Sullivan Media Solutions and its subsidiaries and affiliates (individually or collectively, “SMS” or “we/our/us”) is committed to protecting your privacy. This Privacy Notice applies to all users of our website and mobile applications (“Site(s)”) and to the data we collect via the Sites, including your personal information, or personal information that you may provide to us when you interact with our Sites. Our processing of your personal information is subject to this Privacy Notice and any subsequent updates.
This Privacy Notice describes the type of information we may collect from you and or that you may provide us when you interact with our Sites, email, and online services, participate in our loyalty program, or register for one of our events (our “Services”). “You/your/user(s)” means you as a user of our Services and should be interpreted in the context in which the information is processed. We offer the Services, including all information, tools and features available from the Services, to you conditioned upon your acceptance of all the terms, conditions, policies and notices stated in this Privacy Notice.
When you provide personal information about yourself through the Sites, we only process your personal information when we have a lawful basis to do so. For purposes of this Privacy Notice, “Personal Information” is defined as information that identifies, or can be used to identify, an individual. We collect Personal Information from individuals visiting our Sites, including as you browse our website.
By accessing the Sites and Services, you acknowledge this Privacy Notice and agree to be bound by the terms hereof and the Terms of Service set forth on each of the Sites you visit and the Services that you utilize.
Our legal bases for processing your Personal Information include: (1) your consent; (2) fulfilment of a contractual obligation; and (3) where we have a legitimate interest to process your Personal Information consistent with applicable law. Our legitimate interests include:
• Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this Privacy Notice;
• Protecting and defending our rights and properties, including intellectual property;
• Complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities or as otherwise required by law;
• Improving your experiences with our products and services;
• Understanding and improving our Sites, user experience, and customer relationships; and
• Enabling our business operations.
Where we rely on your consent to process your Personal Information, you have the right to change, withdraw or withhold your consent. Notwithstanding the forgoing, the processing of IP addresses is a necessary part of providing access to the Sites, so we cannot provide access to the Sites without this information.
Personal Information Collected
We collect Personal Information that you choose to share with us as well as information provided directly by your browser or device when you visit our Sites.
PERSONAL INFORMATION COLLECTED FROM YOU
We collect Personal Information that you provide directly to us. You may provide different types of personal information to us when you engage in certain activities through the Services. The Personal Information we request includes, but is not limited to, your name, email address, mailing address, telephone number, age, and demographic information. It is optional for you to engage in such activity; however, if you choose to do so, we may not be able to permit you to participate in the activity unless certain pieces of information are provided.
EMAILS, COMMUNICATIONS AND ACCOUNTS
When you send an email or other communication to SMS, or when you register for an account on one of our services, we may ask for your name, phone number, and email address and, where you are seeking to advertise with us, or procure our services, other information about you and/or your company. We also collect the content of your message or submission to us, which contains any additional information, including Personal Information, you choose to share with us. When you use the Services, you may be given the option to subscribe to or to be added to our email list. We collect this information when you initiate contact with us for the purpose of responding to your email or other communications. Your selection will not affect other uses or sharing of your information as described in this this Privacy Notice. Subscriptions to the email list can be cancelled at any time by following the instructions in the “Your Choices and Rights” section of this Privacy Notice below, or by clicking the “unsubscribe” link at the bottom of an email and follow the unsubscribe instructions.
COMPLETING A SURVEY
If you choose to participate in a survey, you may be asked to provide basic demographic information. You also will be asked to provide additional information related to the survey topic, which may include Personal Information. We use this information to conduct statistical analyses on topics of interest to our users, and your data will only be reported in aggregate form, unless we obtain your consent for further use. Additionally, if you choose to provide a free-text comment in your survey response, we may publish your response. We only collect this information when you consent to participate in the survey.
SWEEPSTAKES AND GIVEAWAYS
When you enter a contest, you may be asked to provide your name, address, e-mail address, company name, and phone number. This information is used to verify your identity, notify you that your entry has been received, and contact you if you are a winner and/or prize recipient.
As part of your entry in our contests, we may choose to provide you with the option of receiving information about our services and publications or other advertisements or information. If you consent to receive this information, we will collect the Personal Information you provided as part of your contest entry for this purpose. You can change, withdraw, or withhold your consent at any time.
