Online Privacy Notice

INFORMATION WE OBTAIN

We may obtain the following types of personal information when you choose to provide it through our Site:

Contact information (such as name, telephone number, and postal and email address);

Login credentials for your Fortis account, including email address or username and password;

Information about products or services viewed on the Site;

Demographic information (such as age and gender);

Geolocation information;

Publicly available information such as name, contact information, content, and online activity that we obtain from publicly available sources (such as public databases); and

any other personal information in content you provide on our Site.

When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web server logs, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely 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 cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.

In addition, as indicated above, we may collect your device’s geolocation information. With your permission, we may receive the precise geolocation and other location information of your device through GPS, Bluetooth and WiFi signals, and other technologies. Your device may provide you with a notification when the Sites attempt to collect your precise geolocation.

We may use these automated technologies on our Site to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Site; (3) tailor the Site around your preferences; (4) measure the usability of our Site and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.

Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Site. 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.

HOW WE USE THE INFORMATION WE OBTAIN

We may use the personal information we obtain for various purpose, including to:

Create and manage your account;

Provide and maintain our products and services;

Communicate with you about our products and services; respond to and communicate with you about your requests, questions and comments; and provide customer service and technical support;

Verify your identity;

Display content and personalize your experience on our Site;

Advertise and market our products and services;

Operate, evaluate, and improve our business;

Maintain and enhance the safety and security of our Site, products, and services and prevent misuse;

Exercise our rights and remedies and defend against legal claims;

Protect against, identify, and prevent fraud and other criminal activity, claims, and other liabilities; and

Comply with and enforce applicable legal requirements, relevant industry standards, and Fortis policies, including our Terms of Use.

THIRD-PARTY ANALYTICS SERVICES

We may use third-party analytics services on our Site, such as Google Analytics. The information we obtain through the Site may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.

INTEREST-BASED ADVERTISING

On our Site, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. This section of our Online Privacy Notice provides details and explains how to exercise certain choices.

You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons, and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information ad services may collect includes data about your visits to websites that serve Fortis advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Site and on third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.

The Site is not designed to respond to “do not track” signals from browsers.

To learn how to opt out of interest-based advertising in the U.S., please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/, and http://preferences-mgr.truste.com/.

For more information, review the Self-Regulatory Principles for Online Behavioral Advertising (“Principles”) of the Digital Advertising Alliance. You can also visit Ad 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 Site 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 Site may still collect information about your use of the Site, including for analytics, fraud prevention, and any other purpose permitted under the Self-Regulatory Principles.

INFORMATION WE SHARE

We may share the information we obtain about you with our affiliates and subsidiaries, and with our joint marketing partners. We also may share the information we obtain about you with third-party vendors and other entities that perform services on our behalf, such as website hosting, data analytics, advertising, and other services.

We also may disclose personal information (1) if we are required or permitted to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent or as directed by your representative.

We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).

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 the personal information we collect about you to the U.S. and other countries outside of the country in which the information originally was collected, including the jurisdictions in which our service providers operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will implement appropriate safeguards to help ensure that we protect that information as described in this Online Privacy Notice and in accordance with applicable law.

RETENTION OF YOUR PERSONAL DATA

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 Online Privacy Notice, which generally means that we will keep your personal information for the duration of our relationship; (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 Online 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 may have certain rights and choices in connection with the personal information we collect from you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in the How To Contact Us section of this Online Privacy Notice. You can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized access, destruction, loss, alteration, disclosure, or use.

CHILDREN'S PRIVACY

Our Site is designed for a general audience and is not directed to children. In connection with the Site, we do not knowingly solicit or collect personal information from children under the age of 13 without parental consent. If we learn that we have collected personal information from a child under age 13 without parental consent, we will either seek parental consent or promptly delete that information. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the How To Contact Us section of this Online Privacy Notice.

LINKS TO THIRD-PARTY SERVICES AND FEATURES

For your convenience and information, our Site may provide links to other online services, and may include third-party features such as apps, tools, widgets, and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Fortis, we are not responsible for these third parties’ information practices.

UPDATE TO OUR ONLINE PRIVACY NOTICE

We may update this Online Privacy Notice from time to time and without prior notice to you to reflect changes in our personal information practices. We will indicate at the top of the policy when it was most recently updated. We encourage you to periodically review this Online Privacy Notice for the latest information on our privacy practices.

HOW TO CONTACT US

You can update your preferences, ask us to remove your information from our mailing lists, submit a request, or ask us questions about this Online Privacy Notice by writing to us at privacy@fortisgames.com.

Effective Date: February 28, 2022

INFORMATION WE OBTAIN

We obtain the following types of personal data in connection with job applications:

• Identification and contact information, such as full name, phone numbers, and email addresses;
• Personal characteristics, such as gender, ethnicity and veteran status (if legally permissible), and citizenship;
• Details about your personal life, such as information on dependents, beneficiaries and/or spouse;
• Professional details, such as information contained in resumes/cover letters concerning your education and work history, training, diplomas and/or certifications, professional qualifications, language and related job skills, career goals and reference’s contact information (name and phone numbers);
• Economic and financial data, such as your current and historic salary;
• Connection or traffic data, such as login timestamps; and
• Other data, such as photographs and video recordings.

