PRIVACY POLICY
LAST UPDATED: May 9, 2023
SCOPE AND APPLICATION
Putter's Gaming Group, Inc. and its subsidiarie or “we”) want you to be familiar with how we collect, use, and disclose information.
This Privacy Policy describes our practices in connection with information that we collect through:
Websites operated by us from which you are accessing this Privacy Policy;
Software applications made available by us for use on computers and mobile devices (“apps”);
Putter's Gaming Group Mobile Messaging Program;
Email messages that we send to you that link to this Privacy Policy; and
Our social media pages,
Wi-Fi services that we provide in our resorts, casinos and other properties.
If you are a California resident, please see “California Consumer Privacy Act Notice,” below, for more information about our practices and your rights.
Personal Information
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We collect such Personal Information as:
Name
Company
Address
Telephone and fax numbers
Email address
Payment card information
Purchase and reservation information
Your Internet protocol (IP) address, from which we may derive your approximate location
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) to us.
Collection of Personal Information
We collect Personal Information in a variety of ways, including:
From You.
We collect Personal Information from you when you choose to provide it, such as when you make a reservation, participate in a promotion, sign up to our mailing list, enroll in our Putter's Gaming Group Mobile Messaging Program, take a survey, seek information on weddings or meetings, register as a meeting planner, or provide feedback or suggestions or otherwise communicate with us.
From Other Sources.
We may also receive your Personal Information from other sources, such as third parties and publicly available sources, including, for example, reservations and ticketing services, social media platforms, publicly available databases, government agencies, credit references and financial crime prevention agencies, consumer reporting agencies, research companies, and event or joint marketing partners.
We need to collect Personal Information in order to provide the requested products and services to you. If you disclose any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Use of Personal Information
We use Personal Information for the following purposes:
Providing our products and services and fulfilling your requests.
To process and fulfill reservations, provide you with our products and services, and provide you with related customer service.
To respond to your inquiries and fulfill your requests and otherwise manage our relationship with you.
To send administrative information to you, such as changes to our terms, conditions, and policies.
We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or where we have a legitimate interest.
Providing you with our newsletter or other marketing materials.
To send you marketing related communications, with information about our services, products, offers and promotions, events, and other Putter's Gaming Group news.
We will engage in this activity with your consent (if required by applicable law) or where we have a legitimate interest.
Analyzing Personal Information for business reporting and providing personalized services.
To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used so that we can improve our online services.
To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with content, information, and offers that we believe will be relevant and interesting to you.
We will provide personalized services based on our legitimate interests or with your consent, to the extent consent is required by applicable law.
Aggregating and/or anonymizing Personal Information.
We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other information for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Accomplishing our business purposes.
For data analysis, including to improve the efficiency of our services;
For audits, to verify that our internal processes function as intended;
To address legal, regulatory, or contractual requirements;
For risk control and fraud and security monitoring purposes, such as to detect and prevent cyberattacks or attempts to commit identity theft or other fraud;
To improve our properties, websites, Putter's Gaming Group Mobile Messaging program and mobile apps;
To determine eligibility for casino credit;
For developing new products and services;
To process financial transactions;
To notify you about promotions and special offers;
To respond to your inquires;
For enhancing, improving, maintaining, or modifying our products and services, as well as undertaking quality and safety assurance measures;
For identifying and understanding usage trends;
For determining the effectiveness of our promotional campaigns; and
For operating and expanding our business activities.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
To our affiliates, for the purposes described in this Privacy Policy.
To our service providers, to facilitate services they provide to us.
Our service providers may provide such services as website hosting, mobile messaging, data analysis, information technology, customer service, email delivery, auditing, and other services.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:
To comply with applicable law and regulations.
These may include laws outside your country of residence.
To cooperate with law enforcement and government authorities.
To respond to a request or to provide information when we believe necessary or appropriate.
These may include authorities outside your country of residence.
For other legal reasons.
To enforce our terms and conditions or other agreements with our users and customers; and
To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
In connection with a sale or business transaction.
