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  • Caesar's Privacy Notice

PRIVACY NOTICE

Last Updated: November 2020

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


This Privacy Notice describes how any personal data that London Clubs Management Limited, its affiliates and subsidiaries (collectively and individually, “London Clubs Management Ltd”, “we”, “us” or “our”) collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our approach and practices regarding your personal data and how we will treat it.


We value you as a customer and take your personal privacy seriously. In the course of providing you with services, we collect certain personal data about you that we understand you may consider private or confidential. 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 sharing this data with others.

  • We protect, according to strict standards of security and confidentiality, all non-public personal data we collect about our customers.
  • We maintain physical, electronic and organisational safeguards to protect this data.
  • We contractually require any person or organisation providing products or services to customers on our behalf to protect the privacy and confidentiality of this data.
  • We afford former customers the same protections as existing customers with respect to the use and sharing of their data.
  • We permit only authorised personnel, who are trained in the proper handling of this data, to have access to it.

Personal data is data that can be used to identify you, directly or indirectly. Personal data also includes anonymous data that is linked to data that can be used to directly or indirectly identify you. Personal data does not include data that has been irreversibly anonymised or aggregated so that it can no longer enable us, whether in combination with other data or otherwise, to identify you.


We may collect, use, store and transfer different kinds of personal data about you, which falls into the following categories:


  • Identity Data includes your first name, last name, user name or similar identifier, title, date of birth, gender and/or (if applicable) company name.
  • Contact Data includes your billing address, delivery address, country of origin, email address and telephone number(s).
  • Transaction Data includes details about payments to and from you and other details of use of our services or digital content.
  • Technical Data includes your internet protocol (IP) address, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices that you use to access Caesars Entertainment EMEA websites.
  • Profile Data includes your user name and (for registered users) password, your transactional history with us, and your interests, preferences, feedback and survey responses.
  • Usage Data includes data about how you use our services and Caesars Entertainment EMEA websites.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and (if relevant) third parties and your communication preferences.


We do not collect any special categories of personal data about you (which include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, data about your health, and genetic and biometric data).


We will only collect and use data which is necessary to comply with our legal obligations and assist us to administer our business and to provide you with the services you request. We may collect personal data about you (or your business) from other companies within Caesars Entertainment EMEA, Caesars US and from certain third-party sources.


Data that you provide when you use our services and products, including, but not limited to:


  • When you complete our membership or application forms, or when you sign up to our Caesars Rewards loyalty program. (The types of data we collect can include: your date of birth, first name, last name, address, phone number, email address, gender, occupation, and other data as shown on the form, as well as your passport, driver’s licence or some other recognised, government-issued document with a photograph.)
  • Anti-Money Laundering (AML) / Know Your Customer (KYC) Data, such as source of funds and proof of occupation
  • When you talk to us on the phone or in a casino
  • In email or letters
  • In insurance claims and other similar documents
  • When you use our websites, mobile phone applications and WiFi services
  • When you take part in our competitions or promotions
  • In surveys


Data we collect when you use our services and products, including, but not limited to:


  • Data about your transactions with us, including your payment history, details of occupation, attendance and gaming activity with us
  • We collect data about you when you visit Caesars Entertainment EMEA websites using cookies and other internet tracking software, including third-party software (please see our Cookie Approach for more data)
  • Data about the type of device you use, your device’s unique identifier, the IP address of your device, your operating system, the type of internet browser that you use, usage data, diagnostic data, and location data from or about the computers, phones, or other devices on which you install or access our products or services

Data we collect from third parties, including, but not limited to:


  • Data we receive from Central Credit, our business partners and other third parties such as ID data, criminal history, creditworthiness and insolvency records
  • Public data sources such as HM Land Registry, Company House and Interpol
  • Social networks

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by employees operating outside 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. We ask you not to share a password with anyone.


Unfortunately, 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.

If you are located in the EEA, our processing of your personal data will be based on the various legal bases described in the ‘Uses made of the data’ (or as otherwise disclosed to you at the time of collection).

We will use the data you provide to us for the purposes for which you provided the data, as indicated at the time of collection, and as otherwise permitted by law.


These are the ways in which we may use your personal data, as well as the legal basis within the EEA for doing so in each case:


  • 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. 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. 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 inquiries 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 helping to monitor 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 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 improve the products and services we provide you and to develop new products and services. This is necessary for our legitimate interests in studying how customers use our services or digital content, developing them and expanding our business.
  • 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 or, 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 obligations.
  • To protect and defend our rights or property or to enforce our agreements with you. This is necessary for our legitimate interests in recovering any debts due to us.
  • Otherwise with your consent or as permitted or required by law.


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, which withdrawal will not affect the lawfulness of any processing previously made on basis of your consent.

Why we have to ask

Sometimes we may have to ask you for more data about you and the source of funds you use to game with us. You may be unhappy about this and, although all data you give us is treated in the strictest confidence, you may feel it is an invasion of your privacy- we understand your feelings. However, we are obliged by law to obtain this data and documents in support where necessary to ensure that we tackle issues such as problem gambling, and gambling-associated crime.


