This privacy notice
for FIRST CLASS RADIO INC (doing business as First Class Radio)
(“Company,” “we,” “us,” or “our“), describes how and
why we might collect, store, use, and/or share (“process“) your
information when you use our services (“Services“), such as when
you:
Visit our website at
www.firstclassradio.com, or any website of ours that links to this
privacy notice, or any other application of ours that links to this
privacy notice]
Engage with us in
other related ways ― including any sales, marketing, or events
Questions or
concerns? Reading this privacy notice will help you understand your
privacy rights and choices. If you do not agree with our policies and
practices, please do not use our Services. If you still have any
questions or concerns, please contact us at info@firstclassradio.com
SUMMARY OF KEY
POINTS
This summary
provides key points from our privacy notice, but you can find out
more details about any of these topics by using our table of contents
below to find the section you are looking for.
What personal
information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you
interact with FIRST CLASS RADIO INC and the Services, the choices you
make, and the products and features you use.
Do you process any
sensitive personal information? We may process sensitive personal
information when necessary with your consent or as otherwise
permitted by applicable law.
Do you receive any
information from third parties? We may receive information from
public databases, marketing partners, social media platforms, and
other outside sources.
How do you process
my information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your
information for other purposes with your consent. We process your
information only when we have a valid legal reason to do so.
In what situations
and with which types of parties do we share personal information? We
may share information in specific situations with your consent, or
when required to do so legally.
How do we keep your
information safe? We have organizational and technical processes and
procedures in place to protect your personal information. However, no
electronic transmission over the internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise
or guarantee that hackers, cyber-criminals, or other unauthorized
third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information.
What are your
rights? Depending on where you are located geographically, the
applicable privacy law may mean you have certain rights regarding
your personal information.
How do I exercise my
rights? The easiest way to exercise your rights is by contacting us.
We will consider and act upon any request in accordance with
applicable data protection laws.
Want to learn more
about what FIRST CLASS RADIO INC does with any information we
collect? Review the notice in full below.
TABLE OF CONTENTS
1. WHAT INFORMATION
DO WE COLLECT?
2. HOW DO WE PROCESS
YOUR INFORMATION?
3. WHAT LEGAL BASES
DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR
STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES
AND OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE
YOUR SOCIAL LOGINS?
8. IS YOUR
INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE
KEEP YOUR INFORMATION?
10. HOW DO WE KEEP
YOUR INFORMATION SAFE?
11. DO WE COLLECT
INFORMATION FROM MINORS?
12. WHAT ARE YOUR
PRIVACY RIGHTS?
13. CONTROLS FOR
DO-NOT-TRACK FEATURES
14. DO CALIFORNIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO VIRGINIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE
UPDATES TO THIS NOTICE?
17. HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU
REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION
DO WE COLLECT?
Personal information
you disclose to us
In Short: We collect
personal information that you provide to us.
We collect personal
information that you voluntarily provide to us when you [register on
the Services,] express an interest in obtaining information about us
or our products and Services, when you participate in activities on
the Services, or otherwise when you contact us.
Personal Information
Provided by You. The personal information that we collect depends on
the context of your interactions with us and the Services, the
choices you make, and the products and features you use. The personal
information we collect may include the following:
Contact info
Information about
the equipment you own
Information
regarding your interests in our products and services
Sensitive
Information. We do not process sensitive information.
Payment Data. We may
collect data necessary to process your payment if you make purchases,
such as your payment instrument number (such as a credit card
number), and the security code associated with your payment
instrument. All payment data is stored by [PayPal]. You may find
their privacy notice link(s) here:
https://www.paypal.com/us/legalhub/privacy-full
Social Media Login
Data. We may provide you with the option to register with us using
your existing social media account details, like your Facebook,
Twitter, or other social media account. If you choose to register in
this way, we will collect the information described in the section
called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.
[Application Data.
If you use our application(s), we also may collect the following
information if you choose to provide us with access or permission:
Geolocation
Information. We may request access or permission to track
location-based information from your mobile device, either
continuously or while you are using our mobile application(s), to
provide certain location-based services. If you wish to change our
access or permissions, you may do so in your device’s settings.
Mobile Device
Access. We may request access or permission to certain features from
your mobile device, including your mobile device’s bluetooth,
calendar, camera, own, and other features. If you wish to change our
access or permissions, you may do so in your device’s settings.
Mobile Device Data.
We automatically collect device information (such as your mobile
device ID, model, and manufacturer), operating system, version
information and system configuration information, device and
application identification numbers, browser type and version,
hardware model Internet service provider and/or mobile carrier, and
Internet Protocol (IP) address (or proxy server). If you are using
our application(s), we may also collect information about the phone
network associated with your mobile device, your mobile device’s
operating system or platform, the type of mobile device you use, your
mobile device’s unique device ID, and information about the
features of our application(s) you accessed.
Push Notifications.
We may request to send you push notifications regarding your account
or certain features of the application(s). If you wish to opt out
from receiving these types of communications, you may turn them off
in your device’s settings.
This information is
primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics
and reporting purposes.]
All personal
information that you provide to us must be true, complete, and
accurate, and you must notify us of any changes to such personal
information.
Information
automatically collected
In Short: Some
information — such as your Internet Protocol (IP) address and/or
browser and device characteristics — is collected automatically
when you visit our Services.