We have a legitimate interest in disclosing or transferring your Personal Information to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
OTHER INFORMATION
“Other Information” is information that does not reveal your specific identity or does not directly relate to an identifiable individual. We collect such Other Information as:
Browser and device information
App usage information
Information collected through cookies, pixel tags, and other technologies
Demographic and other information provided by you that does not reveal your specific identity
Collection of Other Information
We may collect Other Information in a variety of ways, including:
Through your browser or device.
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, and browser type and version. We use this information to ensure that our online services function properly.
Through your use of our apps.
When you download and use one of our apps, we may track and collect app usage information, such as the date and time the app on your device accesses our servers.
Through the use of cookies and similar tracking technologies.
Cookies. Cookies are pieces of information stored directly on the computer that you are using and allow us to collect such information as browser type, time spent on our services, pages visited, language preferences, and other traffic information. We use the information for security purposes, to facilitate navigation, to display content more effectively, and to personalize your experience. We also gather statistical information about use of our online services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions about them. If you do not want information collected through cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting cookies from a particular website. You may also wish to refer to the Electronic Privacy Information Center’s cookie page at www.epic.org/privacy/internet/cookies/. If you do not accept cookies, you may experience some inconvenience in your use of our online services.
Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of our online services (including email recipients), measure the success of our marketing campaigns, and compile statistics about use of our services and response rates.
Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our online services and report on activities and trends. The service may also collect information about the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy// and opt out of them by downloading the Google Analytics opt-out browser add-on, available at //tools.google.com/dlpage/gaoptout.
Advertising. We use third-party advertising companies to serve advertisements that may be of interest to you when you access and use our online services and other websites or online services. You may receive advertisements on any of your devices, based on information relating to your access to and use of our online services and other websites or online services, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser, including through the use of pixel tags. They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit //optout.aboutads.info/#/ and //optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.
Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies. We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of our online services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions. Setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
We do not currently respond to browser do-not-track signals.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.
SECURITY
We seek to use reasonable organizational, technical, and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
CHOICES AND ACCESS
You may opt out from receiving marketing emails from us by following the instructions contained in each such email. If you opt out, we may still send you important administrative messages, from which you cannot opt out.
If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information or to object to or opt out of the processing of Personal Information (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contact Us” section below. We will respond to your request consistent with applicable law.
In your request, please specify what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
For California residents: If you are a California resident, please see the California Consumer Privacy Act Notice, below, for additional information about your rights.
For Nevada residents: We do not sell Covered Information, as defined under Nevada law. If you are a Nevada resident and have any questions, please email us at corporate@puttersvegas.com.
RETENTION PERIOD
We retain Personal Information for as long as needed or permitted to fulfill the purpose(s) for which it was obtained, including to satisfy any legal, compliance, accounting, or reporting requirements, and consistent with applicable law. The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide our products and services to you (for example, for as long as you continue to use our digital services);
Whether there is a legal obligation to which we are subject (for example, to keep records of your transactions for a certain period of time); or
Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation, or regulatory investigations.
THIRD-PARTY SERVICES
This Privacy Policy does not address, and we are not responsible for, the privacy, security, or other practices of any third parties, including any third party operating a website or service to which our online services link. The inclusion of a link on our online services does not imply endorsement of the linked site or service by us or our affiliates.
USE OF OUR SERVICES BY MINORS
Our services are not directed to individuals under the age of twenty-one (21), and we do not knowingly collect Personal Information from individuals under age 21, except for our SkyJump attraction. Individuals age 14 and over may make a reservation on this attraction.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have affiliates or in which we engage service providers. You understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.
UPDATES TO THIS PRIVACY POLICY
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on our online services.
CONTACT US
Putter's Gaming Group, Inc., located at 3755 Breakthrough Way, Suite 250, Las Vegas, Nevada, is the entity responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.
If you have questions about this Privacy Policy, please contact us at corporate@puttersvegas.com.
Because email communications are not always secure, please do not include credit card or other sensitive data in your emails to us.
