Applicant Privacy Notice
Introduction
This Applicant Privacy Notice describes how BetMGM, LLC and BetMGM Canada Inc. (collectively “BetMGM”) collect, use, protect and share personal information (“Personal Data”) we collect or receive in connection with your job application. BetMGM is committed to processing your Personal Data in accordance with privacy and data protection laws applicable to BetMGM.
This notice applies to individuals who apply to work for BetMGM in the United States and Canada. If an applicant becomes a BetMGM employee, the Personal Data collected as part of the application and hiring process becomes part of your employment file and is used and disclosed in accordance with the BetMGM Employee Privacy Policy.
This notice does not form part of any contract of employment or other contract to provide services. This notice also does not cover your interactions with BetMGM outside of the context of learning about, applying for, or interviewing for a position at BetMGM. For information about how we collect and use information related to those types of interactions, please visit www.betmgm.com.
Definition of Personal Data
For the purposes of this privacy notice, Personal Data includes any information that relates to an identifiable individual. Personal Data does not include anonymous, aggregate or non-personal data (i.e., data that cannot be associated with or tracked back to a specific individual). Some examples of Personal Data include:
- An individual’s name
- Home address
- Home phone number
- Personal email address
- Age
- Employment history
- Education
Special categories of sensitive Personal Data include information related to race, ethnic origin, political opinions, religion, trade union membership, genetics, biometrics (where used for ID purposes e.g., fingerprints), health and sexual orientation. We will process these special categories of Personal Data in the following circumstances:
- With your explicit consent.
- Where we need to carry out our legal obligations or exercise rights in connection with your application.
- Where it is required to meet our regulatory licensing and reporting obligations.
- Where it is needed in the public interest, such as for equal opportunities monitoring.
- Where we need to protect your rights (or that of another person).
- Where it is necessary for the establishment, exercise, or defense of legal claims.
- Where it is necessary to comply with federal, state, provincial, or local law pertaining to leaves or accommodations, to assess your working capacity, or to administer benefits.
If we request your consent to process sensitive Personal Data, we will try, as legally permitted, to provide specific details of the information sought and the reasons we need it.
Information we collect from you and why
We collect your Personal Data throughout the application and recruitment process to fill open job positions and recruit job applicants and candidates. This is typically collected directly from you or by and through third parties such as recruitment agencies, job search websites (e.g., LinkedIn or Indeed), or BetMGM employees or other individuals who recommend you for employment. BetMGM may also collect information from online sources such as social networks and recruiting sites, as well as open government databases and other public sources.
The Personal Data we collect is only used and disclosed for our business purposes, including assessing your job application, performing recruiting duties, and establishing your employment relationship with us. BetMGM may also use your Personal Data to manage, monitor, measure, analyze, protect, and improve the BetMGM recruiting assets, systems and processes.
Apart from Personal Data relating to yourself, you may also provide us with Personal Data of other individuals, such as references submitted to further your application. By providing us with third-party Personal Data you represent to BetMGM that these parties have given their consent that their Personal Data may be processed by BetMGM for the purpose of acting as your reference.
Please see the below table that provides you with an overview of the Personal Data we collect and the purposes for which we process the data we collect. Additional Personal Data may be collected from time to time based on BetMGM need and/or your consent.
| Categories of data | Data elements | Purposes |
| Personal identifiers/ contact details |
|
|
| Demographic information |
|
|
| Recruitment information |
|
|
| Employment information |
|
|
| Education details |
|
|
| Medical information |
|
|
| Information about your use of our electronic systems | Your use of our IT systems including;
|
|
| Third-party assessment results |
|
|
Please note that, as an online gaming company, BetMGM is required to comply with state gaming regulations which includes licensing obligations and certain employees must be licensed by or more jurisdictional agency. The licensing process, which begins when an employment offer is made, includes comprehensive background checks which may include a review of criminal records, financial history, and personal background verification.
Who we share your data with
We disclose information about you to third parties (a) for our legitimate purposes or (b) with your consent. Applicable third parties include, but are not limited to:
- Our joint venture parents (Entain and MGM), as needed, including to administer shared technology resources.
- Our other subsidiaries and affiliates (e.g., BetMGM Canada Inc.)
- Professional advisors and/or consultants, such as our accounting, tax, and legal advisors, where they require information to provide advice to BetMGM.
- Third party service providers who provide recruitment products or services to BetMGM as well as those who provide and support our management and data storage systems.
- Government agencies and any other regulatory authorities for the purpose of licensing approval and/or demonstrating compliance with applicable law and regulations.
- BetMGM employees as necessary for recruiting scheduling, interviewing, and making hiring decisions.
