand may periodically update this policy. Please review this page periodically to see these updates.

 

QUESTIONS & CONTACT

Any questions about this Privacy Policy should be addressed to Downtown Grand by email at dtgcomments@downtowngrand.com or by mail:

Downtown Grand Hotel & Casino
206 N. 3rd St.
Las Vegas NV 89101

For EU and California Residents: 

Please click here for additional information regarding our Privacy Notice

GRAND REWARDS PRIVACY NOTICE

Fifth Street Gaming on behalf of the Downtown Grand Hotel & Casino Grand Rewards Club operators, understand and respect our customers, guests and users’ privacy. The Privacy Notice (“Notice”) describes how we collect, use, store, share and protect personal information collected from or about Grand Reward members in connection with Downtown Grand Hotel & Casino. Grand Rewards is a loyalty program for members to gain access to member-only hotel rates and promotions at Downtown Grand Hotel & Casino, earn and track gaming benefits, and receive exclusive announcements and invitations.

1. PRACTICES COVERED BY THIS NOTICE

This Notice describes our privacy practices in relation to the personal information we collect:

  • From individuals who sign up for the Grand Rewards loyalty program on premises at Downtown Grand Hotel & Casino and use the Grand Rewards card to participate in our on-property casino gaming activities such as slot machines, table games and casino tournaments.
  • Through HTML-formatted email message that we sent to you.

The Notice does not apply to the following Downtown Grand Hotel & Casino entities or services, which are governed by separate privacy notices:

  • Hotel Wi-Fi Services – When using Wi-Fi services at our resort, the personal information you provide is subject to separate privacy.
  • Sweepstakes and Other On-Property Promotions – we will use personal information to allow you to participate in these activities. Some of these activities have additional rules and privacy terms attached to Please refer to each activity’s terms and conditions for more information.

2. WHAT PERSONAL INFORMATION WE COLLECT

The personal information we collect may include your name, postal address, email address, phone number, date of birth, driver’s license number, photograph, passport number, card payment details, online information, such as your IP address, as well as any other information you choose to provide to us.

Whether you choose to provide any particular information requested by Downtown Grand is completely your own choice. But, if you choose not to provide the information we request, you may be unable to receive or access certain services, offers and information.

Across our property, Downtown Grand Hotel & Casino maintains integrated profiles of our customers, in keeping with the highest standards for an exceptional customer service experience at our hotel, restaurants, pool and other areas. Thus, gaming or other activities tracked by a Grand Rewards loyalty club member will be paired with other information we collect from or about that member, in order to personalize your experience and deliver the Grand Rewards club member benefits and opportunities.

3. HOW WE COLLECT INFORMATION

  • On-Premises Enrollment  Grand Rewards cards are issued and activated on-premise only at Downtown Grand Hotel & Casino, after your identification is collected and verified. We collect your driver’s license or other form of government-issued identification when you register for a

Grand Rewards account by visiting the Grand Rewards booth or playing casino games or when requesting a replacement card. We also collect information to register or update your Grand Rewards account through a mobile device managed by our Downtown Grand staff members including your name, driver’s license or government-issued identification, email address, phone number, and we also ask you to create a unique PIN to activate your Grand Rewards account.

  • Casino Gaming Activity – We collect information about your gaming activity (such as your bets, payouts, winning and game session duration, and all other activities used with your Grand Rewards card) when you use your Grand Reward
  • Voluntary Information – We collect information which you provide to us voluntarily when you communicate directly to us during your use of the Site or our services. This includes information, such as your preference of casino games or Downtown Grand services and amenities, online login information and profile, and information you direct third parties to share with us. Where you choose to self-exclude or self-limit, we will collect your personal information in relation to this
  • Financial Transactions and Privileges – We collect or use your name, email address, phone number, Grand Rewards account number, member account details, social security number and tax filing information in connection with financial dealings with our casino properties or to administer and service a Grand Rewards account. We also collect, where applicable, banking information that is necessary to process payments or other transactions, such as withdrawals and deposits or personal check
  • Automatically when you use our Site or services  We automatically collect technical information about your online interactions with us (such as IP address and browsing preferences).
  • CCTV Cameras  We use CCTV cameras on our premises that may capture your image and
  • Third parties – We receive information about you and your interactions with us from third parties, such as marketing and advertising providers, social network services, and data
  • Public Sources – We collect personal information that you or the government have made publicly available, such as government entities from which public records are obtained and information you submit in public forums.

