PRIVACY POLICY

Effective Date: January 25, 2021

Last Reviewed: April 2, 2021

We appreciate your visit to our website or our mobile app. We are the Fantasy Springs Resort Casino, a wholly-owned instrumentality of the Cabazon Band of Mission Indians (“FSRC”, “CBMI”, “we”, “us” or “our”). We respect the privacy of our visitors, users, customers, and members (also occasionally referred to as “you” or “your”).

As FSRC is a tribally-owned and operated business, it is not subject to certain state law, but in the interest of protecting its visitors, users, customers, and members, FSRC is committed to protecting your privacy through its efforts to comply with the principles described in this Fantasy Springs Privacy Notice (“Notice”) that align with the California Consumer Privacy Act of 2018 (CCPA). Our efforts to protect your privacy will evolve as laws and best practices continue to take shape.  Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop and update our compliance program.

In the event of a conflict between any other FSRC policy, statement or notice and this Notice, this Notice will prevail as to the statement of our practices and the rights we afford you.  Please also refer to any general privacy policy or notice posted or referenced on our websites, apps, products, or services including, without limitation, https://www.fantasyspringsresort.com/, or as otherwise relate to our products or services (e.g., Entertainment, Hotel, Dining, Casino, and Shopping).

This Notice covers our collection, use, disclosure, and sale of Consumers’ personal information (“PI”) (defined below). Our practices may change at any time. However, if any changes made are materially different from this Notice we will provide pre-collection notice of the current practices, which may include reference to our general privacy policy or other applicable privacy notices, which will reflect current practices. By PI, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

This Policy does not apply to workforce-related Personal Information collected from employees, job applicants, contractors or similar individuals (“Personnel”), or subjects of certain business-to-business communications acting solely in their capacity as representatives of another business. FSRC Personnel may obtain a separate privacy notice that is applicable to them by contacting our Human Resources department.

Terms in this Notice not otherwise defined shall have the same meaning as in the CCPA.

Table of Contents

PI We Collect

(A) Sources of PI

(B) Use of PI

2. Sharing of PI

(A) Disclosures

(B) Sales

3. Privacy Rights

(A) The Right to Know

i. Information Rights

ii. Obtaining Copies of PI

(B) Do Not Sell

(C) Delete

(D) Non-Discrimination and Financial Incentive Programs

(E) Authorized Agents

(F) Limitation of Rights

4. Additional Notices

(A) Third Party Marketing and Your Privacy Rights

Tracking and Targeting

5. Contact Us

  1. PI We Collect

We have collected the following types of PI about Consumers within the last twelve (12) months, and use and share it as set forth below.

Category of PI Examples of PI Sources of PI Business or Commercial Purposes for PI Collection

1.   Identifiers

 

This may include but is not limited to: a real name, postal address, phone, email address, account number, social security number, driver license number, passport number, or other similar identifiers. Players Club, Credit Application, Website Form(s), Tickets.com, OPERA, ClubProphets, OpenTable, Podium, Cyrun Identification, verification, Processing interactions and transactions, Managing interactions and transactions, Performing services, Research and development, Quality assurance, Debugging, and to provide other regulated services (e.g., Security, Gaming services, Financial services)

2.   Personal Information in California Customer Records Statute

 

This may include information such as: Telephone Number, Employment, Bank Account number. Players Club, Credit Application, Podium Processing interactions and transactions, Managing interactions and transactions, Performing services, Quality assurance, to provide regulated services (e.g., Security, Gaming services, Financial services)
3.   Protected Classification or Characteristics This may include, but is not limited to: sex, nationality, veteran status.

Players Club

 

Marketing, to provide regulated services (e.g., Security, Gaming services, Financial services)

4.   Customer Account Details / Commercial Information

 

This may include, but is not limited to: records of products purchased, obtained, or consumed, or gaming histories, or tendencies.

Players Club,

Security, Credit Application Form

 

Processing interactions and transactions, Managing interactions and transactions, Performing services, Research and development, Marketing , to provide regulated services (e.g., Security, Gaming services, Financial services)
5.   Internet or other similar network activity This may include, but is not limited to: browsing history, search history, and information regarding your interaction with an Internet Web site, application, emails or advertisement. Website, Email Marketing, App (Bally’s), Google Ads, Facebook, Bing, Spectrum Managing interactions and transactions, Performing services, Research and development, Quality assurance

6.   Geolocation Data

 

This may include, but is not limited to: City, State, Zip code, Country. Social Media Contest (ToneDen), Email Marketing , App (Scientific Games), Google Ads, Facebook, Bing, Spectrum Performing services, Research and development, Marketing

7.   Professional or Employment Information

 

This may include, but is not limited to: professional, educational, or employment-related information. Credit Application, Credit Companies, other Casinos Required for FinCEN, Processing interactions and transactions Managing interactions and transactions Performing services , to provide regulated services (e.g., Security, Gaming services, Financial services)

8.   Inferences from PI Collected

 

This may include, but is not limited to: creating a profile about a Consumer reflecting the Consumer’s preferences, characteristics, Music Interests, Dining Preferences, Sports, Location Data Players Club Performing services, Research and development, Marketing

We do not treat, de-identified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.

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A. Sources of PI

We primarily collect your PI directly from you, for example when you give it to us, or indirectly from you, for example by observing your interactions with our products, services, or website. We may also collect information about you from third parties, including reservation services, credit reporting agencies, government entities, or from service providers.