We automatically
collect certain information when you visit, use, or navigate the
Services. This information does not reveal your specific identity
(like your name or contact information) but may include device and
usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring
URLs, device name, country, location, information about how and when
you use our Services, and other technical information. This
information is primarily needed to maintain the security and
operation of our Services, and for our internal analytics and
reporting purposes.
Like many
businesses, we also collect information through cookies and similar
technologies.
The information we
collect includes:
Log and Usage Data.
Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you
access or use our Services and which we record in log files.
Depending on how you interact with us, this log data may include your
IP address, device information, browser type, and settings and
information about your activity in the Services (such as the
date/time stamps associated with your usage, pages and files viewed,
searches, and other actions you take such as which features you use),
device event information (such as system activity, error reports
(sometimes called “crash dumps”), and hardware settings).
Device Data. We
collect device data such as information about your computer, phone,
tablet, or other device you use to access the Services. Depending on
the device used, this device data may include information such as
your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model,
Internet service provider and/or mobile carrier, operating system,
and system configuration information.
Location Data. We
collect location data such as information about your device’s
location, which can be either precise or imprecise. How much
information we collect depends on the type and settings of the device
you use to access the Services. For example, we may use GPS and other
technologies to collect geolocation data that tells us your current
location (based on your IP address). You can opt out of allowing us
to collect this information either by refusing access to the
information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain
aspects of the Services.
Information
collected from other sources
In Short: We may
collect limited data from public databases, marketing partners,
social media platforms, and other outside sources.
In order to enhance
our ability to provide relevant marketing, offers, and services to
you and update our records, we may obtain information about you from
other sources, such as public databases, joint marketing partners,
affiliate programs, data providers, social media platforms, and from
other third parties. This information includes mailing addresses, job
titles, email addresses, phone numbers, intent data (or user behavior
data), Internet Protocol (IP) addresses, social media profiles,
social media URLs, and custom profiles, for purposes of targeted
advertising and event promotion. If you interact with us on a social
media platform using your social media account (e.g., Facebook or
Twitter), we receive personal information about you such as your
name, email address, and gender. Any personal information that we
collect from your social media account depends on your social media
account’s privacy settings.
[Information
collected when you use our Facebook application(s). We by default
access your Facebook basic account information, including your name,
email, gender, birthday, current city, and profile picture URL, as
well as other information that you choose to make public. We may also
request access to other permissions related to your account, such as
friends, check-ins, and likes, and you may choose to grant or deny us
access to each individual permission. For more information regarding
Facebook permissions, refer to the Facebook Permissions Reference
page.]
2. HOW DO WE PROCESS
YOUR INFORMATION?
In Short: We process
your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to
comply with law. We may also process your information for other
purposes with your consent.
We process your
personal information for a variety of reasons, depending on how you
interact with our Services, including:
To facilitate
account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log
in to your account, as well as keep your account in working order.
To deliver and
facilitate delivery of services to the user. We may process your
information to provide you with the requested service.
To respond to user
inquiries/offer support to users. We may process your information to
respond to your inquiries and solve any potential issues you might
have with the requested service.
To send
administrative information to you. We may process your information to
send you details about our products and services, changes to our
terms and policies, and other similar information.
To fulfill and
manage your orders. We may process your information to fulfill and
manage your orders, payments, returns, and exchanges made through the
Services.
To enable
user-to-user communications. We may process your information if you
choose to use any of our offerings that allow for communication with
another user.
To request feedback.
We may process your information when necessary to request feedback
and to contact you about your use of our Services.
To send you
marketing and promotional communications. We may process the personal
information you send to us for our marketing purposes, if this is in
accordance with your marketing preferences. You can opt out of our
marketing emails at any time. For more information, see “WHAT ARE
YOUR PRIVACY RIGHTS?” below).
To deliver targeted
advertising to you. We may process your information to develop and
display personalized content and advertising tailored to your
interests, location, and more. For more information see our Cookie
Notice: [Cookie Notice URL].
To protect our
Services. We may process your information as part of our efforts to
keep our Services safe and secure, including fraud monitoring and
prevention.
To identify usage
trends. We may process information about how you use our Services to
better understand how they are being used so we can improve them.
To determine the
effectiveness of our marketing and promotional campaigns. We may
process your information to better understand how to provide
marketing and promotional campaigns that are most relevant to you.
To save or protect
an individual’s vital interest. We may process your information
when necessary to save or protect an individual’s vital interest,
such as to prevent harm.
3. WHAT LEGAL BASES
DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only
process your personal information when we believe it is necessary and
we have a valid legal reason (i.e., legal basis) to do so under
applicable law, like with your consent, to comply with laws, to
provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate
business interests.
If you are located
in the EU or UK, this section applies to you.
The General Data
Protection Regulation (GDPR) and UK GDPR require us to explain the
valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to
process your personal information:
Consent. We may
process your information if you have given us permission (i.e.,
consent) to use your personal information for a specific purpose. You
can withdraw your consent at any time.
Performance of a
Contract. We may process your personal information when we believe it
is necessary to fulfill our contractual obligations to you, including
providing our Services or at your request prior to entering into a
contract with you.
Legitimate
Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and
those interests do not outweigh your interests and fundamental rights
and freedoms. For example, we may process your personal information
for some of the purposes described in order to:
Send users
information about special offers and discounts on our products and
services
Develop and display
personalized and relevant advertising content for our users
Analyze how our
services are used so we can improve them to engage and retain users
Understand how our
users use our products and services so we can improve user experience
Legal Obligations.
