PRIVACY POLICY 

Last Updated: August 20, 2014.

SBEEG Holdings, LLC (“sbe”), together with controlled affiliates (collectively, “we”, “us” or “our”), is a global hospitality and entertainment company comprised of a thriving collection of award-winning hotels, casinos, residences, restaurants and nightlife destinations (the “Venues”).  As a part of our operations, we gather certain types of information from and about online visitors and users through various websites.  This Privacy Policy applies to information collected from and about visitors and users (“you”) through various websites operated by us (either directly or through our service providers) their respective web pages, sub-domains, and any other websites (and subdomains thereof) that we operate and that link to this Privacy Policy (collectively, the “Website”).  This Privacy Policy also applies to information collected from or about you through email and other electronic submissions and communications between you and the Website.   We have adopted this Privacy Policy to describe the types of information that we collect from or about you, how and for what purposes that information may be used or disclosed, how you can make certain choices about what kinds of information is collected and how it is used, and the steps we take to protect that information.

This Privacy Policy does not apply to information collected offline or through any means other than through the Website, or to information collected by any other company or third-party site, application or content (including advertising) that may link to or be accessible from the Website.  Certain transactions and services offered while visiting the Website may be processed or provided by service providers and other strategic partners, even though it appears that you may not have left the Website (e.g., reservations, know-your-customer, payment processing, hosting).  In such cases, these third parties receive information solely for the purpose of your transaction with us, and not for their own independent use.

The Website is operated from the United States in accordance with laws of the United States and visitors to the Website should be aware that the laws of the United States may differ from those of your country of residence.  If you are located in the European Union or elsewhere outside of the United States, your use of this Website is at your own risk and initiative and you, not us, are responsible for compliance with any applicable local and national laws. By using this Website, participating in any Website activities, and/or providing us with your personal information, you: (i) consent to the transfers and processing of any information you provide to the Website; (ii) acknowledge that U.S. law provides a lower standard of protection for personal data than the laws of various countries including, but not limited to, the European Union; and (iii) understand that this Website will deal with your information in accordance with our Privacy Policy and U.S. law. Consequently, you hereby waive any claims that may arise under the laws and regulations that apply to you in any other country or jurisdiction.

Please read this Privacy Policy carefully, which includes terms required for compliance with California Civil Code Section 1798.83 (click here to go directly to the “Your California Privacy Rights” section below).  WHEN YOU ACCESS OUR WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, DO NOT CONTINUE TO ACCESS OR USE OUR WEBSITE.  This Privacy Policy, together with the Terms of Use posted on our Website, sets forth the general rules and policies governing your use of our Website. Depending on your activities when visiting our Website, you may be required to agree to additional terms and conditions. We encourage you to review this Privacy Policy frequently, as it may change from time to time. Click here to go directly to the “Changes to This Privacy Policy” section below which describes how changes to this Privacy Policy will be communicated to you and made effective.

A.            TYPES OF INFORMATION COLLECTED ABOUT YOU AND HOW IT IS COLLECTED

                1.  Information You Provide

                2.  Automatically-Collected Information

                3.  Cookies and Other Tracking Technologies

B.            HOW WE USE YOUR INFORMATION

C.            HOW WE SHARE YOUR INFORMATION

D.            HOW WE RESPOND TO DO NOT TRACK SIGNALS

E.            INTEREST-BASED ADVERTISING

F.            ANALYTICS

G.           PUBLIC FORUMS

H.           WIRELESS MARKETING SERVICES

I.             CHILDREN

J.             SECURITY

K.            OTHER WEBSITES/LINKS

L.             YOUR CHOICES AND ACCESS

M.          YOUR CALIFORNIA PRIVACY RIGHTS

N.           CONTACT US

O.           CHANGES TO THIS PRIVACY POLICY

A. TYPES OF INFORMATION COLLECTED ABOUT YOU AND HOW IT IS COLLECTED

We and our service providers collect various types of information from and about you, including:

