(Effective and Last Modified November 5, 2019)
This website is a service of Salem Media Group,
Inc. together with its subsidiaries, affiliates, agents and licensees
(collectively “we,” “us,” or “our”). We have adopted this privacy policy
(“Privacy Policy”) to explain what information may be collected when you access
this website or any other website on which we place this Privacy Policy
(“Website”), use our online or other services, or use any of our mobile or
other applications (each, an “App”), how we and others use this information,
under what circumstances we may disclose the information to third parties, and
the instances in which we may allow third parties to collect information
directly. Depending on your activities when using or accessing our
Website or App (collectively, the “Services”), you may from time-to-time be
required to agree to additional terms and conditions. For clarity, our Services
include any promotion which refers to this Privacy Policy for terms regarding the
collection and use of your information.
Please note that this
Privacy Policy applies only to information we collect from you through our
Services and does not apply to our collection of information through other
methods (e.g., in person at our restaurants, over the telephone, etc.),
information provided to us by third parties, or information you provide to
third parties.
Modifications to this Privacy Policy
We generally keep this Privacy Policy posted on
our Website and in our App. You should review this Privacy Policy
frequently, as it may change from time to time without notice. Any changes will
be effective immediately upon the posting of the revised Privacy Policy. WHEN YOU USE OUR SERVICES, YOU AGREE TO THIS PRIVACY
POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY
POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP USING OUR
SERVICES. Please note, however, that if we decide
to use your personally identifiable information in a manner materially
different than what is provided in this Privacy Policy or what we advised at
the time it was collected, we will notify you of this change by e-mail to the
last e-mail address provided to us or through our Applications. You will have a
choice (by means of an “opt out” opportunity) as to whether we use their
information in this different manner. In such case, we will use your
personally identifiable information in accordance with the terms in place when
the information was collected.
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.
(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,
realize a benefit we may offer, 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.
Except as provided in
this Privacy Policy, your personally identifiable information will not be
shared or sold to any third parties without your prior approval.
(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.
(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.
If you are concerned
about the storage and use of cookies, you may block or limit the storage of
cookies via browser controls or other software (we do not promise that our
Services will recognize or work with any such browser controls/software – e.g.,
see below for Do Not Track options). You may also be able to delete
cookies manually from your Device through your internet browser, operating
system or other programs. Please note, however, that some portions
of our Services will not function properly or be available if you are able and
do block and/or delete cookies.
(2) Preference Based Advertising: We may work with third
parties, including advertising companies and website analysis firms, who use
cookies and web beacons to collect non-personally identifiable information when
you visit our Website and third party sites. This non-personally identifiable
information, collected through cookies and web beacons, is typically used by
these third-party advertising companies (i.e., advertising networks) to serve
you with advertisements while on third party sites tailored to meet your
preferences and needs. If you do not wish to participate in this
activity, go to www.aboutads.info and follow the simple opt-out process.
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.
(4) Other: Regardless of any other provision in this
Privacy Policy, we reserve the right to disclose
any personally identifiable or non-personally identifiable information about
you if we are required to do so by law, with respect to
copyright and other intellectual property infringement claims, or if we believe that such action is necessary to: (a)
fulfill a government request; (b) conform with the requirements of the law or
legal process; (c) protect or defend our legal rights or property, our
Services, or other users; or (d) in an emergency to protect the health and
safety of our customers or the general public.
We may offer Services with chat rooms, blogs, message boards,
bulletin boards, the ability to post user generated content or similar public
forums where you and other users of our Services can communicate. The
protections described in this Privacy Policy do not apply when you provide
information (including personal information) in connection with your use of
these public forums. We may use personally
identifiable and non-personally identifiable information about you to identify
you with a posting in a public forum. Any
information you share in a public forum is public information and may be seen
or collected by anyone, including third parties that do not adhere to our
Privacy Policy. We are not responsible for events arising from the distribution
of any information you choose to publicly post or share through our Services.
(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 Scott Hunter at scott.hunter@salemmedia.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.
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. From time to time we evaluate new technology for
protecting information, and when appropriate, we upgrade our information
security systems.
(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 and to our users.
(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
You may contact us as via the Contact Us link on
the Website if: (a) you have questions or comments about our Privacy Policy;
(b) wish to make corrections to any personally identifiable information you
have provided; (c) want to opt-out from receiving future commercial correspondence, including emails, from us or our
affiliated companies; or (d) wish to withdraw your consent to sharing your personally identifiable
information with others.
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.