(Effective and Last Modified June 22, 2020)
A. INFORMATION WE COLLECT
We typically collect two kinds of information about you when you use our Services: (1) information that you provide that personally identifies you; and (2) information that does not personally identify you that we automatically collect or that you provide us. We also collect information if you voluntarily provide it to us at one of our events, which may personally identify you.
(1) Personally Identifiable Information: Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, mail address, phone number, etc. As a general policy, we do not automatically collect your personally identifiable information when you use our Services. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable information in connection with a feature, program, promotion or some other aspect of our Services. For instance, you may: (a) provide your name, mail/shipping address, email address, credit card number and phone number when registering with our App or Website, or in connection with your participation in a promotion; (b) provide certain demographic information about you (e.g., age, gender, purchase preference, usage frequency, etc.) when using our App, or participating in a survey or poll; or (c) post a general comment and/or recommendation through our Services. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity, purchase a product or service, or gain access to certain content or features available through our Services.
(2) Non-Personally Identifiable Information: Our definition of non-personally identifiable information is any information that does not personally identify you. Non-personally identifiable information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We obtain non-personally identifiable information about you from information that you provide us, either separately or together with your personally identifiable information. We also automatically collect certain non-personally identifiable information from you when you access use our Services. This information can include, among other things, the computer, mobile device or equipment (“Device”) you are using, other applications or software you are using, your mobile carrier and mobile network information, your IP addresses or Device identifier, the type of browser (e.g., Safari, Opera, etc.) and operating system you are using (e.g. Android, iOS, etc.), your search queries, and how much you use our Services.
Location Information: As noted, when you use our Services, particularly our App, we may automatically collect certain Device-specific information. This includes the general or specific location of your Device through GPS, Bluetooth or WiFi signals. Before we collect or send location-specific information, it is our practice to ask for your consent. In some instances, your operating system may not allow you to install our App unless you provide consent. In all instances, you may withdraw your consent by disabling location features for your Device – the App will still work though certain location features (e.g., Store Locator) may not function and certain other Services may be limited.
B. HOW WE USE & SHARE THE INFORMATION COLLECTED
(1) Personally Identifiable Information: The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to later contact you for a variety of reasons, such as customer service, providing you promotional information for our products or those of our parent company, subsidiaries or other affiliated companies (“affiliated companies”), or to communicate with you about content or other information you have posted or shared with us via use of our Services. You may opt-out from receiving future promotional information from us or our affiliated companies, or direct that we not share your information with any affiliated companies, as set forth below. However, the use of certain Services may be conditioned on your ongoing consent to provide you promotional information.
In certain instances, we may also share your personally identifiable information as follows:
- With our third-party vendors performing functions on our behalf (or on behalf of our affiliated companies) – e.g., vendors that operate the Website or App, process credit card orders, administer our promotions, provide us marketing or promotional assistance, analyze our data, assist us with customer service, etc. Our vendors agree to use this information, and we share information with them, only to carry out our requests; and
- With participating third-party sponsors to a program or promotion (e.g., a sweepstakes or contest) you enter via our Services and certain third-party co-promotional partners and others with whom we have marketing or other relationships.
(2) Non-Personally Identifiable Information: We use non-personally identifiable information in a variety of ways. For example, we may use non-personally identifiable information to evaluate use of our Services, track the types of products being purchased, gauge coupon or offer redemption rates, understand customer needs and trends, carry out targeted promotional activities, and to improve our Services. We may use your non-personally identifiable information by itself or aggregate it with information we have obtained from other customers or other sources. We may, among other things, share your non-personally identifiable information with our affiliated companies, allow third parties to collect such information directly from you, and/or sell the non-personally identifiable information to third parties to achieve these and any other business objectives (e.g., generate revenue, form relationships, etc.). However, it is important to remember that your non-personally identifiable information (whether standing alone or combined with other non-personally identifiable information) is anonymous information that does not personally identify you.
C. TRACKING TECHNOLOGIES
(1) Cookies/Web Beacons. We automatically receive and store certain types of non-personally identifiable information whenever you interact with us. For example, like many websites, we use “cookies,” “web beacons” (also called “clear gifs” or “pixel tags”) and embedded scripts to obtain certain types of information when you use or access our Services. “Cookies” are small files that we transfer to your computer’s hard drive or your web browser memory to enable our systems to recognize your browser and to provide convenience and other features to you. “Web beacons” are tiny graphics with a unique identifier, similar in function to cookies, and may be used to track the online movements of users, when an email has been opened, and to provide other information.
Examples of the information we collect and analyze in this manner include the Internet Protocol (IP) address used to connect your Device to the Internet; computer and connection information such as browser type and version, operating system, and platform; your activities our Website, including the products you view or searched for, as well as the URL you come from and go to next (whether this URL is on our Website or not); and cookie number. It is important to note that the cookies and web beacons that we use do not contain and are not tied to personally identifiable information about you.
