November 20, 2020
UPDATED AS OF: 11/20/2020
QUICK GUIDE TO CONTENTS
- WHAT INFORMATION WE COLLECT
- HOW WE USE INFORMATION
- WE COLLECT INFORMATION FROM VARIOUS SOURCES
- WE SHARE INFORMATION WITH OTHERS
- YOUR CHOICES
- YOUR CALIFORNIA PRIVACY RIGHTS
- SECURITY OF YOUR INFORMATION
- OTHER SITES
- UNITED STATES ONLY
- CONTACT US
1. 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 S&A account usernames and passwords. We may collect your Social Security Number if you are the winner of a promotion or contest. You may create a personal S&A Code by enabling this feature through the settings in the Apps; the S&A Code is connected to a unique identifier that ties back to your S&A account and the information associated with your account. You may also submit photos and videos.
Demographic and Classification Information: We may collect your zip code, age, gender, race, and political affiliation.
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; records of contests you enter.
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 (“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 S&A 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: We or our vendors or third parties may collect information about the general location of your Device when you access or use the Platforms; or if you choose to turn on your Bluetooth, Wi-Fi or other geolocation functionality when you use the Apps, subject to your consent, the Apps or SDKs embedded within the Apps may collect, infer, and use more precise geolocation information.
Employment-Related Information: If you apply for a job, we may collect information about your work experience and previous employment, your education history, your resume, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa to work in the United States, and salary expectations. If you apply for a job, you can choose to also voluntarily provide any of the following self-identifying information: ethnicity, gender, disability status, and/or veteran status.
Payment Information: We collect your credit card or debit card details when you make a purchase.
We develop 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.
2. HOW WE USE INFORMATION
We may use 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, 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 S&A 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 S&A 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; and
- For other lawful purposes disclosed at the time we collect your information or otherwise with your consent.
3. WE COLLECT INFORMATION FROM VARIOUS SOURCES
Directly from you: We, as well as our service providers, 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 or otherwise 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 S&A Code. If you apply for a job, we also collect Employment-Related info and any other personal information you to provide (such as self-identifying information).
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.
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.
Business partners: 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.
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.
Other users: Other users may decide to provide us with your personal information (such as Identifiers) so that we may invite you to join S&A or so that we may facilitate communication between users of the Platforms.
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 as described below:
Affiliates: We may share personal information with our affiliates, subsidiaries, and other companies under common control and ownership with S&A.
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.
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 S&A to stream on the Platforms (e.g., artists or record labels). If you connect your S&A account to a third-party application or social media platform, S&A 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 S&A account, that third party application may have access to certain information such as your S&A playlists and activity. Some transfers of your personal information to these other companies may be viewed as a “sale” under certain state laws.
Nielsen: Our Platforms may include Nielsen’s proprietary measurement software which may allow you to contribute to market research. To learn more about the information Nielsen’s software may collect and your choices with regard to it, please go to https://www.nielsen.com/us/en/legal/privacy-statement/digital-measurement/. If you would like to opt-out of participating, please go to https://priv-policy.imrworldwide.com/priv/browser/cookie-policy-us-en.html?optout=1.
Other users: S&A 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 S&A 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 S&A 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.
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.
Other disclosures: We may share personal information for other reasons we may describe to you from time to time as permitted by law.
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.
5. YOUR CHOICES
To learn how you can reject or delete cookies from us or other companies, please refer to your browser’s help menu. Deleting or rejecting browser cookies does not necessarily affect third-party flash cookies used in connection with our Platform. To delete or disable flash cookies, please go to https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. 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.
Our Platforms may include Nielsen’s proprietary measurement software which may allow you to contribute to market research. If you would like to opt-out of participating, please go to https://priv-policy.imrworldwide.com/priv/browser/cookie-policy-us-en.html?optout=1.
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.
You can opt out of being tracked online for IBA purposes by going to https://optout.aboutads.info/?c=2&lang=EN or https://optout.networkadvertising.org/?c=1. You can opt out of being tracked for IBA purposes on mobile apps by going to https://youradchoices.com/appchoices. Another way to opt out of IBA is by clicking on the Advertising Options Icon featured on certain S&A ads on third-party websites. When clicked it (1) describes the collection and uses of data gathered at the relevant party website and (2) provides a way for you to opt out of data collection and use by the other parties listed for the purposes of IBA.
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.
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; sending us an e-mail: email@example.com
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.
By downloading our Apps or using the Platforms, you consent to our collection, use, and sharing of your Location Information with other parties for analytics, advertising, and other purposes described herein. You can stop the collection of precise 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.
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.
Access to Your Information:
If you wish to verify, correct, or update any of your personal information we have collected or received, you may contact us at the address or e-mail provided below. In accordance with our routine record keeping, we may delete certain records that contain personal information about you. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information.
6. YOUR CALIFORNIA PRIVACY RIGHTS
As of January 1, 2020, California law permits residents of California to request certain details about how their personal information is shared with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us using the methods described in the Contact Us section and include “Shine the Light” in your inquiry.
As of January 1, 2020, if you reside in California, you also have the right to make the following requests with respect to your personal information:
Access: You have the right to request that we disclose to you the following: (1) the categories of personal information that we have collected about you; (2) the categories of sources from which we have collected personal information about you; (3) the business or commercial purpose for collecting or selling your personal information; (4) the categories of personal information that we have sold about you and the categories of outside parties to whom the personal information was sold; (5) 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; and (6) the specific pieces of personal information that we have collected about you.
Deletion: You can request that we delete the personal information that we maintain about you, subject to certain exceptions.
- S&A: firstname.lastname@example.org
Right to be free from discrimination: You have the right not to be discriminated against for exercising these 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. Note that for purposes of these rights, personal information does not include information about job applicants, employees, and other of our personnel collected in the employment context.
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us.
You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent identifies himself/herself/itself as an authorized agent.
We also want California residents to know the following:
- We disclose each of the foregoing categories of personal information to our service providers, business and advertising partners, advertising networks, data analytics providers, and social networks.
- We may “sell” 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.
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.
8. 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.
9. 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).
10. UNITED STATES ONLY
The Platforms are governed by and operated in, and in accordance with the laws of, the United States, and are intended for the enjoyment of residents of the United States. S&A makes no representation that the Platforms are governed by or operated in accordance with the laws of any other nation.
12. CONTACT US
If you have any questions or concerns about this Privacy Statement, the practices of the Platforms, or your experiences with the Platforms, please contact us at:
Sanabria & Associates (“slegal.com”)
Attn: S&A Digital Customer Service
Re: S&A Privacy Statement
8630 Fenton Street, Suite 1104
Silver Spring, MD 20910