4. HOW WE USE YOUR PERSONAL INFORMATION

Downtown Grand Hotel & Casino uses your information for various purposes, including:

  • To provide Grand Rewards club member services, including to manage your account, access member-only rates and promotions, earn and track your gaming benefits, process and fulfil orders, allow you to manage your communication preferences and choose how you wish to use your
  • To contact you to discuss the services or products you receive from
  • To facilitate our casino operations, including to process financial
  • If you have chosen to self-limit or self-exclude, to administer self-exclusion program, monitor gaming activity and as required by law.
  • To respond to your queries, gaming activity requests or transactions and provide you with related customer service.
  • For analytics and profiling purposes, to optimize your experience at Downtown Grand Hotel & Casino, enhance our marketing, create customer or audience segments (including custom and lookalike audience), enhance our business and operational efficiency and tailor promotions and offers to your preferences and habits when interacting with us.
  • To maintain the accuracy of your account or profile information and provide you with a better and more personalize service, including by pairing information collected under this Notice with your hotel guest profile or customer account if you have previously made hotel accommodation with us.
  • To facilitate the provision of transportation services, and other reservations, if these services have been made available to you, upon your request.
  • To carry out appropriate compliance, security and/or financial checks, such as when we need to:
    • Confirm your identity;
    • Make a payment to you or receive payment from you; and
    • Comply with law enforcement, court, and regulatory

5. MARKETING PREFERENCES

  • You may withdraw your consent for direct marketing communications at any time by contacting us at casinoevents@downtowngrand.com, or calling 719.5422 or by following the unsubscribe instructions in the marketing message.
  • When you receive a commercial (promotional) electronic communication, we provide the choice to opt-out of receiving future messages by following the instructions provided in the
  • You may choose whether to provide your phone number to receive text messages or advertising phone calls from us or our call center agents using an automatic telephone dialing system or an artificial or prerecorded voice. By providing your phone number and express consent, you are choosing to receive such messages until you withdraw your consent. Your consent to receive text messages or pre-recorded calls using an automatic telephone dialing system is not required to make a purchase with Downtown Grand. You may revoke your consent at any time by contacting us at casinoevents@downtowngrand.com.
  • Although we do not currently sell, as that term has been defined by the laws of the State of Nevada, your personal information and only share it with third parties who are facilitating the delivery of Downtown Grand services and amenities, if you would like to opt-out of any future sale of your information in the unlikely event we change our practices you can do so by contacting us a casinoevents@downtowngrand.com.

6. HOW WE SHARE YOUR INFORMATION

  • Marketing Partners  We share aggregated or de-identified information with our marketing partners to provide certain services, offers and enhance your experience at Downtown Grand Hotel & This information cannon reasonably be used to identify you.
  • Service Providers – We disclose your personal information to vendors, consultants and other service providers, such as background check companies, payment processors, marketing companies, email service providers, advertising networks and advertisers, information technology services and those who need access to such information to provide services on our These companies are prohibited from retaining, using, or disclosing your personal information except as necessary to provide the services on our behalf.
  • Analytics and Search Engine Providers – We share personal information with these providers to assist us in the improvement and optimization of our Grand Rewards account records,

Grand Rewards Services and provide personal ads to our existing or “lookalike” customer base. Please see the following cookies notice for more information on this:

  • Compliance and Regulatory Purposes  We share your personal information with law enforcement agencies, public authorities or other third parties if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
  • Comply with a legal obligation, process or request, such as a subpoena, court order, search warrant or other valid legal process, or to comply with legal or administrative requirements of any governmental authorities, including gaming regulators, tax authorities and law enforcement authorities;
  • Enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • Detect, prevent or otherwise address security, fraud or technical issues; or
  • (In our sole discretion) to protect the rights, property or safety of the Downtown Grand Hotel & Casino, or any of its corporate affiliates or workforce members, our users and guests, a third party, or the public as required or permitted by law (including without limitation, exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction such as requesting and sharing information with credit bureaus).
    • Sale or Merger – We will also disclose your information to third parties in connection with business transfers or bankruptcy proceedings, as permitted by law:
  • In the event that we sell any business or assets, in which case we will disclose your data to the buyer of such business or assets; or
  • If Downtown Grand Hotel & Casino are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
  • Other than to the extent ordered a court of competent jurisdiction, the use and disclosure of all transferred user information will be subject to this However, any information you submit or that is collected after this type of transfer may be subject to a new privacy notice adopted by the successor entity.

7. COOKIES AND INTERNET-BASED ADVERTISING

Our website functions are based, in part, on your browser’s ability to accept cookie files, web beacons, tracking pixels, and other tracking technologies. Cookies are pieces of information that a website transfers to your hard drive that allow you to more easily navigate a website and customize website features that are updated each time you visit a website. Our web servers may automatically recognize a visitor’s domain name (such as .com, .edu, etc.), the web page from which a visitor enters our website, which pages a visitor visits on our website and on certain other websites, and/or how much time a visitor spends on each page. We may contract with third-party service providers to assist us in our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. We, or third parties, may also use cookies to track you or your online activities over time or across websites. We aggregate this information and use it to evaluate, better understand and improve our website, or to support our advertising practices. Additionally, we may use third-party software to serve ads on the website, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.

Companies may use cookies and similar tracking technologies as described in this Notice to gather information about your visits to our website(s), as well as your visits elsewhere on the Internet. These companies use this information to provide you with more relevant advertising known as interest-based advertising. For more information about third-party advertisers, please visit http://www.networkadvertising.org/choices/. This is a site offered by the Network Advertising Initiative (“NAI”) that includes information on how consumers can opt-out from receiving interest-based advertising from some or all of NAI’s members. The Digital Advertising Alliance (“DAA”) also offers a choice mechanism with respect to certain types of data collection and use by third parties available at www.aboutads.info. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.

You may set your preferences to refuse cookies; however, this may limit your access to some areas of our website. If you have enabled your Internet browser to refuse cookies, we will not collect personal information about you. However, we do not respond to browser do-not-track signals.

8. MINIMUM AGE REQUIREMENTS

We do not knowingly or intentionally collect any personally identifiable information from, or market to, individuals under the age of 21. Pursuant to law, persons under the age of 21 are not permitted to gamble at our properties or loiter in casino areas. Our online services are not intended for persons under the age of 13. Persons under the age of 13 are not allowed to use our online services in any fashion, so the provisions of the Children’s Online Privacy Protection Act do not apply to Downtown Grand Hotel & Casino online services. If you learn that a child under the age of 13 has provided us with personal information contrary to these rules, please contact us at the address listed in the “Contact Us” section below.

9. PROTECTING YOUR PERSONAL INFORMATION

We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Our policy is to restrict access to your personal information to only those employees, service providers and other third parties who need to know that information to provide products or services to you. We maintain commercially reasonable physical, electronic and procedural safeguards consistent with industry standards and other applicable standards as required by law and we require service providers and third parties to do the same.

While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Data security incidents and breaches can occur due   to   vulnerabilities,   criminal   exploits   or   other   factors   that   cannot   reasonably   be prevented. Accordingly, while our reasonable security program is designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the website cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

10. RETENTION

We keep your personal information for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us. Some personal information may be retained after your relationship with us ends.

