CUMULUS MEDIA, INC
UPDATED AS OF MAY 1, 2015
Cumulus Media Inc. (“Cumulus,” “we,” “us,” or “our”) is dedicated to preserving your confidence and trust as it relates to the privacy of your information.
Please read this policy so you understand how we collect, safeguard, use and share the information you provide to us through our technology platforms,
including, without limitation, our websites, web pages, interactive features, applications, Twitter and Facebook pages, and Mobile Application
(collectively the “Cumulus Platform”).
Your personal privacy is a principal concern to us at Cumulus. Our goal in outlining our policy on the collection and use of your information is to ensure
the highest level of confidentiality and security. When you provide your personal information on any Cumulus Platform, we will not give or sell your
personal information to any outside company for its use in marketing or solicitation without your permission, which may be express or implied. We will
maintain the confidentiality of your personal information and it will be used only to support your customer relationship with our company and to assist us
in providing better and more targeted services to you. Additionally, internal practices are in place to help protect your privacy by limiting employee
access to and use of customer information. When we ask you to provide personal information through the Cumulus Platform, it is done with the goal of
improving the relationship between you and Cumulus. At Cumulus, we allow you to maintain control over your personal information while attempting to provide
a more interactive experience. Our intention is to send communications only those of you who have chosen to receive such communications. At any time, you
have the right to decline receiving future communications from Cumulus in any manner, including email, text, social media, fax, telephone and postal mail.
INFORMATION COLLECTED THROUGH THE CUMULUS PLATFORMS
When you utilize any Cumulus Platform, you do so anonymously. Personal information that could be used to identify you as an individual is not automatically
collected. However, there are several ways in which information about you may be collected through the Cumulus Platform.
- Voluntary Disclosure: Some Cumulus Platforms may request that you voluntarily provide personal information for purposes such as correspondence, site
registration, membership, making a purchase, or participating in contests or online surveys. Information that we may ask you to provide may include
your name, e‐ mail address, telephone number, mailing address, birth date, and payment information (such as account or credit card number). We
may also request that you provide your preference information, social security numbers, lifestyle interests, and other demographic information that may
be needed to register or subscribe you to services or offers.
- Device Identifier: Each time the Cumulus Platform is accessed, we or our service providers automatically collect your IP address or other unique
identifier for the device (computer, mobile phone, tablet or other device) you use to access the Platforms (“Device Identifier”). Cumulus uses Device
Identifiers to analyze trends, administer the site, track movements on the site, help identify you and your shopping cart, and gather broad demographic
information for aggregate use. Device Identifiers are not linked to any other personally identifiable information by Cumulus.
- Usage Information: Whenever you access or interact with the Cumulus Platform, we, as well as any third‐party advertisers and/or service
providers, may use a variety of technologies that automatically or passively collect information about how the Cumulus Platform is accessed and used
(“Usage Information”). Usage Information may include device type, operating system, browser type, application version, the page accessed, the date and
time, your use of features or applications, your preceding page views, and your interactions with friends and group activities. This information helps
us maintain a platform that is up‐to‐date and to devise content that is responsive to your interests.
- Cookies, Mobile Analytics, and Pixel Tags: Like many other commercial technology platforms, the Cumulus Platform may use standard technologies such as
cookies, mobile analytics software and pixel tags to collect Usage Information and Device Identifiers. Cookies are small text files on your system used
for keeping track of settings or data for a particular website and can be used to store information necessary to provide a service or access into a
site, including associating you with social networking sites like Facebook and Twitter and enable interactions between your activities on the Cumulus
Platform and your activities on such social networking sites. We, or our vendors and third party partners, may place cookies or similar files on your
Device for security purposes, to facilitate site navigation and to personalize your experience while visiting the Cumulus Platform, such as allowing us
to select the ads or offers that are most likely to appeal to you based on your interests, preferences, location, or demographic information), as well
as for market research related purposes. Any information that we may store in cookies is used for internal purposes only. You may turn cookies off
through your browser or set your browser to notify you before accepting them. You can learn more about cookies by visiting www.allaboutcookies.org
which includes additional useful information on cookies and how to block cookies using different types of browser.
Your browser’s help menu or other instructions related to your browser will show you how to reduce the number of cookies you receive from us or delete
cookies that have already been installed in your browser’s cookie folder. If you elect to disable or opt out of receiving cookies, please understand that
some features and services on the Cumulus Platform may not work properly because we may not be able to recognize and associate you with your Cumulus
account(s). Also, the offers we make available to you when you visit the Cumulus Platform us may not be as relevant to you or tailored to your interests.
Pixel Tags are transparent graphic images, sometimes called web beacons or tracking beacons, that are placed on a web page or in an email to indicate that
the page or email has been viewed. A pixel tag also may tell your browser to get content from another server.