A couple of important notes about this opt-out tool: (1) it includes all the advertising networks that we may work with, but also many that we do not work with; and (2) it may rely on cookies to ensure that a given advertising network does not collect information about you (“Opt-out Cookies”) – an explanation of how Opt-out Cookies work can be found on www.aboutads.info. Therefore, if you use different Device, change web browsers or delete these Opt-out Cookies from your computer, you will need to perform the opt-out task again. In addition, third party mobile applications, such as AppChoices (offered by the Digital Advertising Alliance), may allow you to opt out of preference based advertising via your Device.
(3) Do Not Track Features: Certain internet browsers may offer you the option of providing notice to websites that you do not wish for your online activities to be tracked for preference based advertising purposes (“DNT Notice”). Some browsers are, by default, set to provide a DNT Notice, whether that reflects your preference. Please note that with respect to our Website, we do not take any action based on browser based DNT Notices. If you do not wish to participate in preference based advertising activities, you should follow the simple opt-out process identified above.
D. OTHER USES & INFORMATION
(1) Email Communications: If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. However, aside from our reply to such an email, it is not our standard practice to send you email unless you request a particular service or sign up for a feature that involves email communications, it relates to purchases you have made with us (e.g., product updates, customer support, etc.), we are sending you information about our other products and services, or you consented to being contacted by email for a particular purpose. In certain instances, we may provide you with the option to set your preferences for receiving email communications from us; that is, agree to some communications but not others. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
(3) Transfer of Assets: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets, the personally identifiable information and non-personally identifiable information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
E. PUBLIC FORUMS
F. SPECIFIC PRIVACY RIGHTS
(1) Children: Neither our App nor any of our other Services are intended for children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us, please contact us at email@example.com. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit the use of that information.
(2) California: Beginning January 1, 2005, California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us by clicking the Contact Us link on our Website.
Beginning January 1, 2020, the California Consumer Privacy Act provides certain additional rights to California consumers with respect to personal information we obtain about them. For more information about those rights and how to exercise them, please read the Salem Web Network CCPA Privacy Notice for California Residents, at https://salemmedia.com/salem-web-network-ccpa-privacy-notice-for-california-residents/.
G. KEEPING YOUR INFORMATION SECURE
We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control. Please be advised, however, that while we strive to protect your personally identifiable information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online or through our Services, and are not responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information. In the unfortunate event that your “personally identifiable information” (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. You will also receive any notification required by law. From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.
H. THIRD PARTY DATA/SERVICES
(1) Social Networks. We may allow you to register for an account with us by using an account you have with a social network or other third-party, such as Facebook, Google, Twitter, etc. (“Social Network Account”). In such instances, we may receive and you are granting us access to certain information regarding your Social Network Account (e.g., friends, mutual friends, contacts, etc.). We may make this information available on or through the Services and to our users. You may be able to restrict what information is shared and how it is used through privacy and other settings. Also, depending on the privacy settings you have set in your Social Network Account, personally identifiable information may be shared with us and made available through the Services, to our users, and to the third party operating your Social Network Account.
(2) Third Party Services. Our Services may link to, contain links to or embed functionality provided by third parties, such as reward programs, surveys, etc. (“Third Party Services”). We do not control or maintain Third Party Services, nor are we are not responsible for the privacy practices employed by any provider of a Third Party Service. We encourage you to read the privacy statements applicable to all Third Party Services before submitting any personally identifiable information through these websites.
I. CONTACT & OPT-OUT INFORMATION
We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services.
J. SOLE STATEMENT
K. 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 via the Contact Us link on the Website
- Contact us by mail at:
Salem Web Network
Attn: Data Privacy Department
111 Virginia Street, Suite 200
Richmond, VA 23219
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.
Right to request deletion of your personal information
You may also request that we delete any personal information that we have collected from/about you. However, we may retain personal information as authorized under applicable law, such as personal information required as necessary to provide our services, protect our business and systems from fraudulent activity, to debug and identify errors that impair existing functionality, as necessary for us, or others, to exercise their free speech or other rights, comply with law enforcement requests pursuant to lawful process, for scientific or historical research, for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. We need certain types of information so that we can provide our services. If you ask us to delete it, you may no longer be able to access or use our services.
How to exercise your access and deletion rights
California residents may exercise their California privacy rights by submitting your request via email at firstname.lastname@example.org. While email is the best way to reach us, you may also call us toll-free at +1 804-205-9700.
For security purposes, we may request additional information from you to verify your identity when you request to exercise your California privacy rights.
If you have an online account with us, logging into your account will serve to verify your identity and request, although we may request additional information if we believe your account has been compromised. If you do not have an account with us, or if we have reason to suspect that the security of your account is compromised, we will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought.