Privacy Policy BetMGM.com – Indiana Online Gaming services

Last Updated September 1, 2022

This privacy policy (“Policy”) describes how BetMGM, LLC and its applicable affiliates and subsidiaries (collectively, “BetMGM”, “we,” “our” or “us”) collect, use, protect and share personal information we collect or receive in connection with your access and use of: (1) BetMGM-operated gaming websites and mobile gaming applications, including all features, functionalities, applications, browser extensions and other services available through them (collectively, our “Gaming Operations”); and (2) other websites that we operate, including, without limitation, our corporate website, located at www.betmgminc.com, and other websites or mobile applications we operate that provide a link directly to this Policy, including all features, functionalities, applications, browser and extensions and other services available through them (collectively, our “Corporate Websites” and, together with our Gaming Operations, our “Online Offerings”). This Policy also applies to any personal information we collect or receive in connection with any other interactions we have with you outside of our Online Offerings related to our business operations, such as when you contact us or use other services we provide (collectively, together with our Online Offerings, our “Services”).

You can access our Online Offerings in many ways, including from a computer or mobile device, and this Policy will apply regardless of the means of access. To the extent we provide you notice through our Online Offerings of different or additional privacy policies or practices (e.g., at the point of collection), those additional terms shall govern such data collection and use in addition to this Policy.

Please read this Policy carefully. If you do not want us to collect, use or disclose your personal information in the ways described in this Policy, please do not use our Services, provide us with your personal information, or authorize a third party to make your personal information available to us. By using our Services, providing us with your personal information or otherwise making your personal information available to us, you acknowledge that you understand that we may use your personal information as described in this Policy. Please note, as described in this Policy, we may receive your personal information from third parties who have not expressly advised you that they will disclose your personal information to us. If you have any questions about how we collect, use, protect, disclose or otherwise process personal information, including whether we have received your personal information from a third party, please contact us via e-mail at support.in@betmgm.com, or via our Customer Service portal.

Except as otherwise stated in this Policy, this Policy does not apply to the websites, online gaming services and other services operated, controlled or offered by MGM Resorts International (“MGM”). Furthermore, this Policy does not apply to our privacy practices with respect to our collection, use, storage, disclosure, and protection of personal data relating to our employees and job applicants.

I. GENERAL INFORMATION ABOUT OUR COLLECTION AND USE OF PERSONAL INFORMATION

When we refer to “personal information” in this Policy, we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, as used in this Policy, “personal information” does not include publicly available information from government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual.

Our primary goals in collecting personal information are to provide and improve our Online Offerings, to conduct our business operations, to provide our Services, to communicate with you, and to enable visitors to our Online Offerings to enjoy and easily navigate them. We also collect personal information in a variety of ways.

The categories of personal information we collect and use in connection with our Services may fall into one or more of the categories described below. Please note, the types of personal information provided as examples for each category are not a representation that we will actually collect that specific type of personal information about you.

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, e-mail address, account name, social security number, driver’s license number, passport number, or other similar identifiers;
  • Customer records, such as a name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Please note, for purposes of the California Consumer Privacy Act (“CCPA”), this category of personal information constitutes any personal information described in subdivision (e) of Cal. Civ. Code 1798.80.
  • Legally protected characteristics, such as race, religion, sexual orientation, gender identity, gender expression, and age. Please note, for purposes of the CCPA, this category of information constitutes characteristics of protected classifications under California or federal law.
  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
  • Geolocation data.
  • Audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information.
  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Depending on how you use our Services or otherwise interact with us, the following chart provides a general summary about the categories of personal information we may collect about consumers, the categories of sources from which the personal information is collected, our business or commercial purposes for collecting the personal information and the categories of third parties to whom we may disclose such personal information.

