Spanish Broadcasting System, Inc

Global Internet Privacy Policy

Effective Date: March 16th 2020

Spanish Broadcasting System, Inc. and its subsidiaries (“SBS”) respect your right to privacy. This policy summarizes what personally identifiable information we may collect, and how we might use this information. This policy also describes other important topics relating to your privacy.

SBS Global Internet Privacy Policy

It is SBS’ policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our employees, customers, business partners and others who share their personal information with us.

This Global Internet Privacy Policy (this “Policy”) describes how SBS protects your privacy when we collect personal information on SBS Internet sites. As used in this Policy, the term “personal information” means information that identifies you personally, alone or in combination with other information available to us.

This Policy applies, in general, to all Internet sites operated by or on behalf of SBS and its business units, including but not limited to radio, television and music Internet sites (each an “SBS Internet Site”). It applies to our current information collection, use, and sharing practices, as well as those in place for the last 12 months.

Web Site Privacy Statements

Although this Policy applies to all SBS Internet Sites generally, each SBS Internet Site has a different purpose and different features. If additional or different disclosures are required with respect to a specific SBS Internet Site, we will provide those disclosures on the site itself or in a separate web site privacy statement (“Web Site Privacy Statement”) posted on that site. Each individual disclosure or Web Site Privacy Statement supplements and amends this Policy, but only with respect to the SBS Internet Site on which it is posted.

Your Consent

By using an SBS Internet Site or providing personal information to us, you are consenting to the collection, use and disclosure of your personal information as described in this Policy and any applicable Web Site Privacy Statements.

If you do not consent to the collection, use and disclosure of your personal information as described in this Policy (and any applicable Web Site Privacy Statements), do not use SBS Internet Sites.

Limitations on the Collection, Use and Disclosure of Personal Information

To the extent required by applicable law, whenever SBS collects personal information on an SBS Internet Site, SBS will:

  • provide timely and appropriate notice to you about its data practices;
  • collect, use, disclose and transfer your personal information only with your consent, which may be express or implied, depending on the sensitivity of the personal information, legal requirements, and other factors;
  • collect your personal information only for specific, limited purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
  • process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
  • take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
  • not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”; and
  • take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within SBS.
Information Collected on SBS Internet Sites

When you access and use an SBS Internet Site, we collect the following categories of information about you:

SBS collects information you knowingly and voluntarily provide when you use an SBS Internet Site, for example, the information you provide when you sign up to receive email alerts, when you complete a survey, or when you ask us a question or email us with feedback. Specifically, SBS collects:

  • Identifiers such as your name and your username/password if you register on an SBS Internet Site;
  • Contact information such as your email address, physical mailing address, and telephone number(s); and
  • Payment information such as your credit card number, card expiration date, and CVV.

SBS also collects Internet and other electronic network activity information that is sent to us automatically by your web browser. This information typically includes the IP address of your Internet service provider, the name of your operating system (such as Macintosh® or Windows®) and the name and version of your browser (such as Internet Explorer®, Firefox® or Netscape®). The information we receive depends on the settings on your web browser. Please check your browser if you want to learn what information your browser sends or how to change your settings.

Cookies

Internet and other electronic network activity information is sometimes collected by placing a “Cookie” on your computer

SBS may obtain information about you by installing a “tag” on your computer’s hard drive. This tag is known as a “cookie.”

All of our SBS Internet Sites use “session cookies.” A session cookie is used to tag your computer with a computer-generated, unique identifier when you access our site. A session cookie does not identify you personally and expires after you close your browser. We use session cookies to collect statistical information about the ways visitors use our sites – which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “clickstream data”) in statistical form to better understand our visitors’ interests and needs to improve the content and functionality of our sites.

Some SBS Internet sites also use “persistent cookies.” These cookies do not expire when you close your browser; they stay on your computer until you delete them. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences and in situations where these choices or preferences need to be collected again, they can be provided by us automatically, saving you time and effort. For example, after you make a purchase, if you decide to make another purchase, your shipping address will have been retained and will only need to be confirmed. If an SBS Internet Site uses “persistent cookies” we will notify you in the Privacy Statement posted on that site.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit an SBS Internet Site, you may be unable to use all of the functionality of the site if your browser rejects our cookies.

