Sullivan Media Solutions Privacy Policy

Effective Date: June 16, 2026

Sullivan Media Solutions and our affiliates; KOLA-FM, KCAL-FM (“Affiliates”) (collectively, “Sullivan Media,” “us,” “we,” or “our”) value your privacy and would like you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with the information that we collect through:

• Our websites (the “Websites”), as listed below;
  • kolafm.com
  • kcalfm.com
  • sullivanmediasolutions.com
• Our KOLA and KCAL applications (the “Applications”);
• Email messages that we send to you that link to this Privacy Policy or other communications with you;
• Our social media pages, including, but not limited to, our LinkedIn, Facebook and Instagram accounts (collectively, our “Social Media Pages”);
• Offline business interactions you have with us.

Together, we refer to the Websites, Applications, Social Media Pages, emails and offline business interactions as the “Services”.

This Privacy Policy does not apply to information that we collect from our employees, job applicants, contractors, or vendors.

By accessing and/or using Sullivan Media’s Services, you consent to the data practices described in this Privacy Policy regarding the collection, use, disclosure, and disposal of your Personal Information, as defined below, and as amended from time to time. Consent for cookies and similar technologies is handled separately through our cookie consent banner, described in the “Cookies” section below. Sullivan Media’s Services are designed and targeted to United States audiences and are governed by and operated in accordance with the laws of the U.S. If you are not a U.S. citizen or do not reside in the U.S., you voluntarily consent to the collection, transfer, use, disclosure and retention of your Personal Information in the U.S. You also agree to waive any claims that may arise under your own national laws.

Personal Information

Generally, “Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

• Name
• Email address
• Mailing address
• Telephone number
• Social media account username
• Region-level location data derived from your IP address
• The content of communications with us, including the content of emails, contact form submissions, feedback, or other messages you send through the Services
• Responses to surveys we may ask you to complete

The following are the different ways and reasons we collect Personal Information:

Through our Services. We collect Personal Information through our Services. For example, we collect Personal Information when you interact with our Websites, meet us offline, or enter or win a contest.

From other sources. We receive your Personal Information from other sources, for example:

• Publicly available databases.
• Joint marketing partners, to the extent they share information with us.
• If you connect your social media with one of our social media accounts, you will share certain Personal Information from your social media account with us, such as your name, email address, and list of social media contacts. Sullivan Media may obtain, transport or merge Personal Information posted publicly on social media platforms; however, we will not share any such Personal Information with third parties except as described in this Privacy Policy, including in the “Your California Privacy Rights” section.

Our ability to provide requested Services is tied to our need to collect Personal Information you provide. If you do not provide the requested information, we may not be able to provide the Services requested. If you disclose the Personal Information of others to us in connection with the Services, you represent that you are authorized to do so and permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We use Personal Information for the following purposes:

• Providing the Services and responding to your requests.
  • Responding to your inquiries and fulfilling your requests, for example, when you correspond with us or provide your comments or questions.
  • Responding to a contest submission and/or processing a winning contest entry.
  • Communicating changes to the Services, this Privacy Policy or other terms and policies applicable to the Services.
• Providing marketing materials. Subject to applicable law and your preferences, we may use your contact information to:
  • Send you promotional communications, newsletters, or other marketing materials related to our Services that may be of interest to you.
  • Conduct contests or other promotional activities.
• Improvement, analytics and personalization. We may use your information for:
  • Monitoring and analyzing trends, usage, and activities in connection with the Services.
  • Improving the Services, including developing and enhancing features, content and services.
  • Customizing and personalizing your experience with the Services, such as remembering your preferences.
• For our business purposes.
  • For data analysis, including to improve our marketing;
  • For identifying usage trends;
  • For determining how effective our promotional campaigns are;
  • For expanding our business activities.

Disclosure of Your Personal Information

We disclose Personal Information:

• To our affiliates for the purposes described in this Privacy Policy.
• To our third-party service providers, to facilitate their provision of services to us. This includes providers such as website hosting, data analysis, information technology, benefits (such as special promotions), email delivery, and other services.
• To third parties, to permit them to send you marketing communications, consistent with your choices.
• To third-party advertising platforms and networks (such as Meta and Google), to whom we provide identifiers — including name, email address, and telephone number, in hashed or unhashed form — to match you to their users and deliver targeted advertising, including on behalf of our advertisers. Your right to opt out of this is described in the “Your California Privacy Rights” section below.

