(Last updated: October 15, 2019)
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND WHAT WE DO WITH THE INFORMATION THAT WE COLLECT AS A RESULT OF YOUR ONLINE OR OFFLINE VISIT TO US.
To the extent, you have any questions about or complaints concerning this Policy, please contact us at Privacy@cosmopolitanlasvegas.com.
This Policy is intended to provide adequate and consistent safeguards for the handling of certain “personal information,” “personal data,” or “personally identifiable information” as such terms are contemplated by Nevada state law or other state, federal, or foreign laws, if and to the extent applicable to The Cosmopolitan, such as the California Consumer Privacy Act, the General Data Protection Regulation as issued by the European Parliament and Council of the European Union, or other similar laws as they may be applicable (“Personal Data”).
A. THE TYPES OF INFORMATION WE COLLECT
Website & Services
You are not required to provide Personal Data to visit the Website. However, you must provide certain Personal Data to request information, make a reservation, or purchase products or services from The Cosmopolitan. We may collect any content, record, or electronic communication of any kind that you elect to send to us as part of that process, so we may provide you with such products and services, communicate with you regarding our services, and send you information and materials for marketing and other purposes, subject to applicable laws and the terms of this Policy.
To make a reservation, we require the following categories of information:
- Email Address. By providing your email address, you consent to receive marketing emails. You have the choice to opt-out from marketing emails as further described.
- Phone Number. If you elect to provide us a cell phone number during your reservation, we may send you texts regarding your stay from our automated dialing system. You are not required to provide us a cell phone number to book your reservation or stay with us. We will not send you any marketing texts unless you opt-in to receive such texts from us.
- Physical Mailing Address and Zip Code
- Payment Card Information. For further information on how we process payment cards, please see below.
At check-in, we will require proof of your identity through a government-issued identification, such as a driver’s license or passport. In order to meet government regulations, we scan your government-issued identification at check-in. As a result of this scan, we collect all data as reflected on your government-issued identification, including date of birth and gender. The scanned image is maintained by The Cosmopolitan, and certain Personal Data from the scanned image (such as your name) is incorporated into your reservation record.
If you have not previously provided us with a cell phone number, we may request a cell phone number at check-in, so that we can communicate with you to tell you when your room is ready and provide information about check-in and check-out. However, you are not required to provide us a cell phone number to stay with us.
Once you are on-site at our property, we may collect other Personal Data as part of (of (i) receiving and fulfilling reservation and information requests, (ii) your initial sign-on to access our guest wireless internet, (iii) purchasing products and services, (iv) registering for the Identity Membership & Rewards program, (v) responding to communications from us (e.g., surveys, promotional offers, or reservation confirmations), and (vi) processing a casino credit application. These activities may collect the following additional categories of:
Date of Birth. In order to join Identity Membership and Rewards, we must verify your age, which requires us to collect your date of birth and maintains that Personal Data on file.
Government Identification. In the event you sign up to join Identify Identity Membership and Rewards or otherwise visit the casino cage to purchase chips or collect winnings, we will scan your government-issued identification as required by government regulations. We maintain the scan and store it in our gaming records. Your government-issued identification provides us with certain Personal Data, such as your photograph, name, address, gender, date of birth, and government identification number, and any other data contained on your identification.
IP MAC Addresses and Device IDs. In order to access our free wifi services, we will collect your MAC address and/or IP address and/or device ID from every device that you use to access the wifi services. Use of wifi is also subject to the Guest Wireless Network Terms of Service.
We may record calls for customer service, training, and other purposes, such as investigations and legal disputes. Call recordings may be stored for a minimum of 30 days but may be kept longer as reasonably necessary for security or other investigations, in the event of disputes or legal proceedings, or as otherwise required or permitted by applicable law.
When you contact us by any method, we collect and log the details of your contact in order to respond to you. This information is logged in our internal systems maintained by us or by third party providers on our behalf. For example, if you sign up for us to send you offers, we will use your email address to send you offers.