Use of Information

Many of the SBS Internet Sites permit you to make choices about the use of your personal information. In most cases, we ask you to indicate your choices at the time and on the page where you provide your personal information.

  • Identifiers will be used to:
    • authenticate you as a registered user,
    • communicate with you directly; and
    • prevent fraud;
  • Contact information will be used to:
    • communicate directly with you about a product or service that you have requested;
    • contact you in response to a customer service request, or respond to other inquiries, questions or requests that you make;
    • provide you with promotional materials that we think may be of interest to you; and
    • engage in market research; and
  • Payment information will be used to:
    • process payment in such a way to allow you to purchase goods or services through an SBS Internet Site; and
    • process refunds as appropriate.

The Internet and other electronic network activity information provided by your browser does not identify you personally. We use this information to create statistics that help us improve our sites and make them more compatible with the technology used by our Internet visitors.

We may use Aggregate or Deidentified information for historical, statistical or scientific purposes. “Aggregate” means information that relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device. “Deidentified” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer.

Sharing Personal Information

Many of our SBS Internet Sites permit you to make choices about the disclosure and/or transfer of your personal information. In most cases, we ask you to indicate your choices at the time and on the page where you provide your personal information.

SBS shares your personal information with:

  • Other SBS business units. When provide Identifiers and Contact information to other SBS business units, those other units will use your information in a manner consistent with the purposes for which it was originally collected (or to which you subsequently consented) and only as permitted under this Policy, any applicable Web Site Privacy Statements, and all applicable privacy and data protection laws.
  • Third Parties. We partner with or hire third party service providers to perform support services for us. These third parties are required to use the personal information we share with them in a manner consistent with the purposes for which it was originally collected (or to which you subsequently consented) and only as permitted under this Policy, any applicable Web Site Privacy Statements, and all applicable privacy and data protection laws. Specifically, we share:
    • Your Payment information with third party payment processors who assist us in processing payment for goods and services;
    • Your Internet and other electronic network activity information with advertisers, for purposes of serving you with customized promotions. If you would like to learn more about the sharing of Internet and other electronic network activity information for purposes of providing customized advertisements or promotions, please visit http://www.aboutads.info/consumers/;
    • Your Internet and other electronic network activity information with third party analytics providers, who assist us with analyzing how individuals browse and use the SBS Internet Sites so that we can improve the SBS Internet Sites.
  • Law Enforcement. We will provide Identifiers, Contact information, and/or Internet and other electronic network activity information to comply with a legal requirement or court order; and/or to investigate a possible crime, such as identity theft.
  • Successor Company. We will provide Identifiers, Contact information, and/or Internet and other electronic network activity information to a successor company in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of SBS or a SBS business unit.

SBS will not sell personal information collected from its Internet sites to mailing list brokers without your express consent.

Security of Personal Information

Your personal information will generally be stored in SBS databases or databases maintained by our service providers. Most of these databases are stored on servers located in the United States. To the extent required by law, if your personal information will be transferred outside your country an appropriate notice will be provided.

SBS maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. For example, we use secure socket layer (SSL) technology to transfer personal information over the Internet. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.

Links to Third Party Internet Sites

SBS Internet Sites may contain links to Internet sites that are not operated by SBS. These links are provided as a service and do not imply any endorsement of the activities or content of these sites, nor any association with their operators. SBS does not control these Internet sites and is not responsible for their content, security, or privacy practices. We urge you to review the privacy policy posted on web sites you visit before using the site or providing personal information.

California Privacy Rights

If you are a California resident, you have the following rights.

Right of Access. You have the right to access your personal information maintained by us. Upon receipt of a verifiable request to access personal information, we will disclose and deliver, free of charge, the personal information requested.

Please note that we are not required to provide personal information to you more than twice in a 12-month period.

Right of Deletion. You have the right to request that we delete any personal information about you which we have collected from you. Upon receipt of a verifiable request for deletion, we will delete your personal information from our records and direct any service providers to delete your personal information from our records, within 45 days.

We will comply with your request to delete personal information unless it is necessary for us to maintain your personal information in order to:

  • Complete a transaction, provide requested-for goods/services, and/or perform a contract between you and us;
  • Detect security incidents;
  • Comply with a legal obligation;
  • Enable our internal uses that are aligned with your expectations and your relationship with us.

