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.
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:
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:
Data we collect when you use our services and products, including, but not limited to:
Data we collect from third parties, including, but not limited to:
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:
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.
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:
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
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:
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.
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 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:
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.
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.
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 email@example.com 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 firstname.lastname@example.org 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.
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
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:
The Data Protection Officer
Caesars Entertainment UK
55 Baker Street
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.