PRIVACY NOTICE

Last Updated: October 1, 2020

Introduction

We at Venetian Macau Limited, including our affiliates and subsidiaries in Macao (collectively, the “Company”), respect your concerns about privacy and strive to provide guests, patrons, and visitors (“you”) with exceptional experiences and service. This Privacy Notice describes the types of personal information we obtain, how we may use and retain that personal information, with whom we may share it, and how you may exercise your rights and choices with respect to our processing of that information. This Privacy Notice also describes the measures we take to safeguard the personal information we obtain and how you may contact us if you have questions about our privacy practices.

References in this Privacy Notice to “Company”, “we”, “us”, and “our” refer to the entity responsible for the processing of your personal information, which generally is the entity that collects your personal information (such as the entity responsible for the website through which your personal information is collected).

This Privacy Notice applies to personal information we obtain, including:

• through our websites, social media pages, and other digital platforms we operate or control that reference this Privacy Notice, including www.venetianmacao.com; www.sandsmacao.com; www.theplazamacao.com; www.parisianmacao.com; www.londonermacao.com; www.sandsrewards.com; www.cotaiwaterjet.com; www.cotaiticketing.com (collectively, the “Online Channels”);
• when you visit or stay as a guest or patron or attend a meeting, event, or trade show at one of our properties, and through other offline interactions (collectively, “Offline Channels”);
• when you enroll in any of our loyalty program(s) (Sands Rewards, Sands Lifestyle, Sands Alipay Digital, etc.);
• through third-party sources, including business partners, advertising and social media companies, and vendors; and
• through other data collection points that reference this Privacy Notice (collectively, the “Channels”).

Personal Information We Obtain

We collect personal information about you in different ways and from various sources. This includes, without limitation, when you visit our websites, enroll in our loyalty program(s), submit a credit application, submit an employment application, check-in and stay with us, play at our casinos, attend group events or meetings, dine at our property, use the services offered at our property, complete surveys, shop at our retail stores, interact with us through our social media pages, register for Wi-Fi on our property, or contact us by email or phone.

Personal Information You Provide

Depending on the Channels you use and the nature of your interactions with us, you may provide us with certain types of personal information, including:

• Contact information such as name, email address, postal address, fax number, and telephone number;
• Demographic information such as age, nationality, date of birth, education, profession, marital status, race, color, religion, sex, gender, medical condition, disability, and citizenship status;
• Billing and financial information such as your bank account information, payment card number, expiration date, security code, delivery address, and billing address;
• Government-issued ID information such as your passport, driver’s license, or other government-issued ID, which you may provide, for example, at check-in or when playing at our casino;
• User account information such as username and password, and loyalty account number and PIN provided when you sign up for any loyalty program we have on property;
• Travel itinerary details such as arrival and departure information, flight number and details, points of origin and destination, and group information;
• Preference information such as food and beverage preferences, dietary information, and special requests;
• Commercial information such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
• Content such as photos, comments, feedback, and other content you provide;
• Signature, which you may provide, for example, when you check in at our property or sign an application or form;
• Medical information or health insurance information such as information regarding a medical treatment or diagnosis, health insurance policy number or subscriber identification number;
• Credit application information such as name and contact information, Social Security number, employment information, financial information, other lines of casino credit in your name, credit payment history, and other information provided in connection with your credit application if you apply for credit with us;
• Employment application information such as name and contact information, employment history, Social Security number, education, training and skills (including licenses and certificates), background check information, proof of eligibility to work in the United States (“U.S.”), military service, and any other information provided in connection with an application if you apply for a job with us; and
• Any other personal information you provide through the Channels.

Providing your personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

Personal Information Obtained from Other Sources

In addition to the personal information you provide to us directly, we may obtain from other sources additional personal information about you, including:

• Friends and family-provided information such as information that your friends or family provide to us about you in connection with their reservations;
• Publicly available information such as name, contact information, content and online activity that we obtain from publicly available sources (such as public databases) and social media platforms you interact with;
• Device information such as geolocation data and other location information derived from your IP address, country, and zip code;
• Data collected by cookies and similar technologies such as information about your online activities, devices, browsing actions, and usage patterns across the Online Channels and third-party websites that we obtain through the use of cookies, web beacons, and similar technologies (see the Cookies and Similar Technologies section below);
• Video, audio and other sensory information such as images, video, audio, thermal and olfactory data that may be collected or processed through our security cameras, closed-circuit television, recorded phone lines, and other technologies, where permitted by law;
• Biometric information such as digital images and other information obtained through a facial recognition system that we have or may install in our casinos and gaming areas or where necessary for the use of a product or service;
• Data from third-party sources such as personal information we obtain from our third-party service providers (including background check providers, credit check providers, data aggregators and data cleansing companies), business partners (including ticketing agencies, travel agencies, event organizers and travel booking platforms), and marketing partners; and
• Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