  • “Personal information” or “personally identifiable information,” which is information by which you may be personally identified or contacted, including, for example, your name, email address, telephone numbers, company affiliation, title, physical address, screen names, credit card details (including the three or four digit security code on the back of your credit card), bank account or other payment information, credit information, birth date, driver’s license number, social security number, passport number, frequent flyer or other affinity program numbers, employment information, and any other information by which you may be personally identified. Personal information also may include information that may not be personally identifiable standing alone (for example, your age), but which may become personally identifiable when combined with personal information (for example, your age combined with your name).
  • “Non-personal information,” which is information that is about you but which does not identify you individually and is not linked to any personal information, including: information regarding your computer, devices and Internet connection (such as your IP address, your computer or device type and its capabilities and features, your browser type, the operating system or platform you are using, your general geographic location, and the name and location of your Internet Service Provider), information regarding your use of our Website (including the referring page and the exiting website, clickstream data, the search terms you enter on the Website, your movement within and interaction with the Website, including what pages you look at, and the time, date, and duration of your visit to the Website) and traffic patterns relating to the Website.  Non-personal information may include personally identifiable information that has been de-identified, or in other words, rendered anonymous.  Non-personal information also may be aggregated with non-personal information about others.

We and our service providers may collect this information through various means, including: (a) directly from you when you provide it to us, for example, via forms that you fill out on the Website, through emails and other communications and information that you submit via the Website, and through your other activities on the Website; (b) automatically as you navigate through and interact with the Website, including via cookies, pixels, beacons, and other tracking technologies; and (c) from third parties, including without limitation our service providers.

  1.                    Information You Provide

The information we and our service providers collect may include the following types of information that you provide:

  • Information you provide when you register for the Website, make a purchase, participate in a service or offering made available on the Website, or make a reservation, including without limitation your contact information (such as your name, address, email address, phone numbers), your company name, and title and address, your screen name or username, and your payment information (such as your credit card details, bank and bank account routing information, or other information);
  • Your demographic information, such as your age, gender, marital status, number of children, and nationality;
  • Your travel-related information, such as your frequent flyer number, airlines, rental car providers, passport information, and travel history;
  • Information relating to your reservations, visit or stay at our Venues, including the Venues you have visited, your arrival and departure dates, special requests made, spa and dining reservations, your guest preferences, vehicles you may bring to the Venues, and your transactions and purchases;
  • Certain sensitive health information that you choose to share with us (such as allergy information or other health conditions that impact your guest preferences or special requests when visiting one of our Venues);
  • Details about events or meetings that you plan with us, such as the date of the event, the guest list, and information about the guests at your event;
  • Information you provide to sign up for the CODE Program (such as your name, email address, physical address, mobile phone number, gender, zip code, birth date, social media handles, and social blogs) and information needed to administer the CODE Program;
  • Certain personal and sensitive information that you may provide online in connection with casino credit applications and gaming-related aspects and benefits of the CODE Program, including without limitation your social security number, certain financial information (including your bank and bank account information, your annual income, and other personal financial information), employment information and history, other credit information, and a copy of or the information from official government identification documents, including without limitation, a driver’s license, passport or non-resident alien identification card for identity verification purposes;
  • Information that you share in response to surveys and other market research;
  • Information that you post to public areas on our Website, that you include in an email, general comment, or recommendation posted on or sent through on our Website, as well as records and copies of that correspondence (including email addresses);
  • If you choose to log into the Website through social sign ins (such as Facebook Connect), information collected from your social media account consistent with your settings within the applicable social media service, such as photos, name, gender, contact information, and other information;
  • Resumes and applications for employment at the Venues, including any personal and sensitive information that you provide therein;
  • Your communications preferences; and
  • Other personal information that you choose to provide to us.

Whether you provide this information is your choice; however, please bear in mind that in many instances personal information is required for you to participate in a particular activity, for us to provide a certain service or benefit to you, or for you to gain access to certain features, services or content on our Website.  If you elect not to provide us with certain personal information, you may not be able to participate in a particular activity, realize a benefit we may offer, or gain access to certain content, functionalities or services.

