Privacy Policy

This Website is intended only for users over the age of 21. Please leave this Website if you are under
the age of 21. By continuing, you represent that you are over the age of 21 and release Southland Casino Hotel, our subsidiaries and affiliates, and the creators of the Website from
any and all liability for your use or access to the Website relating to your age.

At Southland Casino Hotel, we take the privacy of your personal information
seriously. This Privacy Policy outlines the ways we collect your personal information, how we use it,
how and to whom we disclose it, and your rights in relation to the personal information that we process.
In addition, it explains how we use that information and how you can opt out of certain uses of
information we may collect. All references to “Company,” “we,” “us,” and “our” shall mean
[INSERT NAME OF LEGAL ENTITY]. If the practices described in this Privacy Policy are
not acceptable to you, you should not provide Company with information about yourself. We may
periodically update this Privacy Policy. The “Last Updated” date at the bottom of the page tells you
when this Privacy Policy was last revised. We will notify you of material changes by posting notice on
our website (“Website”) or other mobile or other web-based application (“Application”) (collectively,
the “Website”) or through other means. Any changes to this Privacy Policy will become effective when we
post the revised Privacy Policy on our Website. Therefore, we encourage you to check the date of our
Privacy Policy whenever you visit our Website for any updates or changes.

This Privacy Policy applies to information we may collect from you through our operations, including, but
not limited to, the Lucky North Club for player rewards, our gaming, hotel, retail, and dining
operations, and our amenity, transaction, management, reservation, security, compliance and reward
systems. When you sign up for the Lucky North Club, we will ask you to provide certain Personal
Information to complete your registration. As you use your Lucky North Club account we will ask you
periodically for certain additional information. This Privacy Policy applies to the Lucky North Club for
player rewards, to websites and social media pages that we or our affiliates manage or control, to our
premises and information obtained on our premises, to applications that we use or offer to you in our
operations, and to email messages and other electronic communications that we send to you that link to
this Privacy Policy. This Privacy Policy does not apply to the Lucky North Casino,
, or other applications sponsored by our affiliate Ruby Seven
Studios, Inc., which is governed by a similar but separate privacy policy. For
those separate application privacy policies see Lucky North Casino Privacy Policy, Betly (WV) Privacy
Betly (AR) Privacy
and/or Ruby Seven Privacy

Collection of Your Personal Information

“Personal Information” refers to information that relates to an identified, or identifiable, person or
household. This includes, for example, your first and last name, home address or email address. We may
also collect and process sensitive Personal Information, such as Social Security number, payment card
number, driver’s license identification, or precise geolocation, as further described in this Privacy
Policy. In addition to Personal Information, we also collect information that does not identify you,
such as de-identified or aggregated information. The Personal Information that we collect depends on
what services you use or information that you request. Our collection and processing of your information
is based on different contexts: our performance of a contract, our obligations under law, our legitimate
interest in conducting our business, protection of a natural person’s vital interests and/or upon your

What Personal Information Has the Company Collected in the Last 12 Months?

The chart below lists the categories of Personal Information that we have collected in the last twelve
(12) months. Please note that the chart may include types of Personal Information that we collect and
share about people other than yourself. For example, we may collect Social Security numbers from our
employees, but we generally do not collect them concerning our customers or guests. The chart below also
lists the categories of third parties, such as processors or other service providers, to which we have
disclosed Personal Information in the last 12 months for a business purpose, such as contacting our
customers or processing a payment transaction.

Category of Information Collected Source of Information Purpose for Collection Third Parties to Which Information Has Been Disclosed for a Business Purpose
Identifiers, such as real name, postal address, date of birth, gender, telephone number,
unique personal identifier, online identifier, Internet Protocol address, e-mail address,
account name, user name, and other similar identifiers and information related to your
account. This also includes demographic information obtained from third parties.
You, your company, and/or your use of our Website; demographic content providers; your
responses to our surveys; government issued identification documents (e.g., driver’s
license); communications with our Customer Service representatives; representatives; other
sources, such as public databases, joint marketing partners, social media platforms, as well
as from other third parties (“Third Party Sources”)
To contact you; provide you or your company, or other Company guests or customers, with
goods, services, or information you or your company request; to send you promotional
materials or other products, services or offerings; secure your account; or to make our
products and services better; to inform you about and administer sweepstakes, contests, and
similar promotions

