PRIVACY POLICY
Last updated, January 11 ,2024
GENERAL
Our company (“Company” or “we” or “us” or “our”), ZenoRadio LLC, builds, hosts, maintains and manages the radio broadcast app (the “Radio App”) you have downloaded and are using. However, the Radio App itself is licensed from us by Bisrat Radio 101.1FM (the “Radio Station”). The Radio Station owns and controls the particular account on the app store from which you downloaded the Radio App, and the Radio Station has full control over all content transmitted through the Radio App. We do not have any ownership of or control over the content delivered over the Radio App, except to the extent that we may inlay and serve certain advertisements that you hear via the Radio App. The reference to Radio App will also include, as and when appropriate for the context, where listeners access Radio Station broadcasts off of our or another website.
The following privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Radio App, about the types of information that Company may gather or collect from you in connection with your access to the Radio App. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.
The Radio App is hosted in the United States of America (“United States” or “U.S.”) and is subject to U.S. state and federal law. If you are accessing the Radio App from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by accessing the Radio App, you consent to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your access to the Radio App and your agreements with us. Any persons accessing the Radio App from any jurisdiction with laws or regulations governing personal data collection, use and disclosure different from those of the jurisdictions mentioned above may only use the Radio App in a manner lawful in their jurisdiction. If your access to the Radio App would be unlawful in your jurisdiction, please do not access the Radio App.
BY ACCESSING THE RADIO APP, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
USE BY CHILDREN
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Radio App represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a listener under 13 years of age through the Radio App, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a user of the Radio App or has otherwise transferred personal information to us through the Radio App, please contact the Company using our contact information below to have that child’s personal information deleted.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY- IDENTIFYING INFORMATION
This Privacy Policy regulates the processing of your personally-identifiable information. “Personally-Identifying Information,” is information such as a name, email address or telephone number that, without more, can be directly associated with a specific person.
We also collect and process “Non-Personally-Identifying Information” which is information that, without the aid of additional information, cannot be directly associated with a specific person. Company gathers from users of the Radio App Non-Personally-Identifying Information of the sort that devices, depending on their settings, may make available. That information includes, for users accessing the Radio App over the Internet, a user’s Internet Protocol (IP) address, operating system, and browser type. If you use a mobile device to access the Radio App or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system and version information, and IP address. Company collects and analyzes Non-Personally-Identifying Information gathered from users of the Radio App to help Company better understand how the Radio App is being used, how to promote the Radio App, and for the delivery of targeted advertising. By identifying patterns and trends in usage, including radio station listening habits and patterns, Company is able to better design the Radio App to improve users’ experiences, both in terms of content, advertising and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from the Radio App users in the aggregate, such as by publishing a report on trends in the usage of the Radio App.
LAWFUL BASES OF PROCESSING
Where Company is acting as a data controller, that determines the purposes and means of processing your personal data, such as when we collect, use, and share personal data as described herein, we must have a lawful processing basis for doing so. The lawful bases we rely on for processing personal information are (if and when applicable):
Processing is necessary for the performance of a contract to which the data subject is party. For example, to respond to your customer service inquiries and requests for information;
Our legitimate interest to facilitate the functionality of the Radio App, as well as to maintain, improve, and analyze our website, apps, advertisements, and the products and services, or in order to detect, prevent, or investigate security breaches or fraud;;
In order to comply with our legal obligations, for example to maintain appropriate records for internal administrative purposes and as required by applicable law; and
Your consent. For example: to send you via email and other electronic means personalized promotions and special offers or informing you about our professional services, offerings, events, or other promotional purposes.
TOOLS USED IN CONNECTION WITH OUR SERVICES.
