Privacy Policy

(Last updated: October 07, 2021)

This Privacy Policy (the “Policy”) tells you what information Nevada Property 1 LLC, doing business as The Cosmopolitan of Las Vegas (“The Cosmopolitan,” “we,” or “us”), collects as part of your visit to The Cosmopolitan, its website located at http://www.cosmopolitanlasvegas.com (the “Website”) or its other online services, and your participation, if any, in the Identity Membership & Rewards program. This Policy explains how that collected information is used, shared, and protected, along with the choices that you have regarding your information.

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.

This Policy is incorporated into and made a part of our Terms & Conditions, which may include an arbitration provision and class action waiver. Please note that we reserve the right to modify this Policy at any time. Material changes will be conspicuously posted on the Website or notice will otherwise be provided to you. All changes will be effective immediately upon posting to the Website unless otherwise stated.

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” as such term is contemplated by Nevada state law and other state, federal, or foreign laws, if and to the extent applicable to The Cosmopolitan, including but not limited to the California Consumer Privacy Act of 2018 (“CCPA”), the General Data Protection Regulation as issued by the European Parliament and Council of the European Union (“GDPR”), or other similar laws as they may be applicable.

If you are a California resident, additional information applicable to California residents is below in the Section titled “Your California Privacy Rights”.

A. THE TYPES OF INFORMATION WE COLLECT

Website & Services
You are not required to provide personal information to visit the Website. However, you must provide certain personal information to request information, make a reservation, or receive 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 that we may provide you with such products and services, communicate with you regarding our products and services, and send you information and materials for marketing and other purposes, subject to applicable laws and the terms of this Policy.

Reservations
To make a reservation, we require you to provide the following categories of personal information:

  • First and last name
  • 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 below.
  • 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 texts for marketing unless you separately 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
At check-in, we may 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 personal information as reflected on your government-issued identification, including your date of birth and gender. The scanned image is maintained by The Cosmopolitan, and certain personal information 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 from you 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.

On-premise
Once you are on-site at The Cosmopolitan, we may collect other personal information as part 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 require us to collect the following additional categories of personal information:

  • Date of Birth. In order to join Identity Membership & Rewards, we must verify your age, which requires us to collect your date of birth and maintain that personal information on file.
  • Government Identification. In the event you sign up to join Identity Membership & 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 scanned information and store it in our gaming records. Your government-issued identification provides us with certain personal information, such as your photograph, name, address, gender, date of birth, government identification number, and any other data contained on your government-issued 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.
  • Casino Credit Application Information. In order to process a casino credit application, we will collect your date of birth, social security number, employer information and may also collect financial account information. We will process such information for purposes of confirming your credit eligibility and will maintain such information for purposes of maintaining and servicing any resulting credit with The Cosmopolitan. Government regulations also require us to maintain this information for compliance and regulatory purposes.

Garage Monitoring
If you park your vehicle with us, we may collect information about your vehicle, including an image of the vehicle, the vehicle's make, model, and license plate number. This information may be collected manually (such as at check-in) or through technology known as “Automatic License Plate Recognition” that automatically captures the images of vehicle license plates and related information such as time/date of image capture. We use this information for safety, security, fraud prevention, and other similar purposes.

Call Recordings
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.

Other Contacts
When you contact us by any method, we collect and log the details of your request, concern or inquiry, and the contact information you provide, 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.

Video/Audio Surveillance
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 use 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, or where available on property via Apple Pay or similar third party payment platforms (such as Apple Pay). Available payment options vary depending on the payment location. All credit and debit card information is provided directly to our third-party booking engines, travel agencies, payment platforms and their related payment processors, which vary based on the products and services requested. If you elect to make a purchase, you will need to submit your payment card or payment platform information for processing, which may include your card number, expiration date, security code, and billing address as well as other information as may be required by the applicable booking engine, travel agency or payment platform. 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 or payment platform is subject to the approval of the applicable card issuer or payment platform, and The Cosmopolitan will not be liable in any way if a card issuer or payment platform refuses to accept your payment credentials for any reason.

Cookies
The Website may use cookies to track the use of the Website and to facilitate and enhance the user experience on the Website. "Cookies" are small pieces of information that are stored by your browser on your device. This Website uses both cookies that we implement and third-party cookies implemented by our vendors. For example, we use third parties to help display certain information to you on our Website and to track how you view our Website. The Website's cookies enable us to facilitate access to different areas of the Website. For example, we use cookies to learn when and how you and others visit the Website, what search terms you use to find the Website, and which third-party websites directed you to the Website. Cookies also tell us which pages of the Website are popular and which are not. Cookies can also help us improve your enjoyment of the Website, for example, by remembering your contact information and other personal information when you access or use the Website. Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that disabling the cookie function may impact your use and enjoyment of the Website.