We disclose your information to service providers, such as mailing fulfillment vendors and
companies that help us identify you and your preferences, to conduct our business. We may
also share your Personal Information with other service providers, such as credit card
processors or professionals, like attorneys or accountants, where necessary for our
business. Company venues in the Company family of brands may also share Personal Information
with affiliates that provide back-office support.
Other identifiers such as signature, credit card number, or debit card number You, your company, and/or your use of our Website See above. Generally, we collect these categories of information in relation to purchases
you make from us.
See above. Generally, we share purchase-related information only to third parties that help
us process your purchases.
Sensitive personal information such as Social Security number, driver’s license
identification or passport identification number
You; Third Party Sources To detect security incidents, protect against malicious or fraudulent activity, to protect
physical safety of natural persons, or to otherwise perform services on behalf of our
business (things like offering credit, processing insurance claims, hiring employees)
We may share this information with our service providers. We may also share this information
with law enforcement to protect the Company and natural persons. We may also share this
information with governmental agencies as required by law.
Internet or other electronic network activity information, including, but not limited to,
browsing history, search history, and information regarding your interaction with our
Website, an application, or advertisement
You, your company, and/or your use of our Website; Third Party Sources To better serve you, provide you information best suited to you, and to maintain and secure
our networks and systems; to operate the website and collect analytics;

to understand our customer preferences; to create remarketing campaigns, and audience
look-a-likes for promotions and marketing

We share with third parties to serve you relevant advertisements, to tailor our content to
your preferences, and to maintain and secure our networks and system.
Audio or video recordings, such as recordings of customer service calls or video recordings
on our premises
You, equipment on our network or at our premises We use audio recordings for training and quality control purposes. We use video recordings
to protect our customers, our employees, our premises and otherwise deter theft and fraud.
We share audio and video recordings only with third parties necessary to our use and
processing of such recordings.
Your location or geolocation From you, your company, and/or use of our Website. Also, if you interact with or connect to
a guest or other wireless network at one of our premises, we or our service provider may
collect information about your location.
To provide you with personalized location-based services and content, including specific
information about our products and services if you are in physical proximity to one of our
properties and have opted into receiving text messages from us.

We may disclose your location to our service providers, including marketing partners to
provide you with more personalized advertisements or services.
Employment related information, including health insurance information and other
health-related information, and biometric information, like fingerprint, of certain of our
employees. This also includes professional information like past employment.
You; Third Party Sources We collect information necessary for the employment of Company employees, and to provide

We share employment information with third parties necessary for the processing of such
information, such as payroll and benefits providers. We also share employment information
with governmental agencies as required by law.
Commercial information, including records of products or services purchased, obtained or
You, your company, and/or your use of our Website; Third Party Sources We may maintain a record of goods and services you obtain from us for our commercial records
and otherwise to better serve you, and to draw inferences about your preferences.

We share purchase and commercial information only with third parties necessary for the
processing of such information.
Professional information You and Third-Party Sources We collect professional information such as job title and contact information, from our
business contacts, so we can connect and do business with them.

We share professional information concerning our business contacts only with those third
parties necessary for us to process such information.
Inferences we draw from any of the information identified above to create a profile about
you reflecting your preferences
We develop such inferences internally or with the help of Third Party Sources. Generally, we may develop inferences, like product or service preferences, concerning our
customers, which we use to better serve them and provide them with information concerning
products or services that may interest them.
We share such inferences with third parties necessary for our processing of such inferences,
such as marketing software platforms.

We will not collect additional categories of Personal Information or use the Personal Information we
collected for materially different, unrelated, or incompatible purposes without providing you with

Disclosing or Using Your Personal Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we disclose Personal
Information in the following circumstances:


We may disclose your information to companies that are under common ownership or control with Company,
our subsidiaries and/or affiliated companies.

Our Clients, Franchisors/Licensors, and Other Comparable Third Parties

We may disclose your information to third parties who require access to your Personal Information because
of the business relationship we have with the third party. In this context, we are often a service
provider to the third party (e.g., providing concessions at sports venues or otherwise providing food,
beverage, and other services at client owned locations) or operate our location under a third-party
brand (e.g., franchisor). These third parties may require that we share your Personal Information with
them. Their use of your Personal Information is governed by their independent data collection and use
practices and privacy policies, which may differ from our privacy policy. You should review their
privacy policies to determine how they use and disclose your Personal Information, along with any
choices you may have regarding the same.

