MARRIOTT CASINOS GLOBAL PRIVACY STATEMENT

Marriott International, Inc. values you as our customer and recognizes that privacy is important to you. We want you to be familiar with how we collect, use, and disclose your Personal and Other Data (collectively, “Data”) in our managed casino properties (collectively, “Casinos”, “we” or “us”). ¹

This Privacy Statement describes the privacy practices of Casinos and how we collect and use your Personal Information: (i) when you visit one of our Casinos; (ii) via our website or online, where applicable; (iii) via our social media pages; and/or (iv) via software applications made available by us for use on or through computers and mobile devices (the “Apps”).

PERSONAL INFORMATION

“Personal Data” is information that identifies you as an individual or relates to an identifiable individual. 

We may collect the following Personal Data when you submit a Front Money application (i.e., with Front Money, you deposit your own funds into a casino account) on a website of one of our Casinos:

• First name
• Middle Initial;
• Last name;
• Suffix;
• Date of birth;
  
• Driver’s license details;
• Passport number;
• Additional passport information (e.g., expiration date);
• Social Security number;
• Home address;
• Email address;
• Telephone numbers;
• Trip details including arrival date;
• Deposit amount;
• Employment information including: (i) employer; (ii) type of business; (iii) number of years with employer; (iv) position; (v) annual income; (vi) business address; (vii) business phone number;
• Financial information including: (i) politically exposed person/relative information;
  (ii) source of income; (iii) estimated annual compensation; (iv) source of funds; (v) bank account details, including name, account type, bank routing number, bank account number, and whether the account is a trust; (vi) branch address; and (vii) confirmation of whether you have Front Money at other casinos; and
• Your signature.

We may also collect the following Personal Data when you visit one of our Casinos, including if you sign up to play table games or in the slot area, or if you choose to cash out above a predetermined threshold (the threshold is dependent on the Casino you are visiting; please contact the Casino for more information on its predetermined threshold):

• First name, middle initial, and last name;
• Date of birth;
• Driver’s license, state issued ID, and/or passport (scanned);
• Home address;
• Email address;
• Telephone numbers;
• Your playing preferences and history when you sign up for the Players Club;
• Your rewards history; and
• Your Casino account balance.

We may also collect the following Personal Data when you sign up to one of our Players Clubs/Cards or VIP Areas:

• First name, middle initial, and last name;
• Date of birth;
• Driver’s license, state issued ID, and/or passport (scanned);
• Email address;
• Home address;
• Telephone number; and
• Your playing preferences and history when you sign up for the Players Club.

In addition to the Personal Data collected when visiting one of our Casinos, we may also collect the following Personal Information where legally required or where necessary to prevent fraudulent activities and to enhance security measures in our Casinos:

• Information on any suspicious activities carried out by you while on our Casino premises (such as if you try to commit credit card fraud or identity theft);
• Photos taken via CCTV security recordings;
• Source of funds information via Lexis Nexis for the prevention of criminal activity;
• Information required by regulatory authorities and law enforcement (such as the police and local gaming commission or other relevant authorities) on their suspicious activity reports including (but not limited to) name, date of birth, address, gender, play behavior, identification documents such as passports or driver’s licenses, source of funds, type of player information, previous sanctions information and open-source research including via Google and social media platforms; and
• Information requested in a subpoena.   

If you disclose any Personal Data 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 Statement.

We also process deidentified and/or aggregated information, such as how individuals in general use certain services provided by our Casinos (“Deidentified Information”). Such information on its own does not identify you, so it does not qualify as Personal Data, unless otherwise provided by applicable law. We will not re-identify, or attempt to re-identify, such Deidentified Information.  We use or disclose Deidentified Information for any purpose, in accordance with applicable law. This Privacy Statement does not apply to such Deidentified Information.

OTHER USES AND DISCLOSURES

We also use or disclose 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. This may include laws outside your country of residence.
• To cooperate with public and government authorities. To respond to a request or to provide information we believe is necessary or appropriate. This may include authorities outside your country of residence.
• To cooperate with law enforcement. For example, when we respond to law enforcement requests or orders or provide information we believe is important.
• For other legal reasons. For example, to enforce our terms and conditions, 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 may have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any 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 any information that does not reveal your specific identity or does not directly relate to an identifiable individual. When you visit our websites, we may collect data typically collected through websites, such as:

• Browser and device information;
• Information collected through cookies, pixel tags and other similar technologies as follows: When you visit our website from either a desktop or mobile device, we may collect and use cookies or other identifiers to serve you with personal advertisements, either via email, on our website, or on other websites on the Internet; to measure how you interact with our websites; and to maintain your preferences. We do this primarily through cookies, which are pieces of data stored directly on the computer or mobile device that you are using.
  
