PRIVACY POLICY

TROPICANACASINO.COM

PRIVACY POLICY

Caesars Interactive Entertainment New Jersey, LLC and its affiliate, Tropicana Atlantic City Corp (which we may refer to as "Tropicana”, CIENJ", "us", "we" and "our") respect and are committed to protecting your privacy. That is why we have adopted this Privacy Policy. This Privacy Policy lets you know how and for what purposes your information is being collected, processed and used. Your information will only be used in ways that are in compliance with this Privacy Policy.

1. PRIVACY POLICY LIMITATION

1.1. This Privacy Policy is only in effect for web pages, mobile and device-specific applications, third party social media sites, e-mail lists, as well as any on-line features, programs and services offered, owned or operated by CIENJ, as an affiliate of Tropicana or on CIENJ’s behalf, including but not limited to, by its platform and service provider, , Gamesys US LLC, a New Jersey limited liability company (together with any other company within a group of parent, affiliate and subsidiary companies of which Gamesys US LLC is a part, being collectively referred to herein as "Gamesys") in connection with the principle URL link: www.tropicanacasino.com; any mobile or device specific version and any related applications of the website at such URL (collectively, the "Website"), and relates to personally identifiable information (“Personal Information”) and non-user-specific information (“Non-Personal Information”) collected by CIENJ, or on CIENJ’s behalf, including but not limited to, by Gamesys, through the Website and through a means other than the Website. References to "CIENJ, Tropicana", "us", "we" and "our" shall also include Gamesys, acting in its capacity as the platform and service provider of the Website behalf of CIENJ.

1.2. This Privacy Policy does not apply to:

i. any other web pages, mobile applications, mobile device specific applications, online features, services and/or programs, or third party social media sites other than the Website, as defined in 1.1 above; and

ii. any information (including but not limited to e-mail lists, Non-Personal Information and Personal Information) collected and/or owned by any entity other than (a) Tropicana or (b) those entities collecting on behalf of Tropicana (including, but not limited to, Gamesys).

1.3. This Privacy Policy also does not apply to any information collected by or for Tropicana or CIENJ through a means other than the Website or in connection with the Website. Information collected from you by Tropicana when you visit the Tropicana Atlantic City property or when you use another Tropicana website or service (collectively “other Caesars Entertainment services”) is governed by the privacy policies of those other Caesars Entertainment services.

1.4. Should there be any changes to this Privacy Policy, we will notify you by e-mail that the Privacy Policy has been revised. If you do not want us to collect, store, use or share your information in the ways described in this Policy, you should not utilize the Website.

2. WEBSITE OWNERSHIP AND OPERATION

2.1. The Website is currently operated for CIENJ by its platform, Gamesys, under and pursuant to the Internet Gaming Permit issued to CIENJ by the New Jersey Division of Gaming Enforcement ("NJDGE") pursuant to N.J.S.A. 5:12-95.21 of the New Jersey Casino Control Act, as amended, and the regulations promulgated thereunder. As required under the Act, the Website is currently operated from computer servers hosted and maintained by CIENJ or its service provider. The terms of this Privacy Policy shall apply to our operation of the Website regardless of what party or parties may act as our service provider for such operations.

2.2. Your use of the Website is also governed by the Website Terms.

2.3. The Website and the games on such Website are provided and operated by CIENJ through its platform provider, Gamesys.

3. INFORMATION WE MAY COLLECT

We collect and use information we believe is necessary to administer and promote the Website and provide you with the services you request. We may collect and maintain both Personal Information and Non-Personal Information needed for these purposes. Your Personal Information and Non-Personal Information will be referred as your “information” in this Privacy Policy. You are under no obligation to provide information to us. However, certain information is essential for the provision and quality of the services we offer to you (for example, enabling you to play the games on the Website) so we cannot provide you with certain services if you choose to withhold requested information. Please see below information we may collect about you.

Purpose Personal Information Collected
Registration information which is required by us for you to open a Patron account shall include but not be limited to, your:

Legal name; date of birth; Social Security Number (in its entirety or part of it); mailing address; e-mail address; cellular telephone number; and gender.

Additional Information that may be required or requested by us may include but not limited to:

Credit card numbers, bank account numbers or other personal financial information; geographical information; biographical information such as household data, preferences and demographic information; drivers’ license numbers; credit and debit card information; purchase information regarding our products and services; demographic information; security question responses; and opt in status for SMS and telephonic marketing.

