Seminole Tribe of Florida d/b/a Seminole Gaming
SPORTSBOOK
Online Sports Betting Privacy Policy: Your Privacy Rights

The Seminole Tribe of Florida d/b/a Seminole Gaming (“Seminole Tribe”, “we”, “us”, “our” and other similar pronouns) know that your privacy is important to you, and we want you to know that it is important to us, too. We created this Privacy Policy (this “Policy”) to explain the types of information we collect through www.hardrock.bet and any related websites on which it is posted, and the various social media platforms that we use (each, a “Site”) as well as the Hard Rock Sportsbook mobile applications (each, an “App”, referred to collectively in this Policy with the Sites as the “Service(s)”). Additionally, we created this Policy to explain how we will use, disclose and protect this information once it is collected, and how you can opt out of some of our uses and disclosures of your information.

Here are a few general principles to keep in mind as you read through this Policy:

• If you are a California or Virginia resident, applicable state law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://www.hardrock.bet/fl/ccpa-notice/. and for Virginia privacy rights visit https://www.hardrock.bet/privacy-policy.
• The Seminole Tribe has entered into the 2021 Gaming Compact with the State of Florida (the “Compact”) under which the Seminole Tribe offers online sports betting services to players physically located within the State of Florida and provides the Services to you as set out in the end user license agreement governing your use of the Services. The Seminole Tribe is a federally recognized tribal government possessing sovereign powers and rights of self-government, and is permitted by the Compact to offer real-money, online sports betting services from its Indian lands in the State of Florida.
• The Seminole Tribe has also entered into an agreement with Seminole Hard Rock Digital, LLC (“HRD”) under which HRD provides services to the Seminole Tribe to support the Seminole Tribe in its provision of real-money, online sports betting, including via the Services, to you. As described in more detail below, we may share your personal information with HRD so that HRD can provide services to us.
• We may share your Personal Information with third parties for such third party’s marketing and other purposes, as described in more detail below. You can elect for us not to do so by emailing [email protected], among other means described in the “Opt In and Opt Out” section below.
• This Policy does not apply to any website or mobile applications that are directed to children under 13 and the Site is not directed to children under 13.
• Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Services (but note that you still have certain opt-out rights under this Policy, as described below). By accessing or using the Services, you agree to this Policy. As our business evolves, this Policy may change (see “Changes to this Privacy Policy” section below), so check back to this page periodically to make sure you understand how your Personal Information will be processed.
• If you are located outside of the United States, you should know that the information you provide to us is being transmitted to us and processed in the United States and will be protected subject to this Policy and applicable United States laws, which may not be as protective as the laws in your country. Also, the Services place cookies and local shared objects on your desktop computer, laptop computer, tablet, smartphone or other device (each, a “Device”) which are further described below. By using the Services, you agree to this (subject to your ability to disable or opt out of certain tracking practices, as described in this Policy).
• Advertisements displayed to you on the Services and elsewhere may be customized to your interests and preferences based on your Personal Information and Web site and mobile application usage information collected over time and across our Services and other online properties. For more information about interest-based ads, and to learn about options for opting out of having your web browsing information used for behavior advertising purposes, please visit here (AboutAds) or here (Your Online Choices). (You have to opt out using each of your Web browsing applications and devices separately.)

What Personal Information Do We Collect?

“Personal Information” is any information that can be used to identify you as an individual. We collect different categories of Personal Information from different sources, including Personal Information you provide directly to us (“User-Provided Information” described below) and Personal Information we collect through your use of our Services (“Service Usage Information” described below). We also collect Personal Information from social media platforms, which may include both User-Provided Information and Service Usage Information. For more on social media platforms, see the “Social Media” section below.

User-Provided Information

We collect certain User-Provided Information such as your name; date of birth or other age information; social security number; tax identification number; postal addresses; email addresses; telephone numbers; credit card and other payment information; account information and activity; information about and contents of your communications with us or other users; wireless device addresses (including text message addresses); photograph; gender; purchase, browsing and transaction history; favorite sports, sports teams and players and rival sports teams; and interests, hobbies, demographic information, banking history, credit reports, location, device identifications, income verification, and other pertinent information for the purposes of anti-money laundering, age and identify verification, and responsible gaming and for other uses as described in this Policy.

When do we collect User-Provided Information?

We collect User-Provided Information when you create an account on the Services; login to your account; place a wager or conduct any other transaction on the Services; sign up for our communications; enter contests or sweepstakes; complete surveys; contribute to our online forums; communicate or transact with other users; or submit a comment or question to us using a “contact us” or similar feature on the Services.

Unless otherwise noted on an online form, you are required to provide to us all of the Personal Information requested in order to register your account, complete your transaction, or make your request. In those cases, you are not required by applicable law to provide the Personal Information, but if you do not provide the required Personal Information, you will not be able to place your wager or conduct your transaction or we may not be able to respond to your request. An example of this is your payment card information, billing address and shipping address when you make a transaction, or your email address when you sign up to receive emails from us.