Submission of Requests for Information. We have designated the following methods for California residents to submit requests for information:

  • By calling us at 305-441-6901
  • By emailing us at support@lamusica.com or
  • By following this to a webform to complete and submit your request.

Verification. After you submit a request, we will promptly take steps to determine whether your request is a verifiable request. We will verify that you are who you say you are by asking you provide unique (non-sensitive) information related to your interaction with us, including

We will disclose and deliver the required information to you free of charge within 45 days of receiving your verifiable request. If necessary, we will extend the time period to provide the required information once by an additional 45 days, and will provide you with notice of the extension within the first 45-day period. The disclosure shall cover the 12-month period preceding our receipt of the verifiable request.

As noted below, we do not knowingly collect information from or about children, including children aged 16 and under. We do not sell information of minors under 16 years of age.

Authorized Agent. You have the right to designate an authorized agent to submit an access or deletion request on your behalf. If you use an authorized agent to submit such a request, we will require that you:

  • Provide the authorized agent written permission  to act on your behalf; and
  • Verify your own identity with us before we can honor the request.

We have not directly sold personal information to third parties for a business or commercial purpose in the last 12 months. We use Internet and other electronic network activity information to provide us with information about the demographics and interests of visitors to the SBS Internet Sites. We in turn use that data for promotional reasons, including to sell advertisements that appear on an SBS Internet Site. In order to opt out of the sale of Internet and other electronic network activity information for purposes of us generating advertisement sales, please follow this link, which is also available on our homepage.

No Discrimination. We will not discriminate against a California resident because the California resident exercised any of the rights described here.

Access to Personal Information

All users, regardless of state of residence, may review, correct and update the personal information that they provide to us at an SBS Internet Site by using the feedback mechanisms provided at a particular SBS Internet Site, by clicking on this feedback link or write to us at Spanish Broadcasting System, Inc., Internet Privacy Policy, SBS Interactive, 2601 S. Bayshore Drive, PH2, Coconut Grove, FL 33133.

Do Not Track

We do not track personal information about users’ online activities over time and across third-party Web sites or online services. We do  not allow third parties to collect personal information about users’ online activities over time and across different Web sites when users use the SBS Internet Sites. We therefore do not respond to Web browser “do not track” signals.

Your Choices

As described above, many of the SBS Internet Sites permit you to make choices about the use of your personal information. In most cases, we ask you to indicate your choices at the time and on the page where you provide your personal information. Often you make these choices by determining whether to provide your personal information, when, and how much to provide. You can thereafter manage those choices by returning to the “Your Privacy Choice” page to review and change your selections.

Retention of Personal Information

SBS retains the personal information collected on SBS Internet Sites as long as necessary to provide the services, products and information you request or as permitted by applicable law.

Children and Parents

SBS Internet Sites are generally not intended for persons under 13 years of age. SBS does not knowingly solicit or collect personal information from or about children on its Internet Sites except as permitted under applicable law. If your child has submitted personal information and you would like to request that such information be deleted from our records, you may do so by using the feedback mechanisms provided at a particular SBS Internet Site, by clicking on this feedback link or write to us at Spanish Broadcasting System, Inc., Internet Privacy Policy, SBS Interactive, 2601 S. Bayshore Drive, PH2, Coconut Grove, FL 33133.

Questions about this Policy or our Privacy Statements

If you have any questions about this Policy or a Web Site Privacy Statement or our use of your personal information, please contact us by clicking on this feedback link or write to us at Spanish Broadcasting System, Inc., Internet Privacy Policy, SBS Interactive, 2601 S. Bayshore Drive, PH2, Coconut Grove, FL 33133.

Changes to this Policy and our Privacy Statements

SBS will annually review this Privacy Policy and reserves the right to update or modify this Policy at any time and without prior notice, by posting the revised version of this Policy on our SBS Internet Sites. We also reserve the right to update or modify our Web Site Privacy Statements, at any time and without prior notice, by posting the revised Privacy Statement on the applicable SBS Internet Site. If we modify this Policy or any Privacy Statement, the modifications will only apply to the personal information we collect after we have posted the revised Policy or Privacy Statement on the applicable SBS Internet Site.