GDPR / CCPA NOTICE
Circus Circus, LLC is the owner and operator of the Circus Circus Hotel and Casino in Las Vegas, Nevada, USA. In 2019, Ruffin Acquisition, LLC, wholly owned by Phil Ruffin, purchased Circus Circus from MGM Resorts International. Circus Circus’ dedicated staff of employees is committed to providing an unsurpassed experience for guests, and fully supports responsible gaming as outlined in the American Gaming Association's Code of Conduct for Responsible Gaming.
II. VISITORS OUTSIDE OF THE UNITED STATES
III. TYPES OF INFORMATION WE COLLECT
A. Personal Information
"Personal Information" is information through which you can be identified. We collect Personal Information that you provide voluntarily at Circus Circus Web Sites and the Circus Circus Hotel and Casino. We also collect Personal Information that you provide voluntarily by e-mail, postal mail, telephone, and other means. Personal Information that we collect through Circus Circus Web Sites may include but is not limited to the unique number assigned to your server or Internet connection, your geographic location, your name, date of birth, postal address, e-mail address, telephone number, gender, credit card information, gaming activity, and your purchase and reservation information. In addition to the Personal Information listed above, Personal Information that we may collect at Circus Circus Hotel and Casino includes driver’s license number and state, social security number, passport information and naturalization information. When you complete a casino marker play application at any Circus Circus Web Site or the Circus Circus Hotel and Casino, we may also collect the name of your firm, your firm’s address and telephone number, your position with the firm, and banking information (including the name and address of your primary and secondary banks along with your account numbers). Some Personal Information described above is considered "Confidential Personal Information." Confidential Personal Information includes your name associated with one or more of the following: date of birth, credit card information, driver’s license number, state ID card, social security number, passport information and naturalization information.
Personal Information may also include your image in a live video feed that can be viewed on the Circus Circus Web Sites if you visit the Circus Circus Hotel and Casino. We may combine Personal Information with other generally or publicly available information to help us identify your preferences or interests. Your Personal Information may also be merged with Personal Information available from other sources, including (a) e-mail address or postal address append services; (b) credit card verification and credit services; and/or (c) other resorts, casinos, or properties that are owned, operated, or affiliated with Circus Circus or its parent companies or subsidiaries or Partners.
B. Non-Personal Information
"Non-Personal Information" is information about you or your activities through which you cannot be personally identified. When you use the Internet, your web browser or client software may transmit certain information to the servers that host the web sites you visit. The information may include your movement within and interaction with the Circus Circus Web Sites, including what pages you look at and what information you download. When you visit Circus Circus Web Sites, our servers collect such Non-Personal Information. We use this Non-Personal Information for a variety of purposes including to generate aggregate statistics about visitors to Circus Circus Web Sites. In situations where it is possible to do so, Non-Personal Information may be linked to Personal Information.
C. Information Collected Utilizing Cookie Technology
In addition, when you book a reservation online to stay at the Circus Circus Hotel and Casino, the reservation or confirmation number may be stored in a cookie on our computer and in an order file generated by third party vendors that assist in processing and fulfillment of Circus Circus Hotel and Casino reservations.
To browse the Internet and Circus Circus Web Sites without using cookies, you can configure your browser to reject all cookies or to notify you when each cookie is offered so that you can accept or reject each cookie. However, if you reject all cookies, you may not be able to conduct some transactions or use some services on Circus Circus Web Sites.
D. Social Media Information
When you use integrated social media features on Circus Circus Web Sites, mobile applications, or other social media web sites, we may obtain Personal Information such as your name and e-mail address.
E. Information Collected From Partners
F. Information Collected by Other Third Parties
Certain transactions and services offered while visiting Circus Circus Web Sites may be processed or provided by third parties under contract with us for fulfillment and other purposes. When your Personal Information is submitted to these third parties for such purposes, we require those third parties to exercise reasonable care to protect your Personal Information and restrict the use of your Personal Information to the purposes for which it was provided.