Promotions: We or one of our partners may sponsor competitions and/or promotions through the Website. Your participation is entirely voluntary. If you participate in these competitions or promotions, you may be asked to provide information including, but not limited to: Name, email address, mailing address, social media profile (if you engage through social media platform)
Customer Support Communications via, telephone and email (monitored and recorded):

We collect information about your communications via our Website, including in our chat and messaging facilities (including the content of any messages you send or post and geographic location).

We collect information about your telephone conversations with our customer and operational support staff. We record all telephone conversations (e.g. customer support calls, wagering communication; responsible gaming calls, fraud monitoring calls and regulatory anti-money laundering and verification calls, etc.) for training and monitoring purposes

We collect and store all copies of emails you send to us and our replies to your emails.

Chat Facility Communications If you submit content and/or participate in the chat facility on the Website, we will collect information on what is communicated or shared in the chat facility.
Information about your Computer: When you connect to the Website, we may also retrieve information from the computer used to log onto the Website. The information we collect may include (but is not limited to) information about the computer's hardware system and data related to the computer's software or use of the Website.
Traffic Information: In addition, when you interact with the Website, our servers keep an activity log unique to you that collects certain administrative and traffic information, including, but not limited to: source Internet Protocol ("IP") address, time of access, date of access, web page(s) visited, language use, geolocation data, software crash reports and type of browser used.

4. PATRON ACCOUNT, PASSWORD, AND SECURITY

4.1. For certain features available through the Website, we may require the use of encryption technologies provided for your protection and/or Patron account. We use reasonable precautions to protect the privacy of your username, password and Patron account information.

4.2. You, however, are ultimately responsible for protecting your username, password and Patron account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You agree to: (a) immediately notify us of any unauthorized use of your username, password and/or Patron, and/or any other breach of security; and (b) ensure that you log out from your Patron account at the end of each session. While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.

5. HOW WE COLLECT YOUR INFORMATION

5.1 Information You Directly Provide To Us: The means by which Tropicana or CIENJ collects your information may include, but is not limited to, when you:

i. create a Patron account for use in connection with the Website;

ii. purchase, order, or request information about our services through the Website;

iii. access a Tropicana or CIENJ social media platform;

iv. sign up for e-mail notifications, electronic newsletters, mobile messages (including SMS), social media notifications from, or on behalf of, Tropicana or CIENJ;

v. enter or participate in a competition or promotion on the Website;

vi. respond to one of our surveys;

vii. provide Tropicana or CIENJ with comments, suggestions or other input through the Website; and

viii. provide us with information in connection with our marketing efforts.

5.2 Information Collected through the Website:

5.2.1 Browser Log Files - Our servers automatically log each visitor to the Website and collect and record certain information about each visitor. This information includes or may include your IP address, browser language, browser type, operating system, domain names, browsing history (including time spent at a domain, time and date of your visit), referring/exit web pages and URLs, and number of clicks. The domain name and IP address reveal nothing personal about the visitor other than the IP address from which the user has accessed the Website.

5.2.2 Unique Identifier - We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Website and some of the electronic communications you receive from us.

5.2.3 Cookies - From time to time, we and/or our advertisers or other third parties may send a "cookie" to your computer. A cookie is a small piece of data that is sent to your Internet browser from a web server and stored on your computer’s hard drive and that can be re-sent to the serving website on subsequent visits. A cookie, by itself, cannot read other data from your hard disk or read other cookie files already on your computer. A cookie, by itself, does not damage your system. We use cookies for a number of different purposes, including, but not limited to:

i. authenticating requests made in our customer help interface;

ii. recognizing a patron and track their actions on subsequent visits;

iii. collecting information about how visitors use the Website;

iv. testing different design ideas; and

v. anonymously tracking visitors to the Website through online advertising.

We, our advertisers and other third parties may use cookies to identify and keep track of, among other things, those areas of the Website and third party websites that you have visited in the past in order to enhance your next visit to the Website.

You can choose whether or not to accept cookies by changing the settings of your Internet browser, but some functionality of the Website may be impaired or not function as intended, if you choose not to accept cookies. See Section 11 below.

5.2.4 Web Beacons - Some of our web pages and electronic communications may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as "clear gifs"). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. We may also carry Web Beacons placed by third party advertisers. These Web Beacons do not carry any Personal Information and are only used to track usage of the Website and activities associated with the Website. See Section 11 below.