The Cosmopolitan employs video and audio surveillance technology both in the casino area and throughout the property. Video surveillance technology may also allow for the collection of facial recognition technology. We may maintain surveillance recordings for at least seven (7) days and may maintain them for longer as necessary to meet our legal obligations and as contemplated by our policies.
Payment Card Information
Purchases of products or services must be made by credit or debit card. All credit and debit card information is provided directly to our third-party booking engines, travel agencies, and payment processors, which vary based on the products and services requested. If you elect to make a purchase, you will need to submit your card number, expiration date, security code, and billing address as well as other information as may be required by the applicable booking engine. In limited instances for group reservations, we may receive credit or debit card information for processing, which we may share with our third-party processors. We are regularly audited under the Payment Credit Industry – Data Security Standard (PCI-DSS). Payment by credit or debit card is subject to the approval of the card issuer, and The Cosmopolitan will not be liable in any way if a card issuer refuses to accept a credit or debit card for any reason.
Apple Business Chat
We use third-party vendors and their technologies to track how our Website visitors use our Website, including whether you complete a reservation, what other websites you visit to compare price, and the links and content you view on our Website. These vendors allow us to monitor your use of our Website live and record that usage session, which we use to help improve our Website.
Our Website may allow you to connect and share information with various social media platforms, such as Facebook, Snapchat, YouTube, FourSquare, Instagram, Twitter, and Pinterest. These features may require us to implement cookies, plug-ins, and/or APIs provided by such social media platforms to facilitate communications and features. We may share information that you provide us or that we may collect about your use of the Website with these platforms, and such information becomes subject to their privacy and data policies. We encourage you to visit the privacy policies of these platforms for further information:
In addition, by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third-party platform. As a result, we cannot be responsible for any use of your information or content by a third-party platform, which you use at your own risk.
We may also use the advertising services and networks offered by these social media platforms, such as Facebook, YouTube, Instagram, Pinterest, and Twitter, to deliver ad content. We may share Personal Data with these social media platforms users to allow such platforms to identify similar platform users that may be interested in our ad content. Use of these services requires the social media platform to implement cookies and/or pixels to deliver ads to you while online with such platforms.
We may also monitor our presence on social media ourselves or through third-party vendors, which means we may view your pictures or postings on social media that are from or relating to The Cosmopolitan. We may contact you from time to time through Personal Data that we may have or receive through the third party social media platform or otherwise in order to request permission to use your content on our Website or for other purposes.
Behavioral and Targeted Advertising. We use third-party ad networks (called third-party ad servers or network advertisers, including Google, Facebook, Sojern, VisualIQ, IgnitionOne, and Dstillery, to deliver ads to you on our behalf. These third-party ad networks may place their cookies, web beacons or other technology on the Website or in your browser to collect non-Personal Data about you when you visit the Website (such as browser type, time and date, browsing or transaction activity, subject of advertisements clicked or scrolled over, or a platform-provided identifier during your visits to this and other websites) to enable those third-party ad networks to deliver advertisements to you on third-party websites and mobile applications for our products and services or those of third parties that are likely to be of interest to you. For example, Google uses the Doubleclick cookie to enable it and its partners to serve ads to you based on your visit to our Website and/or other websites on the internet.
We encourage you to review the privacy policies of advertisers and ad services to learn more about their cookies and other technologies.
You can also visit the websites http://www.networkadvertising.org or http://www.aboutads.info to change your consumer preferences with respect to certain online ads and to obtain further information about third-party ad networks and online behavioral advertising.
You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page and installing the Google Analytics browser add-on, currently made available by Google at https://tools.google.com/dlpage/gaoptout.
Google Analytics Advertising Features
We have also enabled the Google AdWords feature along with the following Google Analytics Advertising Features: Google Display Network Impression Reporting, Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting. The Google Display Network Impression Reporting uses the Google Analytics cookie to track our ad impressions and your interactions with those impressions, including the effectiveness of those ads, which generates reports for us to help us analyze our advertisements. Remarketing with Google Analytics uses the Google Analytics cookie to serve advertisements to you across the internet based on your visit to our Website. Google Analytics Demographics and Interest Reporting uses a third-party cookie to collect information about our Website traffic by tracking users across websites and across time, which generates a report for us to better understand our Website users.