Sources of Personal Information

Categories of Personal Information Collected

Business or Commercial Purposes for Collecting Personal Information

Third Parties with Whom Personal Information May be Disclosed

Directly from individuals or otherwise generated directly by an individual’s use of the Services or other interactions with us

· Identifiers

· Customer records

· Legally protected characteristics

· Commercial information

· Biometric information

· Audio, electronic, visual, thermal, olfactory or similar information

· Inferences

· Provide the Services

· Assess and improve the Services

· Track usage of the Services

· Create and update customer profiles

· Determine eligibility for credit and offers

· Internal market research and analytics

· Provide notifications about promotions and special offers

· Generate statistical studies

· Ensure the security and safety of the Services

· Protect our rights and property

· Respond to inquiries

· Perform background checks

· Process financial transactions

· Predict preferences, interests and future gaming and spending activities

· Third-party service providers

· Third-party business partners

· Government agencies and related entities

· Credit reporting agencies

· Data analytics providers

Automatically through our Online Offerings (including through the use of cookies and other tracking technologies)

· Identifiers

· Internet or other electronic network activity information

· Geolocation data

· Inferences

· Provide the Services

· Assess and improve the Services

· Track usage of the Services

· Create and update customer profiles

· Internal market research and analytics

· Protect our rights and property

· Ensure the security and safety of the Services

· Detect security incidents

· Predict preferences, interests and future gaming and spending activities

· Third-party service providers

· Third-party business partners

· Government agencies and related entities

· Digital advertising providers

· Internet service providers

· Operating system and platform providers

From third-party service providers, third-party business partners and government agencies and related entities

· Identifiers

· Customer records

· Legally protected characteristics

· Commercial information

· Geolocation data

· Audio, electronic, visual, thermal, olfactory or similar information

· Inferences

· Provide the Services

· Assess and improve the Services

· Track usage of the Services

· Create and update customer profiles

· Internal market research and analytics

· Generate statistical studies

· Ensure the security and safety of our Services

· Protect our rights and property

· Respond to inquiries

· Perform background checks

· Process financial transactions

· Detect security incidents

· Predict preferences, interests and future gaming and spending activities

· Third-party service providers

· Third-party business partners

· Government agencies and related entities

· Credit reporting agencies

· Data analytics providers

· Digital advertising providers

II. INFORMATION WE COLLECT

In addition to the general information provided above, this section describes specific personal information collection and use activities related to certain portions of the Services.

A. Information You Provide. In order to access and use our Gaming Operations, you must register for an online wagering account (a “Wagering Account”). When you register for a Wagering Account, we will access and collect the personal information you provide (including your name, postal address, e-mail address, and date of birth). We may also ask you for additional information, including your mobile phone number, Social Security number, and a government-issued photo identification such as your driver’s license, state identification card, or passport.

We will also verify whether you have a current MGM Rewards account. If you do not have a current MGM Rewards Account, you will be required to create an MGM Rewards Account as part of the registration process. You can learn more about the MGM Rewards program by visiting https://mgmresorts.com. You can review the terms and conditions for the MGM Rewards program here and MGM’s privacy practices with respect to the MGM Rewards program here. For more information about how BetMGM and MGM utilize and share information in connection with your Wagering Account and MGM Rewards Account, please see Section III.B below. 

When you access, participate in, or otherwise interact with our Services, or otherwise engage with us in connection with our Services, such as requesting more information about our Services or communicating with us, we may ask you to provide us with additional personal information. Please note, if you do not provide us with personal information that is required for a particular feature of our Services, such as information we are legally required to collect when you register for a Wagering Account, you may not be able to access, participate in, or otherwise use certain portions of our Services.

B. Location, Gaming, and Transaction Information. When you use the Services, we and our third-party service providers may collect information about your precise physical location, your gaming activity, and all transactions associated with your Account. 