 2.                    Automatically-Collected Information

When you visit and as you navigate through and interact with the Website, we, our service providers and third parties may automatically collect information about your visits to our Website, your equipment, and your browsing action and patterns and your activities on the Website. This information may include, but is not limited to:

  • Details of your visits to our Website and the resources that you access, such as traffic data, location data, logs and other communication data, the third-party website from which your visit originated, clickstream data, the search terms you use on our Website, your movement within and interaction with the Website, including what pages you look at, and the time, date, and duration of your visit to the Website.
  • Information about your computer or devices and Internet connection, such as your IP address, your general geographic location, your computer or device type and its capabilities and features, the operating system or platform you are using, your browser type, and your Internet Service Provider.
  • Information about traffic patterns, number of visits to certain pages, visits from other websites or to third-party websites linked to the Website, and visitors’ use of particular services and interest in services, information or features of the Website.

Automatically-collected information often is statistical data that does not contain personal information.  We may share such aggregated data with third parties collectively and in an anonymous way. Automatically-collected information may contain personal information, however, or we or our service providers may maintain it or associate it with personal information collected in other ways or received from third parties.  Such information will be treated as personal information and used and shared as disclosed in this Privacy Policy.

 3.                 Cookies and Other Tracking Technologies

We, our service providers and other third parties may place “cookies” on our Website to collect certain information.  A “cookie” or “browser cookie” is a small data text file that can be stored on your computer’s hard drive or other device, if your web browser or device settings permit.  Certain features of the Website also may use local stored objects (or Flash Cookies) to collect and store information, including information about your preferences and navigation to, from, and on our Website.  Flash cookies are not managed by the same browser settings as are used for browser cookies.  Cookies may allow us and our service providers, for example,  to customize your experience and make your visit to the Website easier (for example, recognizing when you return, remembering your viewing preferences, enabling social sign ins, facilitating social sharing, and, if you are a registered user, remembering your password), measure activity on the Website, track conversions, target ads, and provide analytics. While some cookies are deleted when you close your browser, others remain even after you close your browsing session.

We, our service providers and other third parties also may use pixel tags, web beacons or clear gifs, which are tiny files with a unique identifier, similar in function to cookies, that are placed in the code of a web page or an email.  These technologies might be used, for example, to allow us and our service providers to track conversions, to send emails to you in a format you can read, to count users who have visited our Website, seen our ads, opened our emails or clicked on any links in our emails, to inform us what content and advertising is effective, to optimize the Website and its content, to reduce or eliminate messages sent to customers, to enhance Website usability, to provide you ads and other promotions and content that may be of interest to you, and to collect other information about you and your visit when you use the Website.  In addition, when you click on a link in an email, we or our service providers may record the individual response to allow us to customize our offerings to you.

We and our service providers may analyze the information derived from cookies, pixels and other technologies and match or combine that information with data provided by you or another party. We engage various service providers who may use unique identifiers, cookies, pixels, beacons, and other technologies to provide analytics and to deliver you advertisements and content that may be of interest to you.  For more information about interest-based advertising, click here to go to the “Interest-Based Advertising” section below, and for more information about analytics and our vendors, click here to go to the “Analytics” section below.  To the extent that our service providers are using pixels, cookies, beacons, or other tracking technologies, we do not control the use of those technologies or the resulting information, and we are not responsible for the policies of those companies.

Most web browsers are initially set to accept cookies.  If you prefer, you can set your web browser to refuse cookies (except Flash cookies). You may also delete a cookie manually from your hard drive through your internet browser or other programs.  For more information on how to manage cookies, see http://www.allaboutcookies.org.  For information about how to manage Flash cookies, see http://macromedia.com/support/documentation/en/flashplayer/help/setting_manager07html.  You also can learn more about opting out of our vendors’ and other advertisers’ use of cookies used to tailor ads and other content to you by visiting http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices.  Please keep in mind, however, that you may not be able to access the full functionality of our Website if cookies are disabled.

