Privacy Policy

right-dots Our Privacy Policy right-dots

Effective Date: January 1, 2020
Last Updated: January 1, 2020

Penn National Gaming, Inc. (“Penn National”, “Us” or “We”) has produced this Privacy Policy to explain our practices regarding the gathering, use, and sharing of personal information. This Privacy Policy applies to this website and all of the products, services, websites, mobile applications, social media services, of the properties and services owned, managed or operated by us, our subsidiaries, or our partners on our behalf in the United States, unless otherwise indicated. Where additional detailed information is needed to explain our privacy practices, we post supplementary privacy notices to describe how personal information is processed.

We value your trust and respect your confidentiality. As a general practice, we do not provide any online information, or any information gathered through forms, applications or other means to outside third parties, except as otherwise designated in this policy. We do not sell or rent any information gathered online, or in individual property players’ clubs, to any outside organization.

This Privacy Policy will tell you what information we collect about you, when we may disclose such information to third parties, and about your use of the websites and services. We urge you to read this Privacy Policy carefully.

LIST OF TOPICS COVERED

    Collection of Personal Information

    Biometric Information

    Collection of Aggregated Information

    Sharing of Personal Information with Our Third Party Business Partners and Alliances

    Disclosure of Information

    Non-Personal Information

    Cookies and Web Beacons

    Targeted Advertising; How To Opt-Out

    Security

    Links

    Age Policy & Legal Disclaimers

    Changes

    Business Transitions

    Access to Your Personal Information

    California Privacy Rights: California Consumer Privacy Act

    California Privacy Rights: Shine the Light

    Nevada Opt-Out

    Contacting Penn National

 

Collection of Personal Information

We do not collect personally identifiable information about visitors except when visitors specifically provide such information on a voluntary basis. Such personally identifiable information may be gathered in registrations, applications, mobile applications, information requests, reservations, RSVPs, online purchases, online surveys, social media services and in some instances in the process of utilizing offers from our third party strategic partners and alliances.

We collect the following categories of personal information:

  • Identifiers: First and last name, home or other physical address which includes the name of a street and the name of a city or town, email address, telephone number, social security number, driver’s licenses number, passport number, license plate number, age, and identifiers that allows a specific person to be contacted either physically or online;
  • Player Information: Account number, Universal Player ID, and DAP Info;
  • Device Information: System information, usage, and location data;
  • Transaction Information: Bank account information, reservation information, and purchases;
  • Social Media Information: Facebook and Twitter information;
  • Information concerning a person collected from the person through our website and maintained by us in combination with an identifier in a form that makes the information personally identifiable.

We may use personally identifiable information for the following general purposes:

  • Contacting an account holder regarding account status,
  • Make changes to the account agreement, discounts, promotions, and
  • Offer products and other matters relevant to the service and/or the information collected.

Additionally, we may share your information, whether individually or in the aggregate, with our subsidiaries and affiliates, and in certain cases with selected outside third party partners and alliances for marketing or promotional purposes or to improve the products or services offered by us and our subsidiaries and affiliates.

We value opinions and comments from our visitors and we may conduct online surveys or issue invitations for such. We also offer an online Guest Comment form. These surveys are entirely optional for all website visitors. Usually the information from such surveys is aggregated and used for improving our products, services and operations and those of our subsidiaries and affiliates. In other cases, we will use the identifying information as a vehicle for responding to an individual question or comment.

Biometric Information

Penn National may collect personally identifiable information about you that includes biometric data, such as digital photographs, facial recognition data, and other biometric information (collectively, “Biometric Data”). We may collect this Biometric Data using technological means, such as identification document scanners, digital cameras, and facial recognition scanners, either in person or via your device.

In each case, we only use these technologies as permitted by applicable law. Penn National manages the security and confidentiality of Biometric Data to protect it from unauthorized access, use, disclosure or alteration. Penn National will not use your Biometric Data for marketing purposes or share your Biometric Data with third parties for such third parties’ own marketing purposes. Penn National complies with all local privacy laws in the collection and processing of Biometric Data.

We do not use facial recognition in the state of Illinois or where otherwise prohibited.

Collection of Aggregated Information

Survey participants are anonymous unless otherwise stated in the survey. We reserve the right to perform statistical analyses of visitors’ behavior and characteristics in order to measure interest in and use of the various areas of the website. We may provide aggregated data from these sources to third parties for purposes of research and evaluation.

Sharing of Personal Information with Our Third-Party Business Partners and Alliances

We may share your personal information with our business partners and alliances related to specific marketing efforts and purposes.