HOW WE USE AND DISCLOSE THE INFORMATION WE COLLECT
We collect only information that is needed, and we tell you how we use it. We limit the collection of information about you to what we need to know to
manage your membership; provide customer service, including responding to your questions and communicating with you about your account and activities on
the Cumulus Platform; make access to certain areas and features of the Cumulus Platform available to you; verify your identity; offer new products and
services; notify you of changes to Cumulus policies; perform market research, analytics and operations; tailor content, advertisements, and offers we make
available to you; improve the Cumulus Platform; fulfill any legal and regulatory requirements; and for purposes disclosed at the time you provide your
Personal Information or otherwise with your consent. Under certain circumstances we may share location data with our third party partners for market
research and other data analytics related purposes. We tell you about the general uses of information we collect about you, and we will provide additional
explanation if requested. You may change, update or add additional information about yourself at any time through the Cumulus Platforms that offer this
feature. If a Cumulus Platform does not currently provide this ability, you can still change your data profile by contacting your local radio station. All
Cumulus Platforms will provide this feature in the near future.
As a result of providing your personal information to us, the Cumulus Platform can provide a more customized experience, making your interaction with us
more productive, helpful and fun, and will enhance the services and
offers that we can bring to you. If you provide us with your e‐mail address or cell phone number, or have done so in the past, we may send you
e‐mail or text offers or newsletters. These offers or newsletters are based on information you provided in your membership application, registration
forms, surveys, or from information that may indicate purchasing preferences and lifestyle, as well as information available from external sources, such as
census bureau data. These e‐mail/text offers will come from Cumulus only. Your information, email address or cell phone number is never sold to a
third party. All offers are carefully developed to guarantee that they meet our standards. Our goal is to target offers that you will find to be of value
to you. At any time, you may request to discontinue receiving these communications from us by simply replying to the e‐mail address or text number
included in every e‐mail/text message that you receive from us.
From time to time, we may offer contests or other promotions on the Cumulus Platform. If you enter a contest or sweepstakes, or participate in a
promotional event, we will ask you to provide information about yourself (such as your name, address, and email address). Among other things, we will need
this information to contact you if you win, and we may also use this information for marketing purposes. We may share this information with any sponsors
and prize providers of the contest, sweepstakes, or promotional event; sponsors and prize providers will be identified in the official rules. We may also
share this information with or other third‐party service providers that help administer our contests, sweepstakes, and promotional events, such as by
conducting drawings, and/or delivering prizes to winners. If you do not want to provide the requested information or have the information provided to
sponsors, prize providers, or other third‐party service providers, please do not enter the contest, sweepstakes, or participate in the promotional
We monitor URL click‐throughs found in our electronic communications. The click‐through rate is reviewed in order to track (i) participation in
contests and sweepstakes to judge effectiveness and award prizes; (ii) your interests and preferences; and/or (iii) response rates for marketing purposes
or to report to a client in aggregate form only, the response of listeners. Individual activity is never shared with employees or third parties.
At times, our clients might collect Personal Information about you on the Cumulus Platform or on‐site at a retail locations or other Cumulus events.
The collection of this information is clearly marked as information being collected by or for a third party, and providing such information is strictly
voluntary. We may help facilitate the collection of the information by providing forms and collection boxes for the client. Sometimes this information is
shared with us Cumulus, though we will only market to you if you have given us permission. Information gathered in this manner is shared with our client
partners; and other information you may have previously provided to us remains private.
We may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our partners) such as service providers
that host or operate the Cumulus Platform, analyze data, process transactions and payments, fulfill orders or provide customer service; advertisers;
sponsors or other third parties that participate in or administer our promotions, surveys or provide marketing or promotional assistance and our partners
in co‐branded sites and promotions. Your Personal Information may also be used by us or shared with our subsidiaries, affiliates, sponsors, partners,
advertisers or other third parties in connection with marketing, promotional, and other offers, as well as product information, and for such third party’s
analytics and market research. The Cumulus Platform may include Nielsen’s proprietary measurement software which may allow you to contribute to market
research. For more information, visit: http://www.nielsen.com/digitalprivacy.
We may share your Personal Information with other entities and our affiliates primarily for business and operational purposes. In the event that we are
involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.
Additionally, we may transfer and disclose your information to third parties to comply with a legal obligation; when we believe in good faith that the law
issues; to respond to an emergency; or otherwise to protect our rights or property or security of third parties, visitors to the Cumulus Platform or the
Third‐party platforms and services accessible through the Cumulus Platform have separate privacy and information collection practices, independent of
us. Cumulus has no responsibility or liability for these independent policies or actions. You are solely responsible for maintaining your Personal
Information, the secrecy of your passwords, membership ID, or any account information. Please be careful and responsible whenever you are online. If you
post Personal Information online that is accessible to the public, you may receive unsolicited messages from other parties in return. While we aim to
protect your personal information, Cumulus cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
While we put forth our best efforts in adhering to these minimum privacy standards, additional restrictions may be imposed to comply with state and local
laws, and/or station‐specific programs, products and services.