We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a
law enforcement body or regulatory agency, exercise or defend our
legal rights, or disclose your information as evidence in litigation
in which we are involved.
Vital Interests. We
may process your information where we believe it is necessary to
protect your vital interests or the vital interests of a third party,
such as situations involving potential threats to the safety of any
person.
In legal terms, we
are generally the “data controller” under European data
protection laws of the personal information described in this privacy
notice, since we determine the means and/or purposes of the data
processing we perform. This privacy notice does not apply to the
personal information we process as a “data processor” on behalf
of our customers. In those situations, the customer that we provide
services to and with whom we have entered into a data processing
agreement is the “data controller” responsible for your personal
information, and we merely process your information on their behalf
in accordance with your instructions. If you want to know more about
our customers’ privacy practices, you should read their privacy
policies and direct any questions you have to them.
If you are located
in Canada, this section applies to you.
We may process your
information if you have given us specific permission (i.e., express
consent) to use your personal information for a specific purpose, or
in situations where your permission can be inferred (i.e., implied
consent). You can withdraw your consent at any time.
In some exceptional
cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
If collection is
clearly in the interests of an individual and consent cannot be
obtained in a timely way
For investigations
and fraud detection and prevention
For business
transactions provided certain conditions are met
If it is contained
in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
For identifying
injured, ill, or deceased persons and communicating with next of kin
If we have
reasonable grounds to believe an individual has been, is, or may be
victim of financial abuse
If it is reasonable
to expect collection and use with consent would compromise the
availability or the accuracy of the information and the collection is
reasonable for purposes related to investigating a breach of an
agreement or a contravention of the laws of Canada or a province
If disclosure is
required to comply with a subpoena, warrant, court order, or rules of
the court relating to the production of records
If it was produced
by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for
which the information was produced
If the collection is
solely for journalistic, artistic, or literary purposes
If the information
is publicly available and is specified by the regulations
4. WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may
share information in specific situations described in this section
and/or with the following categories of third parties.
Vendors,
Consultants, and Other Third-Party Service Providers. We may share
your data with third-party vendors, service providers, contractors,
or agents (“third parties”) who perform services for us or on our
behalf and require access to such information to do that work. We
have contracts in place with our third parties, which are designed to
help safeguard your personal information. This means that they cannot
do anything with your personal information unless we have instructed
them to do it. They will also not share your personal information
with any organization apart from us. They also commit to protect the
data they hold on our behalf and to retain it for the period we
instruct. The categories of third parties we may share personal
information with are as follows:
Ad Networks
Affiliate Marketing
Programs
Cloud Computing
Services
Communication &
Collaboration Tools
Data Analytics
Services
Data Storage Service
Providers
Finance &
Accounting Tools
Government Entities
Order Fulfillment
Service Providers
Payment Processors
Performance
Monitoring Tools
Product Engineering
& Design Tools
Retargeting
Platforms
Sales &
Marketing Tools
Social Networks
Testing Tools
User Account
Registration & Authentication Services
Website Hosting
Service Providers
We also may need to
share your personal information in the following situations:
Business Transfers.
We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets,
financing, or acquisition of all or a portion of our business to
another company.
When we use Google
Maps Platform APIs. We may share your information with certain Google
Maps Platform APIs (e.g., Google Maps API, Places API). To find out
more about Google’s Privacy Policy, please refer to this link. We
use certain Google Maps Platform APIs to retrieve certain information
when you make location-specific requests. This includes: [List of
Information Collected], and other similar information. A full list of
what we use information for can be found in this section and in the
previous section titled “HOW DO WE PROCESS YOUR INFORMATION?”.
[We obtain and store on your device (‘cache’) your location for
[#] months. You may revoke your consent anytime by contacting us at
the contact details provided at the end of this document. The Google
Maps Platform APIs that we use store and access cookies and other
information on your devices. If you are a user currently in the
European Economic Area (EU countries, Iceland, Liechtenstein and
Norway) or the United Kingdom, please take a look at our Cookie
Notice, which can be found at this link: [Cookie Notice URL].
Affiliates. We may
share your information with our affiliates, in which case we will
require those affiliates to honor this privacy notice. Affiliates
include our parent company and any subsidiaries, joint venture
partners, or other companies that we control or that are under common
control with us.
Business Partners.
We may share your information with our business partners to offer you
certain products, services, or promotions.
Other Users. When
you share personal information [(for example, by posting comments,
contributions, or other content to the Services)] or otherwise
interact with public areas of the Services, such personal information
may be viewed by all users and may be publicly made available outside
the Services in perpetuity. If you interact with other users of our
Services and register for our Services through a social network (such
as Facebook), your contacts on the social network will see your name,
profile photo, and descriptions of your activity. Similarly, other
users will be able to view descriptions of your activity, communicate
with you within our Services, and view your profile.
Offer Wall. Our
application(s) may display a third-party hosted “offer wall.”
Such an offer wall allows third-party advertisers to offer virtual
currency, gifts, or other items to users in return for the acceptance
and completion of an advertisement offer. Such an offer wall may
appear in our application(s) and be displayed to you based on certain
data, such as your geographic area or demographic information. When
you click on an offer wall, you will be brought to an external
website belonging to other persons and will leave our application(s).
A unique identifier, such as your user ID, will be shared with the
offer wall provider in order to prevent fraud and properly credit
your account with the relevant reward.
5. WHAT IS OUR
STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not
responsible for the safety of any information that you share with
third parties that we may link to or who advertise on our Services,
but are not affiliated with, our Services.
The Services,
[including our offer wall], may link to third-party websites, online
services, or mobile applications and/or contain advertisements from
third parties that are not affiliated with us and which may link to
other websites, services, or applications. Accordingly, we do not
make any guarantee regarding any such third parties, and we will not
be liable for any loss or damage caused by the use of such
third-party websites, services, or applications. The inclusion of a
link towards a third-party website, service, or application does not
imply an endorsement by us. We cannot guarantee the safety and
privacy of data you provide to any third parties. Any data collected
by third parties is not covered by this privacy notice. We are not
responsible for the content or privacy and security practices and
policies of any third parties, including other websites, services, or
applications that may be linked to or from the Services. You should
review the policies of such third parties and contact them directly
to respond to your questions.
6. DO WE USE COOKIES
AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use
cookies and other tracking technologies to collect and store your
information.
We may use cookies
and similar tracking technologies (like web beacons and pixels) to
access or store information.
7. HOW DO WE HANDLE
YOUR SOCIAL LOGINS?
In Short: If you
choose to register or log in to our services using a social media
account, we may have access to certain information about you.
Our Services offer
you the ability to register and log in using your third-party social
media account details (like your Facebook or Twitter logins). Where
you choose to do this, we will receive certain profile information
about you from your social media provider. The profile information we
receive may vary depending on the social media provider concerned,
but will often include your name, email address, friends list, and
profile picture, as well as other information you choose to make
public on such a social media platform. If you log in using Facebook,
we may also request access to other permissions related to your
account, such as your friends, check-ins, and likes, and you may
choose to grant or deny us access to each individual permission.
We will use the
information we receive only for the purposes that are described in
this privacy notice or that are otherwise made clear to you on the
relevant Services. Please note that we do not control, and are not
responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review their
privacy notice to understand how they collect, use and share your
personal information, and how you can set your privacy preferences on
their sites and apps.
8. IS YOUR
INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may
transfer, store, and process your information in countries other than
your own.
Our servers are
located in [Countries where Server is Located]. If you are accessing
our Services from outside [Countries where Server is Located], please
be aware that your information may be transferred to, stored, and
processed by us in our facilities and by those third parties with
whom we may share your personal information (see “WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in [Countries
where Third-Party Servers are Located], and other countries.
If you are a
resident in the European Economic Area (EEA) or United Kingdom (UK),
then these countries may not necessarily have data protection laws or
other similar laws as comprehensive as those in your country.
However, we will take all necessary measures to protect your personal
information in accordance with this privacy notice and applicable
law.
European
Commission’s Standard Contractual Clauses:
We have implemented
measures to protect your personal information, including by using the
European Commission’s Standard Contractual Clauses for transfers of
personal information between our group companies and between us and
our third-party providers. These clauses require all recipients to
protect all personal information that they process originating from
the EEA or UK in accordance with European data protection laws and
regulations. Our Data Processing Agreements that include Standard
Contractual Clauses are available here: [Standard Contractual Clauses
URL]. We have implemented similar appropriate safeguards with our
third-party service providers and partners and further details can be
provided upon request.
Binding Corporate
Rules:
These include a set
of Binding Corporate Rules (“BCRs”) established and implemented
by FIRST CLASS RADIO INC. Our BCRs have been recognized by EEA and UK
data protection authorities as providing an adequate level of
protection to the personal information we process internationally.
You can find a copy of our BCRs here: [BCRs URL].
[EU-US] and
[Swiss-US] Privacy Shield Framework[s]
FIRST CLASS RADIO
INC and the following entities and subsidiaries: [List of
Entities/Subsidiaries] comply with the [EU-US] and [Swiss-US] Privacy
Shield Framework[s] as set forth by the US Department of Commerce
regarding the collection, use, and retention of personal information
transferred from [the European Union (EU)], [the UK], and
[Switzerland] to the United States. Although Privacy Shield is no
longer considered a valid transfer mechanism for the purposes of [EU]
and [Swiss] data protection law, in light of the judgment of the
Court of Justice of the European Union in Case C-311/18 and opinion
of the Federal Data Protection and Information Commissioner of
Switzerland dated 8 September 2020, FIRST CLASS RADIO INC will
continue to comply with the principles of the [EU-US] and [Swiss-US]
Privacy Shield Framework[s]. To learn more about the Privacy Shield
program, please visit www.privacyshield.gov. To view our
certification, please visit [Privacy Shield Certification URL].
FIRST CLASS RADIO
INC adheres to and complies with the Privacy Shield Principles when
processing personal information from [the EU], [UK], or
[Switzerland]. If we have received your personal information in the
United States and subsequently transfer that information to a third
party acting as our agent, and such third party agent processes your
personal information in a manner inconsistent with the Privacy Shield
Principles, we will remain liable unless we can prove we are not
responsible for the event giving rise to the damage.
With respect to
personal information received or transferred pursuant to the Privacy
Shield Framework[s], FIRST CLASS RADIO INC is subject to the
investigatory and enforcement powers of the US Federal Trade
Commission (“FTC”). In certain situations, we may be required to
disclose personal information in response to lawful requests by
public authorities, including to meet national security or law
enforcement requirements.
If you have any
questions or concerns relating to FIRST CLASS RADIO INC’s Privacy
Shield certification, please write to us at the contact details
below. We commit to resolving any complaints or disputes about our
collection and use of your personal information under the Privacy
Shield. [However, if you have an unresolved complaint in connection
with our certification, we commit to cooperating with the panel
established by [the EU data protection authorities (DPAs)], [the UK
Information Commissioner], and [the Swiss Federal Data Protection and
Information Commissioner], as applicable, and to comply with the
advice given by them in respect of the complaint. Click here for a
list of EU DPAs. / However, if you have an unresolved complaint in
connection with our certification, you may contact our independent
dispute resolution provider based in the [EU/United States], [Dispute
Resolution Provider Name]. Please visit [Dispute Resolution Provider
URL] for more information or to file a complaint. These services are
provided to you free of charge.]
In limited
situations, [EU], [UK], and [Swiss] individuals may seek redress from
the Privacy Shield Panel, a binding arbitration mechanism.
Please be sure to
review the following sections of this Privacy Notice for additional
details relevant to FIRST CLASS RADIO INC’s participation in the
[EU-US] and [Swiss-US] Privacy Shield:
WHAT INFORMATION DO
WE COLLECT? To learn more about the types of personal data FIRST
CLASS RADIO INC collects.
HOW DO WE PROCESS
YOUR INFORMATION? To learn more about the purposes for which FIRST
CLASS RADIO INC collects and uses personal information about you.
WHEN AND WITH WHOM
DO WE SHARE YOUR PERSONAL INFORMATION? To learn more about the type
or identity of third parties to which FIRST CLASS RADIO INC discloses
personal information, and the purposes for which we do so.
WHAT ARE YOUR
PRIVACY RIGHTS? To learn more about the right of individuals to
access their personal data.
9. HOW LONG DO WE
KEEP YOUR INFORMATION?
In Short: We keep
your information for as long as necessary to fulfill the purposes
outlined in this privacy notice unless otherwise required by law.
We will only keep
your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention
period is required or permitted by law (such as tax, accounting, or
other legal requirements). No purpose in this notice will require us
keeping your personal information for longer than [the period of time
in which users have an account with us / [#] months past the
termination of the user’s account / [#] months past the start of
the idle period of the user’s account / other].
When we have no
ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or,
if this is not possible (for example, because your personal
information has been stored in backup archives), then we will
securely store your personal information and isolate it from any
further processing until deletion is possible.
10. HOW DO WE KEEP
YOUR INFORMATION SAFE?
In Short: We aim to
protect your personal information through a system of organizational
and technical security measures.
We have implemented
appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information
we process. However, despite our safeguards and efforts to secure
your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure,
so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal
information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services
within a secure environment.
11. DO WE COLLECT
INFORMATION FROM MINORS?
In Short: We do not
knowingly collect data from or market to children under 18 years of
age.
We do not knowingly
solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that
you are the parent or guardian of such a minor and consent to such
minor dependent’s use of the Services. If we learn that personal
information from users less than 18 years of age has been collected,
we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of
any data we may have collected from children under age 18, please
contact us at info@firstclassradio.com.
12. WHAT ARE YOUR
PRIVACY RIGHTS?
In Short: In some
regions, such as the European Economic Area (EEA), United Kingdom
(UK), and Canada, you have rights that allow you greater access to
and control over your personal information. You may review, change,
or terminate your account at any time.
In some regions
(like the EEA, UK, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii)
to request rectification or erasure; (iii) to restrict the processing
of your personal information; and (iv) if applicable, to data
portability. In certain circumstances, you may also have the right to
object to the processing of your personal information. You can make
such a request by contacting us by using the contact details provided
in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will consider and
act upon any request in accordance with applicable data protection
laws.
If you are located
in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your
local data protection supervisory authority. You can find their
contact details here:
https://edpb.europa.eu/about-edpb/about-edpb/members_en.
If you are located
in Switzerland, the contact details for the data protection
authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your
consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on
the applicable law, you have the right to withdraw your consent at
any time. You can withdraw your consent at any time by contacting us
by using the contact details provided in the section “HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.
However, please note
that this will not affect the lawfulness of the processing before its
withdrawal, nor when applicable law allows, will it affect the
processing of your personal information conducted in reliance on
lawful processing grounds other than consent.
Opting out of
marketing and promotional communications: You can unsubscribe from
our marketing and promotional communications at any time by clicking
on the unsubscribe link in the emails that we send, replying “STOP”
or “UNSUBSCRIBE” to the SMS messages that we send, [Other] or by
contacting us using the details provided in the section “HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed
from the marketing lists — however, we may still communicate with
you, for example to send you service-related messages that are
necessary for the administration and use of your account, to respond
to service requests, or for other non-marketing purposes.
Account Information
If you would at any
time like to review or change the information in your account or
terminate your account, you can:
Log in to your
account settings and update your user account.
Contact us using the
contact information provided.
[Other]
Upon your request to
terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems,
assist with any investigations, enforce our legal terms and/or comply
with applicable legal requirements.
Cookies and similar
technologies: Most Web browsers are set to accept cookies by default.
If you prefer, you can usually choose to set your browser to remove
cookies and to reject cookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of our
Services.
If you have
questions or comments about your privacy rights, you may email us at
info@firstclassradio.com.
13. CONTROLS FOR
DO-NOT-TRACK FEATURES
Most web browsers
and some mobile operating systems and mobile applications include a
Do-Not-Track (“DNT”) feature or setting you can activate to
signal your privacy preference not to have data about your online
browsing activities monitored and collected. At this stage no uniform
technology standard for recognizing and implementing DNT signals has
been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your
choice not to be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform you about
that practice in a revised version of this privacy notice.
14. DO CALIFORNIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if
you are a resident of California, you are granted specific rights
regarding access to your personal information.
California Civil
Code Section 1798.83, also known as the “Shine The Light” law,
permits our users who are California residents to request and obtain
from us, once a year and free of charge, information about categories
of personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third
parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would
like to make such a request, please submit your request in writing to
us using the contact information provided below.
If you are under 18
years of age, reside in California, and have a registered account
with Services, you have the right to request removal of unwanted data
that you publicly post on the Services. To request removal of such
data, please contact us using the contact information provided below
and include the email address associated with your account and a
statement that you reside in California. We will make sure the data
is not publicly displayed on the Services, but please be aware that
the data may not be completely or comprehensively removed from all
our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code
of Regulations defines a “resident” as:
(1) every individual
who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual
who is domiciled in the State of California who is outside the State
of California for a temporary or transitory purpose
All other
individuals are defined as “non-residents.”
If this definition
of “resident” applies to you, we must adhere to certain rights
and obligations regarding your personal information.
What categories of
personal information do we collect?
We have collected
the following categories of personal information in the past twelve
(12) months:
Category Examples Collected
A.
Identifiers Contact details, such as real name, alias, postal
address, telephone or mobile contact number, unique personal
identifier, online identifier, Internet Protocol address, email
address, and account name [YES]
B. Personal
information categories listed in the California Customer Records
statute Name, contact information, education, employment, employment
history, and financial information [YES]
C. Protected
classification characteristics under California or federal law Gender
and date of birth [NO]
D. Commercial
information Transaction information, purchase history, financial
details, and payment information [YES]
E. Biometric
information Fingerprints and voiceprints [NO]
F. Internet or other
similar network activity Browsing history, search history, online
behavior, interest data, and interactions with our and other
websites, applications, systems, and advertisements [YES]
G. Geolocation
data Device location [YES]
H. Audio,
electronic, visual, thermal, olfactory, or similar information Images
and audio, video or call recordings created in connection with our
business activities [YES]
I. Professional or
employment-related information Business contact details in order to
provide you our services at a business level or job title, work
history, and professional qualifications if you apply for a job with
us [YES]
J. Education
Information Student records and directory information [NO]
K. Inferences drawn
from other personal information Inferences drawn from any of the
collected personal information listed above to create a profile or
summary about, for example, an individual’s preferences and
characteristics [YES]
L. Sensitive
personal information Account login information, drivers’ licenses,
health data, precise geolocation, racial or ethnic origin, religious
or philosophical beliefs, and sex life or sexual orientation [NO]
We will use and
retain the collected personal information as needed to provide the
Services or for a reasonable and lawful amount of time
We may also collect
other personal information outside of these categories instances
where you interact with us in person, online, or by phone or mail in
the context of:
Receiving help
through our customer support channels;
Participation in
customer surveys or contests; and
Facilitation in the
delivery of our Services and to respond to your inquiries.
How do we use and
share your personal information?
FIRST CLASS RADIO
INC collects and shares your personal information through:
Targeting
cookies/Marketing cookies
Social media cookies
Beacons/Pixels/Tags
Click redirects:
[Click Redirects]
Social media
plugins: [Social Media Plugins]. We use social media features, such
as a “Like” button, and widgets, such as a “Share” button in
our Services. Such features may process your Internet Protocol (IP)
address and track which page you are visiting on our website. We may
place a cookie to enable the feature to work correctly. If you are
logged in on a certain social media platform and you interact with a
widget or button belonging to that social media platform, this
information may be recorded to your profile of such social media
platform. To avoid this, you should log out from that social media
platform before accessing or using the Services. Social media
features and widgets may be hosted by a third party or hosted
directly on our Services. Your interactions with these features are
governed by the privacy notices of the companies that provide them.
By clicking on one of these buttons, you agree to the use of this
plugin and consequently the transfer of personal information to the
corresponding social media service. We have no control over the
essence and extent of these transmitted data or their additional
processing.
[You can opt out
from the selling or sharing of your personal information by disabling
cookies in Cookie Preference Settings and clicking on the Do Not Sell
or Share My Personal Information link on our homepage.]
You may contact us
by email at info@firstclassradio.com, by calling toll-free at
866-723-4605, by visiting www.firstclassradio.com/contactus, or by
referring to the contact details at the bottom of this document.
If you are using an
authorized agent to exercise your right to opt out we may deny a
request if the authorized agent does not submit proof that they have
been validly authorized to act on your behalf.
Will your
information be shared with anyone else?
We may disclose your
personal information with our service providers pursuant to a written
contract between us and each service provider. Each service provider
is a for-profit entity that processes the information on our behalf,
following the same strict privacy protection obligations mandated by
the CCPA.
We may use your
personal information for our own business purposes, such as for
undertaking internal research for technological development and
demonstration. This is not considered to be “selling” of your
personal information.
