Last Updated: October 2018
This policy describes how any personal information that “London Clubs Management Ltd”, its affiliates and subsidiaries (collectively, “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 views and practices regarding your personal data and how we will treat it. Caesars Entertainment EMEA is a trading name of London Clubs Management Ltd.
We value you as a customer and take your personal privacy seriously. In the course of providing you with services, we collect certain personal information about you that we understand you may consider private or confidential. This information 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 policies for collecting, using and sharing this information with others.
Personal information is information that can be used to directly or indirectly identify you. Personal information also includes anonymous information that is linked to information that can be used to directly or indirectly identify you. Personal information does not include information that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.
We will only collect and use information which is necessary to comply with our legal obligations and assist us to administer our business and provide you with the services you request. We may collect personal information about you (or your business) from other companies within Caesars Entertainment EMEA and from these sources:
Information 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 staff operating outside the EEA who work for us. Such staff 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. Please see Paragraph 6 below for additional information on disclosure of personal information.
All information 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 information 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 information 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 information, we will use strict procedures and security features to try to prevent unauthorised access.
We will use the information you provide to us for the specific purposes for which you provided the information, as stated at the time of collection, and as otherwise permitted by law.
The following are some ways in which we may use your information to administer our business and provide you with the products and services you request or may be of interest to you:
We may also use your data to provide you with information about promotions, goods and services which may be of interest to you and we may contact you about these by post or telephone.
We may also use your data to contact you by electronic means (e-mail or SMS) with information about promotions, goods and services which we believe will be of interest to you but only if you have consented to be contacted in this way. If you want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data.
Caesars Entertainment EMEA will not sell or rent to any third party any of the personal information or data that you provide to us.
Legal Basis for the Processing of Personal Information
If you are located in the European Economic Area (“EEA”), our processing of your personal information will be based on the following: To the extent that we obtain your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your personal information is necessary for the performance of a contract between you and us or for taking pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for us to comply with a legal obligation, we will process your personal information on the basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).
Please note that where you have given your consent to the processing of your personal information 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 information about you and the source of funds you use to game with us. You may be unhappy about this and, although all information you give us is treated in the strictest confidence, you may feel it is an invasion of your privacy, and we understand your feelings. However, we are obliged by law to obtain this information 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 information about you to ensure that we comply with the law. It’s as simple as that – it’s a legal and regulatory requirement. The kinds of questions we ask aren’t particular to you or to Caesars Entertainment EMEA; you can expect similar questions wherever you choose to gamble regularly. 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 our 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 information to support your level of spend, it doesn’t mean that we have any suspicion about you as an individual, because the same rules apply to everybody and we also have clear responsibilities to ensure that you are not placed at risk from gambling more than you can afford.
But it’s not all about the law. If we’re asking you for more information it’s 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 Total Rewards loyalty program, we will ask you to provide some form of identification. This can be a passport, drivers licence or some other recognised, government issued document with a photograph. We may also ask for official documents to verify where you reside.
We may ask for more information 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 information that you have provided.
Please don’t be offended if we ask for this further information. We’re not asking because we don’t trust you; we’re asking because the law requires us to record the information and obtain documentary evidence in support where necessary.
Is my personal information secure?
Yes, your personal information is secure – and respected. All information 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.
What happens if I don’t tell you?
We hope we’ve put to rest any concerns you may have about sharing information with us and reassured you about the reasons. If you still feel that you don’t want to provide the information 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 information is sufficient for you to be assured that we treat customer information with the utmost confidentiality. The copy of your financial information will be stored in a secure server controlled by the Compliance Department here at Caesars Entertainment EMEA head office and will only be available to Compliance Department team. It will not be stored in any casino premise.
We may disclose and transfer your personal information to any entity, affiliate and subsidiary of London Clubs Management Ltd, including those based outside of the EEA including our parent company, Caesars Entertainment Corporation, based in the United States of America. Where your personal information 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 information 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 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 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: May 2018
Cookies are text files containing small amounts of information 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”. In the following, we have set out some further information about each category and the purposes of the cookies used:
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 Total Rewards program. Without these cookies, services you have asked for might not be possible.
Functionality cookies record information 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.
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:
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 information 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 information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.
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 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.
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.
If you have disabled one or more cookies, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information.
If you have any questions or comments about this Cookies Policy, or any privacy matters generally, please contact us by email at email@example.com
You have the right to ask us not to use your personal data for 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 marketing communications at firstname.lastname@example.org or 0207 518 0000. You will need to indicate whether you wish to opt out of 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 email@example.com or 0207 518 0000 or click on the "unsubscribe" option found on the bottom of all our email and SMS marketing communications.
You also have the right to object to us processing your other personal information, to have your information deleted and its processing restricted. You also have the right to access or correct the personal information that we collect. You have the right to receive your personal information in a structured and standard format. You may lodge a complaint with the competent data protection authority regarding the processing of your personal information.
To protect the privacy and the security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.
Requests for your personal information should be made by completing and sending to us a subject access request form.
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 provide services to you. Surveillance camera output is monitored by our employees and may be viewed by law enforcement and regulatory authorities.
If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, the way your personal information is processed, please contact our Data Protection Officer by one of the following means:
By Email: firstname.lastname@example.org
The Data Protection Officer
Caesars Entertainment UK
55 Baker Street