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B. Use of PI

Generally, we collect, retain, use and share your PI to provide you services and as otherwise related to the operation of our business. For more specific detail on our collection of PI, see the chart above at PI We Collect. For more detail on our sharing of PI, see the next section, Sharing of PI.

As more fully detailed in the chart above, we or our vendors may collect, use and share the PI we collect for one or more of the following business purposes:

  • Processing interactions, transactions, and requests;
  • To comply with legal obligations governing gaming, banking, and security;
  • Managing interactions and transactions;
  • To fulfill or meet the reason you provided the information, including to provide you with services;
  • To prevent fraud;
  • To respond to law enforcement requests as required by applicable law, court order, or governmental regulations;
  • Research and Development;
  • Quality assurance;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • And as described to you when collecting your PI;

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2. Sharing of PI

We may share PI with our service providers, other vendors (including those that facilitate interest-based and other advertising and marketing), affiliates, including without limitation as follows:

A. Disclosures:

We may share your PI (as described above in PI We Collect) with our service providers for the same business purposes for which we collect such PI as described above in Use of PI, including [in the current calendar year] as follows:

Category of PI Business Purposes for Disclosures, if Applicable Categories of Recipients of Business Purpose Disclosure, if Applicable

1.   Identifiers

 

Identification, verification, Processing interactions and transactions Managing interactions and transactions, Performing services, Research and development, Quality Service Providers including marketing companies, printers, reservation services and referral services

2.   Personal Records

 

Processing interactions and transactions, Managing interactions and transactions, Performing services, Quality assurance Service Providers, including marketing companies, printers, reservation services and referral services

3.   Personal Characteristics or Traits

 

Marketing Service Providers, including marketing companies, printers, reservation services and referral services

4.   Customer Account Details / Commercial Information

 

Processing interactions and transactions Managing interactions and transactions Performing services Research and development Service Providers, including

5.   Internet Usage Information

 

Managing interactions and transactions, Performing services, Research and development, Quality assurance Service Providers, including Marketing companies

6.   Geolocation Data

 

Performing services, Research and development NA

7.   Professional or Employment Information

 

Required for FinCEN, Processing interactions and transactions Managing interactions and transactions Performing services Security NA

8.   Inferences from PI Collected

 

Performing services, Research and development Service Providers, including marketing companies

We restrict to business purposes use of your PI that is shared with our service providers, unless otherwise permitted by the CCPA.

B. Sales:

We do not sell PI and in the preceding twelve (12) months, we have not sold any PI.

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3. EXERCISING YOUR PRIVACY RIGHTS

We provide Consumers the privacy rights described in section 4 here. Your request may be subject to a verification process (“Verifiable Consumer Request”). To exercise your rights to know or delete as described below, please submit a request by either:

Following the instructions at our Consumer Rights Request page here

Calling us at 1-800-827-2946.

Emailing us at [email protected].

Asking a manager at the Fantasy Rewards Club desk.

If we cannot comply with a request, we will explain the reasons in our response.You are not required to create an account with us to make a Verifiable Consumer Request, but for your security, we require Player’s Club account holders to submit a request through their account. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.

We do not charge a fee to process or respond to your Verifiable Consumer Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

4. YOUR PRIVACY RIGHTS

A. Right to Know and Data Portability:

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve (12) months prior to the request date:

  • The categories of PI we have collected about you.
  • The categories of sources from which we collected your PI.
  • The business or commercial purposes for our collecting or selling your PI.
  • The categories of third parties with whom we have shared your PI.
  • The specific pieces of PI we have collected about you (also called a data portability request).
  • A list of the categories of PI disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of PI sold about you in the prior 12 months, or that no sale occurred. If we sold your PI, we will explain:
    o The categories of your PI we have sold.
    o The categories of third parties to which we sold PI, by categories of PI sold for each third party.

B. Right to Delete:

You have the right to request that we delete any of your PI that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

    1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    3. Debug products to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
    7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
    8. Comply with a legal obligation.
    9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

C. Non-Discrimination and Financial Incentive Programs:

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data to FSRC. In addition, we may offer you financial incentives for the collection and retention and use of your PI that can, without limitation, result in reasonably different prices, rates, or quality levels. Our Rewards program gives you access to promotions discounts, and possibly VIP privileges. Click here for more information. Please note that participating in incentive programs is entirely optional. You will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above.

D. Authorized Agents:

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your PI.

5. ADDITIONAL NOTICES

A. Cookies and DNT Signals:

You can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices.  In addition, third-party tools may enable you to search for and opt-out of some of these trackers, such as the Ghostery browser plug-in available at https://www.ghostery.com/.

Further, you can learn more about your choices regarding certain kinds of online interest-based advertising here.  We do not represent that these third-party tools, programs or statements are complete or accurate, clearing cookies or changing settings may affect your choices and you may have to opt-out separately via each browser and other device you use.

Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to indicate a do not sell expression by you so we currently do not recognize these as a do not sell request.  We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.

6. Contact Us

If you have any questions or comments about this Notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under this policy, please contact us at:

Email us at [email protected]

Call us at 1-800-827-2946, or

Write to us at: 84-245 Indio Springs Parkway, Indio, CA 92203.

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If you need to access this Notice in an alternative format due to having a disability, please contact [email protected] and 1-800-827-2946.

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