How We Use Personal Information

We use the personal information we obtain for various purposes, including:

• Processing and managing your reservations and orders including to process payment for your bookings and purchase of products and services, facilitate ID verification, administer your use of our convention and meeting spaces, and provide you with travel-related services;
• Managing our communications with you including to send you booking confirmations, information about your transactions (such as your folio), and information about the property, services available to you, and events or meetings you may attend;
• Responding to you and providing support including to address your inquiries and feedback, requests, and other communications you send us, and provide you with guest support services;
• Managing your account including to create, manage, and administer your loyalty account, and to provide you with certain offers and services (such as casino credit, special events, promotional offers, etc.);
• Marketing including to present or send you messages, news, and other types of information about offers, promotions, and events that may be of interest to you, to plan and execute our marketing campaigns and promotions, for market research and analysis, to administer surveys including guest satisfaction and quality assurance surveys, and to manage your participation in special events, contests, sweepstakes, or programs;
• Managing career opportunities including to process and assess your job application, and to conduct recruiting and other talent management purposes;
• Credit and other financial dealings including to analyze your eligibility for credit, collecting debt, and other financial dealings;
• Data Analytics including to maintain and improve our products and services, to analyze behavioral patterns of our guests and patrons, and to protect our guests and patrons;
• Prevention and Protection including to protect our visitors, guests, patrons and employees, identify and prevent fraud and other unlawful activity, and protect and defend the Company against legal claims and other liabilities;
• Operating, evaluating, and improving our business including to perform accounting, auditing, record keeping, credit risk management, and other internal functions (such as ensuring the functioning, safety, and security of our Online Channels, premises, infrastructure, and networks), developing new products and services, analyzing and improving our existing products and services, and personalizing the guest experience for you and others; and
• Legal and Compliance including to comply with and enforce applicable laws and regulations, industry standards, and contractual obligations, as well as our policies and terms and conditions.

We may combine data collected from you with other sources to help us improve our products, services, marketing, and communications, as well as to help expand and tailor our interactions with you. This includes combining personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other sources for the purposes described above. We may anonymize, de-identify, or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection.

Depending on the purposes for which personal information is used, and the context in which the information is obtained, we rely on one or more of the following legal bases, subject to applicable law:

• Performance of a contract or to take steps at your request prior to entering into a contract;
• Our legitimate business interests (which we can explain to you in further detail upon request by contacting us as indicated in the How to Contact Us section below);
• Compliance with a legal obligation;
• Your consent to the processing of your personal information, which you can revoke at any time; and/or
• Protection of your vital interests if you are unable (physically or legally) to give your consent.

Cookies and Similar Technologies

We use cookies, web beacons (including pixels and tags), and similar technologies on our Online Channels that collect certain information about you by automated means.

A “cookie” is a small text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes IP address, device ID, and other identifiers associated with your device, device type, device characteristics (such as operating system), the pages you visited on our websites, how you arrived at our websites, browser preferences and characteristics, clickstream data and other information about your online activities. We use on our Online Channels both first-party cookies (served directly by our website domain when you visit our Online Channels) and third-party cookies (served by a third-party website when you visit our Online Channels and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).

The cookies we use on our Online Channels include:

• Essential cookies (which are necessary for us to provide you with our Online Channels);
• Functional cookies (which enable improved website performance and an enhanced user experience);
• Analytics cookies (which help us analyze how you navigate through and use our Online Channels); and
• Targeting/advertising cookies (which are used to manage and serve ads to you that may be of interest) (see the Interest-Based Advertising section below).

With respect to analytics cookies, we use third-party analytics services on our Online Channels, such as those of Google Analytics. To learn more about Google Analytics and how to opt out, visit: https://policies.google.com/technologies/partner-sites.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Note, however, that without cookies, you may not be able to use all of the features of our Online Channels. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

The third-party apps, tools, widgets, and plug-ins on our Online Channels (such as Facebook, Weibo, WeChat, Twitter, Instagram, Pinterest, YouTube, and TripAdvisor) also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy notices of these providers.