We will only collect sensitive personal data concerning you, such as information about your race, for representation analysis and programs and criminal data for background check purposes where we are required or permitted to do so by applicable law, or you have, in accordance with applicable law, provided your explicit consent to the collection and processing of your sensitive personal data.

You are required to provide certain personal data to Fortis so that we may consider your application. The mandatory information is indicated on our application forms. If you fail to provide any personal data that is marked as mandatory we may be unable to evaluate and process your application.

HOW WE USE THE INFROMATION WE OBTAIN

We use the personal data we collect in connection with job applications for the following purposes:

• Recruitment: managing the recruitment process, administering our applicant tracking system portal, making offers to successful job applicants, verifying references and employment history of job applicants, carrying out background checks, and staff onboarding. We process personal data for these purposes on the basis that it is necessary in order to take steps at your request prior to entering into a contract or for our legitimate interests of managing and administering our business and recruiting staff.
• Legal and compliance: compliance with legal and other requirements, such as immigration, record-keeping and various reporting obligations, responding to legal processes such as subpoenas and court orders, pursuing legal rights and remedies, defending litigation and managing any complaints or claims, conducting investigations and complying with policies and procedures. We process personal data for these purposes on the basis that we are required to do so by law or that it is necessary for our legitimate interests, including for the establishment, exercise or defence of legal claims.
• Communications, facilities and emergencies: facilitating communications with you (including informing you about future job opportunities), protecting the health and safety of anyone visiting our premises, and safeguarding office equipment, facilities and other property. We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business, and administering, maintaining and ensuring the security of our IT systems and premises.

We also may use the information we collect about you in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.

When processing personal data for our legitimate interests, we take appropriate measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms (which we can explain to you upon request).

INFORMATION SHARING

Your personal data will only be accessible to those individuals within Fortis with a legitimate need to access and process such information, including members of the People, Legal, and IT team, hiring managers, the interview panel and executives making recruitment-related decisions.

We also share your personal data with Fortis affiliates and other entities of the Las Vegas Sands group, if necessary for the purposes described in this Notice.

Your personal data will also be disclosed to third party service providers, which provide products or services to Fortis or any of our affiliates, including recruiting agencies, internal HR software, analytics providers, background checks providers and hosting service providers.. Fortis or the relevant group entity has contractually bound these third-party service providers to appropriate data security and confidentiality obligations, in accordance with applicable law.

In addition, we may disclose personal data about you (1) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (2) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (3) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (4) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

DATA TRANSFERS

To the extent that the data recipients identified above are located in countries outside the European Economic Area (“EEA”) that have not been recognized by the European Commission as providing an adequate level of data protection, we ensure that appropriate safeguards aimed at ensuring such a level of data protection are in place, including by entering into the European Commission’s EU Standard Contractual Clauses with the data recipients pursuant to Article 46, §2 of the EU General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”). To obtain a copy of the safeguards we have put in place, please contact us as indicated below.

YOUR CHOICES AND RIGHTS

Subject to applicable law, you have the right to (1) request access to the personal data we maintain about you; (2) request that we correct or erase your personal data; (3) to obtain the restriction of our processing of your personal data; and (4) object at any time to the processing of your personal data on grounds relating to your particular situation; and (5) where you have consented to the processing of your personal data, withdraw your prior consent at any time. Subject to applicable law, you also have the right to receive, in a structured, commonly used and machine-readable format, the personal data that you have provided to us about you, with your consent or in order to take steps prior to entering into a contract. You also have the right, subject to applicable law, to have this information transmitted to another data controller, where it is technically feasible.

To exercise these rights, please contact us as indicated in the How To Contact Us privacy@fortisgames.com section of this Privacy Notice.

If you are not satisfied with our response to your request, you may lodge a complaint with a supervisory authority.

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request if we find it to be manifestly unfounded or excessive, or in case of an access request, in order to provide you with additional copies of the personal data we maintain about you.

HOW WE PROTECT PERSONAL DATA

We maintain administrative, technical and physical safeguards designed to protect personal data against unauthorised access, disclosure or use.

RETENTION OF PERSONAL DATA

We will keep your personal data for the duration of our relevant recruitment processes, plus a reasonable period thereafter taking into account applicable statute of limitation periods and records retention requirements under applicable law. Retention periods may be extended if you agree that we may retain your personal data to inform you about future opportunities with Fortis.

UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice may be updated periodically to reflect changes in our privacy practices. We will post a notice on the Site to notify you of significant changes to this Privacy Notice. The date at the top of the Privacy Notice will indicate when the Notice was last updated.

HOW TO CONTACT US

If you have any questions or would like to exercise your rights in relation to the processing of your personal data, please contact us at: privacy@fortisgames.com.