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Privacy Policy & GDPR Notice

TI LAS VEGAS PRIVACY POLICY & GDPR NOTICE

Treasure Island, LLC is the owner and operator of the Treasure Island Hotel and Casino in Las Vegas, Nevada, USA.  In 2009, Ruffin Acquisition, LLC, wholly owned by Phil Ruffin, purchased TI from MGM Resorts International.  Treasure Island Hotel and Casino features 2,884 guest rooms and suites, approximately 90,000 square feet of gaming space, several fine and casual dining outlets, and Mystère, the first permanent production in Las Vegas by Cirque du Soleil.  TI’s 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.

We hope that you enjoy our world-class facilities, exciting entertainment, and quality customer service.  Because we value your patronage and respect your privacy, we are providing you with this Treasure Island, LLC ("TI", "we", "us", "our") Privacy Policy ("Privacy Policy") so that you understand how TI collects, stores, shares and uses information from and about our website visitors, customers, and vendors. 

This also includes our General Data Protection Regulation (GDPR) Privacy Notice ("Notice") describing our collection, use and disclosure of personal and non-personal data ("Personal Information") collected through this website or in the course of our business activities conducted elsewhere, such as the Treasure Island Hotel and Casino, when we act as the controller of that data and when its processing is governed by the EU GDPR.  It also describes how you can opt-out of some uses of Personal Information.  Please note this Privacy Policy and Notice does not apply to the information collected, stored, shared or distributed by third-party sites, and this Privacy Policy and Notice may be updated from time to time.

Please review this Privacy Policy and Notice carefully.  Click here to view Frequently Asked Questions or you may contact us at TI-General@treasureisland.com, call +1 702-894-7111, or write to Treasure Island Hotel & Casino, Attn: General Counsel / Privacy Policy, 3300 Las Vegas Blvd South, Las Vegas, NV 89109.  Users of TI Web Sites should also click here to review the Terms of Use.

Privacy Policy

INTRODUCTION

Please note this Privacy Policy is separate, but not mutually exclusive from the GDPR Notice outlined further below.  Should there be any material differences between this Privacy Policy and the GDPR Notice, the GDPR Notice will prevail for individuals within the Territorial Scope of the EU GDPR.

I. SCOPE OF PRIVACY POLICY

A. TI Web Sites & Social Media

This Privacy Policy is applicable only to the web sites and social media pages that specifically refer to this Privacy Policy ("TI Web Sites").  It does not apply to any other web sites, including other web sites that may be owned, operated, or affiliated with TI or its parent companies or subsidiaries. 

B. TI Hotel and Casino

This Privacy Policy is applicable only to the Treasure Island Hotel and Casino ("TI Hotel and Casino").  It does not apply to any other resorts, casinos, or other properties that are owned, operated, or affiliated with TI or its parent companies or subsidiaries.
 
II. VISITORS OUTSIDE OF THE UNITED STATES

The TI Web Sites are maintained on servers located in the United States, and Personal Information is also stored on computers located in the United States.  The United States may not offer a level of privacy protection for Personal Information, which includes Confidential Personal Information (defined below), as great as that offered in other jurisdictions.  Therefore, the disclosure of Personal Information pursuant to this Privacy Policy is at your own risk.  We make no representation that the practices described in this Privacy Policy are compliant with laws outside of the United States that apply to the collection, security, use and disclosure of Personal Information.  TI will use its best reasonable efforts to maintain the security of Personal Information.

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 TI Web Sites and the TI 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 TI Web Sites may include but is not limted 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 TI 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 TI Web Site or the TI 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 TI Web Sites if you visit the TI 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 TI 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 TI Web Sites, including what pages you look at and what information you download.  When you visit TI 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 TI 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

TI Web Sites utilize a website technology known as "cookies."  A cookie is a small file that contains information sent by a web site that is saved on your hard drive by your computer’s browser.  Cookies store information that a web site may need to personalize your experience and to gather web site statistical data, such as which web pages you visit, what material you download, your Internet provider’s domain name and country, and the addresses of web sites you visited immediately before and after visiting a particular web site.  TI Web Sites use cookies to collect and store your preferences for viewing the TI Web Sites, such as whether you disable a particular function, so that you may not have to disable the same function on following visits.  The cookie information may also be used to detect and resolve web site problems and to assist with customer support concerns.

