Privacy Policy

Pavilion Payments Gaming Services, Inc. and its parents, subsidiaries and affiliates (referred to in this Privacy Policy as “Pavilion,” “us,” “we,” and/or “our”) respect your concerns about privacy. This Privacy Policy (“Policy”) relates to the collection of personal information, information security and privacy standards applicable to all users of our online products and services (“Services”), including the associated websites (“Sites”), mobile apps (“Apps”), and transactional kiosks (“Kiosks”).  In the course of providing you with products and services, we may collect certain information from or about you. We are providing this Privacy Policy to explain our practices and policies for collecting, using, and sharing information collected from or about you when you visit, access, or use, or provide information to us in connection with, one of our Services, Sites, Apps, or Kiosks (referred to together as the “Pavilion Services”).  By visiting, accessing, or using, or providing information to us in connection with, the Pavilion Services, you expressly consent to our collection, storage, use, and sharing of your information as described in this Privacy Policy. Please note that if you disagree with anything in this Privacy Policy, you should not visit, access, or use, or provide information to us in connection with, the Pavilion  Services.  This Privacy Policy does not create a contractual obligation between you and Pavilion, and it is subject to our Terms of Service.

This Policy applies to the Pavilion Services provided by Pavilion on our own behalf or in combination with one of our parents, customers, business partners, affiliates, or subsidiaries. Our privacy practices vary depending on the services we provide and the country-specific requirements for the countries in which we operate. For some products and services, where required, we will provide additional privacy policies before collecting your personal information. Please read this Policy carefully. If you have any questions, you may contact us at privacy@pavilionpay.com or by the methods provided in the “Contact Us” section below.

Pavilion provides payment products and services for commercial and non-commercial enterprises. Those products and services include payment card processing, cash access services, ACH services, point-of-sale terminal management and support, merchant accounting, and funds transfer. Many of our customers are businesses or other non-person legal entities. For such customers, information about disclosures, transfers, and other processing of personal information as part of our provision of the Pavilion Services is set out in their agreement with us and the documentation provided at or before onboarding.

Our websites and mobile apps may include links to other websites or mobile applications and other content from third-party businesses. We are not responsible for the privacy practices of these third parties or the content on any third-party website. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

Additional Privacy Policies and Notices

Certain additional Pavilion privacy-related policies and notices may be provided to you at the point of collection, or at the time of obtaining a product or service. The additional policies and notices include the GLBA Notice  (which applies to U.S. customers and consumers as described in that notice).

Personal Information We Collect

Information You Directly Provide to Us

You may provide information directly to us under a wide range of circumstances, such as when you submit information to us through our websites or mobile apps, use any of the Pavilion Services, sign up to receive email or text messages from us, install or use one of our mobile apps, utilize Pavilion Services as a Pavilion VIP Preferred member, enter an online promotion, request information from us, scan your ID at a Kiosk, apply for VIP Preferred, or provide feedback in a survey.

We may collect the following categories of personal information directly from you:

• Identifiers including name and contact details including telephone number, email address, postal address, social media identifiers, and government ID number;
• Information protected against security breaches , such as your username and password, which you may use to log in to the Sites (see “Login Details and Your Responsibility” below), as well as bank information and credit card information;
• Commercial information, such as your preferences regarding products and related services which are of interest to you (see “Managing Your Preferences” below), records of any correspondence we have with you, your transaction history, and information you provide if you report a problem with our Sites;
• Geolocation information such as IP address or mobile device ID;
• Audio information, such as customer service call recordings if you call and speak with a customer service representative;
• Video information, where collected at a Kiosk for security and identity validation purposes;
• Professional or employment related information such as your employment history or qualifications if you apply for employment with us;
• All information about how you use the Pavilion Services.