POSTING USER GENERATED CONTENT
You may also choose to participate in different interactive features we offer. We collect this information for the purpose of facilitating your participation in our interactive features.
APPLYING FOR A JOB
When you submit a job application via our Sites, we collect your first and last name, phone number, and e-mail address. We also ask you to provide a cover letter and permit you to upload any documents to support your job application. When you submit your cover letter and supporting documentation, we will collect any additional information, including Personal Information, you include in those documents.
REGISTER FOR AN EVENT
When you register for one of our events, we may ask you to provide your name, address, e-mail address, and phone number. We also may ask you additional information such as age to facilitate registration.
In exchange for sponsoring our content, we may provide our third party partners for the event, including advertising partners, with the Personal Information you provide when you choose to register for an event.
When you purchase something from any of our Sites as part of the buying process we collect the Personal Information you give us such as your name, address and email address. We use this information to process and provide you with the items you purchased.
We collect this information for the purpose of fulfilling your order, including updating you on your order status. Additionally, if you choose to receive future communications from us regarding our products and offers, we will use the Personal Information you provide through the order process for such purposes.
PERSONAL INFORMATION COLLECTED VIA WEB-BASED TECHNOLOGIES
BROWSER OR DEVICE INFORMATION
We automatically receive and record information on our server logs from your browser, or device, including your browser type; mobile phone, tablet or other device type; computer or mobile operating system; the domain of the website that referred you to us; name of your Internet service provider; web pages you visit on the Services; IP address; geo-location information; and standard server log information, cookie information, and the page(s) you request. We also collect information about your interactions with our email messages, such as whether the messages were opened and the links clicked in those emails. We collect this data for the following general purposes:
• Customizing your user experience;
• Fulfilling your requests for products and services;
• Promoting and improving services;
• Contacting you;
• Analyzing the effectiveness of ad campaigns and personalization;
• Personalize content and services;
• Analyzing the effectiveness of marketing campaigns including offline marketing;
• Targeted advertising;
• Optimize ad campaigns and other online or digital media; and
• Create market and other insights.
We also collect your IP address(es) for the purpose of analyzing website trends, administering the Sites, and tracking user movement for aggregate usage analysis. This website usage information enables SMS to provide our users with an ever-improving site, service, and general offering, including with respect to security. Except for our processing of IP addresses as a necessary part of providing the Services, and except where you have provided consent for us to use your identifiable Personal Information, we only use anonymous, aggregate data that cannot be used to identify you individually for our analytics research.
COOKIES AND WEB BEACONS
We may set and access SMS session cookies on your computer or device to customize the user experience. “Cookies” are small files placed on your computer or device by your browser and are often used to make websites work, as well as provide information to the website operator.
We place two types of cookies on our Sites:
• Session Cookies: Session cookies typically only last for as long as your session, which is usually the duration of your current visit to our Sites or for as long as you keep the browser open that was used to visit our Website. We use our session cookies to store information about your visit (referring website, landing page, etc.). We also use session cookies to track and record the number of visits to our Website.
• Persistent Cookies: Persistent cookies are cookies that remain on your browser and are read when you return to our Sites. We may use persistent cookies to remember your preferences, personalize your experience, and help secure your visit to our Sites. We use persistent cookies to remember the contents of your shopping cart (which is stored for two weeks), and, if applicable, determine if you have access credentials to the Site.
Communications you receive from us, as well as pages of our websites, may also contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that enable us to analyze email and website statistics, including visits and click-through rates. The web beacons only collect aggregate, anonymous data and cannot be traced back to you individually.
THIRD PARTY COOKIES AND WEB BEACONS
Our Sites may include social media “widgets,” small icons that allow you to access our content posted on social media sites (Facebook, Instagram, Twitter, and LinkedIn).
If you are logged into your account on these social media platforms, your access to our social media pages and our Sites will be linked to your account.
When you interact with us or the Services through a social media platform (such as by clicking on a social media icon linked from our Services), we may collect the Personal Information that you make available to us on that page, including your account ID or username and other information included in your posts. If you choose to log in to your account with or through a social networking service, we and that service may share certain information about you and your activities.
