Privacy Policy for Midwest Communications, Inc.

Introduction

Midwest Communications, Inc. and WRIG, Inc. (“Midwest,” “we,” “us,” or “our”) have developed this Privacy Policy because your (“you” and “your” referring to any party using our web site) privacy is important to us.  As we collect certain types of personally identifiable information (“Personal Information”), we believe that you should know how that Personal Information is used. Therefore, this Privacy Policy describes the collection, use, and disclosure of Personal Information in connection with your use of our web site (the “Midwest Site”).

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE MIDWEST SITE.

This Privacy Policy is part of the Midwest Site’s Terms of Use Agreement which is binding upon all users of the Midwest Site.  Your use of the Midwest Site constitutes your acceptance of this Privacy Policy.

 

Definition of Personal Information

Personal Information includes, but is not limited to, data such as your name, street address, city, state, zip code, telephone number, fax number, instant-messenger nickname, date of birth, e-mail address, any other information that identifies you or would permit someone to contact you, and information about your radio listening habits, your interests, and other demographic data.

 

Collection of Personal Information

In general, you may browse and use the Midwest Site without providing any Personal Information.

Information You Provide Directly to Us

We will collect any information you provide to us. We may collect information from you when you contact us or provide feedback. This information may include, but is not limited to, your name, email address, phone number, mailing address, payment information, photo, geographic location, and your social media handles.  The provision of this information by you to us is optional.

Comments

When a visitor leaves comments on the Midwest Site, we collect the data shown in the comments form, as well as the visitor’s IP address and browser user agent string to help us identify spam.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Advertising

When you visit or submit information related to purchasing advertising from us on the Midwest Site, one of our radio stations, or elsewhere, we collect the information you provide on the submission form as well as the visitor’s IP address and browser user agent string to help us identify spam.

Job Applications

When you apply for a job with us through the Midwest Site, we collect the information you provide to us as well as the visitor’s IP address and browser user agent string to help us identify spam.

Information that Is Automatically Collected

Device/Usage Information

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the services offered by Midwest on the Midwest Site (“Services”). As described further below, we may collect and analyze: (a) device information such as IP addresses, location information (by country and city), unique device identifiers, International Mobile Equipment Identify and Transmission Control Protocol/Internet Protocol address, browser types, browser language, operating system, and mobile device carrier information: and (b) information related to the ways in which you interact with the Services, such as referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed, the order in which pages were viewed, statistical information about the use of the Services, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

Cookies and Other Tracking Technologies

We also collect data about your use of the Services through the use of Internet server logs and online tracking technologies, like cookies and/or tracking pixels. An Internet server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website. It enables us to:

    (a) recognize your computer;
    (b) store your preferences and settings;
    (c) understand the web pages of the Services you have visited and the referral sites that have led you to our Services;
    (d) enhance your user experience by delivering content  specific to your inferred interests;
    (e) perform searches and analytics;
    (f) assist with security administrative functions, including to prevent fraud and to protect your data from access by unauthorized parties; and
    (g) comply with legal requirements.

Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags that have a unique identifier embedded in websites, online ads, and/or email and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and access user cookies.

We may also use tracking technologies in our license buttons and/or icons that you can embed on other sites/services to track the website addresses where they are embedded, gauge user interaction with them, and determine the number of unique viewers of them. If you receive email from us (such as the CC newsletter, campaign updates, or other ongoing email communications from CC), we may use certain analytics tools, such as clear GIFs, to capture data such as whether you open our message, click on any links or banners our email contains, or otherwise interact with what we send. This data allows us to gauge the effectiveness of our communications and marketing campaigns.  As we adopt additional technologies, we may also gather additional information through other methods.

You can change your settings to notify you when a cookie is being set or updated, to disable cookies altogether, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g.,  Microsoft Edge; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.

Information from Third Parties

We may also collect information about you or others through third parties.  To the extent permitted by law, we may also collect information from third parties, including public sources, social media platforms, and marketing and market research firms. Depending on the source, this information collected from third parties could include name, contact information, demographic information, information about an individual’s employer, information to verify identity or trustworthiness, information that you provide to a third party regarding an application for a job with us, and information for other fraud or safety protection purposes.

 

Use of Information by Midwest

We may use the information we collect from and about you to:

  •       Fulfill the purposes for which you provided it;
  •       Provide and improve the Services, including to develop new features or services, take steps to secure the Services, and offer and enhance technical and customer support;
  •       Process and respond to your inquiries or to request your feedback;
  •       Offer you products or services that we believe may be of interest to you;
  •       Communicate with you about our stations and operations;
  •       Conduct analytics, research, and reporting, including to synthesize and derive insights from your use of our Services;
  •       Comply with the law and protect the safety, rights, property, or security of the Services, our users, Creative Commons, and the general public; and
  •       Enforce our terms, including to investigate potential violations thereof.