Information You Post on the Pavilion Websites. If you post information on any public areas of our websites, that information may be collected and used by Pavilion, other website users, and the public generally. We strongly recommend that you do not post any information on our websites that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

Information Automatically Collected Through the Pavilion Websites

• Traffic Data. We may track and collect general log information when you visit a website, including your: (A) Internet Protocol (IP) address, (B) domain server, (C) operating system, and (D) type of Web browser as well as the pages you visit on the website (collectively “Traffic Data“). We may use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of our websites. It enables us to do the following:
  • estimate our audience size and usage pattern;
  • learn what information is of most and least interest;
  • speed up your searches; and
  • learn of any possible website performance problems.

We, or our service providers, may also use Traffic Data to identify your physical location to confirm that you are in a jurisdiction where you can use our mobile or online gaming services. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and transparent GIFs (Graphics Interchange Format, a software technology also known as a pixel tag).

• Data Collected Using Cookies and Other Technologies. We may also automatically collect information from you using cookies and other technologies on our websites. Cookies are small text files offered to your computer by servers in order to keep track of your browser as you navigate a website. Cookies may be stored on your hard drive in which case they remain on your hard drive until deleted, or in temporary memory in which case they are deleted when you shut down your browser or turn off your computer. We may use cookies and similar technologies to identify who you are and may use them when you visit a website, click on our ads, or open our emails. Cookies also enable us to remember your user preferences for our websites. Cookies and other technologies may also be used for site maintenance and analysis, performing network communications, authenticating users, serving contextual advertisements, and protecting against fraud and theft. You can block or remove cookies using the Cookie Settings control panel on our website or your Internet browser’s settings. If you block or remove cookies, your ability to perform certain transactions, use certain functionality, and access certain content on the Pavilion Websites may be affected. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Information We Automatically Collect Through Our Apps, including Location Information. If you install or use one of our Apps, we may collect and use information regarding your mobile device, including but not limited to technical information about your mobile device, system and application software, and peripherals, that is gathered periodically to facilitate any upgrades, product support and other services to you (if any) related to the mobile apps, and to provide services or technologies to you. In addition, if you install one of our Apps and allow your device to share location information with us, we may be able to automatically identify and collect the location of your mobile device, including GPS location, which is the real-time geographic location of your mobile device. We may use your location information for any of the reasons disclosed in this Privacy Policy, including, for example, to provide you with more relevant content and useful app features, or to confirm that you are located in a jurisdiction where you can use our Pavilion Services. We also may use this data for statistical or business-related purposes to improve our products or services.  If you allow an App to send you push notifications, your location information may be used to send real-time offers for goods and services at our properties that are close to your location. You may adjust your device settings to turn off push notifications at any time. Location information may also be collected and used to tailor your marketing offers to your specific interests. You may choose not to share your location details with us by adjusting or turning off your mobile device’s location services settings.

Information We Collect From Other Sources including from Service Providers, Third-Party Services, and Business Partners

We may obtain information about you from other sources, including service providers, third-party services (such as data brokers or analytics firms), publicly available sources, government agencies, or third-party business partners, and we may combine such information with information we have collected about you as described in this Privacy Policy. To the extent we combine such third-party information with other personal information we have collected, we will treat the combined information as personal information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices, except as otherwise required by law.

• Information Collected by Third-Party Analytics Services. We may work with third-party analytics services to help us understand how our Sites, Apps, or Pavilion Services are being used, such as tracking the frequency and duration of use of the Sites, Apps or Pavilion Services. These analytics services may use cookies and other technologies to collect information about the content you view, what websites you visit immediately prior to and after visiting a website, and your system information and geographic information. The information generated by these technologies about your use of the websites or mobile apps will be transmitted to and stored by the applicable analytics services. The information collected by these analytics services allows us to analyze your use of our websites and mobile apps.

• Information You Share on Third-Party Websites or through Social Media Services. Our websites may include links to third-party websites and social media services where you will be able to post comments, stories, reviews, or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services. We may also monitor sentiments regarding Pavilion that you publicly post on social media services or customer review sites. We may reach out to you regarding these postings to address customer service issues and to otherwise help ensure that you have a positive customer experience.

Other Information We Collect Relating to Your Gaming History and Other Interactions with Us

When you use any of our Pavilion Services, we may collect transactional information about these activities and store it with your customer account. We may use this information to make predictions about your preferences and interests, future spending, and gaming activity. We also may share or sell this information to our customers or third-party partners.