CALIFORNIA CONSUMER PRIVACY ACT NOTICE
If you are a California resident and our prospective, current, or former employee or contractor or an emergency contacts or benefits recipient of any such employee or contractor, please click here to read our privacy notice applicable to you.
This California Consumer Privacy Act Notice provides information for certain California residents in connection with the California Consumer Privacy Act of 2018 (“CCPA”). Under the CCPA, and for purposes of this California Consumer Privacy Act Notice, “Personal Information” generally means information that identifies, relates to, or describes a California resident or household and includes the categories listed below. Below are details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months.
Categories of Personal Information Collected: We collected the following categories of Personal Information:
Identifiers, such as name, contact information, and online identifiers;
Personal information, as defined in the California customer records law,[1] such as payment card information and government-issued ID numbers;
Characteristics of protected classifications under California or federal law,[2] such as sex and marital status;
Commercial information, such as transaction information and purchase history;
Biometric information, such as fingerprints and voiceprints;
Internet or network activity information, such as browsing history and interactions with our website;
Geolocation data, such as device location;
Audio, electronic, visual, similar information, such as call and video recordings;
Professional or employment-related information, such as work history and prior employer;
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Sources of Personal Information. We collected this Personal Information directly from California residents themselves, as well as from third parties and publicly available sources, including, for example, reservation and ticketing services, social media platforms, publicly available databases, government agencies, credit references and financial crime prevention agencies, consumer reporting agencies, research companies, and event or joint marketing partners.
Purposes. We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to develop, improve, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
Disclosures of Personal Information. We may disclose the following Personal Information to our affiliates and service providers for our operational business purposes:
Identifiers, such as name, contact information, and online identifiers;
Personal information, as defined in the California customer records law,[3] such as payment card information and government-issued ID numbers;
Characteristics of protected classifications under California or federal law,[4] such as sex and marital status;
Commercial information, such as transaction information and purchase history;
Biometric information, such as fingerprints and voiceprints;
Internet or network activity information, such as browsing history and interactions with our website and our wi-fi service;
Geolocation data, such as device location;
Audio, electronic, visual, similar information, such as call and video recordings;
Professional or employment-related information, such as work history and prior employer; and
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
“Sales” of Personal Information. The CCPA defines a “sale” as the disclosure of Personal Information in exchange for monetary or other valuable consideration. We have not “sold” Personal Information for purposes of the CCPA/“sold” the following categories of Personal Information:
Identifiers, such as name, contact information, and online identifiers;
Personal information, as defined in the California customer records law,[5] such as payment card information and government-issued ID numbers;
Characteristics of protected classifications under California or federal law,[6] such as sex and marital status;
Commercial information, such as transaction information and purchase history;
Biometric information, such as fingerprints and voiceprints;
Internet or network activity information, such as browsing history and interactions with our website;
Geolocation data, such as device location;
Audio, electronic, visual, similar information, such as call and video recordings;
Professional or employment-related information, such as work history and prior employer; and
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
The CCPA definition of “sale” does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
If you are a California resident, you have the following rights:
(1) Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:
The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
The specific pieces of Personal Information we collected about you;
The business or commercial purpose for collecting or selling Personal Information about you;
The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information; and
The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.
To make a request for information please us at corporate@puttersvegas.com.
(2) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you. To make a request for the disclosures or deletion described above, please email us at corporate@puttersvegas.com. We will respond to your request consistent with applicable law.
(3) Right to Opt Out of Sale. You may opt out of future “sale” of Personal Information about you by clicking here. Opting out of sale will not prevent your personal information from being shared with third parties for non-marketing purposes (where there is no sale), or for purposes of a merger, acquisition, sale of our assets or bankruptcy.
(4) Right to Be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.[1] This includes name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy 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.
[2] This includes sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), age, race, color, religion or creed, ancestry, national origin, disability, medical conditions, genetic information, AIDS/HIV status, marital status, sexual orientation, gender identity and expression, citizenship, primary language, immigration status, military/veteran status, political affiliation/activities, domestic violence victim status, and request for leave.
[3] See note 1.
[4] See note 2.
[5] See note 1.
[6] See note 2.