AFFINITY INTERACTIVE® (“AFFINITY INTERACTIVE”) PRIVACY POLICY

(Effective as of May 23, 2024)

Affinity Interactive, dba Affinity Gaming® (“Affinity Gaming”) or “we” “our” or “us”), takes your privacy very seriously. Please carefully read this Privacy Policy and familiarize yourself with our privacy practices regarding your personal information and how we will use it. This Privacy Policy applies to all websites associated with Affinity Gaming Corporate and the Affinity Gaming Properties, Affinity Gaming Websites or Affinity Gaming Mobile Apps listed below (collectively, the “Services”). Please see the U.S. State Privacy Rights section of this Privacy Policy for information about rights you may have pursuant to applicable privacy laws.  By visiting, using, accessing or providing information to Affinity Gaming, its websites, mobile apps and/or properties, you accept this Privacy Policy. If you do not agree with these policies, do not use Affinity Gaming Services.

Affinity Gaming has acquired Sports Information Group, LLC, who owns and operates the Daily Racing Form website, DRFBets website and DRF Sports website and app. Please see the privacy policies of those websites for information on their privacy practices as they will be different from Affinity Gaming’s Privacy Policy.

Affinity Gaming Properties
Primm Valley Resort & Casino
Whiskey Pete’s Hotel & Casino
Buffalo Bill’s Hotel & Casino
Silver Sevens Hotel & Casino
Mark Twain Casino
Lakeside Hotel Casino
St Jo Frontier Casino

Affinity Gaming Websites & Mobile Apps
PrimmValleyResorts.com
SilverSevensCasino.com
MarkTwainCasinoLaGrange.com
Lakesidehotelcasino.com
StJoFrontierCasino.com
APlayClub.com & A-Play Club App
AffinityGaming.com
Affinityinteractive.com

A-Play Online sites and apps are operated by Ruby Sevens, a separate business entity. Please visit https://www.aplayonline.com/privacy-policy/ for information about the privacy practices of Ruby Sevens.

I. NOTICE AT COLLECTION: INFORMATION WE COLLECT

We collect information during your visits to our Affinity Gaming Properties and when you use our Services. This information, which ranges from limited personal information such as age, email and mailing addresses to facts about your computer, profession and habits, is then securely stored on our servers.

Affinity Gaming may collect your personal information at various points throughout your visit to our Properties and when you use our Services. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by applicable law. The Personal Information that Affinity Gaming collects through Affinity Gaming Properties and our Services or obtains from its service providers depends on the nature of your activity, such as whether you make reservations, play games, plan a meeting, purchase show tickets or merchandise, or register online to receive promotional information. The Personal Information is collected by physical forms, email, through online forms, and through your activities at Affinity Gaming Properties and while using our Services.
Affinity Gaming may collect the following categories of Personal Information from you directly, or indirectly through service providers and third parties, depending on how you interact with us:

  • Identifiers and Contact Information, such as your name, job title, company name, address, email address, telephone number(s), fax number, government ID numbers (e.g., social security, driver’s license, state identification card, or passport number), date of birth, gender, and account login credentials (e.g., players club number and PIN number);
  • Payment or Financial Information such as credit card information and banking and personal credit information, purchase and reservation information;
  • Commercial Information, such as records of purchases, records of reward program participation including points accumulated and redeemed; dates, times and locations of purchases;
  • Gaming and Hotel Stay activity, such as hotel booking confirmation number and stay dates;
  • Precise geolocation information, including your precise GPS location when you access our Services, or when your Wi-Fi or Bluetooth-enabled device connects to, or is detected by, the wireless networks at certain properties (including when our app is closed or not in use);
  • Internet and Other Electronic Network Activity Information, such as your device and browser type, your device’s operating system, your geographic location based on IP address, your browsing and search history on our Services, and information regarding your interaction with our Services and our advertisements (e.g., how long you use our Services, which pages or content you view, and on which dates and times). On certain Services, we use tools to look at mouse movements, clicks, keystrokes, data or text entered, and the pages you visit. Among other uses, Affinity Gaming uses this Network Activity Information to generate aggregate statistics about visitors to the Services;Audio, Visual, or Similar Information, such as photographs and video tape of your image and recordings of your voice, as well as recordings of customer service interactions, files you attach, and email, text or other correspondence.