Business Transition

We may share or sell your information as an asset of Company in conjunction with the sale to a third
party of our Company, our subsidiaries and/or affiliated companies, or a portion of our or their
business or assets.

Legal Purposes

We may disclose your information:

  • to conform with the law, research and fulfill our regulatory obligations, respond to regulatory
    inquiry, respond to claims, or comply with legal process served on Company (e.g., a lawful subpoena,
    warrant or court order, or discovery request).
  • to enforce or apply our policies or agreements (including to bill and collect for amounts owed to
  • to protect and defend our operations and ours and our employees’, patrons’, users’, or the publics’
    rights, privacy, safety or property (including through surveillance).
  • to protect our Websites, including fraudulent, abusive or unlawful use of our Websites.
  • if we reasonably believe that an emergency involving immediate danger of death or serious physical
    injury to any person requires disclosure of communications or justifies disclosure of records
    without delay.
  • to governmental authorities, in our sole discretion, in exceptional circumstances, such as a
    national emergency, security matter, or other situations in which we deem such disclosure prudent.

De-Identified/Aggregate Information

We may disclose de-identified or aggregate information that does not contain your Personal Information.
Where we do so, we require that the recipient agree not to re-identify any such information.

Sensitive Personal Information

We do not use or disclose sensitive Personal Information for purposes other than to provide the goods or
services you expect, to detect security incidents, protect against malicious or fraudulent activity, to
protect physical safety of natural persons, or to otherwise perform services on behalf of our business
(things like servicing accounts, fulfilling orders or transactions, verifying customer information).

Cookies and Related Information

“Cookies” are small pieces of information that are placed on your device while you interact with a web
site. We use cookies and similar technology with different names (e.g., clear GIFs, pixels, etc.), which
we’ll refer to collectively as “cookies”. Below are the categories of cookies we use and their
respective purposes:

  • Essential: Required to enable basic Website functionality.
  • Targeted Advertising: Used to deliver advertising that is more relevant to you and
    your interests, to limit the number of times you see an advertisement, and to measure the
    effectiveness of advertising campaigns.
  • Personalization: Allow the Website to remember choices you make (such as your
    username, language, or the region you are in) and provide enhanced, more personal features. For
    example, a website may provide you with local weather reports or traffic news by storing data about
    your general location.
  • Analytics: Help us understand how our Website performs, how visitors interact with
    the Website, and whether there may be technical issues.

Depending on the cookie, the data captured may be used by us internally (e.g., Essential cookies) and/or
the information may be shared with the cookie provider and other businesses (e.g., Targeted Advertising
cookies). Cookies that we use show advertisements on our Websites and within our content as that content
is shown across the Internet. We may also use third party network advertisers and analytics providers to
show our advertisements across the Internet and/or to provide information about viewing of our content.
Ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and
access their own cookies on your device and they may otherwise collect or have access to information
about you.

Certain cookie providers require that we include certain information about our use of their cookies.
Below is the information we are required to disclose as of the policy Effective Date. Since this list
may change, you should periodically check the list for any updates.

  • The Website uses Google Analytics. Information concerning Google’s collection and processing of
    information can be found here, or any other URL
    Google may provide from time to time. By using the Website, you acknowledge and consent to the
    storing and accessing of cookies or other information on your device where such activity occurs in
    connection with Google Analytics.
  • In order to provide Microsoft Advertising, Microsoft collects or receives from you certain data or
    information that constitutes personal data or personal information under certain data protection
    laws. For additional information, please visit
    or such other website as Microsoft may designate for this purpose from time to time.

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include
“Do Not Track” instructions.

Sale and Sharing of Personal Information

In the last twelve (12) months, we have not sold Personal Information.

In the last twelve (12) months, we have shared the following categories of information with third parties
for the purposes of Targeted Advertising:

  • Demographics (e.g., age, gender, location, language)
  • Device/Browser/App Information (e.g., device/app type, version, model, language, operating system,
    browser, internet protocol address, use frequency, cookie ID, as applicable)
  • Interests/Browsing Information (e.g., pages viewed, time spent on site/site activities, links
  • Conversion Data (e.g., purchase value, conversion rate)
  • User Categorization (e.g., new/returning visitor, interests based on viewing activity)
  • Hashed email address or phone number (if available)

You can opt out of Targeted Advertising using our Cookie Preference Center.