We may initiate surveys from time to time, using a third-party survey provider. The survey provider collects and processes your survey responses on our behalf and provides us the information in response to the surveys. We use this survey data to help improve our services and our Website.
We also collect information that, in and of itself, cannot be used to specifically identify you, such as the characteristics of the device and software that you use to access the Website. This information includes without limitation internet browser type, other characteristics of your device and software, domain names of your Internet Service Provider (ISP), your approximate geographic location, a record of your usage of the Website, the time of your usage and aggregated personal data that cannot be used to specifically identify you. IP addresses are not used to track a user’s session, and we do not link IP addresses to any Personal Data. IP addresses help us determine your approximate geographic location and how often different areas of the Website are visited. We will use this information to monitor and prevent fraud, diagnose problems, and anonymously estimate demographic information. Such information, which is collected passively using various technologies, cannot in and of itself be used to specifically identify you. We also collect this type of data (including without limitation information of the types set forth above) from third parties. The information we collect from third parties may be combined with the information we collect from you. Our Website provider may collect information about your visits to the Website and other websites, such as your user settings.
Do Not Track
Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
B. HOW WE USE AND SHARE INFORMATION
We may use any Personal Data or other information that you voluntarily provide to us to provide you with information, products, or services that you may request from us. We do not sell, rent, or loan any of your Personal Data to any third party for monetary consideration.
Regardless, you may notify us at our designated request address to opt-out of the sale of your information. Our designated request address for such requests is at firstname.lastname@example.org. Please be aware that we will require you to verify identity before processing any such request.
We may share information with those persons and third parties specifically involved in processing your purchase of our products or services, accommodating your stay and activities while on our property, or other activities involving the provision, maintenance, and improvement of the Website and other products and services. We will not share the information that is collected to others in ways that differ from what is disclosed in this Policy.
We will use and share your information if we believe doing so is necessary to accommodate your stay and activities while on property and otherwise to operate the Website as further set forth below. We use your information to customize your browsing experience, display custom content to you and communicate with you, and otherwise respond to your questions and suggestions regarding the Website as may be permitted by applicable law. The Cosmopolitan may also use your Personal Data to send you promotional communications and information about The Cosmopolitan that we think may be of interest to you.
Your permission to use the Personal Data we collect from you via your interactions with us in other ways may be implied from the nature of the service requested or transaction undertaken. For example, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request.
We will send you emails regarding your transactions with us. We will also send you marketing emails if you provide us your email address. You may unsubscribe from marketing emails from The Cosmopolitan by clicking on the “unsubscribe” links in those emails. Please note that if The Cosmopolitan has shared your information with third parties as permitted by this Policy, opting out or unsubscribing from marketing messages from The Cosmopolitan will apply to marketing messages coming from The Cosmopolitan only, and not to marketing messages coming from such third parties. To opt-out of messages from third parties, please contact those third parties directly.
If you provide us with a cell phone number, we will send you text messages related to your stay with us. We will not send you marketing texts unless you opt-in with us to receive such texts. You may opt-out of marketing text messages by replay BYE. Your provider’s message and data rates apply to all texts that you may send to or receive from us.
We reserve the right to share your information collected from the Website with third parties to the extent permitted by applicable law, or if in our sole discretion, it is reasonable to do so, including in the event of a subpoena or law enforcement request, security issue or to protect our rights or the rights of a third party. We may also disclose information that is necessary to identify, contact, or bring legal action in the event of a violation of our contracts, policies, or procedures.
Sharing Information with Our Suppliers
We may share information with our suppliers, marketing suppliers, reservation system provider, advertising agencies, email suppliers, booking engines, and other suppliers as necessary to provide the Website (including all of the Website’s features) and our products and services to you. We require those suppliers to comply with all applicable data privacy laws and regulations. These companies are authorized to use your Personal Data only as necessary to provide the applicable services to us.
