Privacy Policy

Effective Date: January 2021

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you submit information to or through the Website (as defined below), you consent to the collection and processing of your information as described in this Privacy Policy.

By using the Website, you accept the terms of this Privacy Policy and our Terms of Use and consent to our collection, use, processing, disclosure and retention of your information as described in this Privacy Policy.

If you have not done so already, please also review our Terms of Use, which can be found here. The Terms of Use contain provisions that, among other things, limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action.

This Privacy Policy is incorporated into and made a part of our Terms of Use. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR THE TERMS OF USE, THEN PLEASE DO NOT USE THE WEBSITE.

1. Scope
The Privacy Policy applies to the website located at http://www.motorcitycasino.com (the “Website”). The Website is owned and/or operated by Detroit Entertainment, L.L.C. d/b/a MotorCity Casino Hotel ("MotorCity Casino Hotel," “we,” “our,” or “us”).

This Privacy Policy describes, among other things:

• Information that we receive and/or collect from you when you interact with the Website.
• How we use, process, and retain the information that we receive and/or collect from you.
• If and why Personal Information (as defined below) may be shared, transferred, or otherwise disclosed to third parties
• Your choices regarding the collection and processing of your Personal Information.

Certain transactions and services offered while using the Website may be processed or provided by or through third party websites (referred to as “Linked Services” in the Terms of Use), even though it may appear that you have not left the Website. A link to any Linked Service does not mean that we endorse such Linked Service or the quality or accuracy of information presented on it. This Privacy Policy does not apply to information collected by or through Linked Services that you may access through the Website, nor does it apply to information that you submit to us through email, text message, other electronic message or offline. MotorCity Casino Hotel does not have any control over how such Linked Services use information that they collect from you. To determine the privacy policies applicable to information collected by such Linked Services, please consult their respective websites.

2. Changes to Privacy Policy
We may modify this Privacy Policy, in whole or part, from time to time by posting the modified Privacy Policy on the Website. The modified version will supersede all previous versions. Therefore, you should periodically review the Privacy Policy. The modified Privacy Policy shall be effective immediately on posting, and the date at the top of this page will be changed to reflect the date of posting. Your continued use of the Website following posting of the modified Privacy Policy constitutes your acceptance of such Privacy Policy. We may terminate the Privacy Policy at any time, in our sole discretion, without any notice to you. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so.

3. Information We Collect
We routinely collect a variety of information from a variety of sources. The type of information we collect varies (depending on your use of the Website) and includes both personal and non-personal information. Examples of the type of information that we may potentially collect from you include but are not limited to:

(a) “Personal Information” means information associated with or used to identify or contact a specific person. Personal Information includes but is not limited to:

(i) contact data (such as e-mail address, mailing address, and telephone number);
(ii) demographic data (such as gender, date of birth, and zip code);

(iii) certain Usage Data (defined below), such as IP addresses; and (iv) sensitive Personal Information, such as your Club Metro card number, credit card number, debit card number, or other sensitive financial account information used to make purchases. Note that sensitive Personal Information is subject to stricter regulation than other Personal Information. Before providing it for our use, we urge you to carefully consider whether to disclose your sensitive Personal Information to us. If you provide sensitive Personal Information to us, you consent to its use, processing, retention, and disclosure for the purposes and in the manner described in this Privacy Policy.

(b) “Usage Data” is information about an individual's online activity that, by itself, does not identify the individual, which includes but is not limited to:

(i) technical information, the web browser or other applications or programs through which the user has accessed the Website; and
(ii) information about what the user has searched for and looked at while using the Website, such as search terms used and details of other information and content accessed or requested in using the user's IP address, device version and identification number. Generally, we do not consider Usage Data to be Personal Information because Usage Data by itself usually does not identify an individual; however, some Usage Data may be Personal Information under applicable law. Personal Information and Usage Data may be linked together; different types of Usage Data also may be linked together and, once linked, may identify an individual person. Also, we may combine the information we collect from you with information from other sources (including but not limited to Linked Services) and use the combined information as described in this Privacy Policy.

4. How Information is Collected
(a) Information collection in general We collect information that you provide to us through the Website and from your use of the Website. The information that we collect and how we process it depends on how you use and access the Website. Some information is collected automatically through use of cookies and similar data collection tools. To learn more about how and why we use cookies and similar tools to collect information, please see Section 4(c) below.

