Privacy Policy
September 21, 2023
Chavez Radio Group and our affiliates and subsidiaries (collectively “CRG”, “we”, “us”, or “our”) are committed to maintaining your confidence and trust as it relates to the privacy of your information. This Privacy Policy describes how we collect, protect, share and use your information, both offline and online, including as part of our websites, interactive features, and Apps (collectively, “Platforms”), and your rights and choices in connection your information. If you are an employee, contractor, or job applicant, your personal information collected in those contexts will be subject to a separate privacy notice that we provide to you where and when appropriate.
QUICK GUIDE TO CONTENTS
- WHAT INFORMATION WE COLLECT
- HOW WE USE INFORMATION
- WE COLLECT INFORMATION FROM VARIOUS SOURCES
- WE SHARE INFORMATION WITH OTHERS
- SESSION REPLAY TECHNOLOGY
- YOUR CHOICES
- YOUR PRIVACY RIGHTS
- ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES
- PERSONAL INFORMATION RETENTION
- CHILDREN
- SECURITY OF YOUR INFORMATION
- OTHER SITES
- UNITED STATES ONLY
- CHANGES
- CONTACT US
- WHAT INFORMATION WE COLLECT
We (and the vendors we hire to perform business functions on our behalf) and third parties who have integrated their technologies into our platforms and services may collect, receive, and develop several categories of personal information about you depending on the nature of your interactions with us:
Identifiers: We may collect your name, e-mail address, telephone number, mobile phone number, mailing address, date of birth, social media account handles or usernames, and CRG account usernames and passwords. You may create a personal CRG account by enabling this feature through the settings in the Apps; the CRG account is connected to a unique identifier that ties back
to your CRG account and the information associated with your account. We may collect your digital signature in certain circumstances.
Demographic and Protected Classification Information: We may collect your zip code, age, gender, language preferences, marital status, and political affiliation. Some of this is considered sensitive personal information, as described more fully below.
Purchase and Preference Information: We may collect information about the artists, stations, podcasts, playlists, and genres you are interested in; content you purchase, access, or download; records of your transactions and subscription purchases; and records of contests you enter.
Internet Browser, Usage, and Device Information: We use tracking tools like cookies and pixels to automatically collect information about your interactions with our Platforms, such as your IP address and other unique identifiers for the computer, mobile device, tablet or other device you use to connect (“Device”), including the hardware model and mobile network information. We collect information about your use of the Platforms, including your browser type; operating system; activations; listening times; what areas of the Platforms you access and for how long; search terms you enter; how long you stay on a page; which hyperlinks and content or advertisements you click on; which songs, playlists, audiovisual content and other CRG users you interact with; and the page served and preceding page views. If you use our Apps, we may also look at how often you use the Apps and where you downloaded it. We may collect information about your views, clicks, and interactions with our digital content and advertisements (both on and off the Platforms), as well as our promotional emails. If you create an account using your credentials from a third-party social media site, we will have access to certain information from that site, as described further below.
Location Information: If you choose to turn on your Bluetooth, Wi-Fi or other geolocation functionality when you use the Apps, subject to your consent, we may collect general location information about your Device when you access or use the Platforms (but not your precise geolocation within the ranges defined by applicable laws unless we obtain a separate consent from you).
Voice Data: If you enable voice control features for one of our products on your device, we may collect audio recordings and transcripts of what you say when you interact with one of our voice features. For example, you may be able to use your voice to interact with select audio advertisements or to search, select, and listen to music.
Professional Information: If you interact with us on behalf of business customers, vendors, or other companies, in addition to other information described in this notice, we may also collect items like your job title, office location, compensation or payments, and engagement history with us.
Audio, Electronic, and Visual Information: If you choose to submit voice recordings, photos or videos to the Platform, we will collect that information.
Sensitive Personal Information: We may collect your social security number if you are the winner of a promotion or contest. We will collect your payment card details when you make a purchase. In addition to the above, if you interact with us on behalf of business customers, vendors, or other
companies, we may also collect your driver’s license number, background check information, and social security number if relevant to our relationship with you.
Inferences: Using the other pieces of personal information collected about you, we draw inferences about you, reflecting what we believe to be your interests, characteristics, predispositions, and attitudes.