FIRST CLASS RADIO
INC has not sold or shared any personal information to third parties
for a business or commercial purpose in the preceding twelve (12)
months. / FIRST CLASS RADIO INC has sold or shared the following
categories of personal information to third parties in the preceding
twelve (12) months:
Category A.
Identifiers, such as contact details, like your real name, alias,
postal address, telephone or mobile contact number, unique personal
identifier, online identifier, Internet Protocol address, email
address, and account name.
Category B. Personal
information, as defined in the California Customer Records law, such
as your name, contact information, education, employment, employment
history, and financial information.
Category C.
Characteristics of protected classifications under California or
federal law, such as gender or date of birth.
Category D.
Commercial information, such as transaction information, purchase
history, financial details, and payment information.
Category E.
Biometric information, such as fingerprints and voiceprints.
Category F. Internet
or other electronic network activity information, such as browsing
history, search history, online behavior, interest data, and
interactions with our and other websites, applications, systems, and
advertisements.
Category G.
Geolocation data, such as device location.
Category H. Audio,
electronic, visual, and similar information, such as images and
audio, video or call recordings created in connection with our
business activities.
Category I.
Professional or employment-related information, such as business
contact details in order to provide you our services at a business
level or job title, work history, and professional qualifications if
you apply for a job with us.
Category J.
Education information, such as student records and directory
information.
Category K.
Inferences drawn from any of the personal information listed above to
create a profile or summary about, for example, an individual’s
preferences and characteristics.
Category L.
Sensitive personal information, such as account login information,
drivers’ licenses, health data, precise geolocation, racial or
ethnic origin, religious or philosophical beliefs, and sex life or
sexual orientation.
The categories of
third parties to whom we shared personal information with are:
Ad Networks
Affiliate Marketing
Programs
Data Analytics
Services
Retargeting
Platforms
Social Networks
User Account
Registration & Authentication Services
[Other]]
Your rights with
respect to your personal data
Right to request
deletion of the data — Request to delete
You can ask for the
deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your
personal information, subject to certain exceptions provided by law,
such as (but not limited to) the exercise by another consumer of his
or her right to free speech, our compliance requirements resulting
from a legal obligation, or any processing that may be required to
protect against illegal activities.
Right to be informed
— Request to know
Depending on the
circumstances, you have a right to know:
whether we collect
and use your personal information;
the categories of
personal information that we collect;
the purposes for
which the collected personal information is used;
whether we sell or
share personal information to third parties;
the categories of
personal information that we sold, shared, or disclosed for a
business purpose;
the categories of
third parties to whom the personal information was sold, shared, or
disclosed for a business purpose;
the business or
commercial purpose for collecting, sharing, or selling personal
information; and
the specific pieces
of personal information we collected about you.
In accordance with
applicable law, we are not obligated to provide or delete consumer
information that is de-identified in response to a consumer request
or to re-identify individual data to verify a consumer request.
Right to
Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not
discriminate against you if you exercise your privacy rights.
Right to Limit Use
and Disclosure of Sensitive Personal Information
We do not process
consumer’s sensitive personal information. / If the business
collects any of the following:
social security
information, drivers’ licenses, state ID cards, passport numbers
account login
information
credit card numbers,
financial account information, or credentials allowing access to such
accounts
precise geolocation
racial or ethnic
origin, religious or philosophical beliefs, union membership
the contents of
email and text, unless the business is the intended recipient of the
communication
genetic data,
biometric data, and health data
data concerning
sexual orientation and sex life
you have the right
to direct that business to limit its use of your sensitive personal
information to that use which is necessary to perform the Services.
Once a business
receives your request, they are no longer allowed to use or disclose
your sensitive personal information for any other purpose unless you
provide consent for the use or disclosure of sensitive personal
information for additional purposes.
Please note that
sensitive personal Information that is collected or processed without
the purpose of inferring characteristics about a consumer is not
covered by this right, as well as the publicly available information.
To exercise your
right to limit use and disclosure of sensitive personal Information,
please email info@firstclassradio.com.
Verification process
Upon receiving your
request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system.
These verification efforts require us to ask you to provide
information so that we can match it with information you have
previously provided us. For instance, depending on the type of
request you submit, we may ask you to provide certain information so
that we can match the information you provide with the information we
already have on file, or we may contact you through a communication
method (e.g., phone or email) that you have previously provided to
us. We may also use other verification methods as the circumstances
dictate.
We will only use
personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will
avoid requesting additional information from you for the purposes of
verification. However, if we cannot verify your identity from the
information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity
and for security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying you.
Other privacy rights
You may object to
the processing of your personal information.
You may request
correction of your personal data if it is incorrect or no longer
relevant, or ask to restrict the processing of the information.
You can designate an
authorized agent to make a request under the CCPA on your behalf. We
may deny a request from an authorized agent that does not submit
proof that they have been validly authorized to act on your behalf in
accordance with the CCPA.
[You may request to
opt out from future selling or sharing of your personal information
to third parties. Upon receiving an opt-out request, we will act upon
the request as soon as feasibly possible, but no later than fifteen
(15) days from the date of the request submission.]
To exercise these
rights, you can contact us by email at info@firstclassradio.com, by
calling toll-free at 866-723-4605, by visiting
www.firstclassradio.com/contactus, or by referring to the contact
details at the bottom of this document. If you have a complaint about
how we handle your data, we would like to hear from you.