Additionally, you can opt out of Targeted Advertising by some network advertising companies by going to
the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely
prevent advertising based upon your browsing behavior you should also disable the cookies on your

Protecting Your Information

To help maintain data accuracy, prevent unauthorized access to or disclosure of, and ensure the
appropriate use of your Personal Information, we have put in place administrative, technical, and
physical safeguards. In the event that we are required by law to inform you of any unauthorized access
to your Personal Information, we may notify you electronically, in writing, or by telephone, if
permitted to do so by law.

Retention of Information

We retain Personal Information for the period necessary to fulfill the purposes outlined in this policy,
or until an individual makes a valid request that we delete information about them, unless a longer
retention period is required or is permitted by law.

Your Privacy Rights

Depending on where you reside, applicable law may provide you with certain privacy rights, such as:

  • Changes to Your Personal Information. We rely on you to update and correct your
    Personal Information. Most of our Websites allow you to modify or delete your account profile. Note
    that we may keep historical information in our backup files as permitted by law. If our Website does
    not permit you to update or correct certain information, contact us with such request pursuant to
    the “Your Privacy Rights” section below.
  • Deletion of Your Personal Information. You may request that we delete your Personal
    Information by contacting us with such request pursuant to the “Your Privacy Rights” section below
    and we will delete such Personal Information to the extent required by law. Valid requests to delete
    may be fulfilled by deleting or de-identifying this information, although we will retain any
    information we are required to keep by law.
  • Revocation of Consent and/or Objections to Processing. If we are processing your
    Personal Information based on your consent, you may revoke consent, or object, to specific
    processing of your Personal Information by contacting us with such request. If you revoke your
    consent for or object to the processing of Personal Information, then we may no longer be able to
    provide you services. In some cases, we may limit or deny your request to revoke consent or object
    to processing if the law permits or requires us to do so, or if we are unable to adequately verify
    your identity. We note, however, that the majority of our processing is not based on consent.
  • Right to Know/Access to Your Personal Information. If required by law, upon
    request, we will grant you reasonable access to the Personal Information that we have about you. You
    may request access to, or a portable copy of, your Personal Information by contacting us with such
    request pursuant to the “Your Privacy Rights” section below.

Please note that if you make a request, we will need to verify or authenticate your identity (that you
are the person that is the subject of the request, the legal guardian of that person, or in some
jurisdictions an authorized representative) to carry out the requests. In order to verify your identity,
we may ask for certain additional information that we will only use for the purpose of this
verification. If we can’t authenticate your identity, we will let you know. Note, in order to maximize
the potential that we can identify you when you make a request, please use the information you provided
to us, for example when you registered with one of our Websites or otherwise communicated with us.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt or as
otherwise required by law. If we require more time (up to 90 days in certain circumstances), we will
inform you of the reason and extension period in writing. We will deliver our written response by mail
or electronically, at your option.

If we cannot process your request, we will inform you of the reason why. For data portability requests,
where applicable, we will select a format to provide your Personal Information that is readily useable
and should allow you to transmit the information from one entity to another entity without undue

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If, under applicable law, we determine that the request warrants a
fee, we will tell you why we made that decision and provide you with a cost estimate before completing
your request.


We do not discriminate against consumers who exercise any of their rights described in this section.

Appeal Rights

If we deny a request you make concerning your Personal Information, you may have the right to appeal that
denial. If so, we will provide you information concerning your appeal right when we deny your request.

California residents may also be entitled to ask us for a notice describing what categories of Personal
Information (if any) we share with third parties or affiliates for direct marketing purposes (California
“Shine the Light” Rights).

Other Choices You Can Make

You can make the following choices regarding your Personal Information:

  • Promotional Emails. You may choose to provide us with your email address for the
    purpose of allowing us to send newsletters, surveys, offers, and other promotional materials to you,
    as well as targeted offers from third parties. You can stop receiving promotional emails by
    following the unsubscribe instructions in emails that you receive or by contacting us with such
    request pursuant to the “How to Contact Us” section below. If you decide not to receive promotional
    emails, we may still send you transactional or service-related communications.
  • Promotional Mailings. If at any time you do not want to receive offers and/or
    mailings from us, you can remove yourself from our mailing list by contacting us with such request
    pursuant to the “How to Contact Us” section below and including “NO SNAIL MAIL” in the subject line
    along with your name, address and zip code. Although we will remove your name from our mailing list
    after receiving your request, you may still receive mailings from us that had been initiated prior
    to your name being removed.
  • Promotional Telephone Calls. If at any time you do not want to receive telephone
    calls from us you can remove yourself from our contact list by contacting us with such request
    pursuant to the “How to Contact Us” section below
  • Promotional Text Messages. If you receive a text message from us that contains
    promotional information, you can opt out of receiving future text messages by replying “STOP” or
    otherwise contacting us with such request pursuant to the “How to Contact Us” section below.