G. Employment Application Information
If you apply for a job with us, we might ask for certain Personal Information about you including, for example, your work and education history, and your profile/resume.
IV. HOW WE USE THE INFORMATION WE COLLECT
A. Uses by Circus Circus
1. Use for Marketing Purposes
We may use Personal Information and Non-Personal Information for our own marketing purposes, including notifying you of special promotions, offers and events via postal mail, e-mail, telephone, text messaging, and other means. We will not permit Confidential Personal Information to be used for marketing purposes. If you do not want us to use your Personal Information for marketing purposes, you may opt-out of such uses by notifying us (see Section V below).
2. Use for Non-Marketing Purposes We may use Personal Information, including Confidential Personal Information, and Non-Personal Information for purposes unrelated to marketing, including:
(1) responding to your inquiries, complaints and other communications;
(2) processing and fulfilling reservations and/or purchases and making a record of such reservations and purchases;
(3) contacting you for confirmation or customer service after reservations and purchases are made or after you sign up for or participate in certain activities;
(4) for statistical or demographic analysis;
(5) for tracking reservations and corresponding hotel stays generated through our affiliate program and calculating and/or auditing commissions that may be paid in relation to a hotel stay;
(6) to help improve Circus Circus Web Sites and services;
(7) to customize your experience at Circus Circus Web Sites and social media pages; and/or
(8) to help evaluate your employment application.
Opting-out of the use of your Personal Information for marketing purposes will not prevent your Personal Information, including Confidential Personal Information, from being used for non-marketing purposes.
B. Sharing within Circus Circus and with Subsidiaries
C. Sharing With Partners for Marketing Purposes
We may share your Personal Information and Non-Personal Information with our Partners for joint marketing efforts, or for our Partners’ own marketing purposes. Your Confidential Personal Information will not be shared with Partners for marketing purposes. If you do not want us to share your Personal Information with Partners for marketing purposes, you may opt-out of such sharing by notifying us (see Section V below). When we provide Personal Information to our Partners, we require those Partners to exercise reasonable care to protect your Personal Information and restrict the use of your Personal Information to the purposes for which it was provided. To determine how Partners use the Personal Information they collect directly from you, or about you, from sources other than Circus Circus, please consult the privacy policies of our Partners.
D. Sharing With Partners and Other Third Parties for Non-Marketing Purposes
Although you may request to opt-out of sharing Personal Information for marketing purposes, we reserve the right to disclose Personal Information, including Confidential Personal Information, to our Partners and other third parties for the following purposes:
(1) if you enroll in our Responsible Gaming Program (see "Responsible Gaming Program" in Section VII. below);
(2) for non-marketing purposes, including reservation or purchase fulfillment;
(3) in the event of a transfer to a third party of all or substantially all of the assets of Circus Circus, the Circus Circus Hotel and Casino, and/or any Circus Circus Web Site;
(4) to comply with a court order, subpoena, search warrant or other valid legal process;
(5) to comply with legal, regulatory or administrative requirements of any governmental authorities;
(6) to protect and defend Circus Circus, its subsidiaries and affiliates, and all of their officers, directors, employees, attorneys and agents in connection with any legal action, claim or dispute;
(7) to satisfy any contractual obligation to indemnify its contractors, Partners or other third parties in connection with any legal action, claim or dispute;
(9) to prevent imminent physical harm or threats to public safety;
(10) to third party vendors that Circus Circus may use to perform functions on behalf of Circus Circus, such as companies that process credit card transactions;
(11) to prevent fraud; and
(12) to engage in debt collection.
When we provide Personal Information to our Partners and other third parties for such purposes, we require those Partners and third parties to exercise reasonable care to protect your Personal Information and restrict the use of your Personal Information to the purposes for which it was provided.
