PRIVACY POLICY

 

Turning Stone Enterprises, LLC Privacy Policy
(Effective January 9, 2025)

Turning Stone Enterprises, LLC and its subsidiaries (referred to in this Privacy Policy as "Turning Stone Enterprises," "us," "we," and/or "our") values you as a guest and customer and take your personal privacy seriously. In the course of providing you with products and services, we may collect certain information from or about you. We are providing this Privacy Policy to explain our practices and policies for collecting, using and sharing information collected from or about you when you visit, access, or use, or provide information to us (referred to together as the "Services"). By visiting, accessing, or using, or providing information to us in connection with the Services, you expressly consent to our collection, storage, use and sharing of your information as described in this Privacy Policy.

Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, or use, or provide information to us in connection with our Services.

This Privacy Policy does not create a contractual obligation between you and Turning Stone Enterprises and it is subject to our Terms of Use located at turningstonecarcare.com/terms-of-use. If you have questions about this Privacy Policy, please contact us at privacy@turningstone.com.

1. DEFINED TERMS
As used in this Privacy Policy:

(a) "Personal information" refers to any information by which you can be personally identified, such as your first name, last name, address, phone number, email address, credit card number, social security number, driver license number, passport number, license plate number, geolocation information, TS Rewards number, date of birth, purchase information, gaming activity information, biometric information and other similar information.

(b) "Non-personal information" refers to information by which you cannot be personally identified.

2. INFORMATION WE MAY COLLECT.
We collect and use information we believe is necessary to administer and promote our businesses, provide you with the products and services you request, and to provide a safe and healthy environment to our employees and guests and customers. We may collect and maintain both personal information and non-personal information needed for these purposes. Your personal information and/or non-personal information will be referred as your "information" in this Privacy Policy.

3. HOW WE COLLECT YOUR INFORMATION.
(a) Information You Directly Provide to Us. You may provide information directly to us under a wide range of circumstances, such as when you submit information to us through our websites or applications, when you visit and stay as a guest at our resorts and casinos, or use our restaurants, entertainment, retail outlets, spas, fitness centers, valets and guest services, visit any of our SavOn or Maple Leaf convenience stores or use any services at Turning Stone Enterprises, are videotaped or photographed in connection with a security incident or for other purposes, receive email or text messages from us, access Wi-Fi, enter a promotion or sweepstakes, our TS Rewards program, social media (including Facebook, Instagram, Twitter, TikTok, WhatsApp and Snapchat), request information from us, or provide feedback in a survey.

(b) Information We Collect Automatically.

(i) Traffic Data. We automatically track and collect general log information when you visit our Sites and use our Services, including your: (A) Internet Protocol (IP) address, (B) domain server, (C) operating system, and (D) type of Web browser as well as the pages you visit on our website (collectively "Traffic Data"). Traffic Data does not personally identify you, however, if you choose to provide us with personal information, we may store some items of your personal information and use it with the Traffic Data to better personalize your experience on the website.

(ii) Data Collected Using Cookies and Other Technologies. We also automatically collect information from you using cookies, IP addresses, transparent GIFs, and other technologies on our website and applications. We may use cookies and similar technologies to identify who you are and may use them when you visit our website and applications, click on our ads, or open our emails. Cookies also enable us to remember your user preferences for our website. Cookies and other technologies may also be used for site maintenance and analysis, performing network communications, authenticating users, serving contextual advertisements, and protecting against fraud and theft. You can block or remove cookies using your Internet browser's settings. If you block or remove cookies, your ability to perform certain transactions, use certain functionality, and access certain content on our website and applications may be affected.

(iii) Information Collected by Third Parties through Third-Party Links and Content. Our website and applications may include links to other websites and other content from third-party businesses. These third-party businesses may use cookies, web beacons or other similar technology to collect information about you. We do not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third-party website or application. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on our website.