Some of the information described above may be considered “sensitive” under the laws of certain jurisdictions (including payment information, account login credentials, government ID numbers, and precise geolocation) (“Sensitive Information”). Whether information is Sensitive Information will depend on the laws of your jurisdiction.
We may combine information collected online with data we have collected about you offline, including through our loyalty and players club accounts, surveys, guest comments, and market research.

II. NOTICE AT COLLECTION: USES OF PERSONAL INFORMATION
We use your Identifiers, Contact Information, and Guest and Hotel Stay activity:

  • For marketing purposes, including, but not limited to, administering loyalty programs, notifying you of or administering special promotions or offers, including those that may be offered together with our third party partners;
  • To alert you to new projects, features, special events and services;
  • To conduct surveys to measure your satisfaction with our service;
  • To enforce our rights arising from any contracts entered into between you and us; and
  • To combine information we collect automatically about you with your Contact Information and other information we receive about you.

We use your Payment or Financial Information and Guest and Hotel Stay activity:

  • To enable us to process, validate and fulfilling purchases or reservations and making a record of reservations;
  • To determine your financial status if you apply for credit; and
  • To engage in debt collection

We use your Internet and Other Electronic Network Activity Information:

  • To monitor and evaluate our Services and identify where we should make changes or expand services;
  • To provide advertisers with information that does not directly identify you (e.g., aggregate information about our user base and usage patterns); and
  • To give our marketing and development staff information that’s useful for developing new features and services that meet user needs.

We use also use all categories of Personal Information:

  • To provide, maintain and improve our Services (including handling hotel reservations and bookings);
  • To protect our rights or property or our safety, our members, or others;
  • To comply with any court order, legal process, or respond to any governmental or regulatory request.

We use Sensitive Information for necessary or reasonably expected purposes – specifically, to provide you with services on our Services (i.e., to fulfill purchases, and allow account logins), comply with our legal obligations including relevant gaming regulatory requirements, and as authorized by law.

Additionally, we may receive, collect or use your precise geolocation information for advertising purposes and to look at your visits to various properties. You can manage access to precise geolocation information at any time in your device settings. The U.S. State Privacy Rights section, below, also has information about your choices for these practices.III. NOTICE AT COLLECTION: PERSONAL INFORMATION SOLD OR SHARED TO THIRD PARTIES IN THE PRECEDING 12 MONTHS

We sell or share the following Personal Information with third-party partners such as advertising networks, social networks, data brokers, agencies, other advertisers, and our affiliates which may not share common branding so that we and/or our third-party partners can deliver targeted ads and other tailored communications to you: Personal Identifiers; Commercial Information; Internet or other electronic activity information; and Inferences. 

If you would like to opt-out of the sale or sharing of any of the information described above, please submit an opt-out request via email at privacy@affinitygaming.com, or by contacting us at 702-341-2400.

IV. NOTICE AT COLLECTION: RETENTION PERIODS
We retain the categories of Personal Information we collect for the length of time necessary to provide our services and to comply with legal obligations or to protect our legal rights.

V. SOURCES OF PERSONAL INFORMATION

We collect and obtain Personal Information from:
You. We collect Personal Information that you voluntarily provide to us, for example when you communicate with us via email or other channels, when you sign up for or ask us to send you newsletters or other materials, and when you sign up for an event or make a reservation request or confirm a booking. We collect Contact Information when you provide us with identification at our properties.  We may also collect information from your devices if they connect to, or are detected by, the wireless networks at our Properties. We might also collect information about how you use our Wi-Fi network and other services, such as the websites you visit while using our Wi-Fi network. We may engage or otherwise permit other parties to also collect information in these ways. 