Web Cookies. A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on your computer or device, and that the user’s browser provides each time the user logs on to or submits a query to the Radio App. We use cookies on the Radio App to keep track of services you have used and activities you have performed, radio stations you have listened to and listening and call-in habits, to record, if applicable, registration information regarding your login name and password, to record your use preferences, if applicable, to keep you logged into the Radio App, if applicable, and to facilitate purchase procedures, if applicable. Company also uses Web Cookies to track the pages that users visit and activities performed during each Radio App session, both to help Company improve users’ experiences and to help Company understand how the Radio App is being used. As with other Non-Personally-Identifying Information gathered from users of the Radio App, Company analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help Company, its partners and others better understand how the Radio App is being used. Most browsers allow you to change your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings and learn how to use them, please consult the “Help” function of your browser, or the documentation published online for your particular browser type and version you can check if the procedure for your browser is mentioned in this explanatory website or here. USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS OR DEVICES SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE RADIO APP, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE RADIO APP MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
Web Beacons. A “Web Beacon” is an object that is embedded in a web page or application that is usually invisible to the user and allows operators to check whether a user has viewed a particular web page, application or an email. Company may use Web Beacons on the Radio App and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use to compile aggregated statistics about the Radio App usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.
Advertising Tools and Services.We or broadcasters may either directly or through third-party companies serve ads to you when you access the Radio App. Advertisers may use information about your use of the Radio App (including, without limitation, stations accessed, listening habits, and location of accessing telephone number) that are contained in Web Cookies, Flash Cookies or that we gather when you access the Radio App via a telephone (wireless or wired device) or other application or access method in order to provide advertisements about goods and services that may be of interest to you. We also allow advertisers to choose the characteristics of listeners who will be presented with their advertisements and we may use any of the non-personally identifiable attributes we have collected to select the appropriate audience for those advertisements. If you are accessing the Radio App via the Internet, then using a tool created by the Network Advertising Initiative, you can opt out of several third party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: http://networkadvertising.org/managing/opt_out.asp. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.
Analytic Tools. We use third party services that we use to track activity related to our services, such as Google Analytics and Google Firebase. We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and serve ads based on your past activity on our applications, including Google Analytics for Display Advertising. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https:// tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network. You can do so by using Google’s Ads Settings (www.google.com/settings/ads). Aggregated and Non-Personally Identifying Information we collect under any of the above circumstances we may share with third parties. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Radio App and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Radio App and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other listeners will find of interest and to target content and advertising.
Geo-Location Information. We derive certain inferences based upon your IP address, the telephone number that you use to access the Radio App, Wi Fi network data or cell tower triangulation. As such, we may record general non-specific locations. As stated above, we may also automatically collect anonymous information about you when you have geographical location tools on your Internet-enabled device which have not been disabled. We may also collect Non-Personally-Identifying anonymous information about you whenever you deliberately interact with one of our ads containing a quick response code or follow instructions to send a text, or visit a URL. If you have geo-location tools on your Internet-enabled device which you have not disabled, we may automatically receive information on your device’s location and may use it to comply with our contractual arrangements which restrict our sending certain programming channels outside of defined areas, such as when you want to listen to the Radio App while in another country.
Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
PUSH NOTIFICATIONS
We may send you push notifications if you choose to receive them for other service-related matters. If you wish to opt-out from receiving these types of communications, you may request to have them stopped at any time via preferences on your mobile device.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY- IDENTIFYING INFORMATION
Information Collection
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company may collect Personally Identifying Information from and about the Radio App users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when (1) registering for the Radio App, (2) dialing in to the Radio App, (3) logging in with social network credentials, (4) participating in polls, contests, surveys or other features of the Radio App, or responding to offers or advertisements on the Radio App, (5) communicating with us, or (6) signing up to receive newsletters or other communications. That Personally Identifying Information may include each user’s name, address, email address, and telephone number. We also may request information about your interests and activities, your gender, age, date of birth, language preference, hometown and other demographic information, and other relevant information as determined by Company from time to time. Additionally, when you access the Radio App from a telephone or mobile device we may also obtain your telephone number which may also be used for tracking your use of the Radio App.