Mobile Phone Numbers

Notwithstanding anything to the contrary in this Privacy Policy, unless you provide express consent, we will never share the mobile phone number you have provided for SMS opt-in or for two-factor  authentication purposes with any third parties or affiliates for any marketing or promotional purpose. In addition, we will obtain express consent from you before sending any marketing text messages to your mobile number when required by law. We will not rely on opt-ins that you have provided to non-Pavilion parties in order to send you marketing text messages.

How We Use the Information We Obtain

Subject to your consent if required by law, we may use your personal information for the following business purposes:

• To provide you with the Services you request;
• To obtain commercial and credit information to establish, maintain, or renew a customer's contract(s);
• To comply with the rules and regulations of any credit or debit card payment network;
• To contact you regarding any inquiry you make or to fulfill a request, such as, for example, a request for information about our products and services;
• To improve and personalize your experience when you use our Sites;
• To improve our products and services and for the development of future products and services;
• For internal records keeping and administration of records;
• For auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, auditing compliance with laws and other standards;
• For detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for the activity;
• For internal research for technological development and demonstration;
• To verify or maintain the quality or safety of our products and services and to improve. upgrade, or enhance our services;
• To contact you by email and. if you have signed up for the service, to share e-newsletters or any other updates, communications, or publications;
• For direct marketing purposes subject to your consent if required by applicable law (see "Managing Your Preferences" below);
• As necessary to set up and administer your sign-up to. and use of, the log-in facility available on the Sites;
• For compliance with applicable laws and/or regulations and as otherwise required or permitted by applicable laws and/or regulations;
• To track your use of our Sites, Apps, and Pavilion Services;
• To create a more accurate and complete customer profile for you to better understand and predict the products and services you want to use and to provide a more personalized level of service;
• To notify you about promotions and special offers regarding products and services provided by us or our affiliates or other associated third parties, including our business partners;
• To ask for your participation in our internal market research;
• To generate aggregate statistical studies about our customers to better understand how our customers use our services;
• To contact you in response to your inquiries, comments, and suggestions;
• To protect and defend our rights or property or enforce our agreements with you;
• To perform background checks for any reason (to the extent permitted by applicable laws), which includes but is not limited to any investigation into your identity, any credit checks, or any inquiries into your personal history;
• To process credit card, ACH, and/or other financial transactions;
• Administer general recordkeeping for financial statements and audits;
• Comply with our internal records management policy and retention rules;
• To contact you otherwise when necessary; and
• Otherwise with your consent or as permitted or required by law.

To Whom We May Disclose the Personal Information We Collect

We are a multinational business headquartered in the United States, with subsidiaries and affiliates in various countries around the world. Your personal information may be disclosed to recipients located outside of your country, including our Pavilion subsidiaries and affiliates (see “Our Relationship with Affiliate Companies” below), as well as other types of service providers engaged to help us run our business, subject to your consent if required by law. These types of service providers may include distributors of our products and services, vendors retained to perform functions on our behalf or to provide services to us, including (without limitation) legal, accounting, audit, consulting, account enrollment, web services, marketing, and other professional service providers, and providers of other services related to our business.

In addition, if you were referred to Pavilion Payments Gaming for services via a partner, such as an independent software vendor, we may share information with such partner in accordance with our business relationship with you and that partner, consistent with any privacy policy shared with you by either party at the time of the collection of your personal information.

We take steps aimed at ensuring that all persons who process your personal information as a service provider to us process such information only as necessary for their service delivery and, where required by law, we ensure appropriate written instruction is provided to each service provider.