C. Device Information. When you use the Services, we and our third-party service providers may use cookies (see below), web beacons, tracking pixels, scripts, e-tags, and other technologies (“Tracking Technologies”) to collect and analyze information about you, your device, and your activity. Information collected through Tracking Technologies may include the type of device; browser and operating system you are using; your device identifiers, such as your MAC address; the name you have associated with your device; the unique number associated with your Internet connection; your (mobile) telephone number; the websites you visit; your precise geographic location; and your activities within the Services including the links you click, the pages or screens you view, the bandwidth you use, your session time, the number of times you click a page/screen or use a feature of the Services, the date and time you click on a page or use a feature, and the amount of time you spend on a page or using a feature. Information collected through Tracking Technologies is stored in log files. Please note, we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

D. CookiesWe may use cookies to store some information on your computer, laptop, tablet or mobile device when you access and use the Services. Cookies are small text files that are stored on your computer or equipment when you visit certain online pages and record your preferences. Cookies allow us to remember things about your visits across the Services, but cannot access or use other information on your device. We do not use flash cookies to remember or use directly identifying personal information about you such as your name or e-mail address. We use cookies to track use of the Services. We also may use cookies and third-party cookies to monitor traffic to the Services, improve the Services, and make it easier and/or more relevant for your use.

Most web browsers automatically accept cookies, but, if you prefer, you can usually modify your browser setting to decline cookies. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also modify your Flash Player settings to prevent the use of flash cookies. 

If you choose to decline cookies, you may not be able to experience all of the interactive features available through the Services. You can visit www.allaboutcookies.org in order to obtain more information on deleting or controlling cookies. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the Services.

E. Wi-Fi and Location Information. There are federal law prohibitions and restrictions relating to wagering on the Internet (including such prohibitions and restrictions set out in 18 U.S.C. §§ 1084 et seq. (“The Wire Act”) and 31 U.S.C. §§ 3163 through 3167 (“UIEGA”)). Each of our Gaming Operations is offered for a specific state or other jurisdiction. It is a federal offense for persons physically located outside of the state or other jurisdiction in which a specific Gaming Operation is offered to engage in any Internet wagering activity through such Gaming Operation. We and our service providers utilize several current technologies, and may use future technologies, that enable us and our service providers to determine the location of devices that engage, or attempt to engage, in any wagering activity through or in connection with our Gaming Operations (collectively, “Location Tracking Technologies”) in order to: (i) verify your physical location when you engage, or attempt to engage, in any wagering through or in connection with a specific Gaming Operation; and (ii) improve the location-based services utilized by our Services. Without limiting anything else in this Policy, the Location Tracking Technologies are capable of identifying the precise or near-precise physical location of the computers or Internet-connected devices that engage, or attempt to engage, in any wagering activities through or in connection with our Gaming Operations by accessing the device’s IP address, MAC address, RFID, hardware embedded article/production number, embedded software number (such as UUID, Exif/IPTC/XMP or modern steganography), Wi-Fi positioning system, or device GPS coordinates (collectively, “Location Information”). Without limiting anything else in this Policy, the Location Tracking Technologies will report the Location Information for each any every device you use to engage, or attempt to engage, in any wagering activities through or in connection with our Gaming Operations to us, our service providers and/or regulatory bodies and other applicable government agencies and related entities to ensure you are located in the applicable state or other jurisdiction for the applicable Gaming Operation.

The normal operation of the Location Tracking Technologies and our Gaming Operations transmit Location Information via Secure Socket Layer (SSL) technology and Location Information is stored in password protected servers managed by us and our geolocation and operating partners. Neither us nor our partners will disclose, transfer or resell your Location Information to any additional third parties except:

  • where required by law, including, without limitation, as necessary to satisfy any law, regulation or government agency request;
  • as necessary or appropriate to investigate, respond to and defend against legal claims, including, without limitation, to protect us against liability;
  • to protect our property and rights;
  • for the safety of the public or any person;
  • to stop any illegal, unethical, fraudulent, abusive or legally actionable activity;
  • to protect the security and integrity of our Gaming Operations and any equipment used to make our Gaming Operations available; or
  • in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets.

