CIRCA | SPORTS™ PRIVACY POLICY

Last modified: October 1, 2019

Introduction

Golden Gate Casino, LLC, a Nevada limited liability company doing business as the Golden Gate Hotel & Casino (“Company” or “We”), respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes: (a) the types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the Circa | Sports™ mobile application (the “App”); and (b) our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we (or our authorized representatives) collect in this App and in email, text, and other electronic communications sent through or in connection with this App. This policy DOES NOT apply to information that: (a) we (or our authorized representatives) collect offline or on any other Company apps or websites, including websites you may access through this App; or (b) you provide to or is collected by any third party. Our websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time. Your continued use of this App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Persons Under the Age of 21

YOU MUST BE 21 YEARS OF AGE OR OLDER TO DOWNLOAD, REGISTER WITH OR USE THE APP. We do not knowingly collect personal information from persons under 21. If we learn we have collected or received personal information from a person under 21, we will delete that information.

Information We Collect and How We Collect It

We collect information from and about users of our App directly from you when you provide it to us (or our authorized representatives) and automatically when you use the App.

Information You Provide to Us (or our Authorized Representatives)

When you download, register with, or use this App, we (or our authorized representatives) may ask you to provide information: (a) by which you may be personally identified, such as name, postal address, email address, telephone number, or any other information the App collects that is defined as personal or personally identifiable information under an applicable law (“personal information”); and (b) that is about you but individually does not identify you.

This information includes:

• Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App and posting material. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the App and of the fulfillment of same. You may be required to provide financial information before using some or all of the App.
• Your search queries on the App.

You may provide information to be published or displayed (“Posted”) on public areas of the App and/or websites you access through the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking

When you download, access, and use the App, it may use technology to collect:

• Usage Details. When you access and use the App, we may collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
• Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location Information. This App may collect real-time information about the location of your device and other location and access characteristics.

If you do not want us to collect this information, do not download the App or delete it from your device. We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include, without limitation:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or its content, certain third parties may use information collection technologies to collect information about you or your device. These third parties may include advertisers, ad networks, ad servers, analytics companies, your mobile device manufacturer, your mobile service provider and others. These third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we (or our authorized representatives) collect about you or that you provide to us (or our authorized representatives), including any personal information, to:

• Provide you with the App and its contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
• Confirm that you are accessing the App from an approved location.
• Comply with any court order, law, or legal process, including to respond to any government or regulatory request.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the App.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. We may use the information we collect to display advertisements to our advertisers’ target audiences.

In addition to the above, you hereby understand, agree and consent to the collection of any and all information required to be collected, or that may be collected, by us (or our authorized representatives) in accordance with the Nevada Gaming Laws (as defined below), our house rules, our procedures, the Bank Secrecy Act, FinCEN requirements, and/or other applicable laws, which information may include, without limitation, your identity, personal information, geographic location, wagers, wagering history, tax identification number(s), financial information, wagering patterns and/or App access (regardless of whether any wager is actually placed) (collectively, “Patron Data“). You hereby consent to, and release us and our related persons and entities from all claims, liabilities and damages relating to (and covenant not to sue us or our related persons or entities in relation to), the disclosure at any time, and from time to time, of Patron Data without notice to you to the Nevada Gaming Authorities (as defined below), financial institutions, state and federal law enforcement agencies (including, without limitation, FinCEN), the Internal Revenue Service, wagering service providers, wagering integrity service providers, and/or other third parties as may be necessary or appropriate, as determined in our sole discretion, for us to perform our compliance functions. For purposes of this policy, “Nevada Gaming Laws” means all laws pursuant to which any Nevada Gaming Authority possesses regulatory, licensing or permit authority over gaming within the State of Nevada, including, without limitation, the Nevada Gaming Control Act, as codified in Chapter 463 of the Nevada Revised Statues, as amended from time to time, and the regulations of the Nevada Gaming Commission promulgated thereunder, as amended from time to time; and “Nevada Gaming Authorities” means the Nevada Gaming Commission, the Nevada Gaming Control Board and all other state and local regulatory and licensing bodies with authority over gaming in the State of Nevada and its political subdivisions.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we (or our authorized representatives) collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our App users is among the assets transferred.
• To third parties to market their products or services to you.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent or otherwise consistent with this policy.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the App Terms of Service, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us and our authorized representatives. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
• Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the App may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

In addition, California residents and certain residents of other states may have additional personal information rights and choices. Please see Other Privacy Rights Based on Residency for more information.

Accessing and Correcting Your Personal Information

You can review and change your personal information by logging into the App and visiting your account profile page. You may also send us an email at compliance@circaports.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users.

Other Privacy Rights Based on Residency

If you are a California resident or a resident of another state with specific data privacy laws, applicable law may provide you with additional rights regarding our use of your personal information. To learn more about California privacy rights, visit www.goldengatecasino.com/CAprivacy-policy.

In addition, California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us a notice in writing to compliance@circasports.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at compliance@circaports.com

In addition, to exercise any opt-out, access, data portability or deletion rights under applicable law, please submit a verifiable consumer request in writing to us at compliance@circasports.com.