- HOW WE USE INFORMATION
We may use personal information (including sensitive personal information) for the following purposes:
- To respond to your questions and requests;
- To provide customer service;
- To provide you with access to certain areas and features of the Platforms, such as your favorite stations, your musical preferences, voice control functionality, songs you have listened to, shared playlists and your interaction with other users;
- To communicate with you about your account and activities on the Platforms, such as changes to any CRG policy;
- To administer the Platforms; help diagnose problems with our servers; and facilitate site navigation;
- To conduct Platform analytics and operations and to analyze trends;
- To provide and administer contests, events, and other promotions;
- For market research;
- To improve the Platforms and keep our Platforms fresh and interesting to our visitors;
- To track the effectiveness of our advertising (such as measuring how many people view or click an ad) and for advertising attribution, analytics and reporting;
- To personalize your CRG experience, such as:
- To curate and suggest songs and other content that match your interests; this may include suggesting personalized or localized radio stations, or providing specific features on the Platforms; and
- To serve or display ads and offers (both on and off the Platforms) that are more likely to be relevant to you; these may be for our own products and services, or for products and services offered by our partners and other brands or advertisers (who may pay us to show you such content);
- To send you (either directly or through one of our partners) marketing and promotional messages;
- To pay artists and record labels for tracks you hear;
- To associate you with your account or activities on social networking sites and, if you so choose, to enable interaction and data sharing between your activities on the Platforms and your activities on such social networking sites;
- For security and safety purposes, such as protecting against cyber threats; protecting our rights and the rights of our customers and subscribers; detecting, investigating, or preventing fraud and other illegal activities; and responding to legal and regulatory compliance obligations;
- To comply with our license obligations;
- To verify your identity;
In the case of business contacts, to administer and manage our relationship with you and your employer (such as record keeping, payments, communicating with you, tracking outcomes, and verifying your eligibility and suitability).
For other lawful purposes disclosed at the time we collect your information or otherwise with your consent.
- WE COLLECT INFORMATION FROM VARIOUS SOURCES
Directly from you: We collect personal information directly from you when you use the Platforms, for example to register to create an account, update your information, sign up for a subscription, use certain features, complete a profile, tell us about your preferences, access or download content, purchase items or enter into promotions, post content to the Platforms, refer others to the Platforms, interact with us via third party applications or social media sites, request customer support, or otherwise communicate with us. We collect personal information when you create an CRG account. If you are a business contact, we also collect personal information directly from you when we communicate with you, onboard you, or provide/receive products or services to/from you.
Automatically from your devices: We, as well as advertisers and/or service providers, may use a variety of tracking tools and technologies that automatically or passively collect information like browser/usage/device information and location information any time you visit or interact with the Platforms, our emails, and our advertising and content on other websites and platforms.
From our vendors and service providers: We receive personal information about you from our vendors and service providers we hire to help us run our business, including those companies that host, protect, or operate our Platforms; analyze data; collect debts for us; 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.
From our business partners and data providers: We receive personal information about you from our business partners, including those businesses with whom we offer joint or co-branded promotions, or who advertise on the Platforms. We may also get personal information from advertising networks and search information providers.
From social media: If you create an account using your credentials from a social media site, we will have access to certain information from that site. Services like Facebook Connect give you the option to post information about your activities on our Platforms to your profile page to share with others within your network. In addition, we may receive information about you if other users of a social media application or website give us access to their profiles and you are one of their “connections” or
if information about you is otherwise accessible through your “connections'” web page, profile page, or similar page on a social networking or other third party website or interactive service.
From other users: Other users may decide to provide us with your personal information (such as Identifiers) so that we may invite you to join CRG or so that we may facilitate communication between users of the Platforms. If you are a business contact, we also collect information from other individuals within your organization or from referring parties at different organizations.
We combine information: When we get information from other sources, we may combine that with information we already have. We may combine information that we have collected offline with information we collect online or through the Platforms. We may also aggregate your information with other consumers’ information to understand preferences and trends within your peer group over time.
4. WE SHARE INFORMATION WITH OTHERS
We may share personal information (including sensitive personal information) as described below:
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 CRG to stream on the Platforms (e.g., artists or record labels). If you connect your CRG account to a third party application or social media platform, CRG may automatically share your personal information with that service, and such information may be attributed to your account on the third party platform and published on such service. Likewise, if you log into a third party application with your CRG account, that third party application may have access to certain information such as your CRG playlists and activity. Some transfers of your personal information to these other companies may be viewed as a “sale” under certain state laws.