Our websites may contain links to websites operated and maintained by third parties, over which we have no control. Privacy policies on such linked websites may be different from our Privacy Policy. You access such linked websites at your own risk. You should always read the Privacy Policy of a linked website before disclosing any personal information on such website.

12. POLICY CHANGES

To improve the services we can offer you, Downtown Grand may opt to expand our capabilities for obtaining information, including personal information, about users in the future. Downtown Grand will update this Privacy Policy when necessary to ensure that you are aware of developments in this area.

We will post those changes on our websites and update our Privacy Policy so that you will know what information we collect online, how we use it and what choices you have. Please be sure to check this page before proceeding to use our websites. Regardless of any changes we make to our Privacy Policy, we will always use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information, unless you give your express consent for us to do otherwise.

13. ADDITIONAL PRIVACY TERMS

In conducting business with Downtown Grand or using our websites, you may be required to agree to additional written or electronic agreements, including additional privacy terms and conditions (“Additional Privacy Terms”), as a condition to visiting the websites or receiving products, services and other information. In the event of any conflict between the Additional Privacy Terms and this Privacy Policy, the Additional Privacy Terms shall prevail but we will treat personal information that you provide to us before we adopt such Additional Privacy Terms in accordance with the terms of this Privacy Policy, unless and until you agree with the application of the Additional Privacy Terms to your personal information collected by us prior to the updates or amendments.

14. YOUR FEEDBACK

To help us improve our Privacy Policy and practices, please give us your feedback by emailing us at casinoevents@downtowngrand.com

15. CALIFORNIA PRIVACY RIGHTS AND DISCLOSURES

This California Privacy Rights and Disclosure section addresses legal obligations and rights specified in the California Consumer Privacy Act, or CCPA. For the purposes of this section 12 (California Privacy Rights and Disclosures), personal information means information that identifies, relates to, describes, is reasonably capable or being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device or household. If you need access to this privacy policy in a different format for accessibility reasons, please contact us at privacy@cimgroup.com, or contacting us at 1-833-687-3621.

These obligations and rights apply to businesses doing business in California and to California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.

The following chart describes the categories of personal information we may have collected about you in the past 12 months and, for each category, where and why we collected it, and the categories of entities with which we share or sold the personal information, if any:

Category of Personal Information (PI) Categories of entities with whom PI was shared Categories of entities with whom PI was sold
Address and other identifiers – such as name, postal address, email address, phone number, loyalty account number, date of birth, driver’s license number, photograph, passport number, or other similar identifiers · Third parties with whom we may partner with from time to time in order for those parties to send you electronic marketing, where we have received your consent to do so;

· Group companies, for business and operational purposes;
· Government authorities or other entities with legal authority to request the information; and
· Third party service providers

None.
Unique and online identifiers – such as IP address, device IDs, or other similar identifiers · Group companies, for business and operational purposes; and

· Third party service providers

None.
Financial information such as bank account information and credit card details · Transaction partners, including to facilitate billing;

· Third party service providers; and
· Government authorities or other entities with legal authority to request the information.

None.
Commercial information – such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies · Group companies, for business and operational purposes;

· Transaction partners, including to facilitate the completion phases of transactions contemplated by us, our parent company, or affiliated operating companies;
· Third party service providers; and
· Government authorities or other entities with legal authority to request the information.

None.
Education or other professional information · Group companies, for business and operational purposes;

· Transaction partners, including to facilitate the completion phases of transactions contemplated by you, us, our parent company, or affiliated operating companies;
· Third party service providers; and
· Government authorities or other entities with legal authority to request the information.

None.
Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology) · Group companies, for business and operational purposes;

· Third party service providers; and
· Government authorities or other entities with legal authority to request and for us to provide the information.

None.
Inferences drawn from CCPA PI – such as individual profiles, preferences, characteristics, behaviors · Transaction partners, including travel agents;

· Third party service providers; and
· Group companies, for business and operational purposes

None.

