Privacy Policy
PRIVACY POLICY
BORGATA HOTEL CASINO & SPA – Online Social Gaming Services
This privacy policy (“ Policy”) describes the information collection, use, sharing, and related practices applicable to (1) the New Jersey BorgataFreeCasino.com online social gaming website; and (2) the New Jersey BorgataFreeCasino.com online social gaming mobile app (together the “ Services”) provided by Marina District Development Company, LLC d/b/a Borgata Hotel Casino & Spa, located at 1 Borgata Way, Atlantic City, New Jersey 08401 (“ Borgata,” “ we,” “ our” or “ us”). This Policy is a legally binding contract between us and anyone who accesses or uses the Services (“ you” or “ your”). As used in this Policy, the word “ including” means including, without limitation. Capitalized terms not defined in this Policy have the definitions set forth in the Terms and Conditions for the Services. If you have any questions about this Policy, please contact us at cs@borgatafreecasino.com. If you do not want us to collect, use, or share your information in the ways described in this Policy, please do not use the Services. By using the Services, you consent to the collection and use of your information (including personally identifiable information) by us as identified herein, in compliance with this Policy and the Terms and Conditions for the Services.
This Policy governs the information collection, use, sharing, and related practices applicable to the Services described herein only. This Policy is separate and distinct from the privacy policies that govern the online gaming services offered by Borgata (in New Jersey only) and by MGM Resorts International in other jurisdictions, including the State of Nevada.
I. INFORMATION WE COLLECT
We collect information from a variety of sources and in a variety of ways, including the following:
Customer-Provided Information. You may provide us personal information when you use the Services, such as when you create an account. We may access and collect the information you provide, including your name, postal address, e-mail address, telephone numbers (including mobile telephone number) and date of birth.
Location, Gaming, and Transaction Information. When you use the Services, we and/or our third party service providers may collect information about your precise physical location, your gaming activity, and all transactions associated with your Account. Neither us nor our partners will pass on or resell your location information to any third party except that they reserve the right to provide location information as necessary to satisfy any law, regulation or government agency request.
Device Information. When you use the Services, we and our third party service providers may use cookies (see below), web beacons, tracking pixels, scripts, e-tags, and other technologies (“ Tracking Technologies”) to collect and analyze information about you and your activity. Information collected through Tracking Technologies may include the type of device; browser and operating system you are using; your device identifiers, such as your MAC address; the name you have associated with your device; the unique number associated with your Internet connection; your mobile telephone number; your Wi-Fi positioning system or device GPS coordinates; the web sites you visit; your precise geographic location; and your activities within the Services including the links you click, the pages you view, the bandwidth used, session time, the number of times you click a page or use a feature of the Services, the date and time you click on a page or use a feature, and the amount of time you spend on a page or using a feature. Information collected through Tracking Technologies is stored in log files. Although we do not recognize automated browser signals, which may include “do not track” instructions, we do not share any of the information we collect with third parties for the placement of online behavioral advertising.
Cookies. We may use cookies to store some information on your computer, laptop, tablet or mobile device when you access and use the Services. Cookies are small text files that are stored on your computer or equipment when you visit certain online pages and record your preferences. Cookies allow us to remember things about your visits across the Services, but cannot access or use other information on your computer. We do not use flash cookies to remember or use directly identifying personal information about you such as your name or email address. We use cookies to track use of the Services. We also may use cookies and third party cookies to monitor traffic to the Services, improve the Services, make it easier and/or more relevant for your use, and help us to show you advertisements which are relevant to your interests based on your use of the Services.
Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also modify your Flash Player settings to prevent the use of flash cookies.
If you choose to decline cookies, you may not be able to experience all of the interactive features available through the Services. You can visit http://www.aboutcookies.org/ in order to obtain more information on deleting or controlling cookies. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the Services.
Affiliate and Third Party Information. We may obtain information about you from MGM Resorts International and casinos, resorts, and properties that are owned, operated, managed by or affiliated with MGM Resorts International (collectively “ MGM Affiliates”) and from third parties, including our business partners.
II. HOW WE USE THE INFORMATION WE COLLECT
A. Use by Borgata
Marketing Purposes. We may use the information we collect for our own marketing purposes including notifying you of special promotions, offers, and events via push notifications, e-mail, and other means. We may also link personal information (including your name, mobile phone number, and e-mail address) with non-personal information (including information collected through Tracking Technologies and Wi-Fi services) and use such information for our own marketing purposes. If you do not want us to use your personal information for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.
Non-Marketing Purposes. We may use the information we collect for non-marketing purposes including (1) sending you push notifications or e-mails to provide you with alerts and updates about the Services; (2) monitoring and recording gaming-related activity; (3) conducting statistical or demographic analysis; (4) processing and tracking gaming and non-gaming transactions; (5) complying with legal and regulatory requirements; (6) customizing your experience with the Services; (7) protecting and defending Borgata, MGM Resorts International, and MGM Affiliates against legal actions or claims; (8) preventing fraud; (9) debt collection; (10) satisfying contractual obligations; and (11) cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest (collectively “ Non-Marketing Purposes”).
B. Sharing with MGM Affiliates
We may share the information we collect with MGM Affiliates for marketing purposes and for Non-Marketing Purposes. If you do not want us to share your personal information with MGM Affiliates for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.
C. Sharing with Third Parties
We may share the information we collect with our business partners and other third parties for (1) Non-Marketing Purposes, (2) joint marketing purposes, and (3) our business partners’ own marketing purposes.
D. Certain Business Transactions
We may share all of the information we collect with any successor to all or part of our business in connection with a transaction involving a sale, purchase, reorganization, merger, or transfer of any our assets or the assets of MGM Affiliates.
E. How to Opt-Out
If you wish to opt-out of receiving marketing communications from us, or do not want us to share your personal information for marketing purposes with our business partners, third parties or MGM Affiliates, please e-mail us at optout@mgmresorts.com, call us at (866) 761-7111, or write to us at:
MGM Resorts International
Attn: Privacy Policy
3549 Industrial Road
Las Vegas, Nevada 89109
Although you may opt-out of the use and sharing of personal information for marketing purposes, we may still use and share information we collect for Non-Marketing Purposes.
III. Security
The underlying software and hardware platform used for the Services is wholly-hosted by GameAccount Network PLC (GAN) on its servers. Non-gaming information and non-live social gaming data collected by us through the Services is stored on secure servers located in the United States. Live social game play data collected by us through the Services is stored on secure servers. These servers may not offer a level of privacy protection as great as that offered in other jurisdictions. We make no representation that the practices described in this Policy are compliant with laws outside of the United States.
These servers are protected by firewalls and other industry standard security measures. These security measures are intended to protect these servers from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. GAN has controls in place that are designed to detect potential data breaches, contain and minimize the loss of data, and conduct forensic investigations of a breach.
Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your personal information. Employees who violate our privacy policies are subject to disciplinary action, up to and including termination of employment.
We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you may use to send e-mails and submit information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you use will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of information that you send us before we receive it.
As a standard security practice, we will take reasonable steps which are generally recognized in the industry to ensure that the communication methods used to support the Services do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using the Services, it may be an indication that you need to upgrade your Internet browsing tool or application to a newer version that supports more secure communication methods.
In situations where your personal information is collected by third parties under contract with us for performance of their contractual duties and other purposes, we require such third parties to exercise reasonable care to protect that information and restrict the use of your personal information to the purposes for which it was provided. When we share your personal information with MGM Affiliates or third parties in accordance with this Policy, we require them to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which it was provided to them.
IV. ACCESS TO PERSONAL INFORMATION
We will retain the information we collect about you as long as necessary to comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements. You may access, update, and correct inaccuracies in your personal information which is in our custody and control by visiting the location where you registered for your Account or another MGM Resorts International designated location.
V. OTHER WEB SITES
We are not responsible for the information collection or privacy practices of portals or other web sites, including web sites accessible through the Services. For example, if you purchase virtual credits in connection with the Services, you will be making the purchase via a payment portal or web site operated by a third party, not Borgata. You should review and understand the privacy policies posted on any linked portals/sites you visit before using them or providing any personal information on them.
VI. INTERNATIONAL TRANSFERS
Information collected on the Services may be stored and processed in any country in which we or our affiliates, suppliers, third-party electronic payment processors and/or financial institutions or agents maintain facilities. By using the Services, you expressly consent to any transfer of information outside of your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.
VII. PERSONS UNDER 21
The Services are for use by persons 21 or older. If you are under 21, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of personal information from persons under 21.
VIII. CHANGES TO THIS POLICY
We may revise this Policy from time to time in our sole discretion. We will notify you of any material revisions by sending you an e-mail and/or by placing notice of the revised Policy on the Services or any place through which you access the Services. For material changes to the Policy, you may be required to acknowledge acceptance of such change. For non-material changes, your continued access or use of the Services following any amendments to the Policy constitutes your acceptance of the Policy as amended. It is your sole responsibility to review the Policy and any revisions thereto each time you use the Services.
EFFECTIVE: April 2017