Chat Functions
Our Website employs a third party tool to provide a live chat feature to connect you with online chat assistance. We record live chat sessions, store all data submitted from those sessions, and use all such information for those purposes contemplated by this Policy. Information submitted during a live chat session is not protected as or considered to be confidential information.

Apple Business Chat
If you use Apple Business Chat to communicate or transact business with us, your message will be sent through our third-party vendor for routing through the Apple platform. Both Apple and our third-party vendor may access data you send via Apple Business Chat. Apple Business Chat is subject to Apple's privacy policy, available at www.apple.com/legal/privacy, which we encourage you to review prior to using Apple Business Chat. Although messages are encrypted by Apple in transit, both Apple and our third-party vendor can access data you send via Apple Business Chat. In addition, we will collect data from your messages and use that data as contemplated in this Policy. Information submitted using Apple Business Chat is not protected as or considered to be confidential information.

Video and Other Embedded Content
The Website may incorporate content, including feeds scripts embedded in the Website’s code and visible content (for example, videos), provided by third parties including YouTube, Twitter, Instagram, and Vimeo. In some cases, those third parties collect data about how you interact with their content. Specifically, our use of YouTube content requires us to implement certain application programming interfaces (APIs) from YouTube, which allow for data collection, disclosure and use by YouTube pursuant to the Google Privacy Policy available here. By watching the videos and interacting with such content, you agree to the collection and use of such data. You may revoke YouTube’s access to your data by visiting the Google security settings page available here. See https://policies.google.com/privacy for more information about YouTube's Personal Data collection, use and sharing practices.

Videos you view on the Website may generate pieces of data (such as pixels or cookies) that tell us what videos you watched and when you watched them. We may connect these data points to other information that we collect from your use of our Website, which may be personal information. We share these data points with our third-party vendors that serve these videos on our Website and use this information to help personalize your experience with our Website by providing more tailored content and marketing material on the Website. We may also use this data as part of our online behavioral marketing campaigns, as described below, to serve you ads on social media or other third-party platforms.

Social Media
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 and other similar platforms. 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 various platforms , and such information becomes subject to their privacy and data policies when we do so. We encourage you to visit the privacy policies of these platforms for further information:

  • Facebook's Data Policy at https://www.facebook.com/full_data_use_policy
  • YouTube's Privacy Policy at https://policies.google.com/privacy
  • FourSquare's Privacy Policy at https://foursquare.com/legal/privacy
  • Instagram's Privacy Policy at https://www.instagram.com/about/legal/privacy/
  • Twitter's Privacy Policy at https://twitter.com/en/privacy
  • Pinterest's Privacy Policy at https://about.pinterest.com/en/privacy-policy
  • Snapchat's Privacy Policy at https://www.snap.com/en-US/privacy/privacy-policy

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 information with these social media platforms 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. If you are a California resident, please see the section titled “Your California Privacy Rights” below for more information about your choices with respect to our sharing of your personal information with social media 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 information 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.

Ad Networks
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 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 Website 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 servers to learn more about their cookies and other technologies.

If you do not want to receive those kinds of advertisements, look for the "Ad Choices" icon in the advertisements, which will contain a link to the privacy policy of the ad network that will provide you with information on how to opt-out of receiving such targeted advertising.

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.

Analytics
Like many websites, our Website uses Google Analytics to collect information about your use of our Website. Your web browser automatically sends this information to Google, such as the web address of the page that you visit and your IP address. Google may also set cookies or read preexisting cookies. This information is stored on Google´s servers. Google uses this information to provide us with reports about traffic to our Website and your visit to our Website (such as the domain from which you access the internet, the web address of the website from which you linked to our Website, the time and date of your visit to the web pages that you view and click-through). We will use this data to improve our Website structure and content. Google may also use this data in accordance with its Privacy Policy, which can be found at http://www.google.com/policies/privacy/. For more detailed information on how Google uses your data through our Website, please visit http://www.google.com/policies/privacy/partners/. 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.
For more information on how Google uses this data, visit Google's Privacy Policy and Google's page on "How Google Uses Information From Sites or Apps That Use Our Services".

Surveys
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.

Employment Applications
We collect job applicant information through a website run and maintained on our behalf by ADP. When you click on the link to apply for a position online, you will be redirected to ADP’s website, which is governed by the ADP terms and policies as posted on that site, including its privacy policy posted at https://www.adp.com/privacy.aspx. Please review all policies and terms posted on the ADP website before determining that you would like to submit your employment application online.