5.2.5 Third Party Analytics Services - We may work with third party analytic services to help us understand how the Website is being used. In connection with these third party analytic services, we allow third-party companies to track and collect certain information. Such services include but are not limited to:

i. helping us to improve your use and experience of the Website by tracking your activity on the Website and/or other websites;

ii. measuring the effectiveness of the Website and the effectiveness of our marketing campaigns; and

iii. collecting or receiving information and using that information to advertise to you on other websites.

These companies may use Non-Personal Information (including, but not limited to, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Website in order to provide advertisements about goods and services likely to be of greater interest to you.

These companies typically use a cookie or third party Web Beacon to collect this information, as further described above. Through these technologies, the third party may have access to and use Non-Personal Information about your online usage activity.

5.3 Geolocation Data Collected Pursuant to Law: There are Federal prohibitions and restrictions relating to wagering on the Internet (including, but not limited to, such prohibitions and restrictions set out in 18 U.S.C. §§ 1084 et seq. (The Wire Act) and 31 U.S.C. §§ 3163 through 3167 (UIEGA)). It is a Federal offense for persons physically located outside of New Jersey to engage in Internet wagering through any New Jersey casino, including, but not limited to, placing a Wager (as defined in the Website Terms) on the Website, unless you are explicitly authorized by the Regulator (as defined in the Website Terms). We and our service providers utilize several current technologies, and may use future technologies, in order to verify your physical location while you are placing a Wager on the Website (collectively, the "Geolocation Technologies"). Geolocation Technologies report your physical location from the computer or Internet-connected device that you choose and from which you are accessing the Website. Geolocation Technologies obtain your physical location by accessing your IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID, Exif/IPTC/XMP or modern steganography), Wi-Fi positioning system, or device GPS coordinates. The Geolocation Technologies report to us, our service providers and/or the Regulator the physical and geographic location of the computer or Internet-connected device from which you are accessing the Website. It is possible that your precise or near-precise physical location will be reported to us, our service providers and/or the Regulator when you use the Website.

5.4. Information Collected by Third Parties through Third Party Links on our Website: The Website may include links to other websites and other content from third parties. These third parties may use cookies, Web Beacons or other similar technology to collect information about you as further described in Section 5.2. We do not have access to or control over these third parties or the cookies, Web Beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third party website. We are not and cannot be responsible for how they treat information (including, but not limited to Personal Information about their users). You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on the Website.

5.5 Information Collected through Information You Post on the Website:

5.5.1 Chat Facilities: The Website features Chat Facilities in which you may participate if you wish. If you submit content and/or participate in the chat facility on the Website, your content and/or communications on the chat facility are not private or confidential and may be viewed and used by others accessing the Website. Please do not submit any information to the chat facility that you do not want others to see.

5.5.2 Patron Profile: When you create a Patron profile, the information that you provide, including, but not limited to, a username and an image (such as a photograph), is not private or confidential, and may be viewed and used by others accessing the Website. We recommend that you choose a username and image that is original and makes no reference to your name and does not contain any Personal Information.

5.5.3. Refer a Friend Program: When you accept a friend’s invitation to register as a Patron as part of the Refer a Friend program, information relating to your progress in meeting the wagering requirements related to the Refer a Friend program and number of Points collected may be viewed by such friend. Please do not participate in the Refer a Friend program if you do not want such information to be seen by your friend.

5.6 Information Obtained from Other Sources: In order to operate our Website, we collect information about you from third party service providers for various reasons such as making sure our Website is safe, to offer a good level of service and also to comply with our legal and regulatory obligations as per the requirements of the New Jersey Division of Gaming Enforcement. We may obtain information about you from credit reference agencies, customer verification agencies, and location verification agencies, advertising services providers, hosting providers, analytical providers, anti-money laundering and fraud prevention agencies and we may combine such information with information we have collected about you as described in this Privacy Policy. To the extent we combine such third party information with other Personal Information we have collected, we will treat the combined information as Personal Information under this Privacy Policy.