We may also disclose any of the personal information categories identified above to third parties who are not service providers. Below is a list of categories of third parties to which we may disclose personal information and the purpose for such disclosure:

• To regulators including state and federal agencies, card payment networks, issuing banks, and other parties required to enable compliance with laws, regulations, and industry standards related to transaction processing in order to obtain commercial and credit information to establish, maintain, or renew a customer’s contract(s), as may be required to provide any of the services for which a customer has subscribed, to comply with the rules and regulations of any credit or debit card payment network or otherwise in accordance with this policy;
• To law enforcement, courts, and other relevant parties in response to a court order or a request for cooperation from a regulatory, law enforcement, or other government agency; to establish or exercise our legal rights; to defend legal claims; as otherwise required or permitted by applicable laws and/or regulations; when we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or to protect and defend the rights, property, or safety of Pavilion Payments Gaming, its customers, staff, suppliers, or others;
• Subject to applicable legal requirements, to another company or agent of such company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business assets to such company;
• Subject to applicable legal requirements, we may also disclose:
• To third-party business partners with whom we have joint marketing or similar agreements, or other businesses with whom we have a contractual relationship, who may contact you with marketing and promotional offers. These businesses may include casinos or online gaming companies. If you are a VIP Preferred member and would like us to stop providing your information to these third-party business partners, you may opt-out of personal information sales and/or sharing by submitting a request here.
• We may sell or share your personal information to third parties for monetary compensation.

Our Relationship with Affiliate Companies (Including Sharing and Cross-Border Transfers)

Subject to your consent if required by law, we may appoint an affiliate company to process personal information in a service provider role for and on our behalf. In most cases, we will remain responsible for that company’s processing of your personal information pursuant to applicable data privacy laws.

Because our affiliate companies are located around the globe, your personal information may be transferred to and stored in the United States or in another country outside of the country in which you reside, which may be subject to different standards of data protection than your country of residence.

We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, are carefully managed to protect your privacy rights and interests, and limited to countries that are recognized as providing an adequate level of legal protection or where alternative adequate arrangements are in place to protect your privacy rights.

Data Anonymization and Aggregation

Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it. We may use the anonymized or aggregated data for purposes such as statistical analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and services, conducting risk assessments, and analyzing costs and charges in relation to our products and services. We may share anonymized or aggregated data with our Pavilion affiliates and other third parties. This Policy does not restrict our use or sharing of any non-personal, summarized, derived, anonymized, or aggregated information.

Managing Your Preferences

Subject to your consent if required by applicable law, we may use your personal information to provide you with direct marketing information about our products and services as well as those of our Pavilion affiliates and third parties. Our direct marketing may be by email, telephone, post, SMS, social messaging, or such other method(s) as may become relevant.

We will take steps to ensure that any direct marketing from us which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

You also have options to limit the information that we and our partners collect for online advertising purposes.

• You may disable cookies in your browser or mobile device using their settings menus. Your mobile device may give you the option to disable advertising functionality. Because we use cookies to support Service functionality, disabling cookies may also disable some elements of our online properties.
• The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.
• You may use the Cookie Settings control panel on our website.
• You may contact us directly.

If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you.

If you delete your cookies, you may also delete your opt-out preferences.

Your browser or device may include “Do Not Track” functionality. Our information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this privacy policy regardless of whether a Do Not Track signal is received.

Commitment to Security, Privacy, and Standards

We take seriously our responsibility to protect the security and privacy of the information we receive via our Sites. We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide via our Sites against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Please remember that communications over the internet, such as emails, are not secure. We seek to keep secure all confidential information and personal information submitted to us through our Sites, Apps, and Kiosks in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through our Sites, Apps, and Kiosks.

Cookies and Other Tracking Technologies

A “cookie” is a text file that is stored in your browser when you visit a website. Unique device identifiers like IP address or UDID recognize a visitor’s computer or other device used to access the internet. Unique device identifiers are used alone and in conjunction with cookies and other tracking technologies for the purpose of “remembering” computers or other devices used to access the Sites and Apps.

We may also use other technologies like pixels or tags that allow us to measure responses to our email communications or digital advertisements.

The cookies that we may use on the Sites fall into the following categories:

• Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions taken by you such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but blocking them may impede the functionality of the Sites.
• Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated. If you do not allow these cookies, we will not know when you have visited our site and will not be able to monitor its performance.
• Functionality Cookies. These cookies enable the Sites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some of these services may not function properly.
• Targeting Cookies. These cookies may be set through our Sites by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

How to Delete or Block Cookies

You can manage your choices by visiting the Cookie Settings control panel on our website.