Users of the Radio App are under no obligation to provide Personally- Identifying Information of any kind, though some information, like a telephone number, may be provided automatically when using the Radio App. We may also use reverse look up functionality in order to obtain the name of a person associated with a particular phone number. We store Personally-Identifying Information and linked Non-Personally- Identifiable Information that we gather about you through the Radio App, through social media, through linked social media applications, or that you give to us voluntarily in any other way, and we may use it in accordance with this Privacy Policy.
BY REGISTERING WITH OR USING THE RADIO APP, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION” SECTION.
Company Communications
We may occasionally use your name and email address to send you notifications regarding new services or products offered by Company that we think you may find valuable. If we have obtained proper authorization, we may also contact you via email, telephone, text or push notification. We may also send you service-related announcements from time to time through the general operation of the Service. Generally, you may opt out of receiving such communications, though we reserve the right to email you notices about your account even if you opt out of all voluntary email notifications.
Please note that "opt-out" and "unsubscribe" requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings.
Social Media
We may provide you the option to connect your account, if applicable, on the Radio App to your account on some social networking sites (such as via Facebook Connect) for the purpose of logging in, uploading information or enabling certain features on the Radio App. When logging in using your social network credentials, such as your Facebook account, we may collect the Personally Identifying Information you have made publicly available in Facebook, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list, and any other information you have made public. We may also obtain other non-public information from the social network website with your permission. Once connected, others may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Radio App to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you.
Company Disclosures
Company will disclose Personally-Identifying Information to the following categories of third-parties, under the following circumstances:
Broadcasters/Advertisers. Through your access to the Radio App, we collect a variety of information regarding how you use the Radio App, and this information can be linked to Personally-Identifiable Information we have obtained about you. We may disclose this information to broadcasters of radio stations that you access via the Radio App as well as to our advertisers. Broadcasters may use the information we disclose about you only for their internal purposes, such as improving programming, contacting you as a listener of their programming, in order to deliver advertising, and for related purposes. Advertisers may use information to assist in providing you with targeted advertising.
Marketing Communications. Unless users opt-out from receiving Company marketing materials, Company may push notifications through the Radio Service.
As Required by Law or to Protect Rights. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our Company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms of use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
Affiliates. We may share some or all of your personal information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates would include a parent company or any subsidiaries, joint venture partners, or other companies that we control or that is under common control with us. Such intercompany transfers may be to and from the United States and any other country in which we or our agents maintain facilities for the purposes identified in this Privacy Policy, as well as for storage, processing or other business use as permitted under this Agreement.
Third Party Service Providers. We may share your Personally- Identifying Information, which may include your name and contact information with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, credit card processing, payment gateways, subscription processing providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, supporting or maintaining our service platform or technologies, and supporting contests, sweepstakes, surveys and other features offered through the Radio App. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Business Transfers; Bankruptcy. Company reserves the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Company’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt- out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.
General Use
We use the Personally-Identifying Information in the data we maintain about you, and other information we obtain from your current and past activities in connection with the Radio App to: deliver the products and services that you have requested, manage your account, if applicable, and provide you with customer support, communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties, develop and display content and advertising tailored to your interests on the Radio App and other sites, resolve disputes, troubleshoot problems, measure consumer interest in our services, inform you of updates, customize your experience, detect and protect us against error, fraud and other criminal activity, enforce our terms of use, and as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally Identifying Information to identify users using multiple listener IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made through the Radio App, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
CONTESTS, GIVEAWAYS AND SURVEYS
From time to time, Company may offer users the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. From time to time, Company may also ask users to participate in surveys designed to help Company improve the Radio App. Any Personally-Identifying Information provided to Company in connection with any survey will be used only in relation to that survey, and will be disclosed to third parties not bound by this Privacy Policy only in non-personally- identifying, aggregated form.
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
Third parties are under no obligation to comply with this Privacy Policy, with respect to Personally-Identifying Information that users provide directly to those third parties or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets and a variety of other third party applications accessible through the Radio App. Company neither owns nor controls the third-parties and applications accessible through the Radio App. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties. Before visiting a third-party, or using a third party application, whether by means of a link on the Radio App, directly through the Radio App, or otherwise, and before providing any Personally- Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third parties, and should take those steps necessary to, in those users’ discretion, protect their privacy.