We do not knowingly sell the personal information of minors under 16 years of age.

A. YOUR RIGHT TO REQUEST DISCLOSURE OF INFORMATION WE COLLECT AND SHARE ABOUT YOU

If you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to personal information, subject to certain legal limitations and applicable exceptions. In particular, you can request the following:

  1. Specific Pieces of Information
    • The specific pieces of your personal information that we’ve collected about you in the past 12
  2. Categories of Information
    • The categories of your personal information that we’ve collected in the past 12
    • The categories of sources from which we collected personal
    • The business or commercial purposes for which we collected or sold personal
    • The categories of third parties with which we shared personal information in the past 12
    • The categories of third parties to whom we’ve sold personal information in the past 12 months, and the category or categories of personal information sold to
    • The categories of personal information that we’ve shared with service providers who provide services for us in the past 12 months, like processing your bill, and the category or categories of personal information sold to

To exercise your CCPA rights with request to this information, either email us at privacy@cimgroup.com, or contact us at 1-833-687-3621. These requests for disclosure are generally free.

B. YOUR RIGHT TO REQUEST THE DELETION OF PERSONAL INFORMATION

Upon your request, subject to certain legal limitations and applicable exceptions we will delete the personal information we have collected about you.

To exercise your right to request the deletion of your personal information, either email us at privacy@cimgroup.com, contact us at 1-833-687-3621. These requests for disclosure are generally free.

C. YOUR RIGHT TO ASK US NOT TO SELL YOUR PERSONAL INFORMATION

You have the right to ask us not to sell your personal information. You can exercise this right by calling us toll free at 1-833-687-3621 or emailing us at privacy@cimgroup.com.

We may ask for your permission to resume sale of your personal information at a later date, but will wait at least 12 months from receipt of your request before doing so.

D. OUR SUPPORT FOR THE EXERCISE OF YOUR DATA RIGHTS

We are committed to providing you control over your personal information. If you exercise any of these rights explained in this section of the Privacy Policy, we will not disadvantage you. You will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services.

E. NOTICE OF FINANCIAL INCENTIVES

We may offer you an opportunity to participate in a program where you receive coupons, vouchers and other offers that may be used at the hotel, casino, nearby attractions or for other products and services that may be of interest, in exchange for our sale of your personal information to this marketing company. You may sign up for this program at check in, and may withdraw from the program at any time by contacting us at the information below. These offers are reasonably related to the value of your data to Downtown Grand, based on revenue generated by this marketing partnership, in addition to revenue generated from increased traffic at attractions and activities at the hotel and casino, in light of the volume of anticipated participation in the coupon program.

F. HOW WE WILL HANDLE A REQUEST TO EXERCISE YOUR RIGHTS

For requests for access or deletion, we will first acknowledge receipt of your request. We will provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfil, we’ll let you know.

When you make a request to access or delete your personal information, we will take steps to verify your identity. These steps include asking you for personal information, such as your name, address, email, phone number, or other information we maintain about you. If we are unable to verify your identity to the degree of certainty required, we will not be able to fulfil the request. We will notify you to explain the basis of the denial.

You may also designate an authorized agent to submit requests on your behalf. If you do so, you will be required to verify your identity by providing us with certain personal information as described above. Additionally, we will also require that the agent provide us with either written permission signed by the you to act on your behalf, or a certified copy of Power of Attorney grated under the California Probate Code. We will deny the request if the agent is unable to submit proof that they are authorized to act on your behalf.

G. ADDITIONAL FACTS ABOUT HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with others, but only in certain limited situations, including: (i) within our corporate group or among our affiliated entities, all of which follow this Privacy Policy or equivalent privacy policies; (ii) with our service providers or other parties who agree to keep your personal information confidential and use it only on behalf of Downtown Grand; and (iii) as otherwise agreed by you. Third parties with whom we share your personal information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.