Other Information
We collect job applicant information through a website run and maintained on our behalf by ADP. When you click on the link to apply for a position online, you will be redirected to ADP’s website, which is governed by the ADP terms and policies as posted on that site, including its privacy policy posted at https://www.adp.com/privacy.aspx. Please review all policies and terms posted on the ADP website before determining that you would like to submit your employment application online.

B. HOW WE USE AND SHARE INFORMATION

We may use any personal 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 personal information to any third party for money. Regardless, you may notify us at our designated request address to opt-out of the sale of your personal information. Our designated request address for such requests is at privacy@cosmopolitanlasvegas.com. Please be aware that we will require you to verify your identity before processing any such request. Your permission to use the personal information we collect from you 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, such as ongoing communications regarding the status of a reservation or maintenance of an account with us. We will use and share your information if we believe doing so is necessary to accommodate your stay and activities while on our 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, 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. 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 separately opt-in with us to receive such texts. You may opt-out of marketing text messages by replying BYE to such message. 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 those persons and third parties specifically involved in processing your purchase or receipt 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 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 suppliers are authorized to use your personal information only as necessary to provide the applicable services to us.

Sharing Information with Our Third Party Venues
Certain venues within The Cosmopolitan property are owned or operated by third parties. However, we may receive your personal information from the third party venue as part of the services that we provide that third party venue.

Aggregate Data
We may aggregate your personal 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.

Cookies and Other Tracking Technologies
Our Website suppliers may use cookies and other tracking technologies to track Website visitors across the internet to understand how you get to the Website and to track how you use the Website, including whether and how you complete a reservation.

C. SECURITY MEASURES WE TAKE TO PROTECT YOUR PERSONAL INFORMATION

We have implemented commercially 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 regular access to personal information to our employees and third party vendors 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 (or one of our third party venues onsite). We use commercially reasonable efforts to review our vendors’ and their security practices.
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 these 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 may request information as to the nature of the personal information stored or processed about you by The Cosmopolitan and may request amendments to that personal information at the email address below. 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 information 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 make such a request. Except as set forth below with respect to certain California privacy rights applicable to California consumers, any requests related to your personal information or this Privacy Policy must be submitted to Privacy@cosmopolitanlasvegas.com to ensure our Privacy Office receives them and can timely respond. However, please be aware that we will need to confirm your identity before making any changes or otherwise responding.

If your request to review or update your personal information is denied, you may request information on why it was denied. You may resort to the dispute resolution described in the Terms & Conditions unless otherwise prohibited by law.

E. CALIFORNIA PRIVACY RIGHTS

Subject to certain limitations, if you are a California resident you may make the following requests with regard to your personal information. Instructions on making these requests is below. Please note that California law allows California residents to make the following requests, but applicable law may not require, permit or authorize us to honor all requests.

Right to Know. You have a right to request information on the following information: (a) the categories of personal information we collected about you in the prior 12-month period, (b) the categories of sources from which the personal information was collected, (c) the business or commercial purpose for which we collected your personal information, (d) the categories of personal information we disclosed or sold in the prior 12-month period, and (e) the categories of third parties with whom we shared or sold your personal information.

Right to Access. You have a right to request that we disclose to you the specific pieces of personal information that we have collected about you in the prior 12-month period.

Right to Deletion. You have a right to request that we delete personal information we collected about you.

Right to Opt-Out of the Sale. California law provides you the right to request to opt out of the sale of your personal information. Although we do not “sell” data in the traditional sense, we do utilize marketing and other tools in Facebook, such as their ad networks. In the context of these programs, certain data in the category of “Identifiers” and “Internet” is collected directly from you or your electronic device as you visit our website or other online services, which may be deemed a “sale” as defined by California law. In addition to the methods below, you may submit your opt-out request here: DO NOT SELL MY PERSONAL INFORMATION. If you would like to take further measures to help ensure that your information is not made available to any other online ad networks, you can also visit the websites https://tools.google.com/dlpage/gaoptout, http://www.networkadvertising.org or http://www.aboutads.info to change your consumer preferences with respect to certain online ads. To our knowledge we have not sold any Personal Data of an individual under 16 years of age.

Non-discrimination. You have a right to submit the above requests and we will not discriminate against you for exercising these rights.

How to Exercise Your Rights. To exercise your rights described in this Policy, you may submit your request to us by contacting us at any of the following:

  • Toll Free Number: 833.320.0756. Please leave us a voice mail that contains your name and preferred contact information and identifies the nature of the request that you are submitting (Request to Access Data; Request to Know Categories Collected,Shared, or Sold; Request to Delete; or Request to Opt-Out of the Sale).

