Your California Privacy Rights
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 such third parties’ direct marketing purposes. To make such a request, please write to: email@example.com
Revised April 11, 2019
Company, as the Data Controller, explains in this Policy how we collect, process and/or use information that we receive via our websites, emails we send, and mobile applications (collectively, the “Platform”) that link to this Policy, as amended from time to time. This Policy describes how we collect, process, use, share and secure the personal information you provide. It also describes your choices regarding use, access, and correction of your personal information. For purposes of this Policy, personal information shall mean any information relating to an identified or identifiable natural person.
This Policy applies only to information we collect, process and use through the Platform. This Policy does not apply to information that we collect through other channels, such as information that we collect offline, from other websites, or from emails you send us.
Information We Collect
We collect information about you to provide our services. In order for us to best provide our services to you (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. This means that the data collection is largely necessary for fulfilling the relationship we have with you, and where that is not the case, we have a legitimate interest in collecting the information described below.
We may process the following categories of personal data about you:
- Communication Data that include any communication that you send to us whether that be through the contact form on the Site, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that include data you provide when you register on the Service, subscribe to one of our services, interact with one of our services, make a purchase on or through the Service, and at other times. This can include your name, address, telephone number, email address, billing information, title, website, gender, date of birth, social media handles, or other data which can be reasonably linked to such information such as time spent on stations, stations visited, advertisements served, referral information. We process this data to facilitate your registration and subscription to the Service, to supply the goods and/or services you have purchased through it, and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. The decision to provide this information is optional; however, if you decide not to register or provide such information, you may not be able to use certain features of the Service or other services.
- User Data that include data about how you use the Site and services together with any data that you post for publication on the Site or through other online services. We process this data to operate the Site and ensure relevant content is provided to you, to ensure the security of the Site, to maintain back- ups of the Site and/or databases and to enable publication and administration of the Site, other online services and business. Our lawful ground for this processing is our legitimate interest in enabling us to properly administer the Site and our business.
- Technical Data that include data about your use of the Site and online services such as your IP address, your login data, details about your browser, length of visit to pages on the Site, page views and navigation paths, details about the number of times you use the Site, time zone settings and other technology on the devices you use to access the Site. The source of this data is from our analytics tracking system. We process this data to analyze your use of the Site and other online services, to administer and protect our business and Site, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interest in enabling us to properly administer the Site and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that include data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws, polls, free giveaways and message boards, to deliver relevant website content and advertisements to you, and to measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interest in studying how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
- We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is our legitimate interest in maintaining the viability of, and growing, our business so that we may continue to provide and improve the services we deliver to you. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely, business viability and growth).
Information You Give Us
When you fill out registration forms or provide us with other personal information actively, we collect that information for processing and use in accordance with this Policy. Because we change our offerings and features from time to time, the options you have to provide us with personal information also may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:
- Registering for and subscribing to the Service;
- Signing up for email alerts;
- Completing a form related to one of our products or services;
- Contacting us for technical support or customer service;
Depending on how you interact with our Platform, the personal information we collect from you may vary. If you connect to the Platform using Facebook, Google+, or another social networking site (each a “Social Networking Site”), we will receive information that you authorize the Social Networking Site to share with us, which may include public profile information, birthday, current city work, school, and email address. When we receive this information, it becomes Company’s account information for purposes of your use of the Platform. This information also constitutes personal information and is therefore subject to this Policy. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site’s privacy and data practices. You have the ability to disconnect your Social Networking Site account from your account with us by adapting the privacy settings in your Social Networking Site account. If you come to the Platform through a Social Networking Site, from other websites or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.
If you enter credit card information on the Platform in connection with a purchase, that information is sent directly from your browser to the third-party service provider we use to manage credit card processing and we do not store it on our servers. The service provider is not permitted to use the information you provide except for the sole purpose of credit card processing on our behalf.
Information We Collect Automatically
When you use the Platform, your device is automatically providing information to us so we can respond and customize our response to you. The type of information we collect by automated means generally includes technical information about your computer, such as your IP address or other device identifier, the type of device you use, and operating system version. The information we collect also may include usage information and statistics about your interaction with the Platform. That information may include the URLs of our web pages that you visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type, location data (if you have enabled access to your location on your mobile device), and other information about how you used the Platform.
Automated means of data collection include the following:
Log File Information. Log file information is automatically reported by your browser or mobile application each time you access a website on our Platform. For example, when you access a Company website, our servers automatically record certain information that your web browser sends when you visit any website. These server logs include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, and pages viewed.