When we provide personal information to our third-party business partners and alliances, we require them 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. If you do not want us to share your personal information with third parties for marketing purposes, you may opt-out of such sharing by notifying us in accordance with the “Opt-Out” section located below.

We also share information with our service and analytics providers to provide you with our services.

Disclosure of Information

Although you may request to Opt-Out of sharing personal information with third parties for marketing purposes (see Opt Out section below), we may still disclose personal information to third parties in our sole discretion in the following situations:

  • if you enroll in any of our Responsible Gaming exclusion programs;
  • for non-marketing purposes, such as processing and fulfilling reservations or purchases;
  • to the extent such disclosure is mandated to comply with a court order or with a subpoena, search warrant or other valid legal process;
  • to comply with requests of government or law enforcement entities or legal, regulatory or administrative requirements of other governmental authorities;
  • to protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • to satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • to enforce the Terms of Service or Use of any of our websites, applications or services;
  • to prevent imminent physical harm or threats to public safety;
  • to third-party vendors that perform functions such as credit card transactions;
  • to prevent fraud;
  • to engage in debt collection;
  • to keep your credit card on file for future purchases, unless you tell us not to;
  • to ensure minors do not unlawfully enter our facilities;
  • otherwise with consent or in our discretion if we believe in good faith that disclosure is necessary or advisable.

Non-Personal Information

Even if you do not provide information to us, we may collect non-personal information about your use of our website, special promotions and other services.

Cookies and Web Beacons

Non-personal information (for example, domain names and IP addresses) and data may be automatically collected through the standard operation of our internet servers or at our discretion through the use of "cookies." "Cookies" are small text files we can use to recognize repeat visitors, facilitate a visitor's ongoing access to and use of the website, track usage behavior and compile aggregate data that can allow content and speed of access improvements and targeted offers. We do not link non-personal information from cookies to personally identifiable information without your permission and do not use cookies to collect or store personal information about you.

Cookies are not programs that download onto a visitor's system and damage files (such as, viruses or worms) or send information to third parties about websites visited (such as, spyware). Generally, cookies work by assigning a unique number to the visitor that has no meaning outside the assigning website.

If a visitor does not want information collected through the use of cookies, there is a simple procedure in most browsers that allows the visitor to deny or accept the cookie feature. However, visitors should note that cookies may be necessary to provide them with certain features (e.g., customized delivery of information) available on our websites.

We may also use other standard Internet technologies, such as flash technologies, web beacons or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of our websites. For example, we may include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information obtained with such technology enables us to customize the services offered and measure the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through the websites.

Targeted Advertising: How To Opt-Out

We may license technology to serve advertisements on our websites, mobile apps or related digital services, and within their content as that content is served across the Internet. In addition, we may use third party network advertisers to serve advertisements and third-party analytics vendors to evaluate and provide us with information about the use of our websites and related digital services and viewing of our content. We do not share personally identifiable information with these third parties, but ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own cookies, pixel tags and similar technologies on your device and they may otherwise collect or have access to information about you, including usage information. We and our network advertisers may target advertisements for products and services in which you might be interested based on your visits to both our digital offerings and other web sites or digital services. We may use a variety of companies to serve advertisements.

If you prefer to not receive targeted advertising, you can opt-out of some network advertising programs that use your information. To do so please visit the NAI Opt-Out Page: http://www.networkadvertising.org/choices. Please note that even if you choose to remove your information (opt-out), you will still see advertisements while you are browsing online. However, the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

While we take reasonable steps to protect the privacy of our online users, we cannot promise that the current limitations of our online applications or programming will address every browser setting or honor every personal browser preference. In particular, our systems do not at this time have the necessary programming to honor “Do Not Track” or “DNT” browser signals. Please return to this privacy policy in future for further updates on this topic.

Security

We have in place certain commercially measurable technological and procedural security measures in an attempt to protect and safeguard the security of the personal information provided by our visitors. Strict measures will be taken to protect against unauthorized access, alteration, or dissemination of personal information. Despite these efforts, please understand that no system is perfect or can guarantee that unauthorized access or theft of data might not occur.

For features on our websites that require a login or password, it is important for you to protect against unauthorized access to your password and your computer. Be sure to sign off when finished using a shared computer.

We may have links to outside websites. By accessing another website from our website, you hereby release us from any and all liability for your use of such link and website. We are not responsible for the content that appears on these other websites. We have no control over the content of outside websites. Once you access another website, be aware that we are not responsible for the privacy practices of such other websites. You should always use extreme caution when disclosing private information to such websites. We encourage you to look for and review the privacy policy of each and every website that you visit through a link or advertisement. This Privacy Policy applies only to information collected by us and our subsidiaries and affiliates, unless otherwise indicated. In the case of any digital “play for fun” social gaming opportunities we offer, this privacy policy will apply regardless of the platform or site where the games actually are hosted or played.