A referral or similar tool may be provided on the Services and/or in our emails that allows you to send information about our offerings to another person. When you use these offerings, we may ask you for the name and information of the other person, and that information will be handled pursuant to this Policy.

Service Usage Information

In addition to User-Provided Information, we collect other Personal Information about you and your online activities related to the Services (“Service Usage Information”), including as described below.

Usage Details and Device Information: As is the case with many Web sites and mobile applications, our servers automatically collect your IP address when you visit our Services, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your usage of the Services. Clickstream data includes, for example, Device ID, Device telephone number and other information about your Device, Web browser and operating system and their settings, mobile network information, mobile apps installed or running on your Device, the referring source that linked you to the Service, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next site you visit when you leave the Service, and any search terms you have entered on the Service or a referral Web site.

Geolocation Information: The Services also collect real-time Personal Information about the geographic location of your Device (including precise geolocation information on a real-time basis). Certain services provided to us by third party service providers, including those provided by GeoComply, will make use of your location data. If you use the Services, you consent to us and GeoComply transmitting, collecting, maintaining, processing and using your location data in order to provide and improve location-based services. You may withdraw this consent at any time by turning off the location settings or by notifying us in writing that you would like to withdraw such consent.

You are reminded that, under applicable legal and regulatory requirements, you may only use the Services if you are physically present in Florida. For this reason, if you do not consent to our collection of your location information, we will not be able to provide the Services to you and your choice is not to use the Services.

Stored Information and Files: The Apps may also access metadata and other Personal Information associated with other files stored on your Device.

Among other things, Service Usage Information enables us to generate analytics reports on the usage of our Services. We utilize third party service providers for web analytics on the Services, including Google Analytics. To opt out of your usage of our Services being reported to us by Google Analytics, you may follow the instructions at tools.google.com/dlpage/gaoptout.

In addition, we may deploy various tracking technologies on the Services to collect additional information about your visits to and use of our Services. For example:

• Cookies (or mobile cookies) are small data files stored on your Device at the request of a Web site or mobile application. A cookie assigns a unique numerical identifier to your Web browser or Device, and may enable us to recognize you as the same user who accessed our Services in the past, and relate your use of the Services to other Personal Information about you, such as your Service Usage Information and User-Provided Information. Cookies may also be used to enhance your experience on the Services (for example, by remembering your preferences and username so you can log in easily and keeping you logged into the Services after you have provided your password), to collect general usage and aggregated statistical information, to measure the effectiveness of advertising and display relevant advertising to you and to detect and prevent fraud.
• You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, in some cases, rejection of cookies may inhibit or preclude your use of the Services or its features. Please see allaboutcookies.org for more information about what cookies are and what they do.
• Cache cookies, such as eTags, may be used to identify your computer or other Device as the same Device that visited our Services or another site or mobile application in the past.
• Web beacons (also known as pixel tags, clear gifs and single-pixel gifs) are tiny images – typically just one-pixel – that can be placed on a Site, an App or in our electronic communications in order to help us measure the effectiveness of our offerings and content by, for example, counting the number of individuals who visit us online, verifying whether you’ve opened one of our emails or seen one of our Site or App pages, or verifying system and server integrity.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number or persistent identifier to you, your household or Device and relate your Service Usage Information to User-Provided Information. These technologies also enable us to recognize you when you access our Services using different Web browsers and different Devices.

By using our Services, you consent to our use of these tracking technologies as described above.

Social Media

We use several social media and blogging platforms to communicate with our customers, some of which are operated by third parties, such as Facebook, Instagram, Twitter, TikTok and Snapchat. This Policy applies to our use of Personal Information you submit to us there, but it does not apply to what those third party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.

Our Services may include features and functionalities that allow you to share Personal Information with us that you have already provided to a third party social media platform. For example, you may be able to create an account on our Services or log-in to our Services using your Facebook account or other third party credentials. If you do so, then Personal Information that you have provided to that third party will be made available to us, pursuant to the third party’s terms and conditions and privacy policy, and you consent to our use of that Personal Information in accordance with this Policy as well as the third party’s applicable policies. The Personal Information we receive from that third party may depend on the privacy settings you have on the third party platform.

We may also include tools on our Services that allow you to share and/or publicly post content or information from our Services to your profile on a third party social media. Third party social media platforms and blogging platforms have their own privacy policies which explain how they will use, protect and share your Personal Information, including any information you share on those platforms from our Services, and we encourage you to read them.

How is Your Personal Information Used?

