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Privacy Policy

Revised: September 2011

Grand Victoria Casino Elgin (GVC) GVC values your patronage and respects your privacy. GVC has created this privacy statement to demonstrate our commitment to your online privacy when interacting with our online portals ("Policy'). Our Policy sets forth GVC'S privacy practices in connection with the GVC web sites ("Sites"), and the information that GVC collects via its Sites, properties and casinos, which may be used to notify you via email and other electronic communication of additional promotions, products and services. The Policy also describes how personal information about you may be obtained, used, and disclosed by us.

This Policy applies to GVC-operated Sites. As such, it may also apply to other subsidiaries of GVC, or to other casinos and other properties that are owned, operated, or affiliated with GVC or its subsidiaries. This Policy does not to apply to web sites that are owned or operated by other entities, or entities that are merely affiliated with GVC or its subsidiaries through marketing agreements or other service provider agreements.

INFORMATION WE COLLECT

Personal Information Collection

GVC may collect personal information such as name, gender, gaming activity, telephone and fax number, email address, date of birth, home or business postal address when you access certain areas of the Site that require registration for certain services, or if you require more information about those services. If you decide to make reservations or purchase our services, we may need to collect certain additional information, like your credit or debit card number and expiration date, financial account number, driver's license number, state identification card number, Social Security number, passport number, and naturalization number.

At other times, GVC may collect information that cannot be used to identify you. For example, we may aggregate non-personal information about you and other guests or visitors to our Site. Aggregated information will not contain any information that can be linked directly back to you.

How GVC Collects Personal Information

GVC may use any number of tools to collect information about you, your computer access points, and the web browser that you use to connect to our Web sites. For example, "cookies" are tiny text files that we place on your computer's hard drive when you visit our Site. We may use cookies to personalize your interactions with our Site. You do not have to accept our cookies and you may set your browser to restrict their use and you may delete them after they have been placed on your hard drive. If you do not accept or delete our cookies, some areas of our Site may take more time to work, or may not function properly at all.

GVC may also collect additional information from your web browser each time you visit our Site. We may collect information about the pages that you visit and the time spent on each web page or area of the Site, the promotions or advertisements that you click on, and other actions that you take while using our Site. This information may include your Internet Protocol ("IP") address, Media Access Control ("MAC") address, the type of browser, the time that your browser was used to access our Site, and the referring web site's address.

Our Internet Service Providers (defined below) may also use other standard web-based technologies to analyze your movements while accessing our Site. The list of technologies may include, without limitation, web "beacons," "pixel tags," and "clear gifs." These technologies help ascertain the effectiveness of our product and service campaigns, promotions and marketing programs, allow us to customize the services offered on or through our Site, and help determine the best use for Site content, and product and service offerings. Some of this information, including the IP address, may be stored on our Internet service provider's server logs, and may be available for extended periods of time.

GVC may acquire personal information from our Business Partners (defined below) including entities that direct you to GVC Sites, or GVC properties and casinos. Therefore, we encourage you to review all privacy policies for more information about a third-party's privacy protection practices before submitting personal information.

HOW WE USE THE INFORMATION WE COLLECT

At times GVC may use the services of independent companies to provide certain services to you, including, without limitation, website hosting services, credit card processing, order processing and reservation services, and guest surveys ("Internet Service Providers" or "Business Partners"). GVC may share your personal information with the Internet Service Providers or Business Partners as appropriate. We do not share personally identifiable information with outside third parties without your consent, except to the extent necessary to complete your request for products and services offered through the GVC Site.

GVC may use your personal information to contact you via mail, e-mail, text message, or telephone in order to give you updates about GVC'S special events, new services, current information regarding our services, or other promotions that may be of interest to you. If you are a business or organization that has scheduled a conference, event, or meeting at one of our facilities, we may also share your personal information with our event organizers. We also use return e-mail addresses or cellular telephone numbers to respond to e-mail or text messages that we receive from you. Your e-mail address or cellular number will not be used for any other purpose or shared with outside third parties (other than our Business Partners) for their direct marketing purposes. We may also use your IP address or MAC address to help protect GVC and our Internet Service Providers from fraud.

Additional uses of your non-personal and personal information will allow us to tailor products and services specific to your needs, to help organize and manage our relationship with you or your business, to conduct business, to provide you with customer and guest support, to perform functions that are described to you at the time of collection, and to enforce our Site's Terms of Use.

We may also use non-personal aggregate information to improve our Sites and enhance your interactions with our Site. For example, our Internet Service Providers may report to us that there were a particular number of visitors to a certain area of our Site, or that a certain number of businesses or a certain number of individuals completed our registration forms in particular areas of our Site. Such information may also be used to analyze the effectiveness of our business, advertising, and promotion models.

If you submit a resume or seek to fulfill other staffing requirements, we will use that information solely in connection with your application for current or future staffing requirements, and we may also share your resume or application information with our business partners or affiliates that have staffing requirements for which you may be qualified.

GVC may also disclose your personal information as is necessary to: (a) comply with a subpoena or court order; (b) cooperate with law enforcement or other government agencies; (c) establish or exercise our legal rights; (d) protect the property or safety of our company and employees, contractors, vendors, suppliers, and customers; (e) defend against legal claims; (f) help with internal and external investigations; or (g) as otherwise required by law or permitted by law. We may disclose your information in connection with the sale or merger of GVC or any transaction that involves the sale or assignment of some or all of our assets.

GVC may also aggregate your personal information with other publicly available information to help us recognize your preferences or interests. Your personal information may also be merged with Personal Information available from other sources such as (1) companies that match e-mail addresses with postal addresses; (2) credit card verification and credit services; and (3) other resorts, casinos, or properties that are owned, operated, or affiliated with GVC or its subsidiaries.

If you do not want us to use your personal information for marketing purposes, you may opt-out of such uses by notifying us in accordance with this Policy. Opting-out will not prevent your personal information (including Confidential Personal Information) from being used for non-marketing purposes.

Sharing within GVC and with Subsidiaries

GVC, for marketing purposes, may share your personal information and non-personal information with our affiliated entities that may include: (1) GVC properties and casinos, and GVC Sites, and (2) GVC subsidiaries not covered by this Policy, and any other resorts, casinos, or other properties that are controlled, owned, operated by or affiliated with GVC or its subsidiaries (collectively, "Subsidiaries"). If you do not want your personal information to be shared among GVC, GVC properties and casinos and GVC Sites or with Subsidiaries for marketing purposes, you may opt-out of such sharing by notifying us in accordance with this Policy.

HOW TO OPT-OUT

When you provide us with registration information via our Site, you may be offered the opportunity to subscribe to and receive additional information regarding promotions, and our products and services. After your first use, you can change your initial choices by contacting customer service e-mail at: victoria@gvcelgin.com. Each commercial e-mail that we send to you will offer you the opportunity to opt-out of continuing to receive such messages. We may take up to 10 business days to process your opt-out requests. In some instances, we may have already shared your information with one of our authorized third parties before you changed your information preferences, and you may briefly continue to receive e-mail even after you have opted out. FTC e-mail compliance guidance allows us to send you transactional and relationship e-mail without offering you the opportunity to opt-out of receiving those types of e-mail.

Although you may request to opt-out of sharing personal information for marketing purposes, we may disclose personal information to our Business Partners and other third parties, including law enforcement to comply with legal, regulatory or administrative requirements of any governmental authorities and to protect and defend GVC, our Business Partners, subsidiaries and affiliates, and all of their officers, directors, employees, attorneys and agents in connection with any legal action, claim or dispute, and to prevent imminent physical harm or threats to public safety, and other suspected illegal activities.

SECURITY

GVC makes reasonable efforts to ensure that our Internet Service Providers have implemented physical, electronic, and procedural security measures to assist with safeguarding your personal information, and to help protect against unauthorized access and disclosure. Only our authorized personnel and our Internet Service Providers who perform legitimate business functions for GVC are authorized to access your personal information. Notwithstanding our efforts, the Internet has inherent security risks. GVC cannot promise, and you should not expect, that your personal information, personal searches, and other communications will always remain secure when transmitted over the Internet or other electronic media. You should take care with regard to how you handle and disclose your personal information or any username or password that you are required to use to access services on our Site.

RESPONSIBLE GAMING PROGRAM

We support the Illinois Gaming Board Code of Conduct for Responsible Gaming. Accordingly, we will not use the personal information of members of the GVC'S disassociated persons program, self-limit access programs, self-exclusion programs, or any similar programs that may be applicable in your state of residence, for any marketing purposes.

OTHER WEB SITES

GVC is not responsible for the information collection or privacy practices of other websites, including websites operated by our Business Partners. You should review and understand those third-party privacy policies posted on any linked sites you visit before providing any personal information.

PERSONS UNDER AGE 21

Certain of our areas and activities are intended for persons 21 or older. If you are under 21, we ask that you do not access or attempt to access any areas or participate in any activities that are restricted to persons 21 or older. We do not knowingly collect or allow the collection of Personal Information from persons under 21. If you are the parent or guardian of a person who is under the age of majority in your state of residence and believe that the person has provided us with Personal Information, you may contact us at victoria@gvcelgin.com and request that it be deleted from our files. We will delete the Personal Information of any person under the age of majority in your state of residence and will not use such Personal Information for any purpose.

VISITORS OUTSIDE OF THE UNITED STATES

For those Site users located in the United Kingdom and European Union, we are required by law to advise you that your personal information may, at times, be accessible by individuals who are located worldwide including in countries that the European Commission has not determined provide the same level of data protection as in your country. By providing us with your personal information, you are consenting to our use of it in accordance with GVC'S privacy policy, including the transfer of your personal information across international boundaries to jurisdictions anywhere in the world as permitted by local law.

The United States may not have data privacy laws that afford an equal level of protection for your personal information as those laws legislated at the direction of the United Kingdom and European Union; however, please be assured that GVC will continue to adhere to the principles stated in this privacy policy and in applicable laws in connection with any personal information. GVC will endeavor to preserve the integrity, confidentiality, and security of personal information and afford such personal information an adequate level of protection.

YOUR CALIFORNIA PRIVACY RIGHTS

GVC will not share any personal information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless you agree otherwise as authorized by your prior written consent.

California residents have the right to request information from GVC regarding the manner that we may share personal information with affiliated companies and third parties for their direct marketing purposes. To find out what and how we share such information, you may send us an e-mail request at victoria@gvcelgin.com or mail a request to: Privacy Policy, GVC 250 South Grove Avenue, Elgin, IL 60120, and you will receive the following information:

The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year, if any;
The names and addresses of the third parties who received information for their direct marketing purposes; and
Examples of the products and services subject to the third-parties' direct marketing programs, if the nature of the third parties' business cannot be determined from their names.
CHANGES TO THIS POLICY

We reserve the right to revise this Policy at any time without notice. When this Policy is revised in a material way, notice will be posted on the GVC Sites along with the revised Policy. If you have any questions or concerns after reviewing this Policy, you may contact us at victoria@gvcelgin.com.