(iv) Information Collected by Third-Party Analytics Services. We may work with third-party analytics services to help us understand how our property, offerings or website, or are being used, such as tracking the frequency and duration of use of our website. These analytics services may use cookies and other technologies to collect information about the content you view, what websites you visit immediately prior to and after visiting our website, and your system information and geographic information. The information collected by these analytics services allows us to analyze your use of our Sites and Services.

(v) Information You Share on Third-Party Websites or through Social Media. Our website may include links to third-party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services. We may also monitor sentiments regarding Turning Stone Enterprises or affiliated properties that you publicly post on social media services or customer review sites. We may reach out to you regarding these postings to address guest service issues and to otherwise help ensure that you have a positive guest experience.

(vi) Information You Post on our Website. If you post information on any public areas of our website, that information may be collected and used by us, other users of affiliated websites and the public generally.

(vii) When You Use Our Wi-Fi Services. If you use Wi-Fi services that we make available at Turning Stone Enterprises, we might collect information about your use of our Wi-Fi services, including your IP address, Wi-Fi information (such as SSID), mobile carrier, the websites you visit, the type of device and browser you are using, your device identification number, bandwidth used and session time.

(viii) From Mobile Devices on our Property. If you have a mobile device, are located on or at any of our properties and locations and have your Wi-Fi or Bluetooth functionality enabled, we may collect information concerning your mobile device, including the type of device, device ID, and the precise physical location of your device within and around the property (including geolocation and beacon-based location), enabling us to understand our guests' preferences and use of our properties, including general traffic patterns and for marketing purposes, such as to provide you with real-time offers and personalized promotions. If you do not want information concerning your precise location to be collected, you may adjust your mobile device location sharing settings and disable the Wi-Fi and Bluetooth functionality in your mobile device settings.

(ix) When you Drive a Vehicle on Turning Stone Enterprises' property. If you drive a vehicle onto a Turning Stone Enterprises property, we may automatically collect vehicle information, including without limitation, license plate number, registration, make and model, and vehicle condition when using valet services.

(x) Video Surveillance, Facial Recognition and Related Security Information. Some video surveillance systems may incorporate facial recognition technologies.

(c) 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 (such as data brokers or analytics firms), publicly available sources, government agencies or Joint Marketing Partners (defined below), and we may combine such information with information we have collected about you as described in this Privacy Policy. The third parties from whom we collect information about you include:

• Online travel agencies and other third-party booking partners;
• Consumer reporting agencies, in connection with a credit application or financial account with Turning Stone Enterprises;
• Event ticket sales management partners and ticket brokers;
• Social media channels, such as Facebook and Instagram, consistent with your settings with such channels; and
• Marketing and promotion providers.

This information from third parties includes contact information such as your name, email address and phone number. It may also include your travel details (booking confirmation numbers, arrival and departure dates), payment information, online browsing and usage behavior, social media profile information, age, contact information and other publicly available information.

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.

4. HOW WE MAY USE YOUR INFORMATION.
We will use the information you provide to us for a variety of purposes, including;

• to offer, manage and administer the TS Rewards Program, assess your benefits, administer offerings, provide information to you about your TS Rewards Program activity and manage your choices regarding how you receive offers;
• to send you personalized messages, publications and information about events, special offers, promotions and benefits;
• to facilitate the processing of online reservations such as facilitating payment, sending confirmation or pre-arrival messages including information about the resort, hotel, casino or retail outlet that you are visiting and the amenities available to you, sending administrative messages about events or meetings you have reserved and provide you with related customer services such as sending you your receipt by email or text message;
• to send push notifications if you have chosen to receive push notifications when you install our applications on your mobile device (you can turn off the notifications by visiting your mobile device's "settings" page or through the notification page in the application);
• to improve the products and services we provide you and develop new products and services.
• to improve our property, services, offerings, and websites;
• to facilitate our hotel operations, including guest account management, hotel room reservations, and requests;
• to track your use of our property, services and website for our internal market research and analytics;
• to create a more accurate and complete customer profile for you to better understand and predict the products and services you want to use and
• to provide a more personalized level of service;
• to notify you about promotions and special offers regarding products and services provided by us or our affiliates or other associated third parties, including our Joint Marketing Partners (defined below);
• to ask for your participation in our internal market research;
• to generate aggregate statistical studies about our guests to better understand how our guests use our services;
• to contact you in response to your inquiries, comments and suggestions;
• to provide a healthy, secure, and safe environment for our guests and employees;
• to protect and defend our rights or property or enforce our agreements with you;
• to perform background checks for any reason (to the extent permitted by applicable laws), which includes but is not limited to any investigation into your identity, any credit checks or any inquiries into your personal history:
• to process credit card, ACH and/or other financial transactions;
• administer general recordkeeping for financial statements and audits;
• comply with our internal records management policy and retention rules;
• to enforce our Sites and Services terms of use.
• to contact you otherwise when necessary; and
• otherwise with your consent or as permitted or required by applicable law.

5. HOW WE SHARE YOUR INFORMATION WITH OUR AFFILIATES.
We may share certain information we receive from you, and about your transactions with us, with our affiliates and other instrumentalities, corporate entities or affiliates for purposes described in this policy, to facilitate the TS Rewards program, and to personalize exceptional guest experiences across our Sites and Services and those of our affiliates. Doing so allows us to provide the products and services you have requested and quickly respond to applications for credit or other financial services.

6. HOW WE SHARE YOUR INFORMATION WITH NON-AFFILIATED THIRD PARTIES.
As permitted by law, we may share the information we collect from and about you with non-affiliated third parties as follows:

(a) Third-Party Service Providers. Your information may be shared with or collected by third-party service providers who provide us with services, including but not limited to data hosting or processing, credit card processing, credit or background checks, or processing and fulfilling reservations or purchases. We require these providers to exercise reasonable care to protect your personal information and restrict the use of your personal information to the purposes for which it was provided to them.

(b) Third-Party Joint Marketing Partners. We may share certain information about you with other companies with whom we have joint marketing or similar agreements, or other businesses with whom we have a contractual relationship ("Joint Marketing Partners"), who may contact you with marketing and promotional offers. However, when you join Turning Stone Enterprises mobile alerts promotional program and provide us a mobile phone number for that purpose, that phone number will not be shared with Third-Party Joint Marketing Partners. If you would like us to stop providing your information to these Joint Marketing Partners, you may opt-out of personal information sharing by following the instructions in Section 10 below.

(c) Compliance and Regulatory Purposes. We share your personal information with law enforcement agencies, government authorities or other third parties: (i) if required to do so by applicable law, or in response to a lawful subpoena or court order, search warrant or other valid legal process, (ii) to comply with legal, regulatory or administrative requirements of any governmental authorities having authority or jurisdiction, including but not limited to gaming regulators, (iii) in connection with any legal action, claim or dispute, including but not limited to the collection of debts, (iv) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large, or (v) we believe that you have abused our website by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third-party, your information may be accessible by others to the extent permitted or required by applicable law.

(d) Aggregate Information. We may share your information with affiliated or non-affiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

(e) Analytics and Search Engine Providers. We may share personal information with these providers to assist us in the improvement and optimization of our guest records, Sites and Services.

7. ONLINE ADVERTISING; COOKIES AND TRACKING TECHNOLOGIES.
(a) Online Advertising. Turning Stone Enterprises and third parties may use cookies, pixel tags, web beacons, and other similar technologies to collect information about your usage and browsing activities over time and across different websites, platforms or online services following your use of Turning Stone Enterprises' Sites or Services, including mobile applications. These technologies allow us to recognize your preference information, keep track of purchases, remember your TS Rewards account details, enhance your visits to our Sites, provide you with information, advertising and offerings tailored to you, improve the guest experience and to help manage online advertising programs.

(b) Do Not Track. Your browser may allow you to adjust your browser settings so that "do not track" requests are sent to the websites that you visit. However, at the present time we do not disable tracking technology that may be active on our website in response to any "do not track" requests that we receive from your browser.

8. MARKETING PREFERENCES.
You may withdraw your consent for direct marketing communications by contacting us at privacy@turningstone.com or by following the unsubscribe instruction in the marketing message.

When you receive a commercial (promotional) electronic communication, we provide the choice to opt-out of receiving future messages by following the instructions provided in the messages.

You may choose whether to provide your phone number to receive text messages or advertising phone calls from us. By providing your phone number and consent, you are choosing to receive such messages until you withdraw your consent. Your consent to receive text messages is not required to make a purchase at Turning Stone Enterprises. You may revoke your consent at any time by contacting us at privacy@turningstone.com.

You may choose whether to receive push notifications through our mobile applications. You can change your preferences for receiving push notifications through respective device and mobile application settings.

We do not sell your personal information. "Sale" includes a typical sale (i.e., a transfer of data from a seller to a buyer in exchange for money), but it also includes sharing of personal information with an unaffiliated third-party in exchange for anything of value (money or otherwise). We may share some of your personal information with our affiliates or Joint Marketing Partners (defined in Section 6(b) above) but we do not share any of your personal information provided (mobile phone number) and gathered (device information, etc.) as part of our Turning Stone Enterprises mobile alerts promotional program. You may opt-out out of having your information shared with third parties for marketing purposes by submitting a request to privacy@turningstone.com. Opting out through this mechanism will not prevent your personal information from being shared with third parties for non-marketing purposes (for example, to process one of your transactions).

9. SECURITY.
We maintain physical, electronic and organizational safeguards that reasonably and appropriately protect against the loss, misuse and alteration of the information under our control. With regard to information that you transfer to us through our website, please be aware that no data transmission over the Internet or a wireless network can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit on or through our website and you do so at your own risk.

10. HOW TO ACCESS, UPDATE AND CORRECT PERSONAL INFORMATION.
If you would like to update or correct your personal information, please send an email to privacy@turningstone.com. Your request to update or correct your personal information should include the following:

a) Your full name;

b) Your Email address; and

c) Your corrected contact information.

11. CHANGES TO OUR PRIVACY POLICY.
Over time, it may be necessary to modify or supplement our Privacy Policy. When we make changes, we will post the changes our website and change the effective date at the top of the Privacy Policy. We encourage you to visit our website from time to time to review our Privacy Policy in the event it has changed. Your continued provision of information to us or use of our Services following the posting of changes to the Privacy Policy means that you accept the changes and our use of your personal information in accordance with the revised Privacy Policy. If you do not agree to the changes, you should discontinue your use of our Services prior to the time the modified Privacy Policy takes effect.

12. MINIMUM AGE REQUIREMENTS.
We do not knowingly or intentionally collect any personally identifiable information from, or market to, individuals under the age of 18. Our online services are not intended for persons under the age of 13. Persons under the age of 13 are not allowed to use our online services in any fashion. If you learn that a child under the age of 13 has provided us with personal information contrary to these rules, please contact us at the address listed in the "Contact Information" section below.

13. VIDEO SURVEILLANCE AND FACIAL RECOGNITION TECHNOLOGIES.
Video surveillance cameras may be used for security and to protect us, our guests, customers and team members against potential violations of criminal or civil laws as well as threats to our guests' and team member's. Cameras and video surveillance systems may also be used to enhance your customer experience and provide services to you. Video camera output is monitored by our employees and may be viewed by law enforcement and regulatory authorities.

14. NON-U.S. RESIDENTS.
Unless otherwise specified, our website and material provided on or through our website and services are solely intended for users located in the United States and for promoting products, programs, and business operations within the United States. If you do not reside in the United States and you choose to access or use our website and services or visit our property, and provide your personal information to us, it may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you live. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you live, you should not use our website, our services or visit our property.

15. CONTACT INFORMATION.
Should you have additional questions, comments or concerns regarding this Privacy Policy or how we collect and use your information, you may send an email or contact us by writing to:

Turning Stone Enterprises, LLC
ATTN.: Privacy and Security
Turning Stone Resort Casino
5218 Patrick Road
Verona, NY 134785

privacy@turningstone.com