Please note that we may combine information that we collect from you and about you (including automatically collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Privacy Policy.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes.

Sharing of Information

We do not sell, rent, or lease your Personal Information to others for their use.  We do share Personal Information and Contest Information as described in this Privacy Policy.

As set forth in this Privacy Policy, Midwest may disclose your Personal Information to Midwest’s parent(s), subsidiaries, affiliates, advertisers, sponsors, promotional partners, service providers, and other third parties, including to law enforcement agencies when necessary to do so pursuant to the terms, conditions, or requirements of this Privacy Policy or the Terms of Use Agreement.

Midwest may share any information collected from you with our affiliates, advertisers, sponsors, promotional partners, and service providers for the purpose of extending offers of goods and services without your consent.  Midwest may provide offers of goods and services to you by mail, e-mail, and telephone. When making such offers, Midwest will do so without sharing your Personal Information with the third parties who provide these goods and services on whose behalf Midwest extends the offers.  Midwest accomplishes this by controlling the process by which the offers are extended. The third party extending the offer gets no information about you unless, and until, you respond to the offer.

Midwest has the right to disclose your Personal Information to third parties for the purpose of administering and maintaining services on the Midwest Site.  In addition, we may share any of the information collected from you with third parties on an aggregate basis. The aggregated information is not linked to any individually identifiable information.

Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties or affiliates, both internal and external. If you wish to be removed from receiving future communications, you can opt out by texting STOP.

In general, Midwest does not keep e-mail correspondence received from users of the Midwest Site except for those e-mails pertaining to the on-air programs of Midwest’s radio stations.  As required by federal law, regulations, and rules, if any part of your e-mail correspondence pertains to the programming of any Midwest stations, we must place that correspondence in that Midwest station’s FCC public file or make that correspondence available via electronic file access at that Midwest station to anyone that requests such information.  You therefore understand and acknowledge that your Personal Information contained in certain e-mails will be disclosed to the general public.

You also understand and acknowledge that Midwest may disclose your Personal Information: (1) to the government or third parties in response to legal processes (e.g., in court or regulatory proceedings, or in response to a request from a law enforcement agency), and/or (2) to a user’s employer and/or internet service provider in cases where a party is not in compliance with the Terms of Use Agreement.

Finally, although Midwest takes appropriate measures and makes a good faith effort to safeguard against unauthorized disclosures of information, we cannot assure you that Personal Information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy. In addition, because security of data on the Internet is imperfect, Midwest cannot guarantee that your Personal Information will be safe from access by hackers or other nefarious third parties.

 

Online Analytics

We may use third-party web analytics services (such as Google Analytics) on our Services to collect and analyze the information discussed above, and to engage in auditing, research, or reporting. The information (including your IP address) collected by various analytics technologies described in the “Cookies and Other Tracking Technologies” section above will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services, including by noting the third-party website from which you arrive to our Site, analyzing usage trends, assisting with fraud prevention, and providing certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here

 

Opting Out and Access to Personal Information

The Midwest Site provides you with the option to opt-out of receiving e-mail from Midwest.  To do so, use the Midwest Site’s contact form to ask that we not send you any e-mail. You can also request that we erase any personal data we hold about you by using the Midwest Site’s contact form. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

If you do not contact us to make an election or enter your preferences online, we may send you offers for products or services from Midwest, our affiliates, advertisers, sponsors, and promotional partners, as well as offers of third-party goods and services by mail, e-mail, and telephone.

 

Children’s Personal Information

The Midwest Site is exclusively for the private non-commercial use of individuals who are at least thirteen (13) years of age or older. The Midwest Site, consistent with the requirements of the Children’s Online Privacy Protection Act, does not knowingly collect, use, or disclose personal information (including online contact information) of children under thirteen (13) years of age.  In the event that a child under thirteen (13) years of age attempts to create an Account on the Midwest Site, we will not accept that child’s registration data, and we will delete information received from that child. In the event that a child posts personal information in a Public Forum, we will attempt to delete that information once we become aware of it.

 

Security of Personal Information

Your privacy and the security of your information is very important to us. Midwest employs reasonable security measures consistent with standard industry practice for information collected through the Midwest Site.  Midwest believes that it has adequate security measures, including managerial procedures, in place to help protect against the alteration, misuse, unauthorized access to, or loss of the information that it collects through the Midwest Site.