You may opt-out of, or otherwise withdraw your consent to, our use of the Location Tracking Technologies to collect and report Location Information at any time by turning off the location settings on your applicable devices or by notifying us in writing that you would like to opt-out or otherwise withdraw your consent. If you turn off the location settings or opt-out or otherwise withdraw your consent, you will not be able to place any Internet wagers or access real money games and tournaments via the applicable Gaming Operations.

Location Information is retained for up to ten (10) years as required by applicable regulatory bodies and other government agencies and related entities, as well as state and federal regulations.

F. Affiliate and Third-Party Information. We may obtain information about you from MGM Resorts International and casinos, resorts, platforms, and properties that are owned, operated, managed by or affiliated with MGM Resorts International (collectively “MGM Affiliates”), from our other parent and affiliated companies, including, but not limited to, Entain plc (collectively, with the MGM Affiliates, our “Affiliates”) and from third parties, including our business partners and other companies and individuals that refer you to our Services. This information may include, among other things, information related to your MGM Rewards Account that we need to make the Services available to you, information to set up your Wagering Account and information necessary to connect your Wagering Account to your account with one or more of our business partners.

III. HOW WE USE THE INFORMATION WE COLLECT AND OPT-OUT OPTIONS

A. Use by BetMGM

Marketing Purposes. We may use the information we collect for our own marketing purposes, including notifying you of special promotions, offers, and events via push notifications, e-mail, and other means. We may also link personal information (including your name, mobile phone number, and e-mail address) with non-personal information (including information collected through Tracking Technologies and Wi-Fi services) and use such information for our own marketing purposes. If you do not want us to use your personal information for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.

Non-Marketing Purposes. We may use the information we collect for non-marketing purposes including:

  1. validating your identity;
  2. sending you push notifications or e-mails to provide you with alerts and updates about your Account and the Services;
  3. monitoring, accessing, and recording gaming-related activity;
  4. conducting statistical or demographic analysis;
  5. processing and tracking gaming and non-gaming transactions;
  6. complying with legal and regulatory requirements, including, without limitation, responding to subpoenas and search warrants;
  7. customizing your experience with the Services;
  8. protecting and defending BetMGM, MGM Resorts International, and all other MGM Affiliates against legal actions or claims;
  9. preventing fraud;
  10. debt collection;
  11. satisfying contractual obligations; and
  12. safety and security purposes, including cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest (collectively “Non-Marketing Purposes”). 

Automated Text Messages. Without limiting the other purposes described herein, if you have provided us with your express consent to receive communications via an automatic telephone system (auto-dialer), artificial or prerecorded voice messages or text messages, in accordance with our Texting Program Terms and Conditions, we may use your information to send text messages to any mobile device connected to your cell phone number until you opt out from future text messages by replying STOP to any text messages you receive from us. Once you cancel, we will send one additional confirmation text message stating that you have opted out of receiving automated text messages from us.

B. Sharing with Affiliates 

We may share the information we collect with Affiliates for marketing purposes and for Non-Marketing Purposes. If you do not want us to share your personal information with Affiliates for marketing purposes, you may opt-out in accordance with the “How to Opt-Out” section below.

Regarding sharing of information with MGM about your MGM Rewards Account, we will provide MGM with certain information (subject to compliance with applicable laws and with your consent where required) related to your gaming activity that is necessary for MGM to administer your MGM Rewards Account, including, but not limited to: (1) the amount of money credited to, debited from or present in your Wagering Account; (2) the amount of money you wagered on any game or gaming device; (3) your Wagering Account number and secure personal identification method that identifies you; (4) the identities of particular entities on which you are wagering or have wagered on in the past; and (5) your name, address or other information that BetMGM possesses that would identify you to anyone other than BetMGM or applicable gaming regulators (“Account Information”). The Account Information we will provide to MGM represents the information MGM needs to provide you with certain benefits and rewards as more fully described in the terms applicable to your MGM Rewards Account. For opt-out information specific to your MGM Rewards Account and its connection with your Wagering Account, please see the “How to Opt-Out” section below.

