1. Your California Privacy Rights
If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail). You may contact us in two ways. Send email to PrivacyAdministrator@wror.com
Alternatively, you may contact us at:
55 Morrissey Blvd.
Boston, MA 02125
Attn: Your California Privacy Rights
c/o Privacy Administrator
For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email. All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code. (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.
55 Morrissey Blvd.
Boston, MA 02125
Attn: Privacy Administrator
2. How We Collect Your Information
The information we learn from users helps us personalize and continually improve your experience with our Services. We collect Personal Information, which is traditionally information that by itself can be used to identify or contact a specific individual person, such as your email address, name, home or work address or wireline and/or mobile telephone number. We will also collect data that can be reasonably linked to a specific consumer, computer or device. For example, we will automatically collect your Internet protocol address (“IP Address”), or a unique device identifiers for mobile devices (“UDID”) when you access our Sites or mobile applications. IP Addresses and UDIDs were traditionally classified as Non-Personal Information because they did not identify a specific individual user. When an IP Address or UDID is associated or linked with other Personal Information, or used to monitor usage, search and transaction history or build a user profile for the purposes of customizing your experience or advertising on our Platforms, such information will be classified as Personal Information to the extent required by applicable law. Click here for more information about IP Addresses and UDIDs.
Depending on your relationship with us and the Services that you will use, in addition to that more traditional forms of Personal Information, we will also collect your Facebook, Twitter or other social networking user ID and password (and any other Personal and/or Non-Personal Information that you allow Facebook or any other platform to share with us), date of birth, gender, occupation/employer, and purchasing preferences, photos/videos or audio clips of you, facsimile number, and geolocation data that will tell us your specific or general location. We also collect Personal Information offline via contests or other promotions conducted via telephone (such as contests and promotions that encourage you to call in to our radio programs), text and instant messaging, postal mail, or facsimile, and in person at events, concerts, fairs, retail locations, and other remote locations. We may also collect your Personal Information when you join our various loyal-listener, email marketing and other membership-oriented clubs offline, as well as employment applications.
We may combine your online Personal Information with Personal Information collected offline, via your Facebook, Twitter or other social networking platforms, or other third party companies, such as credit bureaus, background check firms, marketing research companies, and Advertisers.
We also collect Non-Personal Information, which is generally information that cannot by itself be used to identify a specific individual person. Non-Personal Information includes information about your computer, browser, mobile device, visits to our Services and other online activities that are used for internal operations, to enhance or customize your experience, and to improve our Services. Personal Information that is de-identified (meaning it becomes anonymous) and combined with other users’ anonymous Personal Information (also called “aggregated” information) is also Non-Personal information because it cannot be used to identify a specific individual. However, Non-Personal Information linked to or associated with Personal Information will also be classified as Personal Information.
Please keep in mind that if you directly disclose Personal Information through Station public areas such as message boards, blogs, or chat rooms, this information may be collected and used by others. Note: Station does not read any of your private online communications.
3. How We Use Your Information
We receive and store any Personal Information you enter during registrations, account creation or any information you voluntarily provide us in any other way. You can choose not to provide certain Personal Information, but then you might not be able to take advantage of many of our features. We use the Personal Information that you provide to us for such purposes as responding to your requests, customizing your experience, improving our products and services, and communicating with you to inform you of other products or services available from Station, its affiliates and Advertisers. We may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
We collect Personal and Non-Personal Information to assist us in delivering a superior level of product and service. We collect such information to gain a better understanding of your needs and what types of features, activity or content are most popular with users, and thus provide a better experience for you. Reviewing your information and use of our Services enables us to give you convenient access to our products and services, focus on categories of greatest interest to you, keep you posted on the latest product announcements, updates, special offers, promotions, and events that you might like to hear about.
Our Sites and certain other Services will passively collect Personal and Non-Personal Information via cookies, web beacons and other similar technology. (Click here for more information) This information reveals the frequency with which you visit our Services, the times and dates of your visits, the pages or features and activities you reviewed, and other information, including your IP Address and UDID. We also use navigational data, including log files and click-stream data, to identify information about your web browser and operating system, and the time period in which you visit our Sites or select pages or areas of our Sites. This information is also used to improve our Site's content and is retained anonymously, meaning that it does not identify an individual user. This information is also used to improve our software and services by providing personalized content recommendations, location customization, and/or personalized help and instructions. In addition, we track content accesses and downloads for the purpose of paying royalties and license fees to third party providers, such as record labels, advertisers and other copyright holders and content distributors.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features or activities of our Sites or Services.
5. Use of Your Information for Advertising, Marketing & Social Networks
Advertising support allows us to offer many Services, and features and activities to users such as contests, sweepstakes and special events for free or very little cost. We will also share your Personal Information with our advertisers, sponsors or promotional partners (collectively, “Advertisers”) for the marketing of events, products or services, but only with your knowledge and consent. When we plan to share your Personal Information with Advertisers, you will receive such notice on the registration area of the website, in the rules of participation for the Service, activity or event, or via a message delivered via radio broadcast or email. Depending on the Service, feature or activity, we will either ask you for your consent first to receive marketing information directly from our Advertisers via the registration process for a particular Service, activity or event, or by participating in the Service, feature or activity, you agree and acknowledge that your Personal Information will be shared with Advertisers for marketing purposes.
Here’s a description of the types of advertising that we may serve to you: (Contextual, First-Party, and Third-Party Network Advertising.
We may use your Personal and Non-Personal Information for advertising-related purposes, such as:
- Customizing ads based on your geographic region or demographic segment or other Non-Personal Information collected about you;
- Limiting the number of times you see a particular ad;
- Showing ads in a particular sequence;
- Determining when you respond to ads;
- Reporting aggregated statistics.
We may share aggregated Non-Personal Information publicly and with our partners, such as publishers, Advertisers or connected web sites. For example, we may share Non-Personal Information to show trends about the general use of our Services and any features or activities. Additionally, we may be required to provide specific access and usage information to certain content providers and rights holders as a condition of content licensing and royalties. In such cases, we will provide content usage, access, demographic and other information to the content provider without your Personal Information.
We may disclose relevant information about our users to other contractors (e.g. a customer service contractor or a credit card clearing/processing service) in order for the contractor to provide specific services, and to better serve our customers. Our contractors and Operational Service Providers are bound by strict contractual requirements to keep all Personal Information they process strictly confidential and to use such information solely on behalf of Company or Station and not for the Operational Service Providers’ own marketing or advertising purposes.
Here are additional ways we use your Personal Information:
Marketing Via Mobile Devices
Shopping & E-Commerce
Although persons of all ages may visit our Site and other Services and participate in activities that do not require the collection of Personal Information, we do not knowingly or intentionally collect Personal Information from children under the age of 13, and in some cases (as specified on the home page of the Site) we discourage participation by anyone under the age of 18. Except for the limited circumstances listed below, we will automatically reject and delete (to the extent technically feasible) the registration or entry of any person we believe in good faith to be underage unless such information meets an exception under the Children’s Online Privacy Protection Act (“COPPA”) or pertains to the programming or operations of Station. Online or offline correspondence from children that pertains to the programming or operations of Station is subject to Federal Communications Commission (“FCC”) regulations that require broadcast licensees to post such correspondence in the applicable Station’s FCC Public Inspection File. We retain the right to block out or edit the postal and email address, text number and/or name of the child. Except to meet FCC regulations, other applicable laws, or other regulatory and legal purposes, we will not knowingly use, distribute or disclose any child's Personal Information to third parties without prior parental consent.
Any false or fraudulent registration or entry from a minor (a person under the age of 18) will be deemed to be ineligible and will disqualify the minor from the receipt of a prize, benefit, or other participation. Unless we are required to retain a minor’s Personal Information for regulatory, tax or other legal purposes, we will promptly remove such information from our database (to the extent technically feasible) if a parent withdraws his or her consent to our use of the minor’s Personal Information.
7. When We Disclose Information to Third Parties.
- To Company affiliates for business, operational, promotional and marketing purposes.
- To Advertisers if you participate in a co-branded, co-sponsored, or jointly presented promotion/contest or service, or to serve personalized or targeted advertising.
- To our Operational Service Providers, who are prohibited from using your Personal Information for any purpose not authorized by us or required by law.
- To protect the security of our Services, servers, network systems, and databases.
- To protect our users, affiliates, Advertisers, and Operational Service Providers against liability and harm.
- To implement and enforce our TOU or DMCA copyright complaint procedures.
- To respond to subpoenas, judicial processes, or government requests and investigations.
- To act in response to an emergency or situation that threatens the life, health or security of an individual, and to assist in the investigation of a violation (or presumed violation) of law, or if we believe in good faith that the law requires or authorizes such disclosure.
- In connection with any proposed or actual purchase, sale, lease, merger, assignment, re-organization or financing of all or any portion of the Company, our Services, Stations, or any of the business, assets or shares of our parent company(s) and affiliates.
We reserve the right to use, disclose and process any Non-Personal Information collected from you in any manner.
Personalized Content and Advertising Using Third Party Ad Networks
For more information about how targeted Network Advertising works, please visit: http://www.youradchoices.com/ or http://www.networkadvertising.org/understanding-online-advertising.
How to Opt-Out of Targeted Advertising by Network Advertising Services
You may opt-out of third party targeted advertising served by Network Advertising service providers in two ways: 1) By directly notifying a Network Advertising service provider via its opt-out tools (Please see above) or 2) using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage. For more information about DNT and how it works, please visit the Future of Privacy Forum’s website: http://www.allaboutdnt.com/.
We will make a good faith reasonable effort to honor your DNT browser settings for opting out of receiving targeted third party advertising based on your overall Internet usage. Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases or search history.
However, you cannot opt-out of our contextual or first party advertising, which is based on your usage of only our Services and may be combined with your usage of our social media sites. We will continue to serve you contextual and first party advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, advertisements and features and activities are functioning and used. We will also share this information in an aggregated form (meaning that no one individual person can be identified) to our Advertisers or potential Advertisers.
8. Additional Opt-in or Opt-out Choices for Use of Your Personal Information
Depending on the Service, feature or activity, you will have the option to either opt-in or opt-out of our use of your Personal Information for marketing or promotional message sent by us for our own events, features or activities. For example, we may send a marketing email message and you use the designated method in the email, as we cannot guarantee that other methods of notification will be effective or timely. You may also opt-out of text message promotions or subscriptions by following the instructions in the text message. Please see our Text Message Terms for more details.
9. Links to Third Party Websites and Third Party Content.
10. Security of your Personal Information
We use commercially reasonable efforts to secure your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide in a controlled, secure environment. When Sensitive Personal Information (such as a credit card number) is transmitted to us, it is protected through the use of industry-standard secured Internet connection, such as the Secure Socket Layer (SSL) or S-HTTP protocols. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure and no security measures are perfect or impenetrable. By transmitting Personal Information over the Internet, you are accepting any risks associated with doing so. In addition, you are responsible for taking appropriate measures to protect and secure all passwords, log-on or membership identification information and account information.
11. Changes, Corrections, or Deletions to Your Personal Information
You may change or correct any of your Personal Information collected online through the Site or other Services via your account setting on our Site-related Services, or via a written request to PrivacyAdministrator@wror.com
You will need to follow the instructions on the Site or other Services. Please be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data due to technical limitations of our systems, or retention and/or record keeping requirements under federal and state law. For example, although you may opt-out of any email marketing subscription program, loyal listener club or other membership clubs, our system does not delete your email address from our database . We can, however, deactivate your email address so that you do not receive any further marketing messages. You may delete any Personal Information collected via our non-contest text message promotions but we are required to retain contest entries – regardless of the entry method – for a period of years due to regulatory requirements. If you wish to delete Personal Information collected offline, please contact our Privacy Administrator.
Please be aware that we do not control certain privacy settings and preferences maintained by social media partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site.
12. Changes to this Policy
13. Contact Information
IP Address and UDID
An IP Address and UDID are a series of numbers that are automatically assigned to your computer or device and used by us to identify your computer or device. We will use this information to administer our Services, help identify and diagnose problems with our servers and/or operating systems, analyze trends, track users’ webpage movements to help improve our Services, help identify you and your shopping preferences, and gather broad demographic information for aggregating with other users to measure our performance. An IP Address and UDID can also be used to deliver targeted and personalized advertising based on your IP Address' geographic location, or your usage, transaction or search history.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Station pages, or register with the Site or particular features, activities, or services, a cookie helps us to recall your registration, membership, or transaction information on subsequent visits. This simplifies the process of recording your Personal Information, such as billing addresses, shipping addresses, and so on. When you return to the same Site, the information you previously provided can be retrieved, so you can easily use the features that you customized.