Third-Party Service Providers. We may use third-party service providers or other third-party organizations that may collect, store, or process your Personal Information on our behalf, such as to complete your request (e.g. completing a transaction or to outsource one or more of the functions described above). For example, we work with a vendor (Guestcentric Group) to help us collect information and handle hotel reservations and bookings.

Affiliates. We may get information about you from other companies that are a part of the Z Capital Group, LLC (“ZCG”) family of brands. 
Third-Party Advertisers. We work with companies that help us deliver, measure, and analyze the effectiveness of our ads. These companies collect information about you when you interact with ads on our platforms and on the websites where our ads are displayed.

VI. SHARING OF PERSONAL INFORMATION
We may use third-party service providers or other third-party organizations helping to support our mission that may collect, store, or process your Personal Information on our behalf. In addition, we may share your information with other third parties for the purposes outlined below. Specifically, we may share your information with:

  • Affiliates. Within the ZCG family of brands, including with our affiliate companies.
  • Service Providers. We may share each category of Personal Information with companies and individuals that provide services on our behalf or help us operate the our website or our business. For example, we share your Payment and Financial Information with third party service providers for purposes of processing your payment for products and services that you purchase and for making a reservation, check cashing services and to extend credit for gaming activities.
  • Third Parties who may use your Personal Information for their own independent purposes in accordance with their own privacy policies. For example, we share Personal Information with agencies, advertisers, our affiliates and other third parties who provide products/services that may be of interest to you or who serve ads. We work with third-party advertising networks, social networks, data brokers, and other companies to serve ads when you visit our Services. These companies may use information about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. These companies may also include third parties in whose products or services we believe you may be interested. These third parties may use the information for their own marketing purposes or the marketing purposes of others.
  • Third Party Analytics Companies that help us to monitor traffic on the Services, learn how users are navigating our Services, and help troubleshoot or improve the services we provide.
  • Marketing and Promotional Partners.  We may share your Identifiers and Contact Information with our third party promotional partners, for the purpose of administering in promotions in which you enroll.
  • Mail Houses.  We may share Identifiers and Contact Information with mail houses or printing services, for the purpose of sending you information or promotional offers.
  • Market Research Firms. We may contract with a market-research firm to conduct occasional online surveys.
  • Law enforcement or other governmental entities. If we receive a valid subpoena or other service of process, we may share the requested information, which could include your Identifiers and Contact Information, your Gaming and Hotel Stay Activity, your Payment and Financial Information, and/or Internet and Other Electronic Network Activity Information.
  • Successor Company or Companies. In the event that we are acquired by or acquire or merge with another company or companies, we may share your Identifiers and Contact Information and your Network Activity Information with the successor company or companies.

We may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

VII.  COOKIES AND OTHER TRACKING TECHNOLOGIES
Like most websites, our Services use small data files stored on your computer or mobile device called cookies. Cookies consist of two different types; session and persistent. Session cookies enable us to recognize your actions during the browsing session. Persistent cookies remain stored on your device after you close your browser until they expire or when you delete them.

Cookies and web beacons, typically a one-pixel image, used to pass information from your computer or mobile device to our Services, enable us to provide you with great customer service, improvements to our website design, product assortments and special promotions by:

  • keeping track of what you have in your shopping cart;
  • remembering you when you return to visit the Services;
  • identifying the pages you click on during your visit to the Services;
  • the name of the website you visited immediately before clicking onto our Services; and
  • helping track whether our communications are reaching you, measuring their effectiveness and allowing us to better design future communications.

We use this information to improve our Services, customer service, and special promotions. Certain of these cookies are strictly necessary to the access and operation of the Services and other cookies used are non-essential to the access and operation of the Services.

We may contract with third parties who may use cookies and web beacons and collect information on our behalf or provide services such as credit card processing, data management, or website troubleshooting and analytics.