INFORMATION WE RECEIVE FROM THIRD PARTIES
We may receive information about you from third parties. For example, if you are on another website and you opt‐ in to receive information from
Cumulus, that website will submit to us your email address and other information about you so that we may contact you as requested. You may also choose to
participate in a third party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on a third
party website) through which you allow us to collect (or the third party to share) information about you, including Usage Information, Device Identifiers,
and Personal Information such as lists of your friends, “likes”, comments you have shared, groups and location. Services like Facebook Connect give you the
option to post information about your activities on the Cumulus Platform to your profile page to share with others within your network. In addition, we may
receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or
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. We may also receive information about you from third party data providers. We may supplement the information we
collect about you through the Cumulus Platform with such information from third parties in order to enhance our ability to serve you, to tailor our content
to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you.
Access to your Personal Information is limited to those who specifically need it to conduct their business responsibilities. We use security techniques
designed to protect your Personal Information-especially information that is used by employees and business partners to provide services to you. In
addition to providing you with the opportunity to refuse marketing offers, we release information only with your consent or at your requests, or when
required to do so by law or other regulatory authority. When a court order or subpoena requires us to release information, we notify you directly so that
you legal rights can be exercised, if appropriate. The only exceptions to this policy are when we are prohibited by court order or law from notifying you,
or cases in which fraud and/or criminal activity is suspected. Finally, each Cumulus employee is personally responsible for maintaining listener and
customer confidentiality. All Cumulus employees are required to sign an agreement that they will comply with these policies. Employees who violate these
policies are subject to disciplinary action, up to and including termination of employment. Employees are expected to report violations-and may do so
confidentially-to their managers or other supervisors. Each radio station has an employee who has been assigned the responsibility for assuring the
While we take information security seriously, please understand that no electronic data transmission or storage of information can be guaranteed to be 100%
secure. Therefore, we cannot ensure or warrant the security of any information you transmit to us or that you use the Cumulus Platform. You are providing
your information to us at your own risk.
YOUR PRIVACY RIGHTS, CHOICE AND ACCESS
You may always direct us not to share your Personal Information with third parties (other than our service providers), not to use your Personal Information
to provide you with information or offers, or not to send you newsletters, emails or other communications by: (i) modifying your registered user
information on the Cumulus Platform; (ii) sending us an email at [email protected]; (iii) contacting us by mail at Cumulus Digital Department, 3280
Peachtree Road, Suite 2300, Atlanta, GA 30305; Attn: Customer Service; or (iv) following the removal instructions in the communication that you receive.
Your opt‐out request will be processed within 30 days of the date on which we receive it.
If you wish to modify, verify, correct, or delete any of your Personal Information collected through the Cumulus Platform, you may edit your registered
user information or contact us at the above address or email. In accordance with our routine record keeping, we may delete certain records that contain
Personal Information you have submitted through the Cumulus Platform. 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. It may not always possible to completely remove or
delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information
(including geo‐location data) for as long as your account is active or as needed to provide you services. If you wish to cancel your account or
request that we no longer use your information to provide you services contact us at [email protected] We will retain and use your information as
necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not control certain privacy settings and preferences
maintained by our social media partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting
the settings page of the appropriate social media site.
ADVERTISING/BEHAVIORAL TARGETING; HOW TO OPT‐OUT
We may use third party ad network providers to help present ads on the Cumulus Platform, as well as other service providers to evaluate and provide us with
information about the use of the Cumulus Platform and viewing of our content. Such providers may place and access cookies, pixel tags, or similar
technologies on your Device to serve you ads or other content personalized to your interests which they infer from your browsing on the Cumulus Platform
and other sites you have visited. In doing so, the provider collects or has access to non‐Personal Information such as your Usage Information. The
If you do not want to receive the benefits of targeted advertising, you may opt out of some network advertising programs that use your information by
visiting the NAI Opt‐Out Page. Please note that even if you choose to remove your information (opt out), you will still see advertisements while
you’re browsing online. However the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs
allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the
types of targeted advertisements you may receive. The NAI Opt‐Out Page provides a tool that identifies its member companies that have cookies on your
browser and provides a mechanism to opt out of receiving cookies from those companies. Please note that if you opt‐out of targeted advertising, we
may still track your visits to the Cumulus Platform for our own analytics, operations and security purposes.
PROTECTING THE PRIVACY OF CHILDREN
Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone
numbers) over the Internet, to us or to anyone else. The Cumulus Platform is not directed at children under the age of 13 and we will not knowingly allow
anyone under 13 to
provide us any Personal Information. If you are under the age of 13, please do not provide any information about yourself to any Cumulus Platform.
CONSENT TO PROCESSING AND TRANSFER OF INFORMATION
The Cumulus Platform is 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. Cumulus makes no representation that the Cumulus Platform is governed by or operated in accordance with the laws of any other nation.
Given that we are an international business, our use of your information necessarily involves the transmission of data on an international basis. If you
are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and
processed in the United States. By using the Cumulus Platform, or providing us with any information, you (a) acknowledge that the Cumulus Platform is
subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United
States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside
and/or are a citizen, and (c) waive any claims that may arise under those laws.
CHANGES TO THIS PRIVACY STATEMENT
the Cumulus Platform and update the reference to the effective date to reflect the date of the amendment. By visiting the Cumulus Platform, you agree that
please contact us at:
Cumulus Digital Department
3280 Peachtree Road
Atlanta, GA 30305
Attn: Customer Service
E‐Mail: [email protected]