Privacy Policy

Last Updated: April 9, 2025

Introduction
Personal Information Collected
Cookies and Similar Technologies
Use and Disclosure of Personal Information
Sweepstakes, Contests, and Other Promotions
Your Choices
Data Retention
Data Security
Links and Interactive Features
Changes to This Privacy Policy

1. Introduction

This Privacy Policy describes how Cherokee Nation Cultural and Economic Development, LLC (“CED”) (“us”, “we”, “our”) collects, uses, and discloses personal information through websites (“Websites”) and mobile apps (“Apps”) operated by CED that link to this Privacy Policy (together, the “Online Services”), and offline means, such as in-person at our owned locations (with the Online Services, the “Services”).

This Privacy Policy does not apply to other online services that we control and maintain, but do not link to this Privacy Policy. We may also provide additional or supplemental privacy notices to you at the time we collect your personal information.

2. Personal Information Collected

We may obtain personal information from the following sources:

Directly From You. This includes when you sign up for email communications, register an account, enter promotions and sweepstakes, make a reservation or purchase, contact customer service, apply for a sponsorship, check in in-person to one of our casinos or hotels, or otherwise interact with us.

Through Cookies and Similar Technologies. The Online Services may have certain technology enabled, such as cookies, beacons, pixels, APIs, and SDKs (e.g., cookies), that help facilitate and personalize your visit to the Online Services. For more information, please see Section 3 entitled “Cookies and Similar Technologies”.

From Our Vendors. Vendors, including those that operate services to you on our behalf, may provide us your personal information in connection with the Services, such as payment processors, room booking and management vendors, online service hosting services, and customer support service providers. This includes vendors that provide data services such as data consortiums, data providers, or other services that allow us to improve our lead generation and customer relationship management.

Other External Sources. This includes our partners and affiliates (such as in connection with a co-marketing agreement), other individuals (such as when they refer you to sign up for our loyalty program), and social networks (such as when you interact with our official pages on a social network).

Personal information we collect may include, depending on your interactions with us:

Identifiers. This may include name, residential and mailing address, email address, account usernames, telephone number, and signature.

Demographic Information. This may include age, date of birth, nationality, and citizenship.

Commercial Information. This may include purchase history or tendencies.

Travel Information. This may include details such as arrival and departure information, flight number and details, and points of origin and destination.

Preference Information. This may include your food and beverage preferences, dietary information, and special requests, such as part of us providing customer and membership services.

Professional, Education, or Employment-Related Information. This may include your business contact information, employer name, and professional title.

Internet or Other Electronic Network Activity Information. This may include Internet Protocol (IP) addresses, device identifiers, mobile networks, browser types, operating system details, referring URLs, length of visits, traffic data, pages viewed, and information regarding your interactions with the Online Services.

Geolocation Data. This may include precise and approximate location, which may be based on your ZIP code, IP address, or device information, such as when you use location-based features on the Online Services.

Payment Information. This may include shipping and/or billing address, and other payment information to process the transaction when you make a purchase or reservation.

Credit Application Information. This may include Social Security number, financial information, lines of casino credit in your name, and credit payment history, such as if you apply for credit with us.

Officially-Issued Identifiers. This may include information related to your passport, driver’s license, or other government-issued ID, such as when you check in or when playing at the casino; and Certificate Degree of Indian Blood (CDIB), or tribal membership card or ID.

Audio, Electronic, Visual, or Similar Information. This may include audio recordings of customer care calls, and CCTV security photos and video footage.

Biometric Information. This may include identity-verifying or identity-recognition information, such as fingerprint, palm print, face, voice, or other physiological, biological or behavioral characteristics information, that is used to establish an individual’s identity, such as for security, safety, and business protection purposes, including in-person at our owned locations like casinos.

Certain features of the Apps may require access to certain information from your device. Depending on the App and your Apps permission or device settings, the Apps may have access to your device’s approximate or precise geolocation; camera to allow the Apps to take pictures and videos; and storage, including photos, media, and files. Refer to the App’s description on the app store from which you downloaded the App for more information.

3. Cookies and Similar Technologies

Depending on your device and browser settings, the Online Services may enable cookies and similar technologies (such as pixels, beacons, SDKs, and APIs) that collect information related to your visit, such as IP address, the types of device you are using, geolocation, all of the areas within Online Services that you visit, and what content you interact with (including clicks and mouse movements).

We use these technologies for various purposes, such as to:

Provide functionality to Online Services and features within the Online Services. For example, to retain user preferences and settings, support customer service features, enable video media players, allow you to interact with social network feature, and keep your online shopping cart up to date.

Improve the performance and efficiency of the Online Services, such as supporting the routing of traffic between servers to provide a faster and smoother online experience.

Conduct analytics to understand, measure, improve, and research features and content on Online Services, including how users navigate and interact with the Online Services.

Maintain data security and detect and prevent security risks and fraud, including by detecting unauthorized robot software.

Personalize your experience on Online Services and on external-party online services, including through cross-context and targeted advertising campaigns.

These technologies may allow us and external parties, such as our vendors, to collect personal information about your online activities over time and across different online services when you use the Online Services.

Our vendors include those that provide us services based on the information collected through these technologies.

For example, we may implement Google advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and impression reporting. For more information on Google Analytics and other Google products, visit policies.google.com/technologies/partner-sites.

We may use YouTube API Services, which may collect information about you, including your interactions with YouTube features on the CNB Online Services (such as video media players), IP address, device information, and other internet or other electronic network activity information. The YouTube API Services may deliver ads through the video media player or otherwise. For more information about the YouTube API Services, please refer to the Google Privacy Policy at google.com/policies/privacy.

For more information about some of our vendors, and your choices to opt out of their technologies, visit here.

Social networks may provide you settings related to their technologies that connect to your social network profile. For example, Meta may provide settings related to the Meta Pixel, Facebook Custom Audiences, personalized ads, or off-Facebook activity through Facebook or Instagram. Refer to the social networks you use for more information.

Certain vendors may participate in the Digital Advertising Alliance, which provides an opt-out program from its members for website browsers at youradchoices.com and mobile apps at aboutads.info/appchoices; or the Network Advertising Initiative, which provides an opt-out program from its members for website browsers at networkadvertising.org/choices and mobile apps at networkadvertising.org/mobile-choice.

You may be able to exercise certain choices related to these technologies through your browser or device settings. Additionally, our vendors, including those with social media services, may provide settings on their own platforms that allow you to make choices about their technologies. If you change settings in relation to these technologies, you may not be able to access or use portions of the Online Services, or certain offerings on the Online Services may not function as intended or as well. We are not responsible for the effectiveness of, or compliance with, external-parties’, browsers’, or devices’ opt-out options or the accuracy of their statements regarding these options.

4. Use and Disclosure of Personal Information

We use and disclose (such as to our affiliates and vendors) your personal information for various purposes, including as directed by you, such as for the following purposes:

Provide Services. To provide, maintain, and upgrade products and services, including those that you request.

Customer Service. To respond to your requests for technical support, product information, or any other communication you initiate, including requests and inquiries.

Research and Development. We may develop, create, or improve new products or services, including using personal information for internal purposes related to certain research, analytics, development, demonstration, innovation, testing, monitoring, and administrative purposes.

Marketing Messages. To deploy promotional messages, such as push notifications, emails, and texts, including to notify you of products and services we think may be of interest to you.

Advertising. We may personalize your experience on the Online Services and across the internet by conducting contextual or targeted advertising, including to recommend products and services you might like or find useful.

Partnerships. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with us to provide additional features to you. These special relationships may include business partners, sponsors, joint marketing partners, and co-branded services. Personal information we use to provide you these services may be disclosed to the relevant services partners. Separate privacy policies may apply to these services. For more information, refer to the information provided to you at the time of the collection of your personal information for these partnership services.

Security, Safety, and Integrity. We may use personal information for security purposes, such as for loss prevention, to protect against unauthorized disclosure of personal information, detection of security incidents, for the safety of you, us, and others, to maintain the integrity of our Services, and protecting against malicious, deceptive, fraudulent, or illegal activity.

We may also use or disclose personal information for legal compliance, to protect and defend our or third-party rights and property, to enforce our terms and agreements, as part of a business transaction (such as a merger, reorganization, acquisition, liquidation, or bankruptcy), for crime-prevention purposes, and to comply or assist with requests from law enforcement, government or regulatory bodies, lawful authorities, and court orders.

5. Sweepstakes, Contests, and Other Promotions

You may participate in our surveys, contests, sweepstakes, and other promotions. We may request information for your participation (such as your contact information, photos, personal opinions, preferences, and interests). Participation in these promotions is completely voluntary. Contact information may be used to notify winners and award prizes. Your personal information may be disclosed to third parties or the public in connection with the administration of a promotion, including in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winner’s list. For more information, refer to the official rules of the promotion.

6. Your Choices

If you have a registered account on the Online Services, you may be able to change your preferences as well as update your personal information through your account settings.

If you prefer to no longer receive marketing emails from us, you may opt out by clicking the “Unsubscribe” link at the bottom of the email. Note that opting out of marketing emails will not affect your ability to receive transactional emails, such as updates on your purchases.

7. Data Retention

We keep personal information for as long as is necessary for the purposes described in this Policy or for which the information was collected.

8. Data Security

We take reasonable measures to help protect personal information collected through the Services from loss, theft, misuse, and other unauthorized access, disclosure, alteration, or destruction. Nevertheless, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through the Services.

9. Links and Interactive Features

When using the Online Services, you may come across links or interactive features related to third-party websites and services that we do not operate or control. This includes any online services operated by our vendors that provide us your personal information at your direction (such as through certain portals, webforms, or features provided by a vendor). For example, certain third-party interactive features may allow you to share Online Services content to your social media profile. We may also offer customer service features provided through a vendor where contents of your interactions with these features may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature, including to provide services on our behalf. If you provide your personal information to that third party through its websites or services, you will be subject to that third party’s privacy practices, policies, and terms of use. This Privacy Policy does not apply to any personal information that you provide to a third-party website or service.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time as reflected by the “Last Updated” date at the top. If we make any material changes to the Privacy Policy, we will provide a notice about such material changes. By continuing to use the Services following such changes, you will be deemed to have agreed to such changes.