We use third party retargeting and remarketing features on our Services. These technologies allow us to address internet users who previously visited our Services by delivering personalized advertising on our partners’ websites. For this purpose, the retargeting or remarketing provider will store a cookie on your hard drive. Based on the cookie technology, certain user details will be stored – for example, the advertising you received from us or clicked, the products you viewed, or whether you made a purchase.

Additionally, we also allow third parties to set cookies and other trackers when you visit our Services which may collect information about your online activities over time and across different websites, applications or other online platforms.  These third parties may use such information to, for example, provide analytics information or to offer products or services in which you may be interested, and they may combine information about your activities across different websites, applications or other online platforms to do so. You can opt out of tracking on our website or others for online behavioral advertising by visiting the DAA’s Consumer Choice page at http://www.aboutads.info/choices/.

We use also Google Analytics to evaluate the use of our Services. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy and its opt-out tool at https://tools.google.com/dlpage/gaoptout.

VII. UPDATING YOUR INFORMATION
If you believe that any information collected by Affinity Gaming about you is not correct or has changed, please send an email message to privacy@affinitygaming.com, explaining the correction or change and providing any relevant confirmation or reference number.

VIII. OTHER MARKETING COMMUNICATIONS
You can opt out of receiving our marketing emails and text messages. To stop receiving our marketing emails, you can follow the “unsubscribe” instructions in any marketing email message you get from us. Even if you opt out of getting marketing emails, we will still send you transactional messages. These include responses to your questions. You can opt out of our marketing text messages by replying “STOP”.
You can control certain location tracking tools. To control the collection of your precise location on your mobile device or browser, you can adjust your device or browser settings. You can disable location services, disable location access permissions, and turn off Bluetooth and Wi-Fi.

IX. U.S. STATE PRIVACY RIGHTS
You have the following rights, where provided under applicable state law, regarding your Personal Information (each of which are subject to various exceptions and limitations):

Right of Access. You have the right to access your personal information maintained by us. You can request categories of your personal information or specific pieces of your Personal Information. Upon receipt of a verifiable request to access personal information, we will disclose and deliver, free of charge, the Personal Information requested.

Please note that we are not required to provide you access to your Personal Information more than twice in a 12-month period.

Right of Correction. You have the right to request that we correct inaccurate Personal Information collected from you. We will accept, review, and consider any documentation that you provide in connection with your right to correct, provided you make a good-faith effort to provide us with all relevant information available at the time of the request.

Right of Deletion. You have the right to request that we delete any Personal Information about you which we have collected from you. Upon receipt of a verifiable request for deletion, and subject to the exceptions below, we will delete your Personal Information from our records and direct any service providers to delete your Personal Information from our records, within 45 days.
We will comply with your request to delete Personal Information unless it is necessary for us to maintain your personal information in order to:

  • Complete a transaction, provide requested-for goods/services, and/or perform a contract between you and us;
  • Detect security incidents;
  • Comply with a legal obligation;
  • Enable our internal uses that are aligned with your expectations and your relationship with us; or
  • Otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided your information.

Right to Opt Out (Do Not Sell or Share My Personal Information). You have the right to opt-out of the “sale” of your Personal Information (defined very broadly to include situations where we provide Personal Information to partners who provide advertising services to us) and the “sharing” of Personal Information in connection with the display of targeted advertising across third party websites. You can direct us not to sell or share your Personal Information by submitting an opt-out request via email at privacy@affinitygaming.com, or by contacting us at 702-341-2400.  We will act on your request within the timeframes set forth below.
We also honor the Global Privacy Control, a browser-based opt-out signal. We do not respond to other browser-based signals that do not meet applicable state law requirements, which may include older Do Not Track signals.

Right to Limit. You have the right to ask us to limit our use and disclosure of your sensitive personal information.

Right to Appeal. You have a right to appeal decisions concerning your ability to exercise your consumer rights.
 