SECURITY
We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.
WIRELESS CONSENT POLICY
You authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to use your mobile number, name, address, email, network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status details, if available, solely to allow verification of your identity and to compare information you have provided to us with your wireless operator account profile information for the duration of the business relationship.
PRIVACY POLICY CHANGES
Company may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Company’s Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account, if applicable. Users should regularly check this page for any changes to its Privacy Policy. Company will always post new versions of the Privacy Policy within the Radio App.
CALIFORNIA PRIVACY RIGHTS
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, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared 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 our privacy officer as listed below.
DO NOT TRACK POLICY. The Radio App does not respond to “Do Not Track” signals or mechanisms.
GDPR
Provisions for persons governed by the General Data Protection Regulation (GDPR) are found in Annex 1.
US State Privacy laws
Provisions for persons governed by the different state privacy laws are found in Annex 2.
CONTACT
If you have any questions regarding our Privacy Policy, please contact our privacy officer at:
Privacy Officer
ZenoRadio LLC
Email: privacy@zenoradio.com
Phone: (212) 822-3460
ANNEX 1
GDPR PROVISIONS
Please note that this privacy policy shall apply to processing operations of Personal Data related to General Data Protection Regulation (GDPR) protected individuals. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. The Privacy Policy provisions are qualified as follows for such protected individuals.
WHAT PERSONAL DATA WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
Consequences of not providing the data
Period of Storage
Third Parties with whom we Share your Data
Why is the data collected and for what purposes?
Data We Collect
Use Case
Legal Basis: It is either: (i) necessary to provide our Services to you, or (ii) following a User’s request, prior to entering into an agreement with us.
You may not be able to use our Services.
For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days.
Internal storage only
We collect this Personal Data in order to:
enable you to register and use our Services;
for the purposes of delivering the products and services that you have requested;
managing your account; and
if applicable, providing you with customer support.
name, address, email address, and telephone number.
On a voluntary basis, you may also provide us with Personal Data about your interests, your gender, age, date of birth, language preference, and other demographic information
Accessing content made available by our Services through the Websites, streams or Apps.
Dialing in to use our Services.
You may not be able to share certain content through your social media account.
For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days.
3rd party service providers, such as: Google , Facebook, Twitter if users choose to login with external credentials ( for email)
Twilio for SMS authentication
We collect this data in order to enable you to connect and log in to the Services through your social network accounts, upload information and enable certain features of our Services
name, surname, email address, profile picture, cover photo, username, friend list, and any other information you have made public on the applicable social network.
Logging in to our Services using your social network credentials (applicable when using our Services via our App).
We will not be able to respond to your enquiry.
For as long as reasonably necessary to respond to your enquiry.
Intercom
When you commence direct communication with us, we will use the data in order to respond to your enquiry(ies), and if needed, for any further follow-up.
Name and email address.
You may also provide, on a voluntary basis, your phone number and company name.
General communication with us (e.g., through our Contact Us web page), including sending you service-related announcements (e.g., through Push Notifications and audio messages).
Legal Basis: Consent
We may not be able to send you information on new products or services which we think you may find valuable.
For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days.
SendGrid (email distribution service)
Twilio ( SMS )
When you sign up to receive newsletters or other communications related to our Services, we will use the data in order to stay in touch with you.
name, address, email address, and telephone number and any other information you choose to share with us
Signing up to receive from us newsletters (or other communications) regarding new services or products that we think you may find valuable
We may not be able to improve our Services to you.
For as long as you access content through our Services. For as long as you remain subscribed. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days.