Financial Incentives
“Financial
incentive” means a program, benefit, or other offering, including
payments to consumers as compensation, for the disclosure, deletion,
sharing, or sale of personal information.
The law permits
financial incentives or a price or service difference if it is
reasonably related to the value of the consumer’s data. A business
must be able to explain how the financial incentive or price or
service difference is reasonably related to the value of the
consumer’s data. The explanation must include:
a good-faith
estimate of the value of the consumer’s data that forms the basis
for offering the financial incentive or price or service difference;
and
a description of the
method the business used to calculate the value of the consumer’s
data.
We may decide to
offer a financial incentive (e.g., price or service difference) in
exchange for the retention, sale or sharing of a consumer’s
personal information.
If we decide to
offer a financial incentive, we will notify you of such financial
incentive and explain the price difference, as well as material terms
of the financial incentive or price of service difference, including
the categories of personal information that are implicated by the
financial incentive or price or service difference.
If you choose to
participate in the financial incentive you can withdraw from the
financial incentive at any time by emailing us at
info@firstclassradio.com, by calling us toll-free at 866-723-4605, by
visiting www.firstclassradio.com/contactus, or by referring to the
contact details at the bottom of this document.
Metrics
Our metrics for all
CCPA requests received for the previous calendar year can be found
here: [Metrics URL].
15. DO VIRGINIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if
you are a resident of Virginia, you may be granted specific rights
regarding access to and use of your personal information.
Virginia CDPA
Privacy Notice
Under the Virginia
Consumer Data Protection Act (CDPA):
“Consumer” means
a natural person who is a resident of the Commonwealth acting only in
an individual or household context. It does not include a natural
person acting in a commercial or employment context.
“Personal data”
means any information that is linked or reasonably linkable to an
identified or identifiable natural person. “Personal data” does
not include de-identified data or publicly available information.
“Sale of personal
data” means the exchange of personal data for monetary
consideration.
If this definition
of “consumer” applies to you, we must adhere to certain rights
and obligations regarding your personal data.
The information we
collect, use, and disclose about you will vary depending on how you
interact with FIRST CLASS RADIO INC and our Services. To find out
more, please visit the following sections above:
1. WHAT INFORMATION
DO WE COLLECT?
2. HOW DO WE PROCESS
YOUR INFORMATION?
4. WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Your rights with
respect to your personal data
Right to be informed
whether or not we are processing your personal data
Right to access your
personal data
Right to correct
inaccuracies in your personal data
Right to request
deletion of your personal data
Right to obtain a
copy of the personal data you previously shared with us
Right to opt out of
the processing of your personal data if it is used for targeted
advertising, the sale of personal data, or profiling in furtherance
of decisions that produce legal or similarly significant effects
([“profiling”/’profiling’])
[FIRST CLASS RADIO
INC has not sold any personal data to third parties for business or
commercial purposes. FIRST CLASS RADIO INC will not sell personal
data in the future belonging to website visitors, users, and other
consumers. Please see the following section to find out how you can
opt out from further selling or sharing of your personal data for
targeted advertising or profiling purposes.]
Exercise your rights
provided under the Virginia CDPA
[You can opt out
from the selling of your personal data, targeted advertising, or
profiling by disabling cookies in Cookie Preference Settings.]
You may contact us
by email at info@firstclassradio.com, by visiting
www.firstclassradio.com/contactus, or by referring to the contact
details at the bottom of this document.
If you are using an
authorized agent to exercise your rights, we may deny a request if
the authorized agent does not submit proof that they have been
validly authorized to act on your behalf.
Verification process
We may request that
you provide additional information reasonably necessary to verify you
and your consumer’s request. If you submit the request through an
authorized agent, we may need to collect additional information to
verify your identity before processing your request.
Upon receiving your
request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt. The response period may be
extended once by forty-five (45) additional days when reasonably
necessary. We will inform you of any such extension within the
initial 45-day response period, together with the reason for the
extension.
Right to appeal
If we decline to
take action regarding your request, we will inform you of our
decision and reasoning behind it. If you wish to appeal our decision,
please email us at info@firstclassradio.com. Within sixty (60) days
of receipt of an appeal, we will inform you in writing of any action
taken or not taken in response to the appeal, including a written
explanation of the reasons for the decisions. If your appeal is
denied, you may contact the Attorney General to submit a complaint.
16. DO WE MAKE
UPDATES TO THIS NOTICE?
In Short: Yes, we
will update this notice as necessary to stay compliant with relevant
laws.
We may update this
privacy notice from time to time. The updated version will be
indicated by an updated “Revised” date and the updated version
will be effective as soon as it is accessible. If we make material
changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending
you a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
17. HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?
If you have
questions or comments about this notice, you may contact our Data
Protection Officer (DPO), by email at info@firstclassradio.com, by
phone at 866-723-4605, or by post to:
FIRST CLASS RADIO
INC
DPO Admin
3316 #2 W. Chain Of
Rocks Rd.
Granite City, IL
62040
USA
If you have any
further questions or comments, you may also contact us by post at the
following corporate address:
FIRST CLASS RADIO
INC
3316 #2 W. Chain Of
Rocks Rd.
Granite City, IL
62040
USA
Phone: 866-723-4605
18. HOW CAN YOU
REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the
applicable laws of your country, you may have the right to request
access to the personal information we collect from you, change that
information, or delete it in some circumstances. To request to
review, update, or delete your personal information, please email us
at info@firstclassradio.com