Effective Date: September 30, 2023
Any users located within the European Economic Area (“EEA”) are prohibited from using our Platforms. For avoidance of doubt, the Great Circle Media Platforms are not intended for users located within the EEA.
Our Platforms are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 13 years of age.
How We Collect Personal Information
- From you. This may include personal information we collect when you view or consume content, listen to our live streams, sign up to receive marketing information from us, post on our Platforms, enter our various sweepstakes and contests, contact us, or submit a news tip. This may also include streaming or listening metrics, duration of listening sessions, likes, and interactions with an Internet radio player.
- From third parties and publicly available sources. This may include personal information we collect from other public sources, including, but not limited to, websites that enable social sharing, social media sites, and websites from our service providers, vendors, our affiliates, or other individuals and businesses.
- From devices you use when you interact with us online. This may include information collected through our Platforms and automatically from devices you use to connect to our Platforms. For more information about this, please see our “Cookies and similar technologies” section below.
- From you in person.
The Types of Personal Information We May Collect From You
Depending on how you use our Platforms, we may collect:
- User Information. If you create an account with us, then we need certain information to create and manage any account you make on our Platforms, like your phone number, email address, and password.
- Contact Information and Preferences. Such as name, email address, mailing address, phone number, and listening preferences.
- Biographical and Demographic Information. Such as date of birth, age, other preferences.
- Listening and Subscription Information. Such as listening time, listening occasions, last logged in visit, contest entries, notifications subscriptions, notification views, notification clicks, email subscriptions, liked songs, favorite artists, messages sent to the platform, and registration source.
- Internet Activity. Such as your Internet Protocol (“IP”) address, what advertisements aired while logged in to our Platforms, and information on your interaction with our Platforms.
- Device Information. Along with the information you give us directly, we collect a variety of information automatically as you use our Platforms. Like other websites and apps, we collect data about the browsers and devices you use to access our Platforms. The data we collect includes browser or device model and settings, device ad ID, operating system, unique identifiers, and the version of the app you’re using.
- Usage Data. We also collect data about how your browsers and devices interact with our Platforms, including IP address, crash reports, system activity, and the date, and time. If you access our Platforms from a mobile or other device, we may also collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other usage information for that device.
- Other Personal Information. Other information collected online or offline to help us better identify and offer services and information that we believe may be of interest to you, or help us better understand your experience with our Platforms.
- Communications with us. Such as interactions with us on our Platforms and social media channels, including chatbot and live chat. By accessing or using any of these communications features, you agree that we may record and retain a transcript of all communications with you. We may also work with trusted service providers to analyze, store, and use this data on our behalf.
- Fraud Prevention Information. Data used to help identify and prevent fraud.
- Inferences. Inferences may be used to improve our Platforms and make them more useful to you. We may use data about your activity to understand and infer your preferences.
- Aggregate Data. We may collect your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you, including the URL of the site you visited before our Platforms.
How We Use Your Personal Information
We may use your information for the following reasons, depending on your relationship with us:
- To allow us to make personalized recommendations of content you may be interested in.
- To offer you other programs, services or products that we believe may be of interest to you.
- To fulfill your requests for our products and services.
- To communicate with you, such as when we respond to your inquiries, send you communications, and contact you.
- To notify you when we make changes to our subscriber agreements.
- To provide, market, and develop our products and services, including to maintain our Platforms, troubleshoot, provide customer and technical support, conduct data analysis, test and research, and better understand the interests of our customers, listeners, and Platform visitors who use our services and products.
- To serve you targeted advertising or content.
- To conduct marketing research.
- To understand how you interact with our Platforms and to provide you with an interactive online experience, including through personalized or localized Platform experiences.
- To maintain the safety, security, and integrity of our Platforms, for example, by authenticating users and providing account security and fraud detection. We may also use your information to monitor, detect, and prevent fraud and improper or illegal activity.
- To debug our systems, to secure our online services, including our network and websites, and to debug our online services.
