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Privacy Policy

 

MERUELO MEDIA PRIVACY POLICY

Effective and Last Updated:  July 28, 2020

Click on any of the links below to access a specific section of this Privacy Policy:

Introduction

Your Acknowledgment

Special Notices for EEA Residents and California Residents

Information We Collect

How We Collect Information

How We Use Your Personal Information

How We Share Your Personal Information

How We Protect Your Information

How Long We Keep Your Information

Changing and Accessing Your Personal Information

Your Choices Regarding Marketing Communications

Children’s Policy

Links from Our Website and Use of Internet Services

Changes to Our Privacy Policy

Contact Information

Appendix A – EEU GDPR Privacy Notice

Appendix B – California CCPA Privacy Notice

 

 

INTRODUCTION

We at Meruelo Media recognize that privacy is important.  This Privacy Policy explains our practices regarding Personal Information that we collect from you or about you during our interactions with you, whether online or offline.  What we mean when we refer to “Personal Information” is explained in the  Information We Collect section of this Privacy Policy.

We collect your Personal Information through:

·this website

· our mobile applications

· through written or verbal communications or interactions with us, including email and other electronic submissions

· when you visit our station, including independently owned or operated venues within them (collectively, the “Station”),

· your participation in our newsletters (collectively “Newsletters”)

· your participation in our marketing events, contests, promotions, or customer surveys (collectively, “Promotional Events”)

· interaction with third parties such as marketing partners with whom we have marketing relationships with or service providers who assist us in performing core services such as running Promotional Events, provide streaming services, concerts, contesting, and listener surveys

· through other sources such as our advertising and applications on third party websites
or services

The sources or points of collection of Personal Information described above are referred to together in this Privacy Policy as “Touch Points.”

YOUR ACKNOWLEDGMENT

Please read this Privacy Policy carefully tounderstand our practices regarding your Personal Information. If you do not
agree with our practices, your choices are either (1) not to use, access, visit, or participate in our Touch Points or (2) limit the Personal Information you provide. However, if you choose not to provide certain Personal Information, you may not be able to participate in a particular activity, realize a benefit we may offer, or access or receive certain content, functionalities, events, or services because the information is required for those matters.

BY USING, ACCESSING, OR VISITING ANY TOUCH POINTS OR BY AGREEING TO THIS PRIVACY POLICY WHEN YOU REGISTER TO USE, ACCESS OR VISIT ANY TOUCH POINTS, YOU ACKNOWLEDGE THAT WE MAY COLLECT, STORE, USE, AND SHARE YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our website or any of the other Touch Points after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

SPECIAL NOTICES FOR EEA RESIDENTS AND CALIFORNIA RESIDENTS

Local laws regarding privacy vary.  Some jurisdictions place restrictions on our collection, processing, and use of Personal Information or provide additional rights to residents of those jurisdictions. Our practices with respect to residents of those jurisdictions may be more limited and the rights of those residents may be broader than those described in this Privacy Policy. 

If you are a resident of the European Economic Area (EEA), please see Appendix A – EEU GDPR Privacy Notice for additional information regarding our use of your Personal Information and your rights.

If you are a resident of the State of California, please see Appendix B – California CCPA Privacy Notice for additional information regarding our use of your Personal Information and your rights. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

INFORMATION WE COLLECT

We collect various types of information from and about you, including Personal Information.

Personal Information” is


Information that can be used to identify you, your household, or any of your devices that connect to the internet or to other devices (those devices are referred to collectively in this Privacy Policy as “Smart Devices” and as an example, include computers, smartphones, and tablets)


Information that on its own may not be able to identify you, your household, or your Smart Devices but when combined with another piece of information could identify, trace, or locate you.  For example, your age alone may not identify you personally but when combined with your name it can be used to identify you.

By way of example only, Personal Information includes:

·
Information such as your name, postal or residence address, telephone number, email, internet protocol address, or any other identifier by which you may identified or by which you may be contacted online or offline

·
Information such as your signature, social security number, driver’s license or state identification card number, passport  number, physical description (e.g., age, race, color, marital status, gender), and similar data that may be used for identification purposes

·
Information about your education, employment, financial information (e.g., bank account number, credit card number, debit card number, and credit rating), medical or health information, and insurance information

·
Information regarding your Smart Devices and internet connections such as your internet protocol address (“IP address”) and the capabilities and features
of your Smart Devices, including the browser type and operating systems used.

·
Information about your internet or network activity such as your browsing history, search history, and your interaction with a website, application, advertisement, or text messaging

·
Geolocation data such as physical location and movements.

·
Biometric information such as fingerprints, faceprints, imagery of the retina or iris, and voice recordings.

HOW WE COLLECT INFORMATION

We collect information through our Touch Points as follows:

·
Directly
from you when you provide it to us
, including: 

Information that you provide when logging onto our website, subscribing to Newsletters, including filling in forms or registering through any of them

Information that you provide during on site events or concerts

Information that you provide when participating in Promotional Events

Information that you provide when participating in our sponsored social media activities which may include location, activities, photos, friend lists, and status updates

Information that you provide when managing your profile online

Information that you provide when planning an event with us, such as specifics about the event, the number of guests, and yourself or your organization

Information captured by closed-circuit television or other security monitoring technologies in our Station

Information you provide in any communication with us whether verbally, in writing, or electronically

Information that you provide when logging onto our website using other sign-ins (for example, Facebook Connect or Google Account) or social media applications

Information you provide in resumes or applications for employment at our Station

·
Automatically when you use or navigate through our website, social media apps, or Wi-Fi. As you use or navigate through those items, automatic data collection technologies collect certain information about your equipment, browsing actions, and patterns and other activity including:

Information regarding your visits to our website or use of or social media apps and Wi-Fi services including traffic data, location data, logs, and other communication data and the resources that you access and use.

Information about your Smart Devices and internet connection, including their Internet Protocol address (“IP” address), operating system, and browser type.

Information about the location of your Smart Devices (“Location Data”) which may include GPS coordinates (e.g., latitude and longitude) or similar information. 

Automatically-collected information is often statistical data that on its own is not able to identify you, your household, or your Smart Devices (“Non-Personal Information”). We may share Non-Personal Information in a collective (“aggregated”) and anonymous (“de-identified”) way with third parties. However, if Non-Personal Information is ever combined with other information so as to allow you, your household, or your Smart Devices to be identified, the combined information will be treated as Personal Information and used and shared as described in this Privacy Policy.

The technologies we use for automatic data collection includes the use of:

Log file information is automatically reported by your browser or Smart Device each time you access a web page or mobile applications and our servers automatically record some of that information (the “Server Logs”). The information in the Server Logs relates to your Smart Devices and your use of our website or mobile applications, and may include anonymous information such as your web request, IP address, operating system, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on our website, domain names, landing pages, pages viewed, and other such information. The information contained in Server Logs is used to monitor, assess, manage, diagnose problems with, improve and otherwise administer our website and mobile applications.

A small file placed on the hard drive of your Smart Device called a “cookie” or “browser cookie” or “flash cookie.”  You may adjust the settings on your browser or certain applications to refuse to accept cookies.  However, if you select that setting, you may not be able to access certain parts of our website. Unless you have adjusted your browser settings or other application settings to refuse cookies, our system will place cookies on your Smart Device when you visit our website.  While some cookies are deleted when you close your browser, others
remain after you close your browsing session.  For more information on managing cookies visit
www.allaboutcookies.org or www.aboutads.info/choices or search further online.

“Clear Gifs” (also known as web beacons) are used to track your online usage pattern. We also may use Clear Gifs in HTML-based emails sent to you to track which emails are opened and which links are clicked by recipients. You can disable the ability of Clear Gifs to track certain information by setting your browser to refuse certain Cookies. The information collected allows for more accurate reporting, monitoring, and improvement of our website and mobile applications.

“Universally Unique Identifiers (UUID) (“Unique Identifiers”) are small data files or similar data structures stored on or associated with your Smart Devices, which uniquely identify your Smart Devices.  When you access our website or mobile applications by or through a mobile device we or our third-party business partners may access, assign, collect, monitor or remotely store one or more Unique Identifiers in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A Unique Identifier may convey information to us about how you browse and use our website or mobile applications and may also be used to help you log in faster and enhance your navigation through those services.

Advertising Identifiers” are unique strings associated with your Smart Devices provided by the operating system.

·
From third parties, including business partners (for example, web publishers and payment card providers and processors), social media services providers, and other third-party sources that are lawfully allowed to share your data with us.

HOW WE USE YOUR PERSONAL INFORMATION

We use Personal Information that we collect about you or that you provide to us in a number of ways, including: 

·
To provide and personalize the services, products, or information you request from us.  For example: concert tickets, prizes, future events

·
To administer our Promotional Events and Newsletters

·
To conduct and notify you of marketing and sales promotions and for other marketing purposes.  For example: conducting sweepstakes, prize draws, and other contests and undertaking interest-based advertising and other targeted promotions

·
To conduct customer satisfaction and quality assurance surveys and market research.

·
To record listening or streaming activity

·
To present our website and mobile applications and their contents to you, including validating your identity, verifying and responding to communications from you, and providing customer service

·
To prevent fraud and other prohibited or illegal activities, to investigate and resolve disputes and problems, and to comply with our obligations under applicable laws and regulations.

·
To protect our employees, the public, website visitors, and our property and to respond to an emergency

·
To enforce our Terms of Use and other contractual obligations

·
To fulfill the purposes for which you provide the information, including those necessary to achieve those purposes and for any other purpose that is disclosed to you at the Touch Points

·
To administer, optimize, assess, analyze, and secure our website and its functionality 

·
To cross-reference, supplement, or combine with other information that we or our service providers have acquired about you through other sources, except where prohibited by applicable law

·
For other lawful purposes

We also use and combine Non-Personal Information for lawful purposes.

HOW WE SHARE YOUR INFORMATION

We may share your Non-Personal Information
with any third parties for any lawful purpose.

Unless otherwise prohibited by law, we may share
Personal Information about you with the following types of third parties and
for the following purposes:

·
Affiliated Companies:
We may share your Personal Information with our parents, subsidiaries, affiliated companies, and other controlled affiliates (including casinos, hotels, restaurants and other business ventures that are licensed, owned, operated, and/or managed by us or our parents, subsidiaries, affiliated companies and other companies under common control), who may use Personal Information for any of the purposes disclosed in or consistent with the terms of this Privacy Policy (including those identified in
How We Use Your Information.

·
Marketing Partners:
We may share your Personal Information with our promotional partners and other business partners with whom we have marketing or other relationships for joint marketing purposes or the partners’ own marketing purposes.

·
Property Partners:
We may share your information with independently owned or operated properties at or related to our Station who may use your Personal Information to provide you with services at or related to those venues.

·
Service Providers:
We may share your Personal with our service providers who assist us by performing core services (such as, hosting, billing, fulfillment, data storage, security, processing credit card payments, customer service, credit reporting, property management, customer relationship management, “know-your-customer,” accounting, auditing, processing insurance claims, investigating accident reports, administering sweepstakes, surveys, email and mailing services, and delivering packages) related to the operation of our Station, the provision of services at the Station, the operation of our website and mobile applications, the processing and fulfillment of prizing, or by making certain website or mobile applications functionality available to our users.

·
Transactions: In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, reorganization, or liquidation of our business, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, your Personal Information and other information concerning your relationship with us. Any successor may use your information for the same purposes set forth in this Privacy Policy.