When you transmit your Personal Information over an unsecured internet connection, Midwest is not responsible for the security of your Personal Information during the transmission stage.  We cannot assume that responsibility because your e-mail, Account creation, or other Personal Information could be copied and/or intercepted by unknown third parties during transmission. You therefore understand, acknowledge, and agree that when transmitting certain Personal Information to the Midwest Site, you do so at your own risk. To the maximum extent permissible under applicable law, Midwest assumes no responsibility, and expressly disclaims all liability, with respect to the loss or disclosure of your Personal Information due to causes outside of its direct control, including, without limitation, general Internet or transmittal failures and the actions of third-parties, such as hackers. TO THE MAXIMUM EXTENT PERMISSIBLE UNDER APPLICABLE LAW, YOU EXPRESSLY RELEASE AND HOLD HARMLESS MIDWEST AND ITS RESPECTIVE SHAREHOLDERS, SUBSIDIARIES, AFFILIATES, DIRECTORS, OFFICERS, TRUSTEES, EMPLOYEES, VOLUNTEERS AND AGENTS (COLLECTIVELY, THE “RELEASEES”) FROM ANY AND ALL LIABILITY FOR ANY INJURIES, LOSSES, OR DAMAGES OF ANY KIND ARISING FROM OR IN CONNECTION WITH THE USE AND/OR DISCLOSURE OF YOUR PERSONAL INFORMATION.

 

Data Retention

We retain the information we collect for as long as necessary to fulfill the purposes set forth in this Privacy Policy or as long as we are legally required or permitted to do so. Information may persist in copies made for backup and business continuity purposes for additional time.

 

Third-Party Site Links

The Midwest Site contains and provides links to websites which are owned and operated by third parties.  You understand, acknowledge, and agree that these links are provided solely as a convenience to you and not as an endorsement by Midwest or the Midwest Site of the content, advertising, or business practices (including, without limitation, the privacy policies) of such third-party websites regardless of whether any Midwest-affiliated logo or sponsorship identification is on the third-party website.  If you decide to access and use linked third-party websites, you understand, acknowledge, and agree that you do so at your own risk.

Embedded Content from Other Websites

Articles on the Midwest Site may include embedded content (e.g., videos, images, articles, etc.). from another website. Such content behaves in the same way as if the visitor had visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including, without limitation, tracking your interaction with the embedded content if you have an account and are logged in to that website.

 

Changes to this Privacy Policy

We will continue to evaluate this Privacy Policy as we update and expand our Services, and we may , at our sole discretion, revise this Privacy Policy from time to time accordingly. We will post any changes here and revise the date last updated above. We encourage you to check this page periodically for updates to stay informed on how we collect, use, and share your information. If we make material changes to this Privacy Policy, we will provide you with notice as required by law. Your continued use of the Midwest Website following any such change or amendment to this Privacy Policy constitutes your agreement to be bound by the revised Privacy Policy. If you do not agree to the revised Privacy Policy, do not use the Midwest Site. In the event that you do not agree to the revised Privacy Policy, we will only use your Personal Information in accordance with the terms of the Privacy Policy under which your Personal Information was collected.

 

Sale or Merger

If the Midwest Site is sold to, or merges with, another company not owned by Midwest, we reserve the right to disclose and transfer any and all Personal Information collected by the Midwest Site to the buyer or surviving company.  If such an event occurs, Midwest will seek to obligate the buyer or surviving company to use any Personal Information transferred by the Midwest Site in a manner consistent with this Privacy Policy, but Midwest cannot guarantee that it will be able to impose that requirement or that the buyer or surviving company will comply, and in no event will Midwest be responsible or liable for any such non-compliance.

 

Jurisdictional Matters; International Users

The Midwest Site is governed by and operated in accordance with the laws of the United States of America.  It is intended for use only by persons located in the U.S. Midwest makes no representations that the Midwest Site is governed by or operated in accordance with the laws of any other nations.  By using the Midwest Site and submitting any Personal Information, persons accessing the site from outside the U.S.: (1) understand, acknowledge, and agree that all aspects of your use of the Midwest Site are subject to U.S. law; (2) consent to the transfer of Personal Information to the U.S. for processing, storage, maintenance, and use in accordance with this Privacy Policy; and (3) waive any claims that may arise under their own national laws.

 

Contacting Midwest

If you have any questions regarding this Privacy Policy, please use the Midwest Site’s contact form.

This Privacy Policy was last updated on September 15, 2022.