- To send you news and/or marketing communications (by email, phone, or text) subject to your marketing preferences and choices, including information about us or third-party offerings we think may be of interest to you.
- To conduct market research and develop quality assurance, including to study, develop, and improve our products and services. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development and improvement activities.
- To comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Platforms. This would include the use of your information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigations.
- To combine information we receive online from you with records from other sources.
How We Disclose Personal Information
We may collect, use, retain, disclose, and store personal information collected from or about you with any of the following entities and for any of the following purposes:
- Service Providers and Advertising Partners. We may provide personal information to vendors, customer support vendors, payment processors, contractors, business and service partners, or other third parties, such as advertising partners or other marketing partners who provide services to us, including analysis firms, advertisers, and others.
- Collaborators. We may share personal information with collaborators with whom we jointly develop or promote our services, including sponsorships and co-branded opportunities, contests, and promotions.
- Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements, or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
- In connection with a merger, acquisition, or business transfer. If we sell all or a part of our company, are part of a merger, consolidation, restructuring, and/or sale of assets or other corporate change, your information may be transferred as part of that transaction.
- At your direction. We may disclose your personal information at your direction or with your consent.
- The General Public. We may share personal information with the general public that you choose to share when publicly contributing content to our Platforms through a public forum, blog, social feature, or the like;
- Device Sharers. We may share personal information with others who share your device if you make your account available to them through that device.
- Aggregate Data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.
Links to Third Party Websites
We may provide links to websites and other third-party content (e.g., social media platforms) that are not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.
Advertising and Opt-Out Disclosures
When you use our Platforms our third-party advertising partners, social media providers, and analytics providers may collect personal information about your online activity on our Platforms and on third party websites.
One of the third-party partners we use is Google Analytics. Please see www.google.com/policies/privacy/partners to find out more about how Google uses your information.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adspolicy/answer/6008942
Google, as a third-party vendor, may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice, and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt-out page (currently available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt-out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.
We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in our possession against loss, theft, unauthorized use, disclosure, or modification. However, no electronic data transmission or storage of information can be guaranteed entirely secure. We urge you to exercise caution when transmitting personal information over the internet. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.
Cookies and Similar Technology
We and our partners use various tools to collect data when you visit our Platforms, including cookies, pixels, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Platforms use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Platform. These technologies may also be used to collect and store information about your usage of the Platforms, such as pages you have visited, other content you viewed, and search history.
We and our partners may also use these technologies to gather personal information about how you view and use our Platforms and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Platforms. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. Our partners may collect data from your browser or device for advertising and measurement purposes using their own similar tools.
Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies, such as cookies. To find out more about cookies, visit www.aboutcookies.org. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising.
Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our websites.
In addition, if you give your email address to us, we may use a scrambled form (called a “hashed” version) of your email address to deliver tailored ads to you on our Platforms or on other websites, including via Custom Audience Feature or other similar tools.
Your Marketing Preferences
We may periodically send promotional materials or notifications related to our Platforms. If you don’t want to receive promotional communications from us, such as offers, newsletters, advertising e-mails, or other marketing communications, you can unsubscribe by following the removal instructions in the communication that you receive (such as clicking the “UNSUBSCRIBE” or similar link within the email). Please allow time for your request to be implemented.
There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Platforms or policies.
Additional Information for Residents of California & Virginia
What We Collected, Disclosed, and/or Shared/Sold
We may share personal information (including sensitive personal information) as described below:
With our affiliates: We may share personal information with our affiliates, subsidiaries, and other companies under common control and ownership with Great Circle Media, including, but not limited to, the companies listed at gcmaz.com. Additionally, we do not knowingly “share” or “sell” Personal Information of minors under 16 years of age.
With our vendors and service providers: We may share personal information with vendors and service providers we hire to help us run our business, including those companies that host, protect, or operate our Platforms; analyze data; provide customer service, send emails for us; process payments; conduct surveys; fulfill orders; run our promotional activities and contests; or provide marketing, analytics, and advertising services.
