Privacy Policy
GEM Rewards Privacy Policy
The GEM REWARDS app is operated by GEM Rewards – a fully owned subsidiary of Delaware
North Co.
GEM Rewards is designed to deliver an engagement opportunity to guests and users in Illinois
that participate in GEM’s retail operations. For those that are interested in fun and exciting
offers, promotions, awards, rewards and experiential journeys that are awarded to guests and
users – GEM Rewards is the perfect program. In pursuit of our mission to deliver such a
program, GEM Rewards validates certain information from the guests and users. Given the
retail nature of GEM operations in Illinois, such awards, rewards and benefits are available to
users and guests based on the amount of time such users spend within GEM’s retail operations
in Illinois. The other side of such rewards and benefits associated with the GEM Rewards
program is the need to be cognizant of each guest’s privacy considerations. Being transparent
about our use of guests’ location and other information and respecting their privacy is
incredibly important to GEM Rewards.
The GEM Rewards app is designed to seek permission and consent from users to use Location
information – at all times. Should the user decline the Location information sharing with the
app, then such information is unavailable to the app.
Location services may be used to allow users to earn entries into various promotions, offers and
marketing programs – resulting in eligibility to win various awards, rewards and experiences.
When a user is within an operator’s location, the app allows users to start earning entries into
such promotions in a passive manner without the user having to engage with the app – click
buttons etc. Such passive promotional engagements have rich rewards within the app.
In addition to the above, location information is essential for GEM Rewards to allow certain
promotional activity determination to take place within their geo-fenced premises, i.e. when
the user is using the app within the operator’s geographical premises.
User consent and permission to provide location information to the app even when the app is
not in active use, allows GEM Rewards to engage with the user in a meaningful manner as it
pertains to such promotional and marketing awards related activities.
This Privacy Policy applies when you use our Services (described below). Please read it before
using GEM Rewards services because it will tell you how we collect, store, use, disclose, and
otherwise process, your personal information when providing these Services to you. This
Privacy Policy is not, however, a contract and does not create any legal rights or obligations.
If you have questions, comments, or concerns regarding our Privacy Policy or practices, please
Contact Us at support@whiteivoryelephant.com
DEFINED TERMS
As used in this Privacy Policy: (a) “Locations” refers to the various bars restaurants, lounges,
bowling alleys and entertainment facilities located in Illinois that are owned, operated or
managed by GEM – a fully owned subsidiary of Delaware North.
(b) “GEM Rewards websites” refers to websites that display this Privacy Policy, including, but
not limited to, http://www.whiteivoryelephant.com.
(c) GEM REWARDS Mobile, GEM Reward Apps refer to mobile application(s) managed
by White Ivory Elephant Technologies Corporation under the GEM Rewards name that display
this Privacy Policy, including, but not limited to, the GEM Rewards® mobile application.
(d) “Personal information” refers to any information by which you can be personally identified,
such as your first name, last name, address, phone number, email address, driver license
number, geolocation information, GEM Rewards Patron/Guest/Player number, date of birth,
purchase information, gaming activity information, biometric information and other similar
information.
(e) “Non-personal information” refers to information by which you cannot be personally
identified.
Revised: July 2024
Privacy Policy
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