(Last updated: May 25, 2018)
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND WHAT WE DO WITH THE INFORMATION THAT WE COLLECT AS PART OF THE INTERACTIONS.
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 personal information in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“the General Data Protection Regulation”), the Privacy Shield, and any other privacy laws, regulations and principles concerning the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the United States.
A. THE TYPES OF INFORMATION WE COLLECT
Personally Identifiable Information. You are not required to provide personally identifiable information to visit the Website. However, you must provide certain personally identifiable information to request information 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, including without limitation your name, contact information, financial information, demographic information, and other personal information, so we may provide you with such products and services and communicate with you and send you information and materials for marketing and other purposes, subject to applicable laws and the terms of this Policy.
Specifically, we collect your personally identifiable information as part of: (i) receiving and fulfilling reservation and information requests, (ii) your initial sign on to access the internet, (iii) purchasing products and services, (iv) registering for the Identity Membership & Rewards program, (v) submitting a job application, (vi) responding to communications from us (e.g., surveys, promotional offers, or reservation confirmations), and (vii) processing a casino credit application. If you provide your mobile or other telephone number to us and provided express your express consent,, we may send you text (SMS and MMS) messages and call you (both in-person and from automated dialing systems) from us at that telephone number. If you provide your email address, you consent to receive emails from us.
We may request the following types of personal information:
- email address;
- mailing address;
- social security or national identification number;
- date of birth;
- IP address;
- payment card information; and
- phone number.
Payment 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, which vary based on the products and services requested. These may include TravelClick, Expedia, TripleSeat, SevenRooms, and OpenTable. If you elect to make a purchase, you will need to submit your card number, expiration data, security code, and billing address as well as other information as may be required by the applicable booking engine. The Cosmopolitan does not directly access or handle your credit card information. 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.
Social Media. Our Website may allow you to connect and share information with various social media platforms, such as Facebook, Google+, 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, Instagram, Pinterest and Twitter to deliver 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.
Ad Networks; 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-personally identifiable information 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.
Other Information. 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 personally identifiable information. IP addresses help us determine your 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.
B. HOW WE USE AND SHARE INFORMATION
We may use any personally identifiable information 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 personally identifiable information to any third party. We may share information with those persons and third parties specifically involved in processing your purchase of our products or services or other activities involving the Website. We will not sell, share or rent the information that is collected to others in ways that differ from what is disclosed in this Policy.
We reserve the right to use and share your information if we believe doing so is necessary 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 information to send you promotional communications and information about The Cosmopolitan that we think may be of interest to you.
Your permission to use personal information we collect from you via Interactions in other ways will 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 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 or other 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 Website 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 information only as necessary to provide the applicable services to us.
Aggregate Data. We may aggregate your personally identifiable information, 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.
C. SECURITY MEASURES WE TAKE TO PROTECT YOUR PERSONAL INFORMATION
We have implemented reasonable technical, administrative, and physical security measures in an effort to safeguard the privacy of your personal information from unauthorized access or improper use. We limit access to personally identifiable information 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 information 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 information stored or processed about you by The Cosmopolitan and may request deletion or amendments.
You may email Privacy@cosmopolitanlasvegas.com to review, update, and revise your personal information.
If access is denied, you have the right to be informed about the reasons for denial. You may resort to the dispute resolution described in this Policy as well as in any competent regulatory body or authority. The Cosmopolitan shall handle in a transparent and timely manner any type of internal dispute resolution procedure about personal information.
If any information is inaccurate or incomplete, you may request that the data be amended. It is your responsibility to provide use with accurate personal information about yourself and to inform us of any changes. (e.g. new home address or change of name).
If you demonstrate that the purpose for which the data is being processed in no longer legal or appropriate, the data will be deleted, unless the applicable law requires otherwise. You also have the right to request the deletion of your personal data for any reason by emailing Privacy@cosmopolitanlasvegas.com.
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 information 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 personal information 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 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. This 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.
Also, 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.
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 information, 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 personally identifiable information 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 information to them.
H. INFORMATION FROM CHILDREN
We do not knowingly collect personal information 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 information, 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 May 25, 2018