This website is intended only for users over the age of 21. Please leave this website if you are under the age of 21. Exception is made in the case of racing and pari-mutuel operations, where wagering may be permissible by law to those 18 years old and older. By continuing, you hereby release us, our subsidiaries and affiliates, and the creators of the website from any and all liability for your use or access to the website.

Under penalty of law, persons under 21 years of age will not be allowed to loiter on casino or slots property or participate in any gaming activity and persons under the permissible age will not be allowed to loiter on the property or participate in any racing or pari-mutuel activity. We have the right to ask for proper ID from individuals while they are on the property.

We will not rent hotel rooms to persons under the age of 21. Any contests, activities, or programs promoted are strictly limited to people over 21, unless otherwise indicated.

We strongly support parental control of the internet and, if you are a parent and do not want your children viewing this website, consult the following filtering software companies, such as: Net Nanny and Cybersitter. Net Nanny and Cybersitter are third-party service providers that are not affiliated with us or any of our subsidiaries or affiliates and we do not assume any obligation with respect to the services provided by such providers.

Except as provided above with respect to legal racing and pari-mutuel operations for persons 18 years or older, we do not knowingly or intentionally collect any personally identifiable information from, or market to or target, individuals under the age of 21.

We reserve the right to amend this Privacy Statement at any time, so please review it frequently. We may make non-significant changes to the Privacy Policy, not affecting how your personally identifiable information is collected, used or disclosed, of which we may not notify users. If we decide to change our Privacy Policy materially, we will post those changes to this Privacy Policy at least 30 days prior to the effective date of the change so that you are aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. Continued use after the new Privacy Policy has taken effect constitutes acceptance of and consent to the new Privacy Policy. If you do not agree to the new terms, you should stop using our websites and related services, in which case we may continue to use your personal information in a manner consistent with the policy in effect at the time the information was gathered.

This Privacy Statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights in or on behalf of any other person or entity.

Business Transitions

If we or one of our subsidiaries, affiliates or partners is acquired by or merges with another company, the assets of the respective website(s), including personal information, will likely be transferred to the new company.

Access to your Personal Information

If you are a Nevada resident or a resident of another state with similar privacy rights, you have the right to review and request changes to the personal information we have collected about you through our websites or online services.

You can access the personal information you submit to our website via a Players’ Club Player Profile account at any time. If you wish to update the personal information you have submitted to us, you may do so by signing into your account on the applicable website or app, or by sending an email to Corporate@pngaming.com with your request.

You can access the personal information you submit through our website on your online “play for fun” account at any time. If you wish to update the personal information you have submitted to your online “play for fun” account, you may do so by signing into your “play for fun” account or by sending an email to support@play4funnetwork.com with your request.

California Privacy Rights: California Consumer Privacy Act

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information
When California Consumers access the Penn National websites, purchase Penn National products, contact Penn National, or visit one of our physical locations, we collect the following Personal Information.