C. Sharing with Business Partners and Other Third Parties

We may share the information we collect with our business partners and other third parties for joint marketing purposes and/or our business partners’ (or our own) marketing purposes. Even if you opt-out of permitting us to share your personal information with our business partners and other third parties for marketing purposes, we may still share the information we collect with them for Non-Marketing purposes such as processing transactions, fulfilling your requests, responding to your inquiries, etc.

One of our business partners is Yahoo Sports. We may (now or in the future) provide certain integrations between our Services and the services provided by Yahoo Sports. If you are referred to our Services by or through Yahoo Sports, we will provide Yahoo Sports with certain information (subject to compliance with applicable laws and with your consent where required) related to your gaming history for Yahoo Sports’ business purposes, which can include, but is not necessarily limited to, Yahoo Sports’ marketing purposes. You can review Yahoo’s privacy policy here. Additional information about Yahoo’s practices related to Yahoo Sports are provided in Yahoo’s Media Policy, available here.

D. Service Providers

We may engage service providers to provide certain services to us or to perform certain services on our behalf including analytics, marketing, fulfillment, etc. In some cases, service providers may collect or be provided with access to your information as reasonably necessary to perform such services on the condition that they not use or disclose your personal information for other purposes.

E. Certain Business Transactions

We may share all information we collect with any successor to all or part of our business in connection with a transaction involving a sale, purchase, reorganization, merger, or transfer of any our assets or the assets of Affiliates.

F. How to Opt Out of Marketing from Us and How to Opt-Out of having Your Personal Information Shared with Others for Marketing Purposes

If you wish to opt-out of receiving marketing communications from us via postal mail, e-mail, telephone, and text messaging, or do not want us to share your personal information for marketing purposes with our business partners, third parties or Affiliates, please e-mail us at optout@betmgm.com or write to us at:

BetMGM

Attn: Privacy Policy

Harborside Plaza 3, Suite 602

210 Hudson Street

Jersey City, NJ 07311

You can also unsubscribe from receiving SMS messages as described in Section III.A above, including by replying STOP to any text message you receive from BetMGM.

Although you may opt-out of the use and sharing of personal information for marketing purposes, we may still use and share information we collect for Non-Marketing Purposes.

Please note, if you would like to submit a request to opt-out from marketing relating to your MGM Rewards Account, please submit your request to MGM via e-mail to optout@mgmresorts.com; via telephone at 866-761-7111; or via postal mail, with your specific request(s), to:

MGM Resorts International

Corporate Compliance Department

Attn: Opt-Out

71 E. Harmon

Las Vegas, Nevada 89109

G. Your Consent or Instructions

We will share your personal information with any third party to whom you consent or instruct us to provide your personal information.

H. No Additional Disclosures

We will not share the information we collect with third parties, other than as described in this Policy. Any information that we collect that we do not disclose to third parties as described in this Policy will be kept confidential, except where the release of that information is required by law.

IV. STATE SPECIFIC RIGHTS

This section describes the rights certain states provide residents of those states with respect to their personal information. Please note, if you are not a resident of any state described below, the rights described for such states do not apply to you.

A. Nevada. If you are a Nevada resident, Nevada law gives consumers in Nevada the right to restrict certain businesses from selling certain personal information to unaffiliated third parties if those third parties will license or sell such personal information to additional third parties. To exercise this right (for Nevada residents only), please click here, follow the instructions and provide the requested information, including your complete name, street address, city, state, zip code, and e-mail address.