Advertising partners :
Display advertising:
Active: Admob, Facebook / Meta, Monetize More , Instreamatic, Primis, Google Ad Manager (DFP/GAM)
No longer used: Inmobi, Mobfox, Mopub, Aerserv, VRTCAL, via DFP: Antipodes, Tappx, Click Dealer
Audio advertising: Adzwizz, Triton, Instreammatic, WideWorbit,
Targetspot, Audio.Ad, AdTonos, EmpireStreaming
In order to help us better understand how our Services are being used by you, how to promote the Services, and for the delivery of targeted advertising necessary for providing the Services free of charge.
IP address, Mobile device ID, device user-agent
Marketing and Lead Targeting
Certain features of our Services may not function properly without the aid of web cookies.
For as long as you access content through our Services. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days.
Internal storage only
We use cookies, web beacons and other tracking technologies to keep track of services you have used and activities you have performed on our Website, radio stations you have listened to and listening and call-in habits, and several other functionalities, further described here.
Cookies, web beacons and other tracking technologies
Tracking your use of the Services.
You will not be able to participate in any of polls, contents our surveys
For as long as reasonably necessary to process the results of the poll, contest, etc. If you choose to opt out, as soon as reasonably practicable, and within a maximum of 60 days.
Internal storage only
Anonymized/Aggregate data shared with marketing/advertising partners
When you agree to participate polls, contests, surveys or other features of ours, we will use the data in order to help us improve our Service.
name, address, email address, telephone number and any other information you choose to share with us (e.g., information about your interests and activities, your gender, age, date of birth, language preference etc.)
Participating in polls, contests, surveys or other features of our Services.
SECURITY
We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
RETENTION OF YOUR PERSONAL DATA
In addition to the retention periods mentioned in the table above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA
We ensure transfers within the Company group will be covered by an agreement entered into by members of the Company group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.
Where we transfer your Personal Data outside of the Company, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
YOUR RIGHTS
The following rights (which may be subject to certain exemptions or derogations), shall apply to individuals who are protected by the GDPR. Please note that some of these rights may also apply under other jurisdictions as well:
You have a right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.
You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.
The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your Personal Data, in particular if the processing is required to meet our legal and regulatory obligations.
You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us using the contact information in the Privacy Policy.
ANNEX 2
US States Privacy Laws
Please note that this Annex 2 of our privacy policy shall apply to processing operations of Personal Data related to individuals that are protected by applicable US State Privacy Laws. "US State Privacy Laws" are any United States state-specific privacy laws that apply to the Company, including, if applicable: the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and its updates and amendments (the "CCPA"), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act and any other applicable federal and/or state law. The applicability of this section to you is subject to the applicability of those laws to our Company and to their applicability to you individually. “Personal Data” or "Personal Information" means any information that can be used, alone or together with other data, to uniquely identify any living human being. The Privacy Policy provisions are qualified as follows for such protected individuals.
Third Parties with whom we share your Personal Data
Sources of Personal Data
(as applicable)
Purposes such Personal Data is collected for
Categories of Personal Data we collect
Use Case
Internal storage only
Individuals submitting information to us;
Information we automatically collect from site visitors;
We collect this Personal Data in order to: (i) enable you to register and use our Services; (ii) for the purposes of delivering the products and services that you have requested; (iii) managing your account; and, if applicable, (iv) providing you with customer support.
Identifiers: such as name, address, email address, and telephone number.
On a voluntary basis, you may also provide us with Personal Data about your interests, your gender, age, date of birth, language preference, and other demographic information
Accessing content made available by our Services through the Websites, streams or Apps.
3rd party service providers, such as: Google, Facebook, Twitter if users choose to login with external credentials ( for email)
Twilio for SMS authentication
Individuals submitting information to us;
We collect this data in order to enable you to connect and log in to the Services through your social network accounts, upload information and enable certain features of our Services
Identifiers: such as name, surname, email address, profile picture, cover photo, username, friend list, and any other information you have made public on the applicable social network.
Logging in to our Services using your social network credentials (applicable when using our Services via our App).
3rd party service providers, such as: Intercom
Individuals submitting information to us;
When you commence direct communication with us, we will use the data in order to respond to your enquiry(ies), and if needed, for any further follow-up.