Categories of consumer’s Personal Information collected Business or commercial purposes for which the information was collected Categories of sources from which that information was collected Categories of third parties with whom the business shares personal information
Identifiers
  • Real Name
  • Alias
  • Post Address
  • Email Address
  • Phone Number
  • Signature
  • Account Name
  • Social Security Number
  • Unique Personal Identifier
  • Online Identifier
  • If you enroll in any of our Responsible Gaming exclusion programs;
  • For non-marketing purposes, such as processing and fulfilling reservations or purchases;
  • To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To engage in debt collection;
  • To keep your credit card on file for future purchases, unless you tell us not to;
  • To ensure minors do not unlawfully enter our facilities;
  • To provide you with the products and services you request, view, engage with, or purchase;
  • To communicate with you regarding your account or transactions with us;
  • To send you offers and promotions for our products and services;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies.
This information is collected directly from you. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
Other Personal Information (Financial Information)
  • Bank Account Number
  • Credit Card Number
  • If you enroll in any of our Responsible Gaming exclusion programs;
  • For non-marketing purposes, such as processing and fulfilling reservations or purchases;
  • To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To engage in debt collection;
  • To keep your credit card on file for future purchases, unless you tell us not to;
  • To provide you with the products and services you request, view, engage with, or purchase;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies.
This information is collected directly from you. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
Commercial Information
  • Products or service purchased, obtained or considered
  • Purchasing or consuming histories or tendencies
  • If you enroll in any of our Responsible Gaming exclusion programs;
  • For non-marketing purposes, such as processing and fulfilling reservations or purchases;
  • To protect and defend us, or our subsidiaries and affiliates, and all of their or our officers, directors, employees and agents in connection with any legal action, claim or dispute;
  • To satisfy any contractual obligation to indemnify our contractors, business partners or alliances, or other third parties in connection with any legal action, claim or dispute;
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To engage in debt collection;
  • To keep your credit card on file for future purchases, unless you tell us not to;
  • To ensure minors do not unlawfully enter our facilities;
  • To provide you with the products and services you request, view, engage with, or purchase;
  • To communicate with you regarding your account or transactions with us;
  • To send you offers and promotions for our products and services;
  • To provide you with targeted advertising based on your activity on our sites;
  • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies
This information is collected directly from you or by logging our interactions with you. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
Biometric Data
  • Imagery of face
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
We collect this information from you directly or through our interactions with you. Service providers and law enforcement (if necessary).
Internet or Electronic Network Activity Information
  • Browsing history
  • Search history
  • Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
  • Internet Protocol address
  • Device ID
  • Cookies
  • Unique Personal Identifier
  • Online Identifier
  • Beacons
  • Pixel Tags
  • Mobile Ad Identifiers
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To provide you with targeted advertising based on your activity on our sites;
  • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies
We collect your internet or other electronic network activity information from your interactions with our website. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).
Geolocation Data
  • Location information
  • Device location information
 
  • To enforce the Terms of Service or Use of any of our websites, applications or services;
  • To prevent fraud;
  • To send you offers and promotions for our products and services;
  • To provide you with targeted advertising based on your activity on our sites;
  • To operate, understand, optimize, develop, or improve our sites, applications, products, services and operations;
  • To detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • To debug, to identify and repair errors that impair existing intended functionality; and
  • To investigate and prevent activities that may violate our policies
We collect your geolocation information from your interactions with our website. Affiliates, gaming partners, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

Individual Rights

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that Penn National disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
     a. Category of personal information collected,
     b. Categories of sources from which that information was collected,
     c. The business or commercial purpose(s) for which the information was collected,
     d. The categories of third parties to whom Penn National sold or disclosed the category of personal information for a business purpose, and
     e. The business or commercial purpose for which Penn National sold or disclosed the category of personal information.

Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
     a. Specific pieces of Personal Information collected about you.

Penn National does not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless Penn National determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

Right of Deletion
You have the right to request that Penn National and our service providers delete any Personal Information about yourself that Penn National has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Submitting Requests
You can submit your request by calling us at 866-978-5118. You may also submit a request through a webform available by emailing us at CCPA@pngaming.com.

Verifying Requests
Penn National provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. Penn National must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. Penn National reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Authorized Agent
You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, Penn National requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Penn National. Failure to do so may result in Penn National denying your request.

Right to Equal Service
Penn National will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

  • Denying goods or services to you.
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
  • Providing a different level or quality of goods or services to you.
  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

California Privacy Rights: Shine the Light

Under California’s “Shine the Light” law, California residents who provide certain personal information in connection with obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information please contact us at the information provided below. We will provide the requested information to you pursuant to the contact information provided to us.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Nevada Opt-Out

Nevada residents have the right to opt-out of the sale of their data. While we do not currently sell personal information to third parties, you can submit an opt-out request to prevent any future sales of your personal information in the event we begin selling data in the future. To submit your opt-out request, please email us at corporate@pngaming.com. Please note that we will need to verify your identity in order to process this request.

If you wish to opt-out of continuing to receive solicitations from us, or do not want us to continue to share your personal information with our third-party business partners and alliances for marketing purposes, please email us with your instructions at corporate@pngaming.com. Please note that any information previously shared with third parties prior to receipt of your request may result in continued communications from those parties pursuant to their own privacy policies.

Even if you registered your telephone number on a do-not-call list, certain exemptions may allow us to contact you by telephone. However, to ensure our customers' preferences are honored, we also maintain our own internal do-not-call list. If you would like to opt-out of receiving telemarketing sales calls from us by adding your telephone number to our internal do-not-call list, please email us at corporate@pngaming.com.

Contacting Penn National

If you have a privacy concern or question regarding us or this Privacy Policy and you cannot satisfactorily resolve it through the use of our website, you should contact us through one of the following methods:

Send an email to corporate@pngaming.com

By Mail:
Penn National Gaming, Inc.
825 Berkshire Blvd.
Wyomissing, PA 19610
Attn: Legal