We or our service providers may use the Personal Information we collect from and about you, including User-Provided Information, Service Usage Information and/or any Personal Information collected through social media sites, to perform the following business functions:

• providing our offerings and enabling users to use our Services and its features
• identifying, verifying and vetting your identity, credentials and eligibility to use our Services, such as confirming your geographic location and verifying whether you have registered with any mandatory self-exclusion bodies (as may be applicable) for responsible gaming reasons
• processing and fulfilling your transactions, such as when you place a wager, request to make deposits or withdrawals or request to engage in other financial transactions, and other transactional uses
• analyzing your credit and fraud risk and verifying your credentials using third parties, including financial institutions, identification verification agencies and credit reference agencies
• administering the Services and your account with us
• responding to your requests, questions, and concerns
• sending you marketing and other communications, including information about products, services, and events, of ours, our affiliates, pari-mutuels as required by the Compact, and our other marketing partners that we think might interest you. (You may opt out of receiving our marketing communications by following the instructions in the “Opt In and Opt Out” section above.)
• customizing our Services to your interests and history with us
• business intelligence, analytics, data and statistical analysis, market research, administering customer surveys and customer profiling, and counting and verifying ad impressions
• advertising and marketing our offerings, our affiliates offerings, pari-mutuel offerings and third party offerings, contextual advertising, and tailoring ads displayed to you on our Service and elsewhere to your interests and history with us
• internal research for technology development and demonstrations, and to develop, improve, upgrade and enhance new features and offerings
• auditing compliance and other practices, including quality and safety assurance measures
• detecting and protecting against security incidents and risks, as well as unauthorized or fraudulent activity
• testing and debugging software, systems, tools and practices
• assessing your gambling activities for responsible gaming purposes
• complying with applicable legal, licensing and regulatory requirements
• protecting our rights and property and recovering debt
• other purposes disclosed when Personal Information is submitted to us

To perform the above functions, we may match Personal Information collected from you through different means or at different times, including both User-Provided Information and Service Usage Information, and use such Personal Information along with information obtained from other sources (including third parties like data aggregators, sales lead generators, and mobile and social media services) and publicly accessible information (such as Personal Information available publicly on the Internet). We or our affiliates may also use this combined information to assess the level of interest in, and use of, the Services, our emails and our other messaging campaigns both on an individual basis and in the aggregate. Our service providers may be legally required to maintain certain Personal Information for regulatory purposes. Our service providers may also use non-personally identifiable Service Usage Information (including aggregate data) for their own use, in a form that does not include your Personal Information.

Do We Share Personal Information About You with Others?

Yes. We may share the Personal Information we collect on the Services with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing what you voluntarily post to public areas on the Services with other Service users, we may share your Personal Information (including any of the types listed in the “What information is collected on our Services?” section above):

• with the service providers who need your information in order to provide services to us or on our behalf; for example:
  • with service providers for the purposes of settling or making payment in connection with any wager, verifying your identity, and other purposes in connection with the Services,
  • to any payment management or debt collection company engaged by us to handle payment and collection processes, and
  • with pari-mutuels as required by the Compact for the purposes of providing marketing services to us in connection with the Services.
• with our affiliates and partners with which we co-brand offerings or from which we license trademarks and content for the Services or other offerings and other third parties for their marketing and other purposes, unless you tell us not to by following the instructions in the “Opt In and Opt Out” section below; for example:
  • pari-mutuels,
  • HRD and its affiliates, and
  • our marketing and market access partners.
• with our co-sponsor(s) if we obtain your Personal Information in connection with a contest, sweepstakes, offering, or other promotional activity that is jointly offered by us and any third parties, unless you instruct us not to by following the instructions in the “Opt In and Opt Out” section below
• with any governmental agent, regulatory authority or licensing body
• when we believe in good faith that disclosure is necessary or appropriate to protect or enforce our rights or property, protect your safety or the safety of others, investigate or seek to address fraud, money laundering, intellectual property infringement or violation of applicable law, respond to a government, judicial or other legal request, or to comply with  applicable law
• for purposes of disaster recovery
• with credit reporting agencies, such as information about late payments, missed payments, or other defaults on your account
• in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business
• with your consent

Your first name and last initial on the Services and the city in which you registered for the Services may appear in our leaderboards that can be viewed by the public on the Services. In addition, certain of your profile information (such as your name and/or other information) may be viewed by other users participating in the Service in which you participate.

Due to the legal, regulatory and security environment in which we operate, we may be required to disclose information about you under certain circumstances, and we may not be permitted to inform you that we have done so.

In addition, we may share non-personally identifiable Service Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

Our affiliates who receive your Personal Information from us have a policy of using technical, physical and organizational measures designed to protect Personal Information, prevent unlawful or unauthorized processing of Personal Information, and prevent unauthorized disclosure of, or accidental loss of, or damage to, such Personal Information. Our policy is to restrict access to non-public Personal Information about you that we hold, to those of our employees and agents who need to know the Personal Information to enable us to operate and provide services and who are subject to appropriate confidentiality and security obligations. See the “Security” section below for more information about the security of your Personal Information.

