Personal Information and the MGM Resorts International Web Site

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1 GLOBAL PRIVACY POLICY MGM RESORTS INTERNATIONAL EFFECTIVE: March 1, 2012 MGM Resorts International values your patronage and respects your privacy. This Privacy Policy ("Policy") describes the privacy practices of MGM Resorts International and the MGM Resorts International web sites and properties described below (collectively, "us" or "we"). You may click here to view Frequently Asked Questions about our Policy. Please read this Policy carefully before submitting any information to us. If, after reviewing this Policy, you have any privacy questions or concerns, you may contact us at This Policy applies only to MGM Resorts International, the MGM Resorts International web sites that post this Policy (collectively, "MGM Web Sites"), and the resorts, casinos and properties listed below (collectively, "MGM Resorts"): ARIA Resort and Casino in Las Vegas, Nevada Beau Rivage in Biloxi, Mississippi Bellagio in Las Vegas, Nevada Circus Circus in Las Vegas, Nevada Circus Circus in Reno, Nevada CityCenter Residential Division in Las Vegas, Nevada Excalibur in Las Vegas, Nevada Gold Strike in Jean, Nevada Gold Strike Resort in Tunica, Mississippi Luxor in Las Vegas, Nevada Mandalay Bay in Las Vegas, Nevada MGM Grand in Las Vegas, Nevada MGM Grand Detroit in Detroit, Michigan MGM Grand Sanya Monte Carlo in Las Vegas, Nevada New York-New York in Las Vegas, Nevada Skylofts at MGM Grand in Las Vegas, Nevada The Crystals at CityCenter in Las Vegas, Nevada THEhotel at Mandalay Bay in Las Vegas, Nevada The Mirage in Las Vegas, Nevada The Signature at MGM Grand in Las Vegas, Nevada Vdara Condo Hotel at CityCenter in Las Vegas, Nevada This Policy does not apply to any other web sites, including other web sites that may be owned, operated, or affiliated with MGM Resorts International or its subsidiaries. Nor does it apply to any other subsidiaries of MGM Resorts International, or to any other resorts, casinos, or other properties that are owned, operated, or affiliated with MGM Resorts International or its subsidiaries.

2 MGM Resorts International is a United States corporation subject to the laws of the United States. This Policy describes our information collection, use, and sharing practices in the United States. The United States may not offer a level of privacy protection as great as that offered in other jurisdictions. In jurisdictions outside of the United States where we are subject to different or more restrictive local laws, we may adjust our practices in those jurisdictions to comply with local laws. Otherwise, we make no representation that the practices described in this Policy are compliant with laws outside of the United States that apply to the collection, security, use and disclosure of information. Information that is collected or stored in jurisdictions outside of the United States may, subject to applicable law, be disclosed or transferred to the United States or other locations. When information is transferred to the United States, it will be handled in accordance with the laws of the United States. I. INFORMATION WE COLLECT A. Personal Information "Personal Information" is information through which you can be identified. We collect Personal Information that you provide voluntarily to us. Some examples of Personal Information that we may collect include your name, date of birth, postal address, address, telephone number, fax number, gender, gaming activity (in jurisdictions where gaming is permitted), and purchase and reservation information. If you visit MGM Resorts, Personal Information may include your image in a live video feed that can be viewed on the MGM Web Sites. Some Personal Information is considered "Confidential Personal Information". Confidential Personal Information is your name in combination with one or more of the following: credit or debit card number, financial account number, driver s license number, U.S. state identification card number, Social Security number, passport number, and naturalization number. In addition to Personal Information that you provide voluntarily to us, we may obtain Personal Information from third parties including, but not limited to, business partners, family members, friends, and entities that direct you to or are located at MGM Web Sites or MGM Resorts. In situations where your Personal Information is collected by third parties under contract with us for fulfillment and other purposes, we require such third parties to exercise reasonable care to protect your Personal Information and restrict the use of your Personal Information to the purposes for which it was provided. B. Non-Personal Information "Non-Personal Information" is information about you or your activities through which you cannot be personally identified. When you use the Internet, your web browser or software may transmit certain information to the servers that host the web sites you visit. Such information may include, for example, the unique number assigned to your server or Internet connection, your geographic location, and your interactions with the MGM Web Sites, including what pages you look at and what information you download. When you visit the MGM Web Sites, our servers and servers operated by third-party advertising companies may collect Non-Personal Information. In situations where it is possible to do so, Non-Personal Information may be linked to Personal Information.

3 C. Cookies and Information Collected by Advertising Companies When you visit MGM Web Sites, we use cookies and similar technologies to help us recognize and serve you better. Cookies are small files that contain information sent by a web site that is saved on your computer s hard drive. Cookies enable us to gather data such as web pages visited, links clicked, and material download. Cookies also are used to put a unique identifier on your computer. This helps us to generate statistics regarding usage of MGM Web Sites, such as the percentage of repeat visitors. In situations where it is possible to do so, this unique identifier may be linked to Personal Information. There are different types of cookies including browser cookies (also known as html cookies) and Flash cookies (also known as Local Shared Objects). You can configure your browser to reject browser cookies or to notify you when browser cookies are offered so that you can accept or reject such cookies. However, if you reject browser cookies, you may not be able to conduct some transactions or use some services on MGM Web Sites. In addition, blocking or deleting browser cookies may not block or delete other types of cookies including Flash cookies. For information on blocking or deleting Flash cookies, click here. Third-party advertising companies that work with us may also use cookies and similar technologies to collect Non-Personal information at the MGM Web Sites and other web sites for a variety of purposes including providing you with advertisements that are likely to be of interest to you. This type of ad customization is sometimes referred to as online behavioral advertising. For more details about cookies, web beacons, and similar technologies that may be used by thirdparty advertising companies, click here. If you would like more information about your choices concerning behavioral advertising, including how you may opt-out of some uses of information collected by members of the Network Advertising Initiative that may collect Non-Personal Information at the MGM Web Sites, click here. II. HOW WE USE THE INFORMATION WE COLLECT A. Uses by MGM Resorts International Except for Confidential Personal Information, we may use Personal Information and Non- Personal Information for our own marketing purposes, including, but not limited to, notifying you of special promotions, offers and events via postal mail, , telephone, text message, and other means. Confidential Personal Information will not be used for our own marketing purposes without your express consent. We may also use Personal Information and Non-Personal Information for non-marketing purposes. Some examples of such use include (1) processing and fulfilling reservations or purchases; (2) conducting statistical or demographic analysis; (3) tracking reservations and corresponding hotel stays generated through our affiliate program and calculating or auditing commissions that may be paid in relation to a hotel stay; (4) customizing your experience at MGM Web Sites; and (5) responding to your inquiries or other communications.

4 We may combine Personal Information with other generally or publicly available information to help us identify your preferences or interests. Your Personal Information may also be merged with Personal Information available from other sources such as (1) companies that match addresses with postal addresses and other information; (2) credit card verification and credit services; and (3) other resorts, casinos, or properties that are owned, operated, or affiliated with MGM Resorts International or its subsidiaries. If you do not want us to use your Personal Information for marketing purposes, you may opt-out of such uses by notifying us in accordance with Section III.B. below. Opting-out will not prevent your Personal Information from being used for non-marketing purposes. B. Sharing within MGM Resorts International and with Subsidiaries Except for Confidential Personal Information, your Personal Information and Non-Personal Information may be shared for any purpose (1) among MGM Resorts International, MGM Resorts, and MGM Web Sites, and (2) with MGM Resorts International subsidiaries not covered by this Policy, and any other resorts, casinos, or other properties that are owned, operated by or affiliated with MGM Resorts International or its subsidiaries (collectively, Subsidiaries ). If you do not want your Personal Information to be shared among MGM Resorts International, MGM Resorts and MGM Web Sites or with Subsidiaries for marketing purposes, you may opt-out of such sharing by notifying us in accordance with Section III.B. below. Although you may request to opt-out of sharing Personal Information for marketing purposes, we may share Personal Information among MGM Resorts International, MGM Resorts and MGM Web Sites and with Subsidiaries for non-marketing purposes. Confidential Personal Information will only be shared among MGM Resorts International, MGM Resorts, and MGM Web Sites and with Subsidiaries to the extent necessary to permit validation of your identity, completion of a purchase or credit transaction, recording of gaming-related activity (in jurisdictions where gaming is permitted), or other legitimate non-marketing business purposes. C. Sharing With Business Partners and Other Third Parties Except for Confidential Personal Information, we may share your Personal Information with our business partners for joint marketing efforts, or for our business partners own marketing purposes. When we provide Personal Information to our business partners, we require them to exercise reasonable care to protect your Personal Information and restrict the use of your Personal Information to the purposes for which it was provided to them. If you do not want us to share your Personal Information with business partners for marketing purposes, you may opt-out of such sharing by notifying us in accordance with Section III.B. below. Although you may request to opt-out of sharing Personal Information with our business partners for marketing purposes, we may disclose Personal Information to our business partners and other third parties for the following purposes:

5 (1) if you enroll in our responsible gaming program (in jurisdictions where gaming is permitted); (2) for non-marketing purposes, such as processing and fulfilling reservations or purchases; (3) in connection with a business transaction involving a sale, purchase, reorganization, or transfer to a third party of any of the assets of MGM Resorts International, any MGM Resorts, and/or any MGM Web Sites; (4) to comply with a court order, subpoena, search warrant or other valid legal process; (5) to comply with legal, regulatory or administrative requirements of any governmental authorities; (6) to protect and defend MGM Resorts International, its subsidiaries and affiliates, and all of their officers, directors, employees, attorneys and agents in connection with any legal action, claim or dispute; (7) to satisfy any contractual obligation to indemnify our contractors, business partners or other third parties in connection with any legal action, claim or dispute; (8) to enforce the Terms of Use of MGM Web Sites; (9) to prevent imminent physical harm or threats to public safety; (10) to third-party vendors that MGM Resorts International may use to perform functions on behalf of MGM Resorts International, such as companies that process credit card transactions; (11) to prevent fraud; and (12) to engage in debt collection. When we provide Personal Information to our business partners and other third parties for such purposes, we require them (to the extent feasible) to exercise reasonable care to protect your Personal Information and restrict the use of your Personal Information to the purposes for which it was provided to them. III. YOUR COMMUNICATION PREFERENCES A. Guestbooks By using our Guestbooks, you can view and update your Personal Information and choose which MGM Resorts and MGM Web Sites you are most interested in hearing from. You can also select from among various communications preferences including direct mail, , telemarketing, and text messaging. To use our Guestbooks, visit any MGM Web Site and select " Promotions" or "Guestbook". If you are an M life Players Club member, you may update your communications preferences by visiting logging in to your account, and selecting "My Account". B. How to Opt-Out If you wish to opt-out of receiving solicitations from us or do not want us to share your Personal Information with our business partners for marketing purposes, please us at privacy@mgmresorts.com, call (866) , or write to: MGM Resorts International Attn: Privacy Policy

6 840 Grier Drive Suite 200 Las Vegas, Nevada If you do not want us to share your Personal Information among MGM Resorts and MGM Web Sites or with Subsidiaries for marketing purposes, you may us at or call (866) For information on how to opt-out of some uses of Non-Personal Information collected by thirdparty advertising companies at the MGM Web Sites, click here. C. Telemarketing Even if you registered your telephone number on a Do-Not-Call list, certain exemptions may allow us to contact you by telephone. However, to ensure our customers' preferences are honored, we also maintain our own internal do-not-call list. If you would like to opt-out of receiving telemarketing sales calls from us by adding your telephone number to our internal donot-call list, please click here. IV. SECURITY Personal Information and Non-Personal Information collected by MGM Resorts International, the MGM Web Sites and MGM Resorts are stored on secure servers, which are protected by firewalls and other industry standard security measures. These security measures are intended to protect these servers from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. We have controls in place that are designed to detect potential data breaches, contain and minimize the loss of data, and conduct forensic investigations of a breach. Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your Personal Information. Employees who violate our privacy policies are subject to disciplinary action, up to and including termination. We cannot enforce or control the security of the computers, electronic devices, or electronic communication method that you may use to send s and submit information to us over the Internet. You are responsible for ensuring that the computers, electronic devices and electronic communication methods you use will provide adequate security for communicating with us. We are not responsible for the disclosure or interception of information that you send us before we receive it. As a standard security practice, we will take reasonable steps which are standard in the industry to ensure that the communication methods used to support the MGM Web Sites do not permit connection or communication by methods that have known security weaknesses or vulnerabilities. As such, if you experience trouble using an MGM Web Site, it may be an indication that you need to upgrade your Internet browsing tool or application to a newer version that supports more secure communication methods.

7 V. OTHER WEB SITES We are not responsible for the information collection or privacy practices of other web sites, including web sites operated by our business partners or other third parties. You should review and understand the privacy policies posted on any linked sites you visit before using those sites or providing any Personal Information. VI. PERSONS UNDER AGES 18 AND 21 Certain of our areas and activities are intended for persons 21 or older. If you are under 21, we ask that you do not access or attempt to access any areas or participate in any activities that are restricted to persons 21 or older. We do not knowingly collect or allow the collection of Personal Information from persons under 18. If you are the parent or guardian of a person under 18 and believe that the person has provided us with Personal Information, you may contact us at privacy@mgmresorts.com and request that it be deleted from our files. VII. CHANGES TO THIS POLICY We reserve the right to revise this Policy at any time without notice. When this Policy is revised in a material way, notice will be posted on the MGM Web Sites along with the revised Policy.

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