B. HOW WE USE YOUR INFORMATION

We may use and combine non-personal information (including aggregated information) for any lawful purpose.  In addition, we and our service providers may use personal information collected from or about you as described in this Privacy Policy for the purposes disclosed to you or as otherwise permitted or required by law, including:

  • To provide, track, and process the services, purchases and transactions that you request, including facilitating hotel accommodation, spa, dining, and entertainment reservations;
  • To process enrollments and applications, including casino credit applications as well as registration in, the administration of, and the award and redemption of benefits under the CODE Program;
  • To accommodate your preferences, to personalize and enhance your experience and the services provided to you at the Venues, and to improve the Venues and our services;
  • To validate your identity, to verify communications from you, and to respond to your emails, submissions, questions, comments, requests for information, and complaints and to provide customer service;
  • To manage, store and enhance guest data and preferences;
  • To send you important notices, such as communications about purchases, programs you have joined, and changes to our terms, conditions and policies;
  • To conduct customer satisfaction, market research or quality assurance surveys ;
  • To conduct market research and to develop new Venues and services;
  • To conduct and administer sweepstakes, prize draws and other contests;
  • To record gaming-related activity;
  • For marketing purposes, including without limitation interest-based advertising, other targeted promotions, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities;
  • To send you marketing communications about the products and services offered by our property owners, marketing partners and other third parties, including without limitation offers regarding residential sales opportunities;
    • To cross-reference, supplement and combine with other information that we or our service providers have acquired about you or may acquire about you through other sources, except where prohibited by applicable law or regulation (if any non-personal information is combined with personal information, the combined information will be treated as personal information pursuant to this Privacy Policy for as long as it remains combined);
    • To monitor, track, and analyze Website usage and trends, to personalize and improve the Website, and to increase the Website’s functionality;
    • To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Website;
    • To protect the security or integrity of our Website, the Venues and business;
    • To prevent fraud and other prohibited or illegal activities, to investigate and resolve disputes and problems, and to otherwise comply with applicable laws and regulations;
    • To enforce our Terms of Use and other contractual obligations; and
    • For any other purpose that is disclosed to you at the point of collection of the personal information, for any purpose for which you provide your prior consent, in other ways naturally associated with the circumstances in which you provided the personal information, and for any other lawful purpose.

Every computer and device that is connected to the Internet is assigned an Internet Protocol (IP) address.  When visitors request pages from our Website, our servers typically log their IP addresses. While we generally collect IP addresses for purposes of system administration, for Website optimization, Website security assessments, to report non-personal aggregate information to others, to track the use of our Website, and to get a sense of where our Website visitors are located, we reserve the right to use your IP address to personalize content on the Website and to identify you and to share that information as described in the “How We Share Your Information” section below.

C. HOW WE SHARE YOUR INFORMATION

We may share non-personal information with any third parties for any lawful purpose.  Unless otherwise prohibited by law, we may disclose personal information collected from or about you as described in this Privacy Policy to the following types of third parties and for the following purposes:

  • Affiliated Companies:  We may share your information with our parents, subsidiaries, affiliated companies, and other controlled affiliates (including casinos, hotels, restaurants and other business ventures that are licensed, owned, operated, and/or managed by us or our parents, subsidiaries, affiliated companies and other companies under common control), who may use personal information for any of the purposes disclosed in or consistent with the terms of this Privacy Policy (including without limitation those identified in the “How We Use Your Information” section above);
  • Property Partners:  We may share your information with owners of Venues that we manage but do not own, owners and operators of licensed Venues, and owners and operators of certain residential properties associated with or located in proximity to various Venues (as well as the respective designees of any of the foregoing), who may use personal information to provide you with services at or relating to the Venues, to provide you marketing information relating to real estate and other opportunities, and for any of the other purposes disclosed in or consistent with the terms of this Privacy Policy (including without limitation those identified in the “How We Use Your Information” section above).
  • Marketing Partners: We may share your personally identifiable information with our co-promotional partners and other business partners with whom we have marketing or other relationships for joint marketing purposes or such partners’ own marketing purposes.
  • Service Providers: We may share your information with our service providers who assist us by performing core services (such as reservations, hosting, billing, fulfillment, data storage, security, processing credit card payments, customer service, credit reporting, property management, customer relationship management, “know-your-customer,” accounting, auditing, processing insurance claims, investigating accident reports, administering sweepstakes, surveys, email  and mailing services, and delivering packages) related to the operation of the Venues, the provision of services at the Venues, the operation of the Website, the processing and fulfillment of reservations or product orders, and/or by making certain Website functionality available to our users.
  • Transactions: In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personally identifiable information collected from or about you provide, and other information concerning your relationship with us.  Any successor may use your information for the same purposes set forth in this Privacy Policy.
    • Legal: We reserve the right to use IP addresses to identify you and, where permitted or required by law or applicable regulation, we will provide any information about or relating to you, including any personally identifiable information about you, to third parties without your consent if we reasonably believe that such action is necessary to: (a) comply with a court order, subpoena or other legal or regulatory requirements; (b) otherwise fulfill a government request for information; (c) protect or defend our legal rights or property, our Venues, our Website, or other guests and online users; (d) respond to claims that any posting or other content of our Website violates the rights of third parties, including without limitation providing information necessary to satisfy the notice and counter-notice procedures pursuant to the Digital Millennium Copyright Act; (e) in an emergency, to protect the health and safety of our Website’s users or the general public; or (f) enforce compliance with our Terms of Use or other contracts.
    • To fulfill the purpose for which you provide it.
    • With your consent.

