JC Hospitality Privacy Notice - Virgin Hotels Las Vegas

JC Hospitality Privacy Notice

Last Updated and Effective: March 1, 2025

We at JC Hospitality LLC (“JCH”, “us”, “our”, or “we”) are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your personal information, as well as how you can manage the personal information we collect. This Privacy Notice applies to your interactions with us or your use of our websites (https://virginhotelslv.com/) products, services, or features, either online or offline (collectively, our “Services”).

By using our Services, you acknowledge the terms of this Privacy Notice. If you do not agree to the terms of this Privacy Notice, please do not use our Services. If you do not understand, or if you have questions about, this Privacy Notice, please contact us before using, or continuing to use, our Services.

We reserve the right to change our Privacy Notice from time to time by posting the changes here. If we choose to amend this Privacy Notice, we will revise the Last Updated date at the top of this Privacy Notice when we post the updated version. We may also provide you with notice by prominently posting on our website, via email or both, if we make any significant changes to this Privacy Notice. We may also highlight those changes at the top of this Privacy Notice and provide a prominent link to it for a reasonable length of time following the change. Your use of our Services after we have informed you in one of these ways that we made changes to our Privacy Notice will mean that you have accepted those changes.

1. TYPES OF INFORMATION WE COLLECT………. 2

2. HOW WE COLLECT PERSONAL INFORMATION………. 2

3. HOW WE USE PERSONAL INFORMATION………. 3

4. SENSITIVE INFORMATION………. 5

5. HOW WE SHARE PERSONAL INFORMATION………. 6

6. HOW WE PROTECT PERSONAL INFORMATION………. 6

7. TRACKING TECHNOLOGIES……….. 6

8. OPT-OUT………. 7

9. DATA TRANSFERS………. 8

10. CHILDREN’S PRIVACY………. 8

11. YOUR PRIVACY RIGHTS………. 8

12. THIRD PARTY WEBSITES AND APPS………. 9

13. ADDITIONAL CALIFORNIA RESIDENT RIGHTS………. 9

14. FINANCIAL INCENTIVE / LOYALTY PROGRAMS………. 10

15. CONTACT US………. 10

1. TYPES OF INFORMATION WE COLLECT
For purposes of this Policy, personal information includes all that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (collectively, “personal information”). We and the vendors that perform services on our behalf may collect the following types of personal information from you depending upon the device you are using and how you interact with us or use or interact with our Services:

· Personal Identifiers. Name, mailing address, email address, phone number, and other contact information.

· Demographic Information. Age, gender, race / ethnicity, limited medical / health information (if using some of our spa services).
· Account / Payment Information. Account username, date of birth, phone number, and password, including third party accounts, credit and debit card, bank account, and other financial information necessary to send and receive payments. This information may be considered “sensitive information” under the laws of some jurisdictions.

· Technical and Usage Data. Details of your visits to our sites and information generated in the course of using our sites, including pages visited on the website, forms submitted, time spent on each page, IP address, device name, device characteristics, traffic data, location data, communication data, the media that you view, interact with and/or share from our Services, how and when you interacted with the Services, operating system, browser type/version, web session time stamps, session number, and information about how you use our Services.

· Preferences for properties, clubs, and facilities. When you are staying with us, we want to make sure that we can provide you with services to enhance your experience. To do this, we may retain your preferences for our property and its areas and amenities.

· Dietary preferences. When you stay with us, we want to ensure that you are safe, that we are looking after your wellbeing. For example, we may make a note of your dining or beverage preferences so that we are prepared if you request room service or dine at one of our restaurants. These preferences may include medical information, which may be considered “sensitive information” under the laws of some jurisdictions.

· Marketing and Communications Information. Your Preferences to receive email marketing from us.

You can always refuse to provide your personal information, but please note that some personal information is necessary to provide our Services.

2. HOW WE COLLECT PERSONAL INFORMATION
We need to collect personal information from you in order to provide you with our Services, as well as to improve your experience. You may provide us with personal information in several ways, including, for example:

● When you visit our website or use our Services;

● When you register for or create an account;

● When you correspond with us in any way, including through questionnaires and surveys;

● When you sign up to receive our newsletter or promotional information;

● When you ask for customer service, support or other assistance;

● When you interact with us in any other way, online or offline, including through our Services;

● From third parties or publicly available sources, such as vendors, business partners, and/or social media platforms;

● When you use our on-property services, including our Commons Club, Pool Club, spas, restaurants, fitness centers, and other outlets at our properties.

● From third parties who may provide marketing, advertising, and promotions to you, such as sweepstakes, contests, deals, offers, or other marketing and promotional communications. We may combine data collected from advertising partners with data collected from or about you across the Services and use such combined data consistent with this Privacy Notice and applicable law.

● Tracking technologies such as cookies, as further described in the “Tracking Technologies” section; or

● From aggregate metrics

Please note that when you interact with one of our business partners, such as OpenTable or eTix, through our websites in order to use our Services, including to book a room, make a reservation for a restaurant, or purchase tickets for an event at Virgin Hotels Las Vegas, you are directing the relevant business partner to share your personal information with us so that we may provide you with our Services.

3. HOW WE USE PERSONAL INFORMATION
We primarily use personal information to provide, maintain, and improve our Services, but we may also use personal information to do any or all of the following:

Purpose/Use	Type of Information
Provide, maintain and improve our Services	· Personal Identifiers · Demographic information · Account / Payment information · Technical and Usage Data · Marketing and Communications Information · Preferences for properties, clubs, and facilities
Notify you about our Services	· Personal Identifiers · Account / Payment Information · Technical and Usage Data
Interact and respond to you	· Personal Identifiers · Demographics Information · Account / Payment Information
Manage Relationships with our business partners	· Personal Identifiers · Demographic Information · Account / Payment Information
Analyze use of our Services	· Account / Payment Information · Technical and Usage Data · Preferences for properties, clubs, and facilities
Develop new products, features, and Services	· Personal Identifiers · Demographic Information · Account / Payment information · Marketing and Communications Information · Technical and Usage Data · Preferences for properties, clubs, and facilities
Verify your identification to facilitate your use of our Services	· Technical and Usage Data · Account / Payment information
Administer our relationship with you, including creating and managing your account and facilitating your participation in our surveys and, promotions, and Financial Incentive/Loyalty Programs	· Account / Payment Information · Personal identifiers · Preferences for properties, clubs, and facilities
Personalize website content and marketing campaigns	· Personal Identifiers · Demographic Information · Account / Payment information · Marketing and Communications Information · Technical and Usage Data · Preferences for properties, clubs, and facilities
To enforce legal rights or defend or take legal proceedings.	· All categories of personal information.
Security purposes and enhancements	· All categories of personal information.
Provide our Spa & Beauty Services	· Personal identifiers · Demographic Information · Account / Payment information · Preferences for properties, clubs, and facilities
Provide our Dining Services	· Personal identifiers · Demographic Information · Account / Payment information · Preferences for properties, clubs, and facilities · Dietary preferences
Provide our Fitness & Recreation Services	· Personal identifiers · Demographic Information · Account / Payment information · Preferences for properties, clubs, and facilities
To facilitate a merger, acquisition, or other conveyance of some or all of our assets	· All categories of personal information

We may also combine your personal information collected through various sources, including information collected through our Services, and develop a customer profile that will be used for the purposes above.

Except as otherwise permitted or required by applicable law, we only retain personal information for as long as we need to use the information for the purposes listed above, including, for legal, regulatory, backup, archival, accounting, and/or audit purposes.

We may use personal information to create non-personal information. We may use non-personal information for any legitimate business purpose.

4. MOBILE APPLICATION
When you use the Virgin Hotels Mobile Application, we may track and collect certain information that is non-personally identifiable. This information may include:

· Your email and Player ID

· Your device operating system

· The duration of mobile application use

· Mobile application pages / scenes viewed.

· Location Information

The information does not personally identify you and is used for marketing purposes and improving your experience using the mobile application. We may combine information collected within the application with data that has been collected using offline resources including but not limited to player accounts, surveys, and market research.

If you have downloaded our mobile application(s) and wish to benefit from all the application’s features, such as receiving special offers for Virgin Hotels Las Vegas close to your location, you must allow the application to collect, process, transmit, and use real-time geographical information about the location of your mobile phone (the “Local Information”). You may withdraw this consent at any time by disabling the location services settings on your mobile device. Disabling such services will not impact any of the application’s non-location-based features.

Our mobile application is not intended for person under the age of 21.

When you use the Virgin Hotels Las Vegas mobile application, we track and collect certain information that is non-personally identifiable. You have the option within the mobile app settings to logout and delete your mobile app information. You may also request that we delete your mobile app information. You may submit a deletion request using the methods below in the contact information section.

5. SENSITIVE INFORMATION
We collect personal information such as account credentials, credit and debit card, bank account, and other financial information necessary to send and receive payments for the purposes described in the “How We Use Personal Information” section. This information may be considered “sensitive information” under the laws of some jurisdictions.

We do not collect or process sensitive Information for the purposes of inferring characteristics about consumers. For example, We do not collect or process geolocation information for the purposes of inferring characteristics about consumers. We collect sensitive information (e.g., security number, driver’s license number, passport number) only as strictly necessary to perform the Services reasonably expected by an average consumer who requests those services. Accordingly, we treat any such information as “personal information” consistent with applicable provisions.

