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MARRIOTT CASINOS GLOBAL PRIVACY STATEMENT

 

Last Updated: September 20, 2024

Marriott International, Inc. values you as our customer and recognizes that privacy is important to you. We want you to be familiar with how we collect, use, and disclose your Personal and Other Data (collectively, “Data”) in our managed casino properties (collectively, “Casinos”, “we” or “us”).1

This Privacy Statement describes the privacy practices of the Casinos and how we collect and use your Personal Data: (i) when you visit one of the Casinos; (ii) via our casino websites (collectively, our “Websites”) or online, where applicable; (iii) via our social media pages that we control (collectively, our “Social Media Pages”); and/or (iv) via software applications (made available by us for use on or through computers and mobile devices (collectively, our “Apps”).

PERSONAL DATA

“Personal Data” is information that may identify you as an individual or relate to you as an identifiable individual.

We may collect the following Personal Data when you submit a Front Money application (i.e., with Front Money, you deposit your own funds into a casino account) on a website of one of the Casinos:

  • First name
  • Middle Initial;
  • Last name;
  • Suffix;
  • Date of birth;
  • Driver’s license details;
  • Passport number;
  • Additional passport information (e.g., expiration date);
  • National Identification number;
  • Home address;
  • Email address;
  • Telephone numbers;
  • Trip details including arrival date;
  • Deposit amount;
  • Employment information including: (i) employer; (ii) type of business; (iii) number of years with employer; (iv) position; (v) annual income; (vi) business address; and (vii) business phone number;
  • Financial information including: (i) source of income; (ii) estimated annual compensation; (iii) source of funds; (iv) bank account details, including name, account type, bank routing number, bank account number, and whether the account is a trust; (v) branch address; and (vi) confirmation of whether you have Front Money at other casinos; and
  • Your signature.

We may also collect the following Personal Data when you visit one of the Casinos, including if you sign up to play table games, in the slot area, or if you choose to cash out above a predetermined threshold (the threshold is dependent on the Casino you are visiting; please contact the Casino for more information on its predetermined threshold):

  • First name, middle initial, and last name;
  • Date of birth;
  • Driver’s license, state issued ID, and/or passport (scanned);
  • Home address;
  • Email address;
  • Telephone numbers;
  • Your playing preferences and history when you sign up for the Players Club;
  • Your rewards history; and
  • Your Casino account balance.

We may also collect the following Personal Data when you sign up to one of our Players Clubs/Cards or VIP Areas:

  • First name, middle initial, and last name;
  • Date of birth;
  • Driver’s license, state issued ID, and/or passport (scanned);
  • Email address;
  • Home address;
  • Telephone number; and
  • Your playing preferences and history when you sign up for the Players Club.

In addition to the Personal Data collected when visiting one of the Casinos, we may also collect the following Personal Data where legally required or where necessary to prevent fraudulent activities and to enhance security measures in the Casinos:

  • Information on any suspicious activities carried out by you while on the Casino premises (such as if you try to commit credit card fraud or identity theft);
  • Video taken via CCTV security recordings;
  • Source of funds information via data analytics for the prevention of criminal activity;
  • Information required by regulatory authorities and law enforcement (such as the police and local gaming commission or other relevant authorities) on their suspicious activity reports including (but not limited to) name, date of birth, address, gender, play behavior, identification documents such as passports or driver’s licenses, source of funds, type of player information, previous sanctions information and open-source research including via Google and social media platforms; and
  • Information requested in a subpoena.

If you disclose any Personal Data relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.

We also process deidentified and/or aggregated information, such as how individuals in general use certain services provided by the Casinos (“Deidentified Information”). Such information on its own does not identify you, so it does not qualify as Personal Data, unless otherwise provided by applicable law. We will not re-identify, or attempt to re-identify, such Deidentified Information.  We use or disclose Deidentified Information for any purpose, in accordance with applicable law. This Privacy Statement does not apply to such Deidentified Information.

USE OF PERSONAL DATA

We use Personal Data for the purposes listed in the tables below.

Purpose

Description Of Activities Associated With Purpose

Registering your Players Card

Signing up for a Players Card at a Casino, including validating ID.

Issuing of your rewards

Validating your ID (passport or driver’s license) so we can issue rewards cards to you upon your request while you are visiting a Casino.

Issuing of your Front Money Account

Validating your ID and financial information to conduct financial checks, and sharing your Personal Data with our payment processor to carry out more thorough checks and to enable us to validate sources of funds before issuing credit to you in accordance with your request.

Enabling automatic cash out payments

Validating ID for those that want to be able to cash out amounts over certain monetary thresholds, to meet our “know-your-customer” requirements.

