Effective Date: January 1, 2020
This CCPA Privacy Notice for California Residents supplements the information contained in Salem Media Group’s privacy notice at https://salemmedia.com/privacy-policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.
The CCPA currently exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some of its requirements.
Information We Collect and How We Use It
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months, and we may have collected information in some or all of these categories from you depending on the nature of your interactions with us.
Identifiers. Examples of identifiers include your real name, alias, postal address, unique personal identifier, online and social media usernames, Internet Protocol address, email address, account name, Social Security number, driver’s license number, or other similar identifiers.
Personal Information Categories listed in the California Customer Records statute. Examples of this type of information include your name, signature, Social Security number, address, telephone number, driver’s license or state identification card number, credit card number or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law. Examples of these characteristics include your age, religion or creed, marital status, sex, and veteran or military status.
Commercial information. Examples of this information include records of personal property, products or services you purchased, obtained, or considered, or your purchasing or consuming histories or tendencies.
Internet or other similar network activity. Examples of this information include your browsing history, search history, and information on your interaction with a website, application, email, or advertisement.
Geolocation data. Examples of this information include your physical location or movements when you use devices such as a computer or mobile phone to access or our platforms or services.
Inferences drawn from other personal information. Examples of these inferences include a profile reflecting your preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.
How We Use Information We Collect
Salem Media Group uses the information we collect from you to provide you with access to certain areas and features of our platforms, including our websites and mobile applications, and to personalize your experience; to respond to your questions, requests, or to take and fulfill orders for products and services; to send you marketing communications; to market and advertise for third parties; to communicate with you about your accounts and activities with us; to administer and provide contests, events, and other promotions; to maintain the safety and security of our users, services and properties, and to monitor and improve the operation, delivery and accessibility of our services. We may also use any or all of this information to comply with the law, detect or prevent fraud, and to defend our legal rights.
How We Collect Information
We, and our service providers, obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete or products and services you purchase from us, or when you register for certain services, enter contests or competitions, post or provide photos, videos or other information to our websites or applications, interact with us via third party applications or social media sites, or otherwise communicate with us or our affiliates.
Automatically from your devices. Information associated with you and/or your device(s) may automatically be collected or received as part of your use of our websites, applications, and emails through device-based tracking technologies such as cookies, pixels, tags, beacons, scripts or other technology. We may also automatically collect or receive such information any time you interact with our advertising and content on other websites and platforms. Advertisers also may collect information from your interaction with advertising on our websites and platforms.
From third parties. We may collect information about you from other sources, such as publicly available databases and other third parties that have the right to share your personal information. We also may receive information about you from our vendors and service providers we hire to help us run our businesses, including the companies that host or operate our websites, applications and platforms, collect debts or process payments for us, provide customer service, send emails for us, conduct surveys, fulfill orders, or provide marketing, analytics, and advertising services. We also may receive information about you from our business partners, including businesses with whom we partner for promotions or who advertise with us. We also may get personal information about you from advertising networks and search information providers. Other users may decide to provide us with your personal information so that we may invite you to join our services or so we can facilitate communication between users of our services and platforms.
Sharing Personal Information
We may share your personal information among subsidiaries of Salem Media Group. We may also disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt out of further sales
We may share personal information with the following categories of third parties:
- Service providers. We share personal information with vendors who help us with certain services, including customer support, email and text message deployment, research and analytics, marketing and advertising services, data processing and management, fraud prevention, transaction and payment processing, promotion and survey administration, and order fulfillment.
- Business Partners, Advertisers, and other Third Parties. With appropriate consent where required, we may share or make available personal information with our sponsors, partners, advertising networks, advertising servers, and analytics companies or other third parties in connection with our and their marketing, promotional and other offers, as well as product information.
- Audience Measurement Services. We may share personal information with audience measurement companies like Nielsen.
- Law Enforcement, Regulators, Courts, and other Governmental Authorities. We share any of the categories of information we collect, as appropriate or required, to respond to subpoenas, court orders, legal process, and other law enforcement measures, to comply with other legal obligations, to respond to an emergency, or otherwise to protect the rights, property, safety, or security of other parties, visitors to our platforms, or the public.
- Business or Asset Transfers. In the event Salem or any Salem subsidiary is involved in a merger, acquisition, transfer of control, bankruptcy, reorganization, or sale of assets, or diligence associated with such matters, we may share personal information. For example, if another entity acquires us or all or substantially all of our assets, or assets relating to any of our platforms, your information may be disclosed to that entity as part of the due diligence process and may be transferred to that entity as one of the transferred assets.
The following categories of personal information may be disclosed to the above third parties for a business purpose: identifiers, personal information categories listed in California Customer Records statute; characteristics of protected classifications under California or federal law, commercial information, internet or similar network activity information, geolocation data, and inferences.
The following categories of personal information may be sold by us or our affiliates to business partners, advertisers, and other third parties, or as part of business or asset transfers: identifiers, personal information categories listed in California Customer Records statute, characteristics of protected classifications under California or federal law, commercial information, internet or similar network activity information, geolocation data, and inferences
Your Rights and Choices
The CCPA provides consumers who are California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B personal information. We also are not required to search for personal information if certain conditions are met, and in response to a request we will describe the categories of records that may contain personal information that we did not search because they meet these conditions.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
For example, we may deny your deletion request, or fulfill a request only in part, based on our legal rights and obligations. For example we may retain the information if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by
- Sending us an email:
Eagle Financial Publications: [email protected]
- Contacting us by mail:
Eagle Financial Publications
300 New Jersey Avenue NW
Washington, DC 20001-2253
Attn: Data Privacy Department
Information about submitting requests to other Salem Media Group businesses is contained in the Salem Media Group, Inc. CCPA Privacy Rights notice, at https//salemmedia.com/smg-ccpa-privacy-rights-notice/
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. When submitting the request, please ensure that the authorized agent identifies himself/herself/itself as an authorized agent for you.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out Rights
California residents age 16 or older may opt out of the “sale” of their personal information. We do not sell the personal information of California consumers we actually know are less than 16 years of age. Under California law, a “sale” may include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior to add to a profile about your device, browser or you. This profile enables delivery of interest-based advertising on Salem websites, as well as other websites.
If you would like to opt out of our sales of your information, you or your (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our websites, applications, or other platforms and services following the posting of changes constitutes your acceptance of such changes.
Last updated: June 23, 2020