- Contextual Advertising: We may serve you an advertisement for brakes and shocks based on a used car dealer ad you just viewed or a search you’ve made about used cars on one of our Platforms; this type of relevant advertising based on particular content or search query is called “Contextual Advertising” because it is based on the context of how you used our Platforms. We do not collect any other information about you for Contextual Advertising.
- First Party Advertising: Advertising that is tailored or personalized based on a history of your use of content and participation in features and activities on our Platforms (and may be combined with information from our Facebook Fan page or our other social network sites) over time is based solely on a combination of information that Company or its Operational Service Providers collect from you – not from your use of other websites or third parties. We may share such information anonymously with our Advertisers in order to measure the effectiveness of ads on our Platforms, such as how many users opened or acted on a particular ad.
- Network Advertising: Information about your use of our Platforms combined with similar information about your overall Internet usage across different third party websites or online services used to serve tailored and personalized advertising is generally called “Network Advertising.” Multiple third party websites and online services are involved in this tailored or personalized advertising process, in essence a “network” of advertising providers. Such information about you could include information about your browser, computer, and/or mobile device and general information about your demographics (whether you have provided such information voluntarily or such information is estimated based on your usage history and interests), such as your gender, age, lifestyle, education, home ownership, geographic location, etc. See below for more information about how to identify a Network Advertising ad.
For advertising that is part of a Network Advertising service, you should see a small symbol (also called an icon) attached to a banner ad or other targeted advertising on certain Platforms that can be clicked open for information about why and how you are receiving a particular ad. For more information see www.aboutads.info.
Marketing via Mobile Devices
Station may provide commercial marketing and advertising opportunities, contests/sweepstakes, and alerts for news, sports, traffic, election coverage, school closings, and weather delivered via mobile devices. You must subscribe to a mobile service or request that we send such information to you via a text message or a wireless voice call (prerecorded or live). Depending on the type of mobile subscription service, you will be asked to submit your name, age or date of birth, mobile telephone number, and/or standard email address. We do not request submission of a wireless email address and if we collect such information inadvertently for a marketing or advertising opportunity, we will attempt to notify you and request a standard email address that does not have a wireless domain name attached to it. You have the right to opt-out of any mobile service in the same manner in which you registered or by notifying us at firstname.lastname@example.org
We do not generally keep email correspondence, except for those emails that relate to the on-air programs or operations of our Stations. As required by the Federal Communications Commission (“FCC”), if any part of your email correspondence relates to Station programming or operations, we must place such correspondence in the station’s FCC Public Inspection File, or make the correspondence available via electronic file access at the station to anyone that requests such information. Therefore, be informed that your Personal Information contained in certain emails or text messages will be disclosed to the general public. We request that you not place any Personal Information in your email or text correspondence to Station that pertains to Station programming or operations. You understand and agree that we are not responsible for Personal Information that is improperly disclosed in emails or texts that are made available to the general public in compliance with FCC regulations.
Shopping and E-Commerce
In connection with the sale of goods and/or services or for contest prize fulfillment, we may request Sensitive Personal Information. “Sensitive Personal Information” includes, but is not limited to, any individual’s: (1) social security number; (2) driver’s license number or state identification card number; (3) employee identification number; or (4) credit or debit card number, with or without any required security code, or PIN. Sensitive Personal Information will only be used for verification of your identity, federal or state tax reporting requirements, and/or to implement and complete the specific activity or event it was submitted for. We will not share your Sensitive Personal Information for marketing or promotional purposes, or with other third parties unless such disclosure is required by law. We may also request additional Personal Information such as full name, billing and shipping address, email address and telephone number and any such information that is required to fulfill your order and to communicate with you regarding your order. We may use your Personal Information (but not your credit card or debit card number) to contact you about future products, services and discounts or to provide such information indirectly from our Advertisers, unless you tell us otherwise (i.e. “opt-out”). We will only use your credit card and debit card number to complete the specific transaction you requested. Alternatively, we may use an independent third party Operational Service Provider to conduct the financial transaction in a secure manner; the third party payment process will be accessible via a hyperlink from the Site or other Services and the Operational Service Provider will be solely responsible for all financial transactions and the collection, use, and storage of your Sensitive Personal Information.
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