V. YOUR COMMUNICATION PREFERENCES
A. Establishing a Preference Account
We are committed to protecting the accuracy and confidentiality of your Personal Information and encourage you to tell us how you want us to communicate with you and let you know about special offers. By creating a Circus Circus Preference Account, you can view and update your Personal Information and chose your communication preferences. Your Preference Account gives you the ability to select from communications preference options including direct mail, e-mail, telemarketing, and text messaging.
To create a Preference Account, or to update your preferences at any time after you have created your Preference Account, visit the Circus Circus Web Site and select "Receive Offers". These options will allow you to create and access your Preference Account.
B. How to Opt-Out
If you wish to opt-out of receiving solicitations from us, or do not want us to share your Personal Information with Partners, for marketing purposes, you can record your preferences by emailing us at , call (702-734-0410), or write to:
Circus Circus Hotel & Casino
2880 Las Vegas Boulevard South
Las Vegas, Nevada 89109
If you do not want us to share your Personal Information among the Circus Circus Hotel and Casino and Circus Circus Web Sites or Affiliates for marketing purposes, you may email us at , or call (702) 734-0410.
Although you may have registered your telephone number on a Federal or State do not call list, certain exemptions (for example, for communicating with established customers) may allow us to contact you via telephone. However, to ensure our customer’s preferences are honored, we also maintain our own internal "Do Not Call" list. If you would like to opt-out of receiving telemarketing sales calls from us by adding your telephone number to our internal Do Not Call list, you may email us at , or call (702) 734-0410.
Circus Circus Hotel & Casino
2880 Las Vegas Boulevard South
Las Vegas, Nevada 89109
If you do not want us to share your Personal Information among the Circus Circus Hotel and Casino and Circus Circus Web Sites or Affiliates for marketing purposes, you may email us at or call (702) 734-0410.
Non-Personal Information and Personal Information, including Confidential Personal Information, collected by the Circus Circus Web Sites and the Circus Circus Hotel and Casino is stored on secure servers. The secure servers are protected by firewalls and a multitude of other industry standard security measures. These security measures are instituted to ensure the protection of these secure servers from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach.
We have controls in place that are designed to detect potential data breaches, contain and minimize the loss of data, and conduct forensic investigations of a breach. Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your Personal Information. Employees who violate our privacy policies are subject to disciplinary action, up to and including termination.
We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that a consumer may utilize to send e-mails and submit information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you utilize will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of your information before we receive it.
As a standard security practice, we will take reasonable steps, which are standard in the industry to ensure that the communication methods used to support the Circus Circus Web Sites do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using a Circus Circus Web Site, it may be an indication that you need to upgrade your Internet browsing tool or application to a newer version that supports more secure communication methods.
VII. RESPONSIBLE GAMING PROGRAM
We believe that gaming should always be handled responsibly. That is why Circus Circus adheres to the American Gaming Association Code of Conduct for Responsible Gaming. As part of our Responsible Gaming Program, we will not use the Personal Information of members of the Circus Circus Self-Limit Access Program of Nevada, as applicable, for any marketing purposes, including direct mail marketing, telemarketing, promotional mail, and player recognition programs.
VIII. CONNECTIONS (LINKS) TO THIRD PARTY WEB SITES
When you connect (link) to unaffiliated third-party sites, including sites operated by our Partners, through the Circus Circus Web Sites, we are not responsible for, and cannot control the information collection or privacy practices of those sites.
IX. PERSONS UNDER AGES 18 AND 21
Certain areas and activities at the Circus Circus Hotel and Casino and Circus Circus Web Sites are intended for use only by persons 21 years of age or older.
We reserve the right to verify your age at any time for any reason and may refuse admittance or service to a person who does not have valid age identification at any time.
Circus Circus abides by the Children’s Online Privacy Protection Act (COPPA). Therefore, we do not knowingly collect or allow the collection of Personal Information from persons under the age of 18. If the parent or guardian of a person under 18 believes that the person has provided us with Personal Information, the parent or guardian of that person should contact us at and request that such Personal Information be deleted from our files. If a person under the age of 18 submits Personal Information, we delete the information as soon as we discover the source of the submission, and we do not use the information for any purpose.