We may aggregate your Personal Data, either alone or with other data, to create anonymous “aggregate data” regarding the users of our Website. Aggregate data is information that describes the habits, usage patterns, or demographics of users as a group but does not reveal the identity of particular users. This data will not identify you but will be used by The Cosmopolitan internally as statistical information to determine such things as user demographics and usage patterns of our Website. We may use aggregate data to understand the needs of our community of users, to determine what kinds of programs and services we can help provide, and to improve and enrich our products, services, marketing, and Website content.
Cookies and Other Tracking Technologies
C. SECURITY MEASURES WE TAKE TO PROTECT YOUR PERSONAL INFORMATION
We have implemented commercially available technical, administrative, and physical security measures in an effort to safeguard the privacy of your Personal Data from unauthorized access or improper use. We limit access to Personal Data to our employees, and third parties whom we believe need to have access to such information for The Cosmopolitan to respond to your requests and provide you with the information, products, or services you request from us.
From time to time, The Cosmopolitan will review our security procedures in order to consider appropriate new technology and methods to enhance our security procedures as new technology becomes available. However, you acknowledge and agree that despite our best efforts, no security measures are perfect or impenetrable, and your Personal Data may still be accessed and used by others without authorization in the event of a security breach.
D. YOUR RIGHTS
You have the right to be provided with information as to the nature of the Personal Data stored or processed about you by The Cosmopolitan and may request deletion or amendments. If any information is inaccurate or incomplete, you may request that the data be amended. It is your responsibility to provide us with accurate Personal Data about yourself and to inform us of any changes. (e.g., new home address or change of name).
You may email Privacy@cosmopolitanlasvegas.com to review, update, and revise your Personal Data. However, please be aware that we will need to confirm your identity before making any changes.
You have the right to request the deletion of your Personal Data for any reason by emailing Privacy@cosmopolitanlasvegas.com. We have no obligation to process such request until you are able to confirm your identity.
Occasionally, information that you request to be removed will be retained in certain files for a period of time in order to properly resolve disputes, to troubleshoot problems, or as may be required by applicable law. In addition, some types of information may be stored indefinitely on “back up” systems or within log files due to technical constraints, or financial or legal requirements. Therefore, you should not always expect that all of your Personal Data will be completely removed from our databases in response to your request.
E. CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you have the right to request information from us regarding the manner in which The Cosmopolitan shares certain categories of your Personal Data with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
- The categories of your information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- The names and addresses of the third parties that received the information;
- And if the nature of the third party's business cannot be determined from their name, examples of the products or services marketed.
- Information may be provided in a standardized format that is not specific to you. The designated email address for these requests is Privacy@cosmopolitanlasvegas.com.
F. OBLIGATIONS TO DATA PROTECTION AUTHORITIES (“DPAs”)
We will respond diligently and appropriately to requests from DPAs about this Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Data, we will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
G. THIRD-PARTY WEBSITES
The Website may link to, or be linked to, websites not maintained or controlled by The Cosmopolitan. Such links are provided as a convenience, and The Cosmopolitan is not responsible for the content or accuracy of, and does not warrant or endorse, any third-party website. The Cosmopolitan is not responsible for the privacy policies or practices of any third parties or third-party websites, including any websites linked to or from the Website. To the extent that you disclose Personal Data to any such third parties, different rules may apply to the use and disclosure of such information. We encourage you to review the privacy policies of third-party websites before disclosing your Personal Data to them.
H. INFORMATION FROM CHILDREN
We do not knowingly collect Personal Data from children under the age of 13. If you are the parent or guardian of a person under the age of 13 and believe that such person has provided The Cosmopolitan with Personal Data, you may request that it be deleted from our files by contacting us by email at Privacy@cosmopolitanlasvegas.com, by telephone at 702.698.1000, or by postal mail at 3708 Las Vegas Boulevard South, Las Vegas, Nevada 89109, Attn: Privacy.
I. CONSENT TO THIS POLICY AND CONTACT INFORMATION
The Cosmopolitan of Las Vegas, 3708 Las Vegas Boulevard South, Las Vegas, Nevada 89109, Attn: Privacy
This document was last updated on October 15, 2019