B. California.

California’s Shine the Light Law. Under California’s Shine the Light law, certain businesses are required to respond to requests from California residents asking about the disclosure of personal information to third parties for third-party marketing purposes. Alternately, such businesses may adopt a policy of not disclosing personal information to third parties for marketing purposes if a California resident has opted-out of such information sharing. We have adopted an opt-out policy. If you wish to opt-out of our sharing your personal information with third parties for marketing purposes, please follow the instructions in Section III.F above. 

California Consumer Privacy Act. The California Consumer Privacy Act of 2018 as amended and including any regulations adopted by the California Attorney General (collectively, “CCPA”) grants certain privacy rights to California consumers, including the right to: (A) know what categories of personal information we have collected about California consumers during the preceding 12 months, including the categories of sources from which that information was collected, the business or commercial purpose for which it was collected, and the categories of third parties with whom the information was shared (see Section I above); (B) request to know what personal information we have collected, used, disclosed, and sold about you during the preceding 12 months (see Section IV.B.1 below); (C) request that we deleteyour personal information (see Section IV.B.2. below); and (D) opt-out of the sale of your personal information to third parties (see Section IV.B.3 below). These rights, which are discussed more fully below, are subject to some important exceptions, which are intended, among other things, to protect the integrity and privacy of your personal information. You have the right not to be discriminated against for exercising your CCPA rights. You also have the right to designate an authorized agent to exercise your CCPA rights on your behalf.

If you need information on how to exercise your CCPA rights in an alternative, accessible format due to a disability, please send an e-mail with your name and contact information to support.in@betmgm.com, or contact us via our Customer Service portal.

1. Requests To Know About Your Personal Information

You have the right to request that we disclose to you, for the 12-month period preceding the date we receive your request, the following: (1) the categories of personal information we have collected about you, (2) the categories of sources from which personal information was collected about you, (3) the business or commercial purpose for which your personal information was collected or sold, and (4) the categories of third parties to whom we have sold or disclosed your personal information. In addition, you have the right to request that we disclose to you the specific pieces of personal information we have about you. If you are a California resident, and wish to request this information, please click here or call 1-844-604-4423 and indicate that you wish to request this information and provide the identifying information requested. All requests are subject to verification of your identity to protect the privacy and security of your personal information. We are required to fulfill these requests no more than twice within a 12-month period.

2. Requests To Delete Your Personal Information

You have the right to request that we delete your personal information, subject to certain exceptions such as our need to comply with legal obligations, fulfill orders, complete transactions, etc. If you are a California resident, and wish to request deletion of your personal information, please click here or call 1-844-604-4423 and indicate that you wish to delete your personal information and provide the identifying information requested. All deletion requests are subject to verification of your identity.  If we verify your request and delete your personal information pursuant to the request, we will also instruct our service providers (if any) to delete your personal information from their records, subject to applicable legal requirements. 

3. Requests To Opt-Out of Sale Of Your Personal Information

You have the right to opt-out of having your personal information sold to third parties. In the past twelve (12) months, BetMGM has not sold any personal information to third parties with respect to the Services or any Wagering Account. If we decide to sell personal information in the future, we will update this Policy and the Services to make those rights available to you. Even though we do not currently sell any personal information, if you are a California resident and wish to opt-out of any future sale of your personal information to third parties, please click here or call 1-844-604-4423 and indicate that you wish to opt-out of any future sale of your personal information to third parties and provide your identifying information as requested. Please note that even if you opt-out of the future sale of your personal information, we may still: (1) share your personal information with service providers and other entities for business purposes consistent with the CCPA, and (2) share your personal information in connection with certain business transactions consistent with Section II above.

4. Verification Procedures

In order to verify requests made pursuant to the CCPA, we may require two (2) or more pieces of identifying information that match information maintained by us or, if you have a Wagering Account, to verify your identity through your Wagering Account. In some cases, we may require additional identifying information and a signed declaration attesting to your identity. In situations where we receive a request from an authorized agent on your behalf, we may require written proof that the agent is, in fact, authorized to act on your behalf and we may take additional steps to verify your identity and the authorized agent’s identity. A request to opt-out pursuant to Section IV.B.3 above need not be verified. However, if we have a good-faith, reasonable basis to believe that an opt-out request is fraudulent, we may deny the request and provide an explanation of the reason for the denial.

