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  • Caesar's Privacy Notice

Data Processing Notice

Last Updated: July 2021

Caesars Entertainment EMEA is a trading name of London Clubs Management Ltd.

 

This Data Processing Notice (“DPN”) describes how any personal data that London Clubs Management Limited (the “Controller”), its affiliates and subsidiaries (collectively and individually, “London Clubs Management Ltd”, “we”, “us” or “our”) collect from you (the “Data Subject”), or that you provide to us, will be processed by us.

In the course of interacting with you and/or providing you with our services, we collect certain personal data about you. This data may be contained in applications and other forms you submit to us, gathered from your gaming activity with us, or obtained from our affiliates and other third parties. We are therefore providing you with this notice to explain our approach for collecting, using and, where necessary sharing this data with others.

The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom as well as the European Economic Area (“EEA”). It may also be processed by employees operating outside the United Kingdom and the EEA who work for us. Such employees may be engaged in, among other things, the provision of any requested services, the processing of your payment details and the provision of support services.

 

All data you provide to us is stored on secure servers. If you use our site to send personal data to us, your transmission will be protected by Secure Socket Layer (SSL). SSL is a technology that encrypts your data during transmission. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. You must not share your password with anyone.

 

The transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.

The processing of your personal data will be based on the various lawful basis described in the ‘Uses made of the data’ or as otherwise disclosed to you at the time of collection, and as otherwise permitted by law.

We may use your personal data for the following purposes:

 

  • To operate our Caesars Rewards Program. This is necessary for us to perform our contractual obligations to you;
  • To provide you with data about news, events, products, promotions or services that you request from us or which we feel may interest you, based on your preferences. You may be contacted about these by e-mail, SMS or post. To the extent that we require your consent for such communications (such as direct marketing emails) and you give it to us, we rely on your consent for providing you with the data concerned. You can withdraw your consent at any time;
  • Where we do not require your specific consent, such communications are necessary for our legitimate interests in studying how customers use our services or digital content, developing them, expanding our business and informing our marketing strategy;
  • To carry out our other obligations arising from agreements or contracts (including our obligations to you as a customer of our casinos) entered into between you and us. This is necessary for us to perform our contractual obligations to you;
  • To notify you about changes to our policies, terms and conditions or to personnel of Caesars Entertainment EMEA. This may be necessary for compliance with our legal obligations or performance of our contractual obligations to you or may be necessary for our legitimate interest in developing our business and operations from time to time;
  • To perform background checks for any reason (to the extent permitted by applicable laws), which includes but is not limited to any investigation into your identity, any credit checks or any enquiries into your personal history. This is necessary, in some instances, for compliance with our legal obligations and, in others, our legitimate interest in running our business efficiently, minimising the risk of bad debts, preventing fraud and fulfilling our regulatory obligations to ensure that customers are gaming safely and affordably;
  • To confirm the source of funds using confirmation packets and verifying this data with other casinos. This is necessary, in some instances, for compliance with our legal and regulatory obligations and, in others, our and/or other casinos’ legitimate interests in minimising the risk of bad debts and preventing fraud;
  • To create a more accurate and complete customer profile to gain a better understanding of the products and services you want to use. This is necessary for our legitimate interests in keeping our records updated and studying how customers use our services or digital content;
  • To cash your cheques and to process debit-card and other financial transactions. This is necessary for the performance of our contractual obligations to you and, in the context of debt recovery, our legitimate interest in recovering any debts due to us;
  • To detect, investigate, report and seek to prevent financial crime and problem gambling to comply with the regulations that apply to us. This is necessary for compliance with our legal and regulatory obligations; and
  • Otherwise permitted by you, or where we are required by law to do so.

 

Caesars Entertainment EMEA will not sell or rent to any third party any of the personal data that we collect in relation to you.

 

Please note that, where you have given your consent to the processing of your personal data, you may withdraw your consent at any time. Any such withdrawal will not affect the lawfulness of any processing previously made on the basis of your prior consent.

We may disclose and transfer your personal data to any entity, affiliate and subsidiary of Caesars Entertainment EMEA, including those based outside of the EEA and including our parent company, Caesars Entertainment Corporation, based in the United States of America. Where your personal data is transferred to a country outside the EEA, we will enter into model contractual clauses as adopted by the European Commission, will rely on individual country adequacy status or binding corporate rules where our service providers have adopted such internal policies approved by the UK and EU data protection authorities.