(b) From You. We collect Personal Information and Usage Data from you when you use the Website, contact us for help or information, or otherwise voluntarily provide your Personal Information. We also collect the information that you submit to us, such as when you sign into and use your Club Metro web account through the Website. Furthermore, we automatically collect Usage Data and Location Data when you interact with the Website.

(c) Cookies and other information collection tools

Cookies
We use Cookies in connection with the Website. “Cookies” are small computer files sent to or accessed from your web browser or the storage drive of your mobile device that contain information, such as a user ID, user settings, browsing history, and activities conducted while using the Website. Cookies are not themselves personally identifiable, but may be linked to Personal Information that you provide to us through your interaction with the Website. A Cookie typically contains the name of the domain (Internet location) from which the Cookie originated, the “lifetime” of the Cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.

How We Use Data Collection Tools
Cookies help us improve the Website by tracking users' navigation habits and storing users' passwords, customizing users' experiences with the Website, enabling us to analyze technical and navigational information about the Website, and helping to detect and prevent fraud.

We also use other Cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “Data Collection Tools,” to help improve your experience with the Website. For example, Data Collection Tools help us remember users and make the Website more relevant to them.

The Website also may use Data Collection Tools to collect information from the device used to access the Website, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the device is located.

Control of Cookies
Web browsers allow some control of most Cookies through the browser settings. To find out more about Cookies, including how to manage and delete Cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject Cookies or to alert a user when a Cookie is placed on the user's device. Most devices also offer settings to reject mobile device identifiers. Although users are not required to accept Cookies or device identifiers, blocking or rejecting them may prevent access to some features available through the Website.

(d) Online Advertising
We may use Data Collection Tools to track the actions of users of the Website, to measure statistics of our marketing efforts, and to deliver advertisements on the Website that may be more relevant to you. We may use Data Collection Tools to record the actions of users of the Website, to measure statistics of our marketing efforts, to deliver advertisements on the Website that may be more relevant to individual consumers and to improve the consumer experience on the Website.

(e) Data Collection by Linked Services and Other Third Party Service Providers
Linked Services and other third party service providers may use Data Collection Tools on or in connection with the Website, and may include information about a user’s online activities over time and across other online services or websites. This Privacy Policy does not apply to those Linked Services or other third party service providers or their Data Collection Tools, and we are not responsible for practices and privacy policies of those Linked Services or other third party service providers. As indicated previously, we recommend that you review their respective privacy policies.

(f) Information Obtained from Other Sources, including from Service Providers, Third Party Services and Joint Marketing Partners
We may obtain information about you from other sources, including service providers, third party services or publicly available sources and we may combine such information with information we have collected about you as described in this Privacy Policy. To the extent we combine such third party information with other personal information we have collected, we will treat the combined information as personal information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.

(g) Do Not Track. We currently do not employ technology which responds to Do Not Track signals from your web browser.

5. How Information is Used, Shared, and Disclosed
MotorCity Casino Hotel uses the information we collect for our own marketing, advertising, and promotional purposes. We may use, share and/or disclose your information to notify you of special promotions, offers, and events via email, text message, push notifications, other electronic communications, telephone, and by other means at our disposal (in each case subject to this Privacy Policy). We may also use, share and/or disclose your information to facilitate the services you request, to resolve disputes, troubleshoot problems with our servers and software, or enforce our policies, including using, sharing, and/or disclosing your information as follows (this list is purposely illustrative and not meant to be exhaustive):

• to provide the Website to you;
• to perform services requested or functions (e.g. transactions) initiated by users through the Website, such as making restaurant reservations, purchasing tickets for entertainment events, or processing and tracking hotel reservations;
• to allow Linked Services and other service providers to perform the functions for which we engage them (such as hosting and data analyses);
• to operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• for customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Website;
• to communicate with users or identify users in connection with communications sent through the Website;
• to better understand how users access and use the Website, for the purposes of trying to improve the Website and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users' usage of the Website;
• to help us develop our new products and services;
• to provide users with advertising and direct marketing that is more relevant to you;
• to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Website;
• to validate your identity or eligibility to use certain aspects of the Website;
• conducting statistical or demographic analysis;
• complying with legal and regulatory requirements (including, by way of example, disclosures to the Michigan Gaming Control Board or complying with a court order, subpoena, search warrant or other legal process);
• to support external auditing, compliance and corporate governance functions;
• protecting and defending us from legal claims or to pursue available remedies (e.g. debt collection) or limit damages we may sustain;
• protecting against harm to the rights, property, or safety of MotorCity Casino Hotel, users, or the public;
• satisfying contractual obligations;
• enforcing MotorCity Casino Hotel’s policies and procedures, including, by way of example, this Privacy Policy and the Terms of Use; and
• for purposes as disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