With other users: CRG is a social service that offers many ways to find, enjoy, and share content. Your name and/or username, profile picture, who you follow, your followers, and your CRG user profile are publicly available to other subscribers. Your activity on the Platform (e.g., music you listen to, music you share), playlists created or followed, and content you post to the Platform are made publicly available by default and can be accessed by users who follow you or view your CRG profile and will also be displayed publicly in third-party search engine results and may appear together with other public profile information, such as your playlists, picture and name and/or username. This information is made public by default, but you can limit this sharing as described in the “Your
Choices” section below.
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 mobile apps.
For legal compliance: We may share personal information with third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of other parties, visitors to our Platforms, or the public.
Other disclosures: We may share personal information for other reasons we may describe to you from time to time as permitted by law, such as in response to your selection to share a playlist with other users on the Platform.
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.
- SESSION REPLAY TECHNOLOGY
We use session recording and replay technology to observe your mouse movements, scrolling, and clicks on our websites and mobile apps. We use these tracking tools for support and analytics purposes, and to better understand how people engage with our sites and apps. This information is often collected and processed by our service providers who we have engaged to analyze this information on our behalf. By using our websites and mobile apps, you consent to our (or our service provider’s) collection, use, and retention of this information using session replay technology.
- YOUR CHOICES
Cookies:
To learn how you can reject or delete cookies from us or other companies, please refer to your browser’s help menu. If you disable or opt out of receiving cookies, please be aware that some features and services on our Platform may not work properly because we may not be able to recognize and associate you with your account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
To learn how to change your device identifier or mobile advertising ID, please refer to your device’s help menu or other instructions.
Interest-Based Advertising:
When you use the Platforms, we, our service providers, and advertising partners may place cookies and similar tracking technologies on your computer or Device in order to collect information about your online web-browsing activities over time and across different websites and online services or mobile applications, in order to serve you ads or other content personalized to your interests. This form of advertising is referred to as Interest Based Advertising (“IBA”). In order to personalize these ads or content, we or our advertising partners or service providers may connect and/or share personal information about you either to data you provided to us or to browser/usage/device information and location information collected about you.
Choices you make are device-specific and browser-specific. If you use different browsers on your computer, or multiple computers and Devices, you will need to opt out of IBA from each browser on each of the computers and Devices that you use. Please note that even if you opt out of IBA, you may still receive advertisements from us; they just won’t be customized based on your web-browsing activities on third-party websites. Please also note that if you opt-out of IBA, we may still track your visits to the Platforms for our own analytics, operations and security purposes.
Do Not Track:
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our systems are not configured to recognize Do Not Track headers or signals from some or all browsers.
Marketing Communications:
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 note that if you opt out of receiving promotional communications, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Location Information:
We may infer your general location using your IP address. We will not collect more precise location information without your prior consent. You can stop the collection of general location information at any time by going to the setting feature on your Device and changing your preferences. If you do so, certain features of our Apps may no longer function as intended. You also may also uninstall or remove our Apps from your Device.
Voice Data:
Voice control features will only be enabled if you affirmatively activate voice controls by giving us access to the microphone on your device. You can disable our access to your voice data by turning off our access to your microphone on your device at any time by using the operating system settings on your device or by muting your microphone.
Push Notifications:
If you use our Apps, we may send you push notifications from time to time. If you no longer wish to receive push notifications, you can turn them off at the device level in your App settings.
- YOUR PRIVACY RIGHTS
Where provided for by applicable privacy laws, you may be entitled to exercise some or all of the rights described below with respect to your personal information:
Access / Right to Know: You have the right to confirm whether we process personal information about you and to request that we disclose to you the following: (i) the categories of personal information that we have collected about you (including sensitive personal information); (ii) the categories of sources from which we have collected personal information about you; (iii) the business or commercial purpose for collecting or selling your personal information; (iv) the categories of personal information that we have sold about you and the categories of outside parties to whom the personal information was sold; (v) the categories of personal information that we have disclosed about you for our business purposes and the categories of suppliers to whom the personal information was disclosed; (vi) a portable copy of the specific pieces of personal information that we have collected about you; and (vii) information about the logic involved in any automated decision-making processes used by CRG (if applicable), as well as a description of the likely outcome of the process with respect
to you.
Deletion: You can request that we delete the personal information that we maintain about you, subject to certain exceptions.
Do Not Sell My Personal Information or Share my Personal Information for Behavioral Advertising: You can opt-out of the sale of your personal information and the sharing of your personal information for cross-context behavioral advertising by clicking the “Do Not Sell or Share My Personal Information” link in the footer of this webpage. If you would like to opt out of cookie-based tracking for advertising purposes (which could be a “sale” or “sharing” under applicable law), you will need to update your cookie preferences on this webpage or through the “Do Not Sell or Share My Personal Information” link in the footer of this page. Your cookie selections are specific to the device, website, and browser you are using. Your selections are deleted whenever you clear your cookies or browser’s cache.