EU GDPR / CCPA PRIVACY NOTICE
For the purposes of GDPR and/or the CCPA, Circus Circus is the controller of any personal data collected from you on this website or otherwise for the purpose of conducting or developing our business with you. For the purposes of this Notice, personal data means any information relating to an identified or identifiable person.
Information You Provide
In order to access or use certain portions of this website or enjoy the full functionality of this website, or otherwise in conducting business with us or seeking to conduct business with us, you may be prompted to provide certain personal data to us in the following ways:
• by filling in forms on this website, our casino players club, employment applications, a trade show or marketing event, or anywhere else we conduct business;
• by subscribing to newsletters or other communications;
• by corresponding with us by phone, e-mail or otherwise using our contact details;
• by clicking on our online banner advertisements;
• by visiting our social media (e.g. Facebook, Twitter, etc.) pages;
• by making purchases or engage in other transactions or activities;
• by using WiFi services provided by us;
• by using text messaging services provided by us;
• by providing information to authorized third parties or business partners; or
• other activities that my require personal data
Typically, the personal data you give us may include name, business affiliation, business address, telephone number, street address and email address, birth date, credit card or banking information, gaming activity information, and any personal details required by law and/or to resolve any inquiries or complaints.
This personal data is required to enter into a contract with you (such as in anticipation of a services agreement) or to perform a contract with you (such as to provide services at your request), and failure to provide any information may result in our inability to provide requested services or products.
Information We Collect Automatically
When you visit this website, our server automatically collects certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:
• your domain;
• your IP address;
• the date, time and duration of your visit;
• your geographical location;
• your browser type;
• your operating system;
• your page visits;
• information from third parties;
• other information about your computer or device;
• Internet traffic
Information From Other Sources
When you use integrated social media features on this website, mobile applications or other social media websites, we may obtain personal data such as your name and email address.
Why We Use Personal Data
All processing and use of your personal data is justified. The following is an overview of the justifications for processing personal data, and why we use your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or contract.
• Justification – The processing is necessary to perform a contract with you or take steps to enter into a contract at your request: To provide you with documentation or communications which you have requested; to fulfill an order; to contact you for confirmation and provide after-sales support; to process and complete certain transactions involving the website, and more generally transactions involving Circus Circus's products and services; or to provide product information you have requested;
• Justification – The processing is necessary for us to comply with a relevant legal obligation: To keep accounting records and evidence of on-line sales;
• Justification – The processing is in our legitimate interests, which are not overridden by your interests and fundamental rights: To track reservations and corresponding hotel stays generated through our affiliate program and to calculate and/or audit commissions that may be paid in relation to a hotel stay; to send you materials about our products and services; to evaluate transactions involving this website or our products and services; to operate, evaluate, maintain, improve and develop this website (including by monitoring and analyzing trends, access to, and use of this website for advertising and marketing, including statistical or demographic analysis); to engage you about events, promotions, this website and Circus Circus's products and services; to send you marketing communications; to correspond with users to resolve their queries or complaints; to protect and ensure safety of this website, Circus Circus confidential and proprietary information, and Circus Circus employees; to manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations; to share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets; or
• Justification – You have consented to the processing: To cite you on this website as a satisfied customer.
When the justification for processing is our legitimate interests, those interests are to use supplier, customer and this website user data to conduct and develop our business activities with them and with others, while limiting the use of their personal data to those purposes that strictly support the conduct and development of our business within the reasonable expectation of the individuals concerned.
Circus Circus will not sell or rent your personal data to third parties.
Disclosure of Personal Data
From time to time it will be necessary to share your personal data among the Circus Circus Hotel and Casino and this website, as well as with our affiliated businesses for the purposes described above. We may also appoint third party service providers (who will operate under our instructions) to assist us in providing information, products or services to you, in conducting and managing our business, or in managing and improving our products, services or this website. Circus Circus may share your personal data with these affiliates and third parties to perform services that the third parties have been engaged by Circus Circus to perform on Circus Circus's behalf, subject to appropriate contractual restrictions and security measures, or if we believe it is reasonably necessary to prevent harm or loss, or if we believe that the disclosure will further an investigation of suspected or actual illegal activities.