In addition, TI Web Sites utilize cookies to provide a unique identifier to your computer.  This helps us to generate statistics regarding usage of TI Web Sites, such as the percentage of repeat visitors.  In situations where TI has Personal Information, the unique identifiers may be matched with Personal Information.  In addition, when you book a reservation online to stay at the TI 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 TI Hotel and Casino reservations.

To browse the Internet and TI 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 TI Web Sites.

D. Social Media Information

When you use integrated social media features on TI 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

We may obtain Personal Information from carefully selected business partners and other entities that direct you to, or are located at, TI Web Sites and/or the TI Hotel and Casino (collectively, "Partners").  We may use Personal Information obtained from our Partners in accordance with the terms of this Privacy Policy.  We generally have no control over how our Partners use Personal Information they collect from or about you.  Therefore, if you provide Personal Information, including Confidential Personal Information, to our Partners, we encourage you to consult our Partners’ privacy policies for more information about their privacy protection practices.

F. Information Collected by Other Third Parties

Certain transactions and services offered while visiting TI 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 TI

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 TI Web Sites and services;
    (7) to customize your experience at TI 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 TI and with Subsidiaries

Your Personal Information and Non-Personal Information may be shared for any purpose among the TI Hotel and Casino and TI Web Sites.  Your Personal Information and Non-Personal Information may also be shared for any purpose with TI parent companies and subsidiaries not covered by this Privacy Policy, and any other resorts, casinos, or other properties that are owned, operated by or affiliated with TI or its parent companies or subsidiaries (collectively, "Affiliates").  Your Confidential Personal Information will only be shared to the extent necessary to permit TI to validate your identity for the purposes of extending credit, completing a purchase transaction, recording of gaming related activity or other legitimate non-marketing business needs.  If you do not want your Personal Information to be shared among the TI Hotel and Casino, TI Web Sites and Affiliates for marketing purposes, you may opt-out of such sharing by notifying us (see Section V below).

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 TI, 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 TI, the TI Hotel and Casino, and/or any TI 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 TI, 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;
    (8) to enforce the Terms of Use of TI Web Sites;
    (9) to prevent imminent physical harm or threats to public safety;
    (10) to third party vendors that TI may use to perform functions on behalf of TI, 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 TI 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 TI Web Site and select "Email Promotions" or "MyTI Guestbook".   These options will allow you to create and access your Preference Account.

If you are a casino member of TI Players Club, you may update your communications preferences by logging in to your online account, and selecting "Update" on Your Member Home Page.  Information regarding opt-out procedures is also provided within every TI promotional e-mail or direct mail communication sent to you.

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 TI-General@treasureisland.com, call (702-894-7111), or write to:

Treasure Island Hotel & Casino
Attn: Privacy Policy
3300 Las Vegas Boulevard South
Las Vegas, Nevada 89109

If you do not want us to share your Personal Information among the TI Hotel and Casino and TI Web Sites or Affiliates for marketing purposes, you may email us at TI-General@treasureisland.com, or call (702) 894-7111.

C. Telemarketing

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 TI-General@treasureisland.com, or call (702) 894-7111.

D. California, USA Privacy Policy Rights

To fulfill the intent of the State of California law requiring web sites to conspicuously post their privacy policies, we have included the following summary.  The purpose of this Privacy Policy is to identify the Personal Information we collect, describe how you can review and make changes to that Personal Information, describe how you can learn about changes to the Privacy Policy, and provide you with a mechanism to opt-out of certain marketing activities. 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 may email us at TI-General@treasureisland.com, call (702) 894-7111, or write to:

Treasure Island Hotel & Casino
Attn: Privacy Policy
3300 Las Vegas Boulevard South
Las Vegas, Nevada 89109

If you do not want us to share your Personal Information among the TI Hotel and Casino and TI Web Sites or Affiliates for marketing purposes, you may email us at TI-General@treasureisland.com or call (702) 894-7111.

