PRIVACY POLICY

We value our patrons and take their personal privacy seriously. In the course of providing patrons with credit or other financial services we collect certain personal information that we understand may be considered private or confidential. This information may be contained in applications and other forms submitted to us, gathered from gaming activity with us or obtained from our affiliates and other third parties such as credit bureaus. The following is a description of our policies as it pertains to the collection, use and handling of this information.

 

OUR PRIVACY PRINCIPLES

  • We protect, according to strict standards of security and confidentiality,all non-public personal information we collect about our customers.
  • We maintain physical, electronic and organizational safeguards to protect this information.
  • We contractually require any person or organization providing products or services to customers on our behalf to protect the confidentiality of this information.
  • We afford former customers the same protections as existing customers with respect to the use and sharing of their information.
  • We permit only authorized employees, who are trained in the proper handling of this information, to have access to it.

INFORMATION WE MAY COLLECT

We collect and use information we believe is necessary to administer our business and provide patrons with the financial services they request. We may collect and maintain several types of information needed for these purposes, such as those stated below.

  • Information we receive on applications for credit or other financial services, such as name, address, telephone number, Social Security number and other identifying information.
  • Information we receive about patrons from others, including credit bureaus, relating to credit history and financial transactions with others.
  • Information about patron transactions with us including payment history.

INFORMATION DISCLOSURE TO AFFILIATED ENTITIES

If necessary, we may share information we receive from patrons, and about patron transactions with us, with affiliated entities for the purpose of providing financial or promotional services.

INFORMATION DISCLOSURE TO NON-AFFILIATED ENTITIES

We share the information we collect about our patrons with credit bureaus, collection agencies, and other non-affiliated third parties only as permitted by law. Certain limited patron information may be shared with other businesses with which we contract, who may contact patrons as part of a joint marketing or promotional program (Joint Marketers). These businesses may include financial services companies, such as banks and insurance companies, other service providers, such as airlines and car rental agencies, and retailers. The information we share with them such as name, address and telephone number is gathered solely from participation in our loyalty program.

CHOICE TO SHARE INFORMATION

It is the choice of the patron whether or not we share their personal information with Joint Marketers. Patrons must be given the opportunity to opt out of our marketing efforts at all interfaces for which their information is requested for these purposes.

NOTIFICATION

Notification of our Privacy Policy must be provided to patrons in a manner in which provides them the opportunity to understand the implication of sharing their information prior to doing so.

CHANGES IN PRIVACY POLICY

Over time, it may be necessary to modify or supplement our Privacy Policy. Material changes will be communicated to our active credit or gaming customers.

 

 

California Consumer Privacy Statement

 

This California Consumer Privacy Statement ("Statement") applies solely to the personal information we collect online and offline of California consumers (excluding Company employees, applicants, contractors, and B2B personnel). This Statement is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 and its implementing regulations (the "CCPA") and uses certain terms that have the meaning given to them in the CCPA. This Statement supplements our Privacy Notice and is not intended to contradict or limit the applicability of the information provided in the Privacy Notice. 

Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you: 

  • Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; Momentum account number and PIN, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.
  • Additional Data Subject to Cal. Civ. Code § 1798.80 such as signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, other financial information, medical information, and health insurance information.
  • Protected Classifications such as race, color, national origin, religion, age, sex, gender, marital status, medical condition, disability, citizenship status, and military and veteran status, and other characteristics of protected classifications under California or federal law.
  • Commercial Information such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Biometric Information
  • Online Activity such as Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements.
  • Geolocation Data
  • Sensory Information such as audio, electronic, visual, thermal, olfactory, and similar information.
  • Employment Information such as professional or employment-related information.
  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use your personal information for the purposes described in this Privacy Notice and for certain business purposes specified in the CCPA, as described below.

  • Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
  • Short Term Use, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
  • Detecting security Incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Debugging to identify and repair errors that impair existing intended functionality: Identifiers; Online Activity; and Sensory Information
  • Internal R&D for technological development and demonstration
  • Safety, including undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

We also may collect additional information or use the information listed above in other ways for which we provide specific notice at the time of collection.

Our Prior Collection, Use, and Disclosure of Personal Information

We may have collected and used your personal information, as described in the Notice of Collection and Use of Personal Information section above, during the 12-month period prior to the date this Privacy Notice was last updated. For the personal information collected during that timeframe, we describe below: (1) the categories of sources from which we may have obtained the personal information; (2) the categories of third parties with whom we may have shared the information; and (3) the categories of personal information we may have sold

Sources of Personal Information.  We may have obtained personal information about you from various sources, including as described below.