6. HOW WE MAY USE YOUR INFORMATION

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 described in the Privacy Policy or permitted by law. Information collected by us may be used for the following purposes:

6.1 to enable the features of the Website, including, but not limited to:

i. setting up and managing your Patron account, including but not limited to our processing your requests for information, and/or providing support services to you;

ii. if necessary, in connection with the management and operation of your Patron account, contacting you at your registered email address or by means of any other contact details that you provide to us;

iii. processing your online financial and wagering transactions;

iv. building up your personal profiles;

v. confirming that you are physically located in the State of New Jersey when you are Wagering on the Website, and

vi. operating any competitions or promotions in which you may participate.

6.2 to improve the Website by determining, among other things, which of our products, features and services are most popular or effective. We may analyze your information such as usage information, to enable us (and a group of parent, affiliate and subsidiary companies that we are a part of referred to as the "Caesars Entertainment Group"), and/or our third party services providers, including but not limited to Gamesys, to provide products and services to you and develop new features, functionality, products and services;

6.3 to personalize the experience of the Patrons; and

6.4 to communicate with you and to inform you about our products and services as well as our third parties’ products and services.

Unless you have opted in or out as applicable, we and/or other companies within the Caesars Entertainment Group and/or any of our third party service providers, including, but not limited to, Gamesys, may send you information by email, telephone (including, but not limited to SMS), mail (or by any other contact details you provide), about the services, products, competitions, prizes and offers from the Caesars Entertainment Group, Gamesys and selected third parties.

If you do not wish to receive any information about existing and new services, products, competitions, prizes and offers from us or other companies within the Caesars Entertainment Group, and/or Gamesys and selected third parties, you can tell us not to contact you for marketing purposes at initial registration, by updating your marketing preferences in the My Account section of the Website or by clicking on the unsubscribe link in any marketing email that we or other companies within the Caesars Entertainment Group or our third party service providers, including but not limited to Gamesys, send to you. If you opt out or revoke your consent to receive calls and text messages, you acknowledge that such revocation is not instantaneous and will be effective in a reasonable period of time.

If you have provided us with your prior express written consent to receive communications via text messaging (which you understand may include the use of an automatic telephone dialing system (auto-dialer)), you may opt out from future text messages by texting STOP. Once you cancel, we will send one additional confirmation message stating that you've opted out.

6.5 to protect the safety and wellbeing of our Patrons;

6.6 to comply with our legal obligations, resolve any disputes we may have with you or other Patrons and to enforce our agreements with third parties;

6.7 to prevent fraud or potentially illegal activities and to enforce our Website Terms; and

6.8 to use or make available a "strong authentication" process to verify your identity from time to time.

7. HOW WE SHARE YOUR INFORMATION

7.1. When required By Law or to Protect our Rights and/or Comply with Our Policies: We may also disclose your information to governmental authorities or third parties when required by law or in the good-faith belief that such disclosure is necessary to:

i. comply with legal process and applicable laws, including but not limited to responding to subpoenas or court orders and complying with the requirements of the NJDGE or any other regulatory body having jurisdiction over us, any other member of the Caesars Entertainment Group or the Website;

ii. enforce this Privacy Policy;

iii. respond to claims that any materials, documents, images, graphics, logos, designs, audio, video and any other information provided to, from or on the Website violates the rights of third parties;

iv. protect the rights, property or personal safety of Tropicana and CIENJ, its Patrons or the public;

v. enforce our Website Terms;

vi. protect the security and integrity of the Website;

vii. take precautions against liability, to investigate and defend against any third-party claims or allegations; or

viii. respond to financial institutions in connection with debit or credit card chargeback claims.

7.2. Our Affiliates: For business purposes, we may share certain information we receive from you and about your transactions with us, with other companies within the Caesars Entertainment Group, for the purposes of promoting the goods and services of our Affiliates. Doing so allows us to provide you with information about the services and products offered by our Affiliates. In addition, if you self-exclude from the Website, we may disclose information about you to certain of our employees in accordance with applicable laws and regulations. Our Affiliates process such information in compliance with our Privacy Policy.

7.3. Third Party Service Providers: We may share your information with third party service providers and suppliers. We use service providers in connection with the operation of our Website to ensure we deliver the best possible services. We enter into contracts with our service providers and ensure they take good care of your Personal information we share with them for that purpose. We are committed to protecting your Personal Information and we oblige our service providers to handle your Personal information in accordance with applicable privacy laws and the terms of this Privacy Policy

We engage service providers for the following services:

- Platform Services;
- Hosting our website;
- Marketing services such as segmentation, analytics, email messaging services and SMS marketing service providers;
- Affiliate platform services;
- Customer support software service providers;
- KYC, enhanced due diligence, Anti-fraud and money laundering services;
- Gambling restriction service providers;
- Data analytics services; and
- Audit, legal and compliance services.