We also use and disclose your Personal Information as necessary or appropriate, including where we have a legal obligation or legitimate interest in doing so:

• To comply with applicable laws, legal processes, and regulations.
• To cooperate with law enforcement, such as requests and orders for information.
• For legal reasons, such as enforcement of our terms and conditions, contractual rights and other agreements.
• To protect the security and integrity of the Services and our business operations.
• To detect, investigate, and prevent fraudulent transactions and other illegal or unauthorized activities.
• In connection with a business transfer or restructuring. Sullivan Media has a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Collection and Use of Other Information

When you visit our Websites, we will collect information that does not reveal your specific identity or relate to an identifiable individual (“Other Information”). Such Other Information may include:

• Browser and device information
• Website usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in such a way that it does not reveal your specific identity.

We and our service providers may collect Other Information in a variety of ways, including:

• Your browser or device. Certain information is collected by most browsers or automatically collected through your device. This includes your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, the manufacturer of your device and model, language, and Internet browser type and version. We use this information to ensure that our Services are functioning properly.
• Cookies and the cookie consent banner. “Cookies” are text-file identifiers that are transferred to your browser or device and that allow us to recognize your browser or device and to tell us how and when pages and features on our Websites are visited, by how many people, and other activity on the Websites. We and our service providers use this information for security purposes, to facilitate navigation, to display information more effectively, to analyze trends, to administer the Websites, and to personalize your experience. Cookies also allow us, and third parties with whom we partner, to select and display advertisements or offers that are most likely to appeal to you. Our third-party advertising partners may use cookies or other technologies to gather information about your activities on our Websites and on other websites in order to deliver interest-based advertising.
  • When you first visit our Websites, we present a cookie consent banner. Non-essential cookies (such as analytics and advertising cookies) are not set until you provide consent through the banner. You may accept all cookies, reject non-essential cookies, or choose which categories to allow.
  • You can change or withdraw your consent at any time using the consent preferences link available on our Websites, which reopens the cookie settings.
  • A complete, categorized list of the cookies used on our Websites — including their purpose and duration — is set out in the cookie declaration below.
  • In addition to the banner, you may be able to set your browser to decline cookies or to choose which cookies to accept. If you choose not to accept cookies, your experience with our Services may not be as smooth.
• Interest-based advertising opt-out.
  • If you would not like to have this information used for the purposes of serving you interest-based ads, you may opt-out by clicking here.
  • If you do not want information collected through the use of cookies, your browser may allow you to automatically decline cookies or choose which cookies to accept/decline. If you choose to not accept cookies, your experiences with our Services may not be as smooth.
• Pixel tags and similar technologies. Pixel tags, or web beacons, may be used to track your actions and measure the success of our marketing campaigns.
  • We use Google Analytics, which utilizes cookies and similar technologies to collect and analyze information about use of our Services and report on activities and trends. Google Analytics may also collect information regarding the use of other websites and online resources. You can learn about Google’s privacy practices and opt out via the Google Analytics opt-out browser add-on.
  • We also use Google’s reCAPTCHA service to protect our Services against spam and other abuse. reCAPTCHA may utilize cookies, as well as information such as IP address, date, time, language, screen size and resolution, and mouse movements. Use of reCAPTCHA is subject to Google’s privacy policy and terms of service.
• Physical location. We may collect region-level information on the location of your device using Google Analytics.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.

How We Keep Your Personal Information Secure

We take reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can guarantee absolute security. If you have reason to believe any interaction with us is no longer secure, please reach out to us via the contact information available on the Website you are visiting. Service providers with whom we share your Personal Information have agreed to use reasonable security measures to protect it.

Choices

You have choices when it comes to the use and disclosure of your Personal Information. You may opt out of:

• Marketing emails from us. If you do not want to receive marketing emails from us in the future, you may opt out using the unsubscribe options in the emails.