Aggregate Information

We collect aggregate information about use of our Website. This aggregate information generally will not
identify you or be correlated to you individually for external purposes. We may collect, compile, store,
publish, promote, report, sell, or otherwise disclose or use any and all aggregate information, provided
that such information does not reveal your identity. When we share such information with other
companies, it is not traceable to any particular user, and will not be used to contact you. If we do
correlate any aggregate information to you, such information will be treated like any other Personal
Information under this policy.

Links to Other Sites

Please be aware that we provide links to third-party websites as a service to our users, and that we are
not responsible for the content or information collection practices of those pages. Please note that
these websites’ privacy policies may differ from our Privacy Policy. We encourage you to review and
understand their privacy practices before providing them with information.

Transmission of Information to Other Countries

As a multi-national company, we transmit information between and among Company, our subsidiaries and/or
our affiliate companies. As a result, your information may be processed in a foreign country where
privacy laws may be different from the laws in your country. By submitting your Personal Information to
us, you agree to the transfer, storage and processing of your information in a country other than your
country of residence including, but not necessarily limited to, the United States of America.

Children Under the Age of 16

We do not knowingly collect information from children under the age of 16. Our Website is not directed at
persons under the age of 16 and should not be used by them. In no event should children under the age of
16 provide any Personal Information through our website. More information about the Children’s Online
Privacy Protection Act (COPPA) and how it protects children who use the Internet may be found at

Third-Party Data Collection and Use of End-User Information

When you use or connect to our Website or download one of our Apps by or through a third-party platform
– including Meta Platforms, Inc., (META) and its affiliates, including Facebook and Instagram
– you allow us to (a) access and/or collect certain information from your third-party platform
profile/account and (b) . You additionally allow us to access information contained in cookies the
third-party platform placed on your device. The third-party platform provider determines what
information we receive by the third-party platform as permitted by the terms of your agreement and
privacy settings with the third-party platform. We may disclose this information we receive in relation
to your third-party platform profile/account with to the third-party platform. Their use of such
information is determined by your separate for their use as permitted by the terms of your agreement and
privacy settings with the third-party platform.

Use of this Website by Persons Under the Age of 21 is Prohibited

We do not knowingly or intentionally collect any personally identifiable information from, or market or
advertise our products or services to, individuals under the age of 21. Pursuant to law, persons under
the age of 21 are not permitted to gamble at our properties or loiter in casino areas. Similarly, this
Website and any of our online services are not intended for persons under the age of 21.

Any contests, activities, offers, or programs promoted, whether via this Website and any of our online
services or in any of our physical locations are strictly limited to eligible participants over 18 or 21
based on applicable rules and laws. Participants younger than this age are not allowed to use this
Website and any of our online services, accept offers, or win contests. We reserve the right to verify
age at any time for any reason and may decline to provide products, services, or access rights to any
person who does not have valid age identification. Please note that for some of our properties, users
may access limited aspects of our products and services in compliance with applicable local laws (by way
of example, our hotel and restaurant facilities and certain family-oriented events that may take place
at such properties).

How to Contact Us

If you have any questions about our Privacy Policy or our use of your information or to exercise your
privacy rights or choices, you can email or contact us as set forth below. When contacting us, please
include your first and last name, the name of the location that collected your information and a contact
number or email address where you agree to be reached.

Email us at: [email protected]

Or send a letter to:

Southland Casino Hotel
250 Delaware Avenue
Buffalo, New York 14202
Attention: Data Privacy

Or call us: 1-877-313-2605

If you are a person in the United Kingdom, you may also send a letter to:

Delaware North Companies (UK) Limited
2nd Floor, Capital Court
30 Windsor Street
Attention: Head of Risk & Compliance

If you are not satisfied with our response, and you are in the United Kingdom, you may have a right to
lodge a complaint with your local supervisory authority.

Effective Date: July 17, 2024

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