If you contact us via social media, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy Notice. Your interactions with our business pages on these social media platforms is governed by the privacy practices of these platforms.
Personal Information Use
How we use your Personal Information will depend on how you interact with our Sites and the Personal Information that you have shared with us.
RESPOND TO YOUR REQUESTS
We use your Personal Information to respond to your requests, including communications, and content downloads.
ENHANCE WEBSITE AND USER EXPERIENCE
We use the information regarding the use of our Sites to analyze and administer the Sites and track user movement for web analytics purposes. This Site usage information enables SMS to provide you with an ever-improving site, service, and general offering. Except where you have provided consent for us to use your identifiable Personal Information, we only use anonymous, aggregate data that cannot be reasonably linked to you individually. Notwithstanding the forgoing, the processing of IP addresses is a necessary part of providing access to the Sites, so we cannot provide access to the Sites without this information.
Conduct Marketing and Advertising
We or our third party partners may use your Personal Information to provide information about additional products, services, promotions and other content that might be of interest to you and to measure the effectiveness of that advertising. Email and other materials delivered from SMS may also be sent as part of an opt-in process or in response to communications you have initiated with us. You may change your consent for receiving such communications by clicking the “Unsubscribe” link at the bottom of any electronic marketing communications received from us. You may also manage your privacy preferences here or contact us by mail at Sullivan Media Solutions, ATTN: Privacy, 1 Manhattanville Rd, Suite 202, Purchase, NY 10577 to request that we remove you from our marketing communications.
MEET LEGAL AND REGULATORY OBLIGATIONS
In certain circumstances, we may be required to disclose your Personal Information as otherwise required by law or legal or regulatory proceeding. We will only share the information we are required to disclose by law and only when we are required to do so.
SWEEPSTAKES, SURVEYS AND OTHER
We may use your Personal Information to enable you to participate in features such as surveys, reviews, blogs or forums, or to enter sweepstakes, contests, promotions and other special initiatives and to communicate with you about them.
SECURITY AND FRAUD PREVENTION
When necessary, we will use your Personal Information, including email communications, to preserve the security of our website, systems, and Personal Information in our control. If necessary, we will also use your Personal Information to investigate possible fraud, to identify violations of this Privacy Notice and our terms and conditions, and to prevent any attempted harm to our users.
We may combine information from the Services together and with other information we obtain from our business records or from third party sources. We also may use or combine information that we collect from the Services with information provided by third parties, including demographic information and other attributes, and organizational affiliations.
Personal Information Sharing and Disclosure
We share your Personal Information when we have a legal basis to do so, or as otherwise described below. Our legal basis are described under the “General” section of this Privacy Notice above.
We may share the information collected via our Services with third parties who work on our behalf to help us further the purposes described above. We may provide additional information that we have collected about you both directly and automatically to these third parties.
We share information about you with third parties who partner with us to provide advertisements about products and services that may be of interest to you. This may include third parties who assist us in identifying which ads to deliver and third parties who deliver the advertisements. As described above, our third party partners may use persistent identifiers to track your Internet usage across other websites, online services, email and mobile applications in their networks beyond the Services, and may combine information about you from other sources. We may provide additional information that we have collected about you both directly and automatically to our partners.
We may provide products or services jointly with or through certain third-party businesses, including but not limited to retail businesses. When we provide these products or services, we may give you the opportunity to opt-in to the additional sharing of information with these businesses. Should you choose to do so, information you provide specifically in connection with those products and services may be shared with these businesses and subject to their privacy policies.
WEBSITE ANALYTICS COMPANIES
Our partners may use the information collected to serve you with targeted advertising, both through our Services and other websites, email, online services or mobile applications. We may also contribute to or participate in cooperative databases, which give other companies access to your information. For more information regarding the partners with whom we share data, please see our Partners List.
We adhere to the principles of the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising and Multi-Site Data and the Network Advertising Initiative’s Code of Conduct, as applicable. See the Your Choices and Rights section below to learn about choices available to you with respect to this type of advertising.
We may aggregate your information into a form where individuals can no longer be identified. Given the aggregated, de-identified information, there are no restrictions under this Privacy Notice on how we may use or disclose such information. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes.