VI. SECURITY

Non-Personal Information and Personal Information, including Confidential Personal Information, collected by the TI Web Sites and the TI 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 TI 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 TI 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 TI 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 TI 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 TI Web Sites, we are not responsible for, and cannot control the information collection or privacy practices of those sites.

It is important that you review and understand the privacy policies posted on any linked sites you visit, before providing any Personal Information.  These sites may also collect cookies, or allow third-party advertisers on their sites to collect cookies.  You can often find information regarding a site and its privacy policy (if one exists) on the site’s home page.  If you cannot find a site’s privacy policy or do not like a site’s privacy policy, you may prefer not to conduct business with, nor provide information through, that site.

IX. PERSONS UNDER AGES 18 AND 21

Certain areas and activities at the TI Hotel and Casino and TI Web Sites are intended for use only by persons 21 years of age or older.

If you are under the age of 21, we ask that you do not access or attempt to access any portions of the Web Sites that are restricted to persons age 21 or older, including but not limited to any Web Sites containing password-restricted information (see TI Terms of Use for more information).

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.

TI 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 TI-General@treasureisland.com 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.

X. CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise this Privacy Policy at any time without notice.  When this Privacy Policy is revised the revised Privacy Policy will be available at the TI Hotel and Casino and will be posted on the TI Web Sites. Any revised Privacy Policy will only apply prospectively to Personal Information or Non Personal Information collected or modified after the effective date of the revised policy.  You should periodically review the Privacy Policy available at the TI Hotel and Casino and the TI Web Sites for revisions.  You are encouraged to bookmark the Web Sites to check for updates and take or print out copies of the Privacy Policy for your records.  Use of a TI Web Site after revision of the Privacy Policy signifies your consent to the revised Privacy Policy.

If you have any questions regarding this Privacy Policy, please contact us at TI-General@treasureisland.com.

EU GDPR PRIVACY NOTICE

Treasure Island, LLC (TI, we, us) believes it is important that you understand how TI collects, stores, shares and uses information from and about our website visitors, customers and vendors. This Privacy Notice (Notice) and our cookie policy describe our collection, use and disclosure of personal and non-personal data collected through this website or in the course of our business activities conducted elsewhere, such as the Treasure Island Hotel and Casino, when we act as the controller of that data and when its processing is governed by the EU General Data Protection Regulation (GDPR).  This Notice does not apply to the information collected, stored, shared, or distributed by third-party sites.  This Notice may be updated from time to time.

For the purposes of GDPR, TI 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 Disclosure of Personal Data Data Security Your Rights
Information We Collect Automatically Minors Retention of Your Personal Data Contact Us
Why We Use Personal Data Direct Marketing External Links  

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 (e.g. Ivy) 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 enquiries 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.

Cookies

This website uses cookies to learn what is most relevant to you and ensure you have a personalized experience.  We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using.  Cookies allow us to collect data such as browser type, pages visited, referring URL, and other aggregated traffic data.  We use the data to facilitate navigation, to display data more effectively, to collect statistical data, and to personalize your experience.  We also use cookies to track responses to online advertisements and marketing emails.  You can choose whether to accept cookies by changing the settings on your browser.  If you do not accept cookies, you may experience some performance issues with our website, and/or you may not receive advertising or other offers from us that are relevant to your interests. You will find more details on how to manage cookies here.

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 fulfil 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 TI'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 TI'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, TI confidential and proprietary information, and TI 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.

TI 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 TI 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. TI may share your personal data with these affiliates and third parties to perform services that the third parties have been engaged by TI to perform on TI'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 TI 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 TI 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@treasureisland.com.

TI reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.

Minors

This website is not intended for use by children under the age of 18 or 21 years depending on the functionalities used and TI 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 TI and TI will delete all such personal data.

Direct Marketing

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.  Where we do not use electronic media or where we rely on soft-opt in exemption under applicable law, for the purposes of GDPR, 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 TI-General@treasureisland.com

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'.

Security

TI aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and TI 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 TI 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.

External Links

This website may contain links to third party sites.  Since TI 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.

Your Rights

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 TI-General@treasureisland.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 ITmanagers@treasureisland.com if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.

Contact

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 TI-General@treasureisland.com.

Last Modified: May 24, 2018

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