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, or if you would like to receive a copy of your Personal Information (to the extent applicable law provides you that right), you may contact us at contactus@sullivanmediasolutions.com. We will respond consistent with applicable law. In your request, please clearly identify the Personal Information that you would like to be changed and/or deleted. We may need to retain certain information for our records and/or to complete a transaction that was started prior to your request.

Your California Privacy Rights

This section applies to residents of California and describes the rights provided under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”), and how to exercise them. Capitalized terms used in this section have the meanings given to them under the CCPA.

Your Rights

Subject to certain exceptions, California residents have the right to:

• Know and access. Request that we disclose the categories of Personal Information we have collected about you, the categories of sources, the business or commercial purpose for collecting it, the categories of third parties to whom we disclose it, and the specific pieces of Personal Information we have collected about you.
• Delete. Request that we delete Personal Information we have collected from you, subject to certain exceptions.
• Correct. Request that we correct inaccurate Personal Information we maintain about you.
• Opt out of sale or sharing. Opt out of the “sale” of your Personal Information and the “sharing” of your Personal Information for cross-context behavioral advertising.
• Limit use of sensitive Personal Information. To the extent we collect Sensitive Personal Information, request that we limit its use and disclosure to certain permitted purposes.
• Non-discrimination. We will not discriminate against you for exercising any of your CCPA rights.

Sale and Sharing of Personal Information

We do not sell your Personal Information for money. However, certain of our advertising practices may constitute “selling” or “sharing” for “cross-context behavioral advertising” under the CCPA:

• Interest-based advertising cookies. Our use of advertising cookies and similar technologies to deliver interest-based advertising on our Websites.
• Custom Audience and Customer Match advertising. We provide identifiers from our own records — such as your name, email address, or telephone number, including in hashed form — to third-party advertising platforms (such as Meta and Google) so they can match you to their users and deliver targeted advertising, including advertising for our advertisers and other commercial partners.

You may opt out of this sale or sharing through our “Do Not Sell or Share My Personal Information” / “Your Privacy Choices” link, through the cookie consent banner, and by sending an opt-out preference signal such as the Global Privacy Control, as described below.

Opt-Out Preference Signals (Global Privacy Control)

We recognize and honor opt-out preference signals, including the Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of Personal Information for the browser or device from which the signal is sent. You do not need to take any additional action for us to honor a valid signal.

How to Submit a Request

You may submit a request to know, delete, or correct, or to opt out of the sale or sharing of your Personal Information, by contacting us at contactus@sullivanmediasolutions.com.

Verification and Authorized Agents

To protect your Personal Information, we will take steps to verify your identity before responding to a request, and we may decline to act on a request where we cannot verify your identity. You may use an authorized agent to submit a request on your behalf; we may require the agent to provide proof of authorization and may require you to verify your identity directly with us.

Minors

We do not knowingly sell or share the Personal Information of consumers we know to be under 16 years of age without affirmative opt-in consent. For consumers we know to be under 13, we require the consent of a parent or guardian. See also the “Use of Services by Minors” section below.

Retention of Personal Information

We retain Personal Information for as long as needed or permitted given the purpose(s) for which it was obtained and consistent with applicable law. We base retention periods on the following:

• Fulfillment of the purposes for which the Personal Information was collected;
• Fulfillment of legal requirements; and
• Legal needs, when retention is advisable in light of our legal position (such as applicable statutes of limitations, litigation, or regulatory investigations).

Links to Third-Party Websites and Services

Our Websites and our Social Media Pages (or other social networking platforms) may contain a variety of content and functionality and may provide links to other third-party websites or online services. Despite such links, this Privacy Policy applies only to Sullivan Media and our Affiliates. The presence of a link does not constitute or imply Sullivan Media’s endorsement, recommendation, or sponsorship of the content, goods, services, business or privacy practices on such websites or online services. Sullivan Media encourages you to be aware and informed when you leave our Websites and Social Media Pages, or any other social networking platforms.

Use of Services by Minors

The Services are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 16.

Privacy Policy Updates

The Effective Date at the top of this Privacy Policy indicates when it was last updated. Any changes will become effective when we post the revised Privacy Policy on the Services.

Questions or Comments About This Privacy Policy?

If you have any questions or concerns regarding Sullivan Media’s privacy practices and policies, please contact Sullivan Media at contactus@sullivanmediasolutions.com.