  • Interactive Website: Our interactive webform contains buttons allowing you to indicate the nature of your request and provide your preferred contact information.

  • Email: If you submit your request via email, please identify in the subject line the type of request that you are submitting and provide your first and last name. The email address of the request will be used as contact information for you.

Who May Exercise Your Rights. You may make a request to exercise the above rights on behalf of yourself or on behalf of a child if you are a parent or legal guardian of the child. In addition, you may authorize an agent to exercise your rights on your behalf, if you provide the agent with written signed permission. Any legal entity acting as your agent must be registered with the Secretary of State to do business in the State of California.

Verification of Your Request. Once we receive your request, we will contact you to confirm receipt of your request, unless your request is a “Do Not Sell My Personal Information” request submitted through our automated “Do Not Sell” form. In addition, we may request that you provide us with additional information to allow us to verify your identity, the identity of the person that is the data subject of the personal information you have requested (if other than you), and the authenticity of your request. The information we may request may vary depending on the personal information we already have in our systems.

Certain types of requests, such as a request to access, may require additional verification to ensure you are who you say you are as we are subject to higher standards of authentication with respect to such requests.

If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to act on your behalf and submit the particular request, unless the agent holds a lawful Power of Attorney under California probate laws, in which case we will require evidence of such Power of Attorney.

We may deny your request as permitted or as required by law if we are unable to verify your identity or the authenticity of the request.

When We Will Respond.

We will confirm receipt of your request within 10 business days. We will try to respond to your request within 45 calendar days. If we require additional time to respond, we will inform you of the reason and may take an additional 45 calendar days to respond. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request.

We may not send you a separate response to “Do Not Sell My Personal Information” requests submitted through our automated “Do Not Sell” form.

We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. 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 and legal changes.

Categories of Personal Information. Below are lists of personal information required by California law identifying the personal information collected, where they are sourced, why they are collected, and if we disclose such personal information, the categories of service providers or other third parties to whom we disclose them:

Category of Personal Information Source Purpose Collected Disclosed for a Business Purpose Sold Categories of Entities We Disclose To Categories of Entities We Sell To
Identifiers Directly from you onsite, via our Website and other online services. Indirectly from travel agents and other booking service providers Providing you the service, product or communication requested and documenting the request. Contacting you regarding our services or products. Marketing our services and products to you. Safety, security, and fraud detection. Legal and regulatory requirements and best practices. Yes Yes Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services. Third party social media platforms. Third party advertising networks and analytics providers.
Personal Information categories under California Customer Records statute (Cal. Civ. Code 1798.80(e)) Directly from you onsite, via our Website and other online services. Indirectly from travel agents and other booking service providers. Providing you the service product or communication requested and documenting the request. Contacting you regarding our services or products. Marketing our services and products to you. Safety, security, and fraud detection. Legal and regulatory requirements and best practices. Yes No Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services. N/A
Commercial information Directly from you via the transactions you conduct onsite and online. Processing your payments. Processing credit applications. Records of your activities onsite, on our Website and other online services. Yes No Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services. N/A
Biometrics Directly from you while onsite via security surveillance systems. Security and legal investigations Yes No Service providers involved in the provision and maintenance of our security and surveillance systems. N/A
Internet Directly from you, your computer or other device. Indirectly from our service providers. Providing you the service, product or communication requested and documenting the request. Displaying and customizing content on our Website and other online services. Improving our Website and other online services. Marketing to you on other Websites and apps. Yes Yes Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services. Third party social media platforms. Third party advertising networks and analytics providers.
Geolocation (approximate only) Directly from you via IP address. Tracking use of our website and other online services. Yes No Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services N/A
Professional or employment-related Directly from you. Processing credit applications. Yes No Service providers involved in processing or providing our products and services. N/A
Inferences Directly from you. Improving the services and products that we provide. Yes No Service providers involved in processing or providing our products, services and communications. Service providers involved in the provision, maintenance and improvement of our Website and other online services. N/A

Although the categories of information above are collected for the designated purposes, personal information may be otherwise used for the purposes set forth in this Policy to the extent such use is consistent with the purpose for which it is collected.

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 the DPAs with the 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 the 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 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 833.320.0756, or by postal mail at 3708 Las Vegas Boulevard South, Las Vegas, Nevada 89109, Attn: Privacy.

I. Contact Information

If you have any questions about our data privacy or security measures, please contact us using the following information:
The Cosmopolitan of Las Vegas
Attn: Privacy
3708 Las Vegas Boulevard South
Las Vegas, Nevada 89109

Privacy@cosmopolitanlasvegas.com

This document was last updated May, 2021

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