7.4. Business Transfers; Bankruptcy: In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets (for example, a sale of Tropicana or CIENJ to a third party), we may transfer your information to any entity that acquires all or a portion of us. In such cases, we may disclose or transfer all of your information, including Personal Information, to the successor organization in the transaction. We also cannot make any representations regarding the use or transfer of your information in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors.

7.5 Aggregate Information: We may share your Non-Personal Information with affiliated or non-affiliated third parties, such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc. to demonstrate the usage patterns for our advertisements, content, functionality, promotions, competitions, games and/or services on the Website and/or on third party websites. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

8. CALIFORNIA RESIDENT USER PRIVACY RIGHTS

This section 8 applies only to customers who are residents of California.

8.1 SHINE THE LIGHT LAW:

8.1.1. California residents who provide Personal Information in connection with obtaining products or services for personal, family or household use are entitled to request, and obtain from us once each calendar year, information about the Patron information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2018 sharing activities).

8.1.2. To obtain this information on behalf of Tropicana or CIENJ, please send an email message to privacy@gamesys.us with "Request for California Privacy Information" in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

8.1.3. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information covered under this law will be included in our response.

8.2 CALIFORNIA CONSUMER PRIVACY ACT

This Section (Section 8.2) supplements the information contained in this Privacy Policy and applies solely to customers and all website visitors, users and others who reside in the State of California. We adapt this section (Section 8) of the Privacy Policy to comply with the California Consumer Privacy Act 2018 (CCPA) and other California privacy laws (together “California Laws”).

8.2.1 CATEGORIES OF INFORMATION WE COLLECT, HOW WE COLLECT IT AND WITH WHOM WE MAY SHARE

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. For purposes of this section only, this information is referred to as “Personal Information” and falls within the following categories:

Category Examples
Identifiers A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, current or past job history, or other similar identifiers.

Personal information categories listed in the

California Consumer Records statute (Cal. Civ. Code § 1798.80(e))

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Note: Some Personal Information included in this category may overlap with other categories.

Protected classification characteristics under California or federal law Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information).
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing histories or tendencies.
Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data Physical location or movements.
Professional or employment-related information Current or past job history or performance evaluations.

Non-public education information (per the Family Education Rights and Privacy Act (20

U.S.C. Section 1232g, 34

C.F.R. Part 99)

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information or student disciplinary records.
Inferences drawn from other Personal Information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information outside CCPA’s scope, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

Section 5.1 to 5.5 of this Privacy Policy sets forth the specific information we collect and the sources from which we obtain that information. The below table outlines the Section 5.1 – 5.5 categories of Personal Information collected, the purposes for its collection, and the categories of third parties with whom we may share the Personal Information and whether this information has been disclosed during the past 12 months.

Section 5.1 - Information you provide directly to us in connection with your use of the Website
Categories of Information - identifiers, Personal Information protected under the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), protected classification characteristics under California or federal law, commercial information, professional or employment information.
Purposes for Collection of Personal Information - To create an account on the Website
- To operate the Website and process your online wagering transactions
- To provide technical support or respond to your inquiries
- To verify your identification
- To administer promotional activities or events sponsored or managed by us
- To communicate with you and to inform you about our products and services as well as third parties’ products and services
- To conduct internal market research and analytics
- To protect the safety and well-being of our players
- To prevent fraud or potentially illegal activities
- To protect our rights and property in connection with our Website
- To enforce our Terms of Service
Types of Third Parties with whom we share Personal Information - Governmental bodies (see section 7.1 in response to subpoenas and in accordance with regulatory requirements)
- Financial institutions (see section 7.1 in connection with responding to chargeback claims)
- Affiliates (see section 7.2);
- Third party service providers, such as identification verification services and payment processors (see section 7.3)
- Successors in interest (See Section 7.4)
Disclosed within past 12 months - Yes