Responding to your questions, comments, and complaints

Responding to your questions and fulfilling your requests during or prior to your visit to a Marriott Casino, for example, when you ask for more information or make a complaint. This also includes responding to your questions and fulfilling your requests made in accordance with the “Choices and Access” section below.

Providing our services and fulfilling your requests

Arranging access to your account(s) and providing you with related customer service.

Communicating important information to you

There are a number of activities associated with this purpose, such as sending administrative information to you, including changes in our terms, conditions, and policies.

Analyzing Personal Data for business reporting and providing personalized services

Analyzing and predicting player preferences to prepare aggregated trend reports on how our services are used, and this allows us to better understand your interests and preferences so that we can provide you with information tailored to your interests and deliver products and services that may be of interest to you.

Marketing

 There are a number of activities associated with this purpose, such as:
  • Inviting you to visit a Marriott Casino property;
  • Communicating with you about your participation in sweepstakes, contests, or other promotions when you have opted to receive such communications by email;
  • Communicating with you about our products and services at our Marriott Casinos that may be of interest to you; and
  • Communicating with you about our awareness campaigns (such as our Responsible Gaming program), upcoming special events and our Player Loyalty programs.

Aggregating and/or anonymizing Personal Data

We may aggregate and/or anonymize Personal Data so that it will no longer be considered Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

Accomplishing our business objectives

 There are a number of activities associated with this purpose, such as:
  • Data analysis, for example, to improve the efficiency of our services;
  • Audits, to verify that our internal processes function as intended and to address legal, regulatory, and contractual requirements;
  • Fraud and security monitoring purposes, for example, to detect fraudulent activities in the Casinos and/or to prevent cyberattacks or attempts to commit identity theft, including carrying out enhanced security checks (via LexisNexis) to help prevent fraudulent activities and complying with anti-money laundering requirements;
  • Developing new products and services;
  • Enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  • Identifying usage trends, for example, understanding which parts of our services are of most interest to users;
  • Determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  • Operating and expanding our business activities, for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests.

Complying with specific legal requirements

 We may be required by applicable law to collect certain Personal Data, such as:
  • Collecting passport information because we are legally required by applicable laws to do so to allow you entry into the Casinos.
  • Collecting names, addresses, date of birth, gender, play behavior, source of funds, type of player information, previous sanctions information and open-source research including via Google and social media platforms for suspicious activity reports required by regulatory agencies and/or law enforcement including the police and gaming commission and other relevant authorities.
  • Collecting names, addresses, date of birth, gender, ID including type and number, transaction information such as nature, amount, time and place of the transaction, currency type, designated use and origin of monies, securities, precious metals (e.g., gold, platinum, etc.), or other values involved in the transaction, and circumstances regarding a transaction that is considered unusual (pursuant to applicable banking secrecy and transaction laws).

 

DISCLOSURE OF PERSONAL DATA

Marriott Casinos may share Personal Data as follows:

Entity

Category of Personal Data Shared

Purpose

Other Marriott Casinos located in the same country as the Marriott Casino you are visiting.

First and last name, date of birth, photos, scans of passports/ID, and a brief description of activities carried out at the relevant Marriott Casino.

To prevent fraudulent activities and to enhance security measures.

 

The Personal Data will only be shared within the country where the Marriott Casino you are visiting is located. For example, if you are visiting a Marriott Casino in Aruba, the Personal Data will only be shared with entities in Aruba.

Third-party casinos located in the same country as the Marriott Casino you are visiting.

First and last name, date of birth, photos, scans of passports/ID, and a brief description of activities carried out at the relevant Marriott Casino.

To prevent fraudulent activities and to enhance security measures.

 

The Personal Data will only be shared within the country where the Marriott Casino you are visiting is located. For example, if you are visiting a Marriott Casino in Aruba, the Personal Data will only be shared with entities in Aruba.

Third-party service providers (with whom we have appropriate data processing agreements, as applicable).

As needed, depending on the service provided.

To prevent fraudulent activities and carry out enhanced security checks (via Lexis Nexis), and to facilitate the services they provide to us, including website hosting, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

Regulatory agencies and law enforcement, including the police and local gaming commission or other relevant authorities.

As requested on the relevant authority’s suspicious activity report, enhanced due diligence report or as otherwise requested or ordered by the relevant authority.

To prevent fraudulent and criminal activity and cooperate with law enforcement requests or orders or provide information.