Correct or Update my Personal Information: You have the right to request that we correct, update, or modify the personal information we maintain about you. If you have an account, you can also update your profile information any time by visiting the account settings page within your account.
Opt-out of Automated Decision-Making: You have the right to request to opt-out of any profiling or automated decision-making, to the extent we engage in those processing activities.
Limit the Use of my Sensitive Personal Information: In relation to the sensitive personal information identified in Section 1 above, you may be able to request that we limit our use and sharing of such information to those purposes specified under applicable privacy laws. Note that we only use and share your sensitive personal information for the purpose of providing our goods, subscriptions, and services that you’ve requested or purchased, maintaining the quality of our services and Platform, or protecting our services and Platform against illegal activity.
You will not to be discriminated against for exercising these rights. We will not deny you any products or services, nor charge you different prices, in retaliation for exercising your privacy rights.
We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. As noted earlier, if you are an employee, contractor, or job applicant, your rights with respect to your personal information collected in those contexts will be described in a separate privacy notice that we provide to you where and when appropriate.
Eligible individuals can request to exercise these rights by submitting a written request at the following address:
Attn: Privacy
1440 E. Washington Street, Suite 300
Phoenix, Arizona 85034
- ADDITIONAL CALIFORNIA PRIVACY DISCLOSURES
For purposes of California law, please note the following:
We collect and use the following categories of personal information for the business and commercial purposes described in this Privacy Policy: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); characteristics of protected classifications under California or federal law; commercial information; audio (voice) information and visual information; internet or other electronic network activity information; geolocation data; professional information; sensitive personal information; and inferences.
We use the above described categories of personal information for our business and commercial purposes described in Section 2 above.
We collect these categories of personal information from the following categories of sources, as more fully described in Section 3 above: directly from you; automatically from your devices; from our service providers; from social media; from our business partners; from other users; and from our corporate affiliates, subsidiaries, and/or parents.
We disclose each of the foregoing categories of personal information to our affiliates, service providers, business partners, advertisers who advertise on our Platform, advertising networks, data analytics providers, social networks, other Platform users, with entities for legal compliance purposes, and with potential acquirers of parts of our business. See Section 4 above for more details.
We may “sell” or “share” the following categories of personal information: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; Internet or other electronic network activity; geolocation data; and inferences. We sell and share this personal information with advertisers, advertising networks, and social networks. We do not knowingly sell or share the personal information of consumers under 16 years of age.
We do not use or disclose sensitive personal information for purposes other than those specified under applicable California privacy regulations.
- PERSONAL INFORMATION RETENTION
We will only retain your personal information (including your sensitive personal information) for as long as is reasonably necessary for the purpose for which the information was collected, or as legally required. We will not hold or process your personal information for any longer than we are legally permitted to. The criteria used to determine the appropriate retention period includes:
Regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting, and securities
Whether a legal claim might be brought against us, for which the information would be relevant.
The necessity of the information to provide our services to our customers
The types and sensitivity of personal information being processed
- CHILDREN
The Platform is not directed to children under 13. We do not knowingly collect, use or disclose personal information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her personal information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
11. SECURITY OF YOUR INFORMATION
We use certain reasonable security measures designed to help protect your personal information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. 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.
- OTHER SITES
The Platforms may contain links to other sites that we do not own or operate. This includes links from service providers, advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse, and are not responsible for, these sites or their content, products, services or privacy policies or practices. These other websites may send their own cookies to your Device, they may independently collect data or solicit personal Information, and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms (including those linked to through an email or social networking page).
The Platforms may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Privacy Policy.
13. UNITED STATES ONLY
The Platforms are governed by and operated in, and in accordance with the laws of, the United States, and are intended only for the enjoyment of residents of the United States. CRG makes no representation that the Platforms are governed by or operated in accordance with the laws of any other nation.
- CHANGES
Any changes we may make to our Privacy Policy will be posted on this page and/or communicated to you in other ways if required by law. Please check back frequently to see any updates or changes to our Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use the Platform.
- CONTACT US
If you have any questions or concerns about this Privacy Policy, the practices of the Platforms, or your experiences with the Platforms, please contact us at:
CRG
Attn: Privacy
1440 E. Washington Street, Suite 300
Phoenix, Arizona 85034