We will not disclose the amount of your specific gaming winnings or gaming losses to any third party unless required by applicable law or regulation.  For more information about how to opt out of receiving future promotional information from us or our affiliated companies, click here to go to the “Your Choices and Access” section below.

 D. HOW WE RESPOND TO DO NOT TRACK SIGNALS

Some web browsers may give you the ability to enable a “do not track” setting that is an HTTP header field indicating your preferences regarding tracking or cross-site user tracking.  This is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. The Website does not recognize web browser “do not track” signals at this time. We may work with third parties that use tracking technologies on the Website, including in order to serve tailored advertisements on our behalf and on behalf of other advertisers across the Internet. These companies may collect information about your activity on the Website and other websites over time, as well as your interaction with our advertising and other communications, and use this information to determine which ads you see on third-party websites and applications. For more information about this practice and to understand your options, please visit http://www.networkadvertising.org/  or http://www.aboutads.info.

 E. INTEREST-BASED ADVERTISING

We may allow third parties to collect information about your online activities on our Website through unique identifiers, cookies, pixels, beacons and other technologies (as described above).  These third parties include advertising networks that may use unique identifiers, cookies, pixels, beacons, and other technologies to track and collect information about your interests when you visit our Website and other websites or view or interact with one of the advertisements they place on various websites or mobile platforms.  The information gathered by these third parties is used to make predictions about your characteristics, interests or preferences and to display advertisements on our Website and across the Internet tailored to your apparent interests. We use Google’s Remarketing service with Google AdWords to show you our ads as you browse other websites around the Internet. The Remarketing service delivers our ads through the Google AdWords display network, which includes both Google.com pages and the sites of trusted publishers. Third-party vendors, including Google, use cookies (such as the DoubleClick cookie) to serve ads based on your past visits to the Website. Click here to read the Google privacy policy. You can opt out of Google’s use of cookies and/or customize Google display network ads by visiting the Ads Preferences Manager at https://www.google.com/ads/preferences/.  Alternatively, you can opt-out of Remarketing by visiting http://www.networkadvertising.org/.  If you want to permanently opt out of the DoubleClick cookie, you can install the DoubleClick opt out extension by clicking here.  Rocketfuel is another advertising network that we work with to show you our ads on other websites.  Click here to read Rocketfuel’s privacy policy and for more information about how to opt-out of the Rocketfuel cookie.  You also can learn more about how Rocketfuel uses cookies and your choices for opting out by clicking here or by visiting http://www.networkadvertising.org/ Other advertising networks also are members of the Network Advertising Initiative, which offers a single location to opt-out of ad targeting from member companies.  To learn more about interest-based advertising generally as well as your options for opting out, please visit http://www.networkadvertising.org/ or http://www.aboutads.info. Please keep in mind that even if you opt out of receiving ads tailored to your apparent interests, you will continue to see ads from online advertising networks.  However, those networks will not be able to apply any of your apparent ad preferences and the ads that you see therefore may be less relevant to your interests.

F. ANALYTICS

We engage service providers to provide analytics data for the purposes of understanding and optimizing web usage, for business and market research purposes, measuring conversion tracking, and measuring the effectiveness of our content and online advertising campaigns. These service providers may use cookies alone or in conjunction with unique identifiers, pixels, beacons and other tracking technologies to collect information about you when you use the Website.

For example, we use a tool offered by Google Inc. called Google Analytics to collect information about visitors’ use of our Website. For more information about Google Analytics and how it collects and processes data, please see “How Google Uses Data When You Use Our Partners’ Sites or Apps.” We use the information we receive from Google Analytics for a variety of purposes, including to collect information about visitors’ use of our Website and to track Website performance, including without limitation clickstream data, Website traffic data, basic Website impression and user demographics information.  We do not combine the information collected through the use of Google Analytics with your personal information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google Analytics uses cookies by clicking here.  You can prevent Google Analytics from recognizing you on return visits to this Website by disabling cookies on your browser, as described here. If you do not want your Website visit data reported by the Google Analytics JavaScript, you also can install the Google Analytics opt-out browser add-on.  This add-on instructs the Google Analytics JavaScript to prohibit sending visit information to Google Analytics, but does not prevent information from being sent to the Website itself or in other ways to other website analytics services.  Click here if you would like to learn more about the Google Analytics opt-out browser add-on, and click here to install the opt-out browser add-on.  We also may receive reports and analytics from the advertising network Rocketfuel, including without limitation regarding Website optimization, traffic data, and the effectiveness of our online advertising.  Click here to go to the “Interest-Based Advertising” section and to learn more about Rocketfuel.  We also may use pixels such as the Floodlight pixel, which interacts with the DoubleClick cookie, to measure the effectiveness of our online campaigns and for conversion tracking.  Click here to learn more about the Floodlight pixel, and click here to go to the “Interest-Based Advertising” section to learn more about the DoubleClick cookie.  If you want to permanently opt out of the DoubleClick cookie, you can install the DoubleClick opt out extension here 

G. PUBLIC FORUMS

We may offer chat rooms, blogs, message boards, bulletin boards, or similar public forums where you and other users of our Website can communicate.  Unless otherwise required by applicable law or regulation, the protections described in this Privacy Policy do not apply to information (including personal information) that you post to these public forums. We may use personally identifiable and non-personal information about you to identify you with a posting in a public forum. Any information you share in a public forum is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Website.

 H. WIRELESS MARKETING SERVICES

We may provide you with the opportunity on the Website to register for special promotions, services, news, programming, and information delivered via text messaging and other wireless devices such as mobile phones and, in the event we do so, you may be required to provide your express consent to receive such information as required by applicable law, either by registering on a Website or via your wireless device (or both).  To receive these communications, we may require you to consent again in a subsequent confirmation message.  Such services and promotional opportunities may be provided by us or by our service providers or strategic partners.  The information requested as part of the online registration process may include your wireless telephone number or email address, but only if specifically requested, and your carrier’s name.  Additional information may be requested for specific services, programs, promotions, offers, and information, such as your preferences regarding goods or services, choices of music or artists, or other similar survey information.  Depending on the promotion, we may also collect an email address or other contact information, and depending on the information collected, you may also be required to confirm your agreement to this Privacy Policy and the Terms of Use.

If you register for wireless marketing services, you understand and agree that you will be charged by your wireless carrier for all messages sent to you.  Standard messaging rates will apply, unless noted otherwise.  Under no circumstances will we be responsible for any wireless email or text messaging charges incurred by you or by a person that has access to a your wireless device, telephone number, or email address.

You may cancel one or more services via your wireless device at any time by using the unsubscribe mechanism provided by at the time the message is sent, or by sending a text message that says “UNSUBSCRIBE,” “STOP” or such other code referenced in the message.  If you unsubscribe, the applicable service(s) will be terminated and will cancel your previous opt-in.

You understand, acknowledge and agree that we may, in our sole discretion and without liability to any user, terminate any offer of any specific wireless marketing service or all wireless marketing services at any time without advance notice.  We may provide notice of terminations or changes in services on this Website.

 I. CHILDREN

The Website is a general audience site, and the features, programs, promotions and other aspects of our Website requiring the submission of personally identifiable information are not intended for anyone under 21 years of age.   If you are under 21, you may not access, use or register on the Website.  We do not knowingly collect personally identifiable information from individuals under the age of 18. If you are a parent or guardian of an individual under the age of 18 and believe he or she has disclosed personally identifiable information to us without your permission, please contact us at privacy@sbe.com or otherwise as provided in the “Contact Us” section below.  A parent or guardian of a child under the age of 18 may request deletion of such child’s personally identifiable information as well as prohibit the use thereof.

J. SECURITY

We take reasonable steps to protect against the loss, misuse and alteration of the information under our control, including Secure Sockets Layer (SSL) technology to encrypt the transmission of non-public personally identifiable financial and transaction information over the Internet, provided you are using an SSL-enabled device.  We also utilize other reasonable security measures such as firewalls, security patches, and anti-virus programs, to protect non-public personally identifiable information. Despite these efforts, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks), and we cannot and do not guarantee or warrant the security of any information you disclose or transmit to us via the Internet, and are not responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information. For your own privacy protection, we recommend that you do not include any non-public personal or sensitive personal information such as passwords, social security numbers, credit card details, or bank account information, in any emails that you send to us. We will not contact you by email or text message to ask for such information.

K. OTHER WEBSITES/LINKS

Our Website may link to third-party websites that we do not control or maintain.  Be aware that those third-party websites collect information and operate according to their own privacy practices. We are not responsible for the privacy practices employed by any third-party website. We encourage you to note when you leave the Website and to read the privacy statements of all third-party websites to understand how they collect, use and disclose personal information before submitting any personally identifiable information to those websites.

L. YOUR CHOICES AND ACCESS

If you have registered on the Website, or are a member of the CODE Program, you can login to your account to change or update certain information and preferences to keep such data accurate, complete and up-to-date. You also can contact us as described in the “Contact Us” section below to update or correct certain personal information.

In addition, as described above, you can set your web browser to refuse browser cookies (but not Flash cookies). For more information on how to manage browser cookies, click here. For information about how to manage Flash cookies, click here. Please keep in mind, however, that you may not be able to access the full functionality of our Website if cookies are disabled.

In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, you can agree to receive some communications but not others.  At any time, you also may opt-out of receiving future commercial emails from us by following the “Unsubscribe” instructions contained in any commercial emails that you receive from us.   You also may contact us as described in the “Contact Us” section  if you want to opt-out from receiving future commercial correspondence, including marketing emails, from us.  We will respond to your request and, if applicable and appropriate, make the requested change in our active databases within a reasonable timeframe. Please remember that we may not be able to fulfill certain requests while allowing you access to certain benefits and features.  Even if you unsubscribe from our marketing communications, you may continue to receive certain communications from us, such as transactional, customer service or other relationship messages, messages about your account and profile, and emails in response to communications or requests for information that we receive from you.  Please also note that we may not be able to remove your personal information from the databases of third parties to whom we already provided your personal information as of the date of your opt-out request.

M. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes.  We are only required to respond to a customer request once during any calendar year.  To make such a request you should send an email to privacy@sbe.com with the subject heading “California Privacy Rights.”  In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response.  We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

N. CONTACT US

If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise the choices discussed above, please contact us (a) by email at privacy@sbe.com, or (b) by postal mail at SBEEG Holdings, LLC, 5900 Wilshire Blvd. #3100, Los Angeles, CA 90036, Attn: General Counsel. 

 O. CHANGES TO THIS PRIVACY POLICY

We may change or update this Privacy Policy in the future.  You can identify the date that this Privacy Policy was last updated by looking at the date at the top of this Privacy Policy. Any revisions to this Privacy Policy will take effect upon posting to the Website.  We will notify you of any material changes to this Privacy Policy either by sending an email to the email address that you provided to us and/or by placing a notice on the homepage of the Website.  We encourage you to regularly review the current version of this Privacy Policy on the Website. Use of the Website following posted changes constitutes your acceptance of the revised Privacy Policy then in effect.