Device Information. We collect information about the device you use to access the Platform, including type of device, operating system, settings, and unique device identifiers, and IP address. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. For example, different types of information are available depending on whether you’re using a Mac or a PC, or an iPhone or Android phone. We collect the device type and any other information you choose to provide, such as username, geolocation, or email address. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software records information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
How We Use Information
We use the information we collect to provide our services. In order for us to best provide our services (and to help make it feasible for us to do so), it is essential that we are able to collect and use the information as described in this Policy. So it is largely necessary for fulfilling the relationship we have with you, and, where that is not the case, we have a legitimate interest in using the information we collect, including personal information, for these purposes:
- to provide you with services offered by selectlegalleads.com as promotional content and services we believe will be of interest to you.
- to customize, improve and enhance the content, features, performance and support of the Service and your experience with them, including your listener experience in our network of websites and broadcasts. We use tracking information to determine how well each page and station performs overall based on aggregate listener demographics and traffic patterns to those pages and stations. This helps us continue to build a better service for you.
- to provide relevant advertising, including interest-based advertising from us and third parties, which may mean that we share non-personally identifiable information to third-party advertisers;
- for internal operations, including troubleshooting, data analysis, testing, research, and service improvement (this includes use of your IP address and mobile device information to help diagnose problems with our service and to administer the Platform);
- to communicate with you or initiate communication with you on behalf of third parties through your Company account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you provide to us or (where it is lawful for us to do so) that we otherwise obtain from third-party resources;
- to analyze use of the Platform and improve the Platform;
- to create aggregate and statistical data that does not identify you individually and that we can commercialize (for example, we use mobile device data and IP addresses to gather demographic information);
- for other purposes that you separately authorize as you interact with Company.
When we collect any information that does not identify you as a specific natural person (“Non-Personal Information”), we are permitted to use and disclose this information for any purpose, notwithstanding anything to the contrary in this Policy, except where we are required to do otherwise by applicable law. Examples of Non-Personal Information include: physical location information; demographic information, including gender, dates of birth, ZIP codes, etc.; or any personal information that has been anonymized, aggregated or de-identified. If we combine any Non-Personal Information with your personal information (such as combining your ZIP code with your name), we will use and disclose such combined information as personal information in accordance with this policy. Similarly, if applicable law requires that we treat certain Non-Personal Information as personal information, we will use and disclose this information as personal information in accordance with this policy.
How We Share Information
We only disclose your personal information to third parties as follows:
- We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners, and others) to help us deliver our service. These companies are authorized to use your personal information only as necessary to provide these services to us;
- We may share data with the broadcasters whose stations you listen to;
- In reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer and its affiliates accepting the commitments made in this Policy and compliance with applicable law;
- We will otherwise share personal information with your consent.
What types of Cookies do we use?
We use two types of Cookies on the Platform: “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Platform. A persistent Cookie remains on your device for much longer until you manually delete it (how long the Cookie remains will depend on the duration or “lifetime” of the specific Cookie and your browser settings).
What are Cookies used for?
Cookies transmit information about you and your use of the Platform, such as your browser type, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. With the exception of an identifier Cookie that we associate with registered accounts to prevent fraud by members of the Platform, Cookies link to certain unique information that you entered at time of registration or on your profile, but this is not linked to your name.
Authentication: to help us determine whether or not you’ve signed in to the Platform and to keep you signed in during visits as you access different pages.
Security: to enable and support security features, prevent fraud, and protect your data from unauthorized access.
Preferences and Features
Advertising: to deliver, evaluate and improve advertising, such as by using information about you to provide relevant advertising both on and off the Platform. Our Ad Partners may use a cookie to determine whether you’ve already been shown an advertisement or how it performed, or provide us with information about how you interacted with an ad.
Analytics and Performance: to analyze how our visitors use the Platform and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how our visitors reach our sites.
Ad Choices and Managing Cookies
Company may work with several third parties to provide you with personalized, interest-based advertising. We may target ads to you, and measure their performance, on and off the Platform using:
- Registrant/Subscriber-provided profile information and authorized information shared from your Social Networking Site)
- Your use of the Platform
- IP address or mobile device location information (to the extent you have enabled location tracking on your device);
- Cookies (both on and off the Platform) which may include information from the Ad Partners we use to help deliver relevant ads to you.
How We Work with Third-Party Ad Partners
When we work with our Ad Partners to serve you personalized, interest-based advertising, we do not share information with them that they can use to identify you or associate with you as a specific individual unless you have instructed us to do so. Similarly, if one of these Ad Partners has information about you saved in one of their own Cookies on your browser, they use that information to help us send you a relevant ad, but they do not share with us information that we can associate with you as an individual.