Submission of Requests for Information. We have designated the following methods for California residents to submit requests for information:

After you submit a request, we will promptly take steps to determine whether your request is a verifiable request. We will verify that you are who you say you are via our regular log-in process for registered users, or by asking you to provide unique details that relate to your most recent transaction with us, including, for example, an order number or reservation confirmation number.

We will disclose and deliver the required information to you free of charge within 45 days of receiving your verifiable request. If necessary, we will extend the time period to provide the required information once by an additional 45 days, and will provide you with notice of the extension within the first 45-day period.

For requests to stop the sale or sharing of your Personal Information, we will comply no later than 15 business days after receipt of your request.

Authorized Agent. You may designate an authorized agent to make a request to access your Personal Information or have us delete your Personal Information on your behalf. If you use an authorized agent to submit such a request, we will require that you:

  • Provide the authorized agent written permission to act on your behalf; and
  • Verify your own identity with us before we can honor the request.

As noted above, we do not knowingly collect Personal Information from or about children. We do not sell or share Personal Information of minors under 21 years of age.

No Discrimination. We will not discriminate against you because you exercised any of the rights described here.

Notice at Collection Disclosure. For our notice at collection, see above sections of this privacy policy titled: Personal Information We Collect, Purposes for Collection of Personal Information,  Personal Information Sold or Shared to Third Parties in the Preceding 12 Months, and Retention Periods.

Notice of Financial Incentive. From time to time, we may offer financial incentives in connection with the collection or use of Personal Information.  The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at privacy@affinitygaming.com.

Shine The Light. California’s “Shine The Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for those third parties’ direct marketing purposes in the preceding calendar year.  To make such a request, please contact privacy@affinitygaming.com.

X. PERSONAL INFORMATION OF MINORS
Pursuant to law, persons under the age of twenty-one (21) are not permitted to gamble in casinos and are not permitted to loiter in the gaming areas of any Affinity Gaming properties. Similarly, Affinity Gaming Websites are general audience sites intended for persons 21 years of age or older. Affinity Gaming does not knowingly collect any Personal Information from persons under the age of 21. If you know of a minor who has provided Affinity Gaming with Personal Information, please contact Affinity Gaming immediately at privacy@affinitygaming.com so that we may identify the information that needs to be removed from our database. If you are under 21, please do not use the Sites or submit any Personal Information to us.


X. THIRD PARTY LINKS
Our Services may contain links to other websites provided by third parties. Please be aware that we do not control these third-party websites or any of the content contained on those websites. Once you have left our Services, we cannot be responsible for the privacy practices of such other websites. We encourage you to exercise caution and to read the privacy policy for the website you visit.

XI. SECURITY
We are committed to maintaining your confidence and trust, and take steps to help protect the Personal Information you provide to us. However, no transmission or electronic storage of information is guaranteed to be secure. We therefore urge you to always use caution when transmitting information over the Internet.


XII. INTERNATIONAL VISITORS
This Privacy Policy shall be governed by the laws of the United States and the State of Nevada. The servers that make the Services available and databases where information may be stored may be located outside the country from which you accessed the Services, in a country or state that does not have the same privacy laws as your country of residence. The Personal Information made available to Affinity Gaming may, therefore, be transmitted outside of the United States or State of Nevada. If you are accessing our Sites from outside of the United States, please note that Personal Information may be transmitted and stored in the United States. Affinity Gaming will collect, process, and use Personal Information only in accordance with this Privacy Policy. By visiting the Services and submitting information, you consent to such collection, processing, transfer and/or storage of Personal Information.


XVII. CHANGES AND UPDATES
We may revise this Privacy Policy from time to time. We will post any changes on this page and update the date at the top, so please check back periodically. Your continued use of the Sites after changes have been posted will constitute your acceptance of this Privacy Policy and any changes, unless otherwise required by applicable law.


XVIII. CONTACT US
If you have any questions, concerns, or suggestions regarding this Privacy Policy, or to update any information you have provided us, please send us an email to privacy@affinitygaming.com