California Privacy Notice

Last Updated: January 22, 2020

This California Privacy Notice (“CA Notice”) supplements the Privacy Policy of Seminole Hard Rock Entertainment, Inc. ("Hard Rock", “we”, “us” or “our”) and applies solely to individual residents of the state of California (“you” or “consumers”). This CA Notice provides information concerning how we collect, use, disclose and otherwise process Personal Information of California residents within the scope of the California Consumer Privacy Act (CCPA).

For purposes of this CA Notice, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal Information does not include: de-identified or aggregated consumer information; health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the California Confidentiality of Medical Information Act; or information covered by certain sector-specific privacy laws including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, or the California Financial Information Privacy Act. All other capitalized terms used in this notice have the same meanings as in the Privacy Policy.

If you are a California resident who has provided Personal Information to Hard Rock or a California resident who believes Hard Rock collected your Personal Information, you may exercise your rights under the CCPA as explained in this CA Notice.

PLEASE NOTE: We have not sold and do not sell your Personal Information to any third party.

You have the following rights under the CCPA:

Right to Know

Subject to certain limits, you may ask us to provide them with the following information for the 12-month period preceding your request:

The categories of Personal Information we collected about them;

The categories of sources from which the Personal Information was collected;

The business or commercial purpose for collecting Personal Information;

The categories of third parties with whom we shared the Personal Information;

The specific pieces of Personal Information we collected about them (also called a data portability request);

If we disclosed Personal Information for a business purpose, a list of the disclosures for a business purpose and the Personal Information categories that each category of recipient received; and

If we sold Personal Information for a business purpose, a list of the sales and the Personal Information categories that each category of recipient purchased (as noted above, we do not sell Personal Information).

You may only make two requests for information in a 12-month period.

Right to Request Deletion

You may also ask us to delete any Personal Information that we have collected from you. Under the CCPA, we are not required to delete Personal Information that is necessary to: provide our Services; detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; debug to identify and repair errors that impair our Sites, App, and/or Services; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; comply with a legal obligation; or use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.

Right to Nondiscrimination

We will not discriminate against you for exercising your rights under the CCPA, including by:

Denying you goods or services;

Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

Providing you a different level or quality of goods or services; or

Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, the CCPA permits us to offer you certain financial incentives that can resultin different prices, rates, or quality levels, which are related to your Personal Information’s value. We do not currently offer any such financial incentives. We will update this information should that change at some point in the future.

Right to Opt Out of Sale

You have the right to direct businesses to not sell your Personal Information. As noted above, we do not sell your Personal Information, so there is no need to opt out with us.

Submission of Requests to Know and/or Requests to Delete

You may submit a request to know or a request to delete: (a) by submitting this online form; or (b) by calling the following toll free number 1-833-970-1536.

We are required to verify your identity before responding to a request to know or a request to delete. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account. To verify your identity, we may request two or more data points of Personal Information and other proof of identification depending on the nature of the request and the Personal Information requested.

Please note that following your verified request, we will send you your Personal Information from the following email address: dataprotection@hardrock.com Any response to your request including any Personal Information may be sent as an encrypted file.

Generally, we will process and respond to your request within 45 days. As permitted by the CCPA, if we need more time to respond, we will tell you why and our time to respond will be extended by an additional 45 days (up to 90 days total).

Once you have submitted a request, we will send you a receipt acknowledging your request within 10 days. Please be sure to check your email spam folder or filter for this receipt. If you do not receive such a receipt within 10 days of your submitted request, please send us an email to dataprotection@hardrock.com because an error may have occurred.

You also have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at dataprotection@hardrock.com for more information if you wish to submit a request through an authorized agent.

Personal Information We Collect

All of the categories of Personal Information we collect about you (as detailed below) come from the following categories of sources:

Directly from you – for example, from your account registration, forms you complete on the Sites or in the App, or surveys you complete.

Indirectly from you – for example, from observing your actions on our Sites or in the App and other websites, such as through the use of cookies and other online tracking technologies.

Our affiliate businesses – for example, from the home casinos listed in the Privacy Policy.

Third parties – for example, from social media sites such as Facebook or analytics providers such as Google Analytics.

In particular, we have collected the following categories of Personal Information from California consumers within the twelve (12) months preceding the Last Updated date of this CA Notice for the following purposes:

Category

Collected

Business Purpose

A. Identifiers, such as your name, address, email address, phone number, account number, or other similar identifiers.

Yes

To provide the Sites, the App, and the Services

To administer and provide Hard Rock rewards programs

For marketing and promotional purposes

To contact you in response to your inquiries

For security and fraud prevention purposes

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your name, signature, address, telephone number, credit card number, employment history.

Yes

To provide the Sites, the App, and the Services

For security and fraud prevention purposes

To comply with legal reporting requirements

C. Protected classification characteristics under California or federal law, such as age.

Yes

To comply with legal obligations

D. Commercial information, such as your use of our Services.

Yes

To provide the Sites, the App, and the Services

To evaluate, develop and improve the performance, features and functionalities of the Sites, the App, and the Services

For marketing purposes

E. Biometric information, such as fingerprints.

Not Collected

 

F. Internet or other similar network activity, such as your IP address or browser or device information.

Yes

To provide the Sites, the App, and the Services

To evaluate, develop and improve the performance, features and functionalities of the Sites, the App, and the Services

For marketing purposes

G. Geolocation data, such as information about your physical location collected from geolocation features on your device, including your IP address.

Yes

To confirm that a consumer is not from a jurisdiction where we are not offering our Services

H. Audio, electronic, visual, thermal, olfactory, or similar information, such as pictures or video of you.

Not Collected

 

I. Professional or employment-related information, such as your employer, job title, function and nature of your job duties and responsibilities.

Not Collected

 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).

Not Collected

 

K. Inferences drawn from other Personal Information.

Yes

For marketing purposes

Personal Information We Disclose

We may provide your Personal Information to service providers as described in the “Use of Personal Information” and “How We Share Your Information” sections of the Privacy Policy. Service providers are persons and entities that perform services on our behalf, including maintaining or servicing accounts, providing data storage and management, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, property management services, providing advertising or marketing services, or providing analytic services. Such service providers are prohibited from retaining, using, or disclosing the Personal Information for any purpose other than for the specific purpose of performing the services for us.

In particular, we have disclosed the following categories of Personal Information from California consumers within the twelve (12) months preceding the Last Updated date of this CA Notice:

Category A: Identifiers.

Category B: Personal information categories listed in the California Consumer Records statute.

Category F: Internet or similar network activity.

Category G: Geolocation data.

Category K: Inferences drawn from other Personal Information.

Contact

If you want to submit a request for your Personal Information or a request to delete your Personal Information, you may do so in one of the following ways:

By submitting this online form; or

By calling the following toll free number 1-833-970-1536.

If you have other questions or concerns, please email us at dataprotection@hardrock.com.

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