Directly from you (such as when you make reservations or check in; purchase gift certificates, merchandise, or other services during your stay; participate in a contest; contact us with requests, feedback, or suggestions; or enroll in our loyalty program)

  • Your devices (such as when you visit our websites)
  • Your family or friends (such as when they add your information to their reservation)
  • Our affiliates and subsidiaries
  • Organizers or exhibitors for Meetings, Incentives, Conferences, and Exhibitions (“MICE”)
  • Vendors, suppliers, and business partners (including travel agencies, event organizers, and travel booking platforms) and marketing partners
  • Third parties with whom we run promotions or marketing efforts (such as contests, sweepstakes, and giveaways)
  • Social networks
  • Online advertising services, including advertising networks
  • Government entities, law enforcement authorities, and third-party subpoenas
  • Consumer data resellers and data aggregators (such as data append and updating services)
  • Publicly available sources (such as public databases)

Sharing of Personal Information.  We may have shared your personal information with certain categories of third parties, as described below, including for the business purposes described above.

We may have shared the following categories of your personal information with our affiliates and subsidiaries: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Biometric Information; Online Activity; Sensory Information; Employment Information; and Inferences.

We may have shared the following categories of your personal information with vendors, suppliers, and business partners (including travel agencies, event organizers, and travel booking platforms) and marketing partners: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Biometric Information; Online Activity; Sensory Information; Employment Information; and Inferences.

We may have shared the following categories of your personal information with professional services organizations (such as auditors and law firms): Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.

We may have shared the following categories of your personal information with third parties with whom we run promotions or marketing efforts (such as contests, sweepstakes, and giveaways): Identifiers; Protected Classifications; Commercial Information; and Inferences.

We may have shared the following categories of your personal information with online advertising services, including advertising networks: Identifiers; Commercial Information; Online Activity; Sensory Information; Employment Information; Inferences.

We may have shared the following categories of your personal information with government entities and law enforcement authorities in limited circumstances as described in this Privacy Notice: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.

We may have shared the following categories of your personal information with data analytics providers: Identifiers; Commercial Information; Online Activity; and Inferences.

We may have shared the following categories of your personal information with social media platforms: Identifiers; Commercial Information; Online Activity; and Inferences.

We may have shared the following categories of your personal information with third parties in the event of a corporate transaction, such as an acquisition: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Geolocation Data; Sensory Information; Employment Information; and Inferences.

Sale of Personal Information.  We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information, including via automated technologies on our Online Channels, in exchange for non-monetary consideration (such as an enhanced ability to serve you content and send advertisements that may be of interest to you). During the 12-month period prior to the date this Privacy Notice was last updated, we may have disclosed in this manner to online advertising services and social networks the following categories of personal information: (1) Identifiers; (2) Commercial Information; (3) Online Activity; and (4) Inferences. You have the right to opt out of this disclosure of your information, as detailed below. We do not have actual knowledge that we sell personal information of minors under 16 years of age. 

California Consumer Privacy Rights

Effective January 1, 2020, you have certain choices regarding your personal information, as described below.

  • Access. You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure, and sale of such information. To submit an access request, click here or call us at 1.800.910.2387.
  • Deletion. You have the right to request that we delete certain personal information we have collected from you. To submit a deletion request, click here or call us at 1.800.910.2387.
  • Opt-Out of Sale. You have the right to opt-out of the sale of your personal information.  To submit an opt-out of sale request, click here or call us at 1-877-883-6423. For additional information about how to manage cookies and opt out of online interest-based advertising, review the Cookies and Similar Technologies section of our Privacy Notice.  Your opt-out will be specific to the web browser or device you use at the time you exercise your opt-out rights; if you use multiple web browsers or devices, you will need to opt-out from each browser and device. Note that opting-out of the use of your information for interest-based advertising purposes does not mean you will stop seeing ads, including interest-based ads, because (i) your personal information that was collected prior to your opt-out request may be further used for interest-based advertising purposes and (ii) ads may be served to you based on your interactions with other companies and their websites. Note that we may still share your information in ways that are not a “sale”, such as with our service providers, for our own online advertising purposes.
  • Shine the Light Request. You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the preceding calendar year and (2) the identity of those third parties. To submit a Shine the Light request, click here.

Verifying Requests.  To help protect your privacy and maintain security, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion, or opt-out of sale request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).

Momentum Rewards Program.  We may collect and use personal information (such as your name, date of birth, zip code, email address, Momentum ID, and password) in connection with the Momentum Loyalty Program. Momentum Members understand that, in exchange for rewards and offers in connection with the Program, they agree to provide certain personal information for use by the Company. This financial incentive is not determined or adjusted on the basis of whether you exercised your rights under the CCPA and is permitted by the CCPA because the incentives we offer to you are reasonably related to the value provided to us by your personal information. You may opt-in to this program by enrolling in the Momentum Loyalty Program on our website or at a Momentum Rewards Center on property.  You have the right to withdraw from the program at any time and may do so by contacting ContactUs@MoheganSunLasVegas.com.

Additional Information.  If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request by contacting ContactUs@MoheganSunLasVegas.com or 1.800.910.2387.

Coming soon pending approval from all regulatory agencies.