Third Party Ad Servers and Networks

We use third party advertising companies to serve ads when you visit our Services and other online properties. These companies may use information about your visits to the Services and other online properties, the region of the country or world where your IP address indicates you are located, as well as other information about you in order to provide advertisements about goods and services of interest to you. These advertisements may appear on this Service and on other online properties. These companies may employ cookies, clear GIFs and other tracking technologies to cause relevant ads to be displayed to you.

For more information about third party advertisers and how to prevent them from using your information, please visit Aboutads.info at www.aboutads.info/choices/ or Your Online Choices at www.youronlinechoices.eu.

Do-Not-Track Disclosures

Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices (which are explained in more detail under “Service Usage Information” above) in response to DNT settings in your web browser.

Our third party partners, such as web analytics companies and third party ad networks, collect information about your online activities over time and across our Services and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.

Your Access Rights

You may review, update or modify certain of the Personal Information that is stored in your user account on the Services (if you have one) by logging in to the “Profile” or similar area of the Services. You may also request that we update or delete certain of your Personal Information and Service Usage Information, subject to some conditions, by emailing [email protected]. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete your information is subject to our records retention policies and applicable law.

Opt In and Opt Out

By creating an account you are agreeing to be updated about our products, news, promotions, and to us sharing your Personal Information with our affiliates and third parties for their marketing and other purposes, as described in this Policy.

You have the right to opt in to or opt out of certain of our uses and disclosures of your Personal Information. For example, when you are asked to provide Personal Information on our Services, you may have the opportunity to elect to, or not to, receive messages from us by email or, if applicable, text message. You may opt out of certain uses or disclosures in the following ways:

• You may tell us that you do not want to receive our promotional messages or that you do not want us to share your Personal Information with third parties for their marketing and other purposes by:
  • If you have an account with us, logging into your account and changing your communications preferences in settings.
  • Sending us your name, address, email and phone number to [email protected]. Please indicate whether you are asking us to: (a) stop sharing your information with third parties for their marketing and other purposes, or (b) stop sending you a particular media notification via email or, if applicable, text message.
• You can also opt out of our promotional emails by clicking on the opt-out link within the email you receive.

Please understand that it may take us a few days to process any opt-out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. Also, to stop receiving promotional messages from third parties who already have your contact information, please contact them directly.

Security

While we endeavor to protect the security and integrity of sensitive Personal Information collected via the Services, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you correspond with us by email, text message, or using online forms like a “contact us” feature on our Services or communicate with other users, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. By using the Services and corresponding with us by these methods, you agree that we are not liable for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If you create an account on our Services, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.

If at any time during or after our relationship we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your email address, we may notify you by email to the most recent email address you have provided us in your account profile. Please keep your email address in your account up to date. You can change that email address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your Device and email application software. You consent to our use of email as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please email us at [email protected]. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

Retention and Disposal of Personal Information

We and our service providers intend to retain your Personal Information for only as long as necessary to fulfill the purpose for which we collected it. In addition, we and our service providers may retain your Personal Information to meet contractual and regulatory requirements (state and federal), such as accounting, insurance, reporting and other similar statutory requirements.

To determine the appropriate retention period we consider the amount, nature, sensitivity, potential risk of unauthorized use and disclosure, the purposes for which we process it and whether we can achieve such purposes through other means.  When we no longer need to use or retain your Personal Information, both physical and electronic records are destroyed.

“Linked-To” Web Sites & Online Properties

The Services may contain links, banners, widgets or advertisements that lead to other Web sites and online properties. We are not responsible for these other Web sites or online properties, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each Web site and online property visited after leaving the Services to learn about how your information is treated by others.

Changes to this Privacy Policy

We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date”. In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an email to the email address we have on file for you. In some cases, we may request your consent to the changes.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, including under the California Consumer Privacy Act of 2018 (CCPA), visit https://www.hardrock.bet/ccpa-notice/.

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt out of such information-sharing. As discussed above, if you wish to opt out of our sharing of your information with third parties for the third parties’ direct marketing purposes, please contact us at [email protected]. To find out more about your opt out rights, see the “Opt In and Opt Out” section above.

International Privacy Practices

Our Site is operated and managed on servers located and operated on the Indian lands of the Seminole Tribe of Florida within the United States. By using and accessing our Site, residents and citizens of countries and jurisdictions outside of the United States agree and consent to the sharing and processing of Personal Information on servers located in the United States, and that the protection of such information may be different from the laws of your residence or location.

Contact Us

If you have any questions or comments regarding our privacy practices, you may contact us at

Website: hardrock.bet

Email: [email protected]

Postal Address: 5701 Stirling Road, Davie, FL 33314

Effective Date: January 23, 2024