Interest-Based Advertising

When you use our Online Channels, both we and certain third parties (such as advertising networks, digital advertising partners, and social media platforms) collect information about your online activities, over time and across third-party websites. Such information may be used to provide you with advertising about products and services tailored to your interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites because we engage third-party ad buying networks. Through such ad buying networks, we can target our messaging to users through demographic, interest-based, and contextual means. The information our ad networks may collect on our behalf includes data about your visits to websites that serve our advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, visit Your AdChoices.

For more information, review the Self-Regulatory Principles for Online Behavioral Advertising (“Principles”) of the Digital Advertising Alliance in the U.S., the Digital Advertising Alliance of Canada, and the European Digital Advertising Alliance in the European Union (“EU”). If you live in the U.S., Canada, or the EU, you can visit Ad Choices, Ad Choices Canada, or Your Online Choices for information on how to indicate your preferences, including opting out of interest-based advertising with participating entities. Note that opting out of interest-based advertising does not mean you will no longer see advertisements from us or on the Online Channels because your information may have been collected and shared prior to your opt-out request, the ads may not be customized to your specific interests, or the ads may be served based on your interactions with other companies and their websites. When you opt-out of receiving interest-based advertisements through the links above, cookies and other technologies on the Online Channels may still collect information about your use of the Online Channels, including for analytics, fraud prevention, and any other purpose permitted under the Self-Regulatory Principles.

Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. Our Online Channels currently are not designed to respond to DNT signals received from web browsers.

How We Share Personal Information

We may share your personal information with certain third parties, including as indicated below.

• Our Affiliates and Subsidiaries. We may share your personal information with our affiliates and subsidiaries for the purposes set out in this Privacy Notice.
• Service Providers, Suppliers, Agents, and Other Business Partners. We use service providers, suppliers, and agents (including those outside of Macao) to help us provide our products and services and to perform services on our behalf (such as maintenance, IT services and support, analysis and analytics, audit, payments, marketing, development, reservations, ticketing operations, security, ID verification, and background and credit checks). We do not authorize these entities to use or disclose such information except as necessary to perform services on our behalf or comply with legal requirements. We also may share personal information with business partners (such as travel agencies, event organizers, and travel booking platforms) for the purposes described in this Privacy Notice.
• Marketing Partners.We may run promotions and marketing efforts, such as contests, sweepstakes, and giveaways, with certain third parties. If you choose to participate in any such promotions, the personal information you provide may be shared with those third parties (including those outside of Macau) and would be subject to their privacy notices unless otherwise indicated.

We also may disclose personal information about you (1) if we are required or permitted to do so by applicable law, regulation, or legal process (such as a court order or subpoena); (2) to law enforcement authorities and other government officials to comply with a legitimate legal request; (3) when we believe disclosure is necessary to prevent physical harm or financial loss to the Company, our guests, patrons, our employees, or the public as required or permitted by law; (4) to establish, exercise, or defend our legal rights; and (5) in connection with an investigation of suspected or actual fraud, illegal activity, security, or technical issues.

In addition, we reserve the right to transfer to relevant third parties the personal information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation), or other business transaction.

We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.

Data Transfers

We may transfer your personal information outside of Macao, namely to the U.S., Singapore, Hong Kong SAR, Mainland China, and other countries and jurisdictions outside of Macao or the country or jurisdiction in which the information originally was collected, including the countries and jurisdictions in which the Recipients operate, when one the following applies:

• The Office for Personal Protection in Macau has considered the jurisdiction to where the data is to be transferred offers an adequate level of protection when compared with Macau Personal Data Protection laws and authorizes the transfer;
• You have given us your consent;
• It is necessary for the performance of a contract between the you and the Company or the implementation of pre-contractual measures taken in response to a request of yours;
• It is necessary for the performance or conclusion of a contract concluded or to be concluded in your interests between the Company and a Recipient;
• It is necessary or legally required on important public interest grounds, or for the establishment, exercise of defense of the Company court proceedings;
• It is necessary in order to protect your vital interests; and/or
• It is made from a register which according to laws or administrative regulations is intended to provide information to the public and which is open to consultation either by the public in general or by any person who can demonstrate legitimate interest, provided the conditions laid down in law for consultation are fulfilled in the particular.