Sometimes we must ask for more data about you to ensure that we comply with the law. It is as simple as that – it’s a legal and regulatory requirement. The kinds of questions we ask are not particular to you or to Caesars Entertainment EMEA; you can expect similar questions wherever you choose to gamble. A leaflet explaining the reasons why we may need to ask for more information is available on request at any of our UK casinos.


Why me?

Just like any bank or financial institution, we act responsibly and are required by law to be satisfied about the source of their customers’ funds. It doesn’t matter whether you use cash, cards or cheques to pay for your gaming in a casino, the rules still apply. So, if we ask for data to support your level of spend, this does not imply we have any suspicion about you as an individual, the same rules apply to everybody, we have clear responsibilities to ensure that our customers are gambling safely


It is not all about the law. If we’re asking you for more data, it is likely that you are a regular and valued customer. If we get to know you better by learning more about you, we can give you the best possible service and experience.


What will I be asked?

When you sign up to our Caesars Rewards loyalty program, we will ask you to provide some form of identification. This can be a passport, driver’s licence or some other recognised, government-issued document with a photograph. We may also ask for official documents to verify where you reside if required.


We may ask for more data about you if you become a more frequent player, or if you spend larger amounts. For example, we may ask you about your occupation or the source of your funds and ask you for documents to support the data that you have provided.


It may also be necessary for us to ask for additional data or documents to verify what you have told us. Please don’t be offended if we ask for this further data. We are not asking because we don’t trust you; we’re asking because the law requires us to record the data and to obtain documentary evidence in support where necessary. Please be advised, this additional data is necessary to meet legal obligations and to obtain documentary evidence in support where essential.


Is my personal data secure?

Yes, your personal data is secure – and respected. All data you give us is treated in the strictest confidence and used only to meet our legal obligations. Caesars Entertainment EMEA complies strictly with the requirements of data protection legislation and uses appropriate technical and organisational measures to ensure security of your personal data.


What happens if I don’t tell you?

We hope we’ve put to rest any concerns you may have about sharing data with us and reassured you about the reasons. If you still feel that you don’t want to provide the data we need, then, by law, we may have no choice but to stop the provision of our services and products to you, which also prevents you from gaming with us.


We trust that this data is sufficient for you to be assured that we treat customer data with the utmost confidentiality.

We may disclose and transfer your personal data to any entity, affiliate and subsidiary of London Clubs Management Ltd, 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, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our service providers have adopted such internal policies approved by European 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 organization 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 information 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. Please check these policies before you submit any personal data to these websites.

Last Updated: November 2020

We use cookies on our websites to help, provide, protect and improve our services.

This section – ‘Approach to Cookies’ describes the cookies we use and explains how we deal with the collected data. It also explains how cookies enable our website to function properly and why you may not be able to experience the full functionality of the website if you disable the use of cookies. This should be read alongside, and in addition to, the rest of this Privacy Notice.By visiting our website without changing your settings, you agree to receive cookies. If you do not accept the use of cookies, you can change your cookie settings at any time by following the instructions below.


What are cookies?

Cookies are text files containing small amounts of data which are downloaded to your computer or mobile device when you visit a certain webpage. Cookies are then sent back to the originating webpage on each subsequent visit, or to another webpage that recognises that cookie. Cookies are widely used in order to make websites work, or to work more efficiently.Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies may tell us, for example, whether you have visited our website before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests.There are two broad categories of cookies:

  • first-party cookies, served directly by us to your computer or mobile device; and
  • third-party cookies, which are served by a third party on our behalf (and we may use third-party cookies for functionality, performance/analytics, advertising/tracking and social media purposes).

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are session cookies, meaning that they are stored only temporarily during a browsing session and expire when you close your browser. Other cookies are persistent cookies, meaning that they are saved on your computer or mobile device for a fixed period and are not deleted when the browser is closed. They can be used by our website to recognise your computer or mobile device when you open your browser and browse the internet again.


Why do we use cookies?

We use cookies for a variety of reasons, including:

  • to enable, facilitate and streamline the functioning of and your access to our website;
  • to track traffic flow and patterns of travel in connection with our website;
  • to understand the total number of visitors to our website on an ongoing basis and the types of internet browsers and operating systems used by our visitors;
  • to monitor the performance of our website and continually improve them; and
  • to customise and enhance your online experience.

What types of cookies do we use?

The types of cookies used by us and our partners in connection with our website can be classified into one of five categories, namely cookies necessary for essential services, functionality cookies, performance and analytics cookies, advertising and tracking cookies, and social media cookies. We have set out some further information below about each category and the purposes of the cookies used:


Cookies necessary for essential services


These cookies are essential to provide you with our website and any services available through the website and to use some of their features, such as access to our Caesars Rewards program. Without these cookies, services you have asked for might not be possible.