 

We may also disclose data that we collect from or about you with non-affiliated third parties as permitted or required by law, including those based outside of the EEA:

 

  • Third-Party service providers - We work with many different service providers and other third parties who process your personal data on our behalf. We only do business with companies that meet our standards on the processing of data and security, and we only share data that is necessary for the service.
  • Business transfers; bankruptcy - If Caesars Entertainment EMEA or substantially all of its assets are acquired by a third party or in the event of a merger, reorganisation, joint venture, assignment, spin- off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.
  • Compliance with legal obligations - We may disclose personal data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or process; or to comply with any legal requirements of any governmental authority, including, but not limited to, gaming regulators; or in order to enforce the terms of loyalty program membership with you and other agreements.
  • Protection of our business and customers – We may disclose personal data to protect the rights, property or safety of Caesars Entertainment EMEA, our customers or others. This includes exchanging data with other casinos, companies and organisations for the prevention and detection of crime and problem gambling. For example, in order to protect our business from criminal activity and to comply with the Licensing Objectives of the Gambling Act 2005 (i.e. preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime), we may share your personal data such as name, ID card / passport data, contact details, gambling records, photographic images and relevant incident / accident details with other UK land-based casino operators, or if you are found to have committed a crime, such as, but not limited to, cheating, theft, money laundering or robbery.
  • Fraud prevention - As part of our registration ID and verification process, we may conduct identity verification using a recognised fraud prevention agency.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We do not expressly or impliedly endorse the materials disseminated at those websites, nor does the existence of a link to another site expressly or impliedly mean that the organisation or person publishing at that site endorses any of the materials on our site. Links to other websites are provided only as a convenience to our users and for data only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them.

 

If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. 

 

Caesars Entertainment EMEA websites

 

For users of our websites, we have a separate Cookie Policy, which describes our application and use of cookies in relation to your browsing activities and related data.

 

How long do we store your data for?

 

We will process your personal data for as long as it is necessary to fulfil the purposes outlined in this Data Processing Notice after which it will be retained for a defined period as stipulated in the CEUK Data Retention Policy. Once this period, or any subsequent change in the retention period has expired, it will be securely deleted.

 

Marketing consent.

 

You have the right to ask us not to use your personal data for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by leaving certain boxes unticked on the forms we use to collect your data. You can also exercise the right at any time by contacting us to opt out of direct marketing communications at marketing@caesars.co.uk or 020 7518 0000. You will need to indicate whether you wish to opt out of direct marketing communications from Caesars Entertainment UK casinos (this is the default choice) or from the entire Caesars Entertainment EMEA.

 

If you prefer not to receive emails or SMS messages from Caesars Entertainment EMEA Group, you can click on the ‘unsubscribe’ option found on the bottom of all our email and SMS marketing communications or you may contact us at marketing@caesars.co.uk or 020 7518 0000.

In certain circumstances, you have the following legal rights in relation to your personal data (to the extent consisting of “personal data” in the EEA and countries with similar data protection laws, and so we use that term in the rest of this paragraph). We may ask you for additional data, so that we take reasonable steps to check that – for example – we only provide personal data to the person to whom the data relate.

 

  • Right of access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing such data.
  • Right of rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data that you provide to us.
  • Right to erasure of your personal data. This enables you to ask us to delete or remove personal data in certain circumstances. Please note, however, that we may retain your data in certain circumstances in accordance with law, which will be notified to you, if applicable, at the time of your request.
  • Right to restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you would like us to establish the accuracy of such data; (b) where our use of the data is unlawful, but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to portability of your personal data to you or to a third party. If you so request, we shall provide you, or a third party that you have chosen, with a copy of your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated data that you initially provided consent for us to use, and is in the whole mechanically processed, or where we used the data to perform our contract with you.
  • Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground, in which case we will consider whether we have compelling reasons to continue to process your data.
  • Right to object to direct marketing. You also have the right to object where we are processing your personal data for purposes of direct marketing.
  • Right to withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products, content or services to you.
  • Right to complain in the UK or elsewhere in the EEA. If you would like to register a complaint , please contact us. This does not override your right to complain to the relevant supervisory authority at any time.

We are committed to creating a culture of Safer Gambling within our casinos. We have appointed Safer Gambling Ambassadors across all our sites, in order to protect young and vulnerable people from being exploited by gambling, prevent underage gambling and increase support for the treatment of gambling harm.