We work with third parties, such as Google Analytics, to provide analytics services that use the Cookies set on your device to measure the performance of advertising and track traffic. We have also implemented Google Analytics Demographics and Interest Reporting, which categorizes Cookie information so that we and third-party service providers can better deliver advertisements that are relevant and useful to you on the Platform and various websites across the internet.
Opting Out of Cookies
If you enable location data for the mobile version of the Platform (including any version installed as a native application), we may use your location data to serve you geo-targeted ads for advertisers that are local to you. In such instances, we do not share your location with the advertiser or advertising network; rather, we provide the advertiser or advertising network with a means to push ads through to users located in certain areas. You may disable location services at any time in your device privacy settings.
Ad Partner Cookies
You can opt out of being ad targeted by our Ad Partners (and other companies employing online advertising) by going to: http://optout.networkadvertising.org/?c=1#!/.
You can opt out of tracking by Google Analytics and Google Analytics Demographics and Interest Reporting services by visiting Google Ads Settings or by downloading the Google Analytics Opt-Out Browser Add-on.
Other Important Privacy Information
EEA Resident Rights
If you are a resident of the European Economic Area, you have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us at firstname.lastname@example.org
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us at email@example.com
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. Registered users can manage their account settings and email marketing preferences as described in the “Choices Regarding Your Personal Information” section below. If you are an unregistered user, or to opt-out of other forms of marketing (such as postal marketing or telemarketing), you may contact us at firstname.lastname@example.org
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Choices Regarding Your Personal Information
We will send you notifications and if, and to the extent, you have opted-in to promotional communications, or other messages using the contact information (e.g., your email address, your mobile device identifier) you provided to us when you registered or when you requested information from us. You may opt-out of continuing to receive optional messages by following the instructions included in each message.
Close Your Account
If you’d like to close your account with us, you can do so by contacting us at email@example.com. When you close your account, you will no longer have full access to the Service, but we reserve the right to keep any information in a closed account in our archives that we deem necessary to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements. If, after you close your account, you wish to know which personal information we keep you can proceed in accordance with your rights set out above.
How Long We Keep Your Personal Information
We keep your personal information only so long as we need it to provide the Platform to you and fulfill the purposes described in this Policy. This is also the case for anyone that we share your personal information with and who carries out services on our behalf. Retention periods can vary significantly based on the type of information and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, and historical archiving. When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes and enforce our agreements, we’ll either remove it from our systems or depersonalize it so that we can’t identify you.
Telephone Marketing and Mobile Services
By having taken affirmative action on the Site, you have requested and are expressly consenting to be contacted via telephone (whether wireless or wired), including by live or prerecorded calls or SMS (text) message using an automated dialing system, email, and/or mail by us, our network partners, and third-party affiliates and marketing partners, at the telephone number or email address you provided, regardless of whether your telephone number or email address is on any Do Not Call/Contact list(s). You understand, and we agree, that such consent is not a condition of use or purchase of the Service and can be withdrawn at any time by you using reasonable means.
Any information we obtain from you in connection with any mobile service, including SMS services, may include your name, address, mobile phone number, your mobile service provider’s name, and the date, time, and content of your messages. In addition to any fee we may charge, your mobile service provider’s standard messaging rates apply to our confirmation and all subsequent SMS correspondence. All charges are billed by and payable to your mobile service provider. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator. SMS message services are provided on an AS IS basis. You may opt out of mobile services via email to <contact email> or by sending “STOP”, “END”, “QUIT” to the SMS text message you have received. However, such opting out will not apply to any communications from our other website offerings you have registered for or our network partners or other third parties to whom we may have already provided your information.
We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently received personal information from a child under the age of 13, we will delete such information from our records.
Safeguarding Your Information
We endeavor to safeguard and protect our users’ information. We utilize electronic and physical security to reduce the risk of improper access to or manipulation of the information you submit during transmission and storage, but cannot and do not guarantee the security or integrity of the information. We shall have no liability for breaches of security or integrity or third-party interception in transit. Please be advised that any transmission of data at or through the Service is at your own risk.
You may opt-out from receiving future offers in connection with the Service by following the instructions contained within each marketing communication or by emailing us at firstname.lastname@example.org. However, such opting out will not apply to any communications from our other website offerings you have registered for or our network partners or other third parties to whom we may have already provided your information. Those third parties’ use of your information is subject to such parties’ own privacy policies and opt-out procedures, for which we shall not be responsible.
Please provide complete information to facilitate your request, as well as your complete contact information.