1. INFORMATION WE COLLECT
A. Information about You that You Provide.
VegasWiFi, and its Vendors (defined below), collect information you provide directly to VegasWiFi or its Vendors via the Online Service. For example, VegasWiFi collects information when you use or register for the Online Service, subscribe to notifications, post on the Online Service, participate in promotional activities, or communicate, use or transact through the Online Service. In addition, when you interact with Third- Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices.
Information VegasWiFi, its Vendors, and/or Third-Party Services may collect may include: personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, telephone number, VegasWiFi account number, user ID and password, PIN, and full payment account number ("Personally Identifiable Information" or "PII").
We, our Vendors, and third parties may deidentify and/or aggregate (e.g., the removal or modification of the personally identifiable elements, or the rendering of personally identifiable elements into non-personally identifiable elements through anonymization, pseudonymization, and/or hashing) PII (“De-identified PII” or “non-PII”). De-identified PII may be used and disclosed without obligation to you, except as prohibited by applicable law.
B. Information Collected Automatically.
VegasWiFi, its Vendors, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Online Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Online Service (including referring URL, clicks, cursor movement, and scrolling activity), and data regarding network connected hardware (e.g., computer or mobile device).
For more information on Third-Party Services’ data collection and practices
For more information on Service Provider data collection and practices
For information on choices some of these third parties may offer you regarding automated data collection
The methods that may be used on the Online Service to collect Usage Information include:
- Log Information:
- Log information is data about your use of the Online Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
- Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, in-app tracking methods, device and activity monitoring, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Online Service, including information about your browsing and purchasing behavior.
A cookie is a small text file that is stored on a user’s device, which may include session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Online Service and expire when you close your browser. Tracking cookies remain longer and help us understand how you use the Online Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Online Service may not work. HTML5 cookies can be programmed through HTML5 local storage. HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. The Online Service may associate some or all of these types of cookies with your devices. For more information on how to manage your cookie preferences
- Embedded Scripts
An embedded script is programming code designed to collect information about your interactions with the Online Service. It is temporarily downloaded onto your computer from VegasWiFi’s web server, or from a third party with which VegasWiFi works and is active only while you are connected to the Online Service and deleted or deactivated thereafter.
- Location-identifying Technologies
GPS (global positioning systems) software, geo-filtering, geo-targeting, geo-fencing, and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Online Service, your device location may be tracked by us and third parties. For example, our store finder feature may access and use information about your device location (such as based on IP address or GPS, as applicable), or your account information, to suggest appropriate store locations. Our Online Service content may be personalized based on various information we may have about you to try to provide you with more location-relevant content.
- Device Recognition Technologies
Certain technologies, including application of statistical probability to data sets, link a common unique identifier to different device use (e.g., Facebook ID) and attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) ("Cross-device Data").
- In-App Tracking Methods
There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and devices.
- Device and Activity Monitoring
Technologies that monitor, and may record, certain of your interactions with the Online Service, including without limitation, keystrokes, and collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and improving the Online Services and customizing or optimizing your experience on the Online Services.
Some information about your use of the Online Service and certain third-party services may be collected using Tracking Technologies across time and services and used by VegasWiFi and third parties for purposes such as to associate different devices you use and deliver relevant ads and other content to you on the Online Service and certain third-party services
C. Information VegasWiFi Collects From Other Sources.
2. HOW WE USE THE INFORMATION WE OBTAIN
- Allow you to participate in the features we offer on the Online Service;
- Facilitate, manage, personalize, and improve your online experience;
- Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
- VegasWiFi’s Affiliates’ marketing and other purposes;
- Improve the Online Service and for any other internal business purposes;
- Tailor our content, advertisements, and offers;
- Fulfill other purposes disclosed at the time you provide PII or otherwise where we are legally permitted or are required to do so;
- Determine your location and manage digital content rights (e.g., territory restrictions); and
- Prevent and address fraud, breach of policies or terms, and threats or harm.
3. INFORMATION WE DISCLOSE WITH THIRD PARTIES
VegasWiFi may disclose non-PII and PII (provided that VegasWiFi is aware of no restrictions of VegasWiFi’s use, if any), with third parties or VegasWiFi and their affiliates ("VegasWiFi Affiliates") for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your PII to non-PII, including without limitation through hashing it or substituting a unique identifier for the PII and we and third parties may use and disclose that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. VegasWiFi’s disclosure of PII is, however, subject to the following:
- Marketing: We may use your PII to send you marketing communications. Absent your consent (which may be by means of opt-in, your election not to opt-out, or a third party interaction described in the next bullet point), however, VegasWiFi will not disclose your PII with third parties, other than VegasWiFi Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
- Your Disclosure or Consent: As more fully described (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Online Service may, by their nature, result in the disclosure of your information with third parties and by engaging in these activities you consent to that and further disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not VegasWiFi.
- VegasWiFi’s agents, vendors, consultants, and other service providers (collectively “Vendors”) may receive, or be given access to, your information, including, without limitation, PII and Usage Information, in connection with their work on VegasWiFi’s behalf, provided however, VegasWiFi does not authorize its Vendors to use PII provided by VegasWiFi to the Vendors to send you direct marketing messages other than related to VegasWiFi and VegasWiFi Affiliates absent your consent. For more information on choices Vendors may offer you
- VegasWiFi may disclose your PII to advertising networks, analytics providers, and marketing services companies in connection with displaying advertisements to you that we think may be of interest to you;
- To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
In addition, VegasWiFi may disclose your PII and non-PII, in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of VegasWiFi assets, or transfer of all or a portion of VegasWiFi’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
4. SWEEPSTAKES, CONTESTS AND PROMOTIONS
5. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
The Online Service may include hyperlinks to, or include on or in connection with, the Online Service (e.g., apps, plug-ins, application programming interfaces, and software development kits), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit PII from you.
Certain functionalities on the Online Service permit interactions that you initiate between the Online Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Online Service and a Third-Party Service; “liking” or “sharing” VegasWiFi’s content; logging in to the Online Service using your Third- Party Service account (e.g., using Facebook Connect to sign in to the Online Service); and to otherwise connect the Online Service to a Third-Party Service (e.g., to pull or push information to or from the Online Service). If you use Social Features and potentially other Third-Party Services, the information you post or provide access to may be publicly displayed on the Online Service or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Online Service (e.g., by using a hashtag associated with VegasWiFi or other VegasWiFi Affiliates in a tweet or status update), your post may be used on or in connection with the Online Service or otherwise by VegasWiFi and VegasWiFi Affiliates. Also, both VegasWiFi and the third party may have access to certain information about you and your use of the Online Service and any Third-Party Service. Third-Party Services may also include third-party audience measurement services, including but not limited to Nielsen’s measurement software that is used for market research. More information about Nielsen’s measurement software and your choices regarding Nielsen’s measurement is available at http://www.nielsen.com/digitalprivacy.
6. DATA SECURITY AND MONITORING
VegasWiFi takes reasonable measures to protect VegasWiFi-Collected Online PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and VegasWiFi does not guarantee the security of your information collected through the Online Service.
7. INTERNATIONAL TRANSFER
8. CHILDREN’S PRIVACY
The Online Service is intended for a general audience and not directed to children less than 13 years of age. VegasWiFi does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act ("COPPA") ("Children’s Personal Information") in a manner that is not permitted by COPPA. If we obtain actual knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
9. ACCESSING AND CHANGING INFORMATION
VegasWiFi may allow you to delete, correct, or update some VegasWiFi-Collected Online PII, and potentially certain other information about you (e.g., profile and account information) by contacting a Customer Care representative or by signing into your VegasWiFi online account. VegasWiFi will make good faith efforts to make requested changes in VegasWiFi’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from VegasWiFi’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
10. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS
A. Tracking Technologies Generally.
Browser cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to HTML5 cookies, or other Tracking Technologies. Please be aware that if you disable or remove these technologies, some parts of the Online Service may not work and that when you revisit the Online Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some app-related Tracking Technologies can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to digital platforms or other online services you visit. Like many online services, VegasWiFi currently does not alter VegasWiFi’s practices when VegasWiFi receives a “Do Not Track” signal from a visitor’s browser.
B. Analytics and Advertising Tracking Technologies.
For Online Services, you may have the option to choose whether to receive some Online Interest-based Advertising by submitting opt-outs. Some of the third parties and Vendors that perform advertising-related services for us related to our Online Service and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Online Interest-based Advertising, including use of Cross-device Data for serving ads, visit aboutads.info/choices/, and youradchoices.com/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, see optout.networkadvertising.org/. Please be aware that, even if you are able to opt out of certain kinds of Online Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Online Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non- browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may no longer be effective. VegasWiFi supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks VegasWiFi directly engages to serve you Online Interest-based Advertising will do so as well, though VegasWiFi cannot guaranty their compliance. VegasWiFi is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Managing Cookie Preferences
D. Mobile Apps.
With respect to VegasWiFi’s mobile applications (“Mobile App”), you can stop all collection of data generated by use of the Mobile App by uninstalling the Mobile App. You may also be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the Mobile App’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to WiFi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the following links depending on which device you use:
- For Android 6.0 and above: https://support.google.com/googleplay/answer/6270602?hl=en
- For earlier versions of Android: https://support.google.com/googleplay/answer/6014972
You can opt out of receiving certain promotional communications (e-mails or text messaging) from VegasWiFi at any time by (i) for promotional e-mails, following the instructions provided in e-mails to click on the unsubscribe link, or by changing your marketing communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from VegasWiFi to text the word, “STOP”; and (iii) for Mobile App push notifications turn off push notifications on the settings of your device and/or the Mobile App, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, VegasWiFi may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or VegasWiFi’s ongoing business relations.
F. Cross-Device Data.
To learn more about how you can exercise certain choices regarding Cross- device Data for Online Interest-based Advertising regarding the DAA’s Online Interest-based Advertising choices.
G. Nevada Residents.
12. CONTACT VEGASWIFI