If you choose to enter a sweepstakes, contest or other promotion, your information may be disclosed to any third party sponsor of the sweepstakes, contest or promotion and to third parties who help design, administer and implement the promotion, including in connection with winner selection, prize fulfillment and aggregated data analysis. Your information also may be disclosed as required by law, such as on a winners list.
USER GENERATED CONTENT
The Services may allow users to post comments and other content to the Services. Any information about yourself that you post to the Services will become public information and will be accessible by other users of the Services. In addition, your user name will be viewable by others users, along with a profile picture if you have chosen to upload one. We have no responsibility to maintain the privacy or security of any such information that you may choose to post to the Services.
TEXT MESSAGES AND PUSH NOTIFICATIONS
By providing us with your telephone number, you are authorizing us, our service providers and our and their affiliated companies to deliver or cause to be delivered SMS text messages, texts, push notifications and voice message notifications, including promotional messages, using an automatic telephone dialing system. You are not required to receive such messages as a condition of purchasing any property, goods or services. Registered users may choose not to receive text messages from us by not providing us their cell phone number. You can also cancel the SMS service at any time by replying “STOP” via text. Please note that standard message rates and data charges from your cellular service provider apply to sending and/or receiving text messages. You are solely responsible for such message rates and data charges.
We may disclose information about you if required to do so by law or on the good-faith believe that such sharing is necessary to (a) conform to applicable law or comply with legal process served on us or our Services; (b) protect and defend our rights or property, the Services, or our users; or (c) act to protect the personal safety of our employees and agents, other users of the Services, or members of the public.
SALE OF BUSINESS
If we go through a business transition, such as a merger, acquisition by another company or a financing, investment, support or funding, sharing or sale of all or a portion of our assets, your information may be among the assets shared or transferred. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Notice.
Your Choices and Rights
You may update or delete information from your profile at any time, or request that we do so; however, because we archive past transactions, you cannot delete this information. You may also request that we delete your account entirely by contacting us. Terminating your registration will not necessarily remove previous public comments or other user content on public display on the Services. If you wish to cancel your account on the Services or delete your information previously provided to us, you may send your request here: https://www.townsquaremedia.com/privacy-preferences.
If you do not receive a response from us to any emails you send to us within ten (10) business days, please send us another email, as your original email may not have been received.
Registered users who have provided their cell phone number to us may remove it from within their personal profile settings. If you prefer not to receive text or wireless promotional communications on your mobile device, you can opt out by replying “STOP”.
You may choose not to subscribe to email communications other than service-related communications such as payment confirmation. If you do choose to receive email communications such as email newsletters and promotional emails, you may later opt out by following the instructions provided at the bottom of each email, clicking the “unsubscribe” button at the bottom of emails we sent you.
ADVERTISING AND MARKETING AND WEBSITE ANALYTICS
You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the Services for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Advertising Digital Alliance European (EDAA). Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:
• Apple: https://support.apple.com/kb/HT4228
• Android: https://www.google.com/policies/technologies/ads/
• Windows: https://choice.microsoft.com/en-US/opt-out
The DAA’s AppChoices App provides options regarding the collection of cross-app data for your device.
Additional resources or tools may exist that streamline the process of submitting opt-out requests–for example, TRUSTe’s Ad Preference Manager. We do not review or warrant the representations made by these tools and cannot guarantee the effectiveness.
To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page. Site users can also access the Google Analytics Opt Out Browser Add-on.
Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other Services, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences. If you use multiple browsers or devices you may need to execute this opt out on each browser or device.
For international users, please note that it may be necessary to transfer your information internationally and, in particular, your information may be transferred to and processed in the United States. We process data both inside and outside the United States, either directly or through our third-party service providers. It is important to know that data protection laws in some jurisdictions may not be as strong as those in your country. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws. By using the Services, you agree to have your information used and transferred to the United States as set forth in this Privacy Notice. To ensure the continued protection of your Personal Information while in our care, we take appropriate organizational and technical measures.
CALIFORNIA PRIVACY RIGHTS
We provide our California customers with specific rights regarding their Personal Information. The section describes the rights that you have under California law and explains how to exercise those rights.
RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, USED, OR DISCLOSED
You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past 12 months. Once we receive your request and verify your identity, we will disclose to you: (1) the categories of information we collected about you; (2) the categories of sources for the information; (3) our business or commercial purpose for collecting or disclosing that information; (4) the categories of third parties with whom we shared that information; and (5) the categories of information we collected about you in the preceding 12 months.
Right to Delete Personal Information Collected or Maintained
You have the right to request that we delete any of your information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request and verify your identity, we will permanently delete (and direct our service providers to delete) your information from our records, unless a legal exception to deletion applies. In our response to your request to delete, we will specify the manner in which we have deleted your information or, if we must deny your deletion request, the basis for this refusal.
RIGHT TO NON-DISCRIMINATION FOR EXERCISE OF PRIVACY RIGHTS
We will not discriminate against you for exercising any of your rights by: (1) denying you goods or services (except with respect to IP addresses, since we cannot provide our Site to you without collecting the IP address from which you access the Site); (2) charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) providing you a different level or quality of goods or services; or (4) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
EXERCISING YOUR RIGHTS
To exercise the rights described above, please submit a verifiable consumer request to us by either:
• Calling us at 1-909-793-3554
AUTHORIZING AN AGENT
You may designate an authorized agent to submit your consumer request on your behalf, so long the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us.
VERIFYING YOUR REQUEST
We cannot respond to your request or provide you with information if we cannot verify your identity or authority to make the request and confirm the information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use information provided in a verifiable consumer request to verify your identity or authority to make the request. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
To verify your identity, we ask that you provide us with the following information when you submit your request: (1) first name, (2) last name, and (3) phone number or email. We will use the above information to verify your identity. Depending on your type of request or the information requested by you, we may require additional information to verify your identity and fulfill your request.
You may make such a request by contacting us in writing by electronic mail, postal mail, or commercial courier at the address or email address provided at the end of this Privacy Notice under the heading “Contact Information” with a preference on how our response to your request should be sent.
California law also requires that we disclose how we respond to “do-not-track requests” from our users. At this time, we do not currently respond to “do-not-track” requests from our users’ browsers.
In the preceding twelve (12) months, we disclosed the following categories of personal information to third parties for our commercial purposes: Identifiers and Internet or Electronic Network Activity (as those categories are defined in the California Consumer Privacy Act (“CCPA”)). We do not knowingly sell (as defined by the CCPA), the personal information of minors under 16 years of age to non- affiliated third parties without affirmative authorization.
Other Important Information
PRIVACY NOTICE CHANGES
We reserve the right to change or update this Privacy Notice by posting such changes or updates to the Services. Amendments to this Privacy Notice will be posted at this URL and will be effective when posted. You can tell if the Notice has changed by checking the last modified date that appears at the end of this Privacy Notice. Your continued use of the Services following the posting of any amendment, modification or change shall constitute your acceptance thereof.
We will retain your Personal Information for as long as we have a legitimate legal, business, or regulatory need.
If you choose a direct payment gateway to complete your purchase, then one of our payment processors stores your credit card data as set forth in the “Payment Processor” section above. We store your purchase transaction data only as long as necessary to complete your purchase transaction. After that is complete, we delete your purchase transaction data.
CHILDREN UNDER THE AGE OF 13
We do not permit children under 13 years of age to use the Services, and we do not knowingly collect, use or disclose information from anyone under 13 years of age except as part of specific outreach programs with parental permission. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. If you believe that we have mistakenly or unintentionally collected Personal Information of a minor without appropriate consent, please call us at (909) 793-3554.
This Privacy Notice applies to our Services as described above as well as the information we collect when you interact with us through social media or other websites and online services. Our Sites may contain links to websites owned or operated by third parties. This Privacy Notice applies only to our Sites and not to any third-party websites.
We have implemented organizational and technical safeguards for protecting the Personal Information you share with us. Notwithstanding the forgoing, no website is one-hundred percent (100%) secure and transmitting information over the internet inherently possess risk therefore we cannot guarantee absolute security.
Sullivan Media Solutions
1940 Orange Tree Ln., Suite 200
Redlands, CA 92374
Phone: 1 (909) 793-3554