Please note that for the purposes of seeking to provide our users with a better experience and to improve the Website, information collected through the Website may be used in an aggregated or individualized manner. For example, Personal Information collected during use of one aspect of the Website may be used to suggest particular content that can be made available to the user on another aspect of the Website, or it may be used to try to present more relevant advertising in yet another aspect of the Website. We may also share information as needed to operate other related services, as well as provide your information to our affiliated companies or otherwise provide this information to other trusted businesses or promotional partners to process such information on our behalf for the purposes set forth in this Privacy Policy.

6. Information Transfer in Corporate Transactions
We may transfer information about you, including your Personal Information, in connection with a merger, sale, reorganization, acquisition or other change of ownership or control by or of MotorCity Casino Hotel or any affiliated company (in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts under the circumstances to notify users before their information becomes subject to different privacy and security policies and practices.

7. Requesting Removal of Your Information/Opting Outbr> If you wish to opt-out of receiving emails, other electronic communications and/or mail from us or do not want us to share your Personal Information for marketing purposes with Linked Services or other third parties, please email us at OptOut@MotorCityCasino.com with the words "Opt-Out Request" in the subject line and include in the body of the email your name, address, and what you would like to out-out of. If you have a Club Metro account and have accessed your Club Metro web account through the Website, you may also opt-out of receiving emails, other electronic communications and/or mail from us in the “preferences” section of your profile page. Although you may opt-out of the use and sharing of personal information for emails, other electronic communications, mail, and/or marketing purposes, in accordance with this Privacy Policy, we may still use and provide information we collect for non-email/electronic communications, mail, and/or marketing purposes. We may also continue to contact you with information or notifications about your account or transactions with us. Please note that such removal of Personal Information will not ensure the permanent and complete removal of such Personal Information from the Website. For example, such Personal Information may remain in our archival or backup copies of the Website.

8. How Information is Retained and Secured
We retain information as long as it is necessary and relevant for our operations. In addition, we retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce this Privacy Policy and the Terms of Use, collect any fees owed and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion practices.

Information that we collect through the Website is stored on secure servers, which are protected by firewalls and reasonable physical, technical and administrative security protocols. These security protocols are intended to protect information from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. Furthermore, the security of information transmitted through the Internet can never be guaranteed. We are not responsible for any disclosure, interception or interruption of any information that you send to us before we receive it, nor are we responsible for any information you that you transmit through the Internet or for any changes to or losses of data. Users of the Website are solely responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Website. In order to protect you and your data, we may suspend your use of the Website or any aspect thereof, without notice, pending an investigation, if any breach of security is known or suspected. Access to and use of password protected and/or secure areas of the Website are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

9. Children’s Privacy
The Website is not directed at nor intended to be attractive to persons who are under the age of 21 and we do not target the Website to persons who are under the age of 21. If we discover that we are in possession, through the Website, of Personal Information related to a person who is under the age of 21, we will promptly delete and/or destroy such Personal Information. Only persons who are 21 or older may access certain areas (such as the casino and other areas that we may designate from time to time) as well as participate in certain activities (such as gambling and alcohol purchase/consumption) at our facility or elsewhere (such as online). If you are under 21, you may not access (or attempt to access) any areas or participate (or attempt to participate) in any activities that are permitted only for persons who are 21 or older. We do not knowingly collect or allow the collection of Personal Information from persons who are under 21. If a parent or guardian of a person who is underage becomes aware that such underage person has provided us with Personal Information, the parent or guardian should contact us at the e-mail address included in Section 7 of this Privacy Policy. Furthermore, if you are under 21, you are prohibited from accessing or attempting to access password protected information and/or aspects of the Website (including but not limited to a Club Metro web account).