We will not process your sensitive Information unless such processing is compliant with applicable privacy laws. To the extent that we need to obtain your explicit consent to process your personal Information, to the fullest extent permitted by law, when you provide your personal Information to us you are deemed to have consented to us processing your personal Information (including your sensitive personal Information).

6. HOW WE SHARE PERSONAL INFORMATION
We do not sell or rent personal information.
We may share personal information with our third party service providers, suppliers, vendors, professional advisors, advertising partners, and business partners, which may include IT service providers, financial institutions and payment providers, customer relationship management vendors, other cloud-based solutions providers, lawyers, accountants, auditors and other professional advisors.

We contract with such vendors and advisers to ensure that they only process your personal information under our instructions and ensure the security and confidentiality of your personal information. We may share personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law. Finally, we may also transfer or assign personal information to third parties as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose personal information about you that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

7. HOW WE PROTECT PERSONAL INFORMATION
We are dedicated to ensuring the security of your personal information. We use physical, electronic, and administrative security measures appropriate to the risks and sensitivity of the personal information we collect. We aim to provide secure transmission of your personal information from your devices to our servers. We have processes to store personal information that we have collected in secure operating environments. Our security procedures mean that we may occasionally request proof of identity before we disclose your personal information to you. We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your personal information, please contact us immediately.

8. TRACKING TECHNOLOGIES
Like many websites and apps, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions, including how you use the website. We use this information for analytics purposes which allows us to improve your browsing experience. The information we collect through these technologies will also be used to manage your session. Out of these cookies, the cookies that are categorised as “necessary” are stored on your browser as they are essential for the working of basic functionalities of the website. These necessary cookies cannot be disabled.

Cookie Opt-out. You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. If you delete your cookies, if you opt-out from cookies, or if you set your browser or device to decline these technologies, some Services may not function properly. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.

Online Analytics

We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

Social Media Integration

Our Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Facebook, LinkedIn or Twitter, and when you do, we may collect additional information from you, including the information listed in the Types of Information We Collect section above. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “Tweet” button, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.

Do Not Track

Some devices and browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit.

Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices. Our Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.

9. OPT-OUT
Targeted Advertising, “Sharing,” and “Selling”
We do not sell or rent your personal information. However, we work with third parties such as Google to manage our advertising on other websites. Our third-party advertising partners may use cookies or similar technologies on our website and other websites to provide you advertising based upon your browsing activities and interests, or to display ads that link back to our site. Under certain U.S. privacy laws, you may have the option to opt-out from the sharing of your data through third party Cookies for targeted advertising or cross-contextual behavioral advertising (“Sharing”)of your personal information. You can opt-out using the following methods:

· By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the applicable law. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

· By contacting us

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page. You can opt-out of some, but not all, online behavioral based advertising by clicking here or by using your browser settings to block cookies or notify you when a cookie is set.

If you do not want Us to send you email or postal mail regarding our Services, you can choose not to provide your personal information to Us, even though it might be necessary to make a purchase or to take advantage of certain features on our Services.

If you have previously opted-in to receiving marketing emails from us, you can update your preferences to tell us specifically what you are interested in hearing about by clicking on the preferences link included in the marketing e-mails. You can update your preferences at any time.

If you would prefer not to receive marketing emails sent by Us, simply click on the “unsubscribe” link included at the bottom of any of those emails. If you opt out of receiving marketing emails, we may still send you other types of messages, such as purchase receipts, information about our Services, or emails about your user account.

Where we use Google Analytics, we have set up the service to anonymize your IP address as soon as data is received by the Analytics Collection Network, before any storage or processing takes place. To opt out of being tracked by Google Analytics across all websites please visit https://tools.google.com/dlpage/gaoptout.

Automated Decisions

You have the right to opt-out from the processing of your personal information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable. However, we do not process your personal information in this manner.

For information about how to opt-out out of cookies, please see the “Tracking Technologies” section above.

10. DATA TRANSFERS
We are a global business so information we collect may be transferred to, stored, and processed in any country or territory where one or more of our business partners or service providers are based or have facilities which may be a different to your home country. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal information that we transfer in line with this Privacy Notice requiring that our business partners or service providers adhere to this Privacy Notice and the applicable privacy regulations in your home country.

11. CHILDREN’S PRIVACY
Our Services are not for children or those under the age of 16. We do not knowingly collect personal information from children or other persons who are under 16 years of age. Individuals who are children or those under the age of 16 should not attempt to provide us with any personal information. If you think we have received personal information from children or those under the age of 16, please contact us immediately.