- Applicable third parties where required by law, by order or requirement of a regulator, court, administrative agency, or government tribunal, which includes in response to a lawful request by public authorities, including to meet national security or law enforcement requirements or in response to legal process.
- Potential purchasers of BetMGM.
- Other third parties as necessary to protect individual or group rights, privacy, safety, or property or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of BetMGM, our users, applicants, candidates, employees or the public or as otherwise required by law.
Our third-party providers are required to take appropriate security measures to protect your Personal Data in line with this notice.
BetMGM does not “sell” Personal Data to third parties or “share” Personal Data with third parties for “cross-context behavioral advertising” as those terms are defined under the California Consumer Privacy Act.
Data Transfers
Your Personal Data may be stored and processed outside of the United States and Canada. BetMGM will transfer your Personal Data where appropriate safeguards have been put in place and to comply with any local legislative requirements.
How long we store your data
Unsuccessful applicants. Your Personal Data will be retained in a digital and/or physical format for as long as is reasonably necessary and in line with our data retention obligations. After the expiration of the retention period, BetMGM will use reasonable efforts to securely delete/destroy Personal Data.
Successful applicants. Information submitted as part of a successful application will become subject to the BetMGM Employee Privacy Policy once an offer is accepted. At that time, your Personal Data will be in line with our data retention obligations for employees. After the expiration of that retention period, BetMGM will use reasonable efforts to securely delete/destroy Personal Data.
Monitoring
When using BetMGM recruiting software, employees should not have any expectation of privacy with respect to their use of such equipment or resources.
How we protect your data
BetMGM takes the security of your Personal Data seriously. We have put in place internal controls and security measures to protect BetMGM Personal Data from accidental loss, unauthorized access, use, alteration and disclosure. Access to your Personal Data is restricted to individuals and entities who require access to perform their job functions. We take steps to ensure that third parties who process your Personal Data only process it per our instructions and understand their confidentiality obligations. We have in place procedures to deal with any suspected data breaches, and we will notify you and any relevant regulator of a breach where we are legally required to do so.
Your privacy rights
Please note that your main choice for this type of Personal Data is simply not providing it, such as by not submitting a job application to BetMGM.
In some circumstances, such as where you are employed by BetMGM in a country, province, or state with privacy legislation in place covering employment data, you may have certain rights regarding your Personal Data. We will process your request upon verification of your identity and residence (and, to the extent applicable, the identity of the employee on whose behalf you are making such request if the request is being made by an authorized third party). Requests for access to Personal Data or your personnel file should be sent to betmgmprivacy@betmgm.com. BetMGM will allow access to the extent required by law.
These rights may include:
Right to be informed
You have the right to be provided with information about how we use your Personal Data; this is why we are providing you with the information in this privacy notice.
Access to your information
You may have the right to request a copy of your Personal Data. All requests will be dealt with as required by applicable law.
Correcting or erasing your information
Where we hold information about you that is inaccurate or incomplete, you have the right to ask us to rectify or complete it.
Deletion of your information
You may have the right to request deletion of the Personal Data BetMGM holds about you. BetMGM is permitted, however, to maintain a copy of the Personal Data that BetMGM has collected about you to comply with legal obligations or for other legitimate business purposes.
Restriction/objection to processing
You may have the right to restrict or object to your Personal Data being processed, in whole or in part, which means that you can ask us to limit what we do with your Personal Data. As with the right of deletion, this right is also subject to BetMGM’s obligation to maintain certain information to comply with legal obligations and fulfill BetMGM’s other legitimate business purposes.
Right to withdraw your consent
In limited circumstances where you may have provided your consent to the collection, processing and/or transfer of your Personal Data for a specific purpose, you may have the right to withdraw your consent for that specific processing at any time. For example, you may withdraw your application to a role at any time or request that BetMGM not consider you for additional roles. As with the rights of deletion and restriction/objection to processing, this right is also subject to BetMGM’s obligation to process certain information to comply with legal obligations and fulfill BetMGM’s other legitimate business purposes. To withdraw your consent, please contact the BetMGM privacy team as referenced in the Contact Details section. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we have another legitimate and lawful basis for doing so.
Right to make a complaint
Please refer to the Contact Details section if you have any queries regarding your rights or wish to make a complaint.
Non-Discrimination
In certain jurisdictions, you have a right not to be discriminated against for exercising these rights set out in applicable law.
Contact Details
If you have any questions about any information included in this privacy notice, concerns about how BetMGM manages your Personal Data, or if you would like to exercise your rights in relation to the processing of your Personal Data, please contact the BetMGM Privacy team: betmgmprivacy@betmgm.com
Changes to this policy
BetMGM will keep this privacy notice up to date and notify you of any material changes.
This privacy notice was last reviewed July 15th, 2024 (“Last Updated Date”).