We only share data with Recipients that have a privacy policy that is substantially similar to our Privacy Notice and/or those that have entered into a written agreement with us that is substantially similar to this Privacy Notice. Prior to entering into a contract or disclosing personal information, we would have a reasonable basis for believing that the Recipient (a) is capable of maintaining reasonable safeguards for the personal information, and (b) maintains sufficient procedures to detect and respond to security breaches that could compromise personal information.

If you are located outside of Macau and you interact with our website or provide your personal information to us, then your personal information may be transferred to Macao.

If you are located in the EU, United Kingdom (“UK”), or Switzerland, we will comply with legal requirements with respect to providing adequate protection for the transfer of personal information to recipients in countries outside of the EU, UK, or Switzerland that have not been recognized as providing an adequate level of data protection, to the extent such legal requirements are applicable to our processing of your personal information. In this event, we will implement appropriate safeguards, including as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses.

By having access to our Channels and using our services and products, you are authorizing us to transfer your personal information to Recipients, which may be located outside of Macau or the country or jurisdiction in which you are located and that may have a different level of protection. The transfers hereby authorized may constitute an international transfer of your personal information to other countries and jurisdictions, which may have different data privacy laws and protections.

How We Protect Your Personal Information

We take steps to protect your personal information in accordance with applicable law. We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Retention of Your Personal Information

To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it and in accordance with the terms of this Privacy Notice, which generally means that we will keep your personal information for the duration of our relationship or as long as you are enrolled in our loyalty program(s); (2) to take into account applicable statute of limitation periods and comply with applicable laws; or (3) for legitimate business purposes to the extent permitted by applicable law. As described in the Your Rights and Choices section of this Privacy Notice, to the extent provided by the law of your jurisdiction, you may request that we delete your personal information or restrict the processing of such information by contacting us as indicated below.

Your Rights and Choices

Subject to applicable law, you have certain rights and choices in connection with the personal information we obtain about you, such as how we use the information and how we communicate with you.

To update your preferences, limit the communications you receive from us, or submit a request, contact us as specified in the How to Contact Us section of this Privacy Notice. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.

To the extent provided by the law applicable to our processing of your personal information, you may request information about or access to the personal information we maintain about you or request that we correct, update, complete, amend, or delete your information, or that we restrict the processing of such information by contacting us as indicated in the How to Contact Us section below. To the extent provided by applicable law, you also have the right not to be subject to a decision that is based on automated processing of your personal information intended to evaluate certain of your personal aspects and that produces legal effects on you or that may impact you. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information or responding to requests related to your personal information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

Where provided by law, you may withdraw any consent you previously provided to us or object at any time to the processing of your personal information for direct marketing purposes or on legitimate grounds to any other processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal. Subject to applicable law, you may also have the right to receive, in a structured, commonly used, and machine-readable format, the personal information that you provided us with, as well as the right to have this information transmitted to another organization, where it is technically feasible.

For additional information about how to manage cookies and opt out of online interest-based advertising, review the Cookies and Similar Technologies section of our Privacy Notice. Your opt-out will be specific to the web browser or device you use at the time you exercise your opt-out rights; if you use multiple web browsers or devices, you will need to opt-out from each browser and device. Note that opting out of the use of your personal information for interest-based advertising purposes does not mean you will stop seeing ads, including interest-based ads, because (i) your personal information that was collected prior to your opt-out request may be further used for interest-based advertising purposes and (ii) ads may be served to you based on your interactions with other companies and their websites.

Children’s Personal Information & Legal Gaming Age

We do not permit gaming at our properties or loitering in casino areas for persons under the age of 21. The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13 through the Online Channels, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, contact us as specified in the How To Contact Us section of this Privacy Notice.

Links to Other Sites

Our websites may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those websites linked to our websites are not covered by this Privacy Notice. We are not responsible for the privacy notices of websites to which our website links. If you provide any information to such third parties, different rules regarding the collection and use of your personal information may apply. We strongly suggest you review such third parties' privacy notices before providing any data to them.

Updates to this Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our information practices. We may post a notice on our Online Channels to notify you of significant changes to this Privacy Notice and indicate at the top of the notice when it was most recently updated. We encourage you to periodically review this Privacy Notice for the latest information on our privacy practices.

How to Contact Us

For questions or comments regarding this Privacy Notice, or to update your preferences, contact us using either of the following options: