PRIVACY

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, e-mail address, telephone number, fax number, gender, gaming activity, purchase and reservation information. 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.

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 Siena Hotel Spa Casino Web Sites, including what pages you look at and what information you download. When you visit the Siena Hotel Spa Casino 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.

C. Cookies and Information Collected by Advertising Companies

When you visit Siena Hotel Spa Casino 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 Siena Hotel Spa Casino 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 Siena Hotel Spa Casino Web Sites. In addition, blocking or deleting browser cookies may not block or delete other types of cookies including Flash cookies.

Third-party advertising companies that work with us may also use cookies and similar technologies to collect Non-Personal information at the Siena Hotel Spa Casino 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.”

II. HOW WE USE THE INFORMATION WE COLLECT

A. Uses by Siena Hotel Spa Casino

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, e-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 Siena Hotel Spa Casino Web Sites; and (5) responding to your inquiries or other communications.

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 e-mail 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 Siena Hotel Spa Casino 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.A. below. Opting-out will not prevent your Personal Information from being used for non-marketing purposes.

B. 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.A. 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:

(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 Siena Hotel Spa Casino;

(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 Siena Hotel Spa Casino, 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 Siena Hotel Spa Casino Web Sites;

(9) to prevent imminent physical harm or threats to public safety;

(10) to third-party vendors that Siena Hotel Spa Casino may use to perform functions on behalf of Siena Hotel Spa Casino, 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. 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 write to:

Siena Hotel Spa Casino

Attn: Privacy Policy

1 Lake Street

Reno, Nevada 89501

IV. SECURITY

Personal Information and Non-Personal Information collected by Siena Hotel Spa Casino Web Sites 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 e-mails 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 Siena Hotel Spa Casino 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 Siena Hotel Spa Casino 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.

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.

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 Siena Hotel Spa Casino Web Sites along with the revised Policy.