Last Updated: November 18, 2020
We at Las Vegas Sands Corp. (the “Company”) respect your concerns about privacy and strive to provide guests, patrons and visitors (“you”) with exceptional experiences and service. This Privacy Notice describes the types of personal information we obtain, how we may use and retain that personal information, with whom we may share it and how you may exercise your rights and choices with respect to our processing of that information. This Privacy Notice also describes the measures we take to safeguard the personal information we obtain and how you may contact us if you have questions about our privacy practices.
The Company’s affiliates and subsidiaries have operations in the United States, Macao and Singapore. This Privacy Notice does not apply to those operations and relates only to personal information the Company obtains through this website and other sites, applications and data collection points that link to or reference this Privacy Notice. For information about the privacy practices of our properties, review the privacy notices posted to their respective websites.
This Privacy Notice applies to personal information we obtain, including:
- through our websites, social media pages and other digital platforms we operate or control, whether directly or indirectly via third parties, that reference this Privacy Notice (collectively, the “Online Channels”);
- when you visit us, attend a meeting or event and through other offline interactions (collectively, “Offline Channels”); through third-party sources, including business partners, social media companies and vendors; and
- through other data collection points that reference this Privacy Notice (collectively, the “Channels”).
PERSONAL INFORMATION WE OBTAIN
We collect personal information about you in different ways and from various sources. This includes, without limitation, when you visit our Online Channels, interact with us through our social media pages or contact us by email or phone.
Personal Information You Provide
Depending on the Channels you use and the nature of your interactions with us, you may provide us with certain types of personal information, including:
- Contact information such as name, email address, postal address, fax number and telephone number;
- Demographic information such as age, date of birth, education, profession, marital status and gender;
- Billing and financial information such as your bank account information, payment card number, expiration date, security code, delivery address and billing address;
- Government-issued ID information such as your passport, driver’s license or other government-issued ID, which you may provide;
- Content such as photos, comments, feedback and other content you provide;
- Employment application information such as name and contact information, employment history, Social Security number, education, training and skills (including licenses and certificates), background check information, proof of eligibility to work in the United States (“U.S.”), military service and any other information provided in connection with an application if you apply for a job with us; and
- Any other personal information you provide through the Channels.
Providing your personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.
Personal Information Obtained from Other Sources
In addition to the personal information you provide to us directly, we may obtain additional information about you from other sources, including:
- Other individuals such as authorized personnel or agents who provide your information to us on your behalf;
- Publicly available information such as name, contact information, content and online activity that we obtain from publicly available sources (such as public databases) and social media platforms you interact with;
- Device information such as location information derived from your IP address, country and zip code;
- Video and audio information such as images, video and audio data that may be collected or processed through our security cameras, closed-circuit television, recorded phone lines and other technologies, where permitted by law;
- Data from third-party sources such as personal information we obtain from our third-party service providers (including data aggregators and data cleansing companies), business partners and marketing partners.
HOW WE USE PERSONAL INFORMATION
We use the personal information we obtain for various purposes, including:
- Managing our communications with you including to send you information about your transactions, our properties, the services available to you and events or meetings you may attend;
- Managing career opportunities including to process and assess your job application, and to conduct recruiting and other talent management purposes;
- Data analytics including to maintain and improve our products and services;
- Prevention and protection including to protect our visitors and employees, identify and prevent fraud and other unlawful activity and protect and defend the Company against legal claims and other liabilities;
- Operating, evaluating and improving our business including to perform accounting, auditing, record keeping, credit risk management and other internal functions (such as ensuring the functioning, safety and security of our Online Channels, premises, infrastructure and networks), developing new products and services and analyzing and improving our existing products and services; and
- Legal and compliance including to comply with and enforce applicable laws and regulations, industry standards and contractual obligations, as well as our policies and terms and conditions.
We may combine data collected from you with other sources to help us improve our products, services, marketing and communications, as well as to help expand and tailor our interactions with you. This includes combining personal information we obtain through our Online Channels with information we obtain through Offline Channels, as well as other sources for the purposes described above. We may anonymize, de-identify or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection.
Depending on the purposes for which personal information is used, and the context in which the information is obtained, we rely on one or more of the following legal bases, subject to applicable law:
- Performance of a contract or to take steps at your request prior to entering into a contract;
- Our legitimate business interests (which we can explain to you in further detail upon request by contacting us as indicated in the HOW TO CONTACT US section below).
- Compliance with a legal obligation; or
- Your consent to the processing of your personal information, which you can revoke at any time.
We may transfer the personal information we collect about you to the U.S., Macao and Singapore, and other countries outside of the country in which the information originally was collected, including the jurisdictions in which our service providers operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will implement appropriate safeguards to help ensure that we protect that information as described in this Privacy Notice and in accordance with applicable law.
If you are located in the European Union ("EU"), United Kingdom (“UK”) or Switzerland, we will comply with legal requirements with respect to providing adequate protection for the transfer of personal information to recipients in countries outside of the EU, UK or Switzerland that have not been recognized as providing an adequate level of data protection, to the extent such legal requirements are applicable to our processing of your personal information. In this event, we will implement appropriate safeguards, including as appropriate by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
RETENTION OF YOUR PERSONAL INFORMATION
To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it and in accordance with the terms of this Privacy Notice, which generally means that we will keep your personal information for the duration of our relationship or as long as you are enrolled in our loyalty program; (2) to take into account applicable statute of limitation periods and comply with applicable laws; or (3) for legitimate business purposes to the extent permitted by applicable law. As described in the YOUR RIGHTS AND CHOICES section of this Privacy Notice, to the extent provided by the law of your jurisdiction, you may request that we delete your personal information or restrict the processing of such information by contacting us as indicated below.
YOUR RIGHTS AND CHOICES
Subject to applicable law, you may have certain rights and choices in connection with the personal information we obtain about you, such as how we use the information and how we communicate with you.
To update your preferences, limit the communications you receive from us or submit a request, contact us as specified in the HOW TO CONTACT US section of this Privacy Notice. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.
To the extent provided by the law applicable to our processing of your personal information, you may request access to the personal information we maintain about you or request that we correct, update, complete, amend or delete your information, or that we restrict the processing of such information, by contacting us as indicated in the HOW TO CONTACT US section below. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information or responding to requests related to your personal information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.
Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information for direct marketing purposes or on legitimate grounds to any other processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal. Subject to applicable law, you may also have the right to receive, in a structured, commonly used and machine-readable format, the personal information that you provided us with, as well as the right to have this information transmitted to another organization, where it is technically feasible.
CHILDREN’S PERSONAL INFORMATION & LEGAL GAMING AGE
We do not permit gaming at our properties or loitering in casino areas for persons under the age of 21. The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13 through the Online Channels, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, contact us as specified in the HOW TO CONTACT US section of this Privacy Notice.
CALIFORNIA CONSUMER PRIVACY STATEMENT
This California Consumer Privacy Statement (“Statement”) applies solely to the personal information we collect online and offline of California consumers (excluding Company employees, applicants, contractors and B2B personnel). This Statement is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”) and uses certain terms that have the meaning given to them in the CCPA. This Statement supplements our Privacy Notice and is not intended to contradict or limit the applicability of the information provided in the Privacy Notice.
Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
- Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address and other similar identifiers.
- Additional Data Subject to Cal. Civ. Code § 1798.80 such as signature, physical characteristics or description, education, bank account number and other financial information.
- Protected Classifications such as age, sex, gender, marital status and other characteristics of protected classifications under California or federal law.
- Commercial Information such as records of personal property, products or services purchased, obtained or considered and other purchasing or consuming histories or tendencies.
- Online Activity such as internet and other electronic network activity information, including, but not limited to, browsing history, search history and information regarding your interaction with websites, applications or advertisements.
- Sensory Information such as audio, electronic, visual and similar information.
- Employment Information such as professional or employment-related information.
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
We may use your personal information for the purposes described in this Privacy Notice and for certain business purposes specified in the CCPA, as described below.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services or providing similar services.
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance.
- Short-term transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Internal R&D for technological development and demonstration.
- Safety undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for or controlled by us, and to improve, upgrade or enhance the service or device that is owned, manufactured, manufactured for or controlled by us.
We also may collect additional information or use the information listed above in other ways for which we provide specific notice at the time of collection.
Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in the NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION section above, during the 12-month period prior to the date this Privacy Notice was last updated. For the personal information collected during that timeframe, we describe below: (1) the categories of sources from which we may have obtained the personal information and (2) the categories of third parties with whom we may have shared the information.
Sources of Personal Information. We may have obtained personal information about you from various sources, including as described below.
- Directly from you (such as when you attend an event; or contact us with requests, feedback or suggestions)
- Your devices (such as when you visit our websites)
- Our affiliates and subsidiaries
- Vendors, suppliers and business partners
- Social networks
- Government entities, law enforcement authorities and third-party subpoenas
- Publicly available sources (such as public databases)
Sharing of Personal Information. We may have shared your personal information with certain categories of third parties, as described below, including for the business purposes described above.
- We may have shared the following categories of your personal information with our affiliates and subsidiaries: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
- We may have shared the following categories of your personal information with vendors, suppliers and business partners: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
- We may have shared the following categories of your personal information with professional services organizations (such as auditors and law firms): Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
- We may have shared the following categories of your personal information with government entities and law enforcement authorities in limited circumstances as described in this Privacy Notice: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
- We may have shared the following categories of your personal information with data analytics providers: Identifiers; Commercial Information; Online Activity; and Inferences.
- We may have shared the following categories of your personal information with social media platforms: Identifiers; Commercial Information; Online Activity; and Inferences.
- We may have shared the following categories of your personal information with third parties in the event of a corporate transaction, such as an acquisition: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
We do not sell personal information and have not sold personal information during the 12-month period prior to the date of this Privacy Notice was last updated.
California Consumer Privacy Rights
Effective January 1, 2020, you have certain choices regarding your personal information, as described below.
- Access. You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure and sale of such information. To submit an access request, click here or call us at 1-877-883-6423.
- Deletion. You have the right to request that we delete certain personal information we have collected from you. To submit a deletion request, click here or call us at 1-877-883-6423.
Verifying Requests. To help protect your privacy and maintain security, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request by contacting Privacy@Sands.com or 1-877-883-6423.
UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our information practices. We may post a notice on our Online Channels to notify you of significant changes to this Privacy Notice and indicate at the top of the notice when it was most recently updated. We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.
HOW TO CONTACT US
For questions or comments regarding this Privacy Notice, or to update your preferences, contact us using either of the following options:
Privacy Office, Legal Department
Las Vegas Sands Corp.
3355 Las Vegas Boulevard South
Las Vegas, Nevada 89109