  You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html
  In general, we use four different types of cookies:

-   Required Cookies: These cookies are necessary to enable the basic features of the website or app, such as providing a secure log-in.
-  Functional Cookies: These cookies allow our websites to remember your site preferences and choices you make on the site. We also use functional cookies to facilitate navigation, to display content more effectively, and to personalize your experience.
-  Advertising Cookies: Advertising cookies allow us to select which advertisements or offers are most likely to appeal to you. We also use them to track responses to online advertisements and marketing and to better understand your interests or to share this information with advertisers. These cookies may also allow you to share certain pages with social networks.
-  Analytics Cookies: Analytics cookies help us to improve our website by collecting and reporting information on how you use it.

Opting out of Cookies

There are several ways to opt-out of cookies. If, however, you do not accept any cookies, you may experience some inconvenience in your use of our websites, apps, and social media pages. For example, we will not be able to recognize your computer, and you will need to login every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests.

1. Browser settings: You can opt out of cookies on your browser. Every browser is different so please check the instructions provided by your browser.
2. Through our “Tracking Preferences” site
3. Google Analytics: We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the websites, apps and social media pages. These services also collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners and opt out by downloading Google Analytics opt out browser add on, available at http://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt out by visiting http://www.adobe.com/privacy/opt-out.html .

SECURITY

We seek to use reasonable organizational, technical, and administrative measures 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 “Contacting Us” section below.

CHOICES AND ACCESS

If you would like to request to access, correct, add to, or delete your Personal Information, or opt out of or cease the processing of your Personal Information (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below.  We will respond to your request in a manner that is consistent with applicable law.

RETENTION PERIODS

We retain Personal Information for the time period necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by applicable law.  The criteria used to determine our retention periods may include: 

• As long as we have an ongoing relationship with you;
• As required by a legal obligation to which we are subject; or
• As advisable in light of our legal position (such as with regard to applicable statutes of limitations, litigation, or regulatory investigations). 

THIRD-PARTY SERVICES

This Privacy Statement does not address, and we are not responsible for, the privacy, information, security, or other policies or practices of any third parties (such as any third party operating a website or service to which our website may link). The inclusion of a link on any of our websites does not imply endorsement of the linked site or service by us. 

JURISDICTION AND CROSS-BORDER TRANSFERS

Your Personal Information will be stored and processed in the country where the Marriott Casino you are visiting is located (e.g., if you are visiting a Marriott Casino in Aruba, your Personal Information will be stored and processed in Aruba only).

UPDATES TO THIS PRIVACY STATEMENT

The “LAST UPDATED” legend at the top of this Privacy Statement indicates when this Privacy Statement was last revised.  Any changes will become effective when we publish the revised Privacy Statement.  

CONTACTING US

If you have any questions about this Privacy Statement, please contact us at privacy@marriott.com. Alternatively, you can contact our managed Casino properties at the below addresses:

• Sheraton Cairo Hotel & Casino: Galae Square, P. O. Box 11, Cairo, Egypt
• Cairo Marriott Hotel & Omar Khayyam Casino: 16 Saray El Gezira Street, Zamalek, Cairo, Egypt, 11211
• San Juan Marriott Resort & Stellaris Casino: 1309 Ashford Avenue, San Juan, Puerto Rico, 00907
• Aruba Marriott Resort & Stellaris Casino: L.G. Smith Boulevard # 101, Palm Beach, Aruba
• The Ritz-Carlton, Aruba: L.G. Smith Boulevard #107, Noord, Aruba
• The Ritz-Carlton, Turks & Caicos: Grace Bay Rd, Grace Bay TKCA 1ZZ, Providenciales, Turks & Caicos Islands
• The St. Regis Bermuda Resort: 34 Coot Pond Road, St George's, Bermuda, GE 03