With our business partners, rights holders, advertisers, and advertising companies: We may share or make available personal information with or to our sponsors, partners, advertisers, advertising networks, advertising servers, and analytics companies or other third parties in connection with our and their marketing, promotional, and other offers, as well as product information. These third parties may use your personal information for their own advertising, analytics, planning, market research, or other business purposes. We may also share your information with the rights holders that license content to Great Circle Media Platforms (e.g., artists or record labels). Some transfers of your personal information to these other companies may be viewed as a “sale” under certain state laws.
Business transfers: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, or assets related to the Platforms, your information may be disclosed to such entity as part of the due diligence process and may be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
With SDK Partners: We may make available personal information to third party technology companies whose software development kits (SDKs) or application programming interfaces (APIs) are embedded into our sites.
Other disclosures: We may share personal information for other reasons we may describe to you from time to time as permitted by law.
Non-personal information: We may share information that has been de-identified or aggregated such that it does not identify or relate to you, with other parties for any purpose. This may include aggregated user statistics about the Platforms or aggregated demographic information about our users.
Business or Commercial Purposes for Which Personal Information Is Collected
Your Personal Information is used for the following purposes:
- To operate, manage, and maintain our Platforms;
- To provide our Platforms;
- To accomplish our business purposes and objectives, including to:
- Respond to your requests for services or products;
- Provide you with customer support and respond to your communications;
- Maintain our facilities and infrastructure;
- Develop, improve, repair, and maintain our Platforms;
- Conduct research, analytics, and data analysis;
- Send you transactional or administrative communications, as well as certain service-related announcements;
- Personalize your experience on our Platforms;
- Advertise and market our Platforms;
- Run and administer our promotions and contests;
- Send you information relating to other programs, services, or products that we believe may be of interest to you;
- Run website analytics to evaluate performance;
- Fulfill our responsibilities as an employer;
- Quality and safety assurance measures;
- Conduct risk and security controls and monitoring;
- Detect and prevent fraud;
- Perform identity verification;
- Perform accounting, audit, and other internal functions;
- Comply with the law, legal process, and internal policies;
- Exercise and defend legal claims.
Your Privacy Rights Under Applicable State Law
If you are a resident of California or Virginia, you may have the following rights with respect to any information about you that constitutes “personal information” under California law and “personal data” under other state laws, as described below.
We are required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by applicable law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request.
- Right to Know and Access Personal Information: You may request to access information we have collected and maintain about you. If your request is granted, we will provide you with a copy of the personal information we have collected and maintained about you in a portable manner. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Deletion of Personal Information: You may request that we delete the personal information we have collected from you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate personal information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.
- Opt Out of “Sale” and Certain Sharing Practices: Depending on the state you reside in, you will have the right to opt out of the sale of your data, the disclosure of your data for cross-context behavioral advertising/targeted advertising (known as a “share” in California), and profiling in furtherance of solely automatized decisions that produce legal or similarly significant effects. In order for you or your authorized agent to exercise this right, please see ‘To Exercise Rights” section below.
- Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under the CCPA.
- Right to Appeal: If you are a Virginia resident and receive a denial of a personal data rights request, you have the right to request an appeal.
To Exercise Rights:
In order to exercise your right to opt out of the sale or sharing of your personal information, please submit a request through the linked form at gcmaz.com/contact. You may also submit a request via email at firstname.lastname@example.org or by calling us at 928-774-5231. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.
California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of a Great Circle Media user, please contact us at the contact information below with supporting verification information, which includes proof that you have access to the consumer’s interface and proof of your own identity.
Shine the Light Disclosure
We do not disclose personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) with third parties, other than our affiliates, for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by sending an email to email@example.com or by sending a letter to 1117 W Route 66, Flagstaff, AZ 86001, Attn: Legal. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address or mailing address referenced above.
We welcome requests, suggestions and questions concerning our use of your Personal Information. All such communication should be directed to firstname.lastname@example.org.