 

OTHER USES AND DISCLOSURES

We also use or disclose Personal Data, as necessary or appropriate, when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations. This may include laws outside your country of residence.
  • For other legal reasons. For example, to enforce our terms and conditions, and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
  • In connection with a sale or business transaction. We may have a legitimate interest in disclosing or transferring your Personal Data to a third-party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. When you visit our websites, we may collect data typically collected through websites, such as:

  • Browser and device information;
  • Information collected through cookies, pixel tags and other similar technologies as follows: When you visit our Websites from either a desktop or mobile device, we may collect and use cookies or other identifiers to serve you with personal advertisements for Marriott and third-party products, either via email, on our Website, or on other websites on the Internet; to measure how you interact with our Websites; and to maintain your preferences. We do this primarily through cookies, which are pieces of data stored directly on the computer or mobile device that you are using.

You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html↗

In general, we use four different types of cookies:

  • Strictly Necessary Cookies: These cookies are necessary to enable the basic features of the website or app, such as providing a secure log-in.
  • Functional Cookies: These cookies allow our Websites to remember your site preferences and choices you make on the site.  We also use functional cookies to facilitate navigation, to display content more effectively, and or to personalize your experience.
  • Advertising Cookies: Advertising cookies allow us to select which advertisements or offers are most likely to appeal to you. We also use them to track responses to online advertisements and marketing, and we may use it to better understand your interests so we may can present you with relevant messages and offers. These cookies may also allow you to share certain pages with social networks.
  • Analytics Cookies: Analytics cookies help us improve our website by collecting and reporting information on how you use it.


Opting out of Cookies

There are several ways to opt-out of cookies. If, however, you do not accept any cookies, you may experience some inconvenience in your use of our websites, apps, and social media pages. For example, we will not be able to recognize your computer, and you will need to login every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests.

  1. Browser settings: You can opt out of cookies on your browser. Every browser is different so please check the instructions provided by your browser.
  2. Through our “Tracking Preferences” site.
  3. Google Analytics: We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the websites, apps and social media pages. These services also collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners↗ and opt out by downloading Google Analytics opt out browser add on, available at http://tools.google.com/dlpage/gaoptout↗. You can learn more about Adobe and opt out by visiting http://www.adobe.com/privacy/opt-out.html↗.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

If you would like to request to access, correct, add to, or delete your Personal Information, or opt out of or cease the processing of your Personal Information (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request in a manner that is consistent with applicable law.

RETENTION PERIODS

We retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include: 

  • As long as we have an ongoing relationship with you;
  • As required by a legal obligation to which we are subject; or
  • As advisable in light of our legal position (such as with regard to applicable statutes of limitations, litigation, or regulatory investigations).

THIRD-PARTY SERVICES

This Privacy Statement does not address, and we are not responsible for, the privacy, information, security, or other policies or practices of any third parties (such as any third-party operating a website or service to which our website may link). The inclusion of a link on any of our Websites does not imply endorsement of the linked site or service by us.

JURISDICTION AND CROSS-BORDER TRANSFERS

Your Personal Data will be stored and processed in the country where the Marriott Casino you are visiting is located (e.g., if you are visiting a Marriott Casino in Aruba, your Personal Data will be stored and processed in Aruba only).

UPDATES TO THIS PRIVACY STATEMENT

The “LAST UPDATED” legend at the top of this Privacy Statement indicates when this Privacy Statement was last revised.  Any changes will become effective when we publish the revised Privacy Statement.

CONTACTING US

If you have any questions about this Privacy Statement, please contact us at privacy@marriott.com. Alternatively, you can contact our managed Casino properties at the below addresses:

  • Sheraton Cairo Hotel & Casino: Galae Square, P. O. Box 11, Cairo, Egypt
  • Cairo Marriott Hotel & Omar Khayyam Casino: 16 Saray El Gezira Street, Zamalek, Cairo, Egypt, 11211
  • San Juan Marriott Resort & Stellaris Casino: 1309 Ashford Avenue, San Juan, Puerto Rico, 00907
  • Aruba Marriott Resort & Stellaris Casino: L.G. Smith Boulevard # 101, Palm Beach, Aruba
  • The Ritz-Carlton, Aruba: L.G. Smith Boulevard #107, Noord, Aruba
  • The Ritz-Carlton, Turks & Caicos: Grace Bay Rd, Grace Bay TKCA 1ZZ, Providenciales, Turks & Caicos Islands

LANGUAGES

 

1Managed Casino properties include: (i) Sheraton Cairo Hotel and Casino; (ii) Cairo Marriott Hotel and Omar Khayyam Casino; (iii) San Juan Marriott Resort and Stellaris Casino; (iv) Aruba Marriott Resort and Stellaris Casino; (v) The Ritz-Carlton, Aruba; (vi) The Ritz-Carlton, Turks and Caicos; and (vii) The St. Regis, Aruba and Ritz-Carlton, San Juan – projected to open 2024.

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