Section 5.2, 5.3 and 5.4 – All Information Collected through our Website or third party websites
Categories of Information - Identifiers, internet or other similar network activity
- Geolocation data; inferences drawn from Personal Information.
Purposes for Collection of Personal Information - To operate the Website and improve, optimize and personalize the Website for you
- To enable you to communicate with others while using the Website
- To administer promotional activities or events sponsored or managed by us
- To manage and deliver contextual and behavioral advertising, conduct internal market research and analytics
- To protect the safety and well-being of our players
- To protect our rights and property in connection with our Service
- To enforce our Terms of Service
Types of Third Parties with Whom we Share Personal Information - Affiliates (see section 7.2)
- Third party service providers, such as analytics services and digital marketing services (see section 7.3).
Disclosed within past 12 months - Yes

Section 5.5 - Information Collected from your interactions on the Website
Categories of Information - Identifiers, Internet or other similar network activity
- geolocation data and inferences drawn from Personal Information.
Purposes for Collection of Personal Information - To operate the Website
- To ensure you are physically located in New Jersey before processing your online wagering transactions
Types of Third Parties with Whom we Share Personal Information - Third party service providers (see section 7.3)
Disclosed within past 12 months - Yes

Section 5.6 - Information Collected from Other Sources
Categories of Information - Identifiers, Personal Information protected under the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), commercial information, internet or other similar network activity, geolocation data and inferences drawn from Personal Information.
Purposes for Collection of Personal Information - To improve, optimize and personalize the Website for you
- To enable you to communicate with others while using the Website
- To administer promotional activities or events sponsored or managed by us or our business partners
- To manage and deliver contextual and behavioral advertising, conduct internal market research and analytics
- To protect the safety and well-being of our players
- To protect our rights and property in connection with our Service
- To enforce our Terms of Service.
Types of Third Parties with Whom we Share Personal Information - Governmental bodies (see section 7.1 in response to subpoenas and in accordance with regulatory requirements)
Disclosed within past 12 months - Yes

8.2.2 USE AND SHARING OF PERSONAL INFORMATION FOR BUSINESS PURPOSES

In addition to the specific uses and disclosure of Personal Information described in this Privacy Policy, we may also use or disclose your Personal Information for one or more general business purposes as described in the CCPA, which are:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that Personal Information to respond to your inquiry. If you submit a review of our Services or your experience with us, we may post that submission on our websites or social media sites.
  • To provide, support, personalize and develop our websites, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions and payments, and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Service, third party sites and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security and integrity of our Services, products, and other services, databases, and other technology assets and our business.
  • For testing, research, analysis, and product development, including to develop and improve our Services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about users of our Services and our customers is among the assets transferred.

8.2.3 CALIFORNIA RESIDENT’S RIGHTS

This section describes your CCPA rights and explains how to exercise those rights. The CCPA provides California residents with specific rights regarding their Personal Information. These Rights are not absolute and are subject to certain exceptions. For instance, we cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us or the security of the business’s systems of networks. Equally, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

8.2.3.1 Verification and Record Keeping

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. When a request is made, we will first take steps to verify your identity to protect your privacy and security. Further, if you designate an authorized agent to make a request on your behalf, you may have to submit information confirming such designation. Subject to California Laws, we will not act upon a request until your identity has been sufficiently verified.

We will only use Personal Information provided in a verifiable consumer request to verify our identity or authority to make the request. A record concerning the requests may be maintained pursuant to our legal obligations. Further, we do not charge a fee to process or respond to your request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.

8.2.3.2 Disclosure and Access to Specific Information Requests

You have the right to request that we disclose certain information to you about out collection and use of your Personal Information over the past 12 months. Your request must be sufficiently detailed so as to allow us to properly understand, evaluate and respond to it. Where we verify your request, we must provide the following:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).

Please note that we are only required to fulfill Disclosure and Access requests from a consumer twice per every 12-month period.

You can submit such a request by sending an e-mail to privacy@gamesys.us with "Request for California Privacy Information" in the subject line and in the body of your message or calling Customer Service at (844) 737-7615.

8.2.3.3 Deletion Requests

You have the right to request that we delete the Personal Information we have collected or maintained in connection with your use of this Website, subject to certain exceptions as provided for under California Laws. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our services providers to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You can submit a request to us to delete your personal information by sending an email to privacy@gamesys.us with “California Request for Deletion” in the subject line and in the body of your message or calling Customer Service at (844) 737-7615.

8.2.3.4 Right to Opt-out of Sale of Personal Information

Under California Laws, California consumers have the right to opt-out of having their personal information sold. For purposes of California Laws, the definition of “sale” includes sharing of personal information with a third party in exchange for anything of value (money or otherwise).