12. YOUR PRIVACY RIGHTS
We offer you certain rights in connection with our Services.

Access to your personal information / Right of Portability
You have the right to request access to the personal information that we collect, use, and disclose about you in a portable, machine-readable format, to the extent technically feasible. You also have the right to not receive discriminatory treatment for exercising your access right. To submit a request or designate an authorized agent to make a request, please contact us using the information below.

Deleting your personal information
You have the right to request that we delete your personal information, subject to some exceptions under applicable law. Once we have received and confirmed your request, we will delete (and direct our partners and service providers to delete) your personal information, unless an exception under applicable law applies. You have the right to not receive discriminatory treatment for exercising your deletion right. To submit a request or designate an authorized agent to make a request, please contact us using the information below.

Correcting your personal information
The accuracy of the personal information we have about you is very important. To submit a request to update or correct your information, please contact us using the information below.

Exercising Your Rights

If you wish to exercise these rights please contact us using the information below. Or, to the extent applicable, by checking the appropriate box on the online form or clicking the unsubscribe link in the email. Please note, however, that the collection and use of certain information as set forth herein is required for us to provide access and/or use of Our Services. Further note that Our access to and/or use and processing of such information is necessary and required for Us to provide access to and/or use of Services, including services for which you may have contracted with us to provide to you. Further note that we may also still need to send you certain communications regarding the operation and administration of the Services, and you will not be able to opt out of those communications, for example, communications regarding updates to this Policy and other information which We are required to provide to you by applicable law.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. If we deny your request, we will provide reasons for the denial. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Anti-Discrimination

We will not discriminate against you for exercising your rights under applicable privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal information that we receive from you.

Appeal

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal.

You may appeal a decision by contact us using the information below.

Please note that your appeal will be subject to your rights and obligations afforded to you under the applicable privacy law. We will respond to your appeal within the time period required by applicable privacy law. If your appeal is denied, you may contact the attorney general in your jurisdiction if you have questions or concerns about the result of the appeal.

Additional California Resident Rights

13. THIRD PARTY WEBSITES AND APPS
Our website and Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Notice do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

14. ADDITIONAL CALIFORNIA RESIDENT RIGHTS
CA Notice at Collection

California requires the disclosure of categories of personal Information We collect about you, the sources of that Information, the purpose for the collection, and how We share it.

Additional information about the categories of personal information collected and the categories of sources from which personal information is collected is in Section 2 of the Privacy Notice. The purpose for collecting the personal Information listed above is in Section 3 of the Privacy Notice. The third parties with which We may share the Personal Information listed above is in Section 5 of the Privacy Notice.

Limit Sensitive Data Processing

California consumers also have the right to request that we limit the use or sharing disclosure of their sensitive personal information. However, since we only process your sensitive personal information for the permitted purposes under Section 7027(m) of the CCPA Regulations and we do not infer characteristics from your sensitive personal information, we do not offer a way for you to submit such a request.

Shine the Light Law

California’s “Shine the Light” law (Cal. Civil Code Section § 1798.83) permits users of the Site that are California residents to request certain information regarding Our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us.

15. FINANCIAL INCENTIVE / LOYALTY PROGRAMS
We may offer specific pricing or other benefits in exchange for you enrolling in our Loyalty or Financial Incentive Programs. By signing up for the program, you affirmatively opt-in to receive the “financial incentive” under the California Consumer Privacy Act (“CCPA”) and / or “bona fide loyalty program benefits” under the Colorado Privacy Act (“CPA”). The personal information collected when registering for the program includes name, address, phone number, email address, and age. This information is placed in a database that is not sold to any third party.

You can end program participation at any time by contacting us at marketing@vhlv.com We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights. Please note that we need your personal information for you to participate in the rewards program. If you choose to exercise your right of deletion, your Guestbook subscription will be deleted as part of this process. This means that we will no longer have the personal information we need to offer you the program benefits, including reward points, discounts, and other promotional offers [because we will be unable to tie you to your interactions with us, or contact you to provide the benefits to you as part of the program.

For participants in the rewards program, the value of the personal information you provide is reasonably related to the value of the financial rewards provided to you. The value of personal information will vary slightly for each member depending on several factors, including but not limited to your interactions and purchases with us, the administrative and technical expenses associated with maintaining the program (e.g., IT infrastructure, customer service, marketing strategy & planning), and the extent to which you take advantage of the program’s offerings and discounts.

16. CONTACT US
We welcome requests, questions, comments, and feedback on this Privacy Notice and our management of personal information. If you have requests, questions, concerns, or feedback, you can always contact us in the following ways. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.

Email:
marketing@vhlv.com
Mail:
4455 Paradise Rd. Las Vegas, NV 89169
Phone:
1-800-910-2387