We do not intentionally store any personal data within the EU. Should there ever be a situation in which we store your personal data in the EU, and transfer it outside the EU to other Circus Circus affiliates or to third party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. For transfers of personal data among Circus Circus affiliates we will put in place European Commission approved Standard Contractual Clauses. The list of all the countries to which your personal data is transferred, and whether each country benefits from a decision of the European Commission determining that the country provides adequate protection to personal data, is set forth here. Should it ever occur, you have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU by contacting ITmanagers@circuscurcus.com.
Circus Circus reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.
This website is not intended for use by children under the age of 18 or 21 years depending on the functionalities used and Circus Circus does not knowingly collect, store, share or use the personal data of children under 18 years. If you are under the age of 18 years, please do not provide any personal data, even if prompted by this website to do so. If you are under the age of 18 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify Circus Circus and Circus Circus will delete all such personal data.
We may use your personal data to send you direct marketing communications about products or our related services. This will be in the form of email, post, SMS or targeted online advertisements. We limit direct marketing to a reasonable and proportionate level, based on the information we have about you.
Where opt-in consent is required by applicable law, we will ask for your consent, and we will be relying on consent under GDPR and/or CCPA. Where we do not use electronic media or where we rely on soft-opt in exemption under applicable law, for the purposes of GDPR and/or CCPA, our processing of your personal data for direct marketing purposes will be based on our legitimate interests to promote our business. You have a right to stop receiving direct marketing at any time - you can do this by following the opt-out or unsubscribe links in electronic communications (such as emails), by changing your account privacy settings, or by emailing us at firstname.lastname@example.org.
We also use your personal data for customizing or personalizing advertisements, offers and content made available to you based on your use of our platform or other mobile applications, platforms or services, and analyzing the performance of those advertisements, offers and content, as well as your interaction with them. We may also recommend content to you based on information we have collected about you and your viewing habits. This constitutes 'profiling'.
Circus Circus aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and Circus Circus utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by Circus Circus are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.
Retention of Your Personal Data
We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation setting out the period during which legal claims may be filed in court. For example, we’ll retain your personal data during the statute of limitation period, to maintain an accurate record of your dealings with us. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. With respect to marketing, we retain your personal data for up to ten years (or less when required by law) after your last request for service or other contact you initiate.
This website may contain links to third party sites. Since Circus Circus does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third party sites. This Notice applies solely to personal data collected by this website or in the course of our business activities.
Right to withdraw consent: Where applicable, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving electronic marketing communications, you can use the 'unsubscribe' link provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications.
Right of access, rectification and erasure: You have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances. You can see and update most of this data yourself online, or by contacting us directly at email@example.com.
Data portability: Where we are relying (as the justification for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
Right to restriction of processing: You have the right to restrict our processing of your personal data (that is, allow only its storage) where:
• you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
• where the processing is unlawful but you do not want us to erase the personal data;
• where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defense of legal claims; or
• where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
Where your personal data is subject to restriction, we will only process it with your consent or for the establishment, exercise or defense of legal claims.
You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law. A list of data protection supervisory authorities is available here.
Right to object to processing (including profiling) based on legitimate interest grounds: Where we are relying upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
Right to object to direct marketing (including profiling): You have the right to object to our use of your personal data (including profiling) for direct marketing purposes, such as when we use your personal data to invite you to our promotional events.
Please contact us at if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.
Any changes or updates we may make to this Notice will be posted on this page in advance. If we have your contact details on file we will notify you in advance of any changes to this Notice that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this Notice.
If you have any questions in relation to this Notice or you wish to exercise any of your rights, please contact us at firstname.lastname@example.org.
Last Modified: February 6, 2020 © Circus Circus, LLC