We do NOT sell Personal Information of California residents to any third parties.

8.2.3.5 Right to Non-Discrimination

California consumers have the right not to be discriminated against for exercising their Rights. We may not:

  • Deny the goods or services.
  • Charge different prices for goods or services, whether through denying benefits or imposing penalties.
  • Provide a different level or quality of goods or services to consumer.
  • Threaten the consumer with any of the above.

9. INFORMATION FROM PERSONS UNDER 21 YEARS OF AGE

9.1. It is a criminal offense to allow a person who is under the age of twenty-one (21) to participate in Internet wagering. The Website is not for use by any person under the age of twenty-one (21) and we do not knowingly accept as a Patron anyone under the age of twenty-one (21).

9.2. Furthermore, the Website is not intended or designed to attract individuals under the age of twenty-one (21). We do not collect personally identifiable information from any person that we know to be under the age of twenty-one (21) You affirm that you are at least twenty-one (21) years of age and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Policy, and to abide by and comply with this Privacy Policy.

9.3. THE WEBSITE IS NOT INTENDED FOR CHILDREN. Parents should be aware that this Privacy Policy will govern our use of Personally Information, but also that information that is voluntarily given by children - or others - in e-mail exchanges, bulletin boards or the like may be used by other parties to generate unsolicited communications. We encourage all parents to instruct their children in the safe and responsible use of their Personally Information while using the Internet.

10. ACCESS AND CORRECTION

10.1. To access your Personally Information in our possession and correct inaccuracies of that information in our records, please contact us in the manner specified at the end of this Privacy Policy. We ask individuals to identify themselves and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances as permitted by applicable privacy legislation.

11. CHOICES WITH YOUR PERSONAL INFORMATION

11.1. Whether you submit any Personal Information to us is entirely up to you. You are under no obligation to provide Personal Information. However, this information is essential for the provision and quality of the services we offer to you (for example, enabling you to play the games on the Website) so we cannot provide you with certain services if you choose to withhold requested information.

11.2. You may choose to prevent us from disclosing or using your Personal Information under certain circumstances ("opt-out"). You may opt-out of any disclosure or use of your Personal Information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Policy, or by following the procedures set forth in an electronic communication from us, if applicable. Furthermore, even where your Personal Information is to be disclosed and used in accordance with the stated purposes in this Privacy Policy, you may elect to opt-out of such disclosure to and use by a third party that is not acting as an agent of us. There are some uses from which you cannot opt-out, such as our use of your Personal Information in connection with regulatory compliance and/or reporting.

11.3. If we collect Personal Information, such information will not be disclosed or used by us for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization unless you affirmatively consent to such disclosure and use.

11.4. You can opt-out of online behavioral services through any one of the ways described below (you do not need to go to each opt-out site, one is sufficient). After you opt-out, you will continue to receive advertisements, but those advertisements will no longer be as relevant to you.

i. You can opt-out via the Network Advertising Initiative industry opt-out at www.networkadvertising.org.

ii. You can opt-out via the Consumer Choice Page at www.aboutads.info.

iii. You can configure your web browser (Chrome, Firefox, Internet Explorer, Safari, etc.) to delete and/or control the use of cookies. More information can be found in the Help system of your browser. It is at your discretion whether you use the opt-out described above or manage cookies via the browser.

Note: If you opt-out as described above, you should not delete your cookies. If you delete your cookies, you will need to opt-out again.

12. YOUR CONSENT TO THIS PRIVACY POLICY

12.1. By using the Website, you consent to the collection and use of your information (including Personal Information) by us as identified herein, in compliance with this Privacy Policy, unless you inform us otherwise by means of the procedure identified herein. If we make changes to this Privacy Policy or any part of it, you will be notified of such changes in advance of us updating the Privacy Policy. This is so you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Website following such publication of any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.

12.2. If you have additional questions or comments of any kind concerning this Privacy Policy or if you see anything on the Website that you think is inappropriate or incorrect, please let us know by e-mail or by sending your comments or requests to:

Caesars Interactive Entertainment New Jersey, LLC,
c/o Tropicana Atlantic City Corp.
2831 Boardwalk
Atlantic City, New Jersey 08401-6338
Attn: Customer Support support@tropicanacasino.com
Copyright © 2013-2021. Tropicana Atlantic City Corp. All Rights Reserved.

LAST UPDATED: December 20, 2021