You may also delete or block cookies at any time by changing your browser settings. You can click “Help” in the toolbar of your browser for instructions or review the cookie management guide produced by the Interactive Advertising Bureau available at www.allaboutcookies.org . If you delete or block cookies, some features of the Sites may not function properly.

Children

Our Sites, Apps, Kiosks, and Services are not intended for use by minors. We do not solicit or knowingly accept any personal information from persons under the age of 21. Please do not use our Sites, Apps, Kiosks, or Services if you are under the age of 21.

Changes and Updates

Over time, it may be necessary to modify or supplement our Privacy Policy. When we make changes, we will post the changes on our websites and mobile apps and change the effective date at the top of the Privacy Policy. We encourage you to visit our websites and mobile apps from time to time to review our Privacy Policy in the event it has changed. Your continued provision of information to us or use of any of our services following the posting of changes to the Privacy Policy means that you accept the changes and our use of your personal information in accordance with the revised Privacy Policy. If we make any material changes to our information collection practices, including collecting new types of information, new uses of previously collected information, or new categories of third parties with whom we will share information, we will notify you of changes at least thirty (30) days before the effective date of the changes. If you have provided us with your email address, we will also notify you of material changes to this Privacy Policy by sending an email at least thirty (30) days before the effective date of the changes to the email address you most recently provided to us. We encourage you to keep the email address you provide to us current, and to promptly notify us of any changes to your email address, so that you may receive any notices we send to you regarding material changes to this Privacy Policy. If you do not agree to the changes, you should discontinue your use of our services prior to the time the modified Privacy Policy takes effect.

Privacy Disclosures for Specific Jurisdictions

California

Your California Privacy Rights; “Shine the Light” Law

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year. Please contact us to obtain this information. We will give you the opportunity to decide whether you allow us to share your personal information with third parties for those third parties’ direct marketing purposes before we collect your personal information.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. If we collect personal information subject to the CCPA, that information, our practices, and your rights are described below.

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of certain information about our data collection, use, and disclosure. The following table summarizes the categories of personal information we collect; the categories of sources of that information; whether we disclose, sell, or share that information to service providers or third parties, respectively; and the criteria we use to determine the retention period for such information. The table also summarizes the categories of “sensitive” personal information that we collect, the purposes for which such information is used, and whether we sell or share such information.  The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described above in “How We Use the Information we Obtain.”

We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.

Entities to whom we “sell” or with whom we “share” information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us.  A business “shares” personal information when it discloses personal information to a company for purposes of cross-context behavioral advertising.

Your Rights Under the CCPA

• Opt out of sale or sharing of personal information: You have the right to opt out of our sale or sharing of your personal information to third parties. To exercise this right, please visit our Do Not Sell or Share My Personal Information webpage or contact us. Your right to opt out does not apply to our disclosure of personal information to service providers.
• Know and request access to and correction or deletion of personal information: You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct personal information that we have collected about you and to delete personal information that we have collected directly from you. Please contact us to exercise these rights.

Other US States

Residents of states other than California may have the following rights:

• Opt out of “sales” of personal information and use of their personal information for “targeted advertising,” as those terms are defined under applicable law. 
• Opt out of “profiling” under certain circumstances, as defined under applicable law.
• Confirm processing of and access to personal information under certain circumstances.
• Correct personal information under certain circumstances.
• Request the specific third parties (other than natural persons) to which personal data has been disclosed. (Connecticut, Oregon, and Minnesota only)
• Delete personal information under certain circumstances.

To exercise these rights, please contact us by using one of the methods listed below. 

Nevada

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties. We “sell” personal information under Nevada law. If you are a Nevada resident and would like more information about our data sharing practices, please contact us.

Contact Us

If you have questions about the Privacy Policy, or if you want to exercise your rights as described in the Privacy Policy, you may submit a request by completing this form.

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Last Updated: 31, July 2025