I. SCOPE OF THIS POLICY
The practices aforementioned are those carried out in Macau SAR. We are a subsidiary of MGM China Holdings Limited, a company incorporated in the Cayman Islands and listed in the Hong Kong Stock Exchange, an indirect subsidiary of MGM Resorts International (“MRI”), a company incorporated in and subject to the laws of the United States of America, and an affiliate of any other MRI subsidiaries or entities under the control of MRI (collectively, the “Company Group”). The Company Group is spread across different jurisdictions, which may offer different levels of privacy protection. Privacy practices adopted across the Company Group may have to be adjusted in each jurisdiction, so as to comply with local laws. We make no representation that the practices described in this Policy are compliant with laws outside Macau SAR. Should any information collected or stored overseas be disclosed or transferred to Macau SAR, it will be handled in accordance with the laws prevailing herein.
II. INFORMATION WE COLLECT
We collect information from a variety of sources and in a variety of ways, including without limitation, the following:
Information directly provided by you. When you visit our property or our web site(s), you might provide us with personal information such as your name, postal address, e-mail address, telephone number and mobile number (“contact information”). When you make a purchase or engage in other transactions, you might provide us with your contact information and, in addition, other information such as your date of birth, passport or ID number (or copy thereof), and your credit or debit card number. For particular types of purchases or transactions, you might provide us with other additional information, such as your profession, name of your employer and your professional address.
Purchase and Transaction Information. When you visit our property or our web site(s), we might collect information about your purchases, reservations, and gaming activity (if you are legally permitted to gamble).
Wi-Fi and Location Information. When you use Wi-Fi services we make available at our property, we might collect information (directly or through third parties) about the web sites you visit, the type of device and browser you are using, your device identification number, bandwidth used, session time, etc. With your consent, we might also collect information about your precise physical location within and around our property for marketing purposes.
Social Media Information. When you use integrated social media features on our website(s), mobile applications, or other social media websites, we may obtain information such as your name and e-mail address.
Other Information. We may obtain information about you from third parties, including entities that direct you to or are located at our website(s) or our property, business partners, family members, and friends.
III. HOW WE USE, PROCESS AND STORE THE INFORMATION WE COLLECT
A. USE BY MGM GRAND PARADISE LTD.
Marketing Purposes. We might use the information we collect for our own marketing purposes, such as notifying you of special promotions, offers and events via e-mail, telephone, text message, push notifications, and other means.
Non-Marketing Purposes. We might use the information we collect for non-marketing purposes such as (1) validating your identity; (2) recording gaming-related activity (if you are legally permitted to gamble); (3) conducting statistical or demographic analysis; (4) processing, fulfilling, and tracking reservations, purchases, or other transactions; (5) complying with legal and regulatory requirements; (6) customizing your experience at our website(s); (7) protecting and defending MGM Grand Paradise Ltd. and its affiliates against legal actions or claims; (8) preventing fraud; (9) debt collection; and (10) satisfying contractual obligations (collectively “Non-Marketing Purposes”).
B. SHARING WITH THIRD PARTIES
Provided that we are allowed (or required) to, we might share the information we collect with other companies within the Company Group, with our business partners or with other third parties. For marketing purposes specifically, we will share no information other than your contact information, and only with other companies within the Company Group or with our business partners, such as our marketing agencies. We will always require any third party with which information is shared to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which the information is shared. In some cases, we will seek or might be required to collect your specific consent.
C. PROCESSING AND STORAGE
The information we collect may be processed through manual or automated means, and may be digitally stored on premise or with a third party service provider (the “cloud provider”). While stored, the information we collect is kept strictly confidential and not made accessible to any third parties (including, if the case, the cloud provider). Security and confidentiality of the data is protected by systems and procedures no less protective than those followed by the industry standards.
D. TRANSFER TO OVERSEAS
Other companies within the Company Group, our business partners or any other third parties that we might share the information we collect with might be based or located outside the Macau SAR. Likewise, the cloud provider (and its servers) offering any cloud computing solution that we might use to store the information we collect might be based or located outside the Macau SAR. Where this is the case, we might be required to observe additional standards or take additional measures to ensure that the transfer
to overseas of the information we collect is carried out in a secure and lawful manner. In some cases, we will seek or might be required to collect your specific consent.
If you wish to opt-out of receiving marketing solicitations from us, or do not want us to share your personal information for marketing purposes with other companies within the Company Group or with our business partners, please e-mail us at email@example.com, call us at (+853) 8802 8888, or write to us (under the subject “Opt-Out”) at:
MGM Grand Paradise Ltd. Marketing & Communications - Legal Avenida do Dr. Sun Yat Sen no. 1101 Edifício MGM Macau Macau
Although you may opt-out of the use and sharing of personal information for marketing purposes, there might be situations in which we are still allowed (or required) to use and share information we collect for non-marketing purposes.
Information collected by us or our website(s) is stored on secure servers, which 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. We have 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 our website(s) do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using our website(s), 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.
If you have any concern about the way your personal data has been handled, or otherwise want to report any information with respect to any actual or potential cybersecurity incident, please report a concern through the following: MGM China Integrity Hotline.
VI. OTHER WEB SITES
We are not responsible for the information collection or privacy practices of other web sites, including web sites operated by our business partners or other third parties. You should review and understand the privacy policies posted on any linked sites you visit before using those sites or providing any personal information on them.
VII. CHANGES TO THIS POLICY
We reserve the right to revise this Policy at any time without notice. When this Policy is revised in a material way, the revised Policy will be posted in our website(s).
EFFECTIVE: March 1, 2014 If you have questions or concerns about this Policy, please contact us at firstname.lastname@example.org.