PRIVACY NOTICE

Last Updated: January 8, 2020


Introduction

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 U.S., Macau 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 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 from other sources additional personal information about you, 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;
  • Data collected by cookies and similar technologies such as information about your online activities, devices, browsing actions, and usage patterns across the Online Channels and third-party websites that we obtain through the use of cookies, web beacons, and similar technologies (see the Cookies and Similar Technologies section below);
  • 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;
  • Responding to you and providing support including to address your inquiries and feedback, requests, and other communications you send us;
  • Marketing including to present or send you messages, news, and other types of information about the Company and our properties, to plan and execute our marketing campaigns, and for market research and analysis;
  • 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 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:

  • 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.

Cookies and Similar Technologies

We use cookies, web beacons (including pixels and tags), and similar technologies on our Online Channels that collect certain information about you by automated means.

A “cookie” is a small text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes IP address, device ID, and other identifiers associated with your device, device type, device characteristics (such as operating system), the pages you visited on our websites, how you arrived at our websites, browser preferences and characteristics, clickstream data and other information about your online activities. We use on our Online Channels both first-party cookies (served directly by our website domain when you visit our Online Channels) and third-party cookies (served by a third-party website when you visit our Online Channels and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).

The cookies we use on our Online Channels include:

  • Essential cookies (which are necessary for us to provide you with our Online Channels);
  • Functional cookies (which enable improved website performance and an enhanced user experience) and
  • Analytics cookies (which help us analyze how you navigate through and use our Online Channels).

With respect to analytics cookies, we use third-party analytics services on our Online Channels, such as those of Google Analytics. To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Note, however, that without cookies, you may not be able to use all of the features of our Online Channels. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

The third-party apps, tools, widgets, and plug-ins on our Online Channels (such as Facebook, Twitter, Instagram, and LinkedIn) also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy notices of these providers.

Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. Our Online Channels currently are not designed to respond to DNT signals received from web browsers.

How We Share Personal Information

We may share your personal information with certain third parties, including as indicated below.

  • Our Affiliates and Subsidiaries. We may share your personal information with our affiliates and subsidiaries for the purposes set out in this Privacy Notice.
  • Service Providers, Suppliers, Agents, and Other Business Partners. We use service providers, suppliers, and agents to help us provide our products and services and to perform services on our behalf (such as maintenance, IT services and support, analysis and analytics, audit, payments, marketing, development, reservations, security, ID verification, and background and credit checks). We do not authorize these entities to use or disclose such information except as necessary to perform services on our behalf or comply with legal requirements. We also may share personal information with business partners for the purposes described in this Privacy Notice.

We also may disclose personal information about you (1) if we are required or permitted to do so by applicable law, regulation, or legal process (such as a court order or subpoena); (2) to law enforcement authorities and other government officials to comply with a legitimate legal request; (3) when we believe disclosure is necessary to prevent physical harm or financial loss to the Company, our employees, or the public as required or permitted by law; (4) to establish, exercise, or defend our legal rights; and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security, or technical issues.

In addition, we reserve the right to transfer to relevant third parties the personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation), or other business transaction.

We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.

Data Transfers

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 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

We offer you certain 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. 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 (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 the categories of personal information listed above for the purposes described in this Privacy Notice and for certain business purposes specified in the CCPA, as described below.

  • Performing Services. We may use the following categories of personal information for the purpose of 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: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
  • Auditing. We may use the following categories of personal information for the purpose of 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: Identifiers; Commercial Information; Online Activity; Sensory Information; and Inferences.
  • Short Term Use. We may use the following categories of personal information for the purpose of short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction: Identifiers; Commercial Information; Online Activity; Sensory Information; and Inferences.
  • Security. We may use the following categories of personal information for the purpose of detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
  • Debugging. We may use the following categories of personal information for the purpose of debugging to identify and repair errors that impair existing intended functionality: Identifiers; Online Activity; and Sensory Information.
  • Internal R&D. We may use the following categories of personal information for the purpose of undertaking internal research for technological development and demonstration: Identifiers; Commercial Information; Online Activity; Sensory Information; and Inferences.
  • Safety. We may use the following categories of personal information for the purpose of 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: Identifiers; Commercial Information; Online Activity; Sensory Information; and Inferences.

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; (2) the categories of third parties with whom we may have shared the information; and (3) the categories of personal information we may have disclosed for a business purpose.

Sources of Personal Information. We may have obtained personal information about you from various sources, including as described below.

  • We may have obtained the following categories of your personal information directly from you (such as when you attend an event; or contact us with requests, feedback, or suggestions): Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Sensory Information; and Employment Information.
  • We may have obtained the following categories of your personal information from your devices (such as when you visit our websites): Identifiers; Commercial Information; Online Activity; Sensory Information; and Inferences.
  • We may have obtained the following categories of your personal information from 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 obtained the following categories of your personal information from 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 obtained the following categories of your personal information from social networks: Identifiers; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences.
  • We may have obtained the following categories of your personal information from government entities, law enforcement authorities, and third-party subpoenas: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Employment Information; and Inferences.
  • We may have obtained the following categories of your personal information from publicly available sources (such as public databases): Identifiers; Protected Classifications; Commercial Information; Online Activity; and Inferences.

Sharing of Personal Information. We may have shared your personal information with certain categories of third parties, as described below.

  • 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.

Disclosure of Personal Information for a Business Purpose. We may have disclosed to third parties for a business purpose certain categories of personal information, including: (1) Identifiers; (2) Additional Data Subject to Cal. Civ. Code § 1798.80; (3) Protected Classifications; (4) Commercial Information; (5) Online Activity; (6) Sensory Information; (7) Employment Information; and (8) Inferences.

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.

Our websites may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our websites are not covered by this Privacy Notice. We are not responsible for the privacy notices of websites to which our website links. If you provide any information to such third parties, different rules regarding the collection and use of your personal information may apply. We strongly suggest you review such third parties' privacy notices before providing any data to them.

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:

Email:
Privacy@Sands.com
Mail:
Privacy Office, Legal Department
Las Vegas Sands Corp.
3355 Las Vegas Boulevard South
Las Vegas, Nevada 89109