Identifiers: such as name and email address.
You may also provide, on a voluntary basis, your phone number and company name.
General communication with us (e.g., through our Contact Us web page), including sending you service-related announcements (e.g., through Push Notifications and audio messages).
3rd party service providers, such as: SendGrid (email distribution service)
Twilio ( SMS )
Individuals submitting information to us;
When you sign up to receive newsletters or other communications related to our Services, we will use the data in order to stay in touch with you.
Identifiers: such as name, address, email address, and telephone number and any other information you choose to share with us
Signing up to receive from us newsletters (or other communications) regarding new services or products that we think you may find valuable
3rd party service providers, and advertising partners :
Display advertising:
Active: Admob, Facebook / Meta, Monetize More , Instreamatic, Primis, Google Ad Manager (DFP/GAM)
No longer used: Inmobi, Mobfox, Mopub, Aerserv, VRTCAL, via DFP: Antipodes, Tappx, Click Dealer
Audio advertising: Adzwizz, Triton, Instreammatic, WideWorbit,
Targetspot, Audio.Ad, AdTonos, EmpireStreaming
Individuals submitting information to us;
In order to help us better understand how our Services are being used by you, how to promote the Services, and for the delivery of targeted advertising necessary for providing the Services free of charge.
Identifiers: such as IP address, Mobile device ID, device user-agent
Marketing and Lead Targeting
Internal storage only
Individuals submitting information to us;
Information we automatically collect from site visitors;
We use cookies, web beacons and other tracking technologies to keep track of services you have used and activities you have performed on our Website, radio stations you have listened to and listening and call-in habits, and several other functionalities, further described here.
Identifiers: such as Cookies, web beacons and other tracking technologies
Tracking your use of the Services.
Internal storage only
Anonymized/Aggregate data shared with marketing/advertising partners
Individuals submitting information to us;
When you agree to participate polls, contests, surveys or other features of ours, we will use the data in order to help us improve our Service.
Identifiers: such as name, address, email address, telephone number and any other information you choose to share with us (e.g., information about your interests and activities, your gender, age, date of birth, language preference etc.)
Participating in polls, contests, surveys or other features of our Services.
YOUR RIGHTS
The following rights (which may be subject to certain exemptions or derogations) shall apply to individuals protected by some US state privacy laws (the applicability of these rights depends on the applicability of some of these laws to you):
You have the right to know what Personal Information is being collected about you, This include the right to request that we disclose what Personal Information of yours we collect, use, disclose, and sell;
You have a right to correct inaccurate Personal Information we have about you;
You have the right to request the erasure/deletion of your Personal Information (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
You have the right to know whether your Personal Information is sold or disclosed and to whom;
You have the right to restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of the sale or sharing of your Personal Information to third parties, if applicable, where such requests are permitted by law;
You have the right to limit the use of your Sensitive Personal Information;
You have the right not to receive discriminatory treatment for the exercise of the privacy rights;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above. While we cannot guarantee privacy perfection, we will address any requests to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.
You can exercise your rights by contacting us at privacy@zenoradio.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
CCPA "Do Not Sell or Share Personal Information".
Our use of some third-party advertising technologies and services may be considered a “sale” or “sharing” under CCPA. Under the CCPA, you have the right, at any time, to direct us not to sell or share your Personal Information. Categories of Personal Information disclosed in the preceding 12 months that may be considered a “sale” or “sharing” under CCPA are the following: Identifiers (IP address, mobile device ID, device user-agent). Categories of third parties to whom Personal Information was disclosed that may be considered a “sale” or “sharing” under CCPA are: third-third party advertisers. The purposes for which Personal Information was “sold” or “shared” (as defined in the CCPA) in the past year are the following: In order to personalize the services we provide for you and/or our website, in order to analyze your use of our website, in order to establish a business connection with you.
You can opt-out of the “sale” and “sharing” to third parties by contacting us at privacy@zenoradio.com.
We do not knowingly sell or share the Personal Information of consumers under 16 years of age.