In some cases, we may be required to disclose certain personal information to comply with legal or regulatory obligations; to detect and protect against fraud, or any technical or security vulnerabilities; for an investigation or a legal process, such as a court order or subpoena; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the website, our businesses, or the public. In addition, Downtown Grand may disclose certain personal information to any third party that acquires, or is interested in acquiring, all or part of Downtown Grand’s assets or shares, or that succeeds Downtown Grand in carrying on all or a part of its business, whether by merger, acquisition, reorganization or otherwise.

16. EUROPEAN PRIVACY RIGHTS AND DISCLOSURES

This European Privacy Rights and Disclosure section addresses legal obligations and rights specified in the General Data Protection Regulation, or GDPR. These obligations and rights apply to individuals who are located in the European Economic Area. This section describes the policies and procedures followed by Downtown Grand regarding the collection, use and disclosure of your personal data when you visit the website, or otherwise interact with Downtown Grand. For the purposes of this section 13 (European Privacy Rights and Disclosures), personal data means any information relating to an identified or identifiable natural person, either directly or indirectly.

According to the GDPR, Downtown Grand is the controller of your personal data.

A. COLLECTION OF YOUR PERSONAL DATA

When you visit the website, receive services from us or otherwise interact with us, we may collect the following personal data about you: your name, postal address, email address, phone number, loyalty account information, date of birth, driver’s license number, photograph, passport number, credit card information, , as well as any other information you choose to provide to us.

B. USE OF YOUR PERSONAL DATA

We may use the personal data you give us to carry out the following purposes:

Purpose Lawful Basis
To contact you and to respond to your requests and enquiries when you contact us, or subscribe to receive email alerts We have a legitimate interest to respond to your requests and enquiries for ongoing business administration
To deliver services to you To manage and perform our contract with you
To send you our newsletter/bulletin or any other direct marketing information Where we have received your consent
For business administration, including statistical analysis We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient
To personalize your visit to the website and to assist you while you use the websites We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient
To improve the website by helping us understand who uses the websites We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient
For fraud prevention and detection and to comply with applicable laws, regulations or codes of practice To comply with our legal obligations

You have the right to object to processing of your personal data where that processing is carried out for our legitimate interest.

C. SHARING YOUR PERSONAL DATA

We may share your personal information with others, but only in certain limited situations, including: (i) within our corporate group or among our affiliated entities, all of which follow this Privacy Policy or equivalent privacy policies; (ii) with our service providers or other parties who agree to keep your personal information confidential and use it only on behalf of Downtown Grand; (iii) with third parties who we may partner with from time to time in order for those parties to send you electronic marketing, where we have received your consent to do so; and (iv) as otherwise agreed by you. Third parties with whom we share your personal information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.

In some cases, we may be required to disclose certain personal information to comply with legal or regulatory obligations; to detect and protect against fraud, or any technical or security vulnerabilities; for an investigation or a legal process, such as a court order or subpoena; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the website, our businesses, or the public. In addition, Downtown Grand may disclose certain personal information to any third party that acquires, or is interested in acquiring, all or part of Downtown Grand’s assets or shares, or that succeeds Downtown Grand in carrying on all or a part of its business, whether by merger, acquisition, reorganization or otherwise.

D. INTERNATIONAL TRANSFERS

When you are based in the European Union (the “EU”), personal data collected from you, including via the websites may be transferred to certain recipients located outside the EU, which do not provide a similar or adequate level of protection to that provided by countries in the EU. You hereby consent to the transfer of your personal data to recipients as described in this Privacy Policy which are located outside of the EU. You may withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

E. RIGHTS OF INDIVIDUALS

You may have certain data privacy rights which may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification and erasure of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; and (iii) ask for a copy of your personal data to be provided to you, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority. If you would like to exercise any of these rights, please feel free to email us at: privacy@cimgroup.com.

 

Last Updated: 4/8/2021