·
Legal: We may use your Information to identify you and, where permitted or required by law, we will provide any information about or relating to you, including any Personal Information about you, to third parties without your consent if we reasonably believe that the action is necessary to: (a) comply with a court order, subpoena or other legal or regulatory requirements; (b) fulfill a government request for information; (c) protect or defend our legal rights or property, our Station, our website or mobile applications, or other guests and online users; (d) respond to claims that any posting or other content of our website or mobile applications violates the rights of third parties, including providing information necessary to satisfy the notice and counter-notice procedures pursuant to the Digital Millennium Copyright Act; (e) in an emergency, to protect the health and safety of users of our website or mobile applications, our guests and visitors, or the general public; or (f) enforce compliance with our Terms of Use or other contracts.  We will not disclose the amount of your specific gaming winnings or gaming losses to any third party unless required by applicable law, regulation, court order, or subpoena.

·
Other Purposes:
We may share your Personal Information to fulfill the purpose for which you provided it and, with your consent, for any other purpose.

HOW WE PROTECT YOUR INFORMATION

We will take reasonable measures to: (a) protect Personal Information from unauthorized access, disclosure, alteration or destruction, and (b) keep Personal Information accurate and up-to-date as appropriate.

We maintain a PCI compliance program and an IT compliance program.

For online transactions, the measures include Secure Sockets Layer (SSL) technology to encrypt the transmission of personally identifiable financial and transaction information over the Internet, provided you are using an SSL-enabled device. We also utilize other reasonable security measures such as firewalls, security patches, and anti-virus programs, to protect your Personal Information.

We also strive to require our affiliates and service providers with whom we share Personal Information to exercise reasonable efforts to maintain the confidentiality of Personal Information about you.

Unfortunately, despite the efforts described above, no security system or system of transmitting data over the Internet or electronically is guaranteed to be entirely secure.  We cannot and do not guarantee the security of any information you disclose or transmit to us via the Internet or by other electronic means, and are not responsible for the theft, destruction, or inadvertent disclosure of your Personal Information.

For your own privacy protection, we recommend that you do not include any particularly sensitive Personal Information such as passwords, social security numbers, credit card details, or bank account information, in any emails that you send to us. We will not contact you by email or text message to ask for that information.

If a data breach occurs, we will notify regulators or consumers as required by applicable laws or regulations.

HOW LONG WE KEEP YOUR INFORMATION

We keep Personal Information about you for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or allowed by applicable law.

Generally:  (a) we keep Personal Information collected related to contests for up to seven (7) years after the contest is completed, and (b) we retain other Personal Information for shorter periods of time if possible and if permitted by law.

We will destroy your Personal Information as early as practicable and in a way that the information may not be restored or reconstructed.

CHANGING AND ACCESSING YOUR PERSONAL INFORMATION

If you have registered on the Website, or are member of our Newsletters, you can login to your account to change or update certain information and preferences to keep your data accurate, complete, and up-to-date.  You may also contact us as described in the Contact Information section to update or correct certain Personal Information.

We will respond to your request and, if applicable and appropriate, make the requested change in our active databases within a reasonable timeframe. Please remember that we may not be able to fulfill certain requests while allowing you access to certain benefits and features. Even if you unsubscribe from our marketing communications, you may continue to receive certain communications from us, such as transactional, customer service, or other relationship messages, messages about your account and profile, and emails in response to communications or requests for information that we receive from you.

Please also note that we may not be able to remove your Personal Information from the databases of third parties to whom we already provided your Personal Information as of the date of your opt-out request.  Please note that we may be required to retain certain Personal Information to comply with IRS or other government reporting purposes.

YOUR CHOICES REGARDING MARKETING COMMUNICATIONS

If you have provided us with your contact information (and consent where required), we may contact you for marketing purposes such as sharing information about our services or inviting you to events or to participate in special promotions.  Those communications may be through postal mail, email, test messages, social media, mobile applications and alerts, or other means.

We may provide you with