Functionality Cookies

Functionality cookies record data about choices you have made and allow us to tailor our websites to you. These cookies mean that when you continue to use or come back to the websites, we can provide you with our services as you have asked for them to be provided.


Performance and Analytics Cookies


We use performance/analytics cookies to analyse how our website is accessed, used or is performing in order to provide you with a better user experience and to maintain, operate and continually improve the website. For example, these cookies allow us:

  • to gain a better understanding of our website visitors so that we can improve how we present our content;
  • to test different design ideas for particular pages, such as our homepage;
  • to determine the number of unique users of the website;
  • to improve our websites by measuring any errors that occur; and
  • to conduct research and diagnostics to improve product offerings.

To help us understand how users engage with our website we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) which uses cookies. Google Analytics collects data on the usage of our website. This data is used to compile reports and create services to help us improve our website and the services associated with it. The reports disclose website trends without identifying individual visitors. The data generated by the Google cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google may also transfer this data to third parties where required to do so by law, or where such third parties process the data on Google's behalf. Google will not associate your IP address with any other data held by Google. For more data on Google Analytics and how to opt out from Google Analytics please visit https://www.google.com/analytics/learn/privacy.html


Advertising and Tracking Cookies


We may allow third-party companies to place cookies on our website. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. These cookies store data about the content you are browsing together with an identifier linked to your device or IP address. These cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you have last seen it. This data is used for frequency-capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.


Social Media Cookies


On some pages of our website, third parties that provide applications through our website may set their own cookies in order to track the success of their applications or to customize applications for you. For example, when you share content using a social-media sharing button on our website (e.g. Facebook, Twitter or Google Plus), the social network that has created the button will record that you have done this. Because of how cookies work, we cannot access these cookies, nor can the third parties access the data in cookies used by us.


How to control or delete cookies

You have the right to accept or stop cookies from being stored on your device by modifying the settings in your web browser to reflect your cookie preferences. You may refuse the use of cookies at any time by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of our website. Unless you have adjusted your browser setting so that it will refuse cookies, cookies will be issued when you log on to our site and you will have been deemed to consent to the processing of data about you in the manner and for the purposes set out in this Privacy Notice.


Changes to our Approach to Cookies

We will occasionally update our Approach to Cookies to reflect changes in our practices and services. When we implement changes to our approach, we will revise the "Last updated" date at the top of this Privacy Notice. If we make any material changes in the way we collect, use, and/or share data held in cookies, we will notify you by prominently posting notice of the changes on our website. We recommend that you check this page from time to time to inform yourself of any changes in our Approach to Cookies.


Cookies that have been set in the past

If you have disabled one or more cookies, we may still use data collected from cookies prior to your disabled preference being set; however, we will stop using the disabled cookie to collect any further data.

Over time, it may be necessary to modify or supplement our Privacy Notice. If we make any material changes, we will post those changes on this site and update the date shown.

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 may contact us at marketing@caesars.co.uk or 020 7518 0000 or click on the "unsubscribe" option found on the bottom of all our email and SMS marketing communications.


Your legal rights in more detail (for UK and other EEA residents).


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 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 complain, please contact us. This does not override your right to complain to the relevant supervisory authority at any time.
  • Some of those rights may only apply to you if you are resident in the EEA or a country with similar data protection laws. To find out more about those specific rights, please see your local data protection authority’s website, such as the ICO’s website (www.ico.org.uk.)

We will retain your personal data for as long as it is necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.We will take all reasonable steps to ensure that your personal data is correct and up-to date.

We use surveillance systems to monitor all gaming areas and other public or sensitive areas of the Caesars Entertainment EMEA properties. Video and audio surveillance cameras are used for security purposes and to protect us, our customers and employees against potential violations of criminal or civil laws. Video and audio surveillance cameras may also be used at Caesars Entertainment EMEA Properties to enhance your customer experience and to provide services to you. Surveillance camera output is monitored by our employees and may be viewed by law-enforcement and regulatory authorities.


Generally, we do not collect any special categories of personal data about you (which include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic data). However, we may employ facial recognition technology when you enter our casinos to ensure that we are complying with our regulatory obligations to ensure safer gambling, enforce self-exclusions and barrings and to help us keep crime out of casinos. Such records are not retained.


We will only collect and use information which is necessary to comply with our legal and regulatory obligations and assist us to administer our business and to provide you with the services you request. We may collect personal information about you (or your business) from other companies within Caesars

Contact us

Requests for your personal information should be made by completing and sending to us a subject access request form (link to download). You will also need to send us two documents to verify your identity. Further details are provided on the form.


If you would like to exercise one of your rights as set out above, or you have a question about our Privacy Notice or the way your personal data is processed, please contact our Data Protection Officer by one of the following means:


By Email: dataprotection@caesars.co.uk

By Post:

The Data Protection Officer
Caesars Entertainment UK
55 Baker Street
London
W1U 8EW

Please be advised, in accordance with ICO guidance, if your request is regarded as manifestly unfounded or excessive, CEUK reserve the right to charge you a reasonable fee.