In certain circumstances, we may decline a request to exercise the Right to Know (IV.B.1) or Right to Delete (IV.B.2) described above, particularly where we are unable to verify your identity. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

V. SECURITY

We store certain non-gaming information and non-live gaming data collected through the Services on secure servers located in the United States. Internet wagering and live game play data collected by us through the Services for a specific jurisdiction where our Gaming Operations are offered is stored on secure servers located within the jurisdiction for the applicable Gaming Operation and may, subject to applicable laws, also be stored in other jurisdictions where our Gaming Operations are offered. Our servers may not offer a level of privacy protection as great as that offered in other jurisdictions. We make no representation that the practices described in this Policy are compliant with laws outside of the United States.

Our servers are protected by firewalls and other industry standard security measures. These security measures are intended to protect our 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 of employment.

We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you may use 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 use will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of information that you send us before we receive it.

As a standard security practice, we will take reasonable steps which are generally recognized in the industry to ensure that the communication methods used to support the Services do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using the Services, 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.

In situations where your personal information is collected by third parties under contract with us for performance of their contractual duties and other purposes, we require such third parties to exercise reasonable care to protect that information and restrict the use of your personal information to the purposes for which it was provided. When we share your personal information with MGM Affiliates or third parties in accordance with this Policy, we require them to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which it was provided to them.

VI. ACCESS TO AND DELETION OF PERSONAL INFORMATION

With respect to personal information associated with your Wagering Account (“Wagering Account Personal Information”), we will retain such Wagering Account personal information as long as your Account is active. When your Wagering Account is terminated, we will retain applicable Wagering Account personal information for as long as necessary to comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements.  Once we determine that we no longer need to retain such Wagering Account Personal Information, pursuant to applicable law, all such Wagering Account Personal Information will be securely erased from hard disks, magnetic tapes, solid state memory, and other devices, as applicable, before the device is properly disposed of by us. If erasure is not possible, the device will be destroyed. 

Provided that we have not erased or otherwise destroyed your Wagering Account player information, you may access, update, and correct inaccuracies in your Wagering Account personal information that is in our custody and control. Your e-mail address and phone number may be updated by logging in to your Account on the BetMGM platform and making the applicable changes. All other personal information can only be updated by contacting BetMGM’s Customer Service department via e-mail at support.in@betMGM.com or by phone at 317-779-0242.

For all other personal information that we collect in connection with our Services, we will retain such personal information for as long as necessary to fulfill the purposes for which it was collected, comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements. Once we determine that we no longer need to retain such personal information, pursuant to applicable law, such personal information will be securely erased from hard disks, magnetic tapes, solid state memory, and other devices, as applicable, or we will aggregate, anonymize or otherwise de-identify such personal information so that it no longer identifies you.

VII. OTHER WEBSITES

We are not responsible for the information collection or privacy practices of other websites, including websites accessible through the Services. You should review and understand the privacy policies posted on any linked sites you visit before using those sites or providing any personal information on them.

VIII. INTERNATIONAL TRANSFERS

Information collected on the Services may be stored and processed in any country in which we or our affiliates, suppliers, third-party electronic payment processors and/or financial institutions or agents maintain facilities. By using the Services, you expressly consent to any transfer of information outside of your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.

IX. PERSONS UNDER 21

The Services are for use by persons 21 or older. If you are under 21, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of personal information via the Services from persons under 21.  

X. CHANGES TO THIS POLICY

We may revise this Policy from time to time in our sole discretion. We will notify you of any material revisions by sending you an e-mail and/or by placing notice of the revised Policy on the Services or any place through which you access the Services.