PRIVACY POLICY

Cowlitz Tribal Gaming Authority (“ilani,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Notice (“Privacy Notice”). This Privacy Notice describes the types of Information we may collect from you when you visit our resort and/or the website at ilaniresort.com (the “Site”), and that you may provide in your communications with us. It also describes our practices for collecting, using, maintaining, protecting, and disclosing that Information. This Privacy Notice does not apply to Information collected by us offline, through any other means or by any third party.

Please read this Privacy Notice carefully to understand our policies and practices regarding your Information and how we will handle it. If you do not agree with our policies and practices, do not use the Site. By accessing or using the Site, you agree to this Privacy Notice.

ilani may change this Privacy Notice at any time, at its discretion. Your continued use of the Site after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates. Material changes will be communicated to our active credit or gaming customers.

The Privacy Notice is subject to and governed by ilani’s Terms of Use (“Terms of Use”) available at the Site here.

ilani may collect two types of information from you when you visit the Site: Personal Information and Non-Personal Information (collectively “Information”).

• “Personal Information” refers to data by which you may be personally identified, such as name, postal address, e-mail address, and telephone number.
• “Non-Personal Information” means data that is about you, but does not identify you specifically. If you do nothing during your visit to our Site but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.
  

We collect Information:

• Directly from you when you provide it to us, including through your applications for credit or other financial services.
• Through our business-to-business communications with you.
• Automatically as you navigate through the Site.
• From third parties who assist us with our business operations, such as credit bureaus relating to your credit and financial transaction history.
• Through Google Analytics.
  

Information You Provide Directly to ilani. The Information that you provide us directly through our Site may include:

• Information that you provide when you create an account or complete a transaction through our Site, including making hotel reservations or gift card purchases.
• Information that you provide by filling in forms on our Site, including name, address, and telephone number.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete.
  

Information Automatically Collected from You. The Information that ilani may automatically collect and store about you when you visit the Site may include:

• Your location.
• The Internet Protocol Address and domain name used. The Internet Protocol address is a numerical identifier assigned either to your Internet service provider or directly to your computer. We use the Internet Protocol Address to direct Internet traffic to you.
• The type of browser and operating system you used;
• The date and time you visited the Site;
• The web pages or services you accessed at the Site;
• The website you visited prior to coming to the Site;
• Details of transactions you carry out through the Site, including payment history and/or gaming activity with ilani;
• Details of transactions you carry out with your ilani Forever Rewards card, including transactions on the website or at our resort; and
• Cookies, which are small text files that a web server (such as ilani or its chosen web hosting company server) places on a user's computer. When accessing a cookie, ilani’s server reads a number associated with a browser, but is unable to determine any data about a user. With that number, our web server can tailor its content to the needs of the specific browser, and we can optimize the Site for your use.
  

Google Analytics Advertising Features. We also may have the following Google Analytics Advertising Features Implemented: Demographics and Interest reporting, Remarketing, GDN Impression Reporting and Double Click Campaign Manager. These features collect data using Google advertising cookies and anonymous identifiers. ilani and third-party vendors use these first-party cookies to access the success of online marketing campaigns, inform future campaigns and improve usability on the Site. To learn how to opt-out of the Google Analytics Advertising Features we use, please see Google Analytics’ currently available opt-outs for the web at tools.google.com/dlpage/gaoptout.

We use Information that we collect about you or that you provide to us, including any Personal Information, for the following purposes:

• To present our Site and the Site Contents (as defined in the Terms of Use) to you.
• To provide you with the data, products, or services that you request from us. For example, when you provide your email address by contacting us, we are able to use your email address to respond to your comment or question personally.
• To provide you with credit or other financial services.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Site or any products or services we offer or provide through it.
• To communicate with you regarding our products and services, including for marketing purposes.
• To personalize our services and advertising to you.
• In any other way we may describe when you provide the Information.
• To fulfill any other purpose for which you provide it.
• For any other purpose with your consent.
  

Site statistics are compiled into traffic reports, which help ilani understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the Site, we are likely to highlight that information on the Site home page. This Information helps us create a better overall experience for Site users.

ilani will retain your Information for as long as necessary to provide the services you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and for other legitimate and lawful business purposes.

We have implemented physical, electronic and organizational safeguards to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure, and we permit only authorized employees, who are trained in the proper handling of this Information, to have access to it. Unfortunately, the Internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

We may use and disclose Non-Personal Information about our users without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:

• To our subsidiaries and affiliates, including third party payment facilitators.
• To contractors, service providers, and other third parties we use to support our business, as described further below.
• With credit bureaus, collection agencies, and other non-affiliated third parties only as permitted by law.
• Certain limited patron Information may be shared with other businesses with which we contract, who may contact patrons as part of a joint marketing or promotional program (Joint Marketers). These businesses may include financial services companies, such as banks and insurance companies, other service providers, such as airlines and car rental agencies, and retailers. The Information we share with them such as name, address and telephone number is gathered solely from participation in our loyalty program.
• To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ilani’s assets, including any related due diligence.
• To fulfill any other purpose for which you provide it.
• For any other purpose disclosed by us when you provide the Information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Except as described above, ilani does not sell any of your Information.

We use third parties to host the Site, design and operate the Site features, and perform administrative, analytics, payment processing, and communications. Services these third parties provide include enabling ilani to send you email newsletters and providing information to ilani about the use of the Site and viewing of our content. We may disclose your Information to these companies so they can carry out these services. These companies are bound by contractual obligations to keep Information confidential.

ilani complies with the requirements of the Children’s Online Privacy Protection Act and related regulations. The Site is not directed at children, and ilani does not knowingly collect any Information from children under 13 years of age. If ilani learns that a child under 13 years of age has provided Information, ilani will delete this Information from our databases. If you are under 13, do not use this Site or provide any Information about yourself to ilani, including your name, address, telephone number or email address. If you become aware that Information of a child under 13 years of age has been provided, please contact us at ilanicontactus@ilaniresort.com.

We are not responsible for the practices employed by websites or services linked to or from the Site, including the information or content contained therein. Our Privacy Notice does not apply to third-party websites or services.

Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Site does not respond to DNT signals.

If you choose not to provide Information, you may be unable to access or use all portions of the Site. We send promotional and marketing communications only with your consent. If you no longer wish to receive these or other communications, please click on the "unsubscribe" link which is included in every email correspondence that is transmitted from ilani.

Certain Information, such as your address or email address, can be updated or corrected simply by calling Customer Service at 1.877.GO.ilani (1.877.464.5264).

To ask questions or comment about this Privacy Notice and our privacy practices, please contact us at 1.877.GO.ilani (1.877.464.5264) or by email at ilanicontactus@ilaniresort.com . You may also contact us by mail using the following address:

Cowlitz Tribal Gaming Authority
ATTN: Legal Department
1 Cowlitz Way
Ridgefield, WA 98642

EFFECTIVE DATE: September 13th, 2021