Privacy Notice
APPENDIX B:ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF INDIVIDUALS BASED IN THE EEA AND UK
The terms of this Appendix applies where you are an individual based in the EEA or UK and sets out the rights you have with respect to the processing of your personal information, pursuant to the General Data Protection Regulation (“GDPR”) and other applicable laws. This Appendix controls to the extent it conflicts with any provision in the main body of the Notice.
Data Controller
For the purposes of the GDPR:
- If you are a customer of Wynn properties in Las Vegas, the Data Controller is:
Wynn Las Vegas, LLC
3131 Las Vegas Blvd. South
Las Vegas, NV 89109
- If you are a customer of Wynn properties in Boston, the Data Controller is:
Wynn MA, LLC
One Broadway
Everett, MA 02149
Our representative in the EEA and UK is DPR Group. To contact us about any queries you may have about this Notice or your rights, please see the address listed in the “Contact Us” section above or through our representative at:
DPR Group
Tower Business Centre
2nd floor
Tower Street, Swatar
BKR4013, Malta
PLEASE NOTE: when mailing inquiries, mark your letters for ‘DPR Group’ and not ‘Wynn Resorts Group’, or your inquiry may not reach us. In your correspondence, please refer clearly to Wynn Resorts Group.
Purposes and Legal Bases for Processing
We process personal information for the purposes set out in this Notice. We collect and process your personal information only where we have legal basis for doing so under applicable data protection laws. The legal basis depends on the Services you use and how you use them. Our legal bases for processing include processing of personal information which is (i) necessary for the performance of a contract with you; (ii) compliance with a legal obligation; (iii) pursuant to your consent; and (iv) pursuant to our legitimate interests to run an effective operation and administer the Wynn Services you have requested.
- Wynn Insider and Wynn Rewards Card (Online) Loyalty Programs – We process personal information about you to fulfill our contractual obligations to you and to further our legitimate business interests. Specifically, to facilitate membership to our loyalty programs, provide you with access to member-only rates and promotions and allow you to manage your information and communications preferences. The terms and data practices associated with the Wynn Rewards Card program are available here .
- Hotel Reservations – We process personal information about you to fulfill our contractual obligations to you and to further our legitimate business interests. Specifically, to process reservations for hotel rooms.
- Hotel Check-in and Stay – We process personal information about you to operate our business, including to improve and develop our hotel operations, for fraud prevention purposes, improve user experience or other legitimate interests.
- Group Events and Meetings – We process personal information about you to fulfill our contractual obligations to you and to further our legitimate business interests. Specifically, to provide you with access to use our meeting and convention space and facilitate reservations for group events, meetings or weddings.
- Provision of Services – We process personal information about you to operate our business, including to improve and develop our Services and amenities, for fraud prevention purposes, improve user experience or other legitimate interests.
- Wynn Concierge and Customer Service – We process personal information about you to further our legitimate business interests. Specifically, to respond to your comments, questions, requests, and communicate with you to provide customer service through our call center or social media channels.
- Marketing and Communications – We process personal information about you for marketing purposes where we have your consent. Specifically, to inform you of promotions, and periodically send you marketing communications about services and events that are relevant to your interests and for related purposes. You can opt-out at any time by contacting us at privacy@wynnresorts.com or by following the unsubscribe instructions in the marketing message, or by logging in to your Wynn Rewards Card or Wynn Insider account here and updating your communication preferences. If you do not have an account you can manage your email preferences at any time here . For push notifications within our mobile application, you can manage your push notification preferences through the respective device and mobile application settings.
- Social Media – We process personal information about you obtained via social media based on our legitimate interests. Specifically, to respond to your queries and for analytics purposes to better understand our customers and their preferences.
- Surveys – We process personal information about you to further our legitimate business interests. Specifically, to conduct statistical analysis, research and development, customer surveys and customer profiling.
- Analytics and Profiling – We process personal information about you for our legitimate business interests, including for data analytics purposes and data accuracy, such as linking to or combining information we collect to help maintain the accuracy of your account or profile information and to provide you with a better and more personalized service and offers.
- Regulatory and Corporate Compliance – We process personal information about you to carry out appropriate compliance, security and/or financial checks, further to our legitimate business interests such as when we need to:
- Confirm your identity;
- Make a payment to you or receive payment from you;
- Comply with law enforcement, court, tax authorities and regulatory obligations; and
- Otherwise in compliance with law.
- Sale, Merger or similar - We may also disclose your information further to our legitimate business interests to third parties in connection with sale, merger, business transfers or bankruptcy proceedings.
Transfer of Personal Information to Other Countries
Where you provide personal information to us, in order to fulfill your request or provide the Wynn Services, please note that such data is transferred to and stored in the United States (“US”), where Wynn’s corporate headquarters is located and where our IT systems (including email) are located.
Your personal information is also transferred to the third parties set out in the “How we share your information” section of the Notice who are located outside of the European Economic Area (EEA) (in most cases in the US). We transfer your personal data from the EEA to other countries in accordance with the European Commission’s standard contractual clauses.
Although the data protection laws of various countries may differ from those in your own country, we take appropriate steps to ensure that your personal information is handled as described in this Notice and in accordance with the law.
We transfer your information to third parties located outside the EEA where we have adequate measures in place to provide appropriate safeguards.
Data Subject Rights
Where the GDPR applies, you have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances as set out below. We also set out how to exercise those rights. Please note that we require you to verify your identity before we respond to any of your requests. The GDPR provides the following rights:
- Right of Access
You have the right to ask us to access the personal information we hold about you and be provided with certain information about how we use your personal information and who we share it with.
- Right to Rectification
You have the right to ask us to correct your personal information where it is inaccurate or incomplete and we endeavor to do so without undue delay.
- Right to Data Portability
In certain circumstances, you have the right to ask us for a copy of your data in a structured, machine readable format and to ask us to share (port) this information to another entity.
- Right to Erasure
In certain circumstances, you have the right to ask us to delete the personal information we hold about you:
- Where you believe that it is no longer necessary for us to hold your personal information;
- Where we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
- Where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; or
- Where you believe the personal information we hold about you is being unlawfully processed by us.
- Right to Restriction of Processing
In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information:
- Where you believe the personal information we hold about you is inaccurate and while we verify accuracy;
- Where we want to erase your personal information as the processing is unlawful, but you want us to continue to store it;
- Where we no longer need your personal information for the purposes of our processing, but you require us to retain the data for the establishment, exercise or defence of legal claims; or
- Where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.
- Right to Object
You can object to our processing of your personal information based on our legitimate interests. We will no longer process your personal information unless we can demonstrate an overriding legitimate ground.
- Objection to Marketing and Profiling
At any time you have the right to object to our processing of personal information about you in order to send you promotions and special offers and other marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
- Withdrawal of Consent
Where you have provided your consent for us to process your personal information, you can withdraw your consent at any time by emailing privacy@wynnresorts.com.
Exercising your Rights
To exercise any of these rights above, please contact us at privacy@wynnresorts.com.
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal information.
Complaints
We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to address any grievance directly to the relevant Supervisory Authority.
How Long We Retain Your Information
We retain your information for as long as needed to fulfill our legitimate business purposes outlined in this Notice, support our business operations, develop our Services, resolve disputes and enforce our rights. The criteria used to determine our retention periods include:
- The duration of our relationship with you and the ongoing provision of Wynn Services to you (for example as long as you have a Wynn Insider Card with us).
- Whether there is a legal or regulatory obligation which require us to retain certain records for a specific period of time (such as reporting to gaming and other regulatory authorities).
- Whether retention of personal information is legitimate based on statute of limitations, litigation or other regulatory investigations.
We may store your information in an aggregated and anonymized format following the retention periods noted above.