Revel Systems, Inc. Privacy Notice
Last Updated: July 1, 2020
This Privacy Notice applies to all products and services offered by Revel Systems, Inc., and our affiliates (collectively “Revel”, “we”, “us” or “our”), including our websites, products, services, mobile and software applications we own or control (the “Services”).
This Privacy Notice does not apply to products or services offered by other companies or individuals, such as payment processing services, hardware, third-party software, or ISP services that customers may use in connection with the Services, including such third-party products or services that a customer may lease or procure through Revel.
Your privacy is important to us. This Privacy Notice is meant to help you understand what data we collect, why we collect it and what we do with it.
What Data Do We Collect?
Revel collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, Revel has collected the following categories of Personal Information from its consumers within the last twelve (12) months:
|Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers||Yes|
|Personal information.||A name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, employment, employment history. Some personal information included in this category may overlap with other categories||Yes|
|Protected classification characteristics||Age, sex||Yes|
|Commercial information.||Records, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Yes|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement||Yes|
|Geolocation data.||Physical location or movements||Yes|
Revel obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our website.
- From our third-party customers, in which case we will cooperate with them to provide you with the rights described under “What Are Your Data Protection Rights?” below.
Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We may also collect other information that does not identify or relate to an identified or identifiable individual, such as browser and device information, demographic and other information that does not reveal the individual’s specific identity, and information that has been aggregated in a manner that it no longer reveals an individual’s specific identity. We may use and disclose such information for any purpose, except where we are required to do otherwise under applicable law.
We do not knowingly collect personal Information from individuals under the age of 18. Our marketing, sales, and Services are not directed at individuals under the age of 18. If you have reason to believe that an individual under the age of 18 has provided Personal Information to us, we encourage the individual’s parent or guardian to contact us as described in the “How to Contact Us” section of this Privacy Notice to request that we remove the information from our systems.
How Do We Collect Your Data?
We collect information you provide when you access or participate in certain aspects of our Services, such as when you create any type of account, use our Services, make purchases, leave a review, download one of our mobile applications, complete a survey, or enter contests or other promotions. We may also use a third-party payment service to collect payment information to process your transactions with us. The amount and type of information you provide depends on the nature of the interaction. You may always refuse to supply information, with the caveat that it may prevent you from using our corresponding Services.
We may receive information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.
Information Automatically Collected by Using or Accessing Our Services
When you access, use or interact with our Services, we collect information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring website, and the date and time of each visitor request. Revel may also collect Internet Protocol (IP) addresses.
Device Information and Identifiers
When you use our Services, including but not limited to when you install software, download any type of Services or access the Services, on your computer, tablet, mobile device or any other devices, we collect device-specific identifiers and mobile network information including phone number, device type, device identifier and operating system. We may also request access to certain rights on your devices, such as access to storage or camera, and ability to send push notifications.
Registration via Third-party Accounts and Social Media Sharing
You may be given the opportunity to register with us or use our Services via third party accounts such as Google, Apple or Facebook. These services will authenticate your identity and may provide you the option to share certain information (such as your name and email address) with us. We may store the information you provide us through such accounts and combine it with other information, including Personal Information. Disabling your Facebook or other such account may not terminate your relationship with us.
What are Cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.
How Will We Use Your Personal Information?
We use Personal Information for our legitimate business purposes, including to provide, maintain, use, protect and improve our Services, and to develop new products and services. For example, we use Personal Information:
- To respond to your inquiries and fulfill your requests, complete your transactions, and provide you with related customer service. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest. We will engage in this activity with your consent or where we have a legitimate interest.
- To personalize your experience on the website by presenting products and offers tailored to you, and to facilitate social sharing functionality. We will provide personalized services either with your consent or because we have a legitimate interest.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules containing information about how we use and disclose your Personal Information. We use this information to manage our contractual relationship with you.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
We retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
How We Share Information
Your Personal Information may be disclosed:
- To our affiliates for the purposes described in this Privacy Notice.
- To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To third party companies that provide services you have requested, such as payment processing services that you use in connection with the Services.
We may collect statistics about the use of our Services. In addition, we share anonymous information, including aggregated information, and share such anonymous information with third parties, and we may also share such anonymous information publicly to provide information about the general use of our Services.
Additional Uses and Disclosures
We may also use and disclose your Personal Information as we believe to be necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
How Do We Store Your Personal Information?
Revel is a global organization and your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services, you consent to the transfer of Personal Information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
Additional information regarding the EEA: Some of these non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).
For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contacting Us” section below.
If Revel, or substantially all of its assets, were acquired, or in the unlikely event that Revel goes out of business or enters bankruptcy, we have a legitimate interest in disclosing or transferring user information to a third party in connection with such a transaction
We may use third-party advertising companies to offer advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/?c=1
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by contacting us in accordance with the “Contact Us” section below or by using the opt-out mechanism contained in each such email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
What Are Your Data Protection Rights?
You have the right to request that Revel disclose certain information to you about our collection from you and use of your Personal Information.
The Right to Access
We will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or sharing that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we disclosed your Personal Information for a business purpose, we will identify the Personal Information categories that each category of recipient obtained
The Right to Rectification
You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request that we complete the Personal Information you believe is incomplete.
The Right to Erasure or Deletion
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it
The Right to Restrict Processing
You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
The Right to Object to Processing
You have the right to object to our processing of your Personal Information, under certain conditions.
The Right to Portability
You have the right to request that we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions.
Exercising Your Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at firstname.lastname@example.org. If you make a request, we have one month to respond to you.
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.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We also cannot fulfill requests from you that relate to information that another company (for example, one of our third-party customers) has collected from you.
How to Manage Your Cookies
Privacy Policies of Other Websites
Changes to Our Privacy Notice
Revel reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on the website and update the effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
How to Contact Us
If you have any questions or comments